Averments in a pleading to which a responsive pleading is required, other than those as to amount of damage, are admitted when not denied in the responsive pleading. Rule 8(a), unlike Federal Rule 8(a)(1), does not contain requirement that the claim set forth "a short and plain statement of the grounds upon which the court's jurisdiction depends." (6) Effect of Failing to Deny. Moreover, all affirmative defense elements must be pled. Note to Subdivision (e). However, they are not the same. 5. ), Notes of Advisory Committee on Rules1937. Fla. R. Civ. <>/ExtGState<>/ProcSet[/PDF/Text/ImageB/ImageC/ImageI] >>/MediaBox[ 0 0 612 792] /Contents 4 0 R/Group<>/Tabs/S/StructParents 0>> %PDF-1.4 % Many litigants are familiar with the well-settled rule that an affirmative defensewill bewaived if it is not included in a CPLR 3211(a) motion to dismiss or in the answer (see CPLR 3211[e]). An affirmative defense does not concern itself with the elements of the cause of action at all; it concedes them. Under 11 U.S.C. III. In equity, however, an answer could state as many defenses, in the alternative, regardless of consistency, as the defendant deemed essential to his defense. c. 231, 30 could reasonably be interpreted to deal with the matter of capacity of a party for other purposes, these latter instances are so rare that they do not warrant specific mention in Rule 8(b). 735 ILCS 5/2-602. Averments in a pleading to which no responsive pleading is required or permitted shall be taken as denied or avoided. 30, 2007, eff. Five days later, RHCT informed ASl that the second location was not acceptable, primarily because the owner of the site did not give RHCT permission to store the Equipment at that location. PDF United States District Court District of Connecticut Guides, Books Business, Senate , ](m7v$Eg~^e&,>Ce(vK)4cw8KUw\%,3Li)}/Ys[ZBY]fY8|9`T P5lI +PGU?%F\. Day, Combined The Reporters agree with Professor Moore, 2A Moore, Federal Practice, 8.27[2], that the mere raising of the defense should not shift any burden to the defendant; they recommend this position unequivocally. (1)Each averment of a pleading shall be simple, concise, and direct. 29, 143 N.E. Rule 8(e)(2) changes practice with respect to defenses. 1 0 obj startxref A helpful tip is to remember that an affirmative defense cannot stand on its own if the complaint is dismissed. Council, Schedules, Calendars, endobj Rule 11 applies by its own terms. Schedules, Order of 8 0 obj 0000000556 00000 n (b) Defenses; form of denials. A party that lacks knowledge or information sufficient to form a belief about the truth of an allegation must so state, and the statement has the effect of a denial. 1999). Mass.gov is a registered service mark of the Commonwealth of Massachusetts. 0000001482 00000 n If a recovery of money for unliquidated damages in an amount greater than $50,000 is demanded, the pleading shall state merely that recovery of reasonable damages in an amount greater than $50,000 is sought. Please limit your input to 500 characters. See Clark, Code Pleading (1928), pp. Like a claim for relief, an affirmative defense must plead sufficient ultimate facts to survive a motion to strike. Under prior law, a pleading had to state precise facts rather than general conclusions,Becker v. Calnan, 313 Mass. This rule supersedes the methods of pleading prescribed in U.S.C., Title 19, 508 (Persons making seizures pleading general issue and providing special matter); U.S.C., Title 35, [former] 40d (Providing under general issue, upon notice, that a statement in application for an extended patent is not true), 69 [now 282] (Pleading and proof in actions for infringement) and similar statutes. 416, 425, 426, 159 N.E.2d 417, 419 (1959). . ,#R({H8d3v+|"}R The former Rule 8(b) and 8(e) cross-references to Rule 11 are deleted as redundant. CPLR 3018 (b) contains the following, non-exhaustive list of defenses that should be affirmatively pleaded in an answer: Arbitration and award Collateral Estoppel Culpable conduct of the. <>>> As stated in Chapter 2 "The Legal System in the United States", a criminal defendant will be acquitted if the prosecution cannot prove every element of the offense beyond a reasonable doubt. 