Defendant’s Answer and General Denial to Plaintiff’s Complaint

[// GUIDANCE: South Carolina common‐pleas pleading—general denial format. Customize bracketed items and delete guidance blocks before filing.]

I. DOCUMENT HEADER

STATE OF SOUTH CAROLINA )
) IN THE COURT OF COMMON PLEAS
[COUNTY] COUNTY )
) CASE NO.: [202X-CP-__-_]
____ )
[PLAINTIFF NAME], )
) DEFENDANT’S ANSWER AND
Plaintiff, ) GENERAL DENIAL TO
) PLAINTIFF’S COMPLAINT
v. )
)
[DEFENDANT NAME], )
)
Defendant. )
_______ )
Effective Date of Filing: [DATE]

II. PRELIMINARY STATEMENT

1. Pursuant to Rule 12(a), South Carolina Rules of Civil Procedure (“SCRCP”), Defendant files this Answer within thirty (30) days after service of the Complaint.
2. Any allegation not expressly admitted herein is denied.
3. Headings are for convenience only and do not limit the legal effect of any paragraph.

III. GENERAL RESPONSES TO NUMBERED ALLEGATIONS

[// GUIDANCE: Insert or delete individual paragraph responses as needed. For a pure “global” denial, Sections III-A and III-B below typically suffice.]

A. Incorporation by Reference

Defendant incorporates the Preliminary Statement and each Affirmative Defense set forth below as though fully restated in response to every paragraph of the Complaint.

B. Global Denial

Pursuant to Rule 8(b), SCRCP, Defendant denies each and every allegation of the Complaint, whether expressly or impliedly asserted, and specifically denies that Plaintiff is entitled to any relief whatsoever.

C. Specific Admissions and Denials (Optional)

[// GUIDANCE: Use if strategic to admit jurisdictional or identity facts.]
1. Paragraph 1: Defendant admits that this Court has subject-matter jurisdiction and that venue is proper in [COUNTY] County.
2. Paragraph 2: Defendant admits [ADMITTED FACTS, if any].
3. Defendant denies the remaining allegations of Paragraph 2 and each allegation of Paragraphs 3-[N], inclusive.

IV. AFFIRMATIVE DEFENSES

Without assuming any burden not imposed by law, and preserving all defenses, Defendant asserts the following under Rule 8(c), SCRCP. Discovery is ongoing, and Defendant reserves the right to amend or supplement these defenses as permitted by Rule 15, SCRCP.

1. Failure to State a Claim – Rule 12(b)(6).
2. Lack of Standing.
3. Statute of Limitations.
4. Statute of Frauds.
5. Waiver, Estoppel, and Laches.
6. Unclean Hands.
7. Accord and Satisfaction / Payment.
8. Failure of Consideration / Lack of Privity.
9. Comparative / Contributory Negligence.
10. Failure to Mitigate Damages.
11. Economic Loss Rule.
12. Set-Off and Recoupment.
13. Reservation of Additional Defenses – Defendant expressly reserves all defenses that may become known through discovery or law.

[// GUIDANCE: Delete, reorder, or add defenses to align with the facts and avoid frivolous assertions.]

V. COUNTERCLAIMS AND/OR CROSSCLAIMS (If Any)

[// GUIDANCE: Under Rules 13(a)–(b) & 18, SCRCP, assert compulsory or permissive counterclaims here. Delete entire section if none.]
Defendant asserts the following counterclaim(s) against Plaintiff:
1. [Counterclaim Caption]
a. Jurisdiction & Venue.
b. Statement of Facts.
c. Cause(s) of Action.
d. Prayer for Relief (see § VII).

VI. PRAYER FOR RELIEF

WHEREFORE, having fully answered, Defendant respectfully requests that the Court:

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

VII. JURY TRIAL DEMAND (If Applicable)

[// GUIDANCE: Remove if jury trial not desired.]
Defendant demands a trial by jury on all issues so triable.

VIII. VERIFICATION (Required Only If Plaintiff’s Complaint Is Verified)

STATE OF SOUTH CAROLINA)
) ss
[COUNTY] COUNTY )
The undersigned, being duly sworn, deposes and says that (s)he is the [TITLE/POSITION] of Defendant and that the foregoing Answer is true to the best of his/her knowledge, information, and belief.

[NAME], [TITLE]
Subscribed and sworn to before me on this ___ day of _, 20.

Notary Public for South Carolina
My Commission Expires: ____

IX. SIGNATURE BLOCK

Respectfully submitted this ___ day of _, 20.

[LAW FIRM NAME]
[Street Address]
[City], South Carolina [ZIP]
Telephone: [PHONE]
Email: [EMAIL]

By: _______
[ATTORNEY NAME], SC Bar No. [#####]
Attorney for Defendant

X. CERTIFICATE OF SERVICE

I hereby certify that I served a copy of the foregoing Answer on counsel for all parties by [method of service consistent with Rule 5(b), SCRCP] on the ___ day of _, 20.

[ATTORNEY NAME]

APPENDIX – KEY PROCEDURAL REFERENCES

1. Time to Answer: S.C. R. Civ. P. 12(a) (30 days after service).
2. General Denial/Admissions: S.C. R. Civ. P. 8(b).
3. Affirmative Defenses: S.C. R. Civ. P. 8(c).
4. Counterclaims: S.C. R. Civ. P. 13.

[// GUIDANCE: Citations limited per instructions—no case law; only foundational, well-established rules.]

[// GUIDANCE TO PRACTITIONER:
• Confirm service date to ensure timely filing.
• Evaluate whether strategic, partial admissions improve credibility.
• Verify whether a jury demand was included in the Complaint; if not, file within 10 days after service of the last pleading per Rule 38(b), SCRCP.
• If removing to federal court is under consideration, preserve all jurisdictional defenses and do not waive within this Answer.
• Consider motion practice (e.g., Rule 12(b)(6)) prior to or contemporaneous with Answer when appropriate.
• Review local court rules in [COUNTY] for additional signature or filing requirements (e-filing, coversheets, etc.).]