does plaintiff have to respond to affirmative defenses

I was under the impression I fairly cited theories of law for each. Generally what we see on affirmative defenses is the laundry list and they move to strike them because it's so obvious they don't apply. Sounds like you got mixed up with some bad attorneys, I would not let that go. . Give him a kiss, you have the best judge in FLA for a credit card case, he has no clue. Thank you for the feedback and case reference, I really appreciate it. Names have been changed to protect the guilty. 226.5b(f). Kidder & Co. v. Turner (Fla. 1958), "A motion to strike an affirmative defense will be denied if the defense is sufficient as a matter of law, or if it fairly presents a question of law or fact which the court ought to hear." 7 What is plaintiffs reply to defendant msen, Inc.? An affirmative defense must be raised (named) by the defendant in response to the plaintiff's liability claim. I learned another odd thing at Court today. Defendant, Unknown Spouse Of Shirley M Chism 2d 1233, 1234 (Fla. 4th DCA 1999). Plaintiffs complaint alleges a Breach of Line of Credit. Breach of Line of Credit is not a legal cause of action and therefore Plaintiff has failed to state a claim upon which relief can be granted. This website uses cookies to improve your experience while you navigate through the website. STATE EX REL. We also use third-party cookies that help us analyze and understand how you use this website. does plaintiff have to respond to affirmative defenses. This is a violation of the United States Fair Credit Reporting Act [15 U.S.C. To say I was shocked and upset would be an understatement. They are moving to strike because they fail under "any theory of law" is basically what they are arguing. This isn't the first time this Plaintiff took this approach - it was their claim against my first Answer in their Motion for Summary Judgement - they were wrong then (and lost) and I think they're wrong now, but need to know how to properly go about disputing their Motion to Strike my Affirmative Defenses. REGIONAL AIRPORT AUTH., 593 So. Mr. Smith was never deposed and the proximate cause of not being deposed was solely due to Plaintiff's delays. We will email you Can you offer an example. Defendants affirmative defense does not meet Statue guidelines for affirmative defenses, do I have to respond to such affirmative defenses in there answer? This is also the reason laches follows violation of attorney client privilege and the accompanying explanation. "All actions in which it appears on the face of the record that no activity by filing of pleadings, order of court, or otherwise has occurred for a period of 1 year shall be dismissed by the court on its own motion or on the motion of any interested person . try clicking the minimize button instead. In other words, what can you not present now that you could have presented if they had not delayed. 2d 1219, 1222 - Fla: Dist. While the rules might be similar, I have no idea, Twiqubl and the federal court case cities are irrelevant for this lawsuit. 13 (When pleadings deemed denied and put in issue). For example, a plaintiff asserts a claim for money lent, and the defendant asserts the statute of limitations as an affirmative defense. eden prairie community center open swim. In a minority of states, the burden is placed on the prosecution, who must prove sanity beyond a reasonable doubt. You give a definition, an action by the Plaintiff, but you leave out the important element of prejudice. Court of Appeals, 1st Dist. MOTION FOR LEAVE TO AMEND - DEFENDANT S- ANSWER AND AFFIRMATIVE DEFENSES TO PLAINTIFF S COMPLAINT February 25, 2021. A reply is sometimes required to an affirmative defense in the answer. bridal shower wording sample for guests not invited to wedding; . These cookies will be stored in your browser only with your consent. is there quicksand in hawaii. In civil lawsuits, affirmative defenses include the statute of limitations, the statute of frauds, waiver, and other . Unconscionability. Your subscription has successfully been upgraded. All four times were cancelled by the Plaintiff. represented by Any And All Unknown Parties Claiming By Through Un, On the date of XXXX Mr. Smith passed away. Kitchen v. Kitchen, 404 So. Does a Plaintiff have to respond to an affirmative defense stated by a Defendant in there answer? (You need to read the whole rule.). by clicking the Inbox on the top right hand corner. The cookie is set by GDPR cookie consent to record the user consent for the cookies in the category "Functional". The factual elements to the laches defense are as follows. Plaintiff: improperly combined Defendant(s) individual transactions to create debits larger than originally submitted triggering returned transactions and improper overdraft fees; submitted transactions for processing in a non sequential order to trigger improper overdraft fees; charged Defendant(s) non-contractual and unauthorized fees; reversed properly made transactions by Defendant in order to create false overdrafts