Affirmative Defenses by Grace Reed, Eric Reed

• 
• 
• 
• 
• 
• 

                        

						    Preview
                        
                        
                          Filing # 97467673 E-Filed 10/17/2019 03:58:53 PM

IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT
IN AND FOR COLLIER COUNTY, FLORIDA
CIVIL ACTION
ELEVATE EXTERIORS, INC.,

Plaintiff,
v. CASE NO. 19-CA-001868

GRACE REED and ERIC REED,

Defendants,

DEFENDANTS’ AMENDED AFFIRMATIVE DEFENSES
COMES NOW Defendants, GRACE REED and ERIC REED, (“Defendants”), by and
through their undersigned counsel and file their amended affirmative defenses pursuant to the Order
entered September 27, 2019 and state as follows:
AFFIRMATIVE DEFENSES
Defendants state their affirmative defenses to Plaintiffs Complaint (“Complaint”). By so
doing, Defendants do not adopt the burden of proof when such burden properly rests with Plaintiff
under applicable law.
First Affirmative Defense
Plaintiff has failed to set forth a claim for breach of contract as it did not perform as
agreed and the work Plaintiff claims it completed did not pass inspection by Collier County;
accordingly Plaintiff’s claim for breach of…