Legal Forms: Answer (for Rossy)

ANSWER WITH SPECIAL AND AFFIRMATIVE DEFENSES AND COUNTERCLAIM

SAMPLE:

(Caption and Title)

ANSWER

COMES NOW, the defendant, through the undersigned counsel, in the above-entitled case and to this Honorable Court most respectfully alleges:

1.    Defendant admits averment in paragraphs 1,2 and 3 of the complaint;

2.    Defendant specifically denies the allegation in paragraph 4 of the complaint, the truth being that (fact being claimed by the defendant as the true state of facts or truth in the special and affirmative defenses herein set forth):

3.    Defendant has no knowledge or information to form a belief as to the truth of the averment in paragraphs 5, 6, 7 and 8 of the complaint

By way of special and affirmative defenses, the defendant avers:

1.    The obligation has been paid

2.    The cause of action has prescribed

By way of counterclaim, defendant alleges:

1.    That by virtue of this unwarranted and malicious act initiated by the plaintiff, the defendant was forced to engage the services of counsel in the sum of twenty-thousand pesos (P20,000).

PRAYER

WHEREFORE, it is respectfully prayed that the complaint be dismissed and defendant be awarded the amount of __________ pesos (P _________).

Other equitable reliefs are likewise prayed for.

Place and date.

Signature of Counsel

VERIFICATION

CERTIFICATION AGAINST FORUM SHOPPING

PROOF OF SERVICE

Add comment December 3rd, 2009