ANSWER AND SPECIAL DEFENSES

Connecticut Superior Court – Small Claims Session

[// GUIDANCE: This template is designed for use in any Connecticut Small Claims matter. Customize all bracketed placeholders, delete inapplicable sections, and conform final filing to the clerk-issued Answer Date printed on the Small Claims Writ and Notice of Suit.]

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STATE OF CONNECTICUT
SUPERIOR COURT – SMALL CLAIMS SESSION
JUDICIAL DISTRICT OF [COURT LOCATION]

Docket No.: [CASE NUMBER]
Plaintiff: [PLAINTIFF NAME]
v.
Defendant: [DEFENDANT NAME]

Effective Date of Filing: [MM/DD/YYYY]
Answer Deadline: [MM/DD/YYYY] (as shown on court notice)

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I. DOCUMENT HEADER

1. Appearance. Defendant, [DEFENDANT NAME] (“Defendant”), hereby files this Answer, Special Defenses, and any Counterclaims in response to the Small Claims Writ and Notice of Suit dated [DATE OF PLAINTIFF’S COMPLAINT] (the “Complaint”).
2. Jurisdiction & Forum. This matter is properly before the Connecticut Superior Court, Small Claims Session pursuant to Conn. Practice Book Ch. 24.
3. Demand & Monetary Limit. Plaintiff seeks monetary damages not exceeding the small-claims jurisdictional limit of \$5,000 exclusive of interest and costs.

II. DEFINITIONS [Optional – delete if unnecessary]

“Complaint” The Small Claims Writ and Notice of Suit served upon Defendant.
“Court” The Connecticut Superior Court, Small Claims Session having venue over this action.
“Defendant” [DEFENDANT NAME]; “Plaintiff” means [PLAINTIFF NAME].

III. OPERATIVE PROVISIONS – ANSWERS TO COMPLAINT

[// GUIDANCE: Mirror each numbered allegation exactly as it appears in the Complaint, then select “Admit,” “Deny,” or “Lack Knowledge.”]

1. Paragraph 1 of the Complaint: [ADMIT / DENY / LACK SUFFICIENT INFORMATION].
2. Paragraph 2 of the Complaint: [ADMIT / DENY / LACK SUFFICIENT INFORMATION].
3. Continue until all allegations are addressed.

IV. SPECIAL DEFENSES (Affirmative Defenses)

Without assuming any burden of proof not otherwise imposed by law, Defendant asserts the following Special Defenses and reserves the right to amend, supplement, or withdraw any defense permitted under Connecticut law and the Connecticut Practice Book:

A. Failure to State a Claim. The Complaint fails to state a claim upon which relief can be granted.
B. Statute of Limitations. Plaintiff’s claim is barred, in whole or part, by the applicable statute(s) of limitation.
C. Payment / Accord and Satisfaction. The debt alleged has been satisfied, paid in full, or otherwise discharged.
D. Set-Off / Recoupment. Any liability of Defendant is subject to set-off or recoupment in an amount equal to or exceeding Plaintiff’s claim.
E. Lack of Standing. Plaintiff lacks standing or capacity to sue.
F. Lack of Subject-Matter Jurisdiction. The Court lacks jurisdiction over the subject matter because [EXPLAIN].
G. Improper Service. Service of process was defective in that [EXPLAIN].
H. Unclean Hands / Equitable Defenses. Plaintiff’s claims are barred by the doctrines of laches, waiver, or unclean hands.

[// GUIDANCE: Strike any defenses that do not apply; add additional defenses recognized under Connecticut law as needed.]

V. COUNTERCLAIM(S) (If Applicable)

[// GUIDANCE: Under Conn. Practice Book § 24-14, counterclaims may not exceed \$5,000 exclusive of interest and costs and must be related to the transaction or occurrence that is the subject of Plaintiff’s claim.]

1. Parties. Counter-Claimant is [DEFENDANT NAME]; Counter-Defendant is [PLAINTIFF NAME].
2. Basis of Counterclaim. On or about [DATE], Plaintiff breached [describe contract/obligation] by [facts].
3. Damages. As a direct result, Defendant incurred damages of \$[AMOUNT] plus lawful interest and costs.
4. Relief Requested. Judgment in favor of Defendant on the Counterclaim for \$[AMOUNT], interest, costs, and any other relief the Court deems just and proper.

VI. DEFAULT & REMEDIES

1. Prayer for Relief. Defendant respectfully requests:
   a. That Plaintiff take nothing by way of the Complaint;
   b. That judgment enter for Defendant, and, if applicable, on Defendant’s Counterclaim(s);
   c. That costs be taxed to Plaintiff; and
   d. Such other and further relief as equity and justice require.

VII. RISK ALLOCATION

[Not Applicable in Small Claims Answer – Intentionally Omitted]

VIII. DISPUTE RESOLUTION

Governing Law: Connecticut state law applies. The matter shall remain in the Small Claims Session absent transfer pursuant to Conn. Practice Book § 24-21. No jury trial is available unless and until the case is transferred to the regular docket.

IX. GENERAL PROVISIONS

1. Reservation of Rights. Defendant reserves all rights, claims, and defenses available under law or equity, and specifically reserves the right to amend this pleading.
2. Severability. If any part of this Answer is deemed invalid, the remaining portions shall remain in full force and effect.
3. Entire Answer. This document constitutes the Defendant’s complete response to the Complaint as of the Effective Date.

X. EXECUTION BLOCK

Respectfully submitted,

[DEFENDANT NAME], Pro Se
[STREET ADDRESS]
[CITY], CT [ZIP]
Telephone: [PHONE]
Email: [EMAIL]

Date: [MM/DD/YYYY]

VERIFICATION [Optional but recommended]

I, [DEFENDANT NAME], being duly sworn, depose and say that I have read the foregoing Answer, Special Defenses, and Counterclaim(s) and that the statements contained herein are true and correct to the best of my knowledge, information, and belief.

[DEFENDANT NAME]

Subscribed and sworn before me on [DATE].

Notary Public / Commissioner of the Superior Court
My Commission Expires: [DATE]

CERTIFICATE OF SERVICE

I hereby certify that a copy of the foregoing was mailed or electronically delivered to all parties of record as listed below on [MM/DD/YYYY].

• [PLAINTIFF NAME & ADDRESS]

[DEFENDANT NAME]

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[// GUIDANCE: File the original with the Clerk of Court on or before the Answer Date. Mail or otherwise serve a copy on the Plaintiff in accordance with the Connecticut Practice Book.]