How to file motion to dismiss in NC?

1. You may want to ask the court clerk if they have a standard form for a MTD. If not, a search online for "NC Motion to Dismiss" should come up with some samples as well as actually filed MTD.
2. Absolutely. Add every reason you possibly can. The more the better.
3. I am not sure what you mean in question 3. You want to model the MTD with a caption just like the Summons/Complaint and your Answer.

Thanks!

I suppose I was asking is there anything more than the reasons, etc that I should mention. Any other legal "jargon" so to speak?

Also, should I include the copy of a credit report showing that April 2006 was the last time a payment was made as well as articles citing the closing of Mann Bracken?

I've reached out to lawyers to have them file the motion for me to make sure I don't miss anything since I sincerely do not want a judgment against me, but no one has responded. So, since I'm doing this on my own I want to make sure I do everything correctly.

Try your county court website. WATCH Arrow Financial, they are notorious for violating the FDCPA!

It is better to include MORE evidence than needed rather than too little. Make sure you mark each document you are using as evidence as "EXHIBIT A", "EXHIBIT B", etc. and then when you are speaking about it in the Motion, make reference that you are attaching it as "EXHIBIT A", etc. and you wish it to be " attached hereto and incorporated as if fully stated herein."

Thanks so very much for all the help!! I've been harassed by Arrow Financial with phone calls as well as Mann Bracken. I NEVER answered the phone and they never left voicemails but when I googled the numbers calling multiple times daily, it just so happened to be them. I'm thankful Mann Bracken is no longer in business (for the moment I guess anyway) as they are HORRIBLE. What respectable law firm submits a discovery to a defendant listing the wrong plaintiff?? Of course, attached with a letter asking that I call to settle. But, I digress. Now is the time to file the motion. I have only 20 days left to do it and I'm feeling the pressure... Even though Mann Bracken's offices have closed (even their NC number has been disconnected), I just am paranoid someone else will miracuously show up. ANYWAY...here is what I've drafted for the body of the Motion. Thoughts?
[FONT=Times New Roman][SIZE=3][/SIZE][/FONT]
NOW COMES the Defendant and moves this Court for an order of dismissal with prejudice in the above titled suit. In support thereof, the Defendant alleges the following:

• The defendant asserts that the time allowed for the filing of this cause of action has expired under ? 1‑52.1 North Carolina Statutes. The defendant further states that the last payment on the account was made April 2006, thereby exceeding the three year statute from the date the Summons was filed which was June 2009. See Exhibit “A” and Exhibit "B"
  
• The defendant further asserts that Mann Bracken, the law firm representing Arrow Financial, now ceases to exist. See Exhibit “C”
  
• In support of this Motion, the Defendant submits the following exhibits: