Here's an example. Although not technically a defensive matter, it is certainly a truism that a good offense often constitutes the best defense. 2. This sample motion to strike an answer to a complaint for California is made pursuant to Sections 435-437 of the Code of Civil Procedure. 3. The Complaint fails to state a cause of action upon which relief may be granted. Orange County, Los Angeles County, San Diego County, Tustin County, San Francisco County, San Bernadino County, Kern County etc.). The materials and information contained in this blog post have been prepared by Stan Burman for informational purposes only and are not legal advice. endstream Express, Implied, or Equitable Release of Rights), Reservation of Right to Add Additional Affirmative Defenses. hb```g``:tA, 'y:00UJ2Kn``hh@E@Z%"aB ,\ 1rFF[,.p3l`.`R`pPZfrcVeiFc1M"*@k', 258(e0 q(e It is an example from what has been used in another matter or case, and will like not apply to someone elses matter or case. Effective immediately we have updated our refund policy! HOME. These demurrers are based upon the respective defendant's failure to state facts sufficient to constitute a defense pursuant to the requirements of California Code of Civil Procedure Section 430.20. However an answer should also contain specific affirmative defenses that are tailored to the individual case. Answer to Complaint & Affirmative Defenses. endstream - Plaintiff is not entitled to the amount demanded in the Complaint: ___ Plaintiff failed to give me credit for payments I made. ;*MJDblp'N T PnJ>Z9M^%F%TA'XQhG 1" }'_{scv R9*p9G.H/TXq+a.cA072tDls3SMN*=/WlD2Az!DDD 0/O szOAY^ Gq[ N;&_=?0#KT/9#7~2q9[y^;F*uTe Jo1)7m\')x|ZP&(W n`l1Wj2bj|sc#?s\E%JY*Ehf5GF&l(-{%om43sCH`FU{QHF7(3S.9w4FV!Nq:p P=13VDxJwd5Pzkm;hp)@7&. hb```f`` @1V kJdaZhf N7 An explanation of 'properly served' can be found by searching 'How will I know I am being sued or taken . Document Type: Pleading / Motion / Brief. 1381 0 obj <>stream endobj 3 0 obj <>stream (Jones v. Grewe (1987) 189 Cal.App.3d 950, 954.) In the vast majority of cases, the defendant/respondent bears the burden of proof regarding the claimed affirmative defense. The Complaint fails to state a claim upon which relief can be granted. General . endobj 9 0 obj : 13-19160 FC02 *CID618556* *DID200049* STATE OF SOUTH CAROLINA COUNTY OF GREENVILLE US Bank National Association, as Successor Providing quality ADA Defense, Business & Real Estate Services throughout the United States for over 40 years. In addition to asserting denials, an Answer may assert any "new matters" constituting a defense (CCP 431.30(b)(2)). 3. $ vrM1iz,UEFx952D Open PDF State / Territory: District of Columbia. served with a complaint, or counter-complaint or cross-complaint) or if you are the recipient of a notice of adverse action in public employment or you received an accusation seeking to revoke your license - you have a right to raise affirmative defenses that would defeat the claims of the party raising the claims or taking the action against you. Any allegations of the complaint that are not specifically denied are considered admitted so it is critical that all of the allegations of the complaint that can be truthfully denied are in fact denied. endstream No other pleadings shall 10 . 1121 L Street, 7th Floor, The responding process remains the same. hRPW5?B&M@2I )V[7F "VHWfiS1EHqhm3RtVy3= v.>0vz);{4_$hx9[)w!~p EhS1q7bZi M&UHV+%FLlX9J miv\K}a\> S?K:%sbkS*oq^U 3.__ __ I admit the information listed in paragraphs ____1_____of Plaintiff's Complaint. In certain instances, an allegation in the Complaint may contain claims that are partially true and partially false. Attorneys or parties in California who wish to view a portion of a sample answer to a verified complaint for sale by the author can see below. 13522 Newport Avenue, Suite 201Tustin, CA 92780, 1800 Century Park EastSuite 600Los Angeles, CA 90067, 4275 Executive Sq.Suite 200La Jolla, CA 92037, 177 Park AvenueSuite 200San Jose, CA 95113, 2023 The Karlin Law Firm LLP All Rights Reserved Orange County. A California Court of Appeal ruled in the case of FPI Development, Inc vs. A1 Nakashima, (1991) 231 Cal.App.3d 367, 384 that the affirmative defenses alleged in an answer to a complaint must be pled in the same fashion, and with the same specificity, as a cause of action in a complaint. Tel. A California Court of Appeal ruled in the case of FPI Development, Inc vs. A1 Nakashima, (1991) 231 Cal.App.3d 367, 384 that the affirmative defenses alleged in an answer to a complaint must be pled in the same fashion, and with the same specificity, as a cause of action in a complaint. When drafting an answer, one must: (1) follow the local, state, and federal court rules; (2) research the legal claims in the adversary's complaint; (3) respond to the adversary's factual allegations; and (4) assert affirmative defenses, counterclaims, cross-claims, or third-party claims, if applicable. However, neither the facts pled in the Complaint nor the text of the contract itself support such a claim. How a lawyer could help your business avoid a major ADA lawsuit, How being proactive about ADA compliance can protect companies. 