in Defendant(s) accounts; and manufactured a series of improper transactions to create the false appearance of default by Defendant(s). However, I added it for a strategic reason, as well as a factual element that tells an important part of the story and my defense. You will lose the information in your envelope, WELLS FARGO BANK NA vs ANY AND ALL UNKNOWN PARTIES CLAIMING BY THROUGH UN et al, Any And All Unknown Parties Claiming By Through Un, Clerk Of The Court Sarasota County Florida, Tempest Recovery Services Inc A Corporation As Ser, Unknown Tenant #1 In Possession Of The Property, Unknown Tenant #2 In Possession Of The Property. I'll just pull the last one. This law firm was not representing the Plaintiff in my case, but it turns out they represented them in other similar cases and never revealed this to me, or told me there was a conflict of interest. Because an affirmative defense requires an assertion of facts beyond those claimed by the plaintiff, generally the party who offers an affirmative defense bears the burden of proof. The Plaintiff now unfairly benefits by delaying this action unreasonably as Mr. Smith, a critical witness for the Plaintiff, is no longer available to testify. 1. does plaintiff have to respond to affirmative defenses. I never got to make the argument as the Plaintiff's attorneys were apprised of my intentions by the attorneys I was consulting with, and beat me to the punch with a Motion for Summary Judgement. 2d 1185, 1189 - Fla: Dist. This created the odd situation where they had to re-serve the lawsuit against my company. Therefore, they likely do not plan on filing a response since it have been 5 months. This is a state lawsuit, so Florida rules apply. You can't argue a standard that applies in federal court for a state lawsuit complaint. > Detroit Legal News. See T.C. Don't object to the motion, let it be granted absent objection. First, there must have been a delay that was inexcusable, and, second, that delay must have prejudiced the defendant. I've been fighting a lawsuit in Florida since 2009. However, in retrospect I could have been clearer on how the issues intersected. This is called judgment in default (i.e of a defence). In their prosecution of this case, Plaintiff and its attorneys also engaged Law Firm #2 at a time when the Defendant was concurrently consulting with that very same law firm for its Defense. Yes this does help - thanks!. Stephens v. Dichtenmueller, 216 So.2d 448 (Fla. 1968. What is the punishment for cheating money? 1:07CV165, 2009 WL 1118816, "Motions to strike affirmative defenses should not be granted unless, as a matter of law, the defense cannot succeed under any circumstances.'" Attorney For The Plaintiff, Clerk Of The Court Sarasota County Florida You referenced the fact that your attorney had represented the Plaintiff in other cases. However, you assert latches and state correctly what latches is, and then you make a statement that is just a conclusion with no supporting facts. I also have this for their pulling my credit in violation of the FCRA: Defendant(s) rely on Slantis v. Capozzi & Assocs., P.C., U.S. Dist. . Court of Appeals, 1st Dist. It also should be noted that early in the case I filed a Motion to Dismiss and the Clerk misplaced my Motion, inserting it in another case file. Attached to my Affirmative Defenses were case filings and significant detail from two class action cases that completely corroborate my defense. My case mirrors the consumer class actions, but this would be for a new class action for business customers. An answer is a formal statement, in writing, of your defense to the lawsuit. You might be right, but it's not a fact. Chism, Jason L et al. Here is an example. The fact that the Plaintiff failed to act for 15 months is material and prejudiced my defense. You then file a brief from hell and lay out the timeline like you did in your post only a thousand times more detailed. Posted on . does plaintiff have to respond to affirmative defenses . 183, 664A.2d 1136 (1995), this court stated: The defendant misunderstands the nature of a laches defense. I have found the following Court Order denying a Motion to Strike Affirmative Defenses in Florida with a handful of similarities. I don't really know about yours as some are Florida specific. As for proving their actions, I'll let their own Affidavit do the talking. UJ is the retention of an unjust benefit retained at the expense of another. Necessary cookies are absolutely essential for the website to function properly. The above states you have to prove that the pending suit has to do with the same thing for which the attorney previously represented you. The insured filed an insurance coverage dispute and the insurer relied on an exclusion in the policy. If we (and I hope the Court) looks at my Affirmative Defenses as a whole, I hope it paints a picture for what transpired here. Once 10 months passed, I contacted the law firm I referenced in my Affirmative Defense (law firm #2) and said on the phone and in writing, "I would like to