Fill and Sign the Separate Answer and Defenses of Form

IN THE CIRCUIT COURT OF COUNTY, MISSISSIPPI PLAINTIFFVS. NO. , M.D. and , M.D. DEFENDANTS SEPARATE ANSWER AND DEFENSES OF , M.D. FIRST DEFENSE The defendant, , M.D., moves the court for a change of venue. SECOND DEFENSE The complaint filed herein fails to state a claim or cause of action against this defendant. THIRD DEFENSE AND NOW, responding paragraph by paragraph to the allegations of the plaintiff's complaint, the defendant, , M.D., by counsel, states as follows, to -wit: I. Responding to the allegations of Paragraph 1 of the complaint the defendant admits only that he/she is an adult resident citizen of County, Mississippi. II. Responding to the allegations of Paragraph 2 of the complaint the defendant, Dr. , admits only that he/she examined the plaintiff, , on or about . The defendant further . III. Responding to the allegations of Paragraph 3 of the complaint the defendant admits only that on or about the defendant, , M.D., administered anesthesia to the plaintiff. The remaining allegations of Paragraph 3 of the complaint are denied. IV. The defendant denies the allegations of Paragraph 4 of the complaint. V. The defendant denies the allegations of Paragraph 5 of the complaint. VI. The defendant denies the allegations of Paragraph 6 of the complaint.AND NOW, having answered fully, the defendant again denies that he/she is guilty of any negligence, fault, and lack of care or wrongful act whatsoever in these premises. The defendant therefore denies that he/she is liable unto the plaintiff herein in any sum or amount whatsoever.WHEREFORE, PREMISES CONSIDERED, the defendant, , M.D., moves the court for an order of dismissal, with prejudice, at the cost of the plaintiff.THIS the day of , 20 . Respectfully submitted,_______________________________________ Attorney for Of Counsel: Telephone: MSB # Attorney for CERTIFICATE OF SERVICE I, , of counsel to Defendant, , M.D., hereby certify that I have this day mailed, with postage prepaid, a true and correct copy of the above and foregoing document unto: SO CERTIFIED this the day of , 20 . __________________________________