Affirmative Defenses, etc.

For those following my case, I received the answer today. A lot of their answer was based on saying that I alleged legal conclusions which did not require a response. Probably standard, but I had not seen this before. There were also quite a few affirmative defenses, none of which I am really concerned about, but input can never hurt

1. The standard failure to state a claim defense.
2. Truth/Accuracy of Information (claims are barred because all information communicated to any third person regarding Plaintiff was true).
3. Indeminification (any purported damages allegedly suffered by Plaintiff are the results of the acts or omissions of third persons over whom defendant had neither control nor responsibility.
4. Laches
5. Contributory/Comparative Fault (damages were Plaintiff's fault at least in part and Plaintiff's negligence equaled or exceeded any negligence or wrongdoing by EX.)
6. Estoppel (any damages were directly a result of the conduct of Plaintiff.)
7. Statute of Limitations
8. The Unclean Hands Doctrine
9. Immunity (based on the qualified immunity of 15 U.S.C 1681h(e)
10 Preemption (State law claims are preempted by federal statute...this one must be from a template they've used before because I didn't make any state law claims)
11. Qualified priviledge (EX's actions were subject to qualified privilege).

They ask for dismissal, cost of the suit and attorney fees incurred and other relief as the Court may deem just, etc.

I guess that covers just about everything...lol.


L