Free Answer to Counterclaim - District Court of Delaware - Delaware

Case 1:07-ov—00129-I\/| PT Document 8 Filed 04/17/2007 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE g
SHANNON A. LAYMON, i C.A. No. 07-129-*** I
Plaintiff, *
v. ; g
LOBBY HOUSE, INC., * §
a Delaware corporation, I TRIAL BY JURY DEMANDED g
Defendant. * g
ANSWER TO COUN ERCLAIM
l. This paragraph is nonsensical as stated and therefore
denied. g
2. This paragraph is nonsensical as stated and therefore §
denied. %
3. This paragraph is nonsensical as stated and therefore g
denied.
4. Denied. Q
5. Denied. é
6. Denied. l
7. Denied. ?
AFFIRMATIVE DEFENSES g
l. Defendant's counterclaim fails to state a claim upon E
which relief may be granted. y
2. Plaintiff may assert other affirmative defenses to 1
Defendant’s counterclaim hereafter as it appears appropriate. Q

Case 1:07-cv—00129-I\/IPT Document 8 Filed 04/17/2007 Page 2 of 2
WHEREFORE, Plaintiff respectfully requests that Defendant‘s
Counterclaim be dismissed. with prejudice, with costs and
attorneys' fees assessed against Defendant.
SCHMITTINGER & RODRIGUEZ, P.A.
BY: Q E
NOEL E. PRIMOS, ESQUIRE
Bar I.D. #3124
4l4 S. State Street
P.O. Box 497
Dover, DE 19903
(302) 674~0l40
Attorneys for Flaintiff
DATED:£f$ ·/”/—·g’Y

Case 1:07-cv—OO129-IVIPT Document 8-2 Filed 04/17/2007 Page 1 of 1
CERTIFICATE OF SERVICE
I hereby certify that I have caused a copy of the following:
ANSWER TO COUNTERCLAIM
to be served upon: RONALD G. POLIQUIN, ESQUIRE
Young, Maimberg & Eoward, P.A.
30 The Green
Dover, DE 19901
by electronic service on {1L&;kQ{ {P7 , 2007.
SCHMITTIN R & ]?RIGUEZ, RA.
BY; x x A 4.....-.
NOEL . PRIMOS, ESQUIRE
Bar rn. #3124
414 S. State Street
P.O. Box 497 1
Dover, DE 19903
(302) 674—0140
DATED:Lf..\’7,_,O:7