They deny everything and say PPHM has unclean hands, also barred by the doctrine of laches, PPHM failed to perform all its obligations to comply with all of the terms, conditions and provisions of the relevant contracts at issue in the complaint, therefore CSM owes no duties to Peregrine.PPHM failed to mitigate, minimize or avoid any of the damages it allegedly sustained so any recovery against CSM must be barred or reduced.
PPHM's damages were caused by its own actions or actions of other parties or entities, not caused by CSM. PPHM consented to and approved the alleged acts for which it now complains. Peregrine claims may be barred to the extent Peregrine assumed all risks in entering into the alleged contracts with Defendant.
Peregrine's claims are barred in whole or part because there is no private right of action concerning matters regulated by the FDA under applicable federal laws, regulations and rules.
And on and on...
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