PRE-TRIAL PROCEDURE

(such as, accord and satisfaction, assumptions of the risk, estoppel, fraud, laches, res judicata). Similar to the form of a complaint, defense counsel should write the answer in short, plain and concise terms. Fed. R. Civ. P. 8(b) & (e). Most often, the defendant has the luxury of simply writing the words “denied” or “unknown.”

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