Answer (Caption and Title) Defendant thru counsel, and in answer to plaintiffs complaint, respectfully avers: 1.

That he admits paragraph___, ____,____ and ____of the complaint; 2. That he is without knowledge or information to form a belief as to the truth of the averments made in paragraph ___,___,___ thereof; 3. That he DENIES specifically each and every material allegation made in paragraph ___, ___, ___ of the complainant; and alleges that _________(state substance of matters which he will rely upon to support such specific denial) 4. And as AFFIRMATIVE DEFENSES, the defendant alleges: A. That (state affirmative defenses. All such grounds of defenses as would raise issues of facts not arising upon specific denials must be specifically pleaded, including FRAUD, STATUTE OF LIMITATION, RELEASE, PAYMENT, and all other matters by way of confession and avoidance. B. That____; 5. As COUNTERCLAIM against the plaintiff, the defendant alleges: A. That the defendant reproduces paragraphs ___,___ and ___ of the plaintiffs complaint. B. That, (state defendants claim for money and other relief) WHEREFORE, it is respectfully prayed that: (a) Prayer for judgment in favor of defendant with respect to plaintiffs complaint; (b) Prayer for judgment in favor of defendant with respect to counterclaim; (c) For such other relief consistent with law and equity and for costs (Venue, date, signature) Verification