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 Complaint (or Petition) filed against her 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. The father of the ______________________________ (name of child) died on
___________ (date).
8. Respondent admits that she signed a consent form for the adoption of her child
________________________________ (name of child). However, her consent was not
freely given, in that:
a) Respondent and her other young child, were then living at
___________________________________________________________________
_______________________________________________________ (street address, city,
county, state, zip code) , at a distance from her normal residence, at the expense of
Petitioners;
b) At the time, Respondent believed herself to be completely dependent
on Petitioners, not only for her own support, but also for the support of her other
young child; and
c) Respondent feared eviction and withdrawal of financial assistance for food
and other necessities for herself and her other young child if she did not consent to
Petitioners' adoption of _______________________________________ (name of child) .
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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