1 Any Attorney or Party

Any Street
2 Any Town, CA 55555

3 714-555-5555

4 Any Attorney or Party

8 Superior Court of the State of California

9 For the County of _________________

10

11 Any Plaintiff, ) Case No.

)
12 Plaintiff, ) ANSWER OF DEFENDANT______________ TO
) COMPLAINT OF PLAINTIFF_________
13 vs. )
)
14 Any Defendant, and DOES 1-5 )
)
15 Defendants. )
)
16 )
)
17

18
To subscribe to my FREE weekly legal newsletter visit
19

20 http://freeweeklylegalnewsletter.gr8.com/ and enter your e-mail

21
address.
22

23 To view sample document packages sold by LegalDocsPro

24
visit: http://www.legaldocspro.net Be sure to remove this notice and
25

26 all other notices before using this document.

27

28

- 1 -
ANSWER TO COMPLAINT
 1 Defendant, _____________________ for themselves and no other Defendant, denies and
2
alleges as follows:
3
1. Pursuant to the provision of Section 431.30(d) of the California Code of Civil Procedure,
4
Defendant, ______________________ denies, both generally and specifically, each, every and all of
5

6 the allegations of Plaintiff, ______________________________ and each and every cause of action

7 contained therein, and the whole thereof; this Answering Defendant further denies that Plaintiff was
8 damaged and/or injured in any sum or sums, or at all, by reason of any negligent act and/or omission
9
to, or any other conduct on the part of this Answering Defendant, or any of his agents and/or
10
employees.
11

12
FURTHER, AS SEPARATE AFFIRMATIVE DEFENSES to each and every cause of action

13 of the complaint, this Answering Defendant is informed and believes, and on such information and

14 belief alleges as follows:

15
FIRST AFFIRMATIVE DEFENSE
16
2. As a First and Separate Affirmative Defense, this Answering Defendant alleges that the
17
Plaintiffs complaint and each cause of action contained therein fails to state facts sufficient to
18

19 constitute a cause of action against this Answering Defendant.

20 SECOND AFFIRMATIVE DEFENSE

21
3. As a Second and Separate Affirmative Defense, this Answering Defendant alleges that
22
Plaintiff has failed to undertake prudent and necessary steps to rectify the problems alleged, if any, to
23
mitigate the damages, if any, claimed to have been suffered, or will suffer, by virtue of the alleged
24

25 conduct of this Answering Defendant, and, as such, the Plaintiff solely and proximately caused the

26 damages complained of, if any, as alleged in Plaintiffs complaint.

27
///
28

- 2 -
ANSWER TO COMPLAINT
 1 THIRD AFFIRMATIVE DEFENSE
2 4. As a Third and Separate Affirmative Defense, this Answering Defendant alleges that any
3
default and/or breach of agreement, if any, on the part of this Answering Defendant was minor and/or
4
immaterial and Plaintiff has suffered and/or will suffer no damages thereby.
5

6 To purchase the entire document visit:

7
https://legaldocspro.myshopify.com/products/sample-answer-to-
8

9 unverified-complaint-for-california
10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

- 3 -
ANSWER TO COMPLAINT