DO NOT PLEAD A LAUNDRY LIST. The vast majority of these affirmative defenses will not apply to any given case–they are intended as a brainstorming tool, and certainly should not be included in full. Rule 11 requires that you have a good faith basis for believing an affirmative defense actually applies before pleading it, and in discovery you will likely need to respond to an interrogatory identifying all factual bases for every affirmative defense you plead.
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List of Affirmative Defenses (Partial):
– failure to state a claim upon which relief may be granted (almost always use)
– statutory defenses prerequisites (these will vary depending on the claims)
– preemption by federal or other law
– accord and satisfaction
– arbitration and award
– assumption of risk
– economic loss rule
– contributory or comparative negligence
– intervening cause
– supervening cause
– claimants own conduct, or by the conduct…

Here’s a tip for all you tax payers out there: Donating money to help reduce the federal debt counts as one of the more unusual charitable tax deductions.

Deutsche Bank: helped its customers maintain more than 300 secretive offshore companies and trusts through its Singapore branch

Largest German bank’s Singapore unit helped birth companies and trusts in tax havens

Germany’s largest financial institution, Deutsche Bank, helped its customers maintain more than 300 secretive offshore companies and trusts through its Singapore branch, an investigation by German newspaper Sueddeutsche Zeitung, German public broadcaster NDR and the International Consortium of Investigative Journalists has found.

More than 100 customer consultants at Deutsche Bank Singapore helped create or manage 309 offshore entities for its customers in the British Virgin Islands and other tax havens, according to secret records obtained by the news organizations.

Most of the companies carry fantasy names like “Thrilling Returns Incorporated,” “Amazing Opportunity Limited” or “Market Dollar Group Limited.” Public sources don’t show any business activities for most of these companies.