Pro Se Defendant Writes The Answer Every Lawyer Wishes They Could

The best answer to a federal complaint you'll read all year.

You’ve probably seen this complaint before. Okay, sure not this exact complaint (probably), but the essence of it. It’s a complaint about unfair competition, alleged extortion, defamation and related counts that reads like a schoolyard rivalry. Maybe you’ve even had this misfortune to be charged with drawing up the answer to a complaint filled with the details of a petty feud. If so, you’ll appreciate this pro se defendant’s approach.

Oxbridge Quality Resources and Christopher Paris are suing Marc Smith and his company, Cayman Business Systems. Paris and Smith do not appear to like one another. Both in the business consulting space, they have allegedly tussled over social media and message boards (including one that Smith operates, or at least used to operate prior to his retirement) regarding practices and business models. But none of that is important or even necessary to appreciate the beauty of Smith’s answer to this federal complaint.

Reading like a mark-up some poor junior associate is forced to translate after a partner’s long drunken weekend in the Hamptons, the filed document is just a copy of the complaint with Smith’s handwritten notes all over. Mostly just a few words strung together so you get a sense of how he’s really feeling on a particular point.

For instance, Smith takes umbrage at the notion that his business was in competition with Paris’s:

“NEVER.” “NO.” I have to say I appreciate Smith’s style and “straight shooting” method instead of the overly formulaic and verbose way lawyers would say, well, pretty much the exact same thing.

“I have no idea who these people/companies are.” Is Smith having a senior moment? Or is this the most effective denial ever?

HAHAHAHAHAHAHAHA all over your complaint! The full complaint is replete with these short outbursts that really speak to the former litigator in me on a visceral level.

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I’m really appreciating the use of the ‘nope’ meme in a filing. So unexpected, so enjoyable.

Now we get into the name calling section of the document:

I told you these folks didn’t seem to like one another!

And the initial complaint also alleges defamatory content on the website Smith operates about Paris. Seems Paris believes the Google-fu is strong in this one:

Coming up the back end of this filing, Smith has taken to short but effective refutations.

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This is what passes as restraint in this answer, because you know he wanted to write bulls**t.

“Nobody likes you.” Yeah, I told you this read like a schoolyard fight. I bet his momma also wears combat boots.

We’re trudging towards the end of the allegations against Smith and this plea, “gimme a break,” reads like pure exhaustion — or he yearns for the 80s sitcom featuring Nell Carter. Either way.

Slow golf clap to Mr. Smith — I am not sure it was super-effective as a legal strategy, but his answer made me chuckle.

Read the fully annotated version of the answer on the next page.