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IN THE CIRCUIT COURT OF COUNTY, MISSISSIPPI
PLAINTIFF
VS. NO.
, M.D. and , M.D. DEFENDANTS
SEPARATE ANSWER AND DEFENSES OF , M.D.
FIRST DEFENSE
The defendant, , M.D., moves the court for a change of venue.
SECOND DEFENSE
The complaint filed herein fails to state a claim or cause of action against this defendant.
THIRD DEFENSE
AND NOW, responding paragraph by paragraph to the allegations of the plaintiff's
complaint, the defendant, , M.D., by counsel, states as follows, to - wit:
I.
Responding to the allegations of Paragraph 1 of the complaint the defendant admits only
that he/she is an adult resident citizen of County, Mississippi.
II.
Responding to the allegations of Paragraph 2 of the complaint the defendant, Dr. ,
admits only that he/she examined the plaintiff, , on or about . The defendant further
.
III.
Responding to the allegations of Paragraph 3 of the complaint the defendant admits only
that on or about the defendant, , M.D., administered anesthesia to the plaintiff. The
remaining allegations of Paragraph 3 of the complaint are denied.
IV.
The defendant denies the allegations of Paragraph 4 of the complaint.
V.
The defendant denies the allegations of Paragraph 5 of the complaint.
VI.
The defendant denies the allegations of Paragraph 6 of the complaint.
AND NOW, having answered fully, the defendant again denies that he/she is guilty of
any negligence, fault, and lack of care or wrongful act whatsoever in these premises. The
defendant therefore denies that he/she is liable unto the plaintiff herein in any sum or amount
whatsoever.
WHEREFORE, PREMISES CONSIDERED, the defendant, , M.D., moves the
court for an order of dismissal, with prejudice, at the cost of the plaintiff.
THIS the day of , 20 .
Respectfully submitted,
_______________________________________
Attorney for
Of Counsel:
Telephone:
MSB #
Attorney for
CERTIFICATE OF SERVICE
I, , of counsel to Defendant, , M.D., hereby certify that I have this day
mailed, with postage prepaid, a true and correct copy of the above and foregoing document unto:
SO CERTIFIED this the day of , 20 .
__________________________________
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