Paul Andrew Mitchell, Sui Juris Citizen of Arizona state c/o General Delivery at: 2509 North Campbell Avenue Tucson, Arizona state In Propria Persona All Rights Reserved Without Prejudice PIMA COUNTY CONSOLIDATED JUSTICE COURT Paul Andrew Mitchell, ) Case Number #CV-97-3438 Plaintiff ) ) ANSWER TO COUNTERCLAIM v. ) ) Neil and Evelyn Nordbrock, ) Defendants ) ___________________________) COMES NOW Paul Andrew Mitchell, Sui Juris, Citizen of Arizona state and Plaintiff in the above entitled matter (hereinafter "Plaintiff"), to provide this, Plaintiff's ANSWER TO COUNTERCLAIM by Defendants. I Plaintiff specifically denies each and every allegation in the Counterclaim, whether numbered or unnumbered. II Plaintiff specifically denies the allegation that Plaintiff committed "Defamation Per Se" against Defendants. III Plaintiff specifically denies the allegation that Plaintiff committed "Tortious Interference with Business Advantage and/or Contractual Relationship" against Defendants. Answer to Counterclaim: Page 1 of 3 IV Plaintiff relies upon the truth to support Plaintiff's verified complaint against Defendants, and Plaintiff's defense against the Counterclaim of Defendants. Wherefore, Plaintiff requests judgment against Defendants: (1) awarding to Plaintiff the exact amount specified in the original Complaint; (2) awarding legal fees pursuant to A.R.S. 12-341.01(A) and (C) and 349; (3) awarding recoverable costs pursuant to A.R.S. 12-341; (4) dismissing Defendants' Counterclaim with prejudice and denying all relief requested therein; (5) awarding such other and further relief as the Court deems just and proper. OBJECTION TO REPRESENTATION Plaintiff hereby enters a permanent, standing objection to the conflict of interest which is now evident in Defendants' representation in this honorable Court by Mr. Lawrence E. Condit, for reasons which have already been filed in Plaintiff's AFFIDAVIT OF DEFAULT AND OF PROBABLE CAUSE IN RE LAWRENCE E. CONDIT, which is incorporated by reference as if set forth fully herein. Dated: April 23, 1997 Respectfully submitted, /s/ Paul Andrew Mitchell _____________________________________ Paul Andrew Mitchell, Sui Juris Citizen of Arizona state All Rights Reserved without Prejudice Answer to Counterclaim: Page 2 of 3 PROOF OF SERVICE I, Paul Andrew Mitchell, Sui Juris, hereby certify, under penalty of perjury, under the laws of the United States of America, without the "United States," that I am at least 18 years of age, a Citizen of one of the United States of America, and that I personally served the following document(s): ANSWER TO COUNTERCLAIM by placing one true and correct copy of said document(s) in first class United States Mail, with postage prepaid and properly addressed to the following: Neil and Evelyn Nordbrock c/o 6642 E. Calle de San Alberto Tucson, Arizona state Executed on April 23, 1997 /s/ Paul Andrew Mitchell _____________________________________ Paul Andrew Mitchell, Sui Juris Citizen of Arizona state All Rights Reserved without Prejudice Answer to Counterclaim: Page 3 of 3 # # #
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Mitchell v. Nordbrock