The Tenth Circuit has not determined whether the notice pleading standards of Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 127 S.Ct. 1955, 167 L.Ed.2d 929 (2007), and its progeny apply to affirmative defenses. One commentator has noted that “numerous federal courts have held [that] an affirmative defense may be pleaded in general terms and will be held to be sufficient, and therefore invulnerable to a motion to strike, as long as it gives the plaintiff fair notice of the nature of the defense.” 5 Charles Alan Wright &. Arthur R. Miller, Federal Practice & Procedure § 1274. Other courts of appeals have determined that genéral statements of affirmative defenses are sufficient. E.g., Holway v. Negro Leagues Baseball Museum, 263 Fed.Appx. 538, 538 (8th Cir.2008) (unpublished per curiam) (<HOLDING>); Clem v. Corbeau, 98 Fed.Appx. 197, 203 (4th
holding that defendant did not waive its statute of limitations defense by failing to cite the specific statute in its answer holding that the defense of insufficient process was waived because it was not raised by the defendant in its answer but later in its response to the plaintiffs request for default judgment holding that defendants failure to assert the defense in any pretrial motions did not waive defendants limitations defense because the assertion of a limitations defense in the answer preserved defendants right to raise the defense both during the first trial and before the second holding defense of statute of limitations not waived when asserted in a motion for summary judgment rather than in the answer holding that a party does not waive arbitration simply by failing to invoke it in the complaint or answer