Answer to Cross-Complaint for Contribution, Indemnity and Declaratory Relief with statutes and case law for the elements of the 28 affirmative defenses including failure to state cause of action; lack of jurisdiction; no justiciable controversy; statute of limitations – not waived; spoliation; 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; contributory negligence of third party; no liability for/as an intervening superseding cause; no equitable duty to indemnify, indemnity limited to actual loss; no duty to defend Regan Roofing; joint and several liability of multiple tortfeasors; recoverable damages. 30 pages.

Unannotated copy; all 28 affirmative defenses, exclusive of the statutes and case law identifying, interpreting and applying the elements of the defense. 13 pages.