441Pleadings—denials and non-admissions

441 Pleadings—denials and non-admissions (1) It is not enough for a party to deny generally the grounds alleged in a pleading. (2) Instead, a party must deal specifically with each allegation of fact. (3) However, a pleading in response to a pleading that alleges damage or damages is taken not to admit the allegation unless it specifically admits the allegation. (4) A party in a pleading must not deny an allegation of fact in the previous pleading of an opposite party in an evasive way. (5) Instead, a party must answer the point of substance. A plaintiff alleges that a defendant received an amount of money. It is not enough for the defendant to deny that the defendant received that amount. Instead, the defendant must deny that the defendant received that amount or any part of it, or set out how much the defendant received. (6) If an allegation is made with various circumstances, it is not enough to deny it along with the circumstances.