IN THE CIRCUIT COURT OF COUNTY, MISSISSIPPI

AND PLAINTIFFS
VS. NO.
DEFENDANTS
ANSWER AND DEFENSES
COMBS NOW , one of the defendants, by and through its attorneys of record, and
files this its Answer and Defenses to the complaint filed against it, towit!
"#$S% D&"&NS&
%he complaint filed herein fails to state a claim upon which relief can be granted, and this
defendant mo'es the court to dismiss the same pursuant to $ule ()* ,+*,+ of the Mississippi
$ules of Ci'il -rocedure.
S&COND D&"&NS&
Without wai'ing the right to first be heard in the foregoing defense, defendant , will
respond to the plaintiffs/ Complaint, paragraph by paragraph, as follows!
#.
%his defendant is without sufficient 0nowledge and information to form a belief as to the
truth of the allegations of paragraph # of the Complaint and, therefore, the same is denied.
##.
(. %his defendant is without sufficient 0nowledge and information to form a belief as
to the truth of the allegations of paragraph ##, subpart ( of the Complaint and, therefore, the same
is denied.
). %his defendant is without sufficient 0nowledge and information to form a belief as
to the truth of the allegations of paragraph ##, subpart ) of the Complaint and, therefore, the same
is denied.
1. %his defendant is without sufficient 0nowledge and information to form a belief as
to the truth of the allegations of paragraph ##, subpart 1 of the Complaint and, therefore, the same
is denied.
2. %his defendant is without sufficient 0nowledge and information to form a belief as
to the truth of the allegations of paragraph ##, subpart 2 of the Complaint and, therefore, the same
is denied.
3. %his defendant is without sufficient 0nowledge and information to form a belief as
to the truth of the allegations of paragraph ##, subpart 3 of the Complaint and, therefore, the same
is denied.
,. %his defendant is without sufficient 0nowledge and information to form a belief as
to the truth of the allegations of paragraph ##, subpart , of the Complaint and, therefore, the same
is denied.
4. %his defendant admits the allegations of paragraph #i, subpart 4 of the Complaint.
5. %his defendant is without sufficient 0nowledge and information to form a belief as
to the truth of the allegations of paragraph ##, subpart 5 of the Complaint and, therefore, the same
is denied.
###.
%his defendant denies the allegations of paragraph ### and all subparts of the Complaint.
#6.
%his defendant denies the allegations in paragraph #6 of the Complaint.
6.
%his defendant denies the allegations in paragraph 6 and all subparts of the Complaint.
6#.
%his defendant denies the allegations of paragraph 6# of the Complaint.
As to the allegations contained in the last unnumbered paragraph of the Complaint,
beginning with the word 7W8&$&"O$&7, this defendant denies that the plaintiffs are entitled to
9udgment in the amount prayed for or in any amount whatsoe'er and demands to be dismissed
here from with pre9udice.
%8#$D D&"&NS&
Any and all other allegations contained in the Complaint not heretofore specifically
answered are hereby denied.
AND NOW, ha'ing responded to the allegations of the plaintiffs/ Complaint, paragraph by
paragraph, and ha'ing denied all liability in the premises, this defendant would show unto the
Court the following special and affirmati'e matters!
"#$S% A""#$MA%#6& D&"&NS&
%he plaintiffs/ claim is barred by the applicable statute of limitations.
W8&$&"O$&, -$&M#S&S CONS#D&$&D, this defendant demands to be
dismissed here from with pre9udice with all costs being incurred by the plaintiff.
$espectfully submitted,
:::::::::::::::::::::::::::::::::::::::

Attorney for
Of Counsel!




%elephone!
MSB ;
Attorney for
C&$%#"#CA%& O" S&$6#C&
#, , of counsel for , do hereby certify that # ha'e this day mailed a true and
correct copy of the abo'e and foregoing ANSW&$ AND D&"&NS&S to!

%his the day of , .
::::::::::::::::::::::::::::::::