what affirmative defenses must be pled

'S, AFFIRMATIVE DEFENSES . The Code lists common affirmative defenses: accord and satisfaction, arbitration and award, ... affirmative defenses are waived if not pled. There are a myriad of legally recognized affirmative defenses under Florida law. “Affirmative defenses that are neither pled nor tried by consent are deemed waived.” Ashburn, 970 So. 3. . The test for validity of an affirmative defense under Florida law is whether the defense admits the cause of action and supporting facts asserted by a preceding pleading, but raises some new matter which defeats the opposing party’s otherwise apparently valid claim. Certain offenses must be asserted, before trial. Defendant's conviction for aggravated assault should have been merged into a malice murder conviction pursuant to O.C.G.A. Under the Federal Rules of Civil Procedure Rule 56, any party may make a motion for summary judgment on an affirmative defense. While the following are statutorily recognized as affirmative defenses, a defendant-insurer must plead them with a “short and plain statement of facts” and not just as “bare bones conclusory allegations.”. Notice of certain must be given within 20 working days after the date the case is set for trial pursuant to G.S. OR "modify" OR "amend" Either terms can appear in document "" "motion for summary judgment" Exact match of phrase * negligen* Match anything after the * Motion to Strike - PLAINTIFFS' MOTION TO STRIKE DEFENDANT,?JUAN PABLO GIRALDO, M.D. (a) an affirmative defense, such as contributory negligence; the existence of an agreement to arbitrate; assumption of risk; payment; release; satisfaction; discharge; license; fraud; duress; estoppel; statute of frauds; statute of limitations; immunity granted by law; want or failure of consideration; or that an instrument or transaction is void, voidable, or cannot be recovered on … The rationale underlying EPA’s determination that the provisions were substantially inadequate to meet At first reading, it appears as if the Pennsylvania Supreme Court has added to the affirmative defenses, which must be pled specifically under the Pennsylvania Rules of Civil Procedure or deemed waived. The assertion of every conceivable affirmative defense falls far outside this solemn obligation. Assault and Battery 2 — civil assault — defense of family — affirmative defense — failure to plead — submission to jury improper A defendant in a civil action may assert defense of family to justify assault on a third party, but it is an affirmative defense which must be affirmatively pled. You and your highly skilled family law attorney can fight charges of being at fault through affirmative defenses. Civ. 2022 Nwoha Law Firm. That too can result in waiver. In responding to a pleading, a party must affirmatively state any avoidance or affirmative defense, including: • accord and satisfaction; • arbitration and award; • assumption of risk; • contributory negligence; • duress; • estoppel; • failure of consideration; • fraud; • illegality; - Trial court did not err in failing to charge the jury that an affirmative defense to a prosecution for theft by a public officer arose if the defendant, a sheriff, acted under an honest claim of right to the property or service involved pursuant to O.C.G.A. 2d at 212 (¶23) (quoting Goode v. Village of Woodgreen Homeowners, 662 So. Although generally an affirmative defense must be pled in the answer, this rule is displaced where an affirmative defense is apparent on the face of the Complaint. 4th 742, 751. A little explanation of this defense may be helpful. One of those affirmative defenses stated in full, ‘The Plaintiff has given false and/or conflicting information to Defendant, thus, … In responding to a pleading, a party must: (A) state in short and plain terms its defenses to each claim asserted against it; and (B) admit or deny the allegations asserted against it by an opposing party. The factual basis for an affirmative defense must be set out in the same manner as is required for the pleading of claims under the Missouri Rules of Civil Procedure. 4th 742, 751. A denial must fairly respond to the substance of the allegation. This means that it must be pled in the defendant’s answer to the petition and cannot be raised later if it is not in the answer. New York’s Civil Practice Law & Rules (“CPLR”) § 3018 (b) provides that a party must plead as an affirmative defense “all matters which if not pleaded would be likely to take the adverse party by surprise or would raise issues of fact not appearing on the face of a prior pleading.”