Imagine that a plaintiff has acted in bad faith and sued you, and that:

1. "facts" alleged by the plaintiff in the complaint are wrong and the plaintiff's attorney has not done his homework in establishing them; and
2. some facts, if established in court, would incriminate the plaintiff for a crime (e.g., intentionally not paying taxes).

Let's say the case is handled in a state court like this. What responses are appropriate to such a civil complaint? Do I understand correctly that:

1. To make plaintiff pay for defendant's legal expenses the defendant would have to file a cross-complaint?
2. To incriminate the plaintiff, defendant would have to file a Motion to Strike.
3. To make the court question the plaintiff's honesty defendant would file a General Denial?

Imagine that a plaintiff and his attorney both have acted in bad faith and sued you, and that:

1. "facts" alleged by the plaintiff in the complaint are wrong and the plaintiff's attorney has not done his homework in establishing them; and
2. some facts, if established in court, would incriminate the plaintiff for a crime (e.g., intentionally not paying taxes).

Let's say the case is handled in a state court like this. What responses are appropriate to such a civil complaint? Do I understand correctly that:

1. To make plaintiff pay for defendant's legal expenses the defendant would have to file a cross-complaint?
2. To incriminate the plaintiff, defendant would have to file a Motion to Strike.
3. To make the court question the plaintiff's attorney's honesty defendant would file a General Denial?

Imagine hypothetical scenario where a plaintiff has acted in bad faith and has sued you. As defendant you know that:

1. "facts" suggested by plaintiff in complaint are wrong and the plaintiff's attorney has not done his homework in establishing them
2. some facts, if established in front of court, would incriminate his client for something like intentionally not paying taxes.
3. plaintiff and his attorney are buddies. His attorney possibly conspired against you.

Let's say the case is handled here. What would be the best response? Do I understand correctly, that to

1. make plaintiff to pay for defendants legal expenses the defendant would have to file cross-complaint.
2. to incriminate plaintiff, defendant would have to file Motion to Strike.
3. to make the court question plaintiffs honesty you would file General Denial

What would be the best response in that hypothetical scenario?

Imagine that a plaintiff has acted in bad faith and sued you, and that:

1. "facts" alleged by the plaintiff in the complaint are wrong and the plaintiff's attorney has not done his homework in establishing them; and
2. some facts, if established in court, would incriminate the plaintiff for a crime (e.g., intentionally not paying taxes).

Let's say the case is handled in a state court like this. What responses are appropriate to such a civil complaint? Do I understand correctly that:

1. To make plaintiff pay for defendant's legal expenses the defendant would have to file a cross-complaint?
2. To incriminate the plaintiff, defendant would have to file a Motion to Strike.
3. To make the court question the plaintiff's honesty defendant would file a General Denial?

We have retained an attorney approved by State Bar of California for the case where have been accused of unfair business practices by participating in conspiracy with the plaintiff's ex-employees to misappropriate his trade secrets (customer list). Basically, to re-summarize the whole case:

1. plaintiff in complaint incorrectly states that we have hired their ex-employees and solicited customers from their business. The reality is that we are just renting out stations to their ex-employees and they keep all the profits and operate as independent businesses.
2. plaintiff calls them ex-employees throughout the complaint but was giving to them form 1099 (which means plaintiff did not pay their payroll taxes as it would have been the case with w-2 forms). IRS is quite specific in publication 4902 (2-2011) that this arrangement of giving 1099 forms is permissible only if workers own their own customers and workers schedule their own appointments. This is stark opposite of what plaintiff states throughout the complaint.
3. the rest of complaint is also full of misrepresented facts that other two defendants can disprove or at least make less credible (w.r.t how plaintiff is lying in how he tried to maintain customer list as secret).

Since plaintiff's attorney was not willing to voluntarily dismiss us when I explained the whole situation, showed rental contract and explained that we had not yet hired an attorney yet (I made it clear to him that moment we will be forced to hire attorney we will be going after reasonable legal defense expenses), then my goals that I would like to achieve out of this lawsuit would be:

0. prove we are innocent
1. to get plaintiff to cover our legal defense costs,
2. if #2 fails then at least ensure that the other two defendants are responsible to pay for our legal defense costs as we have with them rental contract with indemnity clause (I don't mean to punish them, but if they lose in the court and plaintiff is awarded even 10% of the claimed damages then they will be forced to file bankruptcy anyway. At least plaintiff will get less once we take our share),
3. to incriminate plaintiff in front of court for intentionally not paying payroll taxes (in hopes that IRS would take action)
4. to get State Bar of California impose sanctions against plaintiff's attorney as he is buddy with plaintiff and I believe they are intentionally filing this lawsuit to harass us as we are only ones with the money.

Our court lists possible responses to the plaintiff complaint here.

Our attorney suggested that we should file a demurrer. Calling soon our attorney to discuss.

However, is that best response in our case? Do I understand correctly, that to attain goal #1 I would have to file cross-complaint. To attain goal #2 I would have to file cross-claim. To attain #3 I would have to file Motion to Strike (as it is illegal not to pay taxes for employees and plaintiff indirectly admits to that). And to attain goal #4 I would have to file General Denial (and possibly something with State Bar of California). What court forms should be actually filed here?

Imagine hypothetical scenario where a plaintiff has acted in bad faith and has sued you. As defendant you know that:

1. "facts" suggested by plaintiff in complaint are wrong and the plaintiff's attorney has not done his homework in establishing them
2. some facts, if established in front of court, would incriminate his client for something like intentionally not paying taxes.
3. plaintiff and his attorney are buddies. His attorney possibly conspired against you.

Let's say the case is handled here. What would be the best response? Do I understand correctly, that to

1. make plaintiff to pay for defendants legal expenses the defendant would have to file cross-complaint.
2. to incriminate plaintiff, defendant would have to file Motion to Strike.
3. to make the court question plaintiffs honesty you would file General Denial

What would be the best response in that hypothetical scenario?