1. Specific Denials
The defendant may make specific denials, which denies all of the allegations contained in a particular paragraph or count of the complaint. For example, “in answering paragraph 25, the answering defendant denies the allegations contained therein.”
2. General Denials
The defendant may make a general denial, which denies each and every allegation in the plaintiff’s complaint. However, if a defendant does make this denial he must be ready to challenge every single allegation in the complaint.
3. Qualified Denials
The defendant may deny a particular portion of a particular allegation. For example, the defendant could state “in answering paragraph 25, the answering defendant denies the allegations made in the first sentence and is without sufficient knowledge to form an opinion as to the truth of the remaining allegations.”
4. Denial of Knowledge or Information
The defendant may also deny knowledge or information if he does not have knowledge or information sufficient to form a belief as to the truth of the plaintiff’s complaint. This denial has the effect of a complete denial, but it must be made in good faith.
5. Denial Based on Information and Belief
Courts have allowed a defendant without first-hand knowledge, but with enough information to believe in good faith that the complaint is false, to deny the same. This kind of denial is generally used by large corporations, on whom the burden of obtaining information may be substantial.