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Answer 1
Answer 1
CASE NO. ] ], PLAINTIFF, VS. ], DEFENDANT. ______________________________________/ DEFENDANTS ANSWER AND AFFIRMATIVE DEFENSES ANSWER ] (Defendant), files his Answer and Affirmative Defenses to the numbered
paragraphs referenced in Plaintiffs Complaint, and states: 1. 2. 3. 4. 5. set forth herein. 6. Any allegations not specifically admitted are denied. AFFIRMATIVE DEFENSES 7. As an Affirmative Defense, Defendant states that Plaintiff has failed to meet all Defendant admits ] and ]. Defendant denies ] and ]. Defendant has no knowledge with respect to 5, 6, 7 and 8. ] and ] are Jurisdictional. Defendant realleges and reavers his answers to ] and ] as if they were fully
conditions precedent for commencement of this action. 8. As an Affirmative Defense, Defendant states that Plaintiff has failed to attach
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to the Complaint any documentary evidence of the liability of the Defendant to the Plaintiff. 9. As an Affirmative Defense, Defendant states that Plaintiff has failed to duly apply all payments made by Defendant to the loan balance. WHEREFORE, Defendant respectfully requests that this Honorable Court find in his favor, award him his costs in this action and a reasonable attorneys fee, and provide such other and further relief as justice requires. ________________________ PETER SPINDEL Florida Bar No. 816183 Attorney for Defendant Peter Spindel, Esq., PA P.O. Box 166245 Miami, Florida 33116-6245 Telephone: (786) 517-4229 peterspindel@aol.com
CERTIFICATE OF SERVICE I CERTIFY that a true and correct copy of the foregoing was served on all interested parties on the attached service list by regular mail on ]. ________________________ PETER SPINDEL
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