Answer to Complaint for Damages for Breach of Contract
Answer to Complaint for Damages for Breach of Contract with statutes and case law for the elements of the 113 affirmative defenses including inter alia failure to state a cause of action; lack of standing, legal capacity; lack of jurisdiction; non-joinder indispensable party; no justiciable controversy; pleading uncertain, splits cause of action; defense of concurrent action, res judicata, collateral estoppel, satisfaction; claim barred by statute of limitations - not tolled, waived, extended, stayed, revived; laches; contract not properly pled; lack of enforceable contract; no contractual obligation owed to third party, obligations not severable; contractual obligation extinguished; performance excused, ratified, justified, prevented; breach of contract not pled, no cause of action for breach of contract; waiver of breach, antecedent material breach, anticipatory breach/repudiation; relief barred – unclean hands, equitable estoppel in pais, cause of action pled, adequate remedy at law, election; recoverable damages; third party recovery for negligent performance of contract. 143 pages.
Unannotated copy; all 113 affirmative defenses, exclusive of the statutes and case law identifying, interpreting and applying the elements of the defense. 36 pages.