Here are the basic steps. Check your Court Rules to see if there are any variations.
1. Answer the Summons. The Answer should contain as many of the following are as applicable:
A. Denials of the allegations in the Complaint and a demand for strict proof thereof.
B. General Defenses (defenses that the Plaintiff should be aware of, like offsets)
C. Affirmative Defenses - things the Plaintiff may not be aware of, such as asserting the Statute of limitations
D. Counterclaims - against the Plaintiff, not the Attorney. FDCPA violations by the attorney are dealth with through a lawsuit against the attorney him/herself.
E. Statement that Defendant requests adequate time to proper Discovery.
2. Discovery - DB has threads in the Sample Pleadings section and has helps throughout. Check your Court Rules, there may be limits on the number of Discovery items. The purpose of Discovery is twofold: First, to see the case of the Plaintiff, and second to narrow the issues by seeing what both sides can agree to as far as facts are concerned. This "agreement" is called "Stipulating". When both sides agree to ma fact, they will Stipulate it, as in "Plaintiff and Defendant both stipulate that the Earth is round and orbits the sun". This is probably all you should stipulate. In Discovery you will do any or all of the following:
A. Propose Admissions - statements that you are asking the other side to Stipulate. A commons Admission request from a creditor will read "Admit that you owe the amount claimed in the Complaint and that all your defenses are imaginary." Obviously, you Admit only the most obvious things - things no rational person can deny.
B. Interrogatories: These are questions you ask in order to get specific facts. In the Interrogatories section it is typical to include a statement like "In the event Respondent's response is based on reference to any Document, that reference will constitute a Demand for production of a true and complete copy of that document." Word your Interrogatories carefully. A common response to interrogatories is "Objection. Question is vague" or "Objection. Respondent claims the response is privileged." When they object to the Interrogatory, it provides you an opportunity to petition the Court to rule on the legality of the question, which they will have to pay their attorney to oppose.
C. Demands for Production of Documents: Unlike Interrogatories, you make these as expansive as possible. An example would be "Produce a true, correct and complete copy of all Collector's notes regarding the account named in the Complaint, from the date of the inception of the alleged account to the date of the filing of the Summons and Complaint, on whatever medium they may exist, transcribed onto paper. This includes e-mails, internal memoranda, ledger card notes and any comments of any nature whatsoever regarding the collection process, thoughts, strategies, policies, procedures of any nature whatsoever."
3. Motions: After Discovery has been served you may need to file any or all of the following Motions with the Court and the other side. When you file the Motion with the Court, do so in at least three copies and include an Order of the Court that would execute the Motion with the Motion. This is not an expansive list. In fact, it is probably closer to the bare minimum.
A. Motion and Order to Compel - this wold be used when the other side ignores your Discovery demands, which is common. It orders them, by the Court, to respond.
B. Motion and Order to Preclude: This would be used when they ignore the Order to Compel. It serves as a Judicial Order to exclude from trial any and all evidence, documents, testimony or other things that could have or should have been revealed in Discovery. Basically, it throws their entire case into the garbage can.
C. Motion for Summary Judgment - used when there are no issues of Law or Fact at issue and a Judgment is yours as a right of law.
Obviously, should the other side file any Motions, you will promptly file an Opposition to their Motion detailing the reasons their Motion should be denied.
This, while not complete, gives a good idea of what you can expect before trial. My experience is that unless you are being sued for a huge debt, the other side will usually throw in the towel when presented with this onslaught.