[COURT OF COMMON PLEAS OF [COUNTY] COUNTY, PENNSYLVANIA]
[CIVIL DIVISION]

[PLAINTIFF NAME],
Plaintiff,
v. : Docket No. [DOCKET NO.]
:
[DEFENDANT NAME],
Defendant. : CIVIL ACTION – LAW

ANSWER, NEW MATTER, AND (OPTIONAL) COUNTERCLAIM
OF DEFENDANT [DEFENDANT NAME] TO PLAINTIFF’S COMPLAINT

[// GUIDANCE: Pennsylvania practice permits a “general denial” under Pa.R.C.P. 1029(b). Counsel should nevertheless confirm that a paragraph-by-paragraph response is unnecessary or strategically unwise for the particular matter.]

I. PRELIMINARY STATEMENT
Defendant [DEFENDANT NAME] (“Defendant”) hereby answers the Complaint filed by Plaintiff [PLAINTIFF NAME] (“Plaintiff”), asserts New Matter by way of affirmative defenses, and, if elected, pleads a Counterclaim, stating as follows:

II. ANSWER – GENERAL DENIAL
1. Pursuant to Pa.R.C.P. 1029(b) and 1029(c), Defendant expressly DENIES each and every allegation, matter, and thing contained in Plaintiff’s Complaint, whether set forth in individually numbered paragraphs or otherwise, EXCEPT such allegations as are specifically and unambiguously admitted herein.

2. Defendant ADMITS the following allegations solely for purposes of this litigation:
   a. [INSERT precise allegations admitted, e.g., jurisdictional facts, identity of the parties].
3. All remaining allegations not expressly admitted are DENIED.

[// GUIDANCE: If certain allegations require a response beyond a mere admission or denial (e.g., damages calculations, contract excerpts), insert targeted responses here.]

III. NEW MATTER (AFFIRMATIVE DEFENSES)
Without admitting any liability and expressly reserving the right to amend, Defendant asserts the following defenses pursuant to Pa.R.C.P. 1030:

1. Failure to State a Claim: Plaintiff’s Complaint fails to state a claim upon which relief can be granted.
2. Lack of Standing: Plaintiff lacks standing to bring one or more of the asserted claims.
3. Statute of Limitations: One or more claims are barred by applicable limitation periods.
4. Statute of Frauds: Enforcement is barred, in whole or in part, by the statute of frauds.
5. Estoppel/Waiver/Laches: Plaintiff’s claims are barred by estoppel, waiver, and/or laches.
6. Accord and Satisfaction / Payment: The obligations alleged have been satisfied.
7. Comparative / Contributory Negligence (if applicable): Plaintiff’s own negligence bars or diminishes recovery.
8. Failure of Consideration / Lack of Privity (contract claims).
9. Unclean Hands (equitable claims).
10. Reservation: Defendant reserves the right to assert additional defenses that may become known through discovery.

[// GUIDANCE: Strike or reorder defenses to fit the facts; number sequentially to facilitate a future reply to New Matter under Pa.R.C.P. 1029(d).]

IV. (OPTIONAL) COUNTERCLAIM
Defendant, as Counter-Claimant, for its Counterclaim against Plaintiff, states:

1. Jurisdiction & Venue
   a. This Court has jurisdiction over the Counterclaim pursuant to 42 Pa. Cons. Stat. § 931(a).
   b. Venue is proper in this Court under Pa.R.C.P. 1006.

2. Parties
   a. Counter-Claimant: [DEFENDANT NAME & capacity, e.g., a Pennsylvania corporation].
   b. Counter-Defendant: [PLAINTIFF NAME & capacity].

3. Factual Background
   a. [Brief, numbered factual allegations supporting Counterclaim].

4. Causes of Action
   Count I – [e.g., Breach of Contract]
   (i) Paragraphs 1-[X] are incorporated by reference.
   (ii) [Allegation 1]
   (iii) [Allegation 2]
   (iv) As a direct result, Counter-Claimant suffered damages of $[AMOUNT].
   WHEREFORE, Counter-Claimant demands judgment in its favor and against Counter-Defendant in an amount in excess of $50,000, together with interest, costs, attorney fees as permitted by law, and any further relief the Court deems just.

[// GUIDANCE: Insert additional Counts as necessary; verify that compulsory counterclaims under Pa.R.C.P. 1031(a) are pleaded to avoid waiver.]

V. PRAYER FOR RELIEF
WHEREFORE, Defendant respectfully requests that this Court:
A. Dismiss Plaintiff’s Complaint with prejudice;
B. Enter judgment in favor of Defendant on all claims;
C. Award Defendant its costs of suit and any other relief the Court deems equitable and just; and
D. On the Counterclaim (if asserted), grant the relief set forth therein.

VI. RESERVATION OF RIGHTS
Defendant reserves the right to amend this Answer, assert additional defenses, and supplement or modify the Counterclaim as discovery and investigation proceed, pursuant to Pa.R.C.P. 1033.

VII. JURY TRIAL DEMAND (IF APPLICABLE)
[// GUIDANCE: Delete if not seeking a jury.]
Pursuant to Pa. R. Civ. P. 1007.1, Defendant demands trial by jury on all issues so triable.

VIII. VERIFICATION
I, [AUTHORIZED REPRESENTATIVE / INDIVIDUAL DEFENDANT], verify that the statements made in the foregoing Answer, New Matter, and Counterclaim are true and correct to the best of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. Cons. Stat. § 4904 (relating to unsworn falsification to authorities).

Date: ___ _____
[NAME & TITLE, if applicable]
[DEFENDANT NAME]

IX. CERTIFICATE OF SERVICE
I hereby certify that on the ___ day of ____, 20__, a true and correct copy of the foregoing Answer, New Matter, and Counterclaim was served upon all counsel and/or parties of record in the manner indicated below:

• [Name], Esq. – Counsel for Plaintiff – [Method: First-Class Mail / Hand-Delivery / E-Service]
• [Insert additional recipients]

[ATTORNEY NAME], Esq.
Counsel for Defendant
PA I.D. No. [BAR NUMBER]
[FIRM NAME]
[ADDRESS]
[PHONE] | [EMAIL]

[// GUIDANCE:
1. Filing Deadline – Pa.R.C.P. 1026 requires filing within 20 days after service of the Complaint.
2. Entry of Appearance – Ensure a contemporaneous praecipe to enter appearance where necessary.
3. Confidential Information – Redact personal identifiers per Pa.R.C.P. 205.5.
4. Electronic Filing – If in a county utilizing PACFile or equivalent, follow local e-filing rules.
5. Self-Contained Document – Keep the Answer, New Matter, and Counterclaim in a single pleading unless local rule directs otherwise.
]