SUPERIOR COURT OF RIDGEWAY
HOUSE OF GARDAI,
Plaintiff,
v.
REFRESHEDMANGO, in his official
capacity as Governor of the State of
Ridgeway,
Defendant.
Civil Action No. RSC-CV-2892
DEFENDANTS’ ANSWER AND AFFIRMATIVE DEFENSES
Defendant, 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)
PARTIES
1. Admitted.
2. Admitted.
JURISDICTION AND VENUE
3. Paragraph 3 contains one or more legal conclusions to which no
answer is required; if one is required, denied.
4. Paragraph 4 contains one or more legal conclusions to which no
answer is required; if one is required, denied.
INTRODUCTION
5. Paragraph 5 contains one or more legal conclusions to which no
answer is required; if one is required, denied.
6. Paragraph 6 contains one or more legal conclusions to which no
answer is required; if one is required, denied.
7. Paragraph 7 contains one or more legal conclusions to which no
answer is required; if one is required, denied.
8. Paragraph 8 contains one or more legal conclusions to which no
answer is required; if one is required, denied.
9. Paragraph 9 contains one or more legal conclusions to which no
answer is required; if one is required, denied.
10. Paragraph 10 contains one or more legal conclusions to which no
answer is required; if one is required, denied.
11. Paragraph 11 contains one or more legal conclusions to which no
answer is required; if one is required, denied.
12. Paragraph 12 contains one or more legal conclusions to which no
answer is required; if one is required, denied.
13. Paragraph 13 contains one or more legal conclusions to which no
answer is required; if one is required, denied.
14. Paragraph 14 contains one or more legal conclusions to which no
answer is required; if one is required, denied.
15. Paragraph 15 contains one or more legal conclusions to which no
answer is required; if one is required, denied.
16. Paragraph 16 contains one or more legal conclusions to which no
answer is required; if one is required, denied.
17. Paragraph 17 contains one or more legal conclusions to which no
answer is required; if one is required, denied.
18. Paragraph 18 contains one or more legal conclusions to which no
answer is required; if one is required, denied.
FACTUAL STATEMENTS
19. Admitted.
20. Admitted.
FIRST CAUSE OF ACTION
21. Paragraph 21 incorporates by reference all previous paragraphs to
which