IN THE DISTRICT COURT OF THE STATE OF IDAHO

[___] JUDICIAL DISTRICT

IN AND FOR THE COUNTY OF [_____]

Plaintiff: [PLAINTIFF NAME]
Defendant: [DEFENDANT NAME]

Case No.: [_]

ANSWER, GENERAL DENIAL, AFFIRMATIVE DEFENSES, AND (OPTIONAL) COUNTERCLAIMS OF DEFENDANT [DEFENDANT NAME]

[// GUIDANCE: Idaho state-court answers are governed primarily by Idaho Rules of Civil Procedure (“I.R.C.P.”) 8, 10, 11, 12, and 13. An answer must be filed and served within 21 days after service of the summons and complaint. I.R.C.P. 12(a)(1)(A).]

TABLE OF CONTENTS

1. Preliminary Statement and Reservation of Rights
2. Jurisdictional and Introductory Allegations
3. General Denial and Specific Responses
4. Affirmative Defenses
5. Counterclaims (if asserted)
6. Prayer for Relief
7. Verification (if required)
8. Certificate of Service

1. PRELIMINARY STATEMENT AND RESERVATION OF RIGHTS

1.1 Defendant [DEFENDANT NAME] (“Defendant”), by and through undersigned counsel, submits this Answer pursuant to I.R.C.P. 8 and 12.

1.2 By answering, Defendant does not (i) concede that venue or jurisdiction is proper; (ii) waive any right to compel arbitration, removal, or transfer; (iii) waive any right to move to dismiss under I.R.C.P. 12(b); or (iv) waive any other right, claim, or defense available now or in the future.

2. JURISDICTIONAL AND INTRODUCTORY ALLEGATIONS

Paragraph 1 (Jurisdiction): Defendant admits that this Court has subject-matter jurisdiction pursuant to Idaho Code § [_] and proper venue under Idaho Code § [_] solely for purposes of this action.

Paragraph 2 (Parties): Defendant lacks knowledge or information sufficient to form a belief as to the truth of the allegations concerning Plaintiff’s residency and, on that basis, denies the same. Defendant admits its own corporate/individual status as alleged.

[// GUIDANCE: Continue paragraph-by-paragraph admissions/denials where strategic. Use “admit,” “deny,” or “lack knowledge or information and therefore deny.” Add additional paragraphs as needed.]

3. GENERAL DENIAL AND SPECIFIC RESPONSES

3.1 Pursuant to I.R.C.P. 8(b)(3), Defendant denies each and every allegation not expressly admitted herein and demands strict proof thereof.

3.2 Specific Paragraph Responses:
• Paragraph 3: Denied.
• Paragraph 4: Defendant lacks knowledge or information sufficient to form a belief and therefore denies.
• Paragraph 5: Admitted in part that [STATE PRECISE FACTS]; otherwise denied.
[Add additional paragraph-by-paragraph responses as needed.]

4. AFFIRMATIVE DEFENSES

Without admitting any burden of proof, Defendant asserts the following defenses under I.R.C.P. 8(c) and reserves the right to amend upon discovery of additional facts:

4.1 Failure to State a Claim – I.R.C.P. 12(b)(6).
4.2 Statute of Limitations – Idaho Code §§ [_].
4.3 Lack of Standing.
4.4 Comparative Fault – Idaho Code § 6-801 et seq.
4.5 Failure to Mitigate Damages.
4.6 Accord and Satisfaction / Settlement and Release.
4.7 Waiver and Estoppel.
4.8 Unclean Hands.
4.9 Laches.
4.10 Lack of Consideration (if contract claim).
4.11 Reservation – Additional defenses may be asserted as warranted by discovery.

[// GUIDANCE: Delete, edit, or add defenses to align with the facts. Idaho requires that affirmative defenses be stated in short, plain terms. I.R.C.P. 8(c).]

5. COUNTERCLAIMS (OPTIONAL)

[// GUIDANCE: Counterclaims permitted under I.R.C.P. 13. Compulsory counterclaims must be raised in this Answer or are waived. Permissive counterclaims may be asserted or reserved at Defendant’s option.]

5.1 Parties

Counterclaim-Plaintiff: [DEFENDANT NAME].
Counterclaim-Defendant: [PLAINTIFF NAME].

5.2 Jurisdiction

This Court has jurisdiction over the counterclaims pursuant to Idaho Code § [_] and I.R.C.P. 13.

5.3 General Allegations

1. On or about [DATE], Counterclaim-Defendant [DESCRIBE ACTION].
2. As a direct and proximate result, Counterclaim-Plaintiff suffered damages of [$____].

5.4 Causes of Action

Count I – Breach of Contract
Count II – Quantum Meruit / Unjust Enrichment
[Add counts as appropriate.]

5.5 Prayer on Counterclaims

Counterclaim-Plaintiff requests judgment in its favor for damages in an amount to be proven at trial, pre- and post-judgment interest, costs, attorney fees where allowed, and any further relief the Court deems just.

6. 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 and, where permitted, reasonable attorney fees pursuant to Idaho Code § 12-121 or other applicable authority; and
D. Grant such further relief as the Court deems just and proper.

7. VERIFICATION (Required only if Plaintiff’s complaint was verified; see I.R.C.P. 11(b))

I, [NAME], being first duly sworn, state that I have read the foregoing Answer and know the contents thereof, and that the same are true to the best of my knowledge, information, and belief.

[NAME], [TITLE]

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

Notary Public for the State of Idaho
Residing at: [_]
My Commission Expires: [_]

8. CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the ___ day of _, 20, I caused a true and correct copy of the foregoing Answer, General Denial, Affirmative Defenses, and (Optional) Counterclaims to be served as follows:

☐ U.S. Mail, postage prepaid
☐ Overnight delivery
☐ Hand delivery
☐ E-mail (by prior written consent)
☐ iCourt E-File & Serve

to: [OPPOSING COUNSEL NAME]
[LAW FIRM]
[ADDRESS]
[E-MAIL]

[ATTORNEY NAME], ISB No. [_]
[LAW FIRM NAME]
[ADDRESS]
[PHONE] | [E-MAIL]
Attorney for Defendant

ADDITIONAL STRATEGIC NOTES

[// GUIDANCE:
1. Confirm that service of process was proper; if not, consider a Rule 12(b)(5) motion in lieu of or before answering.
2. If removal to federal court is viable, do not answer in state court before removing.
3. Review any contractual arbitration clauses—filing an answer may waive the right to compel arbitration.
4. Idaho follows notice pleading; concise statements generally suffice, but ensure sufficient detail to preserve defenses.
5. If asserting affirmative defenses sounding in fraud (e.g., misrepresentation), plead with particularity under I.R.C.P. 9(b).
]

THIS TEMPLATE IS PROVIDED FOR LEGAL PROFESSIONAL USE ONLY. ADAPT FACTS, DEFENSES, AND COUNTERCLAIMS TO THE SPECIFICS OF YOUR CASE.