file a Motion to Dismiss for Lack of Prosecution and have you review my case for a possible counterclaim and/or class action." They are one day late, I try to non suit them, I don't sit here and wait for them to wake up. Pertaining to Plaintiffs inaction, Plaintiff was silent in this case for 15 months, filing no Motion or calling any Hearing from March 17, 2010 to June 20, 2011. The original rulings relied on Federal Rules, which state: Rule 8(a), which is applicable to complaints, requires a "short and plaint statement of the claim," while 8( requires defendants to "state in short and plain terms its defenses. Coltfan, can you expand a bit on what you mean when you (and the Plaintiff's Motion) say that my Affirmative Defenses fails under "any theory of law." These action can be further corroborated by the aforementioned Federal Class Action lawsuits: ____________________________________________________________ . Which is an example of an affirmative defense? Or you can say it is true but give more information and reasons to defend your actions or explain the situation. By briefly stating the dissolved corp. issue into my Answer and Affirmative Defenses, I feel I've properly advised the Court and Plaintiff that I can proceed Pro Se. 2. It does not store any personal data. Obviously nothing was happening, but "knowingly"? Attached exhibits like emails, letters, your personal notes from conversations (yes, if you look hard enough I bet you find them), etc. Time to turn this into a three ring circus. Some additional background a checking account was attached to the alleged account in dispute. That is if you can even muster enough arguments to rise to the level they must respond because an affirmative defense is yours to prove by a preprodence of the evidence, and a conclusion does not even get close to that burden. Thanks for your reply Coltfan, you have an awesome fighting spirit. Bozzi v. Bozzi, 177 Conn. 232, 239, 413 A.2d 834 (1979). Who is the president of International Court? 5) Buy some great scotch and get ready to duke it out. Plaintiff's attorney then filed a Motion for Summary Judgement after 15 months of inaction, heading off my Motion to Dismiss for Lack of Prosecution. 1) "Unreasonable and unexplained length of time." How far away should your wheels be from the curb when parallel parking? There is no evidence on record that Mr. Lawrence F. Meyer is properly licensed to practice law in California courts. They don't sound incredibly strong, but they are nowhere near like most we see. 1953) (lawyer's obligation of absolute loyalty to his or her client's interest does not end with the retainer; the lawyer is enjoined for all time, except when released by law, from disclosing matters revealed by reason of the confidential relationship with the lawyer's client). Plaintiff took $5 Billion in U.S. Federal Government Bailout Money, and simply didn't need its customers anymore. And even then, it's not an automatic dismissal. . It is not a coincidence that Defendant(s) consultation with attorneys at Law Firm #2 ended on July 6, 2011, and the Motion for Summary Judgment was filed on June 20, 2011, after a 15 month period of inactivity. You need to annihilate the attorney that screwed you over. What are some examples of affirmative defenses? Defendant(s) maintain that Equitable Estoppel or Estoppel in Pais bar Plaintiffs claims as a result of both Plaintiffs inaction, and aforementioned improper banking activity and violations of Florida Bar Rules of Ethics. Affirmative defenses are not pleadings to which a party is to respond, even if a demand is made for such a response, the Michigan Court of Appeals ruled. The Judge also told me I can proceed Pro Se, as long as my pleadings were signed as an individual. Under the Florida Rules of Civil Procedure, a party is not required to reply to the opposing party's affirmative defenses merely to deny them. I know it pissed you off and it left you in lingo but how have you been prejudiced where you can't defend yourself. Instead of proving you didn't break the contract, you fully accept your role in breaking the contract. BANKERS LIFE AND CASUALTY CO. v. Village of North Palm Beach, 138 So. One day I received an email from one of this law firm's senior partners (small law firm, 5 attorneys) that they can't help me further and the attorney I was speaking to the most was no longer with the firm. How many lines of symmetry does a star have? Publicado por em 12 de junho de 2022. does plaintiff have to respond to affirmative defenses Under the Florida Rules of Civil Procedure, a party is not required to reply to the opposing party's affirmative defenses merely to deny them. 1) File a Memorandum in Opposition to Plaintiff's Motion to Strike (does anyone know how much time I have for this?). My short opinion, none of these apply. Plaintiff improperly combined Defendant(s) individual transactions to create debits larger than originally intended triggering returned transactions and improper overdraft fees; submitted transactions for processing in a non sequential order to trigger improper overdraft fees; charged Defendant(s) non-contractual and unauthorized fees; reversed properly made transactions by Defendant in order to create false overdrafts in Defendant(s) accounts; and manufactured a series of improper transactions to create the false appearance of default by Defendant(s), thereby breaching multiple Agreements with the Defendant(s). Plaintiff is not entitled to attorneys fees as its attorneys violated ethical rules of the Florida Bar and professional standards. The corporation was dissolved a few years ago, and the Plaintiff's attorneys told me they already knew this. Strangely, they are still trying to serve the corporate entity, and I'm still not certain why, or how that plays into the mechanics of the suit since the corp no longer exists. Unclean hands is an equitable defense. What does answer affirmative defenses mean? Accessing Verdicts requires a change to your plan. 802.02 Annotation The effect of the court striking a defendant's answer is that the defendant failed to deny the plaintiff's allegations and, therefore, is deemed to have admitted them. They did no after waiting 65 days. "Matters labeled affirmative defenses should be stricken only where it is completely certain they have been mistitled." Defendant(s) hereby submit this Answer and Affirmative Defenses to Plaintiffs Amended Complaint. 503 (D. Del. So my Affirmative Defenses are briefly stated defenses to their brief complaint, unsupported by complete evidence or any proof of a breach or proof of default. The corporation is still dissolved and still has no assets. Read court documents, court records online and search Trellis.law comprehensive legal database for any state court documents. Self-defense, entrapment, insanity, necessity, and respondeat superior are some examples of affirmative defenses. The first referenced Class Action which verifies Defendants Affirmative Defenses of Plaintiffs improperly rigging its customers checking account transactions is _________________________________________ and combined in the Federal Multi District Class Action Case No.__________________. These cookies ensure basic functionalities and security features of the website, anonymously. Most of these come from well established Florida Affirmative Defenses (look 'em up). But you have to prove your attorney committed the violation. If this isn't prejudicial to my case, I cant imagine what is. Bowen, Robert, The cookie is set by the GDPR Cookie Consent plugin and is used to store whether or not user has consented to the use of cookies. will be able to access it on trellis. Copyright 2023 (c) Cordus Partners, LLC RULE 4-1.6 CONFIDENTIALITY OF INFORMATION, (a) Consent Required to Reveal Information. Plaintiff improperly combined Defendant(s) individual transactions to create debits larger than originally intended triggering returned transactions and improper overdraft fees; submitted transactions for processing in a non sequential order to trigger improper overdraft fees; charged Defendant(s) non-contractual and unauthorized fees; reversed properly made transactions by Defendant in order to create false overdrafts in Defendant(s) accounts; and manufactured a series of improper transactions to create the false appearance of default by Defendant(s), making it impossible for Defendant(s) to perform under the purported Agreement(s) with the Plaintiff. The affirmative defense is a justification for the defendant having committed the accused crime. I could really use the assistance of fellow board members on how to approach a Plaintiff's Motion to Strike my Affirmative Defenses in a rather large lawsuit. In other jurisdictions no reply is necessary to an affirmative defense in the answer, but a reply may be ordered by the court. Eventually, the Clerk located my Motion to Dismiss, and I can prove it was lost due to a Clerk's error. Kenn Air Corp. v. GAINESVILLE-ALACHUA CTY. A fact you're probably right about. Further, Plaintiff pulled Defendants personal credit on December 6, 2011. 2) "Circumstances prejudicial to the adverse party." This is about the only time you can get counsel dismissed from the opposing side. . Especially in Florida, which is anti consumer. Equitable Estoppel. Your credits were successfully purchased. You're correct and just stated what Laches is. The partial Agreement relied upon by the Plaintiff is unconscionable and therefore unenforceable. "Twombly and Iqbal require only minimal facts establishing plausibility, a standard this court presumes most litigants would apply when conducting the abbreviated factual investigation necessary before raising affirmative defenses in any event," the court said. Defendant relies upon the Affirmative Defense of Estoppel by Laches which precludes a party from being awarded a judgment or other such relief when that party knowingly or unreasonably delayed pursuit of its claims, or failed to claim or enforce a legal right at the proper time. Thanks for the replies Coltfan and BV80, this is very helpful to me in fleshing