Form 1.968 Defense. Failure of Consideration
The sole consideration for the execution and delivery of the promissory note described in paragraph ………. of the complaint was plaintiff’s promise to lend defendant $1,000; plaintiff failed to lend the sum to defendant.
NOTE: This form is for failure to complete the loan evidenced by a promissory note. The contract, consideration, and default of the plaintiff must be varied to meet the facts of each case.