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DEFENDANT’S ANSWER AND AFFIRMATIVE DEFENSES – 1
Matthew Skinner
426 Mountain Wasp Dr.
Biltmore Lake, NC 28715-8912
Phone | Fax
Email
Defendant in pro per
IN THE GENERAL COURT OF JUSTICE
COUNTY OF BUNCOMBE
DISTRICT COURT DIVISION
BANK OF AMERICA, N.A.,
Plaintiff,
vs.
MATTHEW SKINNER,
Defendant
Case No.: CVD 22CV 02835
DEFENDANT’S ANSWER AND
AFFIRMATIVE DEFENSES
NOW COMES Matthew Skinner, Defendant, and files this Answer and Affirmative
Defenses to the Complaint filed by Plaintiff, and hereby avers as follows:
Original Answer
1. Defendant admits the allegation in ¶ 1 of the Complaint.
2. Defendant admits the allegation in ¶ 2 of the Complaint.
3. Defendant admits the allegation in ¶ 3 of the Complaint.
4. ¶ 4 of the Complaint contains a legal conclusion that does not require the answer
of Defendant.
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DEFENDANT’S ANSWER AND AFFIRMATIVE DEFENSES – 2
5. Defendant admits the allegation in ¶ 5 of the Complaint.
6. Defendant denies the allegation in ¶ 6 of the Complaint.
7. Defendant denies the allegation in ¶ 7 of the Complaint.
8. Defendant denies the allegation in ¶ 8 of the Complaint.
9. Defendant denies the allegation in ¶ 9 of the Complaint.
Affirmative Defenses
10. Plaintiff’s Complaint fails to state claims upon which relief may be granted
against Defendant.
11. Plaintiff’s Complaint fails to state a cause of action.
12. Plaintiff has failed to mitigate its alleged damages.
13. Plaintiff has brought inaccurate information to prove its case. For instance, the
payment history at page 13 of the packet sent by Plaintiff does not reflect payment of $150 on
07/30/2022 for account no. 21138661.
14. Defendant’s actions were in utmost good faith.
15. Defendant reserves the right to assert further affirmative defenses as they become
evident through discovery investigation.
Prayer
REASONS WHEREFORE, PREMISES CONSIDERED, Defendant prays that his
Answer and Affirmative Defenses be deemed good and sufficient and all claims by Plaintiff
against Defendant be dismissed, with prejudice, and such other further relief, legal and equitable,
be awarded Defendant.
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DEFENDANT’S ANSWER AND AFFIRMATIVE DEFENSES – 3
Dated this ___ day of August, 2022.
Respectfully Submitted,
_________________________________
Matthew Skinner,
Defendant in pro per
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