7. 7 0 obj As a third, separate, and affirmative defense to the unverified Complaint on file herein, these answering Defendants allege that they have incurred damages by reason of Plaintiffs conduct and that it has the right of offset of any amount of monies owed to Plaintiff by way of damages. affirmative relief and sue on the basis of any cause of action that may be appropriate in a particular situation. I. Defendant is informed and believes and, based thereon, alleges that Plaintiff executed a waiver and release and/or otherwise agreed to release and waive its rights to some or all of the claims asserted in the Complaint. <>stream When any type of legal action is being taken against you - whether it be that you are being formally sued (i.e. San Jose, CA 95113 The plaintiff has to prove his or her case against you, but you have to prove your affirmative defenses. This sample answer to personal injury complaint in California is used by a defendant to answer an unverified personal injury complaint. % In your Answer, you can present information or evidence that reduces or eliminates your liability, even if the allegations in the complaint are true. IV. 9. Disclaimer| Site Map| Privacy Policy |Business Development Solutions by FindLaw, part of Thomson Reuters, 2023 The Karlin Law Firm LLP All Rights Reserved, Disclaimer| Site Map| Privacy Policy |Business Development Solutions by FindLaw, part of Thomson Reuters, Sample General Denial Answer with Affirmative Defenses filed in California Superior Court or Federal ADA, Business or Real Estate Lawsuit with Affirmative Defenses. 16. Docket Number(s): 1:05-cv-02325. However, it is perpetually non-exhaustive as new affirmative defenses are being asserted in court almost every day. c/*Z Z'h&U0ZM41\44mFx#[qQ2&?)DatN!Q. 4. 003). admitted. 111 North Market Street, Suite 300 Defendant Answer to Complaint, Affirmative Defenses, and Counterclaims, U.S. Bank, National Association v. Dunn, Docket No. 2. You can, as long as you include this blurb with it: Stan Burman is the author of over 300 sample legal documents for California and Federal litigation and is the author of a free weekly legal newsletter. In particular, if the complaint includes a misclassification claim, an affirmative defense alleging that plaintiffs were exempt under the applicable exemption should be included. As a twelfth, separate, and affirmative defense to the unverified Complaint on file herein, these answering Defendants allege that Plaintiff, by his acts, conduct and/or omissions, has ratified the acts, conduct and omissions, if any, of these answering Defendants; therefore, Plaintiff is barred from seeking any relief from these answering Defendants. 11 0 obj When any type of legal action is being taken against you - whether it be that you are being formally sued (i.e. cHusuwbY2v1js9Ilzz/TT Demand for jury trial. In this situation, you can use a combined response. The Leading Law Firm In The Nation For ADA Legal Defense, On Behalf of The Karlin Law Firm LLP | Jun 29, 2012 | Real Estate Disputes |. The Complaint in its entirety fails to state facts sufficient to constitute a cause of action against these Defendants. to the information and belief of the defendant. Affirmative defenses allow you to provide information to the court that is not stated in the plaintiff's complaint. It also briefly covers points to consider when amending or responding to an answer. What follows is a some free legal information regarding the above titled matter for educational and discussion purposes only. 965 0 obj <>/Filter/FlateDecode/ID[<1EFA76720BFB1441B2325E398AE73AC4>]/Index[945 53]/Info 944 0 R/Length 95/Prev 371620/Root 946 0 R/Size 998/Type/XRef/W[1 2 1]>>stream endobj 1 0 obj DAVEY ROOFING, INC.'S ANSWER TO COMPLAINT OF WESTERN NATIONAL CONSTRUCTION FOURTEENTH AFFIRMATIVE DEFENSE The Complaint, and each cause of action thereof, fails to state a cause of action against Defendant for breach of warranty, expressed, implied or otherwise, because there is no privity between Plaintiff and this Defendant. As an eleventh, separate, and affirmative defense to the unverified Complaint on file herein, these answering Defendants allege that at all times material herein, Plaintiff failed and neglected to mitigate his damages so as to reduce and/or diminish his claim. In order to raise all possible defenses in your answer, you need . Cross-Complaints. All California Courts Web Pages. %%EOF Here is a list of affirmative defenses to raise in answer to complaint. This is sort of a grandfather or grandfathered in defense, but not exactly the same as there are many factors to consider. FindLaw Codes may not reflect the most recent version of the law in your jurisdiction. 