Defenses

As for its defenses to the counterclaims by defendent TPL, Patriot alleges as follows:

First Affirmative Defense

The counterclaims fail to state a claim upon which relief may be granted.

Second Affirmative Defense

By defendent`s conduct, defendent TPL`s claims for relief are barrd by the defense of estoppel

Third Affermative Defense

By defendent`s conduct, defendent TPL`s claims for relief are barred by the defense of laches