Fill and Sign the Abandonment Form

IN THE _____________________COURT OF ________________________ (County), ___________________________ (State)____________________________ &____________________________ PETITIONERSV.CAUSE NO. ______-___________________________________ RESPONDENT ANSWER (or Response) TO COMPLAINT (or Petition) Comes now ____________________________, Respondent herein, and files this Answer to the ___________________ (Petition or Complaint) filed against him in this cause, and would state in support thereof the following: 1.Respondent admits the allegations contained in Paragraph 1 of the Petition.2. Respondent denies the allegations contained in Paragraph 2 of the Petition.3.Respondent lacks sufficient information or belief to admit or deny the allegations contained in Paragraph 3 of the Petition, and denies those allegations on that ground.4. In response to Paragraph 4, Respondent admits that ____________________ ________________________________________________________________________ _________________________________ (set forth allegation admitted), but Respondent denies all of the remaining allegations contained in Paragraph 4.5. In response to Paragraph 5 of the Petition, Respondent denies on information and belief that ____________________________________________________________ ___________________________________________________________________ (set forth allegation denied on information belief), and denies all of the remaining allegations contained in Paragraph 5.6. In answer to Paragraph 6 of the Petition, Respondent lacks sufficient information or belief to admit or deny that _____________________________________________ _______________________________________________________________(set forth allegation as to which Respondent lacks sufficient information or belief to admit or deny), and denies that allegation on that ground. Respondent denies all of the remaining allegations contained in Paragraph 6. AND, NOW, having answered each and every allegation contained in the _____________________ (Petition or Complaint) of _________________________ and ____________________________________, (Petitioners or Plaintiffs) , the undersigned _______________________________ (Respondent) would show unto the Court the following, to-wit:7.Respondent, the natural father of _______________________________ (name of child), has not and does not consent to the adoption of ____________________________ (name of child). 8.Immediately on learning of the birth of the child, Respondent, the natural father of the child, acknowledged paternity of the child and filed the instrument of acknowledgment with _____________________________________________________ (applicable state agency or department).9.______________________________________ (Name of natural mother), the mother of the child, left __________________________ (state) in _________________ (month and year) without informing Respondent that she was leaving the jurisdiction, and without giving Respondent her new address or telephone number. Respondent was able, through an intermediary, to obtain her new telephone number, but not her new address. Respondent stayed in touch in this manner with the mother, expressing repeated concerns for her health and the health of _________________________________ (name of child) the expected infant.10.Prior to the birth of _______________________________ (name of child), Respondent wrote to the natural mother, through an intermediary, and asked that she let him raise the child. A copy of this letter was furnished to the attorney of Petitioners, who helped arrange for the adoption, and is attached to this Answer as Exhibit A. Petitioners should have known that Respondent wanted to raise the child and did not consent to the adoption.11.By virtue of their actual knowledge of the refusal of Respondent to consent to the adoption, Petitioners come into court with unclean hands, and the Petition for Adoption lacks equity.12.Since the birth of ____________________________ (name of child), Respondent has sent money to Petitioners for the support of the child __________________________ (name of child). This money was refused by Petitioners, and is being held in trust for the purpose of the support of the child.13.Respondent, the natural father of _______________________________ (name of child) has a deep and abiding love for the child. It does not matter that Petitioners are wealthier than Respondent or that they also love the child. The natural bond between the ________________________________ (name of child) and his/her natural father is sacred, and the Petition for Adoption in this case fails to establish that Respondent has freely and voluntarily surrendered the child for adoption. WHEREFORE, Respondent respectfully requests that the ___________________ (Petition or Complaint) should be dismissed, with prejudice, at the cost of _______________________________ and _________________________________ (Petitioners or Plaintiffs), and further requests such other, additional, and different relief as to the court may seem just and proper.RESPECTFULLY SUBMITTED, this the of _________________, 20____. ______________________________RESPONDENT CERTIFICATE OF SERVICE I certify that a copy of this document was ( ) mailed ( ) faxed and mailed ( ) hand delivered to the person(s) listed below on ____________________ (Date). . _________________________________ (Name of Attorney for Petitioners): Address: City, State, Zip: Fax Number: ______________________________ RESPONDENTAddress:City, State, Zip: Telephone Number: Fax Number: STATE OF ____________________________COUNTY OF____________________ Sworn to or affirmed and signed before me on (Date) by __________________________ (Respondent). _________________________________NOTARY PUBLIC (Print, type, or stamp commissioned name of notary) Personally known Produced identification Type of identification produced (Oath may vary by state)