You have 14-30 days from service before the plaintiff can move for default judgment. The first 48 hours matter most: confirm the deadline, send a validation letter if you are still within the FDCPA window, and start the answer.
Read the complaint
Know what you are facing before responding. Note the plaintiff name (often a debt buyer like Midland, Portfolio Recovery, LVNV, Cavalry, Resurgent), the alleged amount, the date of last activity, and any exhibits attached. The plaintiff's name and the original creditor are usually different — that gap is leverage.
Calendar your answer deadline — TODAY
Most jurisdictions give 14-30 days from the date of service. Personal service runs from the day you were handed the papers. Substitute service or mail extends or modifies the clock. Miss it and the plaintiff gets a default judgment that lets them garnish wages, levy bank accounts, or place liens.
Verify the debt is yours and the SOL has not run
When was your last payment or written acknowledgment? Compare against your state's statute of limitations on written contracts and open accounts (typically 3-6 years). If the SOL has run, that is an affirmative defense — but you HAVE to raise it in the answer or you waive it.
Check standing
Most plaintiffs are debt buyers. Did the complaint plead each assignment from the original creditor down to the current plaintiff? Are bills of sale, account-level data, or business-records affidavits attached? Missing chain of title = standing problem = strong motion to dismiss.
File your Answer
A state-formatted answer that: (a) denies every allegation you can in good faith, (b) raises affirmative defenses (SOL, lack of standing, failure to state a claim, statute of frauds, payment, accord and satisfaction), and (c) optionally asserts an FDCPA counterclaim if the collector violated § 1692. File in the SAME court as the complaint and serve plaintiff's counsel.
Send a discovery bundle
Force the plaintiff to PROVE its case before MSJ or trial. Interrogatories, requests for production (chain-of-title documents, business records, payment history), and requests for admission. RFAs unanswered within 30 days are deemed admitted — that alone can win the case.
Watch the calendar through trial
Discovery cutoff, motion deadlines, summary-judgment window, pretrial conference, trial date. Each carries its own consequences for missing. Subscribe to the deadline reminder cron with the email reminder option in dashboard settings.
Ask Counsel anything along the way
Free Q&A. Counsel pulls jurisdiction-specific rules and citations via tools, never paraphrasing from memory. Best for: state-specific service rules, affirmative defense framing, opposing-counsel pattern recognition, and counterclaim strategy.
SynthCounsel is a document preparation tool, not a law firm. No attorney-client relationship is created.