STATE COURT ANSWER – GENERAL DENIAL

Washington Superior Court Template

[// GUIDANCE: This pleading is drafted for use in any Washington Superior Court proceeding governed by the Washington Court Rules (“CR”). It assumes the defendant is answering a standard civil Complaint. Attorneys must tailor the template to the facts, court, and local rules (including e‐filing formatting requirements).]

TABLE OF CONTENTS

1. Document Header
2. Preliminary Statement
3. Specific Admissions & Denials
4. General Denial
5. Affirmative Defenses
6. Counterclaims (Optional)
7. Reservation of Additional Defenses
8. Prayer for Relief
9. Certification Under CR 11
10. Verification (if required)
11. Signature Block

1. DOCUMENT HEADER

plaintext
HON. [JUDGE NAME]

IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON
IN AND FOR THE COUNTY OF [COUNTY]

[PLAINTIFF FULL LEGAL NAME], )
) Case No. [_]
Plaintiff, )
) DEFENDANT [NAME]’S ANSWER,
v. ) GENERAL DENIAL, AFFIRMATIVE
) DEFENSES, AND [OPTIONAL]
[DEFENDANT FULL LEGAL NAME], ) COUNTERCLAIMS
)
Defendant. )
_____)
Effective Date of Filing: ___

2. PRELIMINARY STATEMENT

1. Defendant [DEFENDANT NAME] (“Defendant”) answers the Complaint filed by Plaintiff [PLAINTIFF NAME] (“Plaintiff”) pursuant to Washington Superior Court Civil Rule 8(b).
2. Unless expressly admitted herein, all allegations of the Complaint are denied.
3. Paragraph numbers below correspond to the sequentially numbered paragraphs of the Complaint.

[// GUIDANCE: Delete or renumber paragraphs to match the actual Complaint.]

3. SPECIFIC ADMISSIONS & DENIALS

plaintext
Paragraph No. Response
-------------- ------------------------------------------------------------
1 ☐ Admitted.
2 ☐ Denied.
3 ☐ Lacks knowledge or information sufficient to form a belief
as to the truth of the allegation and therefore denies the
same pursuant to CR 8(b).
4–## [Continue as necessary]
[// GUIDANCE: For each allegation, select one of the three standard responses—Admit, Deny, or Lacks Knowledge—and provide any qualified responses as appropriate.]

4. GENERAL DENIAL

Without limiting the foregoing, and pursuant to CR 8(b), Defendant denies each and every allegation, matter, and thing in the Complaint not specifically and unequivocally admitted herein.

5. AFFIRMATIVE DEFENSES

[// GUIDANCE: CR 8(c) requires that affirmative defenses be pleaded or they are generally waived. Insert only those defenses that have a good-faith basis after reasonable inquiry. Delete inapplicable defenses.]

1. Failure to State a Claim
2. Lack of Standing
3. Statute of Limitations (RCW [INSERT])
4. Statute of Frauds (RCW 19.36.010)
5. Accord and Satisfaction
6. Payment and Discharge
7. Estoppel
8. Waiver
9. Laches
10. Comparative Fault (RCW 4.22.005)
11. Assumption of Risk
12. Release
13. Res Judicata / Collateral Estoppel
14. Unclean Hands
15. Illegality
16. Failure of Consideration
17. Duress / Undue Influence
18. Discharge in Bankruptcy (11 U.S.C. § 524)
19. Privilege, Immunity, and Justification
20. Mitigation of Damages
21. Force Majeure / Impossibility
22. Reservation of Right to Assert Additional Defenses (see Section 7)

6. COUNTERCLAIMS (OPTIONAL)

[// GUIDANCE: CR 13(a) governs compulsory counterclaims; CR 13(b) governs permissive counterclaims. Insert only if applicable and be certain the court has subject-matter jurisdiction over the counterclaim.]

6.1 Parties

1. Counter-Claimant: [DEFENDANT NAME].
2. Counter-Defendant: [PLAINTIFF NAME].

6.2 Jurisdiction & Venue

Venue is proper in this Court under RCW 4.12.010 because the claims arise in [COUNTY] County, Washington.

