- The cause of action set forth in the Complaint is barred by the applicable statute of limitations because it did not accrue within __ years next before the commencement of this action.
- Defendant entered into the contract that is the subject of the complaint in reliance upon Plaintiff's oral statements that were made by Plaintiff [or Plaintiff's predecessor] to induce Defendant to enter into the contract, and Plaintiff knew that these statements were false at the time that they were made.
- The Plaintiff lacks standing to pursue any claim and/or cause of action arising from and/or relating to the alleged "credit card account" and/or alleged "balance."
- Plaintiff has no contractual relationship with Defendant.
The above list is far from exhaustive, and is provided solely as an example of some affirmative defenses that debtor have successfully used to get complaints dismissed. Other well-known affirmative defenses include: release (the plaintiff has already released the defendant from any legal obligation; statute of frauds; and failure of the Plaintiff to follow legal prerequisites required to bring a consumer debt action.