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

[// GUIDANCE: This template conforms to the Connecticut Practice Book. Citations are provided only where long-standing, non-controversial, and foundational.]

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

[// GUIDANCE: Under Conn. Practice Book § 10-46, a “general denial” is permissible except for allegations that must be specifically admitted, denied, or pleaded to specially (e.g., amount of damages, misrepresentation, wilful or malicious conduct). If any such allegations appear in the Complaint, insert specific admissions/denials below or convert to a “paragraph-by-paragraph” answer.]

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)

[// GUIDANCE: Remove this section if the General Denial in Section II is sufficient under § 10-46.]

IV. SPECIAL DEFENSES

[// GUIDANCE: In Connecticut, affirmative defenses are pleaded as “Special Defenses.” Conn. Practice Book § 10-50. Plead only those that are supportable by fact and law. Delete or add as appropriate.]

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.

[// GUIDANCE: Renumber or delete defenses to match actual case facts. Consider adding contractual defenses, privilege, res judicata, set-off, etc., where supported.]

V. COUNTERCLAIM (OPTIONAL)

[// GUIDANCE: Counterclaims must “arise out of the transaction or one of the transactions” alleged in the Complaint. Conn. Practice Book § 10-10. Remove this section if no counterclaim is asserted.]

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)

[// GUIDANCE: Civil cases in Connecticut state court are bench trials unless a timely jury claim is filed under Conn. Gen. Stat. § 52-215. Omit or modify as needed.]

Defendant does not assert a jury claim at this time.

VIII. CERTIFICATION OF SERVICE

[// GUIDANCE: Conn. Practice Book § 10-12 requires certification of service on all self-represented parties and counsel of record.]

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.

[// GUIDANCE:
• Verify that any allegation involving the amount of damages, misrepresentation, or wilful conduct is specifically addressed (cannot be swept into a general denial).
• Confirm factual basis for each Special Defense to avoid exposure under Conn. Practice Book § 10-5 (signature certifies good-faith factual and legal basis).
• Re-calculate deadline if an extension of time to plead has been granted.
• File a jury claim within the statutory period if desired (usually within ten days after the last pleading is filed).]