Legal Question in Credit and Debt Law in Texas

We need some more information.

Ordinarily, you would simply file a general denial.

HOWEVER, under some circumstances it would be appropriate to object to the jurisdiction or venue, and this must be done contemporaneously with the filing of the answer.

And some types of answers (Rule 93, TRCP) have to be sworn. Here's Rule 93:

A pleading setting up any of the following matters, unless the truth of such matters appear of record,

shall be verified by affidavit.

1. That the plaintiff has not legal capacity to sue or that the defendant has not legal

capacity to be sued.

2. That the plaintiff is not entitled to recover in the capacity in which he sues, or that the

defendant is not liable in the capacity in which he is sued.

3. That there is another suit pending in this State between the same parties involving the

same claim.

4. That there is a defect of parties, plaintiff or defendant.

5. A denial of partnership as alleged in any pleading as to any party to the suit.

6. That any party alleged in any pleading to be a corporation is not incorporated as

alleged.

7. Denial of the execution by himself or by his authority of any instrument in writing,

upon which any pleading is founded, in whole or in part and charged to have been

executed by him or by his authority, and not alleged to be lost or destroyed. Where

such instrument in writing is charged to have been executed by a person then

deceased, the affidavit shall be sufficient if it states that the affiant has reason to

believe and does believe that such instrument was not executed by the decedent or

by his authority. In the absence of such a sworn plea, the instrument shall be received

in evidence as fully proved.

8. A denial of the genuineness of the indorsement or assignment of a written instrument

upon which suit is brought by an indorsee or assignee and in the absence of such a

sworn plea, the indorsement or assignment thereof shall be held as fully proved. The

denial required by this subdivision of the rule may be made upon information and

belief.

9. That a written instrument upon which a pleading is founded is without consideration,

or that the consideration of the same has failed in whole or in part.

10. A denial of an account which is the foundation of the plaintiff's action, and supported

by affidavit.

11. That a contract sued upon is usurious. Unless such plea is filed, no evidence of

usurious interest as a defense shall be received.

12. That notice and proof of loss or claim for damage has not been given as alleged.

Unless such plea is filed such notice and proof shall be presumed and no evidence

to the contrary shall be admitted. A denial of such notice or such proof shall be made

specifically and with particularity.

13. In the trial of any case appealed to the court from the Industrial Accident Board the

following, if pleaded, shall be presumed to be true as pleaded and have been done

and filed in legal time and manner, unless denied by verified pleadings:

(a) Notice of injury.

(b) Claim for Compensation.

(c) Award of the Board.

(d) Notice of intention not to abide by the award of the Board.

(e) Filing of suit to set aside the award.

(f) That the insurance company alleged to have been the carrier of the workers'

compensation insurance at the time of the alleged injury was in fact the

carrier thereof.

(g) That there was good cause for not filing claim with the Industrial Accident

Board within the one year period provided by statute.

(h) Wage rate.

A denial of any of the matters set forth in subdivisions (a) or (g) of paragraph 13 may

be made on information and belief.

Any such denial may be made in original or amended pleadings; but if in amended

pleadings the same must be filed not less than seven days before the case proceeds

to trial. In case of such denial the things so denied shall not be presumed to be true,

and if essential to the case of the party alleging them, must be proved.

14. That a party plaintiff or defendant is not doing business under an assumed name or

trade name as alleged.

15. In the trial of any case brought against an automobile insurance company by an

insured under the provisions of an insurance policy in force providing protection

against uninsured motorists, an allegation that the insured has complied with all the

terms of the policy as a condition precedent to bringing the suit shall be presumed to

be true unless denied by verified pleadings which may be upon information and

belief.

16. Any other matter required by statute to be pleaded under oath.