sample answer to plaintiff's second amended complaint

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IN THE CIRCUIT COURT FOR THE COUNTY OF LEON, FLORIDA PAUL PERKINS, PLAINTIFF ) CASE NO. 11-123 ) Plaintiff, ) ) ANSWER TO PLAINTIFF’S v. ) SECOND AMENDED COMPLAINT ) DAN DOOP, Defendant. ) ) COMES NOW Defendant, Dan Doop, and for his Answer to Plaintiff’s Second Amended Complaint, states as follows: 1. That as to the allegations of Paragraph One of Plaintiff’s Second Amended Complaint, he is without knowledge or information sufficient to form a belief as to the truth of the matter stated and therefore denies. 2. That the allegations contained in Paragraph Two of Plaintiff’s Second Amended Complaint are admitted. 3. That the allegations of Paragraph Three of Plaintiff’s Second Amended Complaint are denied. 4. That the allegations contained in Paragraph Four of Plaintiff’s Second Amended
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Unformatted text preview: Complaint are denied. 5. As an affirmative defense, Defendant states that Plaintiff’s negligence contributed to the accident and his injury and damages because he negligently operated or maintained the motor vehicle in which he was driving so that it collided with the Defendant’s motor vehicle. WHEREFORE, Defendant prays that the Plaintiff recover nothing of the Defendant; that the costs of this action be taxed against Plaintiff; and for such other and further relief as the Court deems proper. s/ F. Lee Dailey F. LEE DAILEY Attorney for Defendant 1400 Lawyer’s Lane T a l l a h a s s e e , F l o r i d a Telephone – 222-1234 Fla. Bar No. 50505...
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