Answer to Home Owner Complaint for Damages [Construction Defect Claim] with statutes and case law for the elements of the 134 affirmative defenses, including inter alia failure to state a cause of action; lack of standing, legal capacity; no justiciable controversy; no jurisdiction; complaint splits cause of action; statute of limitations not waived, extended, revived, tolled; claim barred by equitable estoppel, promissory estoppel, concurrent action, res judicata, satisfaction, laches, plaintiff’s unclean hands, non-joinder of indispensable party; lack of enforceable contract, breach of purchase agreement, antecedent material breach, breach of implied covenant of good faith and fair dealing; performance excused, impossible, prevented, justified, ratified/approved; defective work not in defendant’s scope, no derivative/imputed liability no cause of action for breach of contract, obligation extinguished by performance, no cause of action in negligence, strict liability; no warranty, warranty waived, disclaimed, no notice of breach, no failure to repair; no cause of action for strict product liability; no liability for defect of owner’s design; defense of no liability for/as an intervening superseding cause, contributory negligence of third party; no standing to protection of SB 800; plaintiff’s contributory negligence; alteration/modification/redesign, misuse/abuse/neglect of work of improvement, failure to maintain, allow repairs; release of claimed violation; equitable relief barred; recoverable damages, limitation of economic loss rule, licensing statutes, unenforceable indemnity provision, defendant’s counter-claim for damages. 134 pages."

Unannotated copy; all 134 affirmative defenses, exclusive of the statutes and case law identifying, interpreting and applying the elements of the defense. 50 pages.