ROMAN, SAMMY vs. ABRAMS, LUIS

Under the law, it is Plaintiff’s burden to prove most of the issues raised in the

affirmative defenses set forth below. The designation of the following as affirmative

defenses should not be construed as an admission by ABRAMS that the burden of

proof or burden of persuasion in asserting such defenses fall on them, and such

burden of proof or persuasion shall be determined according to the applicable legal

standards. It is ABRAMS’ intent to preserve and not to waive his legal position that

the Plaintiff maintains the burden of proof on these issues.

Moreover, this matter is in the early stages of litigation and ABRMS hereby

reserves the right to add, supplement, or otherwise amend the below affirmative

defenses as the litigation herein more fully develops.

Causes of Action

COUNT I – CIVIL BATTERY

COUNT II – CIVIL ASSAULT

COUNT III – INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS