Affirmative defenses

1. Fraud
2. Statute of Limitations
3. Statute of Frauds
4. Release
5. Payment
6. Illegality
7. Former Recovery
8. Discharge in Bankruptcy
9. Other matters by way of confession and avoidance
10. Estoppel

1. The court has no jurisdiction over the person of the defending party
2. Venue is improperly laid
3. Plaintiff has no legal capacity to sue
4. Pleading states no cause of action
5. The condition precedent for filing has not been complied with

Compulsory counterclaim / permissive counter claim

(a) Are the issues of fact and law raised by the claim and the counterclaim largely the same?

(b) Would res judicata bar a subsequent suit on defendants' claims, absent the compulsory counterclaim
rule?

(c) Will substantially the same evidence support or refute plaintiffs' claim as well as the defendants'
counterclaim? and

(d) Is there any logical relation between the claim and the counterclaim

Section 3. Signature and address. – (a) Every pleading [and other written submissions to the court] must
be signed by the party or counsel representing him or her.

(b) The signature of counsel constitutes a certificate by him or her that he or she has read the pleading
and document; that to the best of his or her knowledge, information, and belief formed after an inquiry
reasonable under the circumstances:

(1) It is not being presented for any improper purpose, such as to harass, cause unnecessary delay, or
needlessly increase the cost of litigation;

(2) The claims, defenses, and other legal contentions are warranted by existing law or jurisprudence, or
by a non-frivolous argument for extending, modifying, or reversing existing jurisprudence;

(3) The factual contentions have evidentiary support or, if specifically so identified, will likely have
evidentiary support after availment of the modes of discovery under these [R]ules; and
 (4) The denials of factual contentions are warranted on the evidence or, if specifically so identified, are
reasonably based on belief or a lack of information.