Fill and Sign the Answer Reconventional Form

_________________ : ________ JUDICIAL DISTRICT COURT VS : PARISH OF ________ , LOUISIANA _________________ : DOCKET NO. ____ AMENDED ANSWER AND RECONVENTIONAL DEMAND NOW INTO COURT, through undersigned counsel, comes _________________ , a person of the full age of majority who respectfully represents: 1. The allegations of Paragraph I of Plaintiff = s petition are admitted. 2. The allegations of Paragraph II of Plaintiff = s petition are denied. 3, The allegations of Paragraph III of Plaintiff = s petition are denied. 4. The allegations of Paragraph IV of Plaintiff = s petition are denied. 5. The allegations of Paragraph V of Plaintiff = s petition are denied. 6. The allegations of Paragraph VI of Plaintiff = s petition are denied. AND NOW ASSUMING the position of plaintiff in reconvention, _________________ , respectfully represents that: 7. Made defendant herein is _________________ , a Louisiana limited partnership authorize to do and doing business in the State of Louisiana. 8. On ________ ____ , 20 ____ , _________________ , requested that defendants in reconvention perform certain work to his trailer, namely, replace lights on trailer and wire up, remove and weld air tank, check and adjust brakes, grease cams and install SMV sign. 9. At the time the work was requested by _________________ , it was relayed to the defendants in reconvention that the work requested must be done as quickly as possible because _________________ was under contract with _________________ l to haul sugarcane throughout the grinding season. 10. _________________ was informed by employees of _________________ that the work requested would not take long and would be completed quickly. 11. _________________ called _________________ at approximately 4:30 in the evening on ________ ____ , 20 ____ and was told that his truck was not ready. 12. On the morning of ________ ____ , 20 ____ , _________________ once again called _________________ to find out if is trailer was ready and, once again, was told that it was not. 13. At approximately ____ o’clock ____ .M., _________________ went to _________________ to find out if his trailer was ready, and found out, once again, that is was not. 14. Additionally, defendants in reconvention informed _________________ that his trailer had an air leak which would require additional replacement parts. 15. _________________ , at that time, asked _________________ to provide him with a price for the part, as well as, labor to repair it and was given a figure of approximately $ ________ . 16. At that time, _________________ informed _________________ that he would like the work originally requested performed and that his truck be put back together so that he could get his vehicle put back on road. 17. At approximately 4:30 on the evening of ________ ____ , 20 ____ _________________ paid _________________ via check no. ____ in the amount of $ ________ , believing that all of the work requested had been completed, and completed satisfactorily. 18. Upon arriving home, _________________ realized that instead of welding the air tank as requested, that J.B. Weld had been put on the tank in its place, and this weld did not hold. 19. Additionally, _________________ had requested that the cams be freed up and greased and this work was not done as well. 20. Finally, the air leak that ________ told _________________ would cost approximately $ ________ to repair, was found to be caused by improper connection of the valves by employees of _________________ , thereby, created the problem instead of fixing it. 21. ________ attempted three (3) times to contact _________________ of _________________ to inquire as to the defective work that was done and was told that _________________ was not available every time. 22. _________________ then requested that _________________ call him back as soon as possible regarding the work on the trailer, but to no avail. 23. _________________ , at that time, called his bank and stopped payment on the check until the matter could be cleared up. 24. At this time, _________________ had no choice but to have someone else repair his trailer in order to get it back on the road. (See Exhibit A.) 25. Additionally, on ________ ____ , 20 ____ the same trailer lights that had allegedly been fixed and repaired by _________________ only two (2) months earlier once again had to be repaired and fixed correctly. (See Exhibit B.) 26. Due to the faulty workmanship and/or not doing the work requested, _________________ lost approximately three (3) days of work at a rate of $ ________ per day, all of which could have been avoided had _________________ satisfactorily completed the work requested when first brought in on ________ ____ , 20 ____ . 27. Plaintiff in reconvention has suffered damages and lost wages in the amount of $ ________ . WHEREFORE, Plaintiff in reconvention prays that after due proceedings had there be judgment herein in favor of Plaintiff in reconvention and against defendant in reconvention in the amount of $ ________ plus court costs and attorney = s fees. Plaintiff in reconvention further prays that he be allowed to file this Amended Answer and Reconventional Demand. Plaintiff in reconvention further prays that defendant in reconvention = s suit be dismissed at its costs. Respectfully Submitted, ______________________________ _________________ Attorney for Defendant _________________ ________ , LA ____ ( ____ ) ________ La. Roll No. ____ PLEASE SERVE PLAINTIFF through its attorney of record _________________ _________________ ________ _________________ , LA ____ CERTIFICATE I HEREBY CERTIFY that the above and foregoing has been forwarded by U.S. mail to _________________ , Attorney at Law, _________________ , _________________ , LA ________ , by placing a copy of same in the mail, postage prepaid and properly addressed. __________________________ _________________ _________________ : ________ JUDICIAL DISTRICT COURT VS : PARISH OF ________ , LOUISIANA _________________ : DOCKET NO. ____ ORDER Considering the foregoing: IT IS HEREBY ORDERED, ADJUDGED AND DECREED that Defendant, _________________ , be allowed to file the foregoing Amended Answer and Reconventional Demand. SIGNED this ____ day of _______________ 20 ____ at _________________ , ________ Parish, Louisiana. ______________________________ DISTRICT JUDGE