IN THE JUSTICE COURT, PRECINCT 6
TARRANT COUNTY, TEXAS
INVESTMENT RETRIEVERS, INC. §
Plaintiff, §
§
v. § Case No. JP06-21-DC00015637
§
PATSY G. SANFORD aka PATSY L. § DEFENDANT’S ANSWER AND
SANFORD aka PATSY L. GUY-SANFORD § AFFIRMATIVE DEFENSES
aka PATSY GUY SANFORD aka PATSY §
SANFORD aka PATSY MCTIZIC §
Defendant(s) §
NOW COMES Patsy Sanford, Defendant, and files this Answer and Affirmative Defenses to Plaintiff’s Petition: Debt Claim Case, and hereby avers as follows:
DEFENDANT’S ORIGINAL ANSWER
- Pentagon Federal Credit Union (PenFed) did not issue a credit card in Defendant’s name under its account.
- Defendant did not use any credit card issued by PenFed.
- Defendant was not obligated to make payments for charges incurred on the credit card that Plaintiff purports was issued to Defendant.
- Defendant did not default on any obligation to make minimum monthly payments on the credit card account because no credit card was issued to her by PenFed.
DEFENDANT’S AFFIRMATIVE DEFENSES
- Plaintiff’s Petition fails to state claims upon which relief may be granted against Defendant.
- Plaintiff is not entitled to any damages as Defendant did not act or fail to act in a manner sufficient to give rise to damages liability.
- Defendant avers that this is a case of identity theft and has subsequently filed an FTC report as well as a police report.
- Defendant reserves the right to assert further affirmative defenses as they become evident through discovery investigation.
PRAYER
REASONS WHEREFORE, PREMISES CONSIDERED, Defendant prays that her 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 2nd day of January, 2022.
Respectfully Submitted,
___________________________________
Your Official Name
8775 Hunters Trl
Fort Worth, TX 76123
Defendant in pro per
VERIFICATION
I, _______________, being duly sworn depose and say that I am the Defendant in the above-entitled action, 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 ___________________, 2021.
______________________________
Notary Public
________________________________________
(Printed name of Notary Public)
My Commission Expires: ____________________
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing document was sent on the _____ day of January, 2022 by regular U.S. mail, by facsimile, or certified mail, return receipt requested, to the following parties or attorneys of record:
Carl Tucker
State Bar No. 20265100
Law Office of Carl Tucker, PLLC
2028 E Ben White Blvd #240-1650
Austin, Texas 78741
Tel: (866) 457-4107
Fax: (214) 594-7862
Attorney for Plaintiff
Dated this ____ day of ____________________, 2021.
Respectfully Submitted,
___________________________________
Your Official Name
8775 Hunters Trl
Fort Worth, TX 76123
Defendant in pro per
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