RULE 7. PLEADINGS AND MOTIONS.

1. The pleadings which shall be allowed shall be a Complaint and an Answer, a Counterclaim, a Crossclaim, a reply to a Counterclaim, an answer to a Crossclaim if the Answer contains a Crossclaim, a third party Complaint, and a third party Answer if a third party Complaint served.  No other pleading shall be allowed except that the Court may order a reply to an Answer or a third party Answer.
2. A party shall state in plain, concise terms the grounds upon which he bases his defense to claims pleaded against him and shall admit or deny the claims and statements upon which the adverse party relies.  If he is without information or knowledge regarding a statement or claim, he shall so state.  Such shall be deemed a denial.  Denials shall fairly meet the substance of the claim or statement denied and may be made as to specific parts but not all of a claim or statement is general denial shall not be made unless the party could in good faith deny each and every claim covered thereby.  A claim to which a responsive pleading is required except for the amount of damages shall be deemed admitted unless denied.  If no responsive pleading is required, the claims of the adverse party shall be deemed denied.
3. In responding to a pleading, a party shall set forth affirmatively all matters constituting an avoidance or affirmative defense including accord and satisfaction, arbitration, and award, assumption of risk, contributory negligence, discharge in bankruptcy, duress, estoppel, failure of consideration, fraud, illegality, injury by fellow servant, laches, license, payment, release, re judicata, statute of frauds, statute of limitations, and waiver.  When a party has mistakenly designated a defense as a counterclaim or a counterclaim as defense, the Court if justice so requires, shall treat the pleadings as if the designation had been a proper one.
4. Each paragraph of a pleading shall be simple, concise, and direct.  A party may set forth two or more statements of claim or defense alternatively or hypothetically, either in one count or in separate counts.  A party may also state as many separate claims or defenses as he has regardless of consistency and whether based upon legal or on equitable grounds or both.
5. All pleadings shall be construed so as to do substantial justice.