IN THE IOWA DISTRICT COURT FOR [__] COUNTY

[PLAINTIFF NAME], Plaintiff,
v.
[DEFENDANT NAME], Defendant.

Case No. [__]

ANSWER, GENERAL DENIAL, AFFIRMATIVE DEFENSES, AND RESERVATION OF RIGHTS

[// GUIDANCE: Iowa defendants must ordinarily file and serve an answer within 20 days after service of the Original Notice and Petition, unless another statute or court order extends the period. Calendaring this deadline is critical to avoid default.]

I. Preliminary Statement

1. Pursuant to the Iowa Rules of Civil Procedure, Defendant denies each and every allegation of the Complaint that is not expressly admitted below and demands strict proof thereof.
2. Defendant asserts the defenses set forth below without assuming any burden of proof that would otherwise rest on Plaintiff and reserves the right to amend this Answer to assert additional defenses, counterclaims, cross-claims, or third-party claims as discovery proceeds.

II. Responses to Numbered Allegations

[// GUIDANCE: Choose either paragraph-by-paragraph responses or a short-form general denial, depending on case strategy and judicial preference.]

Option A – Paragraph-by-Paragraph

1. Paragraph 1: Defendant admits that …; all remaining allegations are denied.
2. Paragraph 2: Defendant lacks knowledge or information sufficient to form a belief as to the truth of the allegations and therefore denies the same.
3. Paragraph 3: Denied.
   ⋮

Option B – Short-Form General Denial

Pursuant to the Iowa Rules of Civil Procedure permitting a short and plain statement of defenses, Defendant generally and specifically denies every material allegation of the Complaint and puts Plaintiff to its strict proof at trial.

III. Affirmative Defenses

Without conceding the applicability of any burden of proof and expressly reserving the right to add, amend, or withdraw defenses, Defendant pleads the following affirmative defenses:

1. Failure to State a Claim upon which relief may be granted.
2. Lack of Subject-Matter Jurisdiction.
3. Lack of Personal Jurisdiction and/or Insufficiency of Service of Process.
4. Statute of Limitations / Laches.
5. Accord and Satisfaction.
6. Release and Waiver.
7. Estoppel (Equitable and/or Collateral).
8. Failure or Lack of Consideration.
9. Payment.
10. Comparative Fault / Contributory Negligence.
11. Force Majeure / Impossibility / Frustration of Purpose.
12. Unclean Hands.
13. Set-Off and Recoupment.
14. Reservation of Additional Defenses that may become known during discovery.

[// GUIDANCE: Iowa practice requires certain defenses (e.g., statute of limitations, res judicata, estoppel) to be affirmatively pleaded or they are waived. Tailor, delete, or supplement the above list as facts dictate.]

IV. Counterclaims and Cross-Claims (If Any)

[Defendant asserts the following counterclaims against Plaintiff pursuant to the Iowa Rules of Civil Procedure:]

1. Counterclaim Count I – Breach of Contract
   a. Jurisdiction and Venue.
   b. Contract Formation and Terms.
   c. Plaintiff’s Breach.
   d. Damages.

2. Counterclaim Count II – [Additional Claim]
   ⋮

[// GUIDANCE: Iowa recognizes both compulsory and permissive counterclaims. Analyze whether the claim “arises out of the transaction or occurrence” giving rise to Plaintiff’s claim to avoid waiver.]

V. Prayer for Relief

WHEREFORE, Defendant respectfully requests that the Court:

A. Dismiss Plaintiff’s Complaint with prejudice;
B. Enter judgment in favor of Defendant on all claims;
C. Award Defendant its costs, disbursements, and, where authorized, reasonable attorney fees; and
D. Grant such other and further relief as the Court deems just and equitable.

VI. Demand for Jury Trial (If Applicable)

Defendant hereby demands a trial by jury on all issues so triable.

[// GUIDANCE: Strike this section if the matter is equitable or a contractual jury-trial waiver applies.]

VII. Verification (Optional/If Required)

STATE OF IOWA )
        ) ss:
COUNTY OF [___])

I, [Name], being first duly sworn, depose and state that I have read the foregoing Answer and that the statements therein are true to the best of my knowledge, information, and belief.

[Name & Title]

Subscribed and sworn before me this ___ day of ____, 20__.

Notary Public, State of Iowa

[// GUIDANCE: A verification is not ordinarily required for Iowa answers except in specific proceedings (e.g., replevin). Include only when necessary.]

VIII. Signature Block

Respectfully submitted,

[Attorney Name], AT No. [_]
[Law Firm Name]
[Street Address]
[City, State ZIP]
Telephone: [_]
Email: [_]

ATTORNEY FOR DEFENDANT

IX. Certificate of Service

The undersigned certifies that on the ___ day of ____, 20__, the foregoing Answer was electronically filed with the clerk of court using the EDMS system and was thereby served upon all parties of record. Any parties not registered with EDMS were served by [U.S. mail / personal service / email] as indicated below.

[Attorney Name]

[// GUIDANCE: Precisely describe the method of service for each party and retain proof (e.g., EDMS notice, mailing certificate) in the file.]