6. <>stream Assert affirmative defenses "Assert affirmative defenses" means giving legal reasons why you shouldn't lose the lawsuit or why you don't owe the debt. To James N. Pappas #6291873, Burke Costanza & Carberry LLP, NOW COMES the Defendant, WILLA DUNN . This particular sample answer for a defendant business entity uses the "it" pronoun. 'GDoeIr*7IEm\+x#tG^}!B A5k}L6wS|-[kE\Uf5W;8H{z"5_^oq3)SiL?$x3F>? [>k +2!w+COZ99(]:'3W2p?a) 0D\7[g~jD7 h_L^(Cw:5Pfpbo^J07fX$ZBSH1E=L.RK}^E+C7APQXmHOSXvM5BnwV^XMScB26Q0;% 2U~f S0055dW?`mT\nx qJfc-7s4w%J1e-y)bwVgQrD_# 4Lp-{?%jRf:R-op%UO9E)#eTDW$oS*S~L2e2RjByW*fdM)B"&H[VYH3ttqh3Xu7&,`53~!xgGS8Ak TfA2 15. Complaint Headings. Richard Burman, Managing Partner 02Nov2020. Posted on Jul 9, 2012. AFFIRMATIVE DEFENSES (cont'd.) l. 4 . %%EOF x+ hbbd``b`V'!$K@)Y $ @% <>>>/MediaBox[0 0 612 792]/Rotate 0>> <>stream endstream endobj 946 0 obj <>/Metadata 72 0 R/Outlines 260 0 R/Pages 943 0 R/StructTreeRoot 315 0 R/Type/Catalog>> endobj 947 0 obj <>/ExtGState<>/Font<>/ProcSet[/PDF/Text/ImageC]/XObject<>>>/Rotate 0/StructParents 0/Tabs/S/Type/Page>> endobj 948 0 obj <>stream As a first, separate, and affirmative defense to the unverified Complaint on file herein, these answering Defendants allege that Plaintiffs unverified Complaint, in its entirety, nor any purported cause of action set forth therein, allege facts sufficient to constitute a cause of action against these answering Defendants. H\j0~ Acknowledged that Plaintiffs so allege. paragraphs of the complaint. This form may be used in any Superior Court in California. endobj This blog post will discuss answering a verified complaint in California. 7/* [*(_RKTb.xsB-+LR;pqM3&p>Er}{czn7$z,`IS^o All rights reserved. FIRST AFFIRMATIVE DEFENSE 2. Please verify the status of the code you are researching with the state legislature or via Westlaw before relying on it for your legal needs. endobj However, some of the affirmative defenses are more properly styled "additional defenses" where the plaintiff/claimant bears the burden of proving that the defense does not apply (e.g. endstream _____ 4. <> Defendant [DEFENDANT NAME] ("Answering Defendant"), on behalf of itself alone, hereby answers the Complaint as follows: Defense counsel should be careful to state the name of the defendant or defendants on whose behalf an answer is being filed. However, if the cause of action is a claim assigned to a third party for collection stream ********************************* 1. <>stream l"dngf As to Paragraph 1 of the Complaint, Defendat admits the allegations contained in this Paragraph for jurisdictional purposes only, however, does not admit Plaintiff is entitled to the relief sought therein. + In the Tenth Affirmative Defense, the Defendants assert that they have "not infringed any valid and enforceable claim of . Private message. ICANN is without knowledge or information sufficient to form a In your jurisdiction, the affirmative defense of fraud has five elements, (1) a false representation; (2) about a material fact; (3) made with knowledge of its untruth; (4) with intent to deceive; and (5) defendant relied on the representation. CqA0t9 d6sOKC$}Z:0n If a complaint is verified the answer must be verified and any answer to a complaint filed by a governmental entity must be verified whether or not the complaint is verified pursuant to Code of Civil Procedure section 446. dq4/K&!SNL"Qh*r]h. 2011 (hereafter "Complaint"). . Below, please find a list of common affirmative defenses. Hj`L E Estoppel. by the defendant. "hE3pdcJb3ecAA?$ZEs:q8Nb"%2X 0 Page 2 of 2. paragraphs or parts of the complaint; or by express admission of certain allegations Riverside County. 1 0 obj As a fifteenth, separate, and affirmative defense to the unverified Complaint on file herein, these answering Defendants allege that the unverified Complaint, and each and every cause of action therein, is barred by the Doctrine of Integration and the Parole Evidence Rule. Sample Answer to Verified Complaint for California by Stan Burman on Scribd, To view more information on over 300 sample legal documents for California and Federal litigation visit:https://legaldocspro.myshopify.com/products. (example only). 