SUPREME COURT OF THE STATE OF NEW YORK

COUNTY OF DUTCHESS
________________________________________________X INDEX NO. 2006-7239
LR CREDIT 10, LLC,
Date Purchased:12/18/06
Plaintiffs,
-against-
ANSWER AND DEMAND
PURSUANT TO CPLR 3013
TIMOTHY F. PAULDINE 3015 (b), 3015 (e), 3016 (b),
26 FREIHOFFER LN 3016 (f)
LAGRANGEVILLE, NY 12540

Defendants,
________________________________________________X

Defendant, TIMOTHY F. PAULDINE, as and for his Answer to the

Complaint herein, allege (s) as follows:

1. Deny/Denies any knowledge or information sufficient to form a

belief as to each and every allegation contained in paragraph(s) numbered: “ONE”,

“THREE”, “FOUR”, and “FIVE”.

2. Deny/Denies any knowledge or information sufficient to form a

belief as to each and every allegation contained in paragraph(s) numbered: “TWO”,

except admits he is a resident of the County of Dutchess.

3. Deny/Denies upon information and belief each and every

allegation contained in paragraph(s) numbered” SIX”, “SEVEN”, and “EIGHT”,

“NINE”, “TEN”, and “ELEVEN”.

4. Demands that the plaintiff serve a complaint upon the defendant

pursuant to Civil Practice Laws and Rules Section setting forth with specificity the
allegation making up its complaint against the defendant pursuant to Civil Practice Laws

and Rules 3013, 3015 (b), 3015 (e), 3016 (b), and 3016 (f).

AS AND A FOR A FIRST AFFIRMATIVE DEFENSE, THIS ANSWERING

DEFENDANT ALLEGE(S):

5. That the court lacks jurisdiction of the person(s) of the defendant,

TIMOTHY F. PAULDINE.

6. That the plaintiff had a duty to mitigate their damages and failed to

do so by waiting so long to even contact the defendant with regards to any outstanding

debt.

WHEREFORE, this answering defendant(s) demand(s) judgment

dismissing the Complaint and other relief sought herein with costs.

Dated: Dutchess, New York

January 31, 2007

TIMOTHY F. PAULDINE
26 FREIHOFFER LN
LAGRANGEVILLE, NY 12540