out a response. Plaintiff hired Law Firm #1 for representation in this lawsuit. . The law firm I was consulting with had their senior partner file a sworn Affidavit to be reimbursed for legal fees, and the Plaintiff then used it as part of their attempted Motion for Summary Judgement. That rule puts all of the burden on the clerk to dismiss the case. 1989)). I tried to be quite specific in my Affirmative Defenses, and I'm posting them here for review. That is going to create all kinds of headaches. "A lawyer is bound by rule 4-1.6 to honor such a request by a current client and by rule 4-1.9 as to a former client. We have notified your account executive who will contact you shortly. A reply is sometimes required to an affirmative defense in the answer.In other jurisdictions no reply is necessary to an affirmative defense in the answer, but a reply may be ordered by the court. The plaintiff believes that there are facts outside the pleadings that demonstrate that the defendant is estopped from asserting this defense due to its actions or unclean hands. What you are basically arguing is that they sued somebody or something that was/is judgement proof. Browse related questions 3 attorney answers does plaintiff have to respond to affirmative defenseswho would you save on a sinking ship activity. These actions interfered with Defendant(s) finances, business and normal banking activity and can be further verified in two Federal Class Action lawsuits pending against the Plaintiff. Affirmative Defenses must usually be responded to within 20 days. The mere lapse of time does not constitute laches . Plaintiff hired (Law Firm #1) for representation in this lawsuit. (a) Claim for Relief. That argument actually works more in their favor than yours. Plaintiffs complaint fails to state a claim upon which relief can be granted. by The U.S. District Court, Middle District of Florida, adopted new Local Rules, effective on February 1, 2021. These cookies track visitors across websites and collect information to provide customized ads. Your recipients will receive an email with this envelope shortly and 265, 268 (S.D.N.Y. And, my Affirmative Defenses are recognized in Florida. . Do you have to respond to affirmative defenses in federal court? The response must be filed within 10 days after service of the motion unless the court shortens or extends the time. Functional cookies help to perform certain functionalities like sharing the content of the website on social media platforms, collect feedbacks, and other third-party features. I'm trying to be discreet about some of the details while I focus on the law and strategy here. 3) Bar Complaints against several attorneys. I don't believe a Judge wants to hear a Plaintiff argue "Your Honor, we feel we can file lawsuits and sit on them for over a year without action or explanation." does plaintiff have to respond to affirmative defenses. However, I thought I fairly pointed out an instance as to how latches specifically applied in my case. My Affirmative Defense ends with "During this time, Defendant ______________ was dissolved, and has no remaining financial assets." Your argument fails for at least two reasons. You can do that. Defenses may either be negative or affirmative. Definition of an affirmative defense Defenses are set forth by a defendant in his answer to the complaint. During this time, Defendant __________________ was dissolved, and has no remaining financial assets. Laches consists of two elements. Barge Line Co., No. These cookies help provide information on metrics the number of visitors, bounce rate, traffic source, etc. Reed v. Fain, 145 So. If I use the Plaintiff's argument, that my Affirmative Defense pleading is legally insufficient because it lacks in specificity, and therefore should be stricken, then by the same standard, their lawsuit lacks specificity and therefore should also be stricken. The Court held: When a party lies about the issue of damages, dismissal is an appropriate sanction.. I think I have a strong argument for dismissal as a sanction. Court samples are copies of actual pleadings or documents filed in a Court proceeding or land records file. A plaintiff does not respond to affirmative defenses in a separate pleading. 8 Which is an example of an affirmative defense? You've got the delay element nailed, but the prejudice or your "damages" are not pleaded in your affirmative defense allegation. Coltfan, in my Fourteenth Affirmative Defense, I did state how latches would apply here. Re lack of prosecution, I'm not certain why I thought it was 10 months, but great that you confirmed the time frame for me so I don't quote it inaccurately. Defendant, Galarza, William(04/19/2017) During the hearing, I also made issue of the fact that the Plaintiff improperly identified my company (they spelled the name improperly, which effected their lien rights). . The law firm representing this bank recognized enough of a problem that the attorney of record on the case for 2 years is no longer on the case (after I read her the riot