§ 9-11-120.Form of answer presenting defenses under subsection (b) of Code Section 9-11-12

An answer is a defendant’s chance to respond to everything in the complaint at once, and this form shows how much can fit inside a single pleading: four separate defenses, a counterclaim, and a cross-claim against a codefendant.

The First Defense repeats the failure-to-state-a-claim ground familiar from the article’s motion-to-dismiss form. The Second Defense adds that if the defendant owes anything, he owes it jointly with another named person who is alive, subject to the court’s jurisdiction, and has not been made a party — a defense pointed at a gap in who was sued. The Third Defense illustrates all three response options the Civil Practice Act allows for individual allegations in a single stroke: it admits two specific paragraphs, pleads lack of knowledge as to another, and denies everything else. The Fourth Defense raises a time bar, alleging the claim did not accrue within six years of filing.

Beneath the four defenses, the form adds a Counterclaim and a Cross-Claim Against Defendant M.N., both left as placeholders instructing the drafter to plead them “in the manner in which a claim is pleaded in a complaint.” That instruction shows how the same drafting rules governing an original complaint carry over to claims a defendant raises against the plaintiff or against a fellow defendant, all inside one answer.