The collection of answers includes a general answer to a complaint for personal injury and/or property damage, as well as supplements with affirmative defenses specific to the issues peculiar to a certain type of event or activity; a motor vehicle accident, toxic exposure, dog bite, skiing, or oral contract. Certain of the “answers” are nothing more than a suggestion, an answer that might not be on the attorney’s radar, such as the special answer of a cross-defendant to the complaint.

The Template answers are a comprehensive, but not exhaustive, check list of all the potential and possible issues involved in a case whether alleged by the plaintiff as a cause of action in the complaint, or asserted as an affirmative defense in the answer. The list is cast as an answer simply because that format best lent itself to not only identifying the issue, but to the inclusion of the “annotations”, the statutes and case law providing a definition of the issue and elements to be proven.

The collection of answers includes an “unannotated” answer with the affirmative defenses only, without the statutes and case law providing a definition of the issue and elements to be proven.  The unannotated answers are in the same order and numbered identically to the affirmative defenses of the annotated answers; if you are working the unannotated answer, and have a question about a particular defense, it will be easy to find the corresponding annotated affirmative defense for the rule of law.