Directly from the transcript: Fifteenth Affirmative Defense
Respondent reserves the right to amend this Answer to assert any additional affirmative
defense once discovery proceeds and more information becomes available. Respondent hereby
incorporates herein all affirmative defenses asserted by the other Respondents.
WHEREFORE, Respondent prays for judgment as follows:
1. Dismissing the OIP in its entirety with prejudice on the merits;
2. Awardingjudgment in Respondent's favor against the Commission;
3. Granting Respondent's costs and fees, including reasonable attorneys' fees; and
4. Granting such further and other relief as the Court deems just and proper.
Respectfully submitted, February 29, 2016
CORRIGAN & MORRIS, LLP
By: IS/ Stanley C. Morris
Stanley C. Morris (SM 5814)
(scm@cormorllp.com)
201 Santa Monica Blvd., Suite 475
Santa Monica, CA 90401
(310) 394-2828 Tel.
Attorneys for Respondent
BioElectronics Corporation