IN THE _____________ [1] COURT OF ___________ [2] COUNTY STATE OF GEORGIA ) ) ) Plaintiff, ) ) ) ) ) vs. ) ) _____________________, [4] ) ) Defendant.

) ________________________________ ) _____________________, [3]

CIVIL ACTION FILE NO. ________________ [5]

DEFENDANT(S) ANSWER, and AFFIRMATIVE DEFENSES [6] COMES NOW, ___________________[3], Defendant herein and hereby Answers, Responds, Replies and interposes Affirmative Defenses in response to Plaintiffs Complaint filed in the _____________[1] Court of _____________[2] County, Georgia. Defendant shows the Court as follows: FIRST DEFENSE Plaintiffs Complaint against _____________[4] fails to state a claim upon which relief may be granted and therefore, same should be dismissed. SECOND DEFENSE Plaintiff asserts [___] [7] insufficiency of process and/or [___] insufficiency of service of process, pursuant to OCGA 9-11-4.

THIRD DEFENSE To the extent as may be shown through discovery or pleadings in this action, _____________[3] raises all affirmative defenses as set forth in OCGA 9-11-8(c), to the extent each on is checked: [___] accord and satisfaction, [___] duress, [___] estoppel, [___] promissory estoppel, [___] payment, [___] set-off, [___] failure of consideration, [___] fraud, [___] illegality, [___] laches, [___] payment, [___] release, [___] res judicata, [___] statute of frauds, [___] statute of limitations, and [___] waiver. __________ DEFENSE By way of response to the specific allegations contained in Plaintiffs Complaint against _____________[4] and subject to all of the defenses set forth herein, _____________ [4] shows to this Court as follows: COMPLAINT 1. This Defendant is without sufficient knowledge or information to admit or deny this averment therefore this averment stands Denied. 2. This Defendant is without sufficient knowledge or information to admit or deny this averment therefore this averment stands Denied. JURISDICTION AND VENUE 3. This Defendant is without sufficient knowledge or information to admit or deny this averment therefore this averment stands Denied.

4. This Defendant is without sufficient knowledge or information to admit or deny this averment therefore this averment stands Denied. 5. This Defendant is without sufficient knowledge or information to admit or deny this averment therefore this averment stands Denied. 6. This Defendant is without sufficient knowledge or information to admit or deny this averment therefore this averment stands Denied. 7. This Defendant is without sufficient knowledge or information to admit or deny this averment therefore this averment stands Denied. 8. This Defendant is without sufficient knowledge or information to admit or deny this averment therefore this averment stands Denied. 9. This Defendant is without sufficient knowledge or information to admit or deny this averment therefore this averment stands Denied. 10. This Defendant is without sufficient knowledge or information to admit or deny this averment therefore this averment stands Denied. 3

Any paragraph of the Complaint not specifically admitted is hereby denied. WHEREFORE, Defendant, with regard to Plaintiffs Complaint, prays that this Court: 1) Deny all relief that Plaintiff prays for in its Complaint; and, 2) That Plaintiffs Complaint be dismissed with all costs of this action cast upon the Plaintiff. This _____ day of __________________, 20___.

Respectfully submitted,

_x______________________ _____________, Pro Se

___________________ ___________________ ___________________

Address and Phone Number of Defendant

[1] In Georgia, this will be either the SUPERIOR, or STATE or MAGISTRATE Court. [2] In Georgia, this will be one of the 159 Counties. For example, Fulton, DeKalb, Cobb, Gwinnett, Chatham, Muscogee, Bibb, etc. [3] Name of the Plaintiff who/that filed the suit. [4] Name of the Defendant(s), who/that have been sued. [5] This Number will be on the Complaint and Summons. It needs to be written or typed onto your Answer prior to filing. [6] An Answer is mandatory. Affirmative Defenses are not mandatory; however, if they are not raised in the initial answer they are waived. Additionally, if Defendant(s) chooses to file a Counterclaim, it should be listed (additionally) in this header. If you file a Counterclaim, you must ask for a Jury Trial at the time you file your Counterclaim or it is waived. Plaintiff may have already petitioned for one in the main Complaint. [7] Any box such as [___] indicates that Defendants should check any that apply. Or, if it retyped (which it should be), list only the Affirmative Defenses that apply.

IN THE _____________ [1] COURT OF ___________ [2] COUNTY STATE OF GEORGIA ) _____________________, [3] ) ) Plaintiff, ) ) ) ) ) vs. ) ) _____________________, [4] ) ) Defendant. ) ________________________________ )

CIVIL ACTION FILE NO. ________________ [5]

CERTIFICATE OF SERVICE OF _____________S ANSWER, and AFFIRMATIVE DEFENSES I hereby certify that I have served a copy of: _____________S ANSWER, and AFFIRMATIVE DEFENSES on the Plaintiff by placing a true and correct copy of same in the United States Mail, First Class, postage prepaid, addressed to the Defendants as follows: [Name and Address of Plaintiffs Attorney, or, if none Plaintiff]

This _____ day of __________________, 20___.

Respectfully submitted,

_x______________________ _____________, Pro Se

___________________ ___________________ ___________________

Address and Phone Number of Defendant