I deny that the Plaintiff should be able to foreclose on my home for the following reasons:
I have contacted the lender directly and I currently have a Repayment Plan in place which will commence on May 18, 2012 through October 18, 2012.
I swear that the information contained in the foregoing Answer is true and correct to the best of my information and belief.
What are your thoughts?
Ovarall, pretty good. The only problem that I see is that your stated Affirmative Defense is not a recognized A.D. for your case. It is rational to you but not to the court. Suggest that you check out this list of A.D.'s and restructure this part of your answer with one of these choices, and likely Standing is going to be your best one. You have already stated that you weren't sure that they aren't the holder of the "Note", which is the same is saying they do not have Standing.
Also, # 2: In Ohio is there is not such thing as a Mtg Deed. Insert the word "Note" in its place. NOT Mtg Note, just NOTE, or "Promissory Note"
Lastly I would insert ther word "Affirm" in place of Swear; most used langugage.
Othere than above you should be as good to go.