Attorney

1 123 Main Street

Anytown, US 12345
2

4 DISTRICT COURT OF ___________________

5
) Case No.: 123456-123
6 Joe Smith, )
)
7 Plaintiff, )
) ANSWER
8 vs. )
)
9 ABC Plumbing, Inc, )
)
10 Defendant )

11 As the Defendant, you’ll want to address and answer each paragraph or count

12 brought from in the Complaint in the order it was present in the Complaint. After you

13 have responded to all counts or allegations, then any affirmative defenses (additional

14 issues raised by yourself) can be addressed such as Failure to State a Cause of

15 Action, Statute of Limitations and Failure to Property Serve).

16 COMES NOW the Defendant ABC Plumbing, Inc. in answering the allegations of the

17 Complaint on file herein, affirms, denies and alleges as follows:

18 Answering the allegations of Paragraph 1-5 of the Complaint herein, Defendant

19 affirms all facts.

20 Answering the allegations of Paragraph 6 of the Complaint herein, Defendant

21 affirms in part based on his knowledge of the incident, but denies that the injuries

22 sustained were a result of his plumbing work performed at the residence.

23 Answering Count 1 – Negligence of the Complaint herein, Defendant denies all

24 allegations. On or about July 1, 2009, Defendant was contracted to perform plumbing

25 work on the Plaintiff’s bathroom and kitchen at his residence. On or about July 5,

26 2009, Defendant performed all plumbing work as agreed upon in the residence and did

27 not perform any work related to the wiring of the Plaintiff’s residence. Furthermore,

28 the plumbing work performed was completed by the Defendant in a safe and effective

Answer - 1
www.NorthwestRegisteredAgent.com
 1 manner. This work was not the proximate cause or the cause-in-fact of the injuries

2 sustained by the Plaintiff.

3 The Defendant now brings forth the following Affirmative Defenses:

4 DEFENSE 1 – Failure to State a Claim

5 Defendant answering the Complaint herein, alleges that all allegations and

6 counts brought forth therein fails to state a claim for which relief can be granted.

7 As with the Complaint, typically there will be several defenses brought forth

8 depending on the complexity of the case.

9 WHEREFORE, Defendant prays that the Plaintiff take nothing and the Defendant

10 have judgment against the Plaintiff and recover the costs of suit herein, and such

11 other relief the court may deem proper.

12
Dated this 1st day of January, 2010
13

14

15 Attorney
Address
16 Address

17

18

19

20

21

22

23

24

25

26

27

28

Answer - 2
www.NorthwestRegisteredAgent.com