Fill and Sign the Amended Complaint File Form

IN THE CHANCERY COURT OF       COUNTY, MISSISSIPPI       , PLAINTIFF(S) vs. NO.             , DEFENDANT(S) ANSWER AND DEFENSES TO AMENDED COMPLAINT Defendant       ("       ") files herein its Answer and Defenses to the Amended Complaint filed against it in this action, and in support thereof states as follows: FIRST DEFENSE The Amended Complaint fails to state a claim upon which relief can be granted. SECOND DEFENSE - ANSWER       , responding to the Amended Complaint paragraph by paragraph, states as follows: 1.       admits the allegations contained in Paragraph 1 of the Amended Complaint. 2.       admits that the Plaintiffs are adult resident citizens of Mississippi and that at various times one or more Plaintiffs was a partner in       ,       or       ("the partnerships").       further admits that Exhibit       reflects each Plaintiff's ownership in each partnership.       admits that it collected equipment rentals for the Partnerships. Except as expressly admitted,       denies the allegations contained in Paragraph 2 of the Amended Complaint. 3.       denies the allegations contained in paragraph 3 of the Amended Complaint. 4.       denies the allegations contained in paragraph 4 of the Amended Complaint. 5.       denies the allegations contained in paragraph 5 of the Amended Complaint. 6.       denies the allegations contained in paragraph 6 of the Amended Complaint. 7.       admits that the referenced partnerships no longer exist. Except as expressly admitted,       denies the allegations contained in Paragraph 7 of the Amended Complaint. 8. With respect to the unnumbered paragraph immediately following paragraph 7 of the Amended Complaint,       denies that the Plaintiffs are entitled to the relief requested therein or to any relief whatsoever. THIRD DEFENSE The Plaintiffs have unclean hands, and therefore are not entitled to relief in this court. FOURTH DEFENSE Any amounts due the Plaintiffs from       , which is expressly denied, are subject to a setoff for amounts due from the partnerships to       . FIFTH DEFENSE Some or all of the Plaintiffs' claims are barred by the applicable statute of limitations. SIXTH DEFENSE The Plaintiffs’ claims are barred under the doctrine of laches. SEVENTH DEFENSE The Plaintiffs’ claims are barred under the doctrine of equitable estoppel. EIGHTH DEFENSE The Plaintiffs have waived any right to recover interest by their participation or acquiescence in decisions to postpone distribution of rental receipts. WHEREFORE, PREMISES CONSIDERED, Defendant       demands that the Complaint filed against it be dismissed, with all costs to the Plaintiffs. Respectfully submitted, _______________________________________       Attorney for       Of Counsel:                         Telephone:       MSB #       Attorney for