Answer to Cross-Complaint for Indemnity, Contribution, Defense and Declaratory Relief [Construction Defect Claim] with authority for the elements of each of the 63 affirmative defenses, including inter alia failure to state a cause of action; lack of jurisdiction; no justiciable controversy; statute of limitations not waived; lack of enforceable contract, failure of condition precedent/concurrent; performance excused, justified, impracticable, prevented, justified by compliance with contract or practice in the industry, non-compliance with building code excused, approved/ratified; defective work not within defendant’s scope; no derivative liability; no cause of action for negligence or strict liability; defense of modification/misuse/neglect/ordinary wear and tear, failure to allow repairs by homeowner, repairs successful; release of claimed violation; contributory negligence of cross-complainant /third party; no liability for/as an intervening superseding cause; no duty to defend or indemnify under Crawford; no contractual/implied/equitable duty to indemnity; participation in a WRAP policy, no additional insured endorsement; joint and several liability of several tortfeasors; recovery barred; recoverable damages limited by business risk, cross-defendant’s counter-claim. 77 pages.

Unannotated copy; all 63 affirmative defenses, exclusive of the statutes and case law identifying, interpreting and applying the elements of the defense. 29 pages.