11.  Reimer Law denies for want of knowledge the allegations contained in Paragraph 11 of  Plaintiff's Complaint.  3   12.  Reimer Law admits that Mr. White co-signed several student loans for which his son was  the Borrower and denies for want of knowledge the remaining allegations contained in Paragraph  12 of Plaintiff's Complaint.   13.  Reimer Law denies for want of knowledge the allegations contained in Paragraph 13 of  Plaintiff's Complaint, and further answering admits that Reimer Law filed a collection suit to  resolve certain outstanding debts.   14.  Reimer Law denies for want of knowledge that the Student Loans were taken out  primarily for personal, family or household purposes, including Mr. White's son's college  education.   15.  Reimer Law denies for want of knowledge the allegations contained in Paragraph 15 of  Plaintiff's Complaint.   16.  Reimer Law denies for want of knowledge the allegations contained in Paragraph 16 of  Plaintiff's Complaint.   17.  Reimer Law admits that it filed lawsuits to resolve Mr. White and his son's outstanding  debts and further answering, admits that the complaint in the civil lawsuit speaks for itself.   18.  Reimer Law admits that it caused Mr. White to be served at his address in Jenera, Ohio  and that the summons and complaint for each of the collection suits speaks for themselves.  20.  Defendant Reimer Law admits that it is a law firm that at certain times represents clients  protecting their legal and equitable interests and to resolve outstanding debts, and denies as  stated the remaining allegations contained in Paragraph 20 of Plaintiff's Complaint.   21.  Reimer Law admits that it is a law firm that at certain times represents clients protecting  their legal and equitable interests and to resolve outstanding debts, and denies the remaining  allegations contained in Paragraph 21 of Plaintiff's Complaint.   22.  Reimer Law denies the allegations and conclusions of law contained in Paragraph 22 of  Plaintiff's Complaint and further denies that any class exists or is properly certifiable.   23.  Reimer Law denies the allegations and conclusions of law contained in Paragraph 23 of  Plaintiff's Complaint and further denies that any class exists or is properly certifiable.   24.  In response to the allegations contained in Paragraph 24 of Plaintiff's Complaint, Reimer  Law admits that White is attempting to assert certain class claims on behalf of himself and  others, but denies that any class exists or is properly certifiable.     25.  In response to the allegations contained in Paragraph 25 of Plaintiff's Complaint, Reimer  Law admits that White is attempting to assert certain class claims on behalf of himself and  others, but denies that any class exists or is properly certifiable.     26.  Reimer Law denies the allegations and conclusions of law contained in Paragraph 26 of  Plaintiff's Complaint, denies that the identity of each individual member of the class can be  ascertained from the Reimer Law firm's business records and/or from public records and denies  that the Plaintiff has any evidence to support the allegation that the proposed class is so  5  numerous.  It is purely speculative.  Further answering, denies that any class exists or is properly  certifiable.   27.  Reimer Law denies the allegations and conclusions of law contained in Paragraph 27 of  Plaintiff's Complaint and denies that any class exists or is properly certifiable.  Reimer Law  further denies that there are any questions of law and fact in common to the proposed class that  predominate over questions affecting any individual member, or legal or factual basis to support  a class action.   28.  Reimer Law denies that any class exists or is properly certifiable and further answering  states that it contains legal conclusions to which either requires no response or are denied.   29.  Reimer Law denies the allegations and conclusions of law contained in Paragraph 29 of  Plaintiff's Complaint, and denies that any class exists or is properly certifiable.   30.  Reimer Law denies the allegations and conclusions of law contained in Paragraph 30 of  Plaintiff's Complaint, and denies that any class exists or is properly certifiable.   31.  Reimer Law denies for want of knowledge whether Plaintiff's attorney is competent and  experienced in consumer protection and class action litigation and further answering denies that  any class exists or is properly certifiable.   32.  Reimer Law denies the allegations and conclusions of law contained in Paragraph 32 of  Plaintiff's Complaint, and denies that any class exists or is properly certifiable.    Defendant  Reimer Law further denies there is any legal or factual basis to support a class action. 