Answer to Complaint for Damages for Loss of Consortium with statutes and case law for the elements of the 17 affirmative defenses, including inter alia failure to state cause of action; claim barred; lack of standing, legal capacity; statute of limitations, not tolled, no relation back of amended complaint; defense of claim derivative of personal injury claim, requisite elements not pled; recoverable damages; joinder in the main negligence action. 13 pages.

Unannotated copy; all 17 affirmative defenses, exclusive of the statutes and case law identifying, interpreting and applying the elements of the defense. 6 pages.