Statement Of Defence Drafter

---
name: statement-of-defence-drafter
description: Drafts a statement of defence in arbitration, including paragraph-by-paragraph admissions and denials, jurisdictional and admissibility objections, affirmative defences, responses to quantum, set-off, and properly separated counterclaims. Use when a respondent must answer a statement of claim, prepare a defence and counterclaim, preserve a jurisdictional objection, or organise evidence against pleaded allegations. Use for the merits pleading, not for an award challenge or a generic dispute strategy memo.
---

# Statement of Defence Drafter

## Purpose

Answer the actual case pleaded with precise admissions, denials, alternative cases, and evidence while preserving threshold objections and presenting any counterclaim as a complete claim in its own right.

## Required inputs

Obtain the statement of claim and all exhibits, arbitration agreement, contract set, notice or request, procedural orders, governing law, respondent instructions, contemporaneous documents, payment and performance records, damages material, prior correspondence, and facts supporting any counterclaim or set-off.

Identify filing deadlines, amendment rules, whether jurisdiction has already been contested, the required pleading form, counterclaim fees, and any claim allegation the respondent cannot yet admit or deny after reasonable inquiry.

## Method

1. Create a response matrix for every numbered allegation: Admit, Deny, Not Admitted, Outside Knowledge, or Requires Qualification. Record the reason, respondent's positive case, supporting source, witness, and missing evidence.
2. Address jurisdiction and admissibility first where required. Distinguish consent, scope, party status, tribunal constitution, conditions precedent, limitation, and other objections. Preserve an objection in the manner and time required by current law and rules; do not use a merits defence as an implied waiver without analysis.
3. State the respondent's affirmative narrative in a concise chronology. A denial is not a substitute for the respondent's account of what happened.
4. Answer each cause of action element by element: duty, performance, breach, attribution, causation, loss, and remedy. Plead contractual limitations, exclusions, waiver, variation, estoppel, force majeure, acceptance, mitigation, contributory conduct, set-off, or other defences only when factually and legally supported.
5. Respond to quantum head by head. Test entitlement, causation, measure, proof, formula, inputs, currency, interest, duplication, mitigation, avoided costs, and contractual caps. Provide corrected calculations where possible.
6. Plead alternative positions expressly and consistently. Explain their order; do not make accidental admissions by presenting an alternative without qualification.
7. Draft each counterclaim separately with jurisdiction, material facts, legal basis, breach, causation, quantum, and relief. Verify notice, limitation, scope, fees, and permission requirements. Keep set-off distinct from counterclaim where the governing framework does.
8. Identify document requests, witness evidence, and expert evidence necessary to prove the positive case or test the claim.
9. Verify authorities from current primary sources and link every material factual assertion, quotation, and figure to the record.
10. Run consistency checks across the defence, earlier correspondence, jurisdictional objections, counterclaim, calculations, and prayers.

## Output

Produce:

1. **Statement of defence**, aligned to the claim's numbering where practical.
2. **Jurisdiction and admissibility section**, with reservations precisely stated.
3. **Counterclaim or set-off section**, only if supported and requested.
4. **Response matrix** and **defence-evidence matrix**.
5. **Quantum response schedule**.
6. **Open-items list** — evidence, instructions, law, procedural permissions, and deadlines.

## Guardrails

- Do not use blanket denials where a specific answer can reasonably be given.
- Do not deny authentic documents or undisputed background merely for tactical appearance.
- Do not invent a positive case, counterclaim, payment, notice, authority, or calculation.
- Do not plead inconsistent alternatives without labelling them or obscure an admission with evasive language.
- Do not assume that a jurisdictional objection remains available; verify waiver, timing, and prior submissions.