Summons Dismissal Machine · JOSH.PLAY

JUSTLEGAL // PROCEDURAL 12(b) DEFENSE DISMISSAL ENGINE

JURISDICTION: STATE OF COLORADODEFENSES ACTIVE: 2

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Legal Pleading Output (C.R.C.P. Compliant)

DISTRICT COURT, CITY AND COUNTY OF DENVER, COLORADO
CIVIL ACTION NO. 2026-CV-08941 // DIVISION 4

MIDLAND ASSET RECOVERY LLC,
  Plaintiff,
v.
DEFENDANT PRO SE,
  Defendant.
____________________________________________________

SPECIAL APPEARANCE AND MOTION TO DISMISS
PURSUANT TO C.R.C.P. 12(b)

Defendant, appearing specially and without submitting to general personal
jurisdiction, respectfully moves this Court to dismiss Plaintiff's Complaint
with prejudice based upon the following mandatory statutory bars:

1. LACK OF ARTICLE III STANDING [FRCP 12(b)(1)]:
   Debt buyer failed to produce authenticated forward-flow assignment agreement or bill of sale linking debt to defendant. (U.S. Const. art. III § 2).

2. FAILURE TO STATE A CLAIM [FRCP 12(b)(6)]:
   Complaint pleads speculative, boilerplate conclusions lacking particularized factual assertions of an express contract. (Twombly / Iqbal Standard).

WHEREFORE, Defendant prays that the Complaint be DISMISSED WITH PREJUDICE,
that Plaintiff take nothing, and that Defendant be awarded statutory costs.

Respectfully submitted,
/s/ Joshua M. Abrams, Pro Se Defender
Deterministic Filing Timestamp: 2026-09-22T05:51:50.275Z

Initializing System Sandbox…

DISTRICT COURT, CITY AND COUNTY OF DENVER, COLORADO CIVIL ACTION NO. 2026-CV-08941 // DIVISION 4 MIDLAND ASSET RECOVERY LLC, Plaintiff, v. DEFENDANT PRO SE, Defendant. ____________________________________________________ SPECIAL APPEARANCE AND MOTION TO DISMISS PURSUANT TO C.R.C.P. 12(b) Defendant, appearing specially and without submitting to general personal jurisdiction, respectfully moves this Court to dismiss Plaintiff's Complaint with prejudice based upon the following mandatory statutory bars: 1. LACK OF ARTICLE III STANDING [FRCP 12(b)(1)]: Debt buyer failed to produce authenticated forward-flow assignment agreement or bill of sale linking debt to defendant. (U.S. Const. art. III § 2). 2. FAILURE TO STATE A CLAIM [FRCP 12(b)(6)]: Complaint pleads speculative, boilerplate conclusions lacking particularized factual assertions of an express contract. (Twombly / Iqbal Standard). WHEREFORE, Defendant prays that the Complaint be DISMISSED WITH PREJUDICE, that Plaintiff take nothing, and that Defendant be awarded statutory costs. Respectfully submitted, /s/ Joshua M. Abrams, Pro Se Defender Deterministic Filing Timestamp: 2026-09-22T05:51:50.275Z