§ Form27 Answer Presenting Defenses Under Rule 12(b)

Form27. Answer Presenting Defenses Under Rule 12(b).

First Defense

[Improper Venue]

    The action is brought in the wrong county because (a) the defendant is a foreign corporation and (b) is not doing business by agent in the county where this suit is brought.

Second Defense

[Admission and Denial]

    Defendant admits the allegations contained in paragraphs 1 and 4 of the complaint; alleges that he is without knowledge or information sufficient to form a belief as to the truth of the allegations contained in paragraph 2 of the complaint; and denies each and every other allegation contained in the complaint.

Third Defense

[Statute of Limitations]

    The right of action set forth in the complaint did not accrue within ______ years next before the commencement of this action.

Counterclaim

    [Here set forth any claim as a counterclaim in the manner in which a claim is pleaded in a complaint].

Cross-Claim against Defendant M.N.

    [Here set forth the claim constituting a cross-claim against defendant M.N. in the manner in which a claim is pleaded in a complaint].