Fill and Sign the Defendant Counter Plaintiff Form

IN THE CIRCUIT COURT OF COUNTY, MISSISSIPPI AND PLAINTIFF/COUNTER-DEFENDANTV. NO. DEFENDANT/ COUNTER-PLAINTIFF ANSWER TO COUNTERCLAIM COMES NOW, (" ") for answer to the Counterclaim propounded by defendant/counter-plaintiff, avers as follows: FIRST DEFENSE The Counterclaim fails to state a claim or cause of action upon which relief can be granted. SECOND DEFENSE adopts as if copied herein in extenso each of the allegations set forth in its Complaint. THIRD DEFENSE And now, answering each of the numbered allegations of the Counterclaim, avers as follows upon information and belief:1. The allegations contained in Paragraph 1 of the Counterclaim are admitted.2. The allegations contained in Paragraph 2 of the Counterclaim are admitted.3. Except to admit that was an original shareholder and owned of commencing on or about , 20 and entered into an employment contract with , as well, on or about , 20 , and that said relationships were terminated by agreement memorialized in the "Covenant Not to Compete and Termination Agreement" dated , 20 , the allegations contained in Paragraph 3 of the Counterclaim are denied.4.Except to admit that the "Covenant Not to Compete and Termination Agreement" is the best evidence of 's involvement with , the allegations contained in Paragraph 4 of the Counterclaim are denied.5. Except to admit that the "Covenant Not to Compete and Termination Agreement" is the best evidence for its terms and conditions, the allegations contained in Paragraph 3 of the Counterclaim are denied. 6.The allegations contained in Paragraph 6 of the Counterclaim are denied.7. The allegations contained in Paragraph 7 of the Counterclaim are denied.8. The allegations contained in Paragraph 8 of the Counterclaim are denied.9. reavers as if copied herein in extensor preceding defenses and answers to the Counterclaim.10. The allegations contained in Paragraph 10 of the Counterclaim are denied.11. The allegations contained in Paragraph 11 of the Counterclaim are denied.12. reavers as if copied herein in extensor each of foregoing defenses and answers to the Counterclaim.13. The allegations contained in Paragraph 13 of the Counterclaim are denied. THIRD DEFENSE In violation of the terms of the Covenant Not to Compete and Termination Agreement, dated , 20 , began competing against in of 20 or earlier. FOURTH DEFENSE violated the terms and conditions of the Covenant Not to Compete and Termination Agreement and such violation by the terms of the Covenant Not to Compete and Termination Agreement entitle to preliminary and permanent injunctive relief and to monetary damages from . FIFTH DEFENSE acted reasonably after establishing that there exists good and sufficient grounds to support its claims against and did not interpose this lawsuit for any improper purposes. SIXTH DEFENSE is not entitled to recover punitive damages against since same would violate 's protected rights under the Mississippi and United States Constitutions.WHEREFORE, THE PREMISES CONSIDERED, plaintiff/counter- defendant, , prays that this its Answer and Defenses to Counterclaim of be deemed good and sufficient, and that after due proceedings are had, that there be judgment in its favor and against , and that the Counterclaim of be dismissed with prejudice at his/her costs, and that be granted its attorney's fees in defending this action, together with any further relief the Court may deem just and proper. Respectfully submitted, _______________________________________________BY: OF COUNSEL: CERTIFICATE I, , do hereby certify that I forwarded by U. S. Mail, postage prepaid, a true and Correct copy of the above and foregoing pleading to: This the day of , 20 . __________________________________________