The Answer

You will notice that in the my Answer to the Amended Complaint, I did not leave a single allegation unchallenged.

The Answer

I have seen Answers where the Respondent simply said "Deny" to each allegation; such a strategy may be preferable for some, as you need to spend a lot of time going over your Answer, you do not want to inadvertently say anything that can be used against you.

In my Answers to Interrogatories, Answers to Request for Production and Answers to Request for Admissions, I employed the "Deny" strategy and if I was faced with a similar suit again I would probably employ that strategy in my Answer to Complaint as well.

The reason for this is that you want to blind side Plaintiff's attorney with the Motion to Dismiss that you will eventually file.