[COURT SEAL OR CAPTION HEADER, IF REQUIRED BY LOCAL RULE]

STATE OF MINNESOTA DISTRICT COURT
[JUDICIAL DISTRICT] COUNTY OF [COUNTY]
File No. ____

[PLAINTIFF FULL LEGAL NAME],
Plaintiff,

v.

[DEFENDANT FULL LEGAL NAME],
Defendant.

______/

ANSWER AND GENERAL DENIAL OF DEFENDANT

[// GUIDANCE: Replace bracketed text with client-specific information. Verify local caption formatting requirements under Minn. Gen. R. Prac. § 5 & § 6 as amended.]

Table of Contents
1. Introductory Statement.............................................. ¶ 1
2. Responses to Complaint.............................................. ¶¶ 2-3
3. Affirmative Defenses................................................ ¶¶ 4-18
4. Counterclaims (Optional)............................................ ¶¶ 19-24
5. Reservation of Rights............................................... ¶ 25
6. Prayer for Relief................................................... ¶ 26
7. Certification (Rule 11)............................................. ¶ 27
8. Verification (If Required)......................................... ¶ 28
9. Signature Block..................................................... p. 9
10. Certificate of Service............................................. p. 10

1. INTRODUCTORY STATEMENT

1. Pursuant to Minn. R. Civ. P. 8.02, 8.03, and 12.01, Defendant [DEFENDANT NAME] (“Defendant”) submits this Answer to the Complaint of Plaintiff [PLAINTIFF NAME] (“Plaintiff”). Unless expressly admitted herein, all allegations of the Complaint are denied.

[// GUIDANCE: If you have already served a Rule 12 motion and it was denied, update introductory paragraph accordingly.]

2. RESPONSES TO COMPLAINT ¶¶ [X]–[Y]

2. Defendant lacks knowledge or information sufficient to form a belief as to the truth of the allegations in Paragraphs ___ of the Complaint and therefore denies the same in accordance with Minn. R. Civ. P. 8.02.
3. In the interest of judicial efficiency and pursuant to Minn. R. Civ. P. 8.02, Defendant hereby enters a general denial of each and every allegation, matter, and thing contained in the Complaint not specifically admitted herein.

[// GUIDANCE: If specific admissions are appropriate (e.g., jurisdiction, corporate status), insert a numbered sub-paragraph admitting those limited facts.]

3. AFFIRMATIVE DEFENSES

Without assuming any burden of proof not imposed by law, Defendant asserts the following affirmative defenses under Minn. R. Civ. P. 8.03. Defendant reserves the right to amend, withdraw, and/or add defenses as discovery proceeds.

4. Failure to State a Claim – The Complaint fails to state facts sufficient to constitute a claim upon which relief can be granted.
5. Lack of Standing – Plaintiff lacks standing to assert one or more claims.
6. Statute of Limitations – One or more claims are barred in whole or in part by applicable statutes of limitation.
7. Statute of Frauds – Any alleged agreement not in writing is unenforceable under the statute of frauds.
8. Payment / Accord and Satisfaction – All or part of the obligations alleged have been paid, satisfied, set off, or discharged.
9. Waiver – Plaintiff waived, relinquished, or abandoned its rights by words or conduct.
10. Estoppel – Plaintiff is estopped by its own conduct from asserting the claims alleged.
11. Laches – Plaintiff unreasonably delayed in enforcing its purported rights, causing prejudice to Defendant.
12. Comparative Fault / Contributory Negligence – Any damages claimed are barred or reduced by Plaintiff’s own fault.
13. Failure of Consideration – Any alleged contract lacks consideration.
14. Unclean Hands – Equitable relief is barred by Plaintiff’s inequitable conduct.
15. Force Majeure / Impossibility – Performance was rendered impossible or commercially impracticable by events beyond Defendant’s control.
16. Reservation Under Minn. R. Civ. P. 12 – Defendant reserves all defenses available under Rule 12(b), including lack of personal jurisdiction, improper venue, insufficient process, and insufficient service of process.
17. Mitigation – Plaintiff has failed to mitigate its alleged damages.
18. Additional Defenses – Defendant reserves the right to assert additional affirmative defenses that become known through discovery.

