STATE COURT OF COBB COUNTY
STATE OF GEORGIA
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)
WELLS FARGO & COMPANY, Civil Action File No. VS12345
Plaintiff,
vs.
THOMAS A. SMITH, JR.
Defendant.
ANSWER OF THOMAS A. SMITH, JR.
COMES NOW THOMAS A. SMITH, JR., defendant in the above-styled civil action and files this Answer to plaintiff=s Complaint as follows:
First Defense
Plaintiff’s Complaint, including each Count thereof, fails to state a claim against defendant Thomas A. SMITH, Jr. upon which relief can be granted.
Second Defense
Defendant Thomas A. SMITH, Jr. incorporates herein by reference all O.C.G.A. ‘9-11-8(c) defenses not set forth above to the full extent applicable and asserts on grounds of said affirmative defenses that Plaintiff’s Complaint should be dismissed.
Third Defense
Defendant denies each and every allegation, whether express or implied, not otherwise specifically addressed herein.
Fourth Defense
Defendant answers the specific allegations of plaintiff’s Complaint as follows:
1.
Admitted.
2.
Denied.
3.
Denied.
4.
Denied.
5.
Denied.
6.
Denied.
WHEREFORE, defendant prays that plaintiff’s Complaint against her be dismissed with prejudice, with all costs assessed against plaintiff, and that defendant have such other and further relief as is just and proper.
This ______ day of May, 2011.
_________________________________
THOMAS A. SMITH, JR.
Pro Se
123 Hummingbird Lane
Duluth, GA 30096
CERTIFICATE OF SERVICE
I hereby certify that I have this day served the foregoing Answer upon counsel for all parties by depositing a copy of same in the United States mail in an envelope with sufficient postage thereon addressed as follows:
Scott M. Williams
Engulf, Devour & Assoc.
2970 Peachtree Rd. NW
Atlanta, GA 30305-2191
This _______ day of May, 2013.
___________________________
Thomas A. SMITH, Jr.
Pro Se
3937 Hummingbird Lane
Duluth, GA 30096