Anytown, US 12345
COURT OF ___________________
ABC Plumbing, Inc,
As the Defendant, you’ll want to address and answer each paragraph or count
brought from in the Complaint in the order it was present in the Complaint. After you
have responded to all counts or allegations, then any affirmative defenses (additional
issues raised by yourself) can be addressed such as Failure to State a Cause of
Action, Statute of Limitations and Failure to Property Serve).
COMES NOW the Defendant ABC Plumbing, Inc. in answering the allegations of the
Complaint on file herein, affirms, denies and alleges as follows:
Answering the allegations of Paragraph 1-5 of the Complaint herein, Defendant
affirms all facts.
Answering the allegations of Paragraph 6 of the Complaint herein, Defendant
affirms in part based on his knowledge of the incident, but denies that the injuries
sustained were a result of his plumbing work performed at the residence.
Answering Count 1 – Negligence of the Complaint herein, Defendant denies all
allegations. On or about July 1, 2009, Defendant was contracted to perform plumbing
work on the Plaintiff’s bathroom and kitchen at his residence. On or about July 5,
2009, Defendant performed all plumbing work as agreed upon in the residence and did
not perform any work related to the wiring of the Plaintiff’s residence. Furthermore,
the plumbing work performed was completed by the Defendant in a safe and effective
Answer - 2
manner. This work was not the proximate cause or the cause-in-fact of the injuries
sustained by the Plaintiff.
The Defendant now brings forth the following Affirmative Defenses:
DEFENSE 1 – Failure to State a Claim
Defendant answering the Complaint herein, alleges that all allegations and
counts brought forth therein fails to state a claim for which relief can be granted.
As with the Complaint, typically there will be several defenses brought forth
depending on the complexity of the case.
WHEREFORE, Defendant prays that the Plaintiff take nothing and the Defendant
have judgment against the Plaintiff and recover the costs of suit herein, and such
other relief the court may deem proper.
Dated this 1st day of January, 2010
Your name POA for her name, defendant
This would allow you to dispute this and avoid a judgment.
I appreciate the chance to help you today.I wish you the best.
If you can positive rate it is much appreciated