Defendants deny categorically in paragraph 8, 9, 10, 11 and 12 of the Plaintiff’s/Edmond and
Barbara Shivak complaint
AFFIRMATIVE DEFENSE
1). Plaintiff/Edmond and Barbara Shivak is not entitled to any relief sought against Defendants
2). Defendants are not liable to the Plaintiff/Edmond and Barbara Shivak in this case
3). Mr. Edmond G. & Barbara Shivak is liable to the defendants for endangered defendants and his family by maintaining building/rental property with electrical malfunctions
4). That the Defendants asserts the Plaintiff/Edmond and Barbara Shivak willfully in bad faith, created an unsafe dwelling/housing that includes, but not limited to: