Specific Denial

Specific Denial

Specific Denial

Specific denials address each allegation separately. A party lacking knowledge sufficient to admit or deny may so state, which has the effect of a denial.

Allegations not denied are deemed admitted.

Alternative Names:

Paragraph Denial, Specific Response

Why it Matters?

The insufficient knowledge response is available but not unlimited, since a party cannot claim ignorance of facts within its own records or control. Courts have treated such responses as admissions where the information was readily available to the responding party. Reviewing the complaint against internal records before answering, rather than defaulting to insufficient knowledge, avoids that outcome.

Frequently Confused with

Frequently asked questions

Can a party respond that it lacks knowledge?

Can a party respond that it lacks knowledge?

Yes, which has the effect of a denial, but not for facts within its own records or control where courts treat it as an admission.

What happens to allegations not addressed?

What happens to allegations not addressed?

They are deemed admitted, which makes complete paragraph-by-paragraph response necessary.