Answer to Complaint Template – Free Download 2026

IN THE [____________] COURT OF [____________], STATE OF [____________]. [Plaintiff Name], Plaintiff, v. [Defendant Name], Defendant. Case No.: [____________]. DEFENDANT'S ANSWER TO COMPLAINT AND AFFIRMATIVE DEFENSES. Defendant [____________] ("Defendant"), by and through undersigned counsel, hereby responds to Plaintiff's Complaint filed on [____________] and states as follows. Each numbered paragraph of this Answer corresponds to the identically numbered paragraph of the Complaint.

Defendant admits that this Court has subject-matter jurisdiction over this action [pursuant to [____________] / as alleged in paragraph [__] of the Complaint], but denies any remaining jurisdictional allegations not expressly admitted herein. Defendant [admits / denies / is without sufficient knowledge or information to admit or deny] that venue is proper in this Court and therefore denies the same. Defendant reserves all rights to challenge jurisdiction or venue on any ground not expressly waived by this Answer.

As to each numbered paragraph of the Complaint, Defendant responds as follows: ADMITTED — Defendant admits the allegations contained in paragraphs [____________] of the Complaint. DENIED — Defendant denies the allegations contained in paragraphs [____________] of the Complaint and demands strict proof thereof. INSUFFICIENT KNOWLEDGE — Defendant is without sufficient knowledge or information to form a belief as to the truth of the allegations contained in paragraphs [____________] and therefore denies the same.

Any allegation of the Complaint not expressly admitted herein is denied. To the extent any paragraph of the Complaint contains legal conclusions rather than factual allegations, no response is required; however, to the extent a response is deemed required, Defendant denies each such legal conclusion. Defendant expressly denies that Plaintiff is entitled to any damages, relief, or remedy of any kind or nature whatsoever, whether as alleged in the Complaint or otherwise.

With respect to any exhibit attached to the Complaint, Defendant [admits / denies] that each exhibit is a true and correct copy of the document it purports to represent, and [admits / denies] any characterizations of such exhibits made by Plaintiff in the Complaint. Defendant reserves the right to contest the admissibility of any exhibit and to offer additional context or interpretation of any document that Plaintiff has partially quoted or excerpted.

FIRST AFFIRMATIVE DEFENSE (Statute of Limitations): Plaintiff's claims are barred, in whole or in part, by the applicable statute of limitations. Plaintiff knew or should have known of the alleged injury or damage giving rise to this action more than [____________] years prior to the filing of the Complaint, and thus Plaintiff's claims are time-barred under [applicable statute]. SECOND AFFIRMATIVE DEFENSE (Failure to State a Claim): The Complaint fails to state a claim upon which relief can be granted because [Plaintiff has not adequately alleged all elements of the purported cause(s) of action / the facts alleged, even if true, do not support the legal theories asserted].

THIRD AFFIRMATIVE DEFENSE (Contributory / Comparative Negligence): Plaintiff's own negligence, comparative fault, or contributory conduct proximately caused or contributed to Plaintiff's alleged damages. Any recovery by Plaintiff must be reduced in proportion to Plaintiff's percentage of fault. FOURTH AFFIRMATIVE DEFENSE (Assumption of Risk): Plaintiff voluntarily and knowingly assumed the risks inherent in the activity or transaction giving rise to this action. FIFTH AFFIRMATIVE DEFENSE (Waiver, Estoppel, and Laches): Plaintiff's claims are barred by waiver, equitable estoppel, and/or laches based on Plaintiff's conduct, representations, and unreasonable delay.

SIXTH AFFIRMATIVE DEFENSE (Failure to Mitigate): Plaintiff failed to take reasonable steps to mitigate the damages alleged in the Complaint, and any recovery must be reduced accordingly. SEVENTH AFFIRMATIVE DEFENSE (Payment / Accord and Satisfaction): Plaintiff's claims are barred to the extent that Defendant has previously paid or otherwise satisfied the obligations alleged. Defendant reserves the right to assert additional affirmative defenses as discovery proceeds and facts are developed, and hereby preserves all affirmative defenses available under applicable procedural and substantive law.

[IF APPLICABLE:] Defendant hereby asserts the following Counterclaim(s) against Plaintiff: COUNTERCLAIM I — [____________]: Defendant realleges and incorporates by reference all admissions, denials, and defenses set forth above. On or about [____________], Plaintiff [describe the conduct giving rise to the counterclaim with specificity: ____________]. As a direct and proximate result of Plaintiff's conduct, Defendant has suffered damages in an amount to be determined at trial, but not less than $[____________], together with interest, costs, and attorneys' fees as permitted by law.

COUNTERCLAIM II — [____________] [if applicable]: Plaintiff's [conduct / breach / misrepresentation / other: ____________] also gives rise to a claim for [breach of contract / fraud / unjust enrichment / other cause of action: ____________]. The elements of this claim are satisfied because [____________]. Defendant demands judgment on this Counterclaim in an amount to be proven at trial, together with all available equitable and legal relief. This Court has jurisdiction over these Counterclaims pursuant to [____________], as they arise from the same transactions and occurrences alleged in the Complaint.

WHEREFORE, Defendant respectfully requests that the Court enter judgment as follows: (a) dismiss the Complaint in its entirety with prejudice; (b) deny all relief requested by Plaintiff; (c) award Defendant its costs of suit, including reasonable attorneys' fees to the extent permitted by applicable law or contract; (d) award Defendant judgment on each Counterclaim asserted herein in an amount to be proven at trial; and (e) grant such other and further relief as the Court deems just and proper.

JURY DEMAND: Defendant hereby demands a trial by jury on all issues so triable pursuant to [Federal Rule of Civil Procedure 38 / applicable state rule of civil procedure]. Respectfully submitted, [Defendant's Name / Counsel for Defendant]. Dated: [____________]. Signature: [____________]. [Attorney Name, Bar No., Firm, Address, Phone, Email — if represented by counsel.] Certificate of Service: I hereby certify that on [____________], a true and correct copy of the foregoing was served upon Plaintiff's counsel of record by [____________].