IN THE DISTRICT COURT OF THE ___ JUDICIAL DISTRICT
____ COUNTY, STATE OF WYOMING
[PLAINTIFF(S) NAME],
Plaintiff,
v. Civil Action No. [____]
[DEFENDANT(S) NAME],
Defendant.
_______/
DEFENDANT’S ANSWER AND GENERAL DENIAL
[// GUIDANCE: Title the pleading exactly as required by the local court’s formatting rules. Confirm font size, margins, caption arrangement, and whether a pleading index cover sheet is required in the specific Wyoming district.]
I. PRELIMINARY STATEMENT
-
Defendant, by and through undersigned counsel, timely files this Answer pursuant to the Wyoming Rules of Civil Procedure (“W.R.C.P.”) and within the period allowed for response to the Complaint.
[// GUIDANCE: Wyoming currently affords 20 days from service to answer most complaints. Verify the time limit under the version of W.R.C.P. 12(a) in effect on the filing date, and adjust if service was effected under any method that extends or shortens the deadline (e.g., waiver of service, publication, etc.).] -
Except as expressly admitted herein, Defendant denies each and every allegation, matter, and thing contained in Plaintiff’s Complaint, and strict proof is demanded thereof.
II. RESPONSES TO NUMBERED PARAGRAPHS
[// GUIDANCE: If the Complaint is verified or if the presiding judge’s procedural preferences require paragraph-by-paragraph responses, insert a table or numbered list tracking each paragraph. If a “short-form” general denial is sufficient under local practice, replace the following with one comprehensive denial paragraph.]
- Paragraph 1 of the Complaint: Defendant lacks knowledge or information sufficient to form a belief as to the truth of the allegations, and therefore denies same.
- Paragraph 2 of the Complaint: Admitted that ____. All remaining allegations are denied.
- Paragraph 3 of the Complaint: Denied.
- Paragraph 4 of the Complaint: Denied.
…
n. Paragraph n of the Complaint: Denied.
III. AFFIRMATIVE DEFENSES
[// GUIDANCE: Assert every applicable defense now; unpled defenses may be deemed waived. Below is a non-exhaustive checklist derived from W.R.C.P. 8(c). Delete inapplicable defenses and add case-specific ones.]
- Failure to State a Claim.
- Lack of Standing.
- Statute of Limitations.
- Estoppel (including collateral and equitable).
- Waiver and Release.
- Accord and Satisfaction.
- Payment.
- Laches.
- Unclean Hands.
- Comparative Fault / Contributory Negligence.
- Failure of Consideration.
- Fraud.
- Duress.
- Illegality.
- Statute of Frauds.
- Setoff and/or Recoupment.
- Reservation of Right to Assert Additional Defenses.
Defendant reserves the right to assert any additional defenses that become known during discovery or investigation.
IV. COUNTERCLAIMS (OPTIONAL)
[// GUIDANCE: Under W.R.C.P. 13, counterclaims that arise out of the transaction or occurrence of Plaintiff’s claim are compulsory. If none exist, state “Defendant asserts no counterclaims at this time.”]
- Parties. Defendant/Counter-Plaintiff: [_]; Plaintiff/Counter-Defendant: [_].
- Jurisdiction & Venue. This Court has subject-matter jurisdiction over the counterclaim and venue is proper because [state basis].
- Factual Background.
a. …
b. … - Claims for Relief.
a. Count I – Breach of Contract.
b. Count II – (additional claims). - Damages. Defendant seeks actual damages, pre- and post-judgment interest, fees, costs, and any other relief deemed just and proper.
V. PRAYER FOR RELIEF
WHEREFORE, Defendant respectfully requests that the Court:
A. Dismiss Plaintiff’s Complaint with prejudice;
B. Enter judgment in favor of Defendant;
C. Award Defendant costs as allowed by law;
D. Grant such other and further relief as the Court deems just and equitable.
VI. DEMAND FOR JURY TRIAL (IF APPLICABLE)
[// GUIDANCE: The user indicated “Jury Waiver: not_applicable.” Delete this section if a jury is not sought.]
Defendant hereby demands a trial by jury on all issues so triable.
VII. VERIFICATION (IF REQUIRED)
[// GUIDANCE: Wyoming does not routinely require verification of answers, but some judges mandate it when the complaint was verified. Insert notarized verification only if necessary.]
VIII. CERTIFICATE OF SERVICE
I certify that on this ___ day of ____, 20__, a true and correct copy of the foregoing was served upon all counsel of record by [state method: CM/ECF, email, hand delivery, etc.].
[ATTORNEY NAME]
Wyoming Bar No. [____]
[Law Firm]
[Address] | [Phone] | [Email]
Attorney for Defendant