Credit Card Complaint

A credit card complaint is attached to the Summons of your lawsuit. The Complaint would list numbered paragraphs with each paragraph stating a count against you and listing facts according to the plaintiff.

For example, here is my complaint from Capital One Bank. This is the exact complaint given to me by Capital One in the case that I won:



COMES NOW the Plaintiff, CAPITAL ONE BANK (USA), N.A. Fka CAPITAL ONE BANK, by counsel, and for its claim for relief against Defendant(s) [MY NAME WENT HERE].

  • Plaintiff is a national bank authorized to do business in the State of Indiana and the defendant is a resident of the county of [MY COUNTY WENT HERE].

  • The defendant opened a MasterCard charge account with plaintiff, agreeing to make monthly payments as required by the terms of the charge agreement, for purchases charged to the account.

  • The defendant did make purchases and charged the same to the account, but the Defendant failed to make the monthly payments called for on the account. There is an account stated in the amount of $[MY AMOUNT HERE] See Client Affidavit as Plaintiff’s Exhibit 1.

  • Plaintiff, declared defendant to be in default and demands payment of the balance.

WHEREFORE, the Plaintiff prays for judgment against the Defendant in the amount of $[MY AMOUNT HERE] plus costs and interest at the rate of 8% annum, pursuant to IC 24-4-6-1-101.


I would then use the Complaint that was attached to my summons and Answer my summons using each paragraph with a denial or admission and then list all of my affirmative defenses.

Consider my credit card Complaint as being pretty plain and simple. Others out there might have 20 paragraphs, 10 paragraphs or maybe even fewer. The fewer the paragraphs, the easier it is to answer the complaint.

After answering the Summons with Affirmative Defenses, I would file this with my court, send a copy off to the plaintiff by certified mail, and then keep a copy for my records.

A credit card Complaint will list the plaintiff’s reasonings set in paragraphs of all the counts and facts they have against you. It’s as simple as that.