Need Review for answering a summons

[funnyandnice]

Hi there,

I would like a review of my wifes answer to a summons. A little background...

The summons was one page and only stated ..breach of contract in the amount of $xxxx.xx plus interest and legal fees

And that was it, one page with a few lines other than case #, plaintiff and defendant. There were no allegations listed

I had a consultation with Kristy of this site and said I should do a answer and a motion to dismiss due to improper venue. I will post that in a diff. thread.

Here is what I have for the Answer, please advise if this is good enough or if I should change any of the language. Obviously, I deleted any personal info related to the case.

Answer to a Summons

Collectio Agency, LLC

Plaintiff

Vs.

My Beautiful wiFe

Defendant

xxxxxxxxxxx answers the complaint by stating and showing that:

1. There is insufficient evidence to affirm or deny the complaint and demand strict proof.

AS AND FOR AFFIRMATIVE DEFENSES

2. Plaintiff fails to state a cause of action against the defendant.

3. Plaintiff, as the defendant is informed and believes, lacks the legal standing to bring and maintain this action.

4. The action is barred by the Statute of Frauds.

5. The action is barred by the Statute of Limitations.

6. The court would unjustly enrich the plaintiff by granting the relief sought herein.

WHEREFORE, the defendant asks the Court for judgment:

a. dismissing the complaint herein,

b. such other and different relief as the Court finds proper.

Thanks in advance!

[admin]

I would add in the affirmative defenses about the improper venue.