FEDERAL ANSWER – GENERAL DENIAL

(Template – Drafted for Universal Use in Any U.S. District Court)

[// GUIDANCE: This template is designed for use under the Federal Rules of Civil Procedure (“FRCP”). Replace every bracketed, ALL-CAPS item with matter-specific information. Delete any provisions that do not apply to your case.]

TABLE OF CONTENTS

1. Caption
2. Introductory Statement & General Denial
3. Specific Responses to Numbered Allegations
4. Affirmative Defenses
5. Prayer for Relief
6. Reservation of Rights
7. Jury Demand (optional)
8. Signature Block
9. Certificate of Service

1. CAPTION

IN THE UNITED STATES DISTRICT COURT
FOR THE [_] DISTRICT OF [_]

[PLAINTIFF FULL LEGAL NAME],
Plaintiff,

v. Civil Action No. [____]

[DEFENDANT FULL LEGAL NAME],
Defendant.

2. INTRODUCTORY STATEMENT & GENERAL DENIAL

Defendant [DEFENDANT], by and through undersigned counsel and pursuant to Fed. R. Civ. P. 8(b)(3), hereby answers the Complaint of Plaintiff [PLAINTIFF] as follows:

1. Except as expressly admitted herein, Defendant denies each and every allegation, matter, and statement contained in Plaintiff’s Complaint and denies that Plaintiff is entitled to any relief whatsoever.
2. Any allegation not specifically admitted is denied.

[// GUIDANCE: If local rules disfavor pure general denials, provide paragraph-by-paragraph responses using Section 3 below. Delete whichever approach is not used.]

3. SPECIFIC RESPONSES TO NUMBERED ALLEGATIONS

[// GUIDANCE: Duplicate as needed to match the Complaint’s numbering. “Lacks knowledge or information” language complies with Fed. R. Civ. P. 8(b)(5).]

Paragraph 1. Defendant [ADMITS / DENIES / LACKS KNOWLEDGE OR INFORMATION AND THEREFORE DENIES] the allegations of paragraph 1.
Paragraph 2. Defendant [ADMITS / DENIES / LACKS KNOWLEDGE OR INFORMATION AND THEREFORE DENIES] the allegations of paragraph 2.
…
Paragraph []. Defendant [ADMITS / DENIES / LACKS KNOWLEDGE OR INFORMATION AND THEREFORE DENIES] the allegations of paragraph [].

4. AFFIRMATIVE DEFENSES

Subject to Fed. R. Civ. P. 8(c)(1) and pled in the alternative under Fed. R. Civ. P. 8(d)(2)–(3), Defendant asserts the following Affirmative Defenses without conceding that it bears the burden of proof on any:

1. Failure to State a Claim – Fed. R. Civ. P. 12(b)(6).
2. Lack of Subject-Matter Jurisdiction – Fed. R. Civ. P. 12(b)(1).
3. Lack of Personal Jurisdiction – Fed. R. Civ. P. 12(b)(2).
4. Insufficiency of Service of Process – Fed. R. Civ. P. 12(b)(5).
5. Statute of Limitations.
6. Estoppel, Waiver, and/or Laches.
7. Accord and Satisfaction.
8. Failure to Mitigate Damages.
9. Privilege and Immunity (as applicable).
10. Unclean Hands.
11. Set-Off and/or Recoupment.
12. Reservation of Additional Defenses – Defendant reserves the right to assert additional defenses that become available through discovery.

[// GUIDANCE: Delete, add, or tailor defenses to the facts and governing law. List them in separately numbered paragraphs to avoid waiver.]

5. PRAYER FOR RELIEF

WHEREFORE, Defendant respectfully requests that the Court enter judgment:

a. Dismissing the Complaint with prejudice;
b. Awarding Defendant its costs and reasonable attorneys’ fees as permitted by law; and
c. Granting such other and further relief as the Court deems just and proper.

6. RESERVATION OF RIGHTS

Defendant reserves all rights, remedies, and defenses, whether legal, equitable, or otherwise, including those not expressly set forth herein, and nothing in this Answer shall be construed as a waiver of any such right.

7. JURY DEMAND (OPTIONAL)

Pursuant to Fed. R. Civ. P. 38(b), Defendant demands a trial by jury on all issues so triable.

[// GUIDANCE: Delete if no jury trial is sought.]

8. SIGNATURE BLOCK

Respectfully submitted this ___ day of [MONTH], 20__.

text
[LAW FIRM NAME]

By: /s/ [ATTORNEY NAME]
[ATTORNEY NAME]
[State] Bar No. [_]
[Address]
[City, State ZIP]
Telephone: [--_]
Email: [______]
Counsel for Defendant [DEFENDANT]

9. CERTIFICATE OF SERVICE

I hereby certify that on this ___ day of [MONTH], 20__, I electronically filed the foregoing Answer with the Clerk of Court using the CM/ECF system, which will automatically send notice of such filing to all counsel of record.
text
/s/ [ATTORNEY NAME]
[ATTORNEY NAME]

[// GUIDANCE:
1. Verify and comply with any local rule formatting (e.g., font size, page limits, caption style, signature requirements).
2. If verification is required (rare in federal practice), insert after the signature block in compliance with 28 U.S.C. § 1746.
3. Check court-specific rules for certificate of service language, margin settings, and courtesy-copy procedures.]