IN THE CIRCUIT COURT OF THE [____] JUDICIAL CIRCUIT

IN AND FOR [____] COUNTY, FLORIDA

Case No.: __
Division: __

[PLAINTIFF NAME],
  Plaintiff,

v.

[DEFENDANT NAME],
  Defendant.
__________/

DEFENDANT’S ANSWER, GENERAL DENIAL, AND AFFIRMATIVE DEFENSES

Defendant, [DEFENDANT NAME] (“Defendant”), by and through undersigned counsel and pursuant to Fla. R. Civ. P. 1.110(c) and 1.140(a), hereby files its Answer to the Complaint of [PLAINTIFF NAME] (“Plaintiff”) and states as follows:

1. TIMELINESS OF ANSWER

This Answer is filed within twenty (20) days of service of the Summons and Complaint, in accordance with Fla. R. Civ. P. 1.140(a).
[// GUIDANCE: If an extension or waiver of service altered the response deadline, edit this paragraph accordingly.]

2. GENERAL DENIAL

Pursuant to Fla. R. Civ. P. 1.110(c), Defendant denies each and every allegation of the Complaint not expressly admitted herein and demands strict proof thereof.

[// GUIDANCE:
• Florida is a fact-pleading jurisdiction. Many practitioners prefer a paragraph-by-paragraph response.
• To convert this template, insert a new Section 2 titled “Specific Responses,” replicate each numbered paragraph of the Complaint, and admit, deny, or state “without knowledge,” followed by this General Denial as a savings clause.]

3. AFFIRMATIVE DEFENSES

Defendant asserts the following affirmative defenses without assuming any burden of proof not otherwise imposed by law. Defendant reserves the right to amend these defenses as discovery proceeds.

1. Failure to State a Cause of Action – The Complaint fails to state a claim upon which relief can be granted. Fla. R. Civ. P. 1.140(b)(6).
2. Statute of Limitations – All or part of Plaintiff’s claims are barred by the applicable statute(s) of limitations, including but not limited to Fla. Stat. § 95.11.
3. Lack of Standing – Plaintiff lacks standing to maintain one or more claims asserted.
4. Estoppel / Waiver – Plaintiff’s claims are barred, in whole or in part, by the doctrines of estoppel and/or waiver.
5. Accord and Satisfaction – Any alleged obligation was discharged by accord and satisfaction.
6. Unclean Hands – Plaintiff’s own inequitable conduct bars or diminishes recovery under the doctrine of unclean hands.
7. Set-Off / Recoupment – Any recovery by Plaintiff must be reduced or barred by amounts owed to Defendant.
8. Failure to Mitigate – Plaintiff failed to mitigate its alleged damages.
9. Reservation of Additional Defenses – Defendant reserves the right to assert additional defenses that become known through discovery.

[// GUIDANCE: Rearrange, add, or delete defenses to fit the facts. Affirmative defenses not pled may be waived.]

4. COUNTERCLAIMS (OPTIONAL)

[// GUIDANCE: Fla. R. Civ. P. 1.170(a) requires any compulsory counterclaim arising from the same “transaction or occurrence” to be pled in this Answer or be forever barred. Insert any such claims here or create a separate, consecutively-numbered pleading titled “Counterclaim.”]

5. WHEREFORE CLAUSE

WHEREFORE, Defendant respectfully requests that this Court:
a. Enter judgment in favor of Defendant and against Plaintiff;
b. Tax costs, expenses, and such other relief as the Court deems just and proper; and
c. Grant any additional relief to which Defendant may be entitled at law or in equity.

6. DEMAND FOR ATTORNEYS’ FEES

Defendant demands an award of reasonable attorneys’ fees and costs pursuant to any applicable statute, contract, or common-law basis.
[// GUIDANCE: Delete if no fee entitlement exists or insert the specific statutory/contractual basis.]

7. JURY DEMAND (IF APPLICABLE)

[// GUIDANCE: Jurisdictional metadata indicates no jury waiver is in place. If a jury trial is desired, include the following; otherwise delete.]

Defendant hereby demands trial by jury on all issues so triable as of right.

8. CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via the Florida Courts E-Filing Portal pursuant to Fla. R. Gen. Prac. & Jud. Admin. 2.516(b)(1)(A) (or by [specify method]) to:

• [Name of Counsel], Esq. – [email] – Counsel for Plaintiff
• [Additional Recipients]

on this ___ day of ____, 20__.

9. SIGNATURE BLOCK

Respectfully submitted,
text
LAW FIRM NAME
Address Line 1
Address Line 2
Telephone: () -_
Facsimile: () -_
Email: [Primary E-Service Address]
Secondary: [Secondary E-Service Address]

By: /s/ [ATTORNEY NAME]
[ATTORNEY NAME], Esq.
Florida Bar No. __
Counsel for Defendant

10. VERIFICATION (ONLY IF REQUIRED)

[// GUIDANCE: Most Answers in Florida state court are not verified unless a statute specifically requires it (e.g., defamation retractions, mortgage foreclosure). If verification is required, insert the following:]

text
STATE OF FLORIDA )
) SS
COUNTY OF ____ )

BEFORE ME, the undersigned authority, personally appeared [DEFENDANT REPRESENTATIVE], who, being duly sworn, deposes and says that he/she has read the foregoing Answer and that the statements contained therein are true and correct to the best of his/her knowledge and belief.

[DEFENDANT REPRESENTATIVE]

Sworn to and subscribed before me this ___ day of _, 20_ by [name], who [ ] is personally known to me OR [ ] produced ______ as identification.

Notary Public, State of Florida

END OF TEMPLATE

[// GUIDANCE:
1. File through the Florida Courts E-Filing Portal; select “Answer/Response” event code.
2. Confirm proper format of your case caption (circuit vs. county court, civil vs. small claims).
3. If adding counterclaims, ensure payment of any additional filing fee at the time of e-filing.
4. Review local administrative orders for county-specific formatting, font, or margin requirements.
5. Serve all parties in strict compliance with Fla. R. Gen. Prac. & Jud. Admin. 2.516 to avoid service challenges.
]