Each paragraph of Plaintiff’s Complaint needs to be addressed. The manner in which the Complaint is answered can have far reaching consequences. Likewise, affirmative defenses are very important. Failure to raise them correctly may result in their waiver. We suggest you consult with an attorney before you file a written Answer. COURT OF COMMON PLEAS DIVISION OF DOMESTIC RELATIONS CUYAHOGA COUNTY, OHIO ___________________________________ PLAINTIFF : CASE NO. _____________________________ : JUDGE ________________________________ vs : ___________________________________ DEFENDANT ANSWER OF DEFENDANT : Defendant hereby pleads to the Complaint of Plaintiff with the following Answer: 1. Admits the allegations contained in Paragraph(s) [number(s)] of the Complaint. 2. Denies the allegations contained in Paragraph(s) [number(s)] of the Complaint. WHEREFORE, Defendant demands that Plaintiff’s Complaint be dismissed at Plaintiff’s cost and such other relief as the Court may deem proper. _______________________________________ SIGNATURE _______________________________________ MAILING ADDRESS _______________________________________ CITY, STATE, ZIP CODE _______________________________________ DAYTIME TELEPHONE NUMBER The following are affirmative defenses that should be included in the Answer, if applicable. Affirmative Defense(s) Any and all affirmative defenses you have or may wish to assert must be raised. Failure to do so may result in a waiver of your right(s) to do so. 1. 2. 3. 4. 5. 6. 7. 8. Failure to state a claim upon which relief can be granted. Lack of jurisdiction over the subject matter of this action. Lack of jurisdiction over the person of the Defendant. Venue is improper. Process and service of process were and are insufficient. The claims are barred in whole or in part by the applicable statutes of frauds. The claims are barred by a pre-nuptial/ante-nuptial agreement. The claims are barred by Plaintiff’s lack of capacity to bring this action. DR0706103 Answer of Defendant American LegalNet, Inc. www.FormsWorkflow.com