(a) Claim for Relief. A pleading that states a claim for relief must contain:
(1) a short and plain statement of the grounds for the court’s jurisdiction, unless the court already has jurisdiction and the claim needs no new jurisdictional support;(2) a short and plain statement of the claim showing that the pleader is entitled to relief; and(3) a demand for the relief sought, which may include relief in the alternative or different types of relief.(b) Defenses; Admissions and Denials.(1)In General. In responding to a pleading, a party must:
(A) state in short and plain terms its defenses to each claim asserted against it; and(B) admit or deny the allegations asserted against it by an opposing party.(2)Denials; Responding to the Substance. A denial must fairly respond to the substance of the allegation.(3)General and Specific Denials. A party that intends in good faith to deny all the allegations of a pleading, including the jurisdictional grounds, may do so by a general denial. A party that does not intend to deny all the allegations must either specifically deny designated allegations or generally deny all except those specifically admitted.(4)Denying Part of an Allegation. A party that intends in good faith to deny only part of an allegation must admit the part that is true and deny the rest.(5)Lacking Knowledge or Information. A party that lacks knowledge or information sufficient to form a belief about the truth of an allegation must so state, and the statement has the effect of a denial.(6)Effect of Failing to Deny. An allegation, other than one relating to the amount of damages, is admitted if a responsive pleading is required and the allegation is not denied. If a responsive pleading is not required, an allegation is considered denied or avoided.(c) Affirmative Defenses.(1)In General. In responding to a pleading, a party must affirmatively state any avoidance or affirmative defense, including:
(A) accord and satisfaction;(B) arbitration and award;(C) assumption of risk;(D) contributory or comparative responsibility;(E) duress;(F) estoppel;(G) failure of consideration;(H) fraud;(I) illegality;(J) injury by fellow servant;(K) laches;(L) license;(M) payment;(N) release; (O res judicata;(P) statute of frauds;(Q) statute of limitations;(R) waiver; and(S) discharge in bankruptcy. (2)Mistaken Designation. If a party mistakenly designates a defense as a counterclaim, or a counterclaim as a defense, the court must, if justice requires, treat the pleading as though it were correctly designated, and may impose terms for doing so. (d) Pleadings to be Concise and Direct; Alternative Statements; Inconsistency.(1)In General. Each allegation must be simple, concise, and direct. No technical form is required.(2)Alternative Statements of a Claim or Defense. A party may set out 2 or more statements of a claim or defense alternatively or hypothetically, either in a single count or defense or in separate ones. If a party makes alternative statements, the pleading is sufficient if any one of them is sufficient.(3)Inconsistent Claims or Defenses. A party may state as many separate claims or defenses as it has, regardless of consistency.(e) Construing Pleadings. Pleadings must be construed so as to do justice.
