IN THE [CIRCUIT/DISTRICT] COURT OF [COUNTY] COUNTY, ALABAMA

[PLAINTIFF NAME],
Plaintiff,

v. Civil Action No. [CASE NO.]

[DEFENDANT NAME],
Defendant.

DEFENDANT’S ANSWER AND GENERAL DENIAL

Pursuant to Rules 8, 12, and 13 of the Alabama Rules of Civil Procedure

[// GUIDANCE: This template provides a full-form “general denial” answer compliant with Alabama practice. Replace all bracketed text with matter-specific information and delete any inapplicable defenses before filing.]

I. PRELIMINARY STATEMENT & RESERVATION OF RIGHTS

1. Defendant timely files this Answer within the thirty-day period prescribed by Ala. R. Civ. P. 12(a).
2. By responding herein, Defendant does not admit that Plaintiff has stated a claim upon which relief may be granted, that this Court has personal or subject-matter jurisdiction, or that venue is proper, and expressly reserves the right to raise any applicable motions or additional defenses as discovery proceeds.

II. RESPONSES TO NUMBERED ALLEGATIONS

[// GUIDANCE: If a paragraph-by-paragraph response is preferred, copy each allegation verbatim or by number and respond “Admitted,” “Denied,” or “Defendant is without sufficient knowledge or information to form a belief and therefore denies.” For a pure general denial, use ¶1 below and omit individualized responses.]

1. Pursuant to Ala. R. Civ. P. 8(b), Defendant denies each and every material allegation of the Complaint and demands strict proof thereof.

III. AFFIRMATIVE DEFENSES

Without assuming any burden not imposed by law, and expressly reserving the right to amend, Defendant asserts the following defenses:

1. Failure to State a Claim – Ala. R. Civ. P. 12(b)(6).
2. Lack of Subject-Matter Jurisdiction – Ala. R. Civ. P. 12(b)(1).
3. Lack of Personal Jurisdiction – Ala. R. Civ. P. 12(b)(2).
4. Improper Venue – Ala. R. Civ. P. 12(b)(3).
5. Insufficiency of Process/Service – Ala. R. Civ. P. 12(b)(4)–(5).
6. Statute of Limitations (Code of Ala. 1975, §§ [INSERT]).
7. Contributory Negligence and/or Assumption of Risk (applicable in Alabama).
8. Comparative Fault of Non-Parties – Ala. Code § 6-5-522 & Ala. R. Civ. P. 14.
9. Failure of Consideration / Lack of Privity.
10. Accord and Satisfaction.
11. Payment and Discharge.
12. Waiver, Estoppel, and Laches.
13. Release and/or Settlement.
14. Statute of Frauds – Code of Ala. 1975, § 8-9-2.
15. Immunity and/or Qualified Privilege.
16. Illegality / Violation of Public Policy.
17. Res Judicata and Collateral Estoppel.
18. Lack of Standing.
19. Supervening / Intervening Cause.
20. Failure to Mitigate Damages.
21. Reservation of Additional Defenses – Defendant reserves the right to assert further defenses that become known through discovery.

[// GUIDANCE: Delete any defense that clearly does not apply; pleading in shotgun fashion risks Rule 11 sanctions.]

IV. COUNTERCLAIMS AND/OR CROSS-CLAIMS (Rule 13)

[COUNTERCLAIM/CROSS-CLAIM CAPTION]
1. [Insert compulsory counterclaims here to avoid waiver under Rule 13(a). If none, state “None at this time.”]

V. PRAYER FOR RELIEF

WHEREFORE, Defendant respectfully prays that:
A. Plaintiff takes nothing by the Complaint and that the same be dismissed with prejudice;
B. Judgment be entered in favor of Defendant together with costs taxed as provided by law;
C. Such other and further relief—general or specific, at law or in equity—as the Court deems just and proper be awarded to Defendant.

VI. JURY DEMAND

[Optional] Defendant demands trial by struck jury on all issues so triable.

VII. CERTIFICATE OF SERVICE

I certify that on this the ___ day of ____, 20__, I electronically filed and/or served a true and correct copy of the foregoing on all counsel of record:

• [NAME, ADDRESS, EMAIL OF OPPOSING COUNSEL]

/s/ [DEFENSE COUNSEL NAME]
[DEFENSE COUNSEL NAME] (ASB-_-_)
[LAW FIRM NAME]
[STREET ADDRESS]
[CITY], Alabama [ZIP]
Telephone: [] -
Email: [__@__.com]
Counsel for [Defendant Name]

[// GUIDANCE:
1. Verification is generally not required for an Answer in Alabama unless a statute so mandates. If needed, insert verification language above the signature block.
2. Review local rules for e-filing, word limits, and font size requirements.
3. Check standing orders for judge-specific formatting (e.g., double spacing, tab settings).]