IN THE [COURT NAME – e.g., COURT OF COMMON PLEAS]

[COUNTY], OHIO

[PLAINTIFF NAME],
  Plaintiff,

v.

[DEFENDANT NAME],
  Defendant.

Case No.: [_]
Judge: [_]

DEFENDANT’S ANSWER AND GENERAL DENIAL TO PLAINTIFF’S COMPLAINT

[// GUIDANCE: File/serve within 28 days after service of the Complaint. See Ohio R. Civ. P. 12(A)(1).]

I. PRELIMINARY STATEMENT

1. Defendant [DEFENDANT NAME] (“Defendant”) appears through undersigned counsel and, pursuant to Ohio R. Civ. P. 8 and 12, answers the numbered paragraphs of Plaintiff [PLAINTIFF NAME]’s (“Plaintiff”) Complaint (the “Complaint”) as follows.
2. Unless expressly admitted herein, every allegation of the Complaint is denied.

II. SPECIFIC RESPONSES

[// GUIDANCE: Insert the exact paragraph numbers from the Complaint; respond to each with “Admitted,” “Denied,” or “Defendant lacks knowledge or information sufficient to form a belief and therefore denies.” If the Complaint is lengthy, consider attaching an addendum.]

III. GENERAL DENIAL

Pursuant to Ohio R. Civ. P. 8(B), Defendant denies each and every allegation, matter, and thing contained in the Complaint that is not expressly admitted herein and demands strict proof thereof.

IV. AFFIRMATIVE DEFENSES

[// GUIDANCE: Plead all defenses now; unpled defenses may be waived. See Ohio R. Civ. P. 8(C) & 12(H). Edit, re-order, or delete as case-appropriate.]

1. Failure to State a Claim – The Complaint fails to state a claim upon which relief can be granted. (Ohio R. Civ. P. 12(B)(6)).
2. Lack of Standing – Plaintiff lacks standing to assert one or more claims.
3. Statute of Limitations – One or more claims are barred by applicable limitation periods.
4. Accord and Satisfaction.
5. Estoppel (equitable and collateral).
6. Waiver and Laches.
7. Payment and/or Setoff.
8. Failure of Consideration.
9. Unclean Hands.
10. Comparative/Contributory Fault under Ohio law.
11. Reservation – Defendant reserves the right to amend or supplement these defenses as discovery progresses and as permitted by Ohio R. Civ. P. 15.

V. COUNTERCLAIMS AND/OR CROSS-CLAIMS (IF ANY)

[// GUIDANCE: Under Ohio R. Civ. P. 13(A), compulsory counterclaims must be asserted in this pleading or are lost. Delete this section if none.]

1. Nature of Counterclaim.
2. Jurisdiction & Venue.
3. Factual Allegations.
4. Causes of Action.
5. Prayer for Counterclaim Relief.

VI. PRAYER FOR RELIEF

WHEREFORE, Defendant respectfully requests that the Court:
A. Dismiss the Complaint with prejudice;
B. Enter judgment in Defendant’s favor on all claims;
C. Award Defendant its costs and such further relief as the Court deems just and proper;
D. Grant any additional relief requested in Defendant’s counterclaims.

VII. VERIFICATION (If Required)

[// GUIDANCE: Only include if the Complaint was verified or local rule/court order requires it.]

I, [NAME], being duly sworn, state that the foregoing answers are true and correct to the best of my knowledge, information, and belief.

[NAME], [TITLE]
[DEFENDANT NAME]

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

Notary Public

VIII. JURY DEMAND (If Applicable)

[// GUIDANCE: Metadata indicates “not applicable,” but add if strategic.]
Defendant demands a trial by jury on all issues so triable. (Ohio R. Civ. P. 38).

IX. SIGNATURE BLOCK

Respectfully submitted,

text

[ATTORNEY NAME] (Bar No. _)
[LAW FIRM NAME]
[Street Address]
[City], Ohio [ZIP]
Tel: [###-###-####]
Email: [_@____.com]
Counsel for Defendant [DEFENDANT NAME]

X. CERTIFICATE OF SERVICE

I certify that a true and accurate copy of the foregoing Answer was served on this ___ day of ____, 20__, by [method, e.g., electronic filing system / U.S. Mail] upon:

[Plaintiff’s Counsel Name]
[Law Firm]
[Address / Email]

[ATTORNEY NAME]

[// GUIDANCE:
1. Review local rules for caption formatting, font, page limits, and electronic filing requirements.
2. Confirm whether the county’s common pleas court requires a civil case designation form or filing cover sheet.
3. Preserve all potential insurance, contractual, or statutory notice requirements separately.
4. Maintain a redline with any later amendments to preserve the record of timely filings.
]