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Are the "common counts" in a summons the "allegations" that need to be responded to on the answer contract?

North Hollywood, CA |

We received a summons for a credit card debt in Calif. We would like to complete the Answer Contract but need to know what area the allegations are that we need to respond to? We believe they are the "common counts". Does anyone know if that is correct? These forms are difficult to understand and I know the importance of completing them correctly. Appreciate any help you can provide.

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Attorney answers 4


To not "re-invent the wheel" you might just run a Google search for "California common counts". You will get several hits that explains them in detail. Normally an acceptable answer is just a "general denial" where you simply deny everything. The burden of proving your debt is theirs. Good luck with it.


I noticed that you are near my office in Burbank, California.

I agree with my colleague. I would recommend hiring an attorney to assist you with responding to this lawsuit.

However, you may want to consider resolving the debt rather than fighting it head on. There are bankruptcy options that may be available for you. Realistically, the cost of resolving the debt through non-bankruptcy means becomes more costly and difficult now that the creditor has decided to spend the time and money by filing a lawsuit.

If you want, you are more than welcome to schedule a free consultation where we could discuss these matters.

Good luck to you!

Jonathan Panossian, Esq.

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Please visit my web site, which I have linked below, for you to the correct page, so you may find a specific example (in PDF format) of what is the summons and what are sample debt collection complaints.

The summons is one page, half in English and half in Spanish, about your need to respond within 30 days. The complaint has the particular allegations against you, which your attorney would then need to deny those that are false, admit those that are true, and neither admit nor deny if you do not know in an answer to complaint. i do not recommend a person try to handle this themselves, as a judgment against you for the full balance is a likely result.