1. The plaintiff observes as well that the defendants' Answer also contains a large number of bad faith denials of facts known to them to be true, denials of knowledge of things known by their counsel, and numerous unintelligible partial denials that leave the reader guessing at what is left to be denied.

As discovery, rather than moving to strike, is the remedy for those aspects of the defendants' Answer, he will seek discovery--once the stay on discovery has been lifted--to find out what the defendants mean by their demurrer of an answer, and then will seek to recover the cost incurred by having to prove those facts as a sanction.

2. The defendants' Second Affirmative Defense, at page 9 of their Answer, states, in full:

Plaintiff's claims are barred under the doctrines of estoppel, laches, waiver, res judicata and/or unclean hands."

3. "(b) Fraud, Mistake, Duress, Undue Influence, Condition of the Mind. In all averments of fraud, mistake, duress or undue influence, the circumstances constituting fraud, mistake, duress or undue influence shall be stated with particularity. Malice, intent, knowledge, and other condition of mind of a person may be averred generally."

4. How can both apply? They weren't pled in the alternative!