Answer to Amended/Supplemental Complaint for Damages with statutes and case law for the elements of the 16 affirmative defenses including inter alia the supplemental complaint is improper; the amendment fails to cure defect, is improper or defective; statute of limitations, no relation back; plaintiff bound by omitted allegations; amendment a sham. 14 pages.

Unannotated copy; all 16 affirmative defenses, exclusive of the statutes and case law identifying, interpreting and applying the elements of the defense. 7 pages.