COURT OF HARRISON COUNTY, MISSISSIPPI

Case No. D2401-26-1272

Citibank, N.A., Plaintiff

v.

Zohreh Zoofan, Defendant

DEFENDANT'S ANSWER

Responses to Allegations

For each numbered paragraph of the Plaintiff's Complaint, the Defendant either admits, denies, or states that she lacks sufficient knowledge to admit or deny.

1. Plaintiff alleges that Defendant entered into a credit agreement with Plaintiff on or about January 15, 2020, and that Defendant received and used the credit card account number ending in 4821.

2. Plaintiff alleges the amount currently due and owing on the account is $8,256.98, together with interest and costs.

3. Plaintiff alleges that Defendant defaulted on the credit agreement by failing to make the required monthly payments and that the balance is immediately due and payable.

4. Plaintiff alleges that all conditions precedent to Plaintiff's right to bring this action have been satisfied.

5. Plaintiff alleges that Defendant is not a member of the military service within the meaning of the Servicemembers Civil Relief Act.

Affirmative Defenses

The Defendant raises the following affirmative defenses, each of which is incorporated by reference:

  1. Improper service of the summons and complaint.
  2. The claim is barred by the three-year statute of limitations (Miss. R. Civ. P. 12(b)(6)).
  3. Payment in full was made on __________; attached is proof of payment.
  4. Plaintiff lacks standing as an authorized creditor.
  5. Waiver and release - Defendant previously settled the account on __________.
  6. Set-off - Defendant has a valid counter-claim for __________.
  7. Failure to state a claim upon which relief can be granted.

Prayer for Relief

WHEREFORE, Defendant respectfully requests that this Honorable Court:

  1. Dismiss Plaintiff's Complaint with prejudice;
  2. Enter judgment in favor of Defendant for $0.00;
  3. Award Defendant the costs of this suit and reasonable attorney's fees, if any;
  4. Grant such other relief as the Court deems just and proper.

Respectfully submitted,

Zohreh Zoofan

550 W Magnolia St Apt 8

Gulfport, MS 39507

(555) 555-1234

z.zoofan@email.com

Date:

Verification

I, Zohreh Zoofan, hereby verify that the foregoing is true and correct to the best of my knowledge, information, and belief, and that I understand that false statements are punishable as perjury under Mississippi law.

Signature:  

STATE OF MISSISSIPPI)SS:COUNTY OF HARRISON)

Subscribed and sworn to before me this day of , 2026.

Notary Public

My commission expires: