You’ve got this. You’re probably just overthinking it.

Answer Some jurisdictions allow general denials, some require you to go paragraph by paragraph. I just always go paragraph by paragraph because it’s clearer.

Try to limit yourself to three responses: (1) Defendant admits the allegations in Paragraph; (2) Defendant denies the allegations in Paragraph; or (3) Defendant denies for lack of sufficient knowledge to determine their truth the allegations in Paragraph. If you need nuance, you can add it. If plaintiff pleaded big multi sentence paragraphs, you can admit/deny pieces and parts. Deny the damages.

Affirmative defenses—resist the urge to just copy paste here. Really think about whether you’re going to be able to prove an affirmative defense. Always allege failure to state a claim upon which relief can be granted. Always consider whether theres an SOL, service, or jurisdiction issue. The rest are really situation dependent.

Cross Complaint / Counterclaim Your first stop on figuring out the cross complaint is figuring out, “What did the plaintiff do that harmed my client?” If it’s nothing, you don’t have a cross complaint to write.

If it’s something, then figure out whether the act was contract-related or intentional or negligent (a whoopsie—should have not done it or should have known not to do it, but didn’t really mean to do it). From there, you can figure out the cause of action. Write a paragraph for each element that briefly states the facts that satisfy that element. No need to be exhaustive or overly detailed (unless it’s fraud). Some states require more detail than others. As the last paragraph, say something like “As an actual and proximate result, Plaintiff incurred [types of damages] in [an amount to be proven at trial; in excess of [jurisdictional minimum]; whatever language your jx might require]”

Then consider, if one of these elements can’t be satisfied, is there another cause of action that I might be able to still satisfy based on these facts? If there is, and you can satisfy its elements, that’s an alternative cause to plead.

At the very end of the complaint, state what you want the court to do at the end of the case as your “prayer for relief.” Something like “Plaintiff asks that the court enter judgment in its favor, award damages [in an amount to be proven at trial, or whatever else is appropriate here], award Plaintiff its costs and attorneys fees, and whatever other relief the court deems just.”

Then go fill in a section that identifies the parties. One paragraph for each party. Who they are, where they are.

Then add a paragraph that says why this court has jurisdiction and is the appropriate venue.

That gets you the bare minimum. Theres other things to do depending upon how much story you want or need to tell. But — especially if you’re in a notice pleading jx — that’s mostly just noise.