Fill and Sign the Answer and Counterclaim Mississippi 497314456 Form

IN THE CHANCERY COURT OF       COUNTY, MISSISSIPPI       and       vs.       ANSWER AND COUNTERCLAIM       ("       ") and       ("       ") and the Complaint to Enforce Contract and for Interpleader as follows: FIRST DEFENSE The Complaint fails to state a claim for which relief can be granted. SECOND DEFENSE The Complaint fails to state a claim for which relief can be granted. THIRD DEFENSE       and       respond to the allegations of the Complaint paragraph by paragraph as follows: 1. Admitted. 2. Admitted. 3. Admitted. 3. Admitted. 4. Admitted. 5. Admitted. 6. Admitted. 7. Admitted. 8. Denied. Venue is not properly before this Court. The subject Contract was to be performed in whole or in part in       County, Mississippi where the subject business is located and where       resides. 9.       . 10. The Contract speaks for itself. 11. The Contract speaks for itself. 12. The Contract speaks for itself. 13. Denied. Contemporaneously with the execution of the written agreement       ("       ") agreed to provide       with a       .       has subsequently reneged on this agreement. 14.       and       admit that       paid monthly rental on the real property and have no information as to the remaining allegations of the first sentence of paragraph 14 and therefore deny same.       and       admit that       owes monthly rent for the use of the personal property and the same has not been paid to       and       to date.       and       deny the remaining allegations of paragraph 14. 15. Admitted.       and       would affirmatively state that the documents were executed upon the belief that the entire agreement would be consummated as agreed, which has not transpired to date. 16.       17.       18.       19.       20.       21.       22.       23.       24.       25.       26.       27.       28.       29.       30.             and       deny the remaining unnumbered prayer for relief       and       and request that their be dismissed with prejudice. COUNTERCLAIM       ("       ") and       (       ) bring this Counterclaim against       ("       ") and       ("       ") as follows: 1.       and       are obligated to pay to       the sum of $       per month under a Commercial Lease and Operating Agreement from       ,       through       ,       . The obligation is unconditional. To date, none of the payments have been made. Pursuant to paragraph 7.4 of the subject Contract, this default is a default under the Contract. Despite repeated demands for payment,       and       have failed to make the required payments and the Contract is void at the option of       .       declares the Contract void. 2. Pursuant to paragraph 9.9 of the Contract,       and       were required to keep the Contract and its terms confidential.       and       have intentionally failed to do so and the Contract is void at the option of       .       declares the Contract void. 3.       and       have used confidential information obtained by their attorney when he/she counseled       on confidential personal matters, to the detriment of       .       has been damaged thereby. 4.       and       have incurred expenses, costs and bills in the name of       and       for which       and       and refused to reimburse       and       . WHEREFORE PREMISES CONSIDERED,       and       requests that this Court dismiss the Complaint with prejudice and award       and       a judgment against       and       jointly and severally, in the sum of $       for actual and consequential damages caused by the actions of       and       and grant such other relief as is necessary in the circumstances. DATED: This the       day of       , 20       . Respectfully submitted, _______________________________________       Attorney for       Of Counsel:                         Telephone:       MSB #       Attorney for