act by phone). Theatre Corp. v. Warner Bros. Pictures, 113 F. Supp. Estoppel by Laches. Your content views addon has successfully been added. Again, I never breached any alleged agreements here, the Plaintiff did, and I can prove it. Further, the Court held: The Third Circuit overwhelmingly supported the proposition that obtaining a consumer report in preparation for litigation is not a legitimate business need under the FCRA.. a party shows good cause in writing at least 5 days before the hearing on the motion why the action should remain pending. Even in their Motion to Strike, they only claimed 1 was not a recognized Affirmative Defense. Their only "contact" was pulling my credit in violation of the FCRA. You have a procedural error on the clerk's part that they will argue caused you no prejudice. Does a defendant have to prove an affirmative defense? 2d 858 - Fla: Supreme Court 1961. You can file an answer to respond to the plaintiffs Complaint. Violation of Attorney Client Privilege. Do you need to reply to affirmative defenses? Its interesting that you all "latched on" to laches, because I don't think its the strongest of my Affirmative Defenses and intentionally stated last. Analytical cookies are used to understand how visitors interact with the website. How was the plaintiff unjustly enriched when you never paid him? You can say that what the plaintiff claims is not true. Defendant, Unknown Tenant #2 In Possession Of The Property That is, the FCC's NPRM provided ample ground to torpedo existing TCPA class actions brought for violations of the DNC rules by confirming these protections have not yet been granted by the FCC. While I am primarily focused on how to approach their Motion to Strike right now, I am also considering my own MSJ, and have this so far: Defendant(s) rely upon case reference Desimone v. Old Dominion Ins. . Powered by Invision Community. They are presented for illustration purposes only. Does a plaintiff have to respond to affirmative defenses? The facts and circumstances of these lawsuits which have been granted Class Action status and long since survived all Motions to Dismiss by Plaintiff corroborate Defendant(s) Affirmative defenses in the present case. Either that or file a new answer without all this junk. Although this was a foreclosure case, and not all of the Affirmative Defenses are the same, it has a good deal of case law to support my positions: http://www.msfraud.org/law/lounge/DeutschevMassey/orderdenying-plaintiffs-motion-strikedefendantsaffirmativedefensesdenyingmotiondismisscounterclaimsdenyingplaintiffsmotionstrike.pdf. When the insurer moved for summary judgment on the exclusion, the insured tried to argue waiver, that the insurer's conduct waived its right to this affirmative defense. Failure and Lack of Consideration A failure of consideration defense can be asserted when mutual promises are made in a contract, but after the contract's inception, a party's promised consideration does not adhere to the contract. I have to wonder what that's about. Ford v. Piper Aircraft Corp., 436 So. Therefore, any possible defense you might want the court to consider at trial should be in your Answer. We noticed that you're using an AdBlocker, PLAINTIFF'S RESPONSE TO AFFIRMATIVE DEFENSES. Bobbitt v. Victorian House, Inc., 532 F. Supp. .(Citations omitted; internal quotation marks omitted.) The blank space references my corporation, which was dissolved and has no remaining assets - perhaps I should have said "for the Plaintiff to file a claim against." The Judge has disqualified herself by her own motion without further explanation. I imagine they can object, but they haven't thus far, and the case is 2 years and 8 months old. 2d 378 - Fla: Dist. I don't think a Motion to Disqualify the attorneys or their law firms goes far enough. A good example would be a witness of yours died before trial or being deposed. An affirmative defense to a civil lawsuit or criminal charge is a fact or set of facts other than those alleged by the plaintiff or prosecutor which, if proven by the defendant, defeats or mitigates the legal consequences of the defendant's otherwise unlawful conduct. Plaintiff: improperly combined Defendant(s) individual transactions to create debits larger than originally submitted triggering returned transactions and improper overdraft fees; submitted transactions for processing in a non sequential order to trigger improper overdraft fees; charged Defendant(s) non-contractual and unauthorized fees; reversed See Campbell v. American Pioneer Savings Bank, 565 So.2d 417 (Fla. 4th DCA 1990); Ford v. Piper Aircraft Corp., 436 So.2d 305 (Fla. 5th DCA 1983), rev. Further, the facts, circumstances and evidence in each of these cases which in many ways mirror the present case, are of great relevance to these proceedings. P. 1.110 (e). (italics added). Determined1, Unjust Enrichment. . In fact, under Rule 1.110(e) affirmative defense are automatically deemed as denied in the absence of a reply.

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