. The most commonly used defenses to involuntary manslaughter charges include: Severity of Negligence – negligence resulting in someone’s death must rise to the level of being gross negligence, or criminal negligence. B. February 2022. When must certain affirmative defenses be asserted? (per curiam), the Pennsylvania Superior Court outlined the sudden medical emergency defense for motor vehicle accident matters and held that it should be pled as an affirmative defense when applicable. Monahan also argues that Rule 3:18(e) "contemplates that affirmative defenses must be pled" because it states that they "may . 3 Affirmative … if an affirmative defense is set forth in an answer and the pleader wishes to allege any matter constituting an avoidance of the defense. Heller Fin., Inc. v. Midwhey Powder Co ., 883 F.2d 1286, 1294-1295 (7th Cir. Decker v. However, there is no requirement that an affirmative defense be set forth in a particular way or contain “magic words” in order to be cognizable. Learn more here. Knighton v. Howse, 167 Colo. 530, 448 P.2d 641 (1968). These defenses are known as compulsory affirmative defenses and include: Accord and Satisfaction, Arbitration and Award, Assumption of the Risk, Contributory Negligence, Discharge in Bankruptcy, Duress, Estoppel, Failure of Consideration, Under Rule 8(c) such disputation is called an affirmative defense; the Rule requires the defendant to set forth any and all affirmative defenses, including, as under prior law, "any facts which would entitle him in equity to be absolutely and unconditionally relieved against the plaintiff's claim or cause of action or against a judgment recovered by the plaintiff in such action," G.L. 1791 MDA 2011 (Pa.Super. In order to raise an affirmative defense of fraud, the “pertinent facts and circumstances constituting fraud must be pled with specificity, and all the essential elements of fraudulent conduct must be stated.” Zikofsky v. Robby Vapor Systems, Inc., 846 So.2d 684, 684 (Fla. 4th DCA 2003) (citation omitted). Blum, supra at 345. Cocoves v. Campbell, 819 So.2d 910, 913 (Fla. 4th DCA 2002); Thompson v. Bank of New York, 862 So.2d 768 (Fla. 4th DCA 2003). Failure to do so may preclude a defendant insurer from raising the issue in a motion for summary disposition. A statute of limitations defense, being affirmative in nature, must be raised by responsive pleading. The Appellate Courts have … The defense is not raised if the manufacturer challenges only the practicality of an alternative design or device, and not its technological availability or feasibility at the time the product Ann. Only a few cases references such motions to strike or demurrers attacking boilerplate affirmative defenses. In law as practiced in countries that follow the English models, a pleading is a formal written statement of a party's claims or defenses to another party's claims in a civil action.The parties' pleadings in a case define the issues to be adjudicated in the action. In Maryland, under Rule Md. A statute of limitations is an affirmative defense and hence must be affirmatively pleaded. malfunctions constitutes an affirmative defense to an enforcement action brought for noncompliance with emission standards, or other regulatory requirements’’ if the source can demonstrate that certain criteria in the Rule are met. Thus, the Answer is capable of amendment. (Pa. Nov. 26, 2012), that changes the way defendants in product liability actions must plead and prove an … Ralston, No. must contain at least 4 different symbols; at least 1 number, 1 uppercase and 1 lowercase letter; not based on your username or email address. In . One court was indeed critical of answers that recite “a kitchen sink full of affirmative defenses” but fail to explain “the underlying facts” or apply the law to the defenses. (c) Affirmative defenses. Appeals had held that “[a]n affirmative defense is subject to the same pleading requirements as is the complaint.” Woodfield v. Bowman, 193 F.3d 354, 362 (5th Cir. 7. Defense counsel should periodically review the answer to make sure that all possible affirmative defenses, and potential counterclaims, have been asserted. The proposed Amended Answer shall be served and filed by May 31, 2022.---PERSONAL APPEARANCES ARE PERMITTED. CPLR 3018 (b) contains the following, non-exhaustive list of defenses that should be affirmatively pleaded in an answer: Arbitration and award. The Civil Procedure Rules (CPR) govern pleading in England and Wales. Rule 6.113(2)(h) doesn’t use the word “avoidance,” but it does say any affirmative defense must be raised with specificity, and that any objections or responses to the … One court was indeed critical of answers that recite “a kitchen sink full of affirmative defenses” but fail to explain “the underlying facts” or apply the law to the defenses. Most commonly the statute of limitations is the defense that can be gleaned from the pleading. While the following are statutorily recognized as affirmative defenses, a defendant-insurer must plead them with a “short and plain statement of facts” and not just as “bare bones conclusory allegations.”