3 KINDS OF SPECIFIC DENIAL
UNDER THE RULES OF COURT
(a) by specifying each material allegation of
fact in the complaint, the truth of which he does
not admit, and whenever practicable, sets forth
the substance of the matters upon which he
relies to support his denial;
(b) by specifying so much of an averment in
the complaint as is true and material and
denying only the remainder; and
(c) by stating that the defendant is without
knowledge or information sufficient to form a
belief as to the truth of a material averment
made in the complaint, which has the effect of
a denial