Update;
At pretrial conference the judge allowed my request for production of docs which I send to plaintiff and also filed with the court to have it on record. Plaintiff had 30 days to reply yet absolutely no response.
The trial is set for April 11 and by looking closely at the summons and complaint I found several legalities to fight plaintiff such as; no written instrument, hearsay affidavit, and combined affidavit and motion for default judgment on an account stated with a claim that account stated is attached. There are NO attachments what so ever.
In looking at the Michigan rules of civil procedures and evidence I have to file either an objection to plaintiffs motion to default judgment, or motion to dismiss plaintiffs summons and complaint, or motion to compel (which I think is wasting the courts times).
Just don’t know how to properly prepare a motion? Does it have to have a memorandum, brief in support, and my own affidavit?
Plaintiff is not coming forth with anything to even make there claim stick and I have already prepared a motion to strike plaintiffs affidavit of indebtedness (in doing so I prevent a prima face case).
Further, the judge in his pretrial order indicated to plaintiff that if to collect a debt plaintiff has to attaché any agreement showing my signature and a copy of all assignments making a chain of interest from OC to present plaintiff. Failure to do so may cause a dismissal with prejudice.
Any inside would be appreciated

