IN THE [COURT NAME] COURT OF [COUNTY] COUNTY

STATE OF GEORGIA

[PLAINTIFF NAME],
  Plaintiff,

v. Civil Action File No. [CASE NO.]

[DEFENDANT NAME],
  Defendant.

==================================================================
ANSWER AND GENERAL DENIAL
==================================================================

Defendant [DEFENDANT NAME] (“Defendant”), by and through undersigned counsel, files this Answer and General Denial (the “Answer”) to the Complaint of Plaintiff [PLAINTIFF NAME] (“Plaintiff”), and states as follows:

[// GUIDANCE: Georgia law generally requires an Answer to be filed within 30 days after service of the Summons and Complaint. Failure to answer timely may result in default. See Georgia Civil Practice Act.]

I. RESPONSES TO NUMBERED ALLEGATIONS

[// GUIDANCE: Copy each numbered paragraph of the Complaint verbatim in bold, then respond underneath. A sample format is provided below.]

1. Paragraph 1 of the Complaint:
Defendant’s Response: Defendant admits the allegations in Paragraph 1 only to the extent they accurately identify the parties. Except as expressly admitted herein, Defendant denies each and every remaining allegation in Paragraph 1.

2. Paragraph 2 of the Complaint:
Defendant’s Response: Defendant lacks knowledge or information sufficient to form a belief as to the truth of the allegations in Paragraph 2 and therefore denies the same.

3. Paragraph 3 of the Complaint:
Defendant’s Response: Denied.

…continue this pattern for every paragraph of the Complaint…

II. GENERAL DENIAL

Pursuant to the Georgia Civil Practice Act, and except as expressly admitted herein, Defendant denies each and every allegation of the Complaint and specifically denies that Plaintiff is entitled to any relief whatsoever.

III. AFFIRMATIVE DEFENSES

Without assuming any burden not imposed by law, and reserving the right to assert additional defenses as discovery proceeds, Defendant asserts the following affirmative defenses:

1. Failure to State a Claim – The Complaint fails to state a claim upon which relief may be granted.
2. Lack of Personal Jurisdiction – This Court lacks personal jurisdiction over Defendant.
3. Improper Venue – Venue is improper in this Court.
4. Statute of Limitations – One or more claims are barred in whole or in part by the applicable statute(s) of limitation.
5. Accord and Satisfaction / Settlement – The claims are barred by prior accord and satisfaction or settlement.
6. Estoppel and Waiver – Plaintiff’s claims are barred by the doctrines of estoppel and/or waiver.
7. Laches – Plaintiff’s claims are barred by laches due to unreasonable delay.
8. Failure of Consideration – No valid consideration supports Plaintiff’s alleged claims.
9. Comparative / Contributory Fault – Any damages were proximately caused or contributed to by Plaintiff’s own acts or omissions.
10. Unclean Hands – Plaintiff comes to the Court with unclean hands.
11. Failure to Mitigate – Plaintiff failed to mitigate any alleged damages.
12. Reservation of Additional Defenses – Defendant expressly reserves the right to assert additional defenses that may become available through discovery.

[// GUIDANCE: Delete, add, or renumber defenses to fit the specific facts. Georgia law requires affirmative defenses to be stated in short, plain terms.]

IV. COUNTERCLAIMS (OPTIONAL)

[// GUIDANCE: Under Georgia Civil Practice Act rules governing counterclaims, any compulsory counterclaim arising out of the same transaction or occurrence must be asserted in this Answer or it may be forfeited. Insert paragraphs below only if asserting counterclaims; otherwise delete Section IV in its entirety.]

1. Jurisdiction and Venue – This Court has jurisdiction over the parties and subject matter and is the proper venue for the Counterclaims asserted herein.
2. Statement of Facts – [INSERT concise factual background giving rise to Counterclaims.]
3. Count I – [INSERT legal theory, e.g., Breach of Contract]
    a. Defendant incorporates Paragraphs 1–[X] as if fully set forth herein.
    b. [Set forth essential elements and factual allegations supporting the claim.]
    c. As a direct result, Defendant has sustained damages in an amount to be proven at trial.
4. Prayer for Relief – WHEREFORE, Defendant respectfully requests:
    a. Judgment in Defendant’s favor on all Counterclaims;
    b. An award of compensatory damages in an amount to be determined;
    c. Pre- and post-judgment interest as allowed by law;
    d. Costs of suit and reasonable attorney’s fees; and
    e. Such other and further relief as the Court deems just and proper.

V. PRAYER FOR RELIEF

WHEREFORE, having fully answered, Defendant respectfully requests that the Court:

1. Dismiss the Complaint in its entirety with prejudice;
2. Enter judgment in favor of Defendant and against Plaintiff;
3. Award Defendant its costs of suit and, where permitted, reasonable attorney’s fees; and
4. Grant such other and further relief as the Court deems just and proper.

VI. RESERVATION OF RIGHTS

Defendant reserves the right to amend this Answer to assert additional defenses, affirmative defenses, counterclaims, cross-claims, or third-party claims as may be warranted by facts learned during discovery or as justice requires.

VII. JURY DEMAND (if applicable)

[// GUIDANCE: Omit if no jury trial is desired.]
Defendant hereby demands a trial by jury on all issues so triable.

VIII. VERIFICATION (optional)

[// GUIDANCE: Georgia practice does not ordinarily require verification unless the Complaint was verified or a specific statute requires it. Include only if needed.]

I, [DEFENDANT REPRESENTATIVE NAME], being duly sworn, depose and say that I have read the foregoing Answer and know the contents thereof and that the same is true to the best of my knowledge, information, and belief.

[DEFENDANT REPRESENTATIVE NAME]
[Title, if any]

Sworn to and subscribed before me
this ___ day of ____, 20__.

Notary Public
My Commission Expires: _______

IX. CERTIFICATE OF SERVICE

I hereby certify that I have this day served a true and correct copy of the foregoing Answer and General Denial upon all counsel of record by:

☐ Electronic filing system (if applicable)
☐ E-mail to: [EMAIL ADDRESS]
☐ First-Class U.S. Mail, postage prepaid to: [NAME & ADDRESS]
☐ Hand delivery

This ___ day of ____, 20__.

[ATTORNEY NAME]
Georgia Bar No. [BAR NO.]
Attorney for Defendant

[LAW FIRM NAME]
[ADDRESS]
[PHONE] • [EMAIL]

STRATEGIC NOTES FOR PRACTITIONERS

[// GUIDANCE: Delete this boxed section prior to filing.]

• Double-check the service date to confirm the 30-day answer deadline.
• Ensure each Complaint allegation is either admitted, denied, or claimed as lack of knowledge. Silence equals admission.
• Review Georgia Civil Practice Act §§ 8, 12, 13 for pleading, motion, and counterclaim requirements.
• Affirmative defenses that are even remotely applicable should be pled now; courts may deem them waived if raised later.
• Verify whether a jury demand has been made by Plaintiff. If you want a jury and Plaintiff did not demand one, assert it in the Answer.
• Confirm that any compulsory counterclaims are asserted to avoid preclusion.
• Consider early motions (e.g., motion to dismiss) if strong threshold defenses exist; Georgia allows certain motions to be filed within the Answer window.
• Keep a clean version—without GUIDANCE comments—for actual filing.

END OF TEMPLATE