Fill and Sign the Harassment 497330033 Form

IN THE __________________ COURT OF _______________________ (County) , __________________________________ (State) ___________________________________________ PLAINTIFF (Name of Plaintiff) V. CAUSE NO. ______,______ ____________________________________________ DEFENDANTS (Names of Defendants) ANSWER AND AFFIRMATIVE DEFENSES Comes now Defendant A and Defendant B , Defendants herein, and submits their joint answer and affirmative defenses to the allegations contained in the Complaint filed against them herein. FIRST DEFENSE Defendants would show that the Complaint fails to state a claim or cause of action against them upon which any relief can be granted. SECOND DEFENSE Defendant A , and employees and agents acting on behalf of said Defendant, including Defendant B , at all times conducted its business of collecting delinquent debts in a professional manner and in compliance with all applicable laws. Defendant A sought to collect on a debt owed by Plaintiff assigned to Defendant A for collection, and said debt was delinquent for more than ______ (number of months) . This debt remains unpaid to date. Plaintiff constantly sought to evade paying the debt by changing residences, without any forwarding addresses, agreeing to payment schedules for the debt, but then unilaterally reneging on the agreements, and other acts of evasion and subterfuge. Nevertheless, Defendant A conducted its collection activity with restraint and patience. THIRD DEFENSE And now, answering the allegations of the Complaint filed against him, paragraph by paragraph, Defendants would show the following: 1. Defendants admit the allegations of Paragraph 1 of the Complaint ( e.g., that Plaintiff is an adult resident citizen of (city, county, state) _______________________ ________________________________________________________________________ ________________________________________________________________________ _______________________________________________________________________. 2. Defendants admit the allegations of Paragraph 2 of the Complaint [ e.g., Defendant A is a corporation organized and existing under the laws of (name of state) , engaged in the business of a collection agency, with its principal place of business located at (street address, city, county, state, zip code)] __________________________ ________________________________________________________________________ ________________________________________________________________________ ________________________________________________________________________ ________________________________________________________________________ _______________________________________________________________________. 3. Defendants admit the allegations of Paragraph 3 of the Complaint [ e.g., Defendant B is an adult resident citizen of (city, county, state), and resides at (street address, city, county, state, zip code)] ________________________________________ ________________________________________________________________________ ________________________________________________________________________ ________________________________________________________________________ ________________________________________________________________________ _______________________________________________________________________. 4. Defendants deny the allegations of Paragraph 4 of the Complaint, except Defendants admit that Defendant B was an employee of Defendant A during the times in question. 5. Defendants deny the allegations of Paragraph 5 of the Complaint. 6. Defendants deny the allegations of Paragraph 6 of the Complaint, except Defendants admit that on or about ______________________________________ (date) Defendant A telephoned Plaintiff’s employer. 7. Defendants deny the allegations of Paragraph 7 of the Complaint. 8. Defendants deny the allegations of Paragraph 8 of the Complaint. 9. Defendants deny the allegations of Paragraph 9 of the Complaint. 10. Defendants deny the allegations of Paragraph 10 of the Complaint. WHEREFORE, Defendants request that the Court deny the requested relief and dismiss Plaintiff’s Complaint with prejudice. Defendants further request reasonable attorney fees, costs, and such other and further relief as the court deems just and proper. Respectfully submitted, ____________________________________ DEFENDANT A ____________________________________ DEFENDANT B CERTIFICATE OF SERVICE I, _______________________________________ (Name of Attorney) , Attorney for Defendants, do hereby certify that a true and correct copy of the above and foregoing Answer and Affirmative Defenses has been sent, via first class mail, postage prepaid, to ____________________________________________ (Name of Attorney for Plaintiff) , Attorney for Plaintiff, at ____________________________________________________ ________________________________________________________________________ ___________________________________ (street address, city, county, state, zip code) . So certified, this the _____ day of ______________________________, 20____. ____________________________________ Attorney for Defendants