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8. Barker's claims are barred, in whole or in part, in that granting <br />recovery upon those claims would result in unjust enrichment to the Barkers. <br />9. Barker's at all times gave their consent, express or implied, to any <br />and all acts and conduct of Empire alleged in the Counterclaims. <br />10. Barker's claims are barred, in whole or in part, in that Empire has <br />been expressly, impliedly or by operation of law, excused from any and all <br />obligations relating to Barker's claims for relief. <br />11. Because the Counterclaims are couched in broad and conclusory <br />terms, Empire cannot fully anticipate all defenses that may be applicable to this <br />action. Accordingly, the right to assert additional defenses and to amend this <br />answer, if and to the extent that such defenses are applicable, is hereby reserved. <br />PRAYER FOR RELIEF <br />WHEREFORE, Empire prays as follows: <br />1. That Barkers take nothing by way of their Counterclaims; <br />2. That the Counterclaims be dismissed in their entirety; <br />3. That Barkers be denied each and every demand and prayer for relief <br />contained in the Counterclaims; <br />4. That Empire be awarded its fees and costs, including reasonable <br />attorneys' fees and expert fees, in defense of the Counterclaims as allowed by <br />law; and <br />5. For such other and further relief as the Court may deem just and <br />proper. <br />6 <br />