. The defendant’s attorney faced with a demurrer to the answer must determine whether it is cost-effective to oppose a motion that will likely be granted, or to offer to amend the answer. . (c) Affirmative Defenses. (c) Affirmative Defenses. be included in the same paper" as a defendant's grounds of defense, counterclaims, cross-claims, pleas, demurrers, and other motions. This Court has held that the § 255(a) statute of limitations is “an affirmative defense which must be specifically pled.” Day v. While the Supreme Court had increased the specificity with which claims had to be pled in . See also , Fed. [218 Cal. FPI Development. Cocoves v. Campbell, 819 So.2d 910, 912-13 (Fla. 4th DCA 2002). These defenses are known as compulsory affirmative defenses and include: Accord and Satisfaction, Arbitration and Award, Assumption of the Risk, Contributory Negligence, Discharge in Bankruptcy, Duress, Estoppel, Failure of Consideration, Posted in Legal Updates. 156 "Assets" are sources who ... Flemmi pled guilty to the charges in the Connolly indictment at the same time he pled guilty in the new case. Unlike Bitdefender's other affirmative defenses, "[i]nequitable conduct . Since we find that a defense based on section 426.30 must be specially pleaded, we reject Koehler's contention that her affirmative defense of failure to state facts sufficient to constitute a cause of action effectively incorporated the section 426.30 defense and was sufficient to raise it. Number 1. Sassouni and LLC Defendants answered jointly and raised twenty-one affirmative defenses, including standing and under RP APL § 1303, § 1304 and § 1306. According to Rule 1.110 (d) of the Florida Rules of Civil Procedure, the following affirmative defenses must be raised when pleading to a preceding pleading: any other matter constituting an avoidance or affirmative defense. If you fail to meet those time periods a default judgment may be rendered against you for money damages. An affirmative defense assumes that the allegations in the plaintiff’s complaint are true, but that the plaintiff’s claims are barred for an independent reason. c. 231, § 31. In pleading to a preceding pleading, a party shall set forth affirmatively accord and satisfaction, arbitration and award, assumption of risk, contributory negligence, discharge in bankruptcy, duress, estoppel, failure of consideration, fraud, illegality, injury by fellow servant, laches, license, payment, … Pleading Requirements. Answer: This is an Answer and Affirmative Defenses filed in response to a Complaint which begins a lawsuit. A defense is not waived by being joined with other defenses. 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 … Rule 12 (b) of the Federal Rules of Civil Procedure states that a party may assert certain defenses by motion. (2) Denials—Responding to the Substance. If the answer in the present case represents defense counsel’s usual approach to civil litigation, he should reform his practices immediately. Pioneer State Mut Ins Co v Dells, 301 Mich App 368. Enumerated Affirmative Defenses. 2. The nonperformance of conditions precedent must be pled with particularity. Volume 1. Fla. R. Civ. Where a defendant seeks to rely upon an affirmative defense not apparent from the allegations pled and unrelated to the elements of a plaintiff’s cause of action, that affirmative defense must be pled to avoid unfair surprise or In a Virginia divorce, you may be accused of being at fault, or responsible for the divorce. seq. Affirmative Defenses Contract Related Forms. If either of these are absent, then a plaintiff/counter-plaintiff should strongly consider moving to strike the deficient affirmative defense. Enumerated Affirmative Defenses. A California Court of Appeal has stated that the affirmative defenses alleged (in an answer to a complaint filed by the plaintiff) must be pled in the same fashion and with the same specificity as a cause of action in a complaint (i.e. Contrary to Plaintiffs’ argument, there is no requirement to plead facts to support affirmative defenses.1 Pursuant to Florida Rules of Civil Procedure 1.110(d) and 1.140(b), affirmative defenses must be Many of the insurance company’s defenses related to the insurance policy itself. arbitration and award. The insurer-defendant “filed a forty-six-paragraph list of affirmative defenses, most of which are also boilerplate. (a) Except as provided by subdivision (b), all affirmative defenses including but not limited to the defenses of accord and satisfaction, arbitration and