1. Draft an answer for Ralph Lauren, responding to the complaint bellow.
2. Assume Ralph Lauren is incorporated in California with its principal place of business in California.
3. Assert two affirmative defenses.
4. Do not assert any Federal Rules of Civil Procedures Section 12(b) defenses.
5. Demand a jury trial.

Plaintiff "Rachel and Ralph "alleges as follows on information and belief:

THE PARTIES

1. Rachel and Ralph are, and at all material, times mentioned herein was, a New York corporation in good standing organized and existing under the State of New York with its principal place of business in the New York State.

2. Defendant "Ralph Lauren" is, and at all material times mentioned herein was, a limited liability company organized and existing under the laws of the State of California with its principal place of business in California.

OPERATIVE FACTS

3. On July 11, 2022, Rachel and Ralph paid $100,000 for a variety of clothing to the defendants for its store.

4. The clothing order was supposed to arrive on August 11, 2022, but Ralph Lauren's factory went on strike. Ralph Lauren sent Rachel and Ralph a notice that it would be unable to fulfil the order on the decided date as per the contract.

5. As such, Rachel and Ralph have been left with no choice but to file this action and seek recovery of the money paid to the defendants and damages caused due to delay in providing the order and breach of the written contract between the plaintiff and the defendants.

FIRST CAUSE OF ACTION

[For Breach of Written Contract Against Ralph Lauren]

6. Rachel and Ralph repeat and reallege each allegation contained in the foregoing paragraphs of the Complaint as if outlined in full herein.

7. On July 11, 2022, Rachel and Ralph paid $100,000 for a variety of clothing to the defendants for its store.

8. The clothing order was supposed to arrive on August 11, 2022, but Ralph Lauren's factory went on strike. Ralph Lauren sent Rachel and Ralph a notice that it would be unable to fulfil the order on the decided date as per the contract.

9. As such, Rachel and Ralph have been left with no choice but to file this action and seek recovery of the money paid to the defendants and damages caused due to delay in providing the order and breach of a written contract between the plaintiff and the defendants.

10. As a direct and proximate result of Ralph Lauren's breach of written contract as described herein, Rachel and Ralph have been damaged in an amount to conform to proof at trial, but not less than $100,000, plus interest as allowed by law, and attorneys' fees and costs as provided by law.

PRAYER FOR RELIEF

THEREFORE, the plaintiff prays for judgment against the defendants for as follows:

1. On the cause of action of breach of written contract:

a. An award of all damages available in law and according to proof at trial;

b. for punitive and exemplary damages.

c. For interest to the extent allowed by law;

d. for reasonable attorneys' fees to the extent allowed by law and/or the

e. for costs of suit incurred, and

f. for such other and further relief as the Court deems just and proper.