Now assume in the Brady v. Manning case that Manning serves an answer containing denials of the allegations of negligence and also asserting the affirmative defenses of statute of limitations, lack of jurisdiction, and comparative negligence. Can Manning now move for an MSJ?
a) Yes, Manning can move for MSJ on all grounds
b) No, Manning cannot move for MSJ since affirmative defenses are raised
c) Yes, Manning can move for MSJ on the grounds of statute of limitations only
d) No, Manning can only move for partial summary judgment on specific issues