State Court Answer - General Denial

DEFENDANT'S ANSWER, AFFIRMATIVE DEFENSES, AND OPTIONAL COUNTERCLAIMS

Colorado district-court template. Do not use this document as a county-court answer. Colorado county-court civil cases use the rules in Chapter 25 and may use CRCCP Form 3. Check the summons, any case-management order, local practice, and the court's current filing instructions before filing.

Filing deadline and threshold review

C.R.C.P. 12(a)(1) generally requires an answer or other response within 21 days after service of the summons and complaint, except when another rule or statute provides a different time. Under C.R.C.P. 12(a)(2), the period is generally 35 days when the complaint was omitted from service by special order, or when the summons was served outside Colorado or by publication. A permitted Rule 12 motion changes the later responsive-pleading deadline. Use the deadline stated in the summons or a court order when it differs, and calculate the deadline before drafting.

Before filing an answer, evaluate whether any Rule 12 objection should be raised by motion or preserved in the answer, including objections concerning personal jurisdiction, process, service of process, or failure to join a required party. Also evaluate any timely venue objection under C.R.C.P. 98.

Caption

DISTRICT COURT, [COUNTY] COUNTY, COLORADO

Court Address: [COURT ADDRESS]

Defendant's answer

Defendant [DEFENDANT NAME] ("Defendant") answers Plaintiff's [TITLE OF COMPLAINT] (the "Complaint") as follows.

Responses to numbered allegations

Use one response for every numbered paragraph and tailor it to fairly meet the substance of that allegation. Under C.R.C.P. 8(b), a statement that Defendant lacks knowledge or information sufficient to form a belief has the effect of a denial. If only part of an allegation is true, identify the true and material part and deny the remainder.

1. In response to paragraph 1, Defendant admits [ADMITTED FACTS] and denies the remaining allegations.

2. Defendant denies the allegations in paragraph 2.

3. Defendant lacks knowledge or information sufficient to form a belief as to the truth of the allegations in paragraph 3 and therefore denies them.

4. In response to paragraph 4, Defendant admits [ADMITTED PORTION], denies [DENIED PORTION], and lacks knowledge or information sufficient to form a belief as to [REMAINDER].

5. [CONTINUE THROUGH EVERY NUMBERED PARAGRAPH OF THE COMPLAINT.]

Optional complete general denial: Defendant denies every allegation in the Complaint.

Affirmative defenses

Defendant asserts only the following defenses that are supported by facts and law after reasonable inquiry. C.R.C.P. 8(c) requires affirmative pleading of listed avoidance defenses and other affirmative defenses. The 2015 official Rule 12 comment states that pleading every Rule 8(c) defense without a factual basis is improper under C.R.C.P. 11(a).

First affirmative defense — [DEFENSE NAME]

[STATE THE MATERIAL FACTS SUPPORTING THIS DEFENSE AND IDENTIFY THE CLAIMS TO WHICH IT APPLIES.]

Second affirmative defense — [DEFENSE NAME]

[STATE THE MATERIAL FACTS SUPPORTING THIS DEFENSE AND IDENTIFY THE CLAIMS TO WHICH IT APPLIES.]

Additional affirmative defense — [DEFENSE NAME]

[STATE THE MATERIAL FACTS SUPPORTING THIS DEFENSE AND IDENTIFY THE CLAIMS TO WHICH IT APPLIES.]

Delete unused defenses. Do not insert an open-ended reservation of defenses. If investigation later supplies a proper basis for another defense, follow C.R.C.P. 15(a) and obtain written consent or leave of court when required.

Optional counterclaims

Before deleting or completing this section, screen every claim Defendant presently has against each opposing party under C.R.C.P. 13(a). A claim generally must be stated as a counterclaim when, at the time of filing, Defendant has the claim against an opposing party, it arises from the transaction or occurrence that is the subject of the opposing party's claim, and adjudication does not require a third party over whom the court cannot acquire jurisdiction, subject to Rule 13(a)'s exceptions. Rule 13 also addresses later-maturing and omitted counterclaims.

