IN THE MAGISTRATE COURT OF ROCKDALE COUNTY
STATE OF GEORGIA
CERTIFIED ROOFING & GUTTERS )
Plaintiff, )
)
v. ) Case No. 2022-MAG-M15
)
LORENZO KILGORE )
Defendant. )
DEFENDANT’S ANSWER AND AFFIRMATIVE DEFENSES
NOW COMES Lorenzo Kilgore, and files this Answer and Affirmative Defenses, and hereby avers as follows:
Answer
In the Statement of Claim, Plaintiff states that Lorenzo has refused to pay the balance for new roof installation. Plaintiff also states that Defendant owes Plaintiff $2,500.00 plus costs of $500.00 Defendant denies this claim in its entirety.
Affirmative Defenses
Defendant does not owe any debt to Plaintiff.
Plaintiff is not entitled to any damages as Defendant did not act in any manner sufficient to give rise to damages liability.
Plaintiff has failed to mitigate its claims.
Defendant’s actions were in utmost good faith.
Defendant reserves the right to assert further affirmative defenses as they become evident through discovery investigation.
REASONS WHEREFORE, PREMISES CONSIDERED, Defendant prays that his answer be deemed good and sufficient and all claims by Plaintiff against Defendant be dismissed, with prejudice, and such further relief, legal and equitable, be awarded Defendant.
Dated this ____ day of April, 2022.
Respectfully Submitted,
___________________________________
Lorenzo Kilgore,
Defendant in pro per
VERIFICATION
I, Lorenzo Kilgore, being duly sworn depose and say that I have read the foregoing Answer and Affirmative Defenses and know the contents thereof. That the same is true of my own knowledge except as to those matters and things stated upon information and belief, and as to those things, I believe them to be true.
_________________________________
(Sign in the presence of a Notary Public)
Sworn to and subscribed before me this ___ day of April, 2022.
______________________________
Notary Public
________________________________________
(Printed name of Notary Public)
My Commission Expires: ____________________
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