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  ANSWER COMES NOW the defendant, by undersigned counsel, and inanswer to plaintiff's complaint, respectfully alleges: 1. That defendant admits paragraphs  _____, _____  and  ____  of the complaint; 2. That defendant is without knowledge or information to form abelief as to the truth of the averments made in paragraphs  _____, _____  and  ____  thereof; 3. That defendant DENIES specifically each and every materialallegations made in paragraphs  _____, _____  and  ____  of the complaint, and alleges that (here state the substance of the matterswhich defendant will rely upon to support such specific denial); 4. And as AFFIRMATIVE DEFENSES, the defendant alleges:  A. That (here state as many affirmative defenses asdefendant may have. All such grounds as would raiseissues of facts not arising upon specific denials must bespecifically pleaded. which may have basis in theprovisions of STATUTE OF LIMITATIONS, STATUTE OFFRAUDS, ESTOPPEL, RELEASE OR DISCHARGE,ETC.) B. That (state other defenses): 5. As COUNTERCLAIM against the plaintiff, the defendantalleges:  A. That defendant reproduces paragraphs  _____, _____ and  ____  of the plaintiff's complaint; B. That (state defendant's claim for money or other relief which he may have against the plaintiff; suchcounterclaims need not diminish or defeat the recoverysought by the plaintiff, but may claim relief exceeding inamount or different in kind from that sought by theplaintiff, provided that the court has jurisdiction toentertain the claim); WHEREFORE, it is respectfully prayed that: (a) Prayer (for judgment in favor of defendant with respectto plaintiff's complaint);  (b) Prayer (for judgment in favor of defendant with respectto counterclaim); and (c) For such other relief consistent with law and equity,and for costs.  Agoo, La Union,  _______________ , 20 __    _____________________ Counsel for the Defendant _____Address    ___________  _____IBP No.__________  _____Roll No.___________  _MCLE Compliance No.___ - - - - - - - - - -- - - - - -- - - - -- - - --RULE 6: KINDS OF PLEADINGSSEC. 4. Answer.- An answer is a pleading in which a defending partysets fourth his defenses. (4a)SEC. 5. Defenses.- Defenses may either be negative or affirmative.(a) A negative defense is the specific denial of the material factor facts alleged in the pleading of the claimant essential to his causeor causes of action.(b) An affirmative defense is an allegation of a new matter which, while hypothetically admitting the material allegations in thepleading of the claimant would nevertheless prevent or bar recoveryby him. The affirmative defenses include fraud, statute of limitations,release payment, illegality, statute of frauds, estoppel, former recovery, discharge in bankruptcy, and any other matter by way of confession and avoidance. (5a)SEC. 6. Counterclaim.—A counterclaim is any claim which adefending party may have against an opposing party. (6a)

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Sep 10, 2019

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Sep 10, 2019
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