Unless the Complaint is "verified", you do not need to file a Verified Answer. (The Complaint is a verified complaint if at the end of the complaint, the plaintiff swears under penalty of perjury that the allegations are true and correct.) Inmost instances, the Complaint is not verified. That means you do not need to respond to each and every paragraph by admitting or denying. Rather, you can generally deny all allegations.
If you need to respond to a Verified Complaint, see:
Of course, you realize that no one on Avvo can really tell you how to answer a specific Complaint without having seen it and without knowing your specific facts.
Frank W. Chen is licensed to practice law in the State of California. The information presented here is general in nature and is not intended, nor should be construed, as legal advice. This posting does not create any attorney-client relationship with the author. For specific advice about your particular situation, consult your own attorney.
Answering or responding to the complaint filed against you is the first step in litigation.
If you are having trouble this early in the case, you should probably hire an attorney.
You do not need to answer. You could also file any number of motions, a motion to quash, a motion to strike, a motion for judgment on the pleadings, a demurrer, etc. An answer is the simplest form of response.
Ask the plaintiff's attorney for a little more time, and find yourself an attorney.