Answer to Complaint for Damages for Negligence for Personal Injury and/or Property Damage with statutes and case law for the elements of the 102 affirmative defenses, including inter alia failure to state cause of action; lack of capacity, standing, jurisdiction; no justiciable controversy; claim barred by concurrent action, res judicata, collateral estoppel, satisfaction; statute of limitations, not tolled, waived, stayed, revived; no duty of care owed to plaintiff or duty limited by foreseeability of harm; defendant’s conduct not cause of injury; defense of no liability - conduct of reasonably prudent person, presumption of due care of others, imminent peril; no derivative/imputed/vicarious liability, independent superseding cause; plaintiff’s contributory negligence, assumption of the risk; relief barred – no actual damages, plaintiff’s unclean hands, failure to mitigate damages; recoverable damages and limits thereto – medical and related damages, loss of income, pre-existing condition, pain and suffering, injury to property, economic interest, incurred through the tort of another, future lost income, barred, limited by plaintiff’s negligence, unjust enrichment, defendant’s rights; joint & several liability of multiple tortfeasors. 125 pages."

Unannotated copy; all 102 affirmative defenses, exclusive of the statutes and case law identifying, interpreting and applying the elements of the defense. 35 pages.