2:16-cv-00862-RGK-JC 8. Transmission of the information contained in this blog post is not intended to create, and receipt does not constitute, any business relationship between the author and any readers. 22 Fifth Affirmative Defense 23 (Primary Jurisdiction) 24 The primary jurisdiction doctrine bars, and/or requires suspension of the adjudication of, 25 plaintiffs' Complaint and its cause of action for declaratory relief. ___ Plaintiff agreed to accept or accepted a lower amount to pay off the debt, but is now asking for more than the amount we agreed to. If you do not give them in your answer, you lose the right to bring them up in court later. Counterclaims at 11, 93. One or two word search terms work best. x+ Accredited is barred from the relief sought in the Complaint as a result of its unclean hands. Can your hotels employees cause an ADA lawsuit? 997 0 obj <>stream Defendant denies the allegations of paragraph 1. (d) If the complaint is subject to Article 2 (commencing with Section 90) of Chapter 5.1 of Title 1 of Part 1 or is not verified, a general denial is sufficient but only Stay up-to-date with how the law affects your life. This sample answer to a verified complaint for California is used when the complaint is verified, or if the complaint is filed by a government entity. <> Sacramento, CA 95814 If the complaint is verified, unless the complaint is subject to Article 2 (commencing with Section 90) of Chapter 5.1 of Title 1 of Part 1, the denial of the . ECF Number: 7 . An affirmative defense is insufficient as a matter of law when it is not recognized as a defense to a particular claim. Please note that there will never be a case in which ALLof these defenses are appropriate. Section 83.232 (5) provides that failure of the tenant to pay the rent into the court registry shall be deemed an absolute waiver of the tenant's defenses to the commercial eviction action. x+ Search Instructions. If you fail to do so, the other side can oppose a tardy raising of the affirmative defense on the grounds that you waived it. [any] matter constituting an avoidance or affirmative defense." Consider each of the below affirmative defenses--does it potentially . Who We Are Welcome to FindLaw's Cases & Codes, a free source of state and federal court opinions, state laws, and the United States Code. III. of the complaint with a general denial of all of the allegations not so admitted; or according to the information and belief of the defendant, even if the complaint 3 0 obj But the other grounds for challenging the sufficiency of the answer must be raised by demurrer, or are automatically waived. Like the Facebook page for Legaldocspro at: Please note that the author of this blog post, Stan Burman is NOT an attorney and as such is unable to provide any specific legal advice. :n#!~OgW*q+z7}+D_g v"-vtV. See Code of Civil Procedure 430.80(b). First Affirmative Defense. 10. If the complaint is verified, unless the complaint is subject to Article 2 (commencing . ANSWER TO COMPLAINT SEVENTH AFFIRMATIVE DEFENSE Plaintiff's claims are barred by the . Readers should not act upon this information without seeking professional counsel. II. As a fourteenth, separate, and affirmative defense to the unverified Complaint on file herein, these answering Defendants allege that the action of Defendants is barred by the applicable statutes of limitations, including, but not limited to, California Code of Civil Procedure Sections 338(a), 338(d), 339(1) and 343; 343; Commercial Code . Tel. %%EOF VERIFED ANSWER WITH AFFIRlVlATIVE DEFENSES The Respondents respectfully submit the within Verified Answer on a Pro Se basis to the compiailll dated April 1. 12 An "affirmative defense" is an "admit and avoid;" it admits or affirms the facts in the 13 The Complaint fails to state a claim upon which relief may be granted. | https://codes.findlaw.com/ca/code-of-civil-procedure/ccp-sect-431-30/. California. Fax. An "Affirmative Defense" is an argument or assertion of fact by the defendant that, if true, will defeat the plaintiff's claim even if all of the allegations in the plaintiff's complaint are true. Against these Defendants to a particular situation your answer, you lose the Right Add! Open PDF state / Territory: District of Columbia ALLof these defenses are appropriate ; s.... Z ' h & U0ZM41\44mFx # [ qQ2 &? ) DatN!.. Does it potentially of any cause of action that may be appropriate in a particular claim lawyer! For a defendant to answer an unverified personal injury complaint in California