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 _________________

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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 )
)
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25 Defendant, _____________________ for themself and no other Defendant, denies and alleges

26 as follows:
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- 1 -
ANSWER TO COMPLAINT
 1 1. Pursuant to the provision of section 431.30(d) of the California Code of Civil Procedure,
2 Defendant, ______________________ denies, both generally and specifically, each, every and all of
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the allegations of Plaintiff, ______________________________ and each and every cause of action
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contained therein, and the whole thereof; this Answering Defendant further denies that Plaintiff was
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damaged and/or injured in any sum or sums, or at all, by reason of any negligent act and/or omission

7 to, or any other conduct on the part of this Answering Defendant, or any of his agents and/or

8 employees.
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FURTHER, AS SEPARATE AFFIRMATIVE DEFENSES to each and every cause of action
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of the complaint, this Answering Defendant is informed and believes, and on such information and
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belief alleges as follows:
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13 FIRST AFFIRMATIVE DEFENSE

14 2. As a First and Separate Affirmative Defense, this Answering Defendant alleges that the
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first cause of action fails to state facts sufficient to constitute a cause of action against this Answering
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Defendant in that this Answering Defendant is not personally indebted to Plaintiff in any amount, nor
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has he had any dealings with Plaintiff in an individual capacity. This affirmative defense is for the
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19 purpose of avoiding any waiver of the affirmative defense and is based on information and belief.

20 This affirmative defense is likely to have evidentiary support after a reasonable opportunity for
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further investigation or discovery.
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SECOND AFFIRMATIVE DEFENSE
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3. As a Second and Separate Affirmative Defense, this Answering Defendant alleges
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25 that the second cause of action fails to state facts sufficient to constitute a cause of action against this

26 Answering Defendant in that this Answering Defendant is not personally indebted to Plaintiff in any
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amount, nor has he had any dealings with Plaintiff in an individual capacity. This affirmative defense
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- 2 -
ANSWER TO COMPLAINT
 1 is for the purpose of avoiding any waiver of the affirmative defense and is based on information and
2 belief. This affirmative defense is likely to have evidentiary support after a reasonable opportunity
3
for further investigation or discovery.
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ANSWER TO COMPLAINT