BEASLEY, Judge.
Appellee brought suit against "M. Ray Hodges Plumbing & Electric Co.," alleging indebtedness on an account and two other counts. The complaint also sought attorney fees and punitive damages for stubborn litigiousness. Hodges answered, denying all allegations, asserting several defenses, and counter claiming for a set-off in any indebtedness. In June 1984, the defendant moved for summary judgment on its first three defenses: failure to state a claim...
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