Sample Answer To Complaint

                     STATE OF TEXAS
                     COUNTY OF HARRIS

JENNY A. JONES                          CASE NO:95-45554-DM

VS                                      JUDGE: NORMAN MAILER

JOHN B.JONES                            ANSWER TO COMPLAINT

John Jones
2467 E Hill Rd
Houston, TX. 77001
TX: 713-695-6950
Attorney For Plaintiff
Jenny R. Joplin
8221 Longstreet
Houston, TX 77002
TX: 713-234-1212
Attorney For Defendant

Now comes the Defendant, John B. Jones, who answers Plaintiff’s Complaint for Divorce as follows:






6. NEITHER ADMITTED NOR DENIED, as your Defendant does not have sufficient knowledge to admit or deny this statement.


8. DENIED, for the reason that the statement is untrue: The Plaintiff is gainfully employed, and/or owns a business, as described in Plaintiff’s paragraph 6 of her complaint, and Plaintiff has sufficient income to pay her own attorneys fees.

9. ADMITTED IN PART, AND DENIED IN PART: Your Defendant is just as qualified as the Plaintiff to be the primary physical custodian of the minor children of the parties.
Further, Defendant agrees that the provisions of the Michigan Child Support Guidelines control the support to be paid between the parties, based upon the factors expressed therein.

WHEREFORE, Your Defendant prays that this Honorable Court will:

1. Equitably divide the property of the parties, and

2. Provide for the minor children of the parties, in a joint physical custody arrangement, with support according to the Texas Child Support Guidelines, and

3. Deny Plaintiff’s request for attorneys fees, and

4. Enter a judgment of divorce, and

5. Provide your Defendant such other, and further, relief, as your Defendant may show himself entitled to same.

Further, Defendant prays not.

[signature]John B. Jones.

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