Unverified Answer Form

[Attorney name] [Address] [Telephone number] Attorney for Defendant, [name] xxx Court, County of xxx [xxx District] xxxxxx ) No. xxx Plaintiff(s) ) vs. ) ANSWER TO COMPLAINT ) xxxxxx ) Defendant(s) ) __________________________________) Defendant, [name], answers the complaint of plaintiff, [name], in this action as follows: RESPONSE TO PRELIMINARY ALLEGATIONS 1. Answering paragraph 1, defendant is without sufficient information or belief to admit or deny the allegations in this paragraph. Based on this lack of information or belief, defendant denies the allegations. 2. Answering paragraph 2, defendant admits that he is an individual residing in xxx County, California. Defendant denies the remaining allegations in this paragraph. 3. Answering paragraph 3, defendant admits [specify]. Defendant denies the remaining allegations in this paragraph. 4. Answering paragraph 4, defendant admits that plaintiff is an individual. Defendant is without sufficient information or belief to admit or deny the remaining allegations in this paragraph. Based on this lack of information or belief, defendant denies the remaining allegations. 5. Answering paragraph 5, defendant denies the allegations in this paragraph. RESPONSE TO FIRST CAUSE OF ACTION 6. Answering paragraph 6, defendant realleges and incorporates by reference the admissions, allegations, and denials in paragraphs 1 through 5 of this answer. 7. Answering paragraph 7, defendant denies the allegations in this paragraph. 8. Answering paragraph 8, defendant denies the allegations in this paragraph. 9. Answering paragraph 9, defendant admits [specify]. Defendant denies the remaining allegations in this paragraph. RESPONSE TO SECOND CAUSE OF ACTION 10. Answering paragraph 10, defendant realleges and incorporates by reference the admissions, allegations, and denials in paragraphs 1 through 9 of this answer. 11. Answering paragraph 11, defendant is without sufficient information or belief to admit or deny the allegations in this paragraph. Based on this lack of information or belief, defendant denies the allegations. 12. Answering paragraph 12, defendant denies the allegations in this paragraph. FIRST AFFIRMATIVE DEFENSE Other Action Pending 13. This action is barred by a prior action pending before this Court which involves the same transactions, issues, parties, and property that are the subject of the complaint. The other action is presently pending in this branch, Case No. xxx, filed by plaintiff against defendant. Both parties to this complaint have appeared in the other action. Defendant requests that the Court take judicial notice of the other action under Evidence Code section 452. A copy of the complaint in that action, filed [date], is attached as Exhibit A. SECOND AFFIRMATIVE DEFENSE Lack of Standing 14. This complaint is barred by the fact that plaintiff lacks standing to bring an action. Plaintiff is not a party to the transaction and is not connected to the transaction. Defendant owes no duty to respond to plaintiff's allegations regarding the transaction. THIRD AFFIRMATIVE DEFENSE Fails To State Cause of Action 15. The complaint is barred by plaintiff's failure to state a cause of action against defendant. FOURTH AFFIRMATIVE DEFENSE Laches 16. The complaint is barred in whole or in part by laches. FIFTH AFFIRMATIVE DEFENSE Unclean Hands 17. The complaint is barred in whole or in part by plaintiff's unclean hands. SIXTH AFFIRMATIVE DEFENSE Equitable Estoppel 18. The complaint is totally barred by plaintiff's role in the transactions that are the subject of the other action pending, the complaint in which is attached as Exhibit A. SEVENTH AFFIRMATIVE DEFENSE Indemnity 19. If any liability exists on the part of defendant to plaintiff, such liability is to be completely indemnified by [name]. EIGHTH AFFIRMATIVE DEFENSE Offset 20. Any amount sought to be recovered in this action is barred in whole or in part by the amount owing from plaintiff to defendant. WHEREFORE, defendant requests judgment as follows: 1. That plaintiff take nothing by the complaint, which will be dismissed with prejudice. 2. That defendant recover from plaintiff costs in the amount of $ xxx. 3. That the Court order further reasonable relief. Date: xxx ________________________ [Typed name] Attorney for xxxxxx