[WSBAPT] hello/best practice question

TJW tjw at w3net.net
Sun Sep 3 17:36:41 PDT 2023


Hey Diane,

 

I would use the standard answer of: "Defendants lack information or belief
as to the truth or accuracy of the allegations in Section ___ of the
Complaint, and therefore deny the same." 

 

Sincerely,

 

Tom

 

Thomas J. Westbrook

Attorney at Law

 



324 West Bay Drive NW, Suite 201

Olympia, WA 98502

(360) 866-4000 phone

(360) 866--3832 fax

 <http://www.buddbaylaw.com/> www.buddbaylaw.com

 

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From: wsbapt-bounces at lists.wsbarppt.com <wsbapt-bounces at lists.wsbarppt.com>
On Behalf Of Diane J. Kiepe
Sent: Sunday, September 03, 2023 1:56 PM
To: 'WSBA Probate & Trust Listserv' <wsbapt at lists.wsbarppt.com>
Subject: [WSBAPT] hello/best practice question

 

I am hoping someone may be out there checking e-mails and have an off the
cuff answer.  

 

In a complaint where someone literally makes statements "upon information
and belief", I'm a little unsure how to deny that (how do we know).  My
thought was No Knowledge of the matter alleged and therefore denies the same
----- 

 

Any insights are appreciated.

 

Diane J. Kiepe

Douglas Eden, P.S.

717 W. Sprague Ave., Suite 1500

Spokane, WA  99201

djkiepe at depdslaw.com <mailto:djkiepe at depdslaw.com> 

509-455-5300

 

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