Fill and Sign the Personal Injury Accident 497426638 Form

IN THE ______________ COURT OF ______________ COUNTY STATE OF ________________       ) )       ) Petitioner/Plaintiff, ) ) ) NO.       Vs. ) )       ) Respondent/Defendant ) ) SEPARATE ANSWER OF ____________________ Defendant ____________________ answers as follows the complaint of plaintiffs ____________________ , ____________________ , and ____________________, by and through her mother and next friend, ____________________ : FIRST DEFENSE The complaint fails to state a claim upon which relief may be granted. SECOND DEFENSE Answering the complaint by paragraphs, defendant states: 1. Defendant lacks information and belief concerning the allegations of Paragraph 1 of the complaint. 2. Defendant lacks information and belief concerning the allegations of Paragraph 2 of the complaint. 3. Defendant lacks information and belief concerning the allegations of Paragraph 3 of the complaint. 4. Defendant admits the allegations of Paragraph 4 of the complaint. - 1 - 5. Defendant admits the allegations in the first sentence in Paragraph 5 of the complaint and admits the individual defendants may own the truck. 6. Defendant denies the allegations of Paragraph 6 of the complaint to the extent not specifically admitted. 7. Defendant denies the allegations of Paragraph 7 of the complaint, denies the unnumbered demand of the complaint, and denies that plaintiffs, or any of them, are entitled to recover any sum whatsoever from defendant. THIRD DEFENSE Plaintiffs failed to exercise due care for their own safety and the time and place described in the complaint. Defendant denies plaintiffs are entitled to any relief, but alternatively alleges plaintiffs were comparatively negligent such that any damages they may have sustained as a consequence of the accident should be reduced in proportion to the proximately contributing negligence on each of their parts. Respectfully submitted, Dated: Name:       Title:       Address: Address: City, State, Zip: Phone: Fax: E-Mail: Attorney No.: CERTIFICATE OF SERVICE I, ______________________________, do hereby certify that I have this day mailed, U.S. Mail, postage prepaid, a true and correct copy of the above and foregoing to - 2 - __________________________________, at the following address; ___________________________________________________________________ THIS the ____ day of _____________, 20____. - 3 -