§ 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].