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Write a short and plain statement identifying the defenses to the claims, using one or more of the following alternatives that apply. 1. A general denial of the entire complaint or plea of the general issue shall not be permitted.(b) Response After Demurrer, Plea or Motion. Affirmative defenses allow you to provide information to the court that is not stated in the plaintiff's complaint. An affirmative defense is a defense claiming that the plaintiff is not entitled to a judgment because other facts exist that create a lawful defense. A sample completed written response is available at the end of this Guide. Recently amended complaint and any answers thereto on cross-defendants who have not previously appeared. I have requested copies of additional documents and expect to produce them by. (date). The requested documents exist but I cannot produce them because. Even then, disagreement exists about the proper analysis for spo- liation tort claims and for sanctioning spoliation in ongoing litigation.16.