Date: July 9th, 2012 8:39 PM
Author: maroon contagious lettuce theater stage
Motions to Dismiss filed before the answer will be your DOWNFALL when there is
Documentary defense (that is dispositive of suit. e.g. contract or deed)
Other action pending between the parties
Want of capacity
Non-joinder of a necessary party
Failure to state a claim on which relief can be granted
Affirmative defense consisting of delicious SPARERIBS
Lack of Subj Matter Jdx
Lack of Personal Jdx
Delicious SPARERIBS:
Statute of Frauds
Payment of a debt
Arbitration
Res Judicata
Estoppel (Collateral)
Release
Infancy or other disability
Bankruptcy
Statute of Limitations
(http://www.autoadmit.com/thread.php?thread_id=1990061&forum_id=2#21050193)