Answer to Complaint for Damages for Breach of Contract with statutes and case law for the elements of the 113 affirmative defenses including inter alia failure to state a cause of action; lack of standing, legal capacity; lack of jurisdiction; non-joinder indispensable party; no justiciable controversy; pleading uncertain, splits cause of action; defense of concurrent action, res judicata, collateral estoppel, satisfaction; claim barred by statute of limitations - not tolled, waived, extended, stayed, revived; laches; contract not properly pled; lack of enforceable contract; no contractual obligation owed to third party, obligations not severable; contractual obligation extinguished; performance excused, ratified, justified, prevented; breach of contract not pled, no cause of action for breach of contract; waiver of breach, antecedent material breach, anticipatory breach/repudiation; relief barred – unclean hands, equitable estoppel in pais, cause of action pled, adequate remedy at law, election; recoverable damages; third party recovery for negligent performance of contract. 143 pages.

Unannotated copy; all 113 affirmative defenses, exclusive of the statutes and case law identifying, interpreting and applying the elements of the defense. 36 pages.