DISTRICT COURT OF THE STATE OF RIDGEWAY
COUNTY OF RIDGEWAY
Detachment_Result,
-against-
AlexanderLuthorJr,
Defendant.
Case No. RSC-CV-5938
ANSWER TO COMPLAINT
Defendant, AlexanderLuthorJr, by and through his undersigned counsel, for his
Answer to the Complaint filed by Plaintiff Detachment_Result, admits, denies, and
alleges as follows:
RESPONSES TO ALLEGATIONS
1. In response to Paragraph 1 of the Complaint, Defendant is without knowledge or
information sufficient to form a belief as to the truth of the allegations regarding
Plaintiff's specific duties and therefore denies the same.
2. In response to Paragraph 2 of the Complaint, Defendant admits to pulling into
the parking lot. Defendant denies the characterization that he “followed”
Plaintiff into a store and denies the remaining allegations in this paragraph.
3. In response to Paragraph 3 of the Complaint, Defendant admits he observed an
individual in security attire.
4. In response to Paragraph 4 of the Complaint, Defendant denies the allegations.
Defendant states that he parked his vehicle and that Plaintiff, operating an
armored vehicle in a reckless and aggressive manner, nearly collided with
Defendant's vehicle.
5. In response to Paragraph 5 of the Complaint, Defendant denies the allegations as
stated. Defendant admits to discharging a firearm after the Plaintiff, an armed
individual, exited his vehicle and aggressively advanced on the Defendant in a
threatening manner, causing Defendant to be in reasonable fear of imminent,
severe bodily harm or death.
6. In response to Paragraph 6 of the Complaint, Defendant admits that this Court
has jurisdiction.
7. In response to Paragraph 7 of the Complaint, Defendant admits that venue is
proper.
8. In response to Paragraph 8 of the Complaint, Defendant is without knowledge or
information sufficient to form a belief as to the truth of the allegations regarding
Plaintiff's identity, residency, and employment, and therefore denies the same.
9. In response to Paragraph 9 of the Complaint, Defendant admits he is an
individual, resident, and citizen of the State of Ridgeway.
10. In response to Paragraph 10 of the Complaint, Defendant incorporates his
responses above as if fully set forth herein.
11. In response to Paragraph 11 of the Complaint, which contains legal conclusions
to which no response is required, Defendant denies the allegations. Defendant
asserts that any action taken was with legal cause and justification, specifically in
the act of self-defense.
12. In response to Paragraph 12 of the Complaint, Defendant incorporates his
responses above as if fully set forth herein.
13. In response to Paragraph 13 of the Complaint, Defendant denies the allegations.
Defendant did not “wrongfully take” any property. Any property secured by the
Defendant was done so out of necessity to neutralize an ongoing threat and
secure the scene.
AFFIRMATIVE DEFENSES
FIRST AFFIRMATIVE DEFENSE (Self-Defense)
Defendant’s actions were undertaken in lawful self-defense. Defendant was
confronted by an armed individual, the Plaintiff, who was advancing in a hostile
and threatening manner. Defendant reasonably believed he was in imminent danger
of suffering serious bodily injury or death, and the force used was necessary to repel
the threat posed by the Plaintiff.
SECOND AFFIRMATIVE DEFENSE (Comparative Fault)
Plaintiff's own negligence, recklessness, and aggressive actions were the sole and
proximate cause of the incident and any resulting damages. Plaintiff's decision to
exit an armored vehicle and menacingly "confront" the Defendant, while armed,
created the dangerous situation that resulted in the complained-of injuries. Any
damages awarded to the Plaintiff must be barred or reduced in proportion to
Plaintiff’s own culpable conduct.
THIRD AFFIRMATIVE DEFENSE (Necessity)
In response to the cause of action for Trover, Defendant asserts that the securing of
Plaintiff's firearm was justified by necessity. After using lawful force in self-defense,
it was necessary for the Defendant to neutralize any further threats, including those
posed by the Plaintiff's weapon, to ensure his own safety and the safety of the public
until law enforcement arrived. This action was not a "wrongful taking" but a
reasonable and necessary act under the circumstances.
FOURTH AFFIRMATIVE DEFENSE (Failure to State a Claim)
The Complaint, and each cause of action therein, fails to state a claim upon which
relief can be granted.
FIFTH AFFIRMATIVE DEFENSE (Reservation of Rights)
Defendant reserves the right to assert additional affirmative defenses as they may
become known through the course of discovery and investigation.
Respectfully submitted,
Dated: July 17, 2025
/s/0xSyns
0xSyns
