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))

[// GUIDANCE: Use this template when your client wishes to file a straight general denial under Arkansas procedure. Replace every bracketed [PLACEHOLDER] with matter-specific information. Delete any bracketed provisions that do not apply. Be sure to file within 30 days after service in accordance with Ark. R. Civ. P. 12(a), and serve all counsel of record per Ark. R. Civ. P. 5.]

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.

[// GUIDANCE: If jurisdiction or venue are contested, replace Paragraph 2 accordingly and add an affirmative defense under Rule 12(b).]

II. RESPONSES TO NUMBERED ALLEGATIONS

[// GUIDANCE: Mirror the numbering of Plaintiff’s Complaint. If the Complaint contains 21 paragraphs, list 21 sub-paragraph responses. Example shown for first three.]

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.

[// GUIDANCE: Delete, add, or tailor defenses to match the facts. Arkansas requires that all affirmative defenses be pled in the Answer or risk waiver.]

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]

[// GUIDANCE: Insert only if you have compulsory or permissive counterclaims. Otherwise delete this section.]

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)

[// GUIDANCE: Metadata indicates no jury waiver or jury demand is required. If you need a jury, insert “Defendant demands a trial by jury on all issues so triable.” Otherwise delete this heading.]

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

By: _____
[ATTORNEY NAME]
Arkansas Bar No. [_]
Counsel for Defendant

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

[// GUIDANCE: Verification is generally not required for ordinary civil answers in Arkansas, but confirm local rule requirements.]

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: ____

text

[ATTORNEY NAME]

[// GUIDANCE:
1. File the Answer within 30 days of service to avoid default.
2. Confirm that every allegation in the Complaint is either admitted, denied, or claimed as insufficient knowledge.
3. Attach exhibits (if any) as separate, clearly labeled documents.
4. If asserting counterclaims, ensure the filing fee (if any) is paid and summons issued to new parties.
5. Review local administrative orders for formatting specifics (e.g., font size, margins, electronic filing conventions).]