Sample answer to eviction complaint in California

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This sample answer to unlawful detainer (eviction) complaint for California is for use by a defendant who wants the court to consider their affirmative defenses. The sample contains 18 affirmative defenses including breach of habitability, breach of quiet enjoyment, retaliatory eviction, constructive eviction and more. The sample has been revised and updated as of January 27, 2018, is 16 pages and includes brief instructions, a verification and proof of service by mail. The author is a freelance paralegal who has worked in California and Federal litigation since 1995 and has used this sample for many years. Note that the author is NOT an attorney and no guarantee or warranty is provided.