[// GUIDANCE: This template is drafted to comply with the Rhode Island
Superior Court Rules of Civil Procedure (“R.I. Super. Ct. R. Civ. P.”).
All bracketed items must be completed or deleted before filing. Practitioners
should confirm any local-county formatting, font, or e-filing requirements.]

I. DOCUMENT HEADER

STATE OF RHODE ISLAND
[____] COUNTY SUPERIOR COURT

[PLAINTIFF NAME(S)], :
Plaintiff(s), :
:
v. : C.A. No. [____]
:
[DEFENDANT NAME(S)], :
Defendant(s). :

DEFENDANT[S]’ ANSWER
AND GENERAL DENIAL TO
PLAINTIFF[S]’ [AMENDED] COMPLAINT
(R.I. Super. Ct. R. Civ. P. 8, 12)

Defendant[s] [full legal name(s)] (“Defendant”), by and through undersigned
counsel, hereby answer(s) the Complaint of Plaintiff[s] [full legal name(s)]
(“Plaintiff”) as follows:

II. PRELIMINARY STATEMENT & DEFINITIONS

1. Unless otherwise indicated, capitalized terms herein have the meanings
   ascribed in the Complaint.
2. “Rules” means the Rhode Island Superior Court Rules of Civil Procedure.
3. All allegations not expressly admitted are denied.

[// GUIDANCE: Many Rhode Island judges prefer succinct pleadings. Delete
this Definitions section if unnecessary.]

III. RESPONSES TO NUMBERED ALLEGATIONS

[// GUIDANCE: Copy each paragraph of the Complaint verbatim or by
reference, then answer. A sample format follows.]

1. Paragraph 1 of the Complaint contains legal conclusions to which no
   response is required. To the extent a response is deemed required,
   Defendant denies the allegations.

2. Defendant admits that ________. Defendant otherwise denies
   the allegations of Paragraph 2.

3. Defendant lacks knowledge or information sufficient to form a belief as
   to the truth of the allegations in Paragraph 3 and therefore denies the
   same pursuant to R.I. Super. Ct. R. Civ. P. 8(b).

[Repeat as necessary for each paragraph of the Complaint.]

IV. GENERAL DENIAL

Pursuant to R.I. Super. Ct. R. Civ. P. 8(b) and 8(d), Defendant expressly
denies each and every allegation in the Complaint not specifically admitted
herein and demands strict proof thereof at trial.

V. AFFIRMATIVE DEFENSES

Without assuming any burden that would otherwise rest on Plaintiff, and
expressly reserving the right to amend or supplement these defenses, Defendant
asserts the following:

1. Failure to State a Claim (Rule 12(b)(6)).
2. Lack of Subject-Matter Jurisdiction (Rule 12(b)(1)).
3. Lack of Personal Jurisdiction (Rule 12(b)(2)).
4. Improper Venue (Rule 12(b)(3)).
5. Insufficiency of Process or Service of Process (Rule 12(b)(4)-(5)).
6. Statute of Limitations / Statute of Repose.
7. Payment, Accord and Satisfaction, and/or Set-Off.
8. Estoppel, Waiver, and Ratification.
9. Laches and/or Unclean Hands.
10. Comparative and/or Contributory Negligence.
11. Failure to Mitigate Damages.
12. Compliance With Applicable Law and/or Contract.
13. Reservation of Rights to Assert Additional Defenses Discovered Through
    Investigation or Discovery.

[// GUIDANCE: List only defenses that have a good-faith basis after Rule 11
inquiry. Renumber or delete as appropriate.]

VI. COUNTERCLAIMS AND CROSS-CLAIMS

A. Compulsory Counterclaims (Rule 13(a))
[COUNTERCLAIM COUNT I – (e.g., Breach of Contract)]
[Insert pleading with jurisdictional statement, factual allegations,
elements, and prayer for relief.]

B. Permissive Counterclaims (Rule 13(b))
[COUNTERCLAIM COUNT II – (e.g., Declaratory Judgment)]

C. Reservation
To the extent investigation and discovery reveal additional claims,
Defendant reserves the right to seek leave to amend under Rule 15.

[// GUIDANCE: If no counterclaims are asserted, replace Section VI with:
“Defendant asserts no counterclaims at this time but reserves all rights
under Rules 13 and 15 to assert such claims upon further investigation.”]

VII. PRAYER FOR RELIEF

WHEREFORE, Defendant respectfully requests that this Court:

A. Dismiss the Complaint with prejudice;
B. Enter judgment in favor of Defendant on all claims;
C. Award Defendant its costs, disbursements, and reasonable attorneys’ fees
as permitted by law; and
D. Grant such other and further relief as the Court deems just and proper.

VIII. RESERVATION OF ADDITIONAL DEFENSES

Defendant reserves the right to amend this Answer and to assert additional
defenses, counterclaims, and cross-claims as discovery proceeds or as
otherwise permitted by the Rules.

IX. VERIFICATION (if required)

[// GUIDANCE: Rhode Island practice does not generally require a verified
answer. Include only if the underlying statute or the Court’s order so
mandates.]

X. RULE 11 CERTIFICATION

Undersigned counsel certifies that the foregoing pleading is submitted in
good faith and after reasonable inquiry, and that the contentions herein are
warranted by existing law or by a nonfrivolous argument for the extension,
modification, or reversal of existing law, pursuant to R.I. Super. Ct.
R. Civ. P. 11.

XI. CERTIFICATE OF SERVICE

I hereby certify that on this [___] day of [Month] [Year], a true and
accurate copy of the foregoing Defendant’s Answer was electronically filed
and served via the Rhode Island Judiciary’s Electronic Filing System (ECF)
upon all counsel of record.

/s/ [Attorney Name]
[Attorney Name] (#RI Bar No.)
[Law Firm Name]
[Street Address]
[City, State ZIP]
Tel: []-[]-[_]
Email: [_____]

IMPORTANT RHODE ISLAND TIMING NOTES

[// GUIDANCE: Under Rule 12(a)(1)(A), an answer must be served “within 20
days after the service of the summons and complaint,” unless (i) the case is
removed to federal court, (ii) the parties agree to extension, or (iii) the
Court orders otherwise. Calendar all dates accordingly.]