I am a defendant in a Florida civil law suit and just received an amended complaint that included the following item:

"All conditions precedent to commencement of this action have occurred or have been waved."

A brief search of the Florida Rules of Civil Procedure led me to rule 1.120(c) which states the following: “In pleading the performance or occurrence of conditions precedent, it is sufficient to aver generally that all conditions precedent have been performed or have occurred. A denial of performance or occurrence shall be made specifically and with particularity.”

I interpret this to be an exception to what the course teaches us about answers to complaints, because it seems to say that "DENY" is not a good enough answer. Rather I must list all possible ways I will attack their Causes of Action or waive forever my right to do so.

Any thoughts or suggestions?

David
I think what is meant is You must state all affirmative defenses.You must state all affirmative defenses or they will be waived.You should also allege the material facts of that affirmative defense.I think that's what specifically and particularity mean.Hate to say this but You must.At least that is how it is in all the jurisdictions I know of.No trial by ambush.
Hope that helps
Tom