award, consent, discharge in bankruptcy, duress, estoppel, failure of consideration, fair comment, fraud, illegality, immunity from suit, impossibility of performance, justification, laches, license, … Let’s start with the Black’s Law Dictionary definition of “affirmative defense”: “A defendant’s assertion of facts and arguments that, if true, will defeat the plaintiff’s or prosecution’s claim, even if all the allegations in the complaint are true.” 2022 Nwoha Law Firm. Chapter. Person causing injury which results in death at least three years later not to be prosecuted for homicide. According to Rule 1.110(d) of the Florida Rules of Civil Procedure, the following affirmative defenses must be raised when pleading to a preceding pleading: accord and satisfaction. Overview. Because appellants have not sufficiently pled the alleged affirmative defenses, they fail as a matter of law. Stat. Collateral Estoppel. 2d 1064 ... but the matter must be an actual, arguable defense. THE MIS-USE OF AFFIRMATIVE DEFENSES IN PERSONAL INJURY. A complaint against a health care provider must be pled “with particularity by alleging facts in sufficient detail to support each element of … In the instant case, Defendant has properly pled his affirmative defenses. New York’s Civil Practice Law & Rules (“CPLR”) § 3018 (b) provides that a party must plead as an affirmative defense “all matters which if not pleaded would be likely to take the adverse party by surprise or would raise issues of fact not appearing on the face... Stat. Within the personal injury practice, it is very common for defense counsels to submit answers to the plaintiff’s petition which assert a wide myriad of … Statute of Limitations and Laches. Rodriguez v. Cho (2015) 236 Cal. Written by Joseph Collison on October 18, 2017. affirmative defenses were insufficiently pled. 1999). (720 ILCS 5/1-4) (from Ch. Illegal purpose is an affirmative defense to contract formation under Illinois law (735 Ill. Comp. 1-4) Sec. AnyLaw is the FREE and Friendly legal research service that gives you unlimited access to massive amounts of valuable legal data. (1) In General. An avoidance or defense must be pled as an affirmative defense. 15(a), or be deemed waived. Failure to Specifically Plead an Affirmative Defense Means Reversal of Dismissal In Florida Eviction Action. Although unlikely, a court could potentially sustain the demurrer as to some or all of the affirmative defenses without leave to amend. A cause of action for fraud must be pled with “specificity,” meaning that allegations of fraud must be described in a complaint with much more detail than other causes of action. P. 1.140(h). 7A-49.4, or such other later time as set by the court. A common affirmative defense for fraud cases is failure to plead a cause of action with specificity. ." Civil remedies preserved. R. 4:5-3 and -4; Cavanaugh v. Skil Corp., 164 N.J. 1, 7 (2000). As amended through April 25, 2022. An affirmative defense does not deny the allegations in the plaintiff’s petition. Bitdefender asserts in its thirteenth affirmative defense that "the '494 patent is unenforceable for inequitable conduct occurring during its prosecution. Research the case of Livesay v. National Credit Systems Inc, from the N.D. Indiana, 04-25-2022. Federal Rules of Civil Procedure govern pleading … 2d 1064 ... but the matter must be an actual, arguable defense. Ashland Oil, Inc. v. Warmann, 869 S.W.2d 910, 912 (Mo.App.1994). – In pleading to a preceding pleading, a party shall set forth affirmatively accord and satisfaction, arbitration and award, assumption of risk, contributory negligence, discharge in bankruptcy, duress, estoppel, failure of consideration, fraud, illegality, However, construing Defendants’ pleadings in the case, as described below, to have pled such an affirmative defense, the Court affirmed the lower Court’s jury verdict, based on the instruction at issue. “Affirmative defenses that are neither pled nor tried by consent are deemed waived.” Ashburn, 970 So. Make sure to properly plead an affirmative defense denying the plaintiff's general allegation that all conditions precedent have even performed or have occurred. An avoidance or defense must be pled as an affirmative defense. Among these defenses … These defenses are known as compulsory affirmative defenses and include: Accord and Satisfaction,Arbitration and Award,Assumption of the Risk,Contributory Negligence,Discharge in Bankruptcy,Duress,Estoppel,Failure of Consideration,Raise It or Waive It: Potential Problems for Practitioners with Minimal\nwww.alabamainjurylaw-blog.com > raise-it-or-waive-it-potential … Affirmative defenses raised in an answer (or amended answer) are deemed denied by plaintiff. February 2022. 