What the plaintiff must show
The plaintiff must establish that the account existed, that the balance is what they claim, and — if they bought the debt — that it was validly assigned to them through each link in the chain. New York has heightened requirements for consumer credit actions, including specific affidavits and documentation before a default judgment can be entered. Boilerplate affidavits from a records custodian who never saw the account are regularly rejected.
Timeliness
Consumer credit claims are subject to a limitations period, and New York has shortened it for consumer debt. Payments or acknowledgments do not revive a time-barred debt the way many collectors assume. If the last activity on the account predates the limitations window, plead the defense — it is waived if you leave it out of the answer.
Service problems
High-volume filings often produce sloppy service: papers left at former addresses, affidavits describing deliveries that never happened, or service on the wrong person entirely. If a default judgment appeared without warning — usually discovered through a frozen bank account — that is a strong sign to examine the affidavit of service closely.
Practical outcomes
Defended collection cases often settle for a fraction of the claimed balance, or are discontinued when the plaintiff cannot produce documents. Exempt income — Social Security, disability, veterans' benefits, certain wages — is protected from restraint, and a wrongly frozen account can usually be released. Do not agree to a payment plan you cannot sustain; a broken stipulation can convert into a judgment for the full amount.