You cannot possibly know what to write, and no one on a web site on the Internet can tell you what to write. Attorneys go to law school for years to get the most basic clue about these subjects, and then spend many years shaprmening their skills.
The court clerk is not an attorney, and does not care what you write. However, what gets filed as your response could be crucial to the outcome of the case.
You need an attorney. If your mother's attorney feels he has a conflict of interest, you should discuss with your mother the fact that the company should hire counsel for you, since otherwise, if you try to do this yourself, you cannot possibly do it right and it might cause harm to your mother and to the company.