[CAPTION]

ANSWER

The defendant answers the petition as follows:

1. Defendant admits the allegations stated in the petition in paragraphs

2. Defendant denies the allegations stated in the petition in paragraphs

3. Defendant lacks knowledge or information sufficient to form a belief

about the truth of the allegations stated in the petition in paragraphs

and therefore denies those allegations.

4. All other allegations not expressly admitted are denied.

[AFFIRMATIVE DEFENSES

5. Further, defendant alleges plaintiff’s claim for relief should be

denied by reason of the following affirmative defense(s): (accord and

satisfaction) (arbitration and award) (assumption of risk) (contributory

negligence or comparative fault) (duress) (estoppel) (failure of consideration)

(fraud) (illegality) (injury by fellow servant) (laches) (license) (payment)

(release) (res judicata) (statute of frauds) (statute of limitations) (waiver) (and

any other matter constituting an avoidance or affirmative defense).]

[COUNTERCLAIM]

Rev. 6/2017 KSJC 1

 (See counterclaim form)

WHEREFORE, defendant prays that plaintiff be denied relief and that

defendant have judgment for costs and other relief as the Court deems just and

proper.

(Signature of attorney)
(Name), Attorney for (party)
Bar Registration Number
Address
Telephone
[Facsimile number]
[Email address]

CERTIFICATE OF SERVICE

I certify that a copy of the above Counterclaim was served on (name) on

the day of , 20 , as follows:

(Signature of attorney)

Authority

K.S.A. 60-208.

Rev. 6/2017 KSJC 2