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Enigma · 04-16-2008, 01:13 AM

ANSWER AND AFFIRMATIVE DEFENSES

DEFENDANT XXXXX appearing pro se, answers the complaint of Plaintiff and, in responses to each numbered paragraph thereof, and states:

1. Admitted as to being responsible for the minor child, otherwise without knowledge and therefore denied.

2. Without knowledge and therefore denied.

3. Admitted as to purported cause of action, however Defendant deny that any breach occurred, or in the alternative assert that any such breach should be excused by the Plaintiff’s conduct, as Defendant has had no contact with Plaintiff prior to the filing of this instant action..

AFFIRMATIVE DEFENSES

1. Plaintiff failed to allege ultimate facts to establish existence of a contract.

2. Defendant allege that the Plaintiff herein and each and every purported Cause of Action in the Complaint are barred because Plaintiff has engaged in acts and courses of conduct which rendered them in pari delicto.

3. Plaintiff’s action is barred by the statute of limitations.

04-16-2008, 01:13 AM	#14 (permalink)
Enigma Administrator Join Date: May 2006 Posts: 2,282 Casino Cash: $953350	ANSWER AND AFFIRMATIVE DEFENSES DEFENDANT XXXXX appearing pro se, answers the complaint of Plaintiff and, in responses to each numbered paragraph thereof, and states: 1. Admitted as to being responsible for the minor child, otherwise without knowledge and therefore denied. 2. Without knowledge and therefore denied. 3. Admitted as to purported cause of action, however Defendant deny that any breach occurred, or in the alternative assert that any such breach should be excused by the Plaintiff’s conduct, as Defendant has had no contact with Plaintiff prior to the filing of this instant action.. AFFIRMATIVE DEFENSES 1. Plaintiff failed to allege ultimate facts to establish existence of a contract. 2. Defendant allege that the Plaintiff herein and each and every purported Cause of Action in the Complaint are barred because Plaintiff has engaged in acts and courses of conduct which rendered them in pari delicto. 3. Plaintiff’s action is barred by the statute of limitations. __________________ It is better to keep your mouth shut and appear stupid than to open it and remove all doubt. - Mark Twain The information and materials in this document are provided for general information purposes only and are not intended to constitute legal, accounting or tax advice or opinions on any specific matters. Laws and regulations change frequently and their application can vary widely based upon the specific facts and circumstances involved. You are responsible for the applicability and accuracy of Information as it relates to your specific situation.