SAMPLE PLEADING (ANSWER)

JOHN W. JONES

Plaintiff

AT LAW NO. 12346

XYZ CORPORATION

Defendant

ANSWER

COMES NOW the defendant, XYZ Corporation, by counsel, Robert S. Jones, and respectfully submits the following as his Answer to Plaintiff=s Motion for Judgment:

1) Defendant admits the allegations contained in Paragraphs One and Two of

the plaintiff=s Motion for Judgment.

2) Defendant denies the allegations contained in Paragraph Three of the

Plaintiff=s Motion for Judgment and states that the plaintiff=s detention was based on

just legal cause.

3) Defendant denies the allegations contained in Paragraph Four of the

plaintiff=s Motion for Judgment and states that a socket wrench was found in the

corner of the area in which the plaintiff was first seen in the store.

4) Defendant denies the allegations contained in Paragraph Six of the

plaintiff=s Motion for Judgment and states that the furtive activity by the plaintiff

gave the store manager probable cause to believe that he was stealing merchandise.

5) Defendant is without sufficient information upon which either to admit or

deny the allegations contained in Paragraph Seven of the plaintiff=s Motion for

Judgment and therefore demands strict proof thereof.

WHEREFORE, the defendant respectfully moves that the plaintiff=s Motion

for Judgment be dismissed.

___________________________

XYZ CORPORATION

JOHN G. EDWARDS

Store Manager

By Counsel

Submitted by:

_______________________

ROBERT S. JONES

Counsel for the defendant

2000 Side Street #1

Vienna, VA 11111

(703)555-3333

CERTIFICATE OF SERVICE

I hereby certify that a copy of the foregoing Answer was mailed, postage prepaid, to counsel for the plaintiff, T. Robbins Joyner, 1000 Main Street, #111, Fairfax, VA 22222 this ___ day of ____________, 2002.

___________________________

ROBERT S. JONES