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Fill and Sign the Answer by Natural Mother to Complaint that She Abandoned Childor Consented to Give Up Custody Form

Fill and Sign the Answer by Natural Mother to Complaint that She Abandoned Childor Consented to Give Up Custody Form

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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 Complaint (or Petition) filed against her 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.The father of the ______________________________ (name of child) died on ___________ (date).8. Respondent admits that she signed a consent form for the adoption of her child ________________________________ (name of child). However, her consent was not freely given, in that: a) Respondent and her other young child, were then living at ___________________________________________________________________ _______________________________________________________ (street address, city, county, state, zip code), at a distance from her normal residence, at the expense of Petitioners; b) At the time, Respondent believed herself to be completely dependent on Petitioners, not only for her own support, but also for the support of her other young child; and c) Respondent feared eviction and withdrawal of financial assistance for food and other necessities for herself and her other young child if she did not consent to Petitioners' adoption of _______________________________________ (name of child). 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)

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