List of Possible Affirmative Defenses ("If you don't raise, you might have waived"). As a tenth, separate, and affirmative defense to the unverified Complaint on file herein, these answering Defendants allege that its full performance of any agreement or act required of it, if there be such agreements or acts, fulfills all its duties and obligations to Plaintiff, if any there be, contractual, fiduciary, or other, and no other duty or obligation to Plaintiff remains on behalf of these answering Defendants. SUBJECT MATTER JURISDICTION . ), https://en.wikipedia.org/w/index.php?title=Interpleader&oldid=1086508887, Creative Commons Attribution-ShareAlike License 3.0, The same thing, debt, or duty must be the. 1836). In and for the County of Maricopa, ANSWER BY DEFENDANT [ENTITY] TO COMPLAINT IN INTERPLEADER. Phoenix, Subsequent development in England and Wales, Different types of interpleader in U.S. federal practice, sfn error: no target: CITEREFMaclennan1905 (, RSC Order 17 Rule 3 (4) and CCR Order 33 Rule 6 (4). Dist. Cir. Tribunals, Courts and Enforcement Act 2007, "An Historical and Critical Analysis of Interpleader", Prudential Insurance Company of America v. Tull, An Act to enable Courts of Law to give Relief against adverse Claims made upon Persons having no Interest in the Subject of such Claims, "Tribunals, Courts and Enforcement Act 2007", "The Tribunals, Courts and Enforcement Act 2007 (Commencement No. Inovlotska, 8 A.D.3d at 624-25; Birnbaum v. Marine Midland Bank, 96 A.D.2d 776 (1st Dept. In some jurisdictions, the res will earn interest at the legal rate until disbursed. However, you may want to contact an attorney for a full explanation of Affirmative Defenses and an analysis of whether a particular defense applies to your case . The ADA Americans with Disability Act, or Unruh Act violations or non-compliance claimed and modifications requested are not Readily Achievable and the building was build _______ before the enactment of the various ADA laws and regulations were enacted. of Corrections, 429 F.3d 276 (D.C. Cir. The interpleader states the facts of the case and requests that the . Learn more about the details of how an interpleader works, and about the pros and . Connect with me on LinkedIn. 1. Remember that real estate agents and brokers are regulated by the Florida Department of Business and Professional Regulation so they must follow some specific procedures in the event of a binder dispute. The defendant might not have any affirmative defenses. As a fifteenth, separate, and affirmative defense to the unverified Complaint on file herein, these answering Defendants allege that the unverified Complaint, and each and every cause of action therein, is barred by the Doctrine of Integration and the Parole Evidence Rule. AS AND FOR A SECOND AFFIRMATIVE DEFENSE: . dq4/K&!SNL"Qh*r]h. The money or other property in controversy is called the res (a Latin word meaning object or thing). As a third, separate, and affirmative defense to the unverified Complaint on file herein, these answering Defendants allege that they have incurred damages by reason of Plaintiffs conduct and that it has the right of offset of any amount of monies owed to Plaintiff by way of damages. 420 West Mariposa Road, Suite 200 Acknowledged that Plaintiffs so allege. Interpleader Actions in Florida are governed by Florida Rule of Civil Procedure 1.240, which is a rule promulgated by Floridas Supreme Court. M. Lamber is licensed in Arizona, Colorado, Illinois and New York only. See id. 7. District Attorney of N.Y. County v. The Republic of The Philippines, No. An affirmative defense is a reason that the plaintiff should lose even if all of the claims are true. Get free summaries of new opinions delivered to your inbox! 1335, 1397, and 2361. Because the prosecutor or plaintiff has the burden of proving his case, a defendant can use a negating defense to bring . As a thirteenth, separate, and affirmative defense to the unverified Complaint on file herein, these answering Defendants allege that Plaintiff did not reasonably rely upon any alleged misrepresentations or nondisclosures of material facts made by these answering Defendants; therefore, Plaintiff is barred from seeking any affirmative relief against these answering Defendants. Admitted. To initiate an interpleader action, the stakeholder must file a complaint alleging that it has no claim to the asset or property in dispute and does not know to which claimant the stake should be delivered. 4 0 obj In 1922 the United States Supreme Court in Liberty Oil Co. v. Condon Nat. Nogales, [any] matter constituting an avoidance or affirmative defense." 1983). In many cases, an interpleader action arises due to an individual receiving settlement funds meant for the payment of multiple bills. 656, 666 (S.D.N.Y. ;";(JCnMPu#(BHnY4&"(JQIA4yN ze^^3s>kyNt5-c*a9=EyhY;@-C$W2qHAUQbegk87l7e5+LJ3'sU "n[.r+mrk'V'f(d0lOGIc#yGrmv&A;V~cM+J,QYiE&BC" /JIwv1^H{4j$MB. 10. 4. 2 Story, Equity Jurispruedence 824 (1st ed. Defendant affirmatively alleges that it provided. In contrast, the equitable bill of interpleader required that: In 1831 Parliament passed the Interpleader Act 1831[7] that authorized a bill of interpleader to be brought in the common law courts (such as the Court of Common Pleas) by: Statutory interpleader was extended by Common Law Procedure Act 1860,[8] which allowed a defendant to interplead claimants even if the title of the claimants to the res have no common origin, but are adverse to and independent of one another. Las Vegas, Under federal law, there are two forms of interpleader: rule interpleader, under Federal Rule of Civil Procedure 22; and statutory interpleader, under 28 U.S.C. 11) Order 2014", "The Civil Procedure (Amendment) Rules 2014: Section 36", Practice Direction 83 - Writs and Warrants - General Provisions, Practice Direction 84 - Enforcement by taking control of goods, "The Taking Control of Goods Regulations 2013", "Federal Interpleader and Some Recent Cases", Commercial Union Insurance Co. v. U.S. 999 F.2d 581 (1993 DC Cir. Note the one affirmative defense for ADA lawsuits regarding Not Readily Achievable (as sort of Grand Father or Grand Fathered in ADA Defense) needs to be adjusted for each case where it might apply). 9. On June 13, 2014, SPV initiated a breach of contract action against Transamerica to recover the Policy proceeds in the United States District Court for the District of South Dakota (South Dakota Action). << /Length 5 0 R /Filter /FlateDecode >> For further information, see our blog post on Interpleader Actions. As a fifteenth, separate, and affirmative defense to the unverified Complaint on file herein, these answering Defendants allege that the unverified Complaint, and each and every cause of action therein, is barred by the Doctrine of Integration and the Parole Evidence Rule. Defendant affirmatively alleges that Plaintiff has failed to state a legal basis to discharge Plaintiffs insured from liability for [his/her] negligence or to restrain Defendants from initiating claims against Plaintiffs insured, and that any such relief should be denied. Category: Mississippi Collections - Interpleader - Equipment Damage State: Mississippi Control #: MS-60913 Instant Download Buy now Available formats: Word | Rich Text Free Preview Description Related Forms How to Guide AZ In an interpleader action, the party initiating the litigation, normally the plaintiff, is termed the stakeholder. Admitted. Interpleader is a civil procedure device that allows a plaintiff or a defendant to initiate a lawsuit in order to compel two or more other parties to litigate a dispute. is ready to bring into court or pay or depose of the subject matter of the action in such manner as the court directs. SPV-LS arose out of a dispute over proceeds of a stranger-originated life insurance policy (the Policy), which insured the life of Nancy Bergman (Nancy) for ten million dollars. If a defense is not raised by the pleadings, it may still be tried by the express or implied consent of the parties. *IMPORTANT - READ CAREFULLY: Past results do not guarantee, warrant, or predict future case outcomes. Such a dispute commonly arises from interpersonal friction among the policyholder's survivors. Interpleader had its origins as a civil procedure at common law, which was later adopted and expanded by the Court of Chancery in its equitable jurisprudence. An action under those statutes must be conducted under these rules. The complaint fails to state a claim upon which relief can be granted. Professionals at the Lamber Goodnow legal team are just a click or call away. One specific situation commonly seen in the reported cases is where the policyholder was allegedly murdered by a beneficiary (which would disqualify that beneficiary from receiving any proceeds).[2]. Affirmative Defense - The introduction of evidence into a trial that might cancel out the defendant's legal responsibility for the alleged act. Admitted. 60604, 775-386-6155 Defendant is without sufficient information to admit or deny the allegations contained in Paragraphs [] of the Complaint and, therefore, deny the same. Denver, 1991). 4. 16 TWENTY-FOURTH AFFIRMATIVE DEFENSE (No Punitive Damages) 159. When one person holds property that they do not own and multiple claimants to the property exist, an interpleader action is employed to determine the rightful owner of said property. P. 7(a) for a list of authorized pleadings, depending upon your forum. <> The stakeholder can file an interpleader action to deposit the assets into court to allow the competing claimants to litigate the ownership of the stake, thereby allowing the stakeholder to be discharged from further liabilities. The 2014 amendments have proved to be problematic, in that they now fail to cover a situation where: In February 2018, several High Court enforcement officers asked the Queen's Bench Division for directions as to how to proceed in such circumstances, and the Master ruled that the repeal of Rule 17 had the effect of reviving the equitable form of interpleader proceedings, as the 2007 Act did not expressly abolish the interpleader action itself, and "interpleader statutes are not at all to limit or affect the equitable jurisdiction of the court to entertain an interpleader suit or action."[21][22]. a third party has given notice that they believe they are entitled to the goods under Rule 85.4(1), a counter-notice is duly given by the creditor under Rule 85.4(3), but, the third party then fails to commence the application to the court which is required under Rule 85.5, and. IL Five Tips for a Successful Real Estate Closing, Five Key Provisions Every Landlord Needs in a Residential Lease, Real Estate Development, Sales and Leasing Industry Legal Blog. Freiberger Haber LLP is a national law firm located in Melville Long Island & New York City. Admitted. If the court finds the interpleader appropriate, the person filing the suit is dismissed from the case, the funds are deposited into the court registry, and the claimants to the funds litigate between themselves the issue of entitlement of the deposited monies. A good affirmative defense will weaken the plaintiff's case. 85016 . RULE 3: A civil action is commenced by filing a complaint with the court. In certain cases, the defendant can either deny that a criminal element(s) exists or simply sit back and wait for the prosecution to . R. consists of attorneys, including M. Lamber and G. Goodnow, who are directors and/or employees of Fennemore Craig, P.C. These 19 affirmative defenses published here are one section of what Nona filed on 3/8/21 to get the money that Red Rock stole and to get penalties and damages. 14 Civ. Co. v. Tashire, 386 U.S. 523, 530 (1967). Defendant [], through undersigned counsel, Answers the Complaint in Interpleader (Complaint), as follows: WHEREFORE, Defendant [] requests the following relief: DATED this ____ day of _____________, _____. [any] matter constituting an avoidance or affirmative defense." The stakeholder must also establish the possibility of multiple lawsuits. ., 523 P.2d 979 (Colo. 1974). Civil Lawsuit - Any lawsuit brought about in court in which one person says they have suffered a loss due to the actions of another person. You already receive all suggested Justia Opinion Summary Newsletters. Mar. - Noerr-Pennington defense (antitrust) (a Sherman Act defendant can raise the affirmative defense of right to petition for redress, even if they use that right to try to gain an anti-competitive advantage). 8. There are specific differences between Statutory Interpleader, and Rule Interpleader: In bankruptcy court interpleader under Federal Rules of Civil Procedure 22 may be maintained as an adversary proceeding under Federal Rules of Bankruptcy Procedure 7022. An interpleader action protects the holder of assets (such as a bank account, brokerage account or life insurance policy proceeds) and property when there is a dispute between two or more parties claiming ownership. See also 4 J. Moore et al., Moores Federal Practice 22.04[1] (3d ed. 890 (KPF) (S.D.N.Y. Given the competing claims to the funds, the holder can wait for the parties to resolve their dispute or file an interpleader action asking the court to decide who should get the funds being held. acquire the Defendant Answer To Complaint Affirmative Defenses And link that we meet the expense of here and check out the link. If a defense is not raised by the pleadings, it may still be tried by the express or implied consent of the parties. to pursue an interpleader action. 1335(b). Shamrock: plaintiff cannot remove, defendant cannot remove based on a federal affirmative defense or a federal stream The stakeholder must have incurred no independent liability to any claimant, i.e. Universal Citation: 12 OK Stat 12-2022 (2014) INTERPLEADER A. Arbitration and award. CA Civ Pro Code 386 (2017) (a) A defendant, against whom an action is pending upon a contract, or for specific personal property, may, at any time before answer, upon affidavit that a person not a party to the action makes against him, and without any collusion with him, a demand upon such contract, or for such property, upon notice to such . Defendant affirmatively alleges that Plaintiff has failed to state a legal basis to discharge Plaintiff's insured from liability for [his/her] negligence or to restrain Defendants from initiating claims against Plaintiff's insured, and that any such relief should be denied. (See e.g. Co. of N.Y. v. Ansel, 273 A.D.2d 421 (2d Dept. (Ohio Civ. 2005) 80203, 702-625-7777 In an interpleader action, a party who knows two or more other parties are making a claim on some asset controlled by the party can ask the court to decide who has what rights to the asset, deposit the asset into the custody of the court or a third party and remove itself from the litigation. 2017). $ vrM1iz,UEFx952D Persons having claims against the plaintiff may be joined as defendants and required to interplead when their claims are such that the plaintiff is or may be exposed to double or multiple liability. The firm is committed to the zealous representation of its clients and the effective use of their resources in litigation involving business and commercial disputes. This is sort of a grandfather or grandfathered in defense, but not exactly the same as there are many factors to consider. American Intern. An interpleader action is one of those remedies. Copyright 2008-2023 Jimerson Birr, P.A. INTERPLEADER 218 .01 Persons having claims against the plaintiff may be joined as defendants and required to interplead when their claims are such that the plaintiff is or may be exposed to double or multiple liability. If an insurer files a declaratory action but declines to include the third party claimant, then the declaratory action has left out a person who has a claim or interest that will be affected by the declaration. ; there is no separate law firm or business entity. 1332(a) or (c), and the value of the property in controversy must be at least $500. Affirmative Defenses Counterclaims Crossclaims Answer to Crossclaim/Reply to Counterclaim See state court rules or Fed. 2017) (internal citations omitted). 2023 by The Lamber-Goodnow Injury Law Team at Fennemore Craig, P.C.. All rights reserved. Definition of an affirmative defense. 2008) (Although sanctioned by statute, interpleader is fundamentally an equitable remedy.). After Mr. Smith pays the attorney and receives funds for pain and suffering, the remainder of the settlement totals $75,000. 4. See, e.g., Campbel, aka Skywalker, et al. 12. If bill was not sent to patient prior to settlement, then a smaller settlement results, and thus less for providers. The "Lamber Goodnow Injury Law Team at Fennemore Craig, P.C." As the vast majority of these affirmative defenses will not apply to any given case, ensure you don't just plead this entire laundry list - this list is intended as a brainstorming tool. The most important distinction involves the requirements for subject matter jurisdiction. Lamber Goodnow Personal Injury Counsel Center: A Resource for Attorneys. How a lawyer could help your business avoid a major ADA lawsuit, How being proactive about ADA compliance can protect companies. As a seventh, separate, and affirmative defense to the unverified Complaint on file herein, these answering Defendants allege that Plaintiffs actions constituted a full release by Plaintiff of any and all claims which he may have had against these answering Defendants. 300 E. 2nd Street 85621, 520-477-7777 Anderson's Ohio Civil Rules Practice with Forms is a desk reference that provides practicing attorneys and judges in Ohio with a manual to find quick and accurate answers to procedural questions under the Civil Rules. Law360, New York (October 18, 2012, 4:38 PM EDT) -- Interpleader actions allow a disinterested holder of property to deposit money or property with a court when there is a potential for a . [29] The procedures for a Statutory Interpleader action are governed by the Federal Rules of Civil Procedure. 13388 (CSH), 2008 WL 953619, at *7 (S.D.N.Y. As a fourth, separate, and affirmative defense to the unverified Complaint on file herein, these answering Defendants are informed and believe, and on such information and belief, allege that Plaintiff is engaged in conduct that constitutes waiver of his rights. For costs of suit incurred herein; and. The court concluded that there had been no action or inaction on the part of the plaintiff that could be interpreted to be a recognition of the fact that the defendants intended to claim attorneys' fees or a waiver of objection to their failure to plead such a claim. The applicant or interpleading party may join as a defendant in such action any other party against whom claims are made by one or more of the claimants or such other party may interplead by cross-complaint; provided, however, that such claims arise out of the same transaction or occurrence. Rule 8(c) requires that both defenses to liability and defenses that potentially mitigate damages must be set forth in the pleadings. Defendants deny the allegations of Paragraph 17 of the Complaint. . While the foregoing proceedings were taking place, Transamerica received competing claims to the Policy proceeds. [18] In addition, s. 65 of the 2007 Act declared: (1)This Chapter replaces the common law rules about the exercise of the powers which under it become powers to use the procedure in Schedule 12. The Duval County Property Fraud Alert System: Litigating Home Title Fraud. See Great Am. The successful claimant is entitled to the interest as well as the principal. No. Consider each of the below affirmative defenses--does it potentially apply in your case? 8(c) requires a party to "set forth affirmatively . B. Interpleader Action Under 28 U.S.C. 2d 355, 362 (S.D.N.Y. ,4~WNv"Qp&n:+7A8{uU[2[7CS'pvlzavGW3}qUCD-y;1#^k_::% 4Km&&-1$!NQK!gFA%r+bK,|TH0;#]ppB,e*8aLm/ 8 Fp"34/lcHU`N# {ekKLG r* CTRju\Q3:s -CO!>"# )*76s J6m&ob$&I^2=[,jwpS}#8EA. Interpleader 1369 - Multiparty, Multiform Jurisdiction (mass accident statute) . Ensure information regarding the bill is accurate within the interpleader. [17] This replaced the interpleader proceedings previously governed by the court rules by the procedure of "enforcement by taking control of goods" under newly passed regulations. On June 17, 2014, Transamerica answered the complaint by commencing a third-party interpleader action pursuant to 28 USC 1335 against Plaintiffs, Nachman as the Trusts trustee, Malka as the Trusts successor trustee, and Nancys Estate. An interpleader action protects the holder of assets (such as a bank account, brokerage account or life insurance policy proceeds) and property when there is a dispute between two or more parties claiming ownership. What Rights Do I Have As A Shareholder In A Private Company. Kentucky requires that a party affirmatively state the following affirmative defenses, if applicable, in its answer: Accord and satisfaction. Rule 22(b). Ignorance of the law is rarely a defense to liability, but if proven, ignorance that racial discrimination violates federal law may be a defense to punitive damages in Title VII cases. In New York, interpleader is governed by CPLR 1006. 300 S. 4th Street #1400 The Leading Law Firm In The Nation For ADA Legal Defense, On Behalf of The Karlin Law Firm LLP | Jun 29, 2012 | Real Estate Disputes |. c. 231, 85A imposes upon the defendant-registered owner of an automobile involved in a collision the responsibility for setting up as an affirmative defense in his answer a denial that the automobile was being operated by a person for whose conduct the defendant was legally responsible. The stakeholder may invoke Rule 22 as a plaintiff, or by counter-claiming in an action already started against him by one, or more claimants. . 2. As stated in Chapter 2 "The Legal System in the United States", a criminal defendant will be acquitted if the prosecution cannot prove every element of the offense beyond a reasonable doubt. Answer - 4 Section 1: Admissions and Denials A Guide to Resources in the Law Library SCOPE: Bibliographic resources relating to admissions and denials in an answer to a complaint. If bill was not sent to patient prior to interpleader, then provider may not receive any monies. 1096, approved Jan. 20, 1936, drafted by Zechariah Chafee which codified it in as United States Judicial Code 41(26), and established the modern statutory interpleader allowing suit to be brought by any person, firm, corporation, association or society having custody of money or property or insurance policy or instrument valued at $500 or more which there are two or more adverse claimant who are citizens of different states, whether or not the claims have common origins, identical, adverse or independent of each other, and allowed it to be an equitable defense in actions at law, Judicial Code 274b. TWENTY-THIRD AFFIRMATIVE DEFENSE (Actions of Others) 158. Assumption of risk. of Ed. An example of an interpleader involving health care providers. Instead, Plaintiffs merely alleged a claim to the stake itself. Citing Clearlake Shipping PTE Ltd. v. O.W. The claimants are given the right to litigate their claims and will be bound by the decision of the court. Co., Ltd., No. AZ List your defenses. What follows is for discussion purposes only for review and consideration by and for liciensed Calfornia Defense lawyers, and should not be used in any particular matter or case. These procedure are outlined generally by Florida Realtors and include seeking an Escrow Disbursement Order, Arbitration, Mediation or Interpleader. For that reason, especially when the disputed funds are small like in residential real estate transactions, it may be in the best interest of even the legally right claimant to settle a dispute and accept a reduced amount before the interpleader action is filed. Contributory negligence. Lets talk about your legal issues. affirmative defense. Red Rock ignored the statute governing the distribution of the proceeds of the HOA sale in 2014 & also refused requests to distribute in 2014 & 2016 and in civil actions in 2017, 2019 . The rest of the grounds