SUPERIOR COURT OF RIDGEWAY
THR33SIX8,
Plaintiff,
v.
ZARTALOX, THORSTRUCKED; and
RIDGEWAY STATE POLICE,
Defendants.
Civil Action No. RSC-CV-2201
DEFENDANTS’ ANSWER AND AFFIRMATIVE DEFENSES
Defendants, proceeding by and through the Solicitor General of Ridgeway,
respectfully file their Answer pursuant to Rid. R. Civ. P. 7(a) and hereby invoke a
general denial of all allegations not expressly admitted herein. Id., at 8(b)
PRELIMINARY STATEMENT
1. Paragraph 1 contains one or more legal conclusions to which no answer
is required; if an answer is required, denied.
2. Paragraph 2 contains one or more legal conclusions to which no answer
is required; if an answer is required, denied.
JURISDICTION AND VENUE
3. Paragraph 3 contains one or more legal conclusions to which no answer
is required; if an answer is required, denied.
PARTIES
4. Admitted,
5. Admitted.
6. Admitted.
7. Admitted.
FACTUAL ALLEGATIONS
8. Admitted that Plaintiff had engaged in crime prior to Zartalox pursuing
him; Denied that this unlawful conduct is “not at issue here”. By way of further
answer, Defendants state that Plaintiff had unlawfully shot and killed a law
enforcement officer and had been declared LFA.
9. Admitted.
10. Admitted that Plaintiff shot Zartalox with a firearm; Denied that
Plaintiff “[f]ear[ed] for his life”, “[acted] in self-defense”, and that “this was the only
time Plaintiff fired his gun at Zartalox”.
11. Admitted.
12. Admitted that Zartalox shot at Plaintiff in self-defense; Defendants are
without knowledge or information sufficient to form a belief as to the truth of the
remainder of this paragraph.
13. Admitted that Zartalox shot at Plaintiff in self-defense; Defendants are
without knowledge or information sufficient to form a belief as to the truth of the
remainder of this paragraph.
14. Admitted that Plaintiff fired multiple shots at Zartalox and that one of
Plaintiff’s shots hit Ontario_RBLX in the head and caused him to suffer severe
physical injuries; Denied that Plaintiff acted in “self-defense”.
15. Admitted that Defendant died; Denied that Zartalox committed assault
or any other legal wrongdoing.
16. Admitted that Plaintiff submitted a formal misconduct complaint with
the Ridgeway State Police on or about July 5, 2025; Denied that Zartalox engaged
in “reckless use of deadly force” or any other legal wrongdoing.
17. Admitted that Plaintiff’s misconduct complaint was not sustained;
Denied that Plaintiff’s complaint was dismissed “without substantive review.”
18. Paragraph 18 contains one or more legal conclusions to which no
answer is required; if an answer is required, denied.
19. Paragraph 19 contains one or more legal conclusions to which no
answer is required; if an answer is required, denied.
20. Paragraph 20 contains one or more legal conclusions to which no
answer is required; if an answer is required, denied.
21. Paragraph 21 contains one or more legal conclusions to which no
answer is required; if an answer is required, denied.
COUNT 1
22. Paragraph 22 contains a recitation of all preceding paragraphs to which
no response is required; if an answer is required, denied.
23. Paragraph 23 contains one or more legal conclusions to which no
answer is required; if an answer is required, denied.
24. Paragraph 24 contains one or more legal conclusions to which no
answer is required; if an answer is required, denied.
25. Paragraph 25 contains one or more legal conclusions to which no
answer is required; if an answer is required, denied.
26. Paragraph 26 contains one or more legal conclusions to which no
answer is required; if an answer is required, denied.
27. Paragraph 27 contains one or more legal conclusions to which no
answer is required; if an answer is required, denied.
COUNT 2
28. Paragraph 28 contains a recitation of all preceding paragraphs to which
no response is required; if an answer is required, denied.
29. Paragraph 29 contains one or more legal conclusions to which no
answer is required; if an answer is required, denied.
30. Paragraph 30 contains one or more legal conclusions to which no
answer is required; if an answer is required, denied.
31. Paragraph 31 contains one or more legal conclusions to which no
answer is required; if an answer is required, denied.
32. Paragraph 32 contains one or more legal conclusions to which no
answer is required; if an answer is required, denied.
33. Paragraph 33 contains one or more legal conclusions to which no
answer is required; if an answer is required, denied.
PRAYER FOR RELIEF
34. Paragraph 34 contains one or more legal conclusions to which no
answer is required; if an answer is required, denied.
35. Paragraph 35 contains one or more legal conclusions to which no
answer is required; if an answer is required, denied.
36. Paragraph 36 contains one or more legal conclusions to which no
answer is required; if an answer is required, denied.
37. Paragraph 37 contains one or more legal conclusions to which no
answer is required; if an answer is required, denied.
First Affirmative Defense
(Self-Defense)
1. Defendants pray that the Complaint be dismissed because their acts
were made in lawful self-defense.
Second Affirmative Defense
(Necessity)
2. Defendants pray that the Complaint be dismissed because their acts
were reasonable and necessary to prevent a greater harm.
Second Affirmative Defense
(Qualified Immunity)
3. Defendants pray that the Complaint be dismissed because its claims are
barred under the doctrine of qualified immunity.
Certificate of Service
I, the undersigned counsel, do hereby certify that a copy of this document and
its contents have, on July 24, 2025, been filed with the Clerk of Court by CM/ECF
system and that the CM/ECF system will serve an electronic copy of this document
on all parties and counsel of record.
Dated: July 24, 2025 Respectfully submitted,
Palmer, Ridgeway.
/s/ BrendaPopplewell
BrendaPopplewell
Solicitor General
EffortlessBrit
Deputy Solicitor General
Ridgeway Department of Justice
1 County Annex
Palmer, Ridgeway 33368
Attorneys for Defendants
