Answer to Cross-Complaint for Contribution, Contractual Indemnity and Declaratory Relief with statutes and case law for the elements of the 45 affirmative defenses including inter alia failure to state cause of action; lack of jurisdiction; no justiciable controversy; statute of limitations – not waived; spoliation; contract not properly pled, lack of enforceable contract; performance excused, justified, impossible, prevented, defective work not in defendant’s scope; failure of condition precedent; no liability for performance of others; no cause of action for negligence; relief barred - cross-complainant’s unclean hands, contributory negligence; cross-defendant’s conduct not cause in fact of plaintiff’s injuries; alteration/modification/misuse of product/instrumentality involved; no liability for/as an intervening superseding cause; no duty to defend - failure to tender claim, no duty to indemnify under Crawford, no contractual duty to indemnify, no implied contractual or equitable duty to indemnify; joint and several liability of multiple tortfeasors; recoverable damages. 56 pages.

Unannotated copy; all 45 affirmative defenses, exclusive of the statutes and case law identifying, interpreting and applying the elements of the defense. 20 pages.