4. COUNTERCLAIMS (OPTIONAL)

[// GUIDANCE: Assert compulsory counterclaims now to avoid waiver. See Minn. R. Civ. P. 13.01.]

19. Nature of Counterclaim – Defendant asserts a claim against Plaintiff for [BREACH OF CONTRACT / DECLARATORY JUDGMENT / ETC.].
20. Jurisdiction and Venue – This Court has jurisdiction and venue over the counterclaim pursuant to [CITE RELEVANT AUTHORITY].
21. Facts Common to All Counterclaims – Defendant realleges ¶¶ – above.
22. [COUNT I: Breach of Contract] – Plaintiff breached the parties’ agreement by _____.
23. Damages – Defendant has sustained damages in an amount to be proven at trial but not less than $[AMOUNT].
24. Prayer – Defendant demands judgment on the counterclaims as set forth in ¶ 26 below.

5. RESERVATION OF RIGHTS

25. Defendant reserves the right to amend this Answer and to assert additional defenses or counterclaims as permitted by Minn. R. Civ. P. 15.

6. PRAYER FOR RELIEF

26. WHEREFORE, Defendant respectfully requests that the Court:
    a. Dismiss the Complaint in its entirety with prejudice;
    b. Enter judgment in favor of Defendant on all claims;
    c. Award Defendant its costs, disbursements, and reasonable attorney fees as allowed by law or contract;
    d. Enter judgment in favor of Defendant on the counterclaims (if asserted) in an amount to be determined at trial; and
    e. Award such other and further relief as the Court deems just and equitable.

7. RULE 11 CERTIFICATION

27. Pursuant to Minn. R. Civ. P. 11, the undersigned certifies that, to the best of counsel’s knowledge, information, and belief formed after reasonable inquiry, this pleading is well-grounded in fact and law and is not interposed for any improper purpose.

8. VERIFICATION (IF REQUIRED)

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

[SIGNATURE OF VERIFIER]
[TITLE]
Date: _______

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

Notary Public

[// GUIDANCE: Verification is optional in civil actions unless required by statute or court order. Confirm whether claims (e.g., defamation) trigger a verified pleading requirement.]

9. SIGNATURE BLOCK

Dated: _____, 20__

Respectfully submitted,

[LAW FIRM NAME]

By: ____
[ATTORNEY NAME] (#_)
[ADDRESS]
[CITY, STATE ZIP]
Telephone: () -_
Email: [EMAIL ADDRESS]

ATTORNEYS FOR DEFENDANT [DEFENDANT NAME]

10. CERTIFICATE OF SERVICE

I hereby certify that on ___, 20__, I served the foregoing Answer on all counsel of record by [E-SERVICE THROUGH E-FILE & SERVE / U.S. MAIL / HAND DELIVERY] in compliance with Minn. R. Civ. P. 5.02 and Minn. Gen. R. Prac. 14.

[ATTORNEY NAME]

[// GUIDANCE SUMMARY]

1. Answer Deadline: Serve within 20 days after service of the Summons. Minn. R. Civ. P. 12.01.
2. Affirmative Defenses: Must be pleaded in the Answer or are waived. Minn. R. Civ. P. 8.03.
3. Counterclaims: Compulsory counterclaims must be stated in the Answer. Minn. R. Civ. P. 13.01.
4. E-Filing: Most Minnesota district courts mandate electronic filing/service. Consult Minn. Gen. R. Prac. 14.
5. Rule 11: Signature constitutes certification of good-faith basis in fact and law.

[// GUIDANCE: Retain this comment block for attorney reference; delete prior to filing.]