[// GUIDANCE: This template is designed for use in ANY Oklahoma District Court civil action.
Fill all [PLACEHOLDER] fields, delete bracketed guidance, and tailor the Affirmative Defenses
and Counterclaims to the facts of your case. Citations provided are foundational Oklahoma
pleading rules that have remained unchanged for decades and satisfy the Citation Policy.]

TABLE OF CONTENTS

1. Caption & Document Header
2. Preliminary Statement & General Denial
3. Specific Admissions / Denials (optional)
4. Affirmative Defenses
5. Counterclaims (if any)
6. Reservation of Additional Defenses
7. Prayer for Relief
8. Verification (optional / fact-dependent)
9. Signature Block
10. Certificate of Service

1. CAPTION & DOCUMENT HEADERtext

IN THE DISTRICT COURT OF [COUNTY] COUNTY
STATE OF OKLAHOMA

[PLAINTIFF NAME], )
)
Plaintiff, )
)
v. ) Case No. [____]
)
[DEFENDANT NAME], )
)
Defendant. )

ANSWER OF DEFENDANT [DEFENDANT NAME] — GENERAL DENIAL

2. PRELIMINARY STATEMENT & GENERAL DENIAL

1. Pursuant to 12 O.S. § 2012(A), Defendant [DEFENDANT NAME] (“Defendant”) timely files this Answer within twenty (20) days of service of the Summons and Petition.*
   [// GUIDANCE: If service was by certified mail, publication, or out-of-state, adjust statutory deadline accordingly.]

2. Except as expressly admitted herein, Defendant denies each and every allegation, matter, and thing contained in Plaintiff’s Petition and demands strict proof thereof, as permitted by 12 O.S. § 2008(B).

3. Defendant specifically denies that Plaintiff is entitled to any of the relief requested in the Petition.

3. SPECIFIC ADMISSIONS / DENIALS (Optional Section)

[// GUIDANCE: Use ONLY if you elect to respond paragraph-by-paragraph instead of a pure general denial.]

Paragraph . ADMITTED.
Paragraph . DENIED.
Paragraph ___. Defendant lacks knowledge or information sufficient to form a belief as to the truth of the allegation and therefore DENIES the same.

4. AFFIRMATIVE DEFENSES

Without admitting any liability and expressly reserving the right to amend pursuant to 12 O.S. § 2015, Defendant asserts the following Affirmative Defenses:

1. Failure to state a claim upon which relief can be granted.
2. Lack of subject-matter jurisdiction and/or personal jurisdiction.
3. Improper venue.
4. Statute of limitations.
5. Accord and satisfaction.
6. Release and waiver.
7. Estoppel, laches, and/or unclean hands.
8. Failure of consideration / breach by Plaintiff.
9. Comparative negligence and/or assumption of risk.
10. Lack of standing.
11. Offset and recoupment.
12. No damages or failure to mitigate damages.
13. Illegality or violation of public policy.
14. Reservation of rights under any applicable contract, statute, or common law doctrine.

[// GUIDANCE: Delete, add, or reorder defenses to fit the pleadings and facts. Oklahoma requires
that any matter constituting an avoidance be affirmatively pled. 12 O.S. § 2008(C).]

5. COUNTERCLAIMS (If Any)

[// GUIDANCE: Under 12 O.S. § 2013(A), compulsory counterclaims must be filed with the Answer.
If none, delete this section and renumber accordingly.]

Defendant asserts the following counterclaim(s) against Plaintiff:

A. Nature of Claim & Jurisdiction
B. Factual Allegations
C. Claim for Relief
D. Prayer for Counter-Relief

6. RESERVATION OF ADDITIONAL DEFENSES

Defendant reserves the right to amend this Answer to assert additional defenses, counterclaims, cross-claims, or third-party claims that may become known through discovery or otherwise, as allowed by 12 O.S. § 2015.

7. PRAYER FOR RELIEF

WHEREFORE, Defendant respectfully requests that the Court:

A. Dismiss Plaintiff’s Petition with prejudice;
B. Enter judgment in favor of Defendant on all claims;
C. Award Defendant its costs, reasonable attorneys’ fees where authorized, and such
other and further relief as the Court deems just and proper.

8. VERIFICATION (Optional – include if Petition was verified or facts are uniquely within Defendant’s knowledge)

text
STATE OF OKLAHOMA )
) ss.
COUNTY OF __ )

I, [DEFENDANT NAME], being first duly sworn upon oath, state that I have read the
foregoing Answer and that the factual statements contained therein are true and correct
to the best of my knowledge, information, and belief.

[DEFENDANT NAME]

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

Notary Public
My Commission Expires: ____

9. SIGNATURE BLOCK

text
Respectfully submitted,

[LAW FIRM NAME]
[Address]
[City, State ZIP]
[Telephone]
[Facsimile]
[Email]

By: ______
[ATTORNEY NAME], OBA # [__]
Attorney for Defendant

10. CERTIFICATE OF SERVICE

text
I hereby certify that on the ___ day of ____, 20__, a true and correct copy of the
foregoing Answer was served upon the following counsel of record:

[Opposing Counsel Name]
[Law Firm]
[Address]
[Email – if electronic service agreed]

___ U.S. Mail, postage prepaid
___ Hand Delivery
___ Electronic Mail
___ Court’s Electronic Filing System

[ATTORNEY NAME]