State Court Answer - General Denial

SUPERIOR COURT OF THE STATE OF CONNECTICUT

JUDICIAL DISTRICT OF [JUDICIAL DISTRICT] AT [COURT LOCATION]

DOCKET NO.: [DOCKET NUMBER]

[PLAINTIFF NAME],
 Plaintiff,

v.

[DEFENDANT NAME],
 Defendant.

RETURN DATE: [RETURN DATE]

DEFENDANT’S ANSWER, SPECIAL DEFENSES, AND (OPTIONAL) COUNTERCLAIM

I. DOCUMENT HEADER

1. Appearance is made on behalf of Defendant [DEFENDANT NAME] (“Defendant”) by undersigned counsel, pursuant to Conn. Practice Book §§ 3-1 et seq.
2. Pursuant to Conn. Practice Book § 10-8, this pleading is timely filed within thirty (30) days after the Return Date.

II. GENERAL DENIAL OF COMPLAINT

Except as expressly admitted herein, Defendant denies each and every allegation, matter, and thing contained in Plaintiff’s Complaint dated [COMPLAINT DATE] and demands strict proof thereof at trial.

III. SPECIFIC RESPONSES (IF NECESSARY)

IV. SPECIAL DEFENSES

Without conceding or shifting any burden of proof, and reserving the right to amend, Defendant asserts the following Special Defenses:

1. Failure to State a Claim
   The Complaint fails to state a claim upon which relief can be granted.

2. Statute of Limitations
   One or more of Plaintiff’s claims are barred, in whole or in part, by the applicable statute(s) of limitation.

3. Lack of Standing
   Plaintiff lacks standing to pursue one or more of the asserted claims.

4. Payment / Accord and Satisfaction
   Any obligation alleged has been paid, released, or otherwise discharged.

5. Waiver, Estoppel, and/or Laches
   Plaintiff’s claims are barred by the doctrines of waiver, estoppel, and/or laches as a result of Plaintiff’s own conduct.

6. Comparative / Contributory Negligence
   Plaintiff’s damages, if any, were proximately caused or contributed to by Plaintiff’s own negligence or fault.

7. Failure to Mitigate
   Plaintiff has failed to mitigate any alleged damages.

V. COUNTERCLAIM (OPTIONAL)

A. Parties

1. Counterclaim-Plaintiff: [DEFENDANT NAME].
2. Counterclaim-Defendant: [PLAINTIFF NAME].

B. Jurisdiction & Venue

This Court has jurisdiction and venue is proper under Conn. Gen. Stat. § 51-345 because the original action is pending here.

C. Factual Allegations

1. …
2. …

D. Causes of Action

Count One – Breach of Contract

1. …
2. …

E. Prayer for Relief on Counterclaim

Counterclaim-Plaintiff requests:
a. Compensatory damages in an amount to be proven at trial;
b. Pre- and post-judgment interest as allowed by law;
c. Costs and reasonable attorney’s fees where permitted;
d. Such other and further relief as equity and justice require.

VI. PRAYER FOR RELIEF

WHEREFORE, Defendant respectfully requests that the Court:

1. Enter judgment in favor of Defendant and against Plaintiff on all counts of the Complaint;
2. Dismiss the Complaint with prejudice;
3. Award costs as allowed by law; and
4. Grant such other and further relief as the Court deems just and proper.

VII. CLAIM FOR TRIAL BY JUDGE (NON-JURY)

Defendant does not assert a jury claim at this time.

VIII. CERTIFICATION OF SERVICE

I hereby certify that on [DATE] a copy of the foregoing Answer, Special Defenses, and (Optional) Counterclaim was or will be sent electronically through the E-Service system and/or mailed first-class postage prepaid to all counsel and self-represented parties of record as follows:

• [NAME & ADDRESS OR E-SERVICE E-MAIL]
• …

/s/ _________________________
[ATTORNEY NAME] (Juris No. [NUMBER])
[LAW FIRM NAME]
[STREET ADDRESS]
[CITY, STATE ZIP]
Tel: ([AREA CODE]) [PHONE]
Fax: ([AREA CODE]) [FAX]
E-mail: [EMAIL]

Attorney for Defendant [DEFENDANT NAME]

QUICK REFERENCE TO KEY CONNECTICUT RULES

1. Time to plead – Conn. Practice Book § 10-8 (30 days after Return Date).
2. General Denial – Conn. Practice Book § 10-46.
3. Special Defenses – Conn. Practice Book § 10-50.
4. Counterclaims/Cross-complaints – Conn. Practice Book § 10-10.
5. Service & Certification – Conn. Practice Book § 10-12.