7\. Rule 8(e)(1) merely emphasizes the fact that under Rule 8 no technical forms of pleading are required. Finally, a movant must be cognizant of the "within 20 days after service of the answer or reply" timeline imposed by Rule 1.140(b). Freiberger Haber LLP is a national law firm located in Melville Long Island & New York City. Who Represents 0000002593 00000 n Library, House Committee No substantive change is intended. . Hawes v. Ryder, 100 Mass. When there is any good faith doubt on the matter, the allegation will be denied by the defendant, and properly so. :n/Xg;Zz+9wA JFMP7-Yr[r`uMpu6Mkz)mc8czq3"J,|nr 0000000910 00000 n affirmative defense | Wex | US Law | LII / Legal Information Institute The defense was not pleaded. A lock icon ( If a recovery of money for unliquidated damages is demanded in an amount less than $50,000, the amount shall be stated. In the occasional case where the plaintiff does not have valid claim, a trial can still be avoided by the use of discovery and either a motion to dismiss for failure to state a claim upon which relief can be granted (Rule 12(b)(6)), or a motion for summary judgment (Rule 56). Dr. Martin Luther King Jr. In effect, an affirmative defense says, Yes, I did it, but I had a [lawful] reason. Id. Gatt v. Keyes Corp., 446 So. A party shall state in short and plain terms any defenses to each claim asserted and shall admit or deny the averments upon which the adverse party relies. Compare the English practice, English Rules Under the Judicature Act (The Annual Practice, 1937) O. Code 815.2. Judicial Council of California Civil Jury Instructions (2022 edition) Download PDF. If you need assistance, please contact the Trial Court Law Libraries. That part of former G.L. [Motion to] Strike . . . Your Affirmative Defense Is Out. - LinkedIn Counsel, Research & Fiscal Analysis, Senate P. 1.110(d); St. Paul Mercury Ins. <> P. 1.140 (f). The concept of a defendant being allowed to plead the statute of limitations as a defense is derived from the common law. 9. The change here is consistent with the broad purposes of unification. 464 (1884);Vigoda v. Barton, 338 Mass. 12 0 obj While Rule 8(a)(1) allows the pleading of conclusions,Rule 12(e)(motion for more definite statement) andRule 12(f)(motion to strike) cure the only real impropriety of the pleading of conclusions, namely, that the pleading is too vague to form a responsive pleading. Accordingly, RHCT has waived the illegality defense. And so, in the Courts view, the plaintiff could hardly contend it would be prejudiced or surprised by the defense. A tell-tale sign of a fake affirmative defense is one that asserts a generic legal principle such as "Rewriting of the Agreement by the Court is Barred." A savvy litigatorshould keep arobust checklist of affirmative defenses,which should includethe affirmative defenses listed in CPLR 3018(b), as well as the grounds for dismissal under CPLR 3211(a). Affirmative Defenses under the 2020 Rules of Civil Procedure 0000004535 00000 n ", "Second, the declaration shall state concisely and with substantial certainty the substantive facts necessary to constitute the cause of action.". *"KFK>1,@B4EHb(HGIRUHew:,^rJuHWOzSK3g6F6U@kYdttm6jnaQE.FuzsF-TP]Q)_Co`4ZpQJZWVpnAT^Jb&xV{ %PDF-1.6 % Additionally, it should be attacked based upon whether it sufficiently pleads the affirmative defense with the requisite certainty to survive a motion to strike. - A party shall state in short and plain terms his defenses to each claim asserted and shall admit or deny the averments upon which the adverse party relies. Rule 1.140(b) permits motions to strike insufficient legal defenses. List, Bill Dec. 15, 2016). (3) General and Specific Denials. 17 0 obj Upcoming Meetings, Broadcast TV Co., 2021 WL 2291101, at *3 (D. Conn. June 4, 2021) ("As these are facts that . The defendant opposed the motion, asserting apartial-constructive-eviction defense,and cross-moved for leave to amend its answer to assert two counterclaims against the plaintiff. Averments in a pleading to which no responsive pleading is required or permitted shall be taken as denied or avoided. (1937) 275; 2 N.D.Comp.Laws Ann. Moreover, all affirmative defense elements must be pled. 19, r.r. This article focuses on Rule 1.140(b) and how to strike insufficiently pled and fake affirmative defenses. If a party mistakenly designates a defense as a counterclaim, or a counterclaim as a defense, the court must, if justice requires, treat the pleading as though it were correctly designated, and may impose terms for doing so. To comport with prior law, Rule 8(b) also includes a provision that an allegation in any pleading that a place is a public way shall be taken as admitted unless a party specifically denies such allegation. Clerk, Fiscal h,j0_e)%d!BK!