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IN THE COURT OF COMMON PLEAS
CUYAHOGA COUNTY
SCOTT M. SANTORA, et al
Plaintiffs		 CASE NO.
367149  
vs. JUDGE JANET BURNSIDE
PUTLTE HOMES OF OHIO
CORPORATION
Defendant		 ANSWER OF DEFENDANT,
PULTE HOMES OF OHIO
CORPORATION

     For its Answer to Plaintiff s Complaint, Defendant Pulte Homes of Ohio Corporation, states as follows:

  1. This Defendant admits the allegations contained in Paragraphs 1, 2, 3 and 4 of Plaintiffs' Complaint.
  2. Answering Paragraph 5 of Plaintiffs' Complaint, Defendant admits that Exhibit A is part of the Purchase Agreement between Plaintiffs and Defendant.
  3. Defendant denies the allegations of Paragraphs 6 through 97 of Plaintiffs' Complaint.

FIRST AFFIRMATIVE DEFENSE

Plaintiffs' Complaint is barred in its entirety by the applicable statutes of limitations.

SECOND AFFIRMATIVE DEFENSE

Plaintiffs' claim is barred in whole or in part by the statute of frauds.
RJV\VJS\248017.

THIRD AFFIRMATIVE DEFENSE

Plaintiffs' claim is barred by the doctrine of laches.

FOURTH AFFIRMATIVE DEFENSE

Plaintiffs' Complaint is barred by the express limitations of their contract with Defendant.

FIFTH AFFIRMATIVE DEFENSE

Plaintiffs' Complaint is barred in whole or in part by the doctrine of waiver.

SIXTH AFFIRMATIVE DEFENSE

Plaintiffs' Complaint is barred in whole or in part by an accord and satisfaction reached with

SEVENTH AFFIRMATIVE DEFENSE

Plaintiff, Scott Santora, has no standing to assert claims against Defendant. WHEREFORE, having fully answered, Defendant demands that Plaintiffs' Complaint against it be dismissed at Plaintiffs' cost.

Robert J. Valerian (00 1 5 3 3)
Kahn Kleinman Yanowitz & Amson Co., LPA
Attorney for Defendant
2600 Tower at Erieview
Cleveland, Ohio 44114-1824
(216) 696-3311

RJV\VJS\248017.1

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