1 Any Defendant

Any Street
2 Any Town, CA 55555

3 714-555-5555

4
Any Attorney or Defendant
5

8
SUPERIOR COURT OF THE STATE OF CALIFORNIA
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FOR THE COUNTY OF ________________
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SAMPLE PLAINTIFF, ) CASE NO.
12 )
Plaintiff, ) ANSWER OF DEFENDANT _______
13 ) TO COMPLAINT OF PLAINTIFF
v. ) ____________________
14 )
15 SAMPLE DEFENDANTS, )
)
16 Defendants. )
)
17 ____________________________________)
18

19
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Defendant, _____________________ for themselves and no other Defendant, denies and
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27 alleges 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
2 Procedure, Defendant, ______________________ denies, both generally and specifically, each,
3
every and all of the allegations of Plaintiff, ______________________________ and each and every
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cause of action contained therein, and the whole thereof; this Answering Defendant further denies
5

6
that Plaintiff was damaged and/or injured in any sum or sums, or at all, by reason of any negligent act

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

8 agents and/or employees.

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FURTHER, AS SEPARATE AFFIRMATIVE DEFENSES to each and every cause of action
10
of the complaint, this Answering Defendant is informed and believes, and on such information and
11
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
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the Plaintiffs complaint and each cause of action contained therein fails to state facts sufficient to
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constitute a cause of action against this Answering Defendant. This affirmative defense is for the
17
purpose of avoiding any waiver of the affirmative defense and is based on information and belief.
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19 This affirmative defense is likely to have evidentiary support after a reasonable opportunity for

20 further investigation or discovery.

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24
personal-injury-complaint-in-california
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- 2 -
ANSWER TO COMPLAINT