[COURT NAME], [COUNTY]

COMMONWEALTH OF KENTUCKY

PLAINTIFF: [PLAINTIFF NAME]

v. Civil Action No. [__]

DEFENDANT: [DEFENDANT NAME]

ANSWER AND GENERAL DENIAL OF DEFENDANT [DEFENDANT NAME]

[// GUIDANCE: This template complies with the Kentucky Rules of Civil Procedure (“Ky. R. Civ. P.”) and is formatted for immediate attorney customization and filing.]

TABLE OF CONTENTS

1. Document Header, Caption & Appearance
2. Preliminary Statements & Rule 12.01 Deadline Compliance
3. Responses to Numbered Allegations & General Denial
4. Affirmative Defenses (Ky. R. Civ. P. 8.03)
5. Counterclaims & Cross-Claims (Ky. R. Civ. P. 13) – Optional
6. Prayer for Relief
7. Reservation of Rights to Amend & Add Defenses
8. Verification (Optional/When Required)
9. Signature Block (Ky. R. Civ. P. 11)
10. Certificate of Service

1. DOCUMENT HEADER, CAPTION & APPEARANCE

Comes now Defendant [DEFENDANT NAME] (“Defendant”), by counsel [LAW FIRM NAME], and for its Answer to the Complaint (“Complaint”) of [PLAINTIFF NAME] (“Plaintiff”) states as follows.

2. PRELIMINARY STATEMENTS & RULE 12.01 DEADLINE COMPLIANCE

1. Service of the Summons and Complaint was effected on Defendant on [DATE OF SERVICE].
2. Pursuant to Ky. R. Civ. P. 12.01, this Answer is timely filed within twenty (20) days of service.
3. The paragraph numbers below correspond to those set forth in the Complaint unless otherwise indicated.

3. RESPONSES TO NUMBERED ALLEGATIONS & GENERAL DENIAL

[// GUIDANCE: Insert one sub-paragraph for EACH paragraph in the Complaint. If electing a pure “general denial,” keep ¶3.1 only.]

3.1 Except as expressly admitted herein, Defendant denies each and every allegation contained in the Complaint, pursuant to Ky. R. Civ. P. 8.02.

3.2 Paragraph 1: [ADMIT / DENY / LACK KNOWLEDGE].
3.3 Paragraph 2: [ADMIT / DENY / LACK KNOWLEDGE].
3.4 Paragraph 3: [ADMIT / DENY / LACK KNOWLEDGE].
3.5 Paragraph 4: [ADMIT / DENY / LACK KNOWLEDGE].
3.6 Paragraph 5: [ADMIT / DENY / LACK KNOWLEDGE].
[CONTINUE AS NEEDED]

4. AFFIRMATIVE DEFENSES (Ky. R. Civ. P. 8.03)

Without admitting any allegation, and expressly reserving the right to assert additional defenses as discovery proceeds, Defendant pleads the following affirmative defenses:

1. Failure to state a claim upon which relief can be granted. Ky. R. Civ. P. 12.02(f).
2. Lack of subject-matter jurisdiction. Ky. R. Civ. P. 12.02(a).
3. Lack of personal jurisdiction. Ky. R. Civ. P. 12.02(b).
4. Improper venue. Ky. R. Civ. P. 12.02(c).
5. Insufficiency of process or service of process. Ky. R. Civ. P. 12.02(d)–(e).
6. Statute of limitations/bar of laches.
7. Estoppel, waiver, and/or release.
8. Failure of consideration and/or accord and satisfaction.
9. Comparative and/or contributory fault of Plaintiff and/or third parties.
10. Failure to mitigate damages.
11. Set-off and/or recoupment.
12. Unclean hands.
13. Reservation of the right to assert any additional defenses that become apparent during discovery.

[// GUIDANCE: Delete, add, or reorder defenses to fit case-specific facts. Each defense should be supported by good-faith factual basis per Ky. R. Civ. P. 11.]

5. COUNTERCLAIMS & CROSS-CLAIMS — OPTIONAL (Ky. R. Civ. P. 13)

[// GUIDANCE: If no counterclaims are asserted at this time, retain §5.1 only.]

5.1 Defendant asserts no compulsory or permissive counterclaims at this time but expressly reserves the right to move to amend and assert any such claims as permitted by Ky. R. Civ. P. 13 and the Court’s scheduling orders.

—or—

5.1 Counterclaim Count I – [BREACH OF CONTRACT]
a. Jurisdiction & Venue.
b. Facts Common to All Counts.
c. Elements & Damages.
d. Prayer for Counterclaim Relief.

[// GUIDANCE: For each counterclaim, set forth a short and plain statement showing entitlement to relief, segregate counts, and include a prayer for relief.]

6. PRAYER FOR RELIEF

WHEREFORE, Defendant respectfully prays that the Court:

A. Dismiss the Complaint in its entirety with prejudice;
B. Enter judgment in favor of Defendant and against Plaintiff;
C. Award Defendant its costs and reasonable attorneys’ fees as allowed by law; and
D. Grant such other and further relief as the Court deems just and proper.

7. RESERVATION OF RIGHTS TO AMEND & ADD DEFENSES

Defendant reserves the right to amend this Answer to assert additional defenses, counterclaims, or cross-claims as may become appropriate pursuant to Ky. R. Civ. P. 15 and other applicable law.

8. VERIFICATION (OPTIONAL/WHEN REQUIRED)

[// GUIDANCE: Kentucky generally does not require verification unless a statute specifically so provides. Remove this section unless verification is mandatory for the particular cause of action.]

I, [AUTHORIZED REPRESENTATIVE], being first duly sworn, state that I have read the foregoing Answer and that the statements contained herein are true and correct to the best of my knowledge, information, and belief.

[AUTHORIZED REPRESENTATIVE]
[Title, if any]

Subscribed and sworn before me this ___ day of ____, 20__.

Notary Public
My Commission Expires: ____

9. SIGNATURE BLOCK (Ky. R. Civ. P. 11)

Respectfully submitted,

[ATTORNEY NAME] (KY Bar No. [__])
[LAW FIRM NAME]
[Street Address]
[City, State ZIP]
Telephone: [--_]
Email: [_____]
Counsel for Defendant [DEFENDANT NAME]

10. CERTIFICATE OF SERVICE

I hereby certify that on this ___ day of ____, 20__, I served the foregoing Answer via:

☐ U.S. Mail, postage prepaid
☐ Electronic Filing System
☐ Hand Delivery
☐ Other: [____]

upon:

[Opposing Counsel Name]
[Law Firm]
[Address / Email]
Counsel for Plaintiff

[ATTORNEY NAME]

[// END OF TEMPLATE]