IN THE _____________________ COURT OF ________________________ (County),
___________________________ (State)
____________________________ &
____________________________ PETITIONERS
V. CAUSE NO. ______-______
_____________________________ RESPONDENT
ANSWER (or Response) TO COMPLAINT (or Petition)
Comes now ____________________________, Respondent herein , and files this
Answer to the ___________________ (Petition or Complaint) filed against him 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. Respondent, the natural father of _______________________________ (name of
child), has not and does not consent to the adoption of ____________________________
(name of child).
8. Immediately on learning of the birth of the child , Respondent, the natural father of
the child, acknowledged paternity of the child and filed the instrument of
acknowledgment with _____________________________________________________
(applicable state agency or department) .
9. ______________________________________ (Name of natural mother) , the
mother of the child, left __________________________ (state) in _________________
(month and year) without informing Respondent that she was leaving the jurisdiction,
and without giving Respondent her new address or telephone number. Respondent was
able, through an intermediary, to obtain her new telephone number, but not her new
address. Respondent stayed in touch in this manner with the mother, expressing repeated
concerns for her health and the health of _________________________________ (name
of child) the expected infant.
10. Prior to the birth of _______________________________ (name of child) ,
Respondent wrote to the natural mother, through an intermediary, and asked that she let
him raise the child. A copy of this letter was furnished to the attorney of Petitioners, who
helped arrange for the adoption, and is attached to this Answer as Exhibit A. Petitioners
should have known that Respondent wanted to raise the child and did not consent to the
adoption.
11. By virtue of their actual knowledge of the refusal of Respondent to consent to the
adoption, Petitioners come into court with unclean hands, and the Petition for Adoption
lacks equity.
12. Since the birth of ____________________________ (name of child) , Respondent
has sent money to Petitioners for the support of the child __________________________
(name of child) . This money was refused by Petitioners, and is being held in trust for the
purpose of the support of the child.
13. Respondent, the natural father of _______________________________ (name of
child) has a deep and abiding love for the child. It does not matter that Petitioners are
wealthier than Respondent or that they also love the child. The natural bond between the
________________________________ (name of child) and his/her natural father is
sacred, and the Petition for Adoption in this case fails to establish that Respondent has
freely and voluntarily surrendered the child for adoption.
WHEREFORE, Respondent respectfully requests that the ___________________
(Petition or Complaint) should be dismissed, with prejudice, at the cost of
_______________________________ and _________________________________
(Petitioners or Plaintiffs) , an d 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:
______________________________
RESPONDENT
Address:
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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FAQs
Here is a list of the most common customer questions. If you can’t find an answer to your question, please don’t hesitate to reach out to us.
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