executing-plans
executing-plans
Use when executing an implementation plan in the current session as the implementer yourself — your human partner chose inline execution, or no subagent tool is available
answer-affirmative-defensesDrafts U.S. civil litigation Answers with paragraph-by-paragraph admissions/denials, affirmative defenses, and counterclaim triage. Trigger when user needs a responsive pleading to a complaint, mentions affirmative defenses, admit/deny responses, Rule 8, or insufficient knowledge responses.
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name: answer-affirmative-defenses language: en description: >- Drafts U.S. civil litigation Answers with paragraph-by-paragraph admissions/denials, affirmative defenses, and counterclaim triage. Trigger when user needs a responsive pleading to a complaint, mentions affirmative defenses, admit/deny responses, Rule 8, or insufficient knowledge responses. tags:
Drafts a rule-compliant Answer with strategic admissions/denials and preserved affirmative defenses to avoid waiver.
Collect before drafting:
Build a response table before drafting the pleading body.
| ¶ | Allegation | Response | Qualification | Source |
|---|---|---|---|---|
| 1 | Party identity | Admit | Name/status only | Client docs |
| 2 | Jurisdiction | Deny | — | Investigate |
| 3 | Contract exists | Qualified | Admit execution; deny breach | Contract |
Response types: Admit · Deny · Lack knowledge (deny on that basis) · Qualified admit/deny
Response templates:
Rules: Address every paragraph. Separate factual admissions from legal conclusions. Do not overuse lack-knowledge where defendant should reasonably know.
Number each defense separately. Include brief factual grounding without overcommitting.
Procedural: lack of subject-matter jurisdiction, lack of personal jurisdiction, improper venue, insufficient service, failure to join indispensable party, lack of standing.
Substantive: failure to state a claim, statute of limitations, statute of frauds, waiver, estoppel, laches, release, accord and satisfaction, payment, arbitration/award, unclean hands, illegality, comparative/contributory negligence, failure to mitigate.
Template: "[Defense Name]. Plaintiff's claims are barred because [factual basis]. The allegations show [timing/conduct/term], and the claim fails as a matter of law."
End with reservation clause: "Defendant reserves the right to assert additional defenses as they become known through discovery or further investigation."
If included, structure as: parties/jurisdiction → numbered factual allegations → cause of action with elements → damages and relief.
Minimum: dismissal with prejudice, judgment for defendant, costs, attorney fees (if contractual/statutory basis), pre/post-judgment interest, catch-all "other relief as just and proper." Add specific relief tied to defenses or counterclaims.
Attorney signature block with bar number. Verification if jurisdiction requires. Certificate of service with method and date.