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Date Posted: 16:41:36 12/13/05 Tue
Author: Randy Layman, Esquire
Subject: Re: DEFAULT JUDGMENT SET ASIDE
In reply to: Nikki 's message, "DEFAULT JUDGMENT SET ASIDE" on 13:00:04 12/09/05 Fri

Answer each numbered paragraph as (1) Admit (2) Deny as untrue. (3) Neither Admit nor Deny for the reason that I do not have personal knowlege of the facts alleged. Do it in the same format as the complaint (the top caption and the case number part) and all the number paragraphs 1. 2. 3. 4. 5. etc. Sign it with your name address and phone number. Get a separate sheet of paper. Title it "Affirmative Defenses". Number each reason and give some facts to back it up.

YOu say that you were overcharged and underserved.

That is breach of contract. Overcharging is breach of contract, perhaps. Maybe it is violation of Consumer Protection Act, put down both. Put down that there was no meeting of the minds as to prices. Put down that you did not receive all the services alleged. Put down that you did not consent to all the services alleged. Sign it with your name address and phone number.

file original signature versions with the court and send a copy to the attorney for the Plaintiff.

Then get yourself an attorney because you are going to get killed because you have no idea what you are doing or getting into.

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