(a)        A pleading which sets forth a claim for affirmative relief shall contain:

(1)          A short, plain statement of the grounds upon which the Court's jurisdiction depends, unless the Court already has jurisdiction over the matter;

(2)          A short, plain statement of the claim showing that the pleader is entitled to relief; and

(3)          A demand for judgment for the relief to which the pleader considers herself/himself entitled.  Such claim for relief can be in the alternative or for several types of relief.

(b)        A party shall state in plain, concise terms the grounds upon which she/he based her/his defense to claims pleaded against her/him, and shall admit or deny the claims and statements upon which the adverse party relies.  If she/he is without information or knowledge regarding a statement or claims, she/he shall so state and such shall be deemed to be a denial.  Denials shall fairly meet the substance of the claims or statements denied and may be made as to specified parts but not all of a claim, statement, or averment.  A 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 amount of damages, shall be deemed admitted unless denied; if no responsive pleading is allowed the claims of the adverse party shall be deemed denied.