6.3 Factual Allegations

[PLACEHOLDER – concise statement of facts giving rise to counterclaim.]

6.4 Causes of Action

Count One – [e.g., Breach of Contract]
Count Two – [e.g., Negligence]
[Add additional counts as required.]

6.5 Damages

Counter-Claimant seeks damages in an amount to be proven at trial, together with prejudgment interest, costs, and reasonable attorney fees where allowable by contract or statute.

6.6 Prayer on Counterclaims

WHEREFORE, Counter-Claimant prays for judgment against Counter-Defendant as set forth in Section 8 below.

7. RESERVATION OF ADDITIONAL DEFENSES

Defendant reserves the right to amend this Answer to assert additional defenses, counterclaims, or third-party claims as discovery progresses and as permitted by CR 15.

8. PRAYER FOR RELIEF

WHEREFORE, Defendant respectfully requests that the Court:
A. Dismiss Plaintiff’s Complaint in its entirety with prejudice;
B. Enter judgment in favor of Defendant on all claims;
C. Award Defendant its costs and disbursements as authorized by RCW 4.84.010 et seq.;
D. Award attorney fees where permitted by contract or statute;
E. Grant such other and further relief as the Court deems just and equitable.

9. CERTIFICATION UNDER CR 11

I certify (or declare) that to the best of my knowledge, information, and belief, formed after an inquiry reasonable under the circumstances, the foregoing is well-grounded in fact and is warranted by existing law or a good-faith argument for the extension, modification, or reversal of existing law, and is not interposed for any improper purpose.
DATED: __, 20.

10. VERIFICATION (required only when a statute specifically mandates verified pleadings)

plaintext
STATE OF WASHINGTON )
) ss.
COUNTY OF [COUNTY] )

I, [NAME], being first duly sworn, depose and say that I am the
[Defendant / authorized representative] in the above-entitled action; that I
have read the foregoing Answer and know the contents thereof; and that the
same is true and correct to the best of my knowledge, information, and belief.

[NAME]
SUBSCRIBED AND SWORN to before me this _ day of _, 20__.

Notary Public in and for the State of Washington
My Commission Expires: ______
[// GUIDANCE: Omit the verification section entirely unless a statute (e.g., unlawful detainer, RCW 59.12) or court order specifically requires it.]

11. SIGNATURE BLOCK

plaintext
Respectfully submitted,

[ATTORNEY NAME], WSBA No. [_]
[Law Firm Name]
[Street Address]
[City, State ZIP]
Telephone: [--_]
Email: [email address]
Attorney for Defendant [NAME]

KEY WASHINGTON PRACTICE NOTES

1. Answer Deadlines (CR 4 & CR 12):
   • 20 days after service within Washington.
   • 60 days after service outside Washington or by publication.
   • If a motion under CR 12 is timely filed, the time to answer is tolled until ten (10) days after the court’s disposition of the motion (CR 12(a)(4)).

2. Form of Pleadings (CR 10):
   • Use line numbering and margin requirements mandated by local rules.
   • Pleadings must be typed or printed, double-spaced, on letter-size paper.

3. Affirmative Defenses:
   • Each must be stated “separately and distinctly.”
   • Burden of proof rests on the party asserting the defense.

4. Counterclaims:
   • Compulsory counterclaims (arising out of the same transaction or occurrence) must be stated or they are barred.
   • Permissive counterclaims require an independent jurisdictional basis if they exceed the monetary limits of district court removal.

5. Case Schedule & DCM:
   • Many counties issue an automatic Case Schedule upon filing of the Complaint. Review and calendar all deadlines immediately.

6. Service & E-Service:
   • Confirm whether the opposing party has consented to e-service under CR 5(b)(7).

7. Local Rules:
   • Always consult the Local Civil Rules (“LCR”) for the county of filing.

[// GUIDANCE: Save the completed document as a Word or PDF file using your court’s mandated format. Verify that all placeholders are updated, the certificate of service is attached if required, and that any counterclaims are accompanied by the appropriate filing fee if one is assessed by the clerk.]