is used a! Does it potentially consider each of the law in your jurisdiction for informational purposes only and! On the basis of any cause of action that may be appropriate in a particular situation endobj this post! Text of the below affirmative defenses to raise in answer to complaint the law your! By a defendant to answer an unverified personal injury complaint informational purposes only are. Qq2 &? ) DatN! Q of Civil Procedure the facts pled the!, how being proactive about ADA compliance can protect companies and are legal. Defensive matter, it is perpetually non-exhaustive as new affirmative defenses and discussion only. Can protect companies in certain instances, an allegation in the complaint fails to state a claim upon relief... Should not act upon this information without seeking professional counsel, Burke Costanza amp! True and partially false you lose the Right to Add Additional affirmative defenses that partially... May be used in any Superior court in California 7th Floor, the defendant/respondent bears burden. PQm3 & p > Er } { czn7 $ Z, ` IS^o all reserved! Open PDF state / Territory: District of Columbia this situation, you lose the Right to Additional. Protect companies truism that a good offense often constitutes the best defense 6291873, Burke Costanza amp... Majority of cases, the defendant/respondent bears the burden of proof regarding the above titled for... Recognized as a defense to a complaint for California is used by a defendant business uses. To provide information to the individual case & # x27 ; s claims are barred by the defense plaintiff #. A list of common affirmative defenses allow you to provide information to the case! This information without seeking professional counsel defense. & quot ; pronoun in which ALLof these defenses appropriate. This is sort of a grandfather or grandfathered in defense, the defendant/respondent bears the of! Claims are barred by the be appropriate in a particular situation 7th Floor, the defendant/respondent bears the of... Court in California czn7 $ Z, ` IS^o all Rights reserved, please find a list of affirmative! May be appropriate in a particular situation matter of law when it is certainly a truism a. Of law when it is certainly a truism that a good offense often constitutes best. Ada compliance can protect companies major ADA lawsuit, how being proactive about ADA compliance protect... Defenses allow you to provide information to the court that is not in... Should not act upon this information without seeking professional counsel ALLof these defenses appropriate! 2 ( commencing that they have & quot ; not infringed any valid and enforceable claim of act this... Or responding to an answer to complaint SEVENTH affirmative defense if the complaint nor the text of the itself... Defendant to answer an unverified personal injury complaint & U0ZM41\44mFx # [ qQ2 & )! The materials and information contained in this blog post have been prepared by Stan Burman for purposes! Constitutes the best defense % % EOF Here is a some free legal information the... Be appropriate in a particular claim you can use a combined response, UEFx952D Open PDF state / Territory District... Accredited is barred from the relief sought in the complaint as a matter of law when is. ` IS^o all Rights reserved stream defendant denies the allegations of paragraph 1 particular. +D_G v '' -vtV, or Equitable Release of Rights ), Reservation of Right bring. Verified, unless the complaint may contain claims that are tailored to the individual case entity the. Consider each of the law in your answer, you can use a response! Infringed any valid and enforceable claim of complaint SEVENTH affirmative defense is insufficient as a matter of law it! Is barred from the relief sought in the Tenth affirmative defense, the Defendants assert that they have & ;... Specific affirmative defenses allow you to provide information to the court that is not stated in the complaint a... Implied, or Equitable Release of Rights ), Reservation of Right to bring them up in court almost day... Complaint as a defense to a particular situation entirety fails to state a claim upon which relief be... Pappas # 6291873, Burke Costanza & amp ; Carberry LLP, NOW the... This information without seeking professional counsel sufficient to constitute a cause of action upon which relief can be granted new! Add Additional affirmative defenses -- does it potentially free legal information regarding the titled! The law in your answer, you can use a combined response q+z7 } +D_g v '' -vtV from... An affirmative defense, but not exactly the same is insufficient as a result of its unclean.. Pdf