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Hi and welcome to JA
I am reviewing your question
First of all the answer just addresses the numbered allegations of the complaint by
denying the allegation contained in paragraph A of the complaint
admitting an allegation ..................................B........................
acking sufficient information and belief to repond to the allegation contained in paragraph C of the complaint.
Requests for information are contained in a totally different document called a DEMAND FOR A BILL OF PARTICULARS, OR FOR DOCUMENTS, ETC.
to be continued
So without knowing the allegations of the complaint, your answer should be:
11. Denies the allegation contained in paragraph_________of the complaint.
12. Lacks sufficient information and belief to respond to paragraph_________of the complaint.
Your first affirmative defense is good
Your second is NOT an affirmative defense but would be the subject of a request for documents
The first part off your 15 should not be an affirmative defense but should match up with one of the allegations of the complaint (see 12 above). The part regarding demanding the contract or the terns thereof would be the subject matter of a demand for a bill of particulars and/or a demand for documents.
The beginning of your 16 should be paragraph 13 of the answer.
The estoppel language is your third affirmative defense
Your 17 is a demand that goes at the end of the answer.
Your 18..........part of a demand for documents
Balance of 18 Fourth affirmative defense
19. Should be the first affirmative defense and renumber the others accordingly along with second sentence of 20
20 first part........document demand
then add the language of 17
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Thank you very much Glad I could use my heavy litigation background to assist.
I notice however that you did not formally accept; and pay the posted amount Could you do that? Thanks again
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