§ FORM 23 ANSWER PRESENTING DEFENSES UNDER RULE 12(b)

FORM 23. ANSWER PRESENTING DEFENSES UNDER RULE 12(b)

    First Defense

[Improper Venue]

    The action is brought in the wrong county because the defendant is a domestic corporation domiciled in _______ County, which is not the county in which this action is brought or in which the cause of action occurred or accrued.

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.

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