casemark/answer-affirmative-defenses
skills/legal/answer-affirmative-defenses/SKILL.md
Drafts U.S. civil litigation Answers with paragraph-by-paragraph admissions/denials, affirmative defenses, and counterclaim triage. Trigger when user needs a responsive pleading to a complaint, mentions affirmative defenses, admit/deny responses, Rule 8, or insufficient knowledge responses.
$ install --global
skillsauthnpx skillsauth add casemark/skills answer-affirmative-defensesInstall this skill globally with one command. Works with Claude Code, Cursor, and Windsurf.
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Last scanned: May 25, 2026, 3:27 AM26.0s1 file scanned
SKILL.md
- name:
- answer-affirmative-defenses
- language:
- en
- description:
- >-
Answer and Affirmative Defenses
Drafts a rule-compliant Answer with strategic admissions/denials and preserved affirmative defenses to avoid waiver.
Prerequisites
Collect before drafting:
- Complaint — filed version with numbered paragraphs and caption
- Service data — date, method, proof of service
- Client facts — timeline, documents, communications, witnesses
- Governing instruments — contracts, policies, statutes
- Jurisdiction rules — local rules on format, verification, deadlines
Workflow
1. Caption + Appearance
- Match court, parties, case number exactly from complaint.
- Note general vs special appearance (if contesting jurisdiction/venue).
2. Response Matrix
Build a response table before drafting the pleading body.
| ¶ | Allegation | Response | Qualification | Source | |---|---|---|---|---| | 1 | Party identity | Admit | Name/status only | Client docs | | 2 | Jurisdiction | Deny | — | Investigate | | 3 | Contract exists | Qualified | Admit execution; deny breach | Contract |
Response types: Admit · Deny · Lack knowledge (deny on that basis) · Qualified admit/deny
3. Paragraph-by-Paragraph Responses
Response templates:
- Admit: "Defendant admits the allegations in Paragraph __ of the Complaint."
- Deny: "Defendant denies the allegations in Paragraph __ of the Complaint."
- Lack knowledge: "Defendant lacks knowledge or information sufficient to form a belief as to the truth of the allegations in Paragraph __ and on that basis denies them."
- Qualified: "Defendant admits [specific fact] as alleged in Paragraph __, but denies the remaining allegations in that paragraph."
Rules: Address every paragraph. Separate factual admissions from legal conclusions. Do not overuse lack-knowledge where defendant should reasonably know.
4. Affirmative Defenses
Number each defense separately. Include brief factual grounding without overcommitting.
Procedural: lack of subject-matter jurisdiction, lack of personal jurisdiction, improper venue, insufficient service, failure to join indispensable party, lack of standing.
Substantive: failure to state a claim, statute of limitations, statute of frauds, waiver, estoppel, laches, release, accord and satisfaction, payment, arbitration/award, unclean hands, illegality, comparative/contributory negligence, failure to mitigate.
Template: "[Defense Name]. Plaintiff's claims are barred because [factual basis]. The allegations show [timing/conduct/term], and the claim fails as a matter of law."
End with reservation clause: "Defendant reserves the right to assert additional defenses as they become known through discovery or further investigation."
5. Counterclaim Triage
- Compulsory counterclaim from same transaction?
- Permissive counterclaim worth asserting now?
- Cross-claim vs co-defendant (indemnity/contribution)?
- Third-party claim to shift liability?
If included, structure as: parties/jurisdiction → numbered factual allegations → cause of action with elements → damages and relief.
6. Prayer for Relief
Minimum: dismissal with prejudice, judgment for defendant, costs, attorney fees (if contractual/statutory basis), pre/post-judgment interest, catch-all "other relief as just and proper." Add specific relief tied to defenses or counterclaims.
7. Signature + Service
Attorney signature block with bar number. Verification if jurisdiction requires. Certificate of service with method and date.
Quality Checklist
- [ ] Every complaint paragraph addressed — no admissions by omission
- [ ] Defenses tailored to facts and jurisdiction
- [ ] Counterclaims labeled compulsory/permissive
- [ ] Caption matches complaint exactly
- [ ] Deadline confirmed and calendared
- [ ] No defenses asserted without plausible factual basis
- [ ] Jurisdiction-specific pleading standard noted (notice vs fact)
Pitfalls
- Omitted paragraphs may be deemed admitted — address every one.
- Bare legal conclusions should be denied, not admitted.
- One-word defenses risk being stricken — always include factual grounding.
- Timing defenses (limitations, laches) — verify periods before filing; flag if uncertain.
- Verified answers — check if jurisdiction or claim type requires defendant verification.
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