The First Defense

While looking at the Complaint, go through each numbered paragraph and decide whether you agree or disagree with that statement.

List all of the numbers for the paragraphs you agree with on Line 2.

List all of the numbers for the paragraphs you disagree with on Line 3.

If you feel that you need to explain or clarify your response to something the Plaintiff said in the complaint, you can write that in Line 4. Use additional pages if necessary.

If you don’t have enough information to admit or deny something, you can say that in Line 4.

When talking about something the Plaintiff said, mention to the paragraph number so people can understand which one you are talking about.

If you are not sure about something, it is generally safest to just deny it. Once you admit something, you cannot argue about it later.