[Kevin]

As far as the response goes, is Alabama a state which recognizes simple pleading? A lot of judges never even read the pleadings until something gets called to their attention (e.g., a Defendant didn't plead a certain defense). Aside from that, (and this may not be the case in AL) all you have to do is admit or deny what's in the Petition.

This is more of a detailed press release than an Answer.