affirmative defenses

Unclean Hands, Failure of Consideration, Waiver, Accord & Satisfaction, Setoff, Void on Account of Public Policy, Statute of Limitations ... if you put lots of those terms in someplace, even more are likely to pop out...

 

Doctrine of Laches . . .

Do a google search and see what is applicable.

 

http://consumers.creditnet.com/Discussions/p-the-script-post457736/postcount4.html includes a bunch used by experian in a law suit I researched. You can pick and choose as fit your case, but in your answer, feel free to use as broad an interpretation of each one as you feel comfortable doing. It was obvious from reading the suit I pulled these from that the defense attorneys had no problem with that.

For example:
Unclean Hands
unclean hands
n. a legal doctrine which is a defense to a complaint, which states that a party who is asking for a judgment cannot have the help of the court if he/she has done anything unethical in relation to the subject of the lawsuit. Thus, if a defendant can show the plaintiff had "unclean hands," the plaintiff's complaint will be dismissed or the plaintiff will be denied judgment. Unclean hands is a common "affirmative defense" pleaded by defendants and must be proved by the defendant.

 

Unclean hands and equitable estoppel are of particular good use against debt purchasers.