[// GUIDANCE: Delete guidance comments and complete all placeholders
before filing. Verify all facts, defenses, and timing
requirements against the operative Complaint and the
Oregon Rules of Civil Procedure (“ORCP”). ]

IN THE CIRCUIT COURT OF THE STATE OF OREGON

FOR THE COUNTY OF [COUNTY]

[PLAINTIFF NAME(S)],
  Plaintiff(s),
v.
[DEFENDANT NAME(S)],
  Defendant(s).

Case No. [###]

ANSWER AND GENERAL DENIAL OF DEFENDANT [DEFENDANT]

[// GUIDANCE: ORCP 15 D(1) generally requires an appearance/answer
within 30 days after service. Verify service date and
any extensions obtained.]

Defendant [DEFENDANT] (“Defendant”), by and through undersigned counsel, hereby appears and answers the Complaint of Plaintiff [PLAINTIFF] (“Plaintiff”) as follows:

I. PRELIMINARY STATEMENT & JURISDICTIONAL ALLEGATIONS

1. Appearance. Defendant appears pursuant to ORCP 7 C and ORCP 15 D(1) and submits this Answer within the time permitted.
2. Jurisdiction & Venue. Defendant admits that this Court has subject-matter jurisdiction and that venue is proper only to the extent such allegations are conclusions of law. All remaining jurisdictional or venue allegations are denied.
3. Reservation of Responsive Rights. Except as expressly admitted herein, Defendant denies each and every allegation of the Complaint and demands strict proof thereof.

II. GENERAL DENIAL (ORCP 19 B)

Pursuant to ORCP 19 B, Defendant generally and specifically denies each and every material allegation of the Complaint not expressly admitted herein and puts Plaintiff to its strict burden of proof.

[// GUIDANCE: Oregon practice customarily addresses each paragraph of
the Complaint. A true general denial is permitted
under ORCP 19 B when the pleader “intends in good faith
to controvert all allegations.” If any allegation is
partially true, expressly admit the undisputed portion
and deny or qualify the remainder.]

III. AFFIRMATIVE DEFENSES

Without conceding the allocation of the burden of proof, and reserving the right to amend under ORCP 23 A, Defendant asserts the following affirmative defenses pursuant to ORCP 19 B:

1. Failure to State a Claim – The Complaint fails to state facts sufficient to constitute a claim for relief.
2. Lack of Standing – Plaintiff lacks standing to assert one or more claims.
3. Statute of Limitations – One or more claims are barred, in whole or in part, by the applicable limitation period(s) under ORS Chapter [###] (insert specific statute).
4. Comparative Fault – To the extent Plaintiff sustained any damages, such damages were caused or contributed to by Plaintiff’s own negligence or fault in excess of any fault, if any, attributable to Defendant, reducing or barring recovery under ORS 31.600.
5. Failure to Mitigate – Plaintiff failed to take reasonable steps to mitigate alleged damages.
6. Setoff / Recoupment – Any recovery must be reduced or barred by amounts owed by Plaintiff to Defendant.
7. Waiver, Estoppel, & Laches – Plaintiff’s claims are barred, in whole or in part, by the doctrines of waiver, estoppel, and/or laches.
8. Reservation of Additional Defenses – Defendant reserves the right to assert additional defenses that become known during discovery.

[// GUIDANCE: Delete, renumber, or supplement defenses to fit the
facts. Under ORCP 19 B, defenses not pled may be
deemed waived.]

IV. COUNTERCLAIMS (ORCP 22 A) [Optional]

[// GUIDANCE: Counterclaims in Oregon are permissive unless arising
out of the same contract in actions on contracts for
recovery of money. Insert any counterclaim(s) here or
remove entire section if none.]

V. PRAYER FOR RELIEF

WHEREFORE, Defendant respectfully requests that the Court enter judgment:
A. Dismissing the Complaint with prejudice;
B. Awarding Defendant its costs and disbursements incurred herein; and
C. Granting such other and further relief as the Court deems just and equitable.

VI. DEMAND FOR ATTORNEY FEES [If Applicable]

Pursuant to ORS 20.096 and/or any contractual or statutory right, Defendant seeks an award of reasonable attorney fees.

VII. RESERVATION OF RIGHTS TO AMEND

Defendant reserves the right to amend this Answer and to assert additional defenses, counterclaims, or third-party claims as discovery may warrant, consistent with ORCP 23.

VIII. CERTIFICATION (ORCP 17)

The undersigned certifies that this pleading is not presented for any improper purpose, that the legal contentions are warranted by existing law or a non-frivolous extension thereof, and that factual contentions have evidentiary support.

IX. CERTIFICATE OF SERVICE (ORCP 9)

I hereby certify that on [DATE] I caused a true and correct copy of the foregoing ANSWER AND GENERAL DENIAL to be served upon the following by:
☐ U.S. Mail ☐ Hand Delivery ☐ Email (per ORCP 9 G) ☐ eFiling
[NAME & ADDRESS OF OPPOSING COUNSEL]

/s/ [ATTORNEY NAME]
[ATTORNEY NAME] (OSB No. [#####])
[LAW FIRM NAME]
[ADDRESS] • [PHONE] • [EMAIL]
Counsel for Defendant [DEFENDANT]

Date: [DATE]

[// GUIDANCE:
1. Verify that any attorney-fee demand is supported by statute, contract, or ORCP 68 A(1).
2. Confirm service method complies with ORCP 9 B–G and any eFile rules of the particular Circuit Court.
3. Consider whether a jury demand, claim for contribution, or third-party practice under ORCP 22 C is necessary.
4. Maintain internal deadlines: answer amendments (ORCP 23 A), discovery scheduling orders, and dispositive-motion cut-offs.
]