Response to Motion for Summary Judgment

[Momto3]

Pertains to the state of Wyoming

I have filed a motion for dismissal based on the SOL (account was charged off in 2000 and suit filed in 2009) - the plaintiff has not made a response to that yet.

The plaintiff has filed a motion for summary judgment stating there is no "genuine issue".

I know that I need to respond, but I am a little confused as to how to do so. This is not an account opened by me and the plaintiff states they are unable to provide a copy of the original application. All that he provides in support of his claim that this is my debt is a bill of sale from Ctibank to one collection company (unifund Partners) and later to another (High Plains Financial). The bill of sale from Citibank to Unifund does not include my name, an account number or a social security number. This information does appear on the sale from Unifund to High Plains. Personally I thought that was odd.

I just want to make sure I word things correctly in case (for some reason) the court does not rule in my favor on the motion for dismissal.

Thanks for any assistance in advance.

[Mr. Knowitall]

If you're denying some of the allegations in the motion, deny them in your response. If you believe issues remain to be proved, argue that in your response. There's not much we can do except speak in broad terms.