Should I serve the plaintiff first, and then file with the POS?
You cannot serve the plaintiff, because you're a party to the action. However, the third party that serves the plaintiff for you would do the service before filing the POS. A proof of service cannot be filed until the party is served.
A general denial without the answer is adequate for the court, a proper enough response to the form?
My purpose for the question, is because I can raise those requests for evidence if and when it goes to discovery or trial. Is that right ?
Yes. Hearsay is a trial objection - evidence is not attached to a Complaint, so technically everything in the Complaint is hearsay. That's OK. The plaintiff has the burden of proof
. If they do not provide discovery after you request it, you can object. You can also move for dismissal if they never produce evidence at trial.
Should I include the general "new matters" wording in to reserve my rights?
Again, a person can't preserve a right to raise a new defense later. Defenses have to be raised in the Answer.
My defense is lack of evidence, and "new matters" - is it necessary to reserve my right to file for bankruptcy?
No. A court case is about liability. It has nothing to do with whether a person intends to file for bankruptcy.
If a judgment is decided against me, can I then file for bankruptcy, and what tis the time frame to do so?
Yes. There isn't a set time frame - any person who has outstanding debts that exceed his ability to pay can file for bankruptcy. However, they're allowed to start trying to collect immediately, so many people will file as soon as possible. If you have more detailed questions about bankruptcy, I'm afraid that the terms and conditions of this site require that I ask you to open a new question in that category.