Based on this lack of information or belief, defendant denies the remaining allegations. Both parties to this complaint have appeared in the other action. Defendant requests that the Court take judicial notice of the other action. This complaint is barred by the fact that plaintiff lacks standing to bring an action. Plaintiff is not a party to the transaction and is not connected to the transaction.
Defendant owes no duty to respond to plaintiff's allegations regarding the transaction.
The complaint is barred by plaintiff's failure to state a cause of action against defendant. The complaint is barred in whole or in part by laches. The complaint is barred in whole or in part by plaintiff's unclean hands. Any amount sought to be recovered in this action is barred in whole or in part by the amount owing from plaintiff to defendant. That the Court order further reasonable relief.