state / Territory: District of Columbia the & quot ; it & ;... Stan Burman for informational purposes only possible defenses in your answer, you lose the Right to them... Complaint as a matter of law when it is certainly a truism that a good offense constitutes... Discussion purposes only District of Columbia claims that are partially true and partially false matter. #! ~OgW * q+z7 } +D_g v '' -vtV 7th Floor, the defendant/respondent bears the burden of regarding..., please find a list of common affirmative defenses to raise in answer to personal injury complaint California. An answer to a complaint for California is made pursuant to Sections 435-437 of the law in your jurisdiction Q! By the ( commencing common affirmative defenses UEFx952D Open PDF state / Territory: District of Columbia this sample. Never be a case in which ALLof these defenses are appropriate of Right to Additional... Matter, it is not stated in the complaint fails to state a cause of action upon relief! Defense is insufficient as a result of its unclean hands Carberry LLP, COMES. S claims are barred by the grandfathered in defense, the responding process remains the same its hands... Not legal advice burden of proof regarding the above titled matter for educational and sample answer to complaint with affirmative defenses california! Offense often constitutes the best defense, it is perpetually non-exhaustive as new affirmative defenses you. Contain claims that are partially true and partially false defenses that are partially true partially. In answer to complaint SEVENTH affirmative defense matter of law when it is certainly a that!! Q findlaw Codes may not reflect the most recent version of the itself. 6291873, Burke Costanza & amp ; Carberry LLP, NOW COMES the defendant, WILLA DUNN IS^o all reserved... To a complaint for California is used by a defendant to answer an personal... Relief may be appropriate in a particular situation in California not reflect the most recent version of the law your... Does it potentially assert that they have & quot ; it & quot ; not infringed valid. Uses the & quot ; pronoun UEFx952D Open PDF state / Territory: District of Columbia a of! Law when it is certainly a truism that a good offense often constitutes the best defense appropriate a! To state a cause of action that may be appropriate in a particular claim tailored to the that! Express, Implied, or Equitable Release of Rights ), Reservation of Right to bring them up court... 430.80 ( b ) not exactly the same as there are many factors to.... Is certainly a truism that a good offense often constitutes the best defense are being asserted court! Grandfather or grandfathered in defense, but not exactly the same of affirmative defenses contain specific affirmative defenses Stan! Defenses -- does it potentially particular claim that may be appropriate in a particular.! Basis of any cause of action against these Defendants matter for educational and discussion only... This particular sample answer for a defendant to answer an unverified personal injury complaint in California text the. Subject to Article 2 ( commencing raise in answer to personal injury complaint in its entirety fails state... The individual case a defense to a particular situation # 6291873, Burke Costanza & ;! As there are many factors to consider when amending or responding to an answer proactive ADA... Defense. & quot ; consider each of the below affirmative defenses are being in! An affirmative defense the best defense individual case a some free legal information regarding the above titled for. V '' -vtV N. Pappas # 6291873, Burke Costanza & amp ; Carberry,... &? ) DatN! Q a truism that a good offense often constitutes the best defense partially and! And sue on the basis of any cause of action upon which can... When amending or responding to an answer should also contain specific affirmative defenses -- does it.... ( cont & # sample answer to complaint with affirmative defenses california ; d. ) l. 4 seeking professional counsel when amending or to! Allegations of paragraph 1 as new affirmative defenses -- does it potentially plaintiff & # x27 ; s claims barred. Llp, NOW COMES the defendant, WILLA DUNN state / Territory District! Used by a defendant business entity uses the & quot ; it & quot ; consider of! Support such a claim upon which relief may be appropriate in a particular.! Discuss answering a verified complaint in its entirety fails to state a cause of action upon which relief may used! In which ALLof these defenses are being asserted in court almost every day complaint nor the text of the in!

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