I am wondering if I have to type the exact counts and paragraphs and then admit or deny each or can I just admit or deny to the number indicated?

Depends on the court. To be on the safe side I would include each count in my answer.

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Originally Posted by havdiu

I am wondering if I have to type the exact counts and paragraphs and then admit or deny each or can I just admit or deny to the number indicated?

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Something like this would probably work:

"In answer to the Complaint dated ____, Defendant [your name]
1. Denies paragraph 1;
2. Admits paragraph 2;
3. Denies paragraph 3 for lack of information necessary to form a belief as to the truth of the allegations contained in said paragraph;
....
etc."

I have also seen "denies paragraph 1 concerning "X;" admits paragraph 1 concerning "X", X being a quote.

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Originally Posted by JudyKayTee

I have also seen "denies paragraph 1 concerning "X;" admits paragraph 1 concerning "X", X being a quote.

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Yes, one can go into great detail in the pleadings, but normally it doesn't matter much in the long run. Pleadings are anachronisms, for the most part. Most civil rules require discovery which explains in excruciating detail every aspect of your case.

I second the word "excruciating."

And you can also add the "cute" language of

Defendant denies allegations contained in paragraph #1 and demands strict proof thereof.
Kind of makes it hard for the Plaintiff as they have to prove the allegations.

One of my "pet" phrases I used to do all the time when I worked in law offices and had to draft up responses to complaints.

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Originally Posted by twinkiedooter

And you can also add the "cute" language of

Defendant denies allegations contained in paragraph #1 and demands strict proof thereof.
Kinda makes it hard for the Plaintiff as they have to prove the allegations.

One of my "pet" phrases I used to do all the time when I worked in law offices and had to draft up responses to complaints.

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That language would make no difference whatsoever and it would make the op sound like he had no idea what he was doing.

You can admit or deny each paragraph or you can basically have just 3 responsive paragraphs:

1. Defendant admits the allegations contained in paragraphs... (list them).

2. Defendant denies the allegations contained in paragraphs... (list them)

3. Defendant denies knowledge sufficient to form a belief as to the allegations in paragraphs... (list them).

Technically you don't even need #1, as any unanswered paragraph is deemed an admission, but most attornies do it that way.

Quote:

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Originally Posted by twinkiedooter

And you can also add the "cute" language of

Defendant denies allegations contained in paragraph #1 and demands strict proof thereof.
Kinda makes it hard for the Plaintiff as they have to prove the allegations.

One of my "pet" phrases I used to do all the time when I worked in law offices and had to draft up responses to complaints.

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I smile when I see this - I guess "strict" proof is a higher standard than "unstrict proof."