622. The counter-statement.

622.     The counter-statement.

Any counter-statement filed by the defendant1 must:

  1.  

    (1)     state which of the allegations in the statement of grounds2 he denies3;

  2.  

    (2)     state which of the allegations he is unable to admit or deny, but which he requires the claimant4 to prove5;

  3.  

    (3)     state which of the allegations he admits6;

  4.  

    (4)     be verified by a statement of truth7; and

  5.  

    (5)     comply with the formal requirements for documents8.

Where the defendant denies an allegation he must state his reasons for