☐ Defendant has no counterclaim to plead after completing the Rule 13 review; delete the remainder of this section.

☐ Defendant pleads the following counterclaim(s).

Counterclaim parties, jurisdiction, and venue

1. Counterclaimant [DEFENDANT NAME] is [IDENTIFY PARTY AND RELEVANT RESIDENCE OR ORGANIZATIONAL FACTS].

2. Counterclaim Defendant [PLAINTIFF NAME] is [IDENTIFY PARTY AND RELEVANT RESIDENCE OR ORGANIZATIONAL FACTS].

3. This Court has subject-matter jurisdiction because [CONSTITUTIONAL OR STATUTORY BASIS AND JURISDICTIONAL FACTS].

4. The place of trial is proper under C.R.C.P. 98([SUBSECTION]) because [VENUE FACTS].

General counterclaim allegations

5. [STATE FACTS IN NUMBERED PARAGRAPHS. DO NOT INCORPORATE THE ANSWER'S ADMISSIONS OR DENIALS AS A SUBSTITUTE FOR COUNTERCLAIM FACTS.]

First counterclaim — [CLAIM NAME]

6. Counterclaimant incorporates paragraphs [NUMBERS] of the counterclaim allegations.

7. [PLEAD EACH REQUIRED ELEMENT AND ITS SUPPORTING FACTS.]

8. As a result, Counterclaimant suffered [HARM AND DAMAGES OR OTHER RELIEF].

Request for relief

Defendant requests that the Court:

1. enter judgment in Defendant's favor on Plaintiff's claims to the extent denied;
2. award Defendant costs and attorney fees only to the extent authorized by applicable law, rule, or contract;
3. if counterclaims are pleaded, enter judgment awarding the relief stated in those counterclaims; and
4. grant any other relief the Court determines is proper.

Signature

Respectfully submitted on [__/__/____].

Signature: ____________________________________

Attorney for Defendant [DEFENDANT NAME] / Self-Represented Defendant

Defendant's address, if represented: [DEFENDANT ADDRESS]

Under C.R.C.P. 11(a), the attorney of record must sign a represented party's pleading; a self-represented party must sign and state an address. Pleadings generally need not be verified unless a rule or statute specifically requires verification.

Certificate of service

I certify that on [__/__/____], I served a true and correct copy of this Defendant's Answer, Affirmative Defenses, and Optional Counterclaims on the following parties or counsel by the method checked below:

☐ Colorado Courts E-Filing under C.R.C.P. 121 § 1-26

☐ Delivery permitted by C.R.C.P. 5(b)(2)(A)

☐ Mail to the last known address under C.R.C.P. 5(b)(2)(B)

☐ Filing with the clerk because no address is known under C.R.C.P. 5(b)(2)(C)

☐ Other means permitted by C.R.C.P. 5(b)(2)(D): [DESCRIBE]

Signature: ____________________________________

Printed Name: [NAME]

Sources and references

• Colorado Judicial Branch, Adopted & Proposed Rule Changes
• Colorado Judicial Branch, Rule Change 2024(08) — C.R.C.P. 12
• Colorado Judicial Branch, Rule Change 2020(01) — C.R.C.P. 8(c)
• Colorado Judicial Branch, Rule Change 2015(05) — C.R.C.P. 12 and official comment
• Colorado Judicial Branch, Civil Rules Committee agenda packet dated November 7, 2025 — reproduced Rules 8, 11, 12, 13, 15, and 98
• Colorado Judicial Branch, 2026 opinion No. 25CA0687 (modified) — C.R.C.P. 15(a)
• Colorado Judicial Branch, JDF 70 Certificate of Service
• Colorado Judicial Branch, Form 1.1 Summons by Publication
• Colorado General Assembly, official online access page for Colorado statutes and court rules