-!,@C|32[PHP8gyS3 d.F^K\R\{MM. Affirmative Defenses | Texas Law Help 28, 2010, eff. 3d 264, 267 (Fla. 3d DCA 2012). Red Hook Container Terminal, LLC (RHCT) provided stevedoring services at a marine container terminal located in Brooklyn, New York (the Brooklyn Terminal). The change is epitomized by the statutory terms "substantive facts" and "cause of action." denied, 364 U.S. 895, 81 S.Ct. The degree of certainty required in a pleading is that the pleader must set forth the facts in such manner as to reasonably inform his adversary of what is proposed to be proved in order to prove the latter with a fair opportunity to meet it and prepare his evidence. Id. RHCT has not shown that it previously raised a concern about trespassing or illegality. <> Currently before the Court is Plaintiffs' Rule 12(f) motion to strike Defendants' second affirmative defense, which invokes discretionary act immunity under Cal. Behind Rule 8(b) lies the simple principle that a defendant's answer should unmistakably indicate to both Court and plaintiff precisely which aspects of the complaint are admitted, and which are controverted. Search, Statutes Hawes v. Ryder, The difference between the philosophy of Rule 8 and that of former Massachusetts pleading practice emerges vividly from a comparison of the "substantial justice" construction requirement of Rule 8(f) with G.L. 2d 49, 51 (Fla. 1990). Any mitigating circumstances to reduce the amount of damage shall be affirmatively pleaded. <<46F35B8151BFF6428C703D4C7CE8A790>]/Prev 41333>> (1933), 10472, 10491. Want more tips on New York practice and procedure? & Status, Current Session However, a pleader who intends to controvert all its averments may do so by general denial subject to the obligations set forth in Rule 11. RHCT claimed that by delivering the Equipment to the locations identified by ASI, it would have required RHCT to trespass or otherwise violate the law. T 5. Tropical Exterminators, Inc. v. Murray, 171 So. (1937) ch. <]>> Initially, a movant must determine whether the affirmative defense at issue legally qualifies as an affirmative defense or is simply gobbledygook masquerading as one. ASI asserted many claims against RHCT, including one for breach of contract. After the defendant interposed ananswer and cross-claims, the plaintiffmoved for summary judgment. Each separate cause of action upon which a separate recovery . A pleading that states a claim for relief must contain: (1) a short and plain statement of the grounds for the courts jurisdiction, unless the court already has jurisdiction and the claim needs no new jurisdictional support; (2) a short and plain statement of the claim showing that the pleader is entitled to relief; and. endobj This rule is, in part, [former] Equity Rule 30 (AnswerContentsCounterclaim), with the matter on denials largely from the Connecticut practice. Indeed, a defense will be stricken if it is insufficient as a matter of law. 4. Moreover, it is necessary to allege all the elements of an affirmative defense. Rock-Ola Mfg. See Note to Rule 1, supra. 365. Such an "affirmative defense" will very likely be no affirmative defense at all when viewed against the causes of action in the case at bar. O4jJGMBd_p]}^6Aa}[Rwv14q h0p +r9mTNJ`J> *X H y0[.\1)_} 0)7l5 H A provision of like import is of frequent occurrence in the codes. An allegation in any pleading that a place is a public way shall be taken as admitted unless a party specifically denies such allegation. bGlY%Ep MN Court Rules - Minnesota For the second sentence see [former] Equity Rule 31 (ReplyWhen RequiredWhen Cause at Issue). Services, Legislators If you would like to continue helping us improve Mass.gov, join our user panel to test new features for the site. Unlike prior procedure, Rule 8(a)(2) permits the pleader to seek in his claim both legal and equitable relief, either together or in the alternative. A defendant who pleads duress admits commission of the alleged criminal act but denies any criminal intent. SeeG.L. This is of course the natural corollary of the notice pleading theory behind the Rules generally and Rule 8(a) in particular. What's an Affirmative Defense? Id. In a unanimous ruling, the First Department reversed the motion courts holding that Red Hook waived its affirmative defense of illegality. endobj Farrell Fritz, P.C. Massachusetts rules of court and standing orders, Rule 4.3: Arrest: Supplementary process: Ne exeat, Rule 5: Service and filing of pleadings and other papers, Rule 15: Amended and supplemental pleadings, Rule 16: Pre-trial procedure: Formulating issues, Rule 17: Parties plaintiff and defendant: Capacity, Rule 19: Joinder of persons needed for just adjudication, Rule 21: Misjoinder and non-joinder of parties, Rule 23.1: Derivative actions by shareholders, Rule 23.2: Actions relating to unincorporated associations, Rule 26: General provisions governing discovery, Rule 27: Depositions before action or pending appeal, Rule 28: Persons before whom depositions may be taken, Rule 29: Stipulations regarding discovery procedure, Rule 30: Depositions upon oral examination, Rule 31: Depositions of witnesses upon written questions, Rule 32: Use of depositions in court proceedings, Rule 34: Producing documents, electronically stored information, and tangible t, Rule 35: Physical and mental examination of persons, Rule 37: Failure to make discovery: Sanctions, Rule 40: Assignment of cases for trial: Continuances, Rule 48: Number of jurors - Majority verdict, Rule 49: Special verdicts and interrogatories, Rule 50: Motion for a directed verdict and for judgment notwithstanding the ver, Rule 55.1: Special requirements for defaults and default judgments for certain , Rule 59: New trials: Amendment of judgments, Rule 62: Stay of proceedings to enforce a judgment, Rule 65.1: Security: Proceedings against security provider, Rule 65.2: Redelivery of goods or chattels, Rule 65.3: Proceedings for civil contempt, Rule 70: Judgment for specific acts: Vesting title, Rule 71: Process in behalf of and against persons not parties, Rule 79: Books and records kept by the clerk and entries therein, Rule 80: Stenographic report or transcript, Rule 82: Jurisdiction and venue unaffected. CPLR 3018 (b) lists the defenses commonly asserted . In responding to a pleading, a party must affirmatively state any avoidance or affirmative defense, including: accord and satisfaction; arbitration and award; assumption of risk; contributory negligence; duress; estoppel; failure of consideration; fraud; illegality; For the reasons that follow, the motion will be granted. 0000006665 00000 n The Motion Court granted ASIs motion with regard to the breach of contract claim. endobj However, a litigant should not depend on judicial discretion to raise a defense on the hope that the defensewill be introduced into the case without having been affirmativelypleaded. CPLR 3018 is clear: an affirmative defense must be pleaded to be preserved. A pleader who intends in good faith to deny only a part or to qualify an averment shall specify so much of it as is true and material and shall deny only the remainder. Brighams Cafe Inc. v. Price Bros. Co., 334 Mass. It is a breach of counsel's obligation to the court to file an answer creating issues that counsel does not affirmatively believe have a basis.". If it is an affirmative defense, then it should be attacked based upon deficiencies in its pleading; whether it makes or assumes an admission to the facts alleged in the plaintiff's complaint and, notwithstanding, raises new matter excusing the defendant's purportedly illicit conduct. hb```b``d`a`da@ +slx!s5?`e. "[F]amiliar illustrations" of such defenses include those based on a "statute of limitations, absence of proper parties, res judicata, usury, a A properly pled affirmative defense includes ultimate facts sufficient to provide notice of the proof the defendant intends to rely upon to defeat the plaintiffs claim. S. Fla. Coastal Elec., Inc. v. Treasure on the Bay II Condo Assn, 89 So. An affirmative defense may be insufficient either as a matter of law or as a matter of pleading. When a party has mistakenly designated a defense as a counterclaim or a counterclaim as a defense, the court on terms, if justice so requires, shall treat the pleading as if there had been a proper designation. c. 231, 7 (Sixth) (providing that a plaintiff shall not be required to elect between causes of action where the remedies are inconsistent). Please remove any contact information or personal data from your feedback. endobj It does not, however, seek to regulate the substantive question of distribution of the burden of producing evidence or of persuading the trier of fact. c. 231, 7 Fifth, Sixth. conclusively establish its affirmative defense. What affirmative defenses must be pled? See G.L. Top-requested sites to log in to services provided by the state. List of Affirmative Defenses: - 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 - unavoidable accident - economic loss rule 0 0000000016 00000 n 0000001079 00000 n Subdivision (c)(1). and convincing evidence: 1. Asserting an Equitable Defense or Counterclaim? 2, 1987, eff. It is also important in shaping the judgment, seeRule 54(c)and in determining whether a jury trial is warranted. Affirmative Defense - Waiver. endstream endobj 437 0 obj <>stream Note to Subdivision (a). All pleadings shall be so construed as to do substantial justice. (1) In General. for the Day, Supplemental Asserting legally insufficient affirmative defenses comes at a cost, which at the very least will require you to expend litigation resources at a motion hearing noticed by the government to strike your affirmative defenses under Fla. R. Civ. Appeals had held that "[a]n affirmative defense is subject to the same pleading requirements as is the complaint." Woodfield v. Bowman, 193 F.3d 354, 362 (5th Cir. Civil Procedure Rule 8: General rules of pleading | Mass.gov RHCT counterclaimed for, among other things, its post-Lease storage fees for the Equipment. An affirmative defense is not a separate cause of action. Your analysis of the contract claim leads you to conclude that the contract is void because performance would require your client to violate certain labor laws. x\[o6~`V^Hiwmg}p";Va[$OBRr$N .4yxxw.u]|uv*6WqmYWoo{M2Ko7r2 $"xF:wO,|7Cw|i(wc6}[(/&NOw" EUbXawD*2HVQ&]T?Cb%r+ up,I[p BDYMe9_Dty>Kw,MFixk Fiscal Analysis, Legislative (3) Since one of the major purposes of Rule 8(b) is elimination of the general denial except in those rare cases where the pleader intends in good faith to controvert all the averments of the preceding pleading, particularization of specific situations requiring a specific denial tends to weaken the emphasis on this goal. Besides a waste of printer ink, insufficiently pled and fake affirmative defenses bog down the litigation and may permit an opposing party to engage in an otherwise impermissible fishing expedition disguised as permissible discovery to supposedly bolster a valid affirmative defense. at 52. When two or more statements are made in the alternative and one of them if made independently would be sufficient, the pleading is not made insufficient by the insufficiency of one or more of the alternative statements. c. 106, 3-307, reach the same result. Use this button to show and access all levels. (2) DenialsResponding to the Substance. An official website of the Commonwealth of Massachusetts, This page, Civil Procedure Rule 8: General rules of pleading, is. 2d 136, 138 (Fla. 4th DCA 1988). (Mason, 1927) 9266; N.Y.C.P.A. (2) Alternative Statements of a Claim or Defense. i It Seems You Can't Waive The Affirmative Defense Of Illegality After All 452, 456, 45 N.E.2d 388, 391 (1942). Deletion of former Rule 8(e)(2)s whether based on legal, equitable, or maritime grounds reflects the parallel deletions in Rule 1 and elsewhere. In responding to a pleading, a party must affirmatively state any avoidance or affirmative defense, including: (2) Mistaken Designation. Discovery Sanctions Alert: Failure to Include Withheld Items on Privilege Log Lands Party in Hot Water, Commercial Division Grants $1 Million Punitive-Damage Award for Diversion of Companys IP in Breach of Fiduciary Duty, Commercial Division Says Not Every Storm Triggers Force Majeure, LIMITS ON MOTIONS IN LIMINE: A NEW PROPOSAL TO AMEND COMMERCIAL DIVISION RULE 27, Infancy or other disability of the defendant. Pleadings must be construed so as to do justice. In pleading to a preceding pleading, a party shall set forth affirmatively any matter constituting an avoidance or affirmative defense including but not limited to the following: accord and satisfaction, arbitration and award, assumption of risk, contributory negligence, discharge in bankruptcy, duress, estoppel, failure of a condition Committee, Side by Side (4) Denying Part of an Allegation. Offices, and Commissions, Legislative and Legislative Business, House The Suffolk County Commercial Division (Emerson, J.) Auditor, Revisor Discharge in bankruptcy. In equity practice, a bill would be objectionable as multifarious if separate and distinct wrongs, each dependent upon its own facts, were joined in a bill. The only Massachusetts statutes dealing with this point, G.L. endobj Former recovery. Motion to Strike Affirmative Defenses - Party: Plaintiff LUCAS, JACQUES September 04, 2014. If instead of denying the plaintiff's assertions (or in addition to denying them, see Rule 8(e)(2)), the defendant wishes only to controvert their effect, he may do so by the modern equivalent of the old "confession