Answer

The answer is the defendant's written response to the Complaint. Under New York law defendant is required to respond separately to each allegation contained in each paragraph of the complaint with responses such as :"Denied" or "Denied Upon Information and Belief". If the defendant does not respond to a paragraph it is deemed to be an admission of the contents of the paragraph. It is because of these types of responses that we carefully construct each paragraph of the complaint to one single allegation. If there is more then one allegation in the paragraph then, under New York practice, the defendant can deny the entire paragraph. For example in an intersection automobile accident we would not state "That the accident happened on January 1, 2008 at the intersection of 123 St and Avenue A". We would divide the allegation into two paragraphs: "That the accident happened on January 1, 2008" and a second paragraph, "That the accident happened at the intersection of 123 St and Avenue A".

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