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v.
FULL NAME HERE, American Citizen; and
FULL NAME HERE, American Citizen,
Defendant(s).
Defendant(s), appearing Sui Juris, for their reply to the Complaint of QUICK COLLECT, INC
(hereafter known as, "QUICK COLLECT") states as follows: All Answers correspond to the
numbered paragraphs of the Complaint. All allegations of the Complaint are denied unless
expressly admitted herein.
ANSWERS
1. DENIED. In response to paragraph #1, the Defendant(s) disputes the alleged debt, as solicited
and claimed by QUICK COLLECT in paragraph #1 of the complaint. Defendant(s) are at this
time without knowledge or information sufficient to form a belief as to the truth of the alleged
claim contained therein, and on that basis generally and specifically denies the alleged claim
contained therein, and leaves the Plaintiff to provide lawful proof that binds and compels the
defendant(s) and Plaintiff QUICK COLLECT which is defined as a creature of the state as
defined by US Supreme Court Ruling Hale vs. Henkel, 201 U.S. 43 at 74 (1906).
Defendant(s) demand strict proof thereof.
DEFENSES
CASE NO. SC121604
DEFENDANT(S) ANSWER AND COUNTERCLAIM
[CERTIFICATE OF SERVICE]
Defendant(s) invokes the Doctrine of Unclean Hands as the Defendant(s) alleges that the
Plaintiff or the person or entity that assigned the alleged claim to Plaintiff acted in a dishonest or
fraudulent manner with respect to the dispute at issue in this case.
1
(a) by failing to cease collection of an alleged debt after the Defendant notified Plaintiff in
writing that the alleged debt was disputed, therefore violating 15 USC 1692g(b).
(b) Plaintiff, willfully and/or negligently reporting the Defendant(s) credit history
inaccurately to the Credit Agencies Experian and Transunion, therefore violating US
Court of Appeals, Ninth Circuit, No. 00-15946, Nelson vs. Chase Manhattan.
(c) by falsely representing the legal status of the alleged debt and therefore violating 15 USC
1692e(2)(A)
(d) by QUICK COLLECT failing to report the claim it as disputed to the credit bureaus,
therefor violating 15 USC 1692e 807(8)
(e) by falsely reporting the alleged debt to the credit agencies without providing reasonable
bona fide proof of claim, therefor violating 15 U.S.C. 1681s-2 (a)(1)(a).
(f) by QUICK COLLECT claiming to be BOTH purchaser and 'assignee' upon open contract
of alleged claim. It's can only be either one or the other, therefor it is violating the FDCP
in relationship to Gearing v. Check Brokerage Corp 233 F.3d 469 (7th Cir. 2000).
(g) By Misrepresentations by QUICK COLLECT about themselves or the alleged claim are
actionable regardless of intent, therefor it is violating the FDCP in relationship to Gearing
v. Check Brokerage Corp Cacace v. Lucas, 775 F. Supp. 502, 505 (D. Conn. 1990)
(h) By QUICK COLLECT failing to validate Defendant(s) alleged debt yet continue to
pursue collection activity via this claim, therefor in violation of 15 USC 1692g 809(b).
(i) By QUICK COLLECT having not validated the alleged debt after lawful notice of
dispute on June 14, 2012 and as of July 19, 2012 they still continue to report the alleged
debt to the credit bureaus, therefor in violation of 15 USC 1692g 809(b) and FTC
opinion letter Cass from LeFevre.
(j) By QUICK COLLECT failing to live or retain a valid business license in the County of
Deschutes, Oregon at the time this claim was made or failing to produce a valid signed
contract between defendant(s) and Plaintiff in the county which defendant(s) live at the
time of creation of the alleged debt/claim, therefor violating 15 USC 1692i 811 (a)(2)