This template is a list of defenses to employment claims that enumerates common defenses and affirmative defenses that California employers may plead in their answers to complaints that assert equal employment opportunity (EEO), wage and hour, and/or class and collective action claims. It is intended for private employers. This template's language has been customized to comply with California and federal law. As a result, the text of this template differs from the non-jurisdictional Defenses to Employment Claims template. The drafting notes and alternate clause address issues under both California and federal law. They do not address local or municipal laws. For more information on defending against EEO claims, see Employment Discrimination Litigation: Defending Single-Plaintiff Cases, Defenses to EEO Claims: Key Considerations, and California Employment Law ยง 43.01 et seq. (2017). For additional information on responding to wage and hour class or collective action claims, see Answers, ...