[COURT NAME]
[COUNTY], [STATE]

[PLAINTIFF NAME], )
Plaintiff, )
) Case No. [CASE NUMBER]
v. )
)
[DEFENDANT NAME], )
Defendant. )

ANSWER AND AFFIRMATIVE DEFENSES

1. Responses to Allegations

1.1 In response to Paragraph 1, Defendant [ADMITS/DENIES/LACKS KNOWLEDGE].
1.2 In response to Paragraph 2, Defendant [ADMITS/DENIES/LACKS KNOWLEDGE].
1.3 In response to Paragraph 3, Defendant [ADMITS/DENIES/LACKS KNOWLEDGE].
[Continue for each numbered paragraph of the complaint.]

2. General Denial (If Permitted)

Defendant denies each and every allegation not expressly admitted.

3. Affirmative Defenses

Without admitting any liability, Defendant asserts the following affirmative defenses:
☐ Failure to state a claim
☐ Statute of limitations
☐ Lack of standing
☐ Lack of jurisdiction
☐ Payment or accord and satisfaction
☐ Waiver, estoppel, or laches
☐ Comparative or contributory negligence
☐ Failure to mitigate damages
☐ Unclean hands
☐ Release or settlement
☐ Arbitrability or contractually required ADR
☐ Statutory caps or limitations on damages
☐ Other: [SPECIFY]

4. Prayer for Relief

Defendant requests that the Court:
a. Dismiss the complaint with prejudice.
b. Award costs and attorney fees where allowed.
c. Grant any other relief the Court deems just.

5. Jury Demand

Defendant demands a trial by jury on all issues so triable.

6. Signature Block

text
Dated: [DATE]

______________________________
[ATTORNEY NAME]
[LAW FIRM]
[ADDRESS]
[PHONE]
[EMAIL]
Attorney for Defendant