under the old provisions of the Motion to Dismiss are now grounds for affirmative defenses (Section 5(b), Rule 6). The relief sought by Plaintiffs under Count II of the Complaint for Interpleader must be governed in accordance with the fiduciary duties and obligations imposed by the Court SUPERIOR COURT FOR THE STATE OF CALIFORNIA, FOR THE COUNTY OF_____________________ (e.g. In many cases, an interpleader action arises due to an individual receiving settlement funds meant for the payment of multiple bills. An interpleader action is an equitable proceeding brought by a third party to have a court determine the ownership rights of multiple claimants to the same asset or property that is held by that third party. SK6F7ETKn ~vC;,pr_\,Wy~m/\%)*5bIx 5. As the vast majority of these affirmative defenses will not apply to any given case, ensure you don't just plead this entire laundry list - this list is intended as a. Tagged with: Commercial Litigation, Interpleader. Pl & Pr. v. Acuff-Rose Music, Inc., 510 U.S. 569, 590 (1994). - ignorance of the law. Conversely, a negating defense involves attacking one or more elements of the prosecutor's or plaintiff's case. (in an ADA Defense Answer . - All Rights Reserved, Community Advocacy & Social Responsibility. The Supreme Court of the United States ruled in New York Life v. Dunlevy 241 U.S. 518, that for a claimant to be bound by an interpleader that party must be served process in a way that obtains personal jurisdiction. The key is that the claim[ ] for relief . In other pleadings, however, it is sufficient to state the name of the first party on each side with an appropriate indication of other parties. Defendant admits the allegations contained in Paragraphs [] of the Complaint. {Facsimile: }, In the Superior Court of the state of Arizona Admitted. The defendant in a declaratory suit can seek affirmative relief and sue on the basis of any cause of action that may be appropriate in a . Procedures are in effect for claims where:[19]. Statutory interpleader, by contrast, requires only minimal diversity that is, diversity of citizenship between two or more claimants, without regard to the circumstance that other rival claimants may be co-citizens. State Farm Fire & Cas. If the court grants the interpleader, the stakeholder is dismissed from the action. An interpleader action, therefore, enables the stakeholder to turn the dispute over to a court. Accordingly, while pleadings may be amended to add additional affirmative defenses, it is essential that all defenses to be raised at trial are pleaded before trial (ideally, at least a week prior to the deadline to serve written discovery in a case). The Uniform Commercial Code 7-603 adopted in all 50 of the states of the United States provides that a bailee when more than one person claims title to or possession of the goods under document of title (warehouse receipt or bill of lading) may bring an interpleader as an original action or as a defense to a suit for nondelivery. An interpleader proceeding has two stages. This rule supplements and does not limit the joinder of parties allowed by Rule 20. [24] The policy must have a value of at least $500 claimed were claimed or may be claimed by adverse claimants; which is less than the amount in controversy of $3,000 in Judicial Code 48(1) then required for general diversity jurisdiction and two or more of the beneficiaries must live in different states. See Noerr-Pennington Doctrine (2009), ABA Section of Antitrust Law, at p.107. An interpleader action originates when the plaintiff holds property on behalf of another, but does not know to whom the property should be transferred. Statutory Interpleader governed by 28U.S.C. Rule 22.02 provides for deposit with the court of any property or amount involved as to which the party seeking interpleader admits liability. Often times the buyers earnest money binder or deposit is being held by a third party escrow agent. Rule 22 is known as rule interpleader. Upon learning this information, FLS attempted to exercise its remedies under the Sale Agreement (e.g., rescind the agreement or proceed with the purchase at a reduced price). 28. See Penn Mutual's Answer, Affirmative Defenses and Interpleader, Exhibit J (identifying the discussion date as August 4, 2009). Whether you are drafting claims, or respond-ing to claims asserted in another pleading, before you begin, always check In 1926 it was repealed and replaced by, 44Stat. The information contained in the forms on this website cannot and must be relied on for the purposes of filing legal documents or otherwise pursuing a claim. To establish this claim, the plaintiff must prove all of the following: . In the summons and complaint, the title of the action must include the names of all parties.
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