FIRST DEFENSE
The complaint fails to state a claim against defendant upon which relief can be granted.
SECOND DEFENSE
Defendant admits the allegation contained in Paragraphs one and four of the complaint; alleges that he is without knowledge or information sufficient to form a belief as to the truths of the allegations contained in Paragraph two of the complaint; and denies each and every other allegation contained in the complaint.
THIRD DEFENSE
The right of action set forth in the complaint did not accrue within three years next before the commencement of this action.
COUNTERCLAIM
(Here set forth any claim as a counterclaim in the manner in which a claim is pleaded in a complaint.)
CROSS-CLAIM AGAINST DEFENDANT M. N.
(Here set forth a claim constituting a cross-claim against defendant M. N. in the manner in which a claim is pleaded in the complaint.)
Del. R. Civ. P. Super. Ct. Form 20