1991). must be pled with particularity under Rule 9(b)." A defendant may want to assert an affirmative defense attacking or denying this allegation relating to the plaintiff’s failure to satisfy certain conditions precedent.    In doing so, a defendant must identify the nonperformance or nonoccurrence of conditions precedent with specificity. Moreover, all affirmative defense elements must be pled. Heller Fin., Inc. v. Midwhey Powder Co ., 883 F.2d 1286, 1294-1295 (7th Cir. Five typical affirmative defenses in divorce cases are condonation, insanity, collusion, recrimination, and connivance. at 156, (the party seeking to set aside a contract has the burden of proving the existence of a dominant confidential relationship Policy Exclusions Are Affirmative Defenses Which Must Be Pled. The requirement that most such defenses be specifically pled arises from their collateral nature. Description Answer Circuit Court. . While general affirmative defenses alleging fraud at the outset of litigation are commonplace, such must be amended and pled with specificity to conform with the evidence once uncovered throughout discovery. Neill T. Nwoha, Esq. Self-defense, entrapment, insanity, necessity, and respondeat superior are some examples of affirmative defenses. Where a defendant seeks to rely upon an affirmative defense not apparent from the allegations pled and unrelated to the elements of a plaintiff's cause of action, that affirmative defense must be pled to avoid unfair surprise or prejudice to the plaintiff. 25 at 15-17. 8(c) uses languages that includes avoidances as well as affirmative defenses, the rule requires that any legal argument a defendant may assert to require dismissal of a claim or to prevail at trial must be plead, not just affirmative defenses in the strict sense that only apply where all the elements of a claim are proven. “This has generally led to a requirement that affirmative defenses must be pled in order to be relied upon at trial.” Id. In order to trigger Plaintiff’s alleged future harm, the following series of events is required occur: (1) Plaintiff must contract COVID-19; (2) Plaintiff must suffer mild to moderate symptoms (as opposed to being asymptomatic or hospitalized due to severe or critical symptoms), see Dkt. 5/2-613(d)). (2) Defenses Must Be Pleaded; Exceptions. (ii) if an association or an owner is seeking an estoppel affirmative defense, they must be sure all of the necessary elements are pled, (iii) at times a court will look to the purpose of the rule itself where it makes sense to do so, and (iv) dogs and cats are different, but they are both considered “pets.” P. 94 (providing that affirmative defense of lack of consideration and any other matter constituting an avoidance or affirmative defense must be affirmatively pled). Number 1. denied, 107 N.J. 152 (1987). Woodfield, the court held that a defendant “must plead an affirmative defense with enough specificity or factual 38, par. Within the personal injury practice, it is very common for defense counsels to submit answers to the plaintiff’s petition which assert a wide myriad of … You have very specific time periods you must comply with in order to present your claims and defenses against the other party. App. See Tex.R. A judge will prevent the presentation of affirmative defenses that have not been timely raised before trial. Town of Avon, 820 P.2d 1133 (Colo. App. 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 … Rule 94 - Affirmative Defenses. assumption of risk. Counterclaims and affirmative defenses are too often confused by practitioners. However, the Illinois Supreme Court recently established in a unanimous opinion that it is essential for practitioners to plead these correctly. See Carmichael v. Union Pacific R.R. Co., 2019 IL 123853. This Code does not bar, suspend, or otherwise affect any right or liability to damages, penalty, forfeiture, or other remedy authorized by law to be recovered or enforced in a civil action, for any conduct which this Code makes punishable; and the civil injury is not merged in the offense. Dkt. Password confirm. Only a few cases references such motions to strike or demurrers attacking boilerplate affirmative defenses. The Court went through each of the affirmative defenses that were pled by the insurance company. New Dimensions, 286 Va. at 36, 743 S.E.2d at 271. list of affirmative defenses new jersey new jersey affirmative defenses 3d 1133, 1141 (7th Cir. What affirmative defenses must be pled Florida? Affirmative defenses, if valid, provide a complete or partial defense to plaintiffs' lawsuit. ... proper notice to vacate) must be pled specifically and with particularity or it will be deemed waived). You have very specific time periods you must comply with in order to present your claims and defenses against the other party. (3) General and Specific Denials. Rule 2-323(g), there are 20 affirmative defenses that must be raised in the defendant's answer to the Complaint or they are waived and cannot be raised later: 3.The party seeking to use the defense of fraud must specifically identify misrepresentations or omissions of fact. Ineffectiveness claims can be brought by defendants who pled guilty to a plea deal and did so following the bad advice of counsel. If necessary, the defendant should file a motion to amend the answer. Affirmative defenses not affirmatively pled are waived. ~CLICK HERE TO DOWNLOAD THE PDF VERSION~. A person who causes bodily injury which results in the death of the victim is not criminally responsible for the victim's death and must not be prosecuted for a homicide offense if at least three years intervene between the injury and the death of the victim. App. 2 Purported affirmative defenses that do not satisfy this test are properly stricken. . Still, at a minimum, if a defense is listed in the federal or state rules, it must be pled in the answer. If the subject matter of a contract is illegal, the Ann. 4.Fraud must be pled with particularity. In state court, Rule 8.03 requires that the “facts relied upon to constitute” the affirmative defense must be pled in “short and plain terms.” Thus, it is not enough just to list the affirmative defense. SECTION 16-3-5. An affirmative defense cannot be pled in the form of "terse legal conclusions." This panel will be composed of individuals in various areas of immigration law, from those dealing with removal defense, to affirmative petitions in dealing with same-sex marriages, business immigration, asylum law (LGBTQ issues), pro bono organizations, immigration volunteers. [5] Mutual mistake is an affirmative defense that must be pleaded or is waived. 191716 Potter v. Volume 1. All affirmative defenses must be pled in the answer or in an amended answer permitted under Fed.R.Civ.P. If pleaded as an affirmative defense, a defendant must plead it with particularity (735 Ill. Comp. Practitioners need to also remember that if a party files an affirmative answer, the opposing party must file a reply, or the affirmative defenses will be deemed admitted. 1989). The judgment is affirmed in part and reversed in part, and the case is remanded for further proceedings. The Complaint fails to state a claim upon which relief may be granted. Affirmative defenses are reasons why the defendant should not be liable for the plaintiff’s injuries. 1-4. All persons, two years of age and older, must wear a face covering. The “State-of-the-Art” defense must be pled by the defendant as an affirmative defense. So, … 1. 735 ILCS 5/2-602. Fla. R. Civ. . Rodriguez v. Cho (2015) 236 Cal. Any objections/responses to the affirmative defenses must be pled with specificity. Birthday: The FBI must obtain the concurrence of the U.S. Attorney's Office with regard to all material aspects of their use by the JLEA. Davis v. Sun Oil Co., 8. the relevant precedent in the district, had allowed a succinctly pled affirmative defense to stand. So, … And so, lawyers tasked with drafting an answer will often consult a “checklist” to ensure that all relevant affirmative defenses are sufficiently pleaded. Inc. vs. Nakashima (1991) 231 Cal.App.3d 367, 384. R. Civ. AND "damages" AND "injuries" AND "relief" Both terms must appear in document. No. P. 1.110(e). “While the burden of proving coverage is on the insured, it is incumbent on the insurer to prove that an exclusion to coverage is applicable.”. 2013 Bowes, Ott, Strassburger, JJ.) The City of New York ("City") also answered on behalf of Defendant ECB and pled four affirmative defenses, including a claim of lien priority, as well as a counterclaim and crossclaim. Affirmative Defenses. No. The Wszolas could not have imagined that their motion would be denied. P. 8(b), (c). 38See Podkowicz v. Slowineski, supra, 44 N.J. Super. C. Reply: Neill T. Nwoha, Esq. Then there's the requirement in Florida Administrative Code Rule 60Q-6.113(2)(h) that the misrepresentation defense "and any affirmative defense," must be raised with specificity in the pretrial stipulation. New Matter. Proc., § 431.30(g).) In order to state an affirmative defense, the answer must set forth facts "as carefully and with as much detail as the facts which constitute the cause of action and are alleged in the complaint." If the defendant’s actions were only slightly negligent, it may prove an effective defense. Such claims typically arise when the defendant’s lawyer fails to inform their client about the “collateral” consequences of their guilty plea. There are over 100 potential affirmative defenses.

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