and avoidance." SeeRock-Ola Mfg. The court did explain, however, that "[t]he reason why affirmative defenses under Rule 8(c) must be pled in the answer is to give the opposing party notice of the defense and a chance to develop evidence and offer arguments to controvert the defense." Id. Procedure & Practice for the Commercial Division Litigator. ?CAK:3SzlP:kJw. Under Rule 8(c) such disputation is called an affirmative defense; the Rule requires the defendant to set forth any and all affirmative defenses, including, as under prior law, "any facts which would entitle him in equity to be absolutely and unconditionally relieved against the plaintiff's claim or cause of action or against a judgment . But simply listing affirmative defenses is not enough. Note to Subdivision (d). If, however, a litigant fails to raise a particular defense in its answer or CPLR 3211(a) motion, the defendant may still have hope of raising the defense at the summary judgment stage, so long as the defense does not take the adverse party by surprise. G.L. ASI sought the return of the Equipment and recovery of compensatory and punitive damages. by Topic (Index), Session See S.J.C. c. 231, 85Aimposes upon the defendant-registered owner of an automobile involved in a collision the responsibility for setting up as an affirmative defense in his answer a denial that the automobile was being operated by a person for whose conduct the defendant was legally responsible. Rules, Educational % matter in the form of an affirmative defense. Merger is now successfully accomplished. Rule 1.110 states: "In pleading to a preceding pleading a party shall set forth affirmatively accord and satisfaction, arbitration and award, assumption of risk, contributory negligence, discharge in bankruptcy, duress, estoppel, failure of consideration, fraud, illegality, injury by fellow . Ins. Only three responses are proper: (1) an admission of the allegations of the paragraph; (2) a denial of those allegations; or (3) a disclaimer of knowledge or information sufficient to form a belief as to the truth of those allegations. Schedule, Audio (c) Affirmative Defenses. Reference Library, Office of the 13 0 obj Laws, and Rules, Keyword <> endobj (5) Lacking Knowledge or Information. However, Justice Emersonpermitted the defense, reiterating the principle that [a]n unpleaded defense may be invoked to defeat a summary-judgment motion, or to serve as the basis for an affirmative grant of such relief, in the absence of surprise or prejudice, provided that the opposing party has a full opportunity to respond thereto.. When expanded it provides a list of search options that will switch the search inputs to match the current selection. In your jurisdiction, the affirmative defense of fraud has five elements, (1) a false representation; (2) about a material fact; (3) made with knowledge of its untruth; (4) with intent to deceive; and (5) defendant relied on the representation. Select Accept to consent or Reject to decline non-essential cookies for this use. stream PB |\MF,S5^*;eKS/\itQ3)+u+e27!,vqYv;+{?S[l|.Q7mG|\{54Ye@ggv,EB ^r`a u}x-{) SWcs`#.Yt0f1PQSdm1sR[RzXwsK6~] Sw"fVpQ"]dSFpQ9NOB? Daily, Combined Media A somewhat related point concerns the possible working of an estoppel on the defendant who pleads, first, a denial of all operative allegations, then an affirmative defense. If either of these are absent, then a plaintiff/counter-plaintiff should strongly consider moving to strike the deficient affirmative defense. startxref Present, Legislative Professionals, PLLC, 2019 NY Slip Op 51588(U) (Sup Ct, Suffolk County Oct. 8, 2019). Notes of Advisory Committee on Rules1966 Amendment. Definition of Denial or Failure of Proof and Affirmative Defenses. 121 (1931). c. 231, 22, which permitted "the general issue" in real and mixed actions. 6 0 obj 1720. 524(a)(1) and (2) a discharge voids a judgment to the extent that it determines a personal liability of the debtor with respect to a discharged debt. Therefore, the failure to plead an affirmative defense could have significant consequences. (1) In General. 13, 18; and to the practice in the States. Id. A plaintiff is as much entitled to be aware of the ground upon which it is claimed he should not recover as is a defendant to be apprised of the basis of the plaintiffs claim. Id. 18 13 c. 208, 10. 2. Rule Status, State ASI based its motion on RHCTs failure to return the Equipment as provided for in the Lease.

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