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Case 2:16 .v-04347-JJT Document 54 Filed1 4/19 Page 18 of 24 SECOND AFFIRMATIVE DEFENSE (Eault or Negligence) AS AND FOR A SECOND, SEPARATE AND AFFIRMATIVE DEFENSE to said Complaint this answering Defendant alleges that the Plaintiffs were totally at fault or negligent in and about the matters referred to in its Complaint and that such fault or egligence and carelessness on the part of the Plaintiffs amounted to One Hundred Percent THIRD AFFIRMATIVE DEFENSE (Unclean Hands) AS AND FOR A THIRD, SEPARATE AND AFFIRMATIVE DEFENSE to said Petition, this answering Defendant alleges that the Plaintiffs are not entitled to relief becausq Plaintiffs acted and reacted in the matters alleged in its Complaint with unclean hands. More specifically by their actions encouraged illegal immigration knowing that the majority of the illegal immigrants’ claims for political asylum are false and Plaintiffs know that the majority of these illegal immigrants will not appear for a Court hearing and remain in the Arizona community or other parts of the State illegally at taxpayer expense. Plaintiffs also are aware that many of the illegal immigrants have ctiminal records and encourage them to remain in the United States in violation of U.S. Statutes to promote a radical leftist agenda and open border policy. FOURTH AFFIRMATIVE DEFENSE (Statute of Limitations) AS AND FOR A FOURTH, SEPARATE AND AFFIRMATIVE DEFENSE to said ‘Complaint, this answering Defendant raises the statute of limitations to all of the causes of action in the Complaint. 18 ANSWER Case 2:19-cv-04347-JJT Document 54 Filed 11/24/19 Page 20 of 24 TENTH AFFIRMATIVE DEFENSE (Violation of U.S. Statutes) AS AND FOR A TENTH, SEPARATE AND AFFIRMATIVE DEFENSE to said Complaint, this answering Defendant maintains that the Plaintiffs have aided and abetted. illegal aliens that entered the United States, unlawfully, under false claims of “political oppression” knowing that these claims were false. The Plaintiffs also knew that most of the illegal aliens requesting asylum never appear for the court hearing and remain in the U.S. ELEVENTH AFFIRMATIVE DEFENSE (Public / Limited Public Figures) AS AND FOR AN ELEVENTH AFFIRMATIVE DEFENSE to said Complaint, this answering Defendant maintains that the Plaintiffs are Public Figures and/or Limited Public Figures and by their actions voluntarily participate in a public controversy for the purpose o' influencing the outcome of the public controversy of illegal immigration. Their actions are newsworthy. ‘TWELFTH AFFIRMATIVE DEFENSE (Truth and/or opinion) AS AND FOR A TWELFTH, SEPARATE AND AFFIRMATIVE DEFENSE to said Complaint, this answering Defendant maintains that any comments made by this answering defendant, if any, were the truth and/or based on opinion. 20 ANSWER

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