dissenting:
I disagree with the majority opinion’s analysis and the conclusion which it reaches. In my opinion, the majority, while acknowledging this court’s precedents, has failed to apply the standard we have adopted in cases involving default judgments. In doing so, it has departed from and violated our longstanding policy of preventing disputes from being prematurely ended without being resolved on the merits.
I.
In determining whether the district court abused its discretion in refusing to reopen a default judgment, we must keep in mind the operative premise: “[T]his court does not favor defaults and ... in a close case doubts should be resolved in favor of setting aside the default and reaching a decision on the merits.” Gross v. Stereo Component Sys., Inc., 700 F.2d 120, 122 (3d Cir.1983). That is why we have held that three factors must be considered in deciding whether to reopen a default judgment: first, whether the plaintiff will be prejudiced; second, whether the defendant has a meritorious defense; and third, whether culpable conduct of the defendant led to the default. Id.; Feliciano v. Reliant Tooling Co., 691 F.2d 653, 656 (3d Cir.1982); Medunic v. Lederer, 533 F.2d 891, 893-94 (3d Cir. 1976).
My analysis of the relevant factors as they apply to the circumstances of this case leads me to conclude, contrary to the majority, that the district court abused its discretion in refusing to vacate the default judgment entered against Golden. The government conceded, in its brief and at oral argument, that there would be no prejudice to its cause if the default judgment were to be set aside. The other two factors, establishment of a meritorious defense, and lack of culpable conduct, are more than satisfied by the record in this case under the liberal standards that must be applied in considering a motion to set aside a default, see, Medunic v. Lederer, supra, 533 F.2d at 894.
A.
As the majority notes, to establish a meritorious defense a defendant need only show allegations that, if established, would make out such a meritorious defense. Farnese v. Bagnasco, 687 F.2d 761, 764 (3d Cir.1982). That it is sufficient to proffer very little in the way of substance is shown by the Far-nese court’s favorable citation of Keegle v. Key West & Caribbean Trading Co., 627 F.2d 372, 374 (D.C.Cir.1980).
Keegle held that it is sufficient if the defendant’s allegations “contain ‘even a hint of a suggestion’ which, [if] proven at trial, would constitute a complete defense.” Moreover, the Keegle court found it sufficient that the defendant, who had been sued for fraud, breach of contract, and violations of securities laws,
alleged lack of subject matter jurisdiction and denied any misrepresentations, fraudulent acts, or securities law violations. Though somewhat broad and con-clusory, those allegations adequately meet the meritorious defense criterion for setting aside the default, (footnote omitted)
In direct conflict with Keegle is the case relied on by the district court, In re Stone v. Stone, 588 F.2d 1316 (10th Cir.1978). In *198Stone, allegations were held insufficient to establish a meritorious defense to a charge of false pretenses and false representations, because these allegations merely denied that the defendant committed acts constituting false pretenses and false representations. The Stone court said that the allegations were too general and contained no relevant specific facts supporting a defense. Keegle, by contrast, held sufficient allegations that essentially did no more than deny the complained-of acts. Thus, at the outset, it is evident that the district court abused its discretion when it applied the Golden facts to a standard which this court has never accepted.
It must be emphasized that it is the Kee-gle standard, not the Stone standard, that Chief Judge Seitz relied upon in writing for this court in Farnese, supra. Thus it is the Medunic-Farnese-Keegle standard that has been adopted as the standard to be applied in this circuit. Under that standard, it is simply incorrect to require, as the majority does, that Golden do more than he did in asserting the defense upon which he relies. Contrary to the majority’s statement, a defendant need not allege specific facts showing what he intended or did not intend to do with the money; nor must a defendant allege specific facts as to the source of his funds, such as whether they were inherited or earned, or whether they had just been withdrawn from his bank account. (See maj. op. at 11.) None of the cases cited by the majority, i.e., Gross v. Stereo Component Sys., Inc., 700 F.2d 120 (3d Cir.1983); Feliciano v. Reliant Tooling Co., 691 F.2d 613 (3d Cir.1982); Farnese v. Bagnasco, 687 F.2d 761 (3d Cir.1982); Tozer v. Charles A. Krause Milling Co., 189 F.2d 242 (3d Cir. 1951), holds that the defendant must allege “specific facts.”1 Indeed, Feliciano itself held it sufficient to establish a meritorious defense for the defendant (an English insurance company) to assert merely that the insurance policy on which it was sued did not cover the plaintiff’s injury; support for this argument was provided by a barrister’s opinion.
In my view, there is no principled difference between the insurance company’s denial of its liability under the policy which it issued and Golden’s denial that “the money seized was not property subject to forfeiture under the provisions of 21 U.S.C. § 881, i.e., it was neither furnished nor intended to be furnished by any person in exchange for a controlled substance.” The defendants’ liability in both cases, and especially in Golden’s case, is predicated on the existence of certain facts. If such facts do not exist, no more is required under Far-nese, Medunic, or Keegle than that the defendant seeking to vacate the default, deny their existence in order to establish his defense. Indeed, I do not know what more Golden could have said when charged with intending to exchange money for cocaine than to say “the money seized ... was neither furnished nor intended to be furnished in exchange for a controllable substance.”
The majority’s holding is particularly pernicious in this case. The gist of the offense is the defendant’s subjective intent with respect to the money: the government must prove that the money was “intended to be furnished” for use in an illegal transaction.2 The majority’s analysis requires that a defendant aver “specific facts” tending to show that he had a different intent from the one he was accused of having. Engrafting such an unnecessarily strict requirement onto our established liberal standard has the effect of dramatically altering the test announced in Tozer, Medunic, and Farnese, without the benefit of the in banc approval required for such a departure *199from precedent. Third Circuit Internal Operating Procedure 8C.
It is plain that the majority simply does not believe Golden, and is unwilling to let his credibility be tested by a trier of fact. Instead the majority applies an unsupported requirement that the defendant aver “specific facts” beyond his denial of the alleged facts. Yet all the government must do to convict Golden is prove the existence of the very facts which Golden has denied. Under the established standard of this court, announced in numerous cases, most particularly in Tozer, Medunic, and Farnese (citing Keegle), Golden has done all that is required to establish a meritorious defense.
B.
The third factor, whether culpable conduct of the defendant caused the default, also supports a holding that the judgment should have been vacated. The majority’s brisk summation of the events leading up to the default obscures the important fact that throughout the period between the date when the government filed its claim and the date of the judgment, Golden did not know whether the office of the Federal public defender would provide him with counsel. Indeed, it would seem that it was not until the very date the government filed for default that Golden and the court were finally informed to the contrary by that office.
To more fully show this, a complete chronology of events, including relevant correspondence, is warranted.
9 Nov. 82 DEA/FBI seizes $55,518.05 in Golden’s residence, arrests and jails Golden.
23 Dec. 82. U.S. files complaint alleging the $55,518.05 is subject to forfeiture under 21 U.S.C. § 881.
29 Dec. 82 U.S. gives public notice of forfeiture action, and sets deadline for filing of claims, 6 Jan. 83.
6 Jan. 83 Deadline passes, no claim filed.
21 Jan. 83 U.S., in letter to Golden’s criminal attorney Crawford, says U.S. will seek default judgment on or before 31 Jan. 83, and cautions that claims filed now must include request to extend time.
31 Jan. 83 In letter to District Court (Judge Mencer), U.S. says Golden desires to file claim but attorney Crawford is unsure whether he is permitted to handle civil case, U.S. asks court to determine whether appointment of counsel would be appropriate.
7 Feb. 83 U.S. Attorney sends copy of Jan. 31 letter to Crawford.
9 Feb. 83 Judge Mencer, in letter to U.S. Attorney, copy to Crawford, says he is unaware of any authority that he has to appoint civil counsel, asks U.S. or Crawford to advise him of any authority to contrary.
22 Feb. 83 Federal Public Defender Office in letter to Judge Mencer, copies to Crawford, U.S. Attorney, and Golden, says Office’s opinion is that court has no authority to appoint civil counsel here.
22 Feb. 83 U.S. files application with clerk for entry of default, and informs court by letter with copies to Crawford and Golden.
24 Feb. 83 Judgment of default entered by court.
On or about 4 Mar. 83 Crawford by phone informs U.S. Attorney that he would try to find civil counsel for Golden.
9 Mar. 83 Golden, via new civil attorney Gelder, files claim to currency and motion to vacate default judgment.
30 Mar. 83 Motion denied on ground that Golden failed to set forth existence of meritorious defense.
The foregoing chronology shows that Golden and his criminal counsel spent the time between the government’s filing of the claim, and its filing of the default judgment, engaged in efforts to determine whether Golden would have to obtain different counsel for the forfeiture proceeding. Both the government and the court were kept fully informed of these efforts; indeed the court in its February 9 letter virtually asked Golden’s counsel to continue his ef*200forts to determine the answer to that question.
It is evident from the correspondence that all parties, including the government, had acted on the assumption that it was an open question whether Golden’s criminal counsel could represent him in the forfeiture proceeding, and that the court would decide the question. The government’s January 31 letter, which sets forth this position, clearly contemplates further delay until the court determines the proper course. This letter was written after the deadline for Golden’s filing his answer had passed. Thus the government cannot argue, as it does in its brief to this court, that default was caused by Golden’s “intentional neglect.” Rather, the evidence shows that the government provided statements, on which Golden could reasonably rely, to the effect that there was nothing objectionable in any delay for the purpose of obtaining the answer to the question of which counsel would be proper.
The record unquestionably establishes that there is no culpable conduct attributable to Golden that might be said to have led to his default.
II.
Tozer, Medunic, and Farnese explicitly require findings to be made by the district court as to the factors of prejudice, meritorious defense, and bad faith. The district court here focused only on the factor of meritorious defense, and in doing so not only relied on an incorrect standard but failed to apply the liberal standard that has been established by the precedents on this circuit. Moreover, the district court, as did the majority, has failed to attribute the appropriate significance to the defense which Golden has set forth.
My reading of the record reveals that all three of the relevant factors required to be satisfied by Golden have been satisfied, and thus support vacation of the default judgment. Golden did all that he was required to do in order to obtain an opportunity to reopen the forfeiture case. The government concededly was not prejudiced; no bad faith has been shown or found; and, as discussed, Golden’s defense, as alleged, is sufficient.
I conclude that the district court abused its discretion in refusing to vacate the judgment thus preventing the issues from being resolved by a trial on the merits. I therefore respectfully dissent.
. We have repeatedly recognized the sufficiency of “notice pleading,” observing that the pleader need not plead evidence, or facts on which the claim is based. See, e.g., Bogosian v. Gulf Oil Corp., 561 F.2d 434, 446 (3d Cir. 1977), cert. denied, 434 U.S. 1086, 98 S.Ct. 1280, 55 L.Ed.2d 791 (1978).
. The complaint in the forfeiture action alleged that the currency was intended to be furnished in exchange for cocaine, although 21 U.S.C. § 881(a)(6) (1982), the applicable statute, also provides for forfeiture of money actually furnished for such a transaction.