Ben Baad
12345 Calle Real
Regal City, California

Defendant

SUPERIOR COURT OF CALIFORNIA

COUNTY OF ORANGE

Aima Hert,                       ) CASE NO. 	_________
                                 ) 		
          Plaintiff,             ) 
                                 ) ANSWER and
              vs.                ) AFFIRMATIVE DEFENSE
                                 ) (VERIFIED)
Ben Baad, and                    ) 
                                 ) Judge:  Joe Jedge
State of California,             ) Dept:   X666
                                 ) 
          Defendants.            ) 
                                 ) 
---------------------------------)------------------------------

ANSWER
Defendant Ben Baad answers the complaint of Aima Hert as follows:
1.  As to paragraph 1, deny.
2.  As to paragraph 2, admit.
3.  As to paragraph 3, no knowledge.
The remainder of the answer follows the above pattern.  For each paragraph in the action, the defendant denies, admits, or has no knowledge.
AFFIRMATIVE DEFENSE
4.  Defendant Ben Baad asserts the following defenses to Plaintiff Aima Hert’s action:
5.  Plaintiff’s action is barred by reason of latches, in that he has unreasonably delayed his suit to effect his benefit and Defendants disadvantage.
The affirmative defenses serve to provide factual and legal reasons why the Plaintiff’s action should fail.
6.  I am Ben Baad.  I am the defendant in this case.  I have personal knowledge of the foregoing facts and am competent to testify as to the truth of these facts if called as a witness.  I declare under penalty of perjury that the foregoing is true and correct, and that this declaration was executed in Tustin, California, on January 31, 2009.

Respectfully submitted

___________________________
Ben Baad