IN THE CIRCUIT COURT FOR [COUNTY] COUNTY, MARYLAND

[// GUIDANCE: Replace with “DISTRICT COURT OF MARYLAND FOR [County]” if the action is pending in the District Court. Modify rule citations accordingly (Md. Rule Title 3).]

Civil Action No.: [CASE NO.]

[PLAINTIFF NAME],
  Plaintiff,

v.

[DEFENDANT NAME],
  Defendant.

DEFENDANT’S ANSWER, GENERAL DENIAL, AFFIRMATIVE DEFENSES, AND RESERVATION OF RIGHTS

[// GUIDANCE: This template follows Md. Rule 2-323. All citations are to the Maryland Rules, Title 2 (Circuit Court).]

1. Preliminary Statement

Pursuant to Md. Rule 2-323(d), Defendant [DEFENDANT NAME] (“Defendant”) hereby answers the Complaint of Plaintiff [PLAINTIFF NAME] (“Plaintiff”) as follows.

2. General Denial

Except as expressly admitted herein, Defendant denies each and every allegation, matter, and thing contained in Plaintiff’s Complaint and demands strict proof thereof.

3. Specific Admissions and Denials

[// GUIDANCE: Use one of the two options below.]

Option A – Paragraph-by-Paragraph Response
1. Paragraph 1: [Admitted / Denied / Without knowledge or information sufficient to form a belief.]
2. Paragraph 2: …
continue for each paragraph of the Complaint

Option B – Pure General Denial
Defendant elects under Md. Rule 2-323(d) to interpose a general denial to all allegations not expressly admitted.

4. Affirmative Defenses

Without assuming any burden of proof that the law does not place on Defendant, and expressly reserving the right to amend these defenses as discovery proceeds, Defendant asserts the following Affirmative Defenses pursuant to Md. Rule 2-323(f):

1. Failure to State a Claim – The Complaint fails to state a claim upon which relief can 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 – The claims are barred, in whole or in part, by applicable statutes of limitation.
5. Accord and Satisfaction.
6. Payment and Release.
7. Waiver, Estoppel, and Laches.
8. Comparative/Contributory Negligence.
9. Failure of Consideration.
10. Unclean Hands.
11. Set-Off and Recoupment.
12. Reservation – Defendant reserves the right to assert additional defenses as they become known.

5. Counterclaims / Cross-Claims (If Any)

[// GUIDANCE: Counterclaims are governed by Md. Rule 2-331. Insert here or file as a separate pleading within the same deadline. If none, state “None at this time.”]

6. Prayer for Relief

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

7. Reservation of Rights

Defendant reserves all rights, claims, and defenses, both legal and equitable, that may be available now or discovered hereafter, including the right to file dispositive motions under Md. Rule 2-322.

8. Jury Demand

[// GUIDANCE: The metadata indicates “Jury Waiver: not_applicable.” Omit if no jury is sought. If a jury trial is desired, insert:
“Defendant demands a trial by jury on all issues so triable pursuant to Md. Rule 2-325.”]

CERTIFICATE OF SERVICE

I hereby certify that on this ___ day of ____, 20__, a copy of the foregoing Answer, General Denial, Affirmative Defenses, and Reservation of Rights was served by [hand delivery / first-class mail / MDEC e-service] upon:

[Name and address of Plaintiff’s counsel or unrepresented Plaintiff]

[ATTORNEY NAME]
[Bar No.]
[Law Firm]
[Address]
[Phone]
[Email]
Counsel for Defendant

KEY MARYLAND PROCEDURAL NOTES

[// GUIDANCE: Remove this section before filing; it is for attorney reference only.]

1. Answer Deadline:
   • Circuit Court – 30 days after service. Md. Rule 2-321(a).
   • District Court – 15 days after service (small claims & landlord-tenant may vary). Md. Rule 3-307.

2. Affirmative Defenses: Must be pled in the Answer. Md. Rule 2-323(f).

3. Counterclaims: File with the Answer or by separate pleading within the Answer deadline. Md. Rule 2-331(a).

4. Verification: Not required unless specifically mandated by statute or if pleading special damages for defamation.

5. Electronic Filing: Most counties require electronic filing via MDEC; include the MDEC filing code “ANSWER.”

6. Modify Caption: Use “District Court of Maryland for [County]” and substitute Title 3 rules if the case is in District Court.