State Court Answer - General Denial - Arkansas

IN THE CIRCUIT COURT OF [COUNTY] COUNTY, ARKANSAS

☐ DIVISION

PLAINTIFF: [PLAINTIFF NAME]
DEFENDANT: [DEFENDANT NAME]

Case No.: ☐

DEFENDANT’S ORIGINAL ANSWER

(GENERAL DENIAL PURSUANT TO ARK. R. CIV. P. 8(b))

I. APPEARANCE, JURISDICTION, AND VENUE

1. Defendant appears through the undersigned counsel and answers Plaintiff’s Complaint.
2. Defendant admits this Court has subject-matter jurisdiction and that venue is proper in [COUNTY] County under Arkansas law, but denies any remaining allegations of Paragraph ☐ of the Complaint not expressly admitted herein.

II. RESPONSES TO NUMBERED ALLEGATIONS

3. Paragraph 1: Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations contained in Paragraph 1 and therefore denies the same pursuant to Ark. R. Civ. P. 8(b).
4. Paragraph 2: Defendant admits that [limited admission—e.g., “Defendant is an Arkansas corporation”] but denies the remaining allegations.
5. Paragraph 3: Denied.

… (continue until every paragraph of the Complaint is addressed) …

III. GENERAL DENIAL

26. Pursuant to Ark. R. Civ. P. 8(b), Defendant denies each and every allegation, matter, and thing in the Complaint not specifically and expressly admitted herein and demands strict proof thereof.

IV. AFFIRMATIVE DEFENSES

(asserted under Ark. R. Civ. P. 8(c); numbered for clarity)

1. Failure to State a Claim: The Complaint fails to state facts upon which relief can be granted.
2. Statute of Limitations: Plaintiff’s claims are barred, in whole or in part, by the applicable statute(s) of limitation.
3. Comparative Fault / Contributory Negligence: Any recovery must be reduced or barred pursuant to Ark. Code Ann. § 16-64-122.
4. Assumption of Risk.
5. Accord and Satisfaction and/or Release.
6. Laches, Waiver, Estoppel.
7. Failure to Mitigate Damages.
8. Lack of Standing.
9. Set-Off and Recoupment.
10. Reservation: Defendant reserves the right to assert additional defenses that become known through discovery.

V. COUNTERCLAIMS / CROSS-CLAIMS (if any)

27. [Optional] Defendant asserts the following counterclaim(s) against Plaintiff pursuant to Ark. R. Civ. P. 13:
    a. Claim I – [Breach of Contract]
    b. Claim II – [Declaratory Judgment]

VI. PRAYER FOR RELIEF

WHEREFORE, Defendant respectfully requests that the Court:
A. Dismiss Plaintiff’s Complaint with prejudice;
B. Enter judgment in favor of Defendant on all claims;
C. Award Defendant its costs and fees as allowed by law; and
D. Grant such other and further relief as the Court deems just and proper.

VII. DEMAND FOR JURY TRIAL (IF APPLICABLE)

VIII. RESERVATION OF RIGHTS

Defendant reserves the right to amend this Answer to add, modify, or withdraw defenses or counterclaims as discovery and investigation proceed, consistent with Ark. R. Civ. P. 15.

IX. SIGNATURE BLOCK – ARK. R. CIV. P. 11

Respectfully submitted,

[LAW FIRM NAME]
[Address]
[City, State  ZIP]
Telephone: [___]
Facsimile: [___]
Email: [___]

By: ___________________________________
    [ATTORNEY NAME]
    Arkansas Bar No. [___]
    Counsel for Defendant

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### X. VERIFICATION *(if required by statute or court order)*

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### XI. CERTIFICATE OF SERVICE

I hereby certify that on this ___ day of [Month] 20__, a true and correct copy of the foregoing was served upon all counsel of record via:

☐  E-mail
☐  E-Filing/ECF
☐  U.S. Mail, postage prepaid
☐  Hand Delivery
☐  Other: ______________________

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[ATTORNEY NAME]

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