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Law Firm

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Submitted By jennyd153
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ARIZONA SUPERIOR COURT
MARICOPA COUNTY
GEORGIA ANN TUCKER,
Plaintiff,
vs.
HARRY JOE CLYDE,
Defendant Case No.: 000-55-6659
ANSWER

JURISDICTIONAL ALLEGATIONS

1. Defendant lacks sufficient information to form a belief as to the truth of the allegations contained in Paragraph 1 of Plaintiff’s Complaint.
2. Defendant admits he is a resident of Morris, Oklahoma, Defendant denies allegations in Paragraph 2 of Plaintiff’s Complaint.

GENERAL ALLEGATIONS
(BREACH OF PROMISE)

3. Defendants admits allegations of Plaintiff and Defendant agreeing to marry each other in Paragraph 3 of Plaintiff’s complaint.
4. Defendant denies allegations in Paragraph 4 of Plaintiff’s Complaint.
5. Defendant admits he refused to marry Plaintiff. Defendant denies allegations of forcing Plaintiff and children to leave planned marital residence in Arizona, forcing them to return Oklahoma in Paragraph 5 of Plaintiff’s Complaint
6. Defendant denies allegations in Paragraph 6 of Plaintiff’s Complaint.
7. Defendant denies allegations of intentional or reckless disregard in Paragraph 7 of Plaintiff’s Complaint.
COUNT TWO
(TORT)

8. Defendant denies allegations in Paragraph 9 of Plaintiff’s Complaint
9. Defendant denies allegations in Paragraph 10 of reckless disregard Plaintiff’s Complaint
10. Defendant denies allegations in Paragraph 11 of Plaintiff’s Complaint.

NEW MATTER AND AFFIRMATIVE DEFENSE

Although denying that the Plaintiff is entitled to the relief prayed for in the Plaintiff’s complaint, Defendant further states that the Plaintiff is barred from recovery by reasons of the following:
1. That the Plaintiff’s injuries were proximately caused by her own contributory negligence and want of due care under the circumstances prevailing at the time of the breach of promise.
2. That the Plaintiff was not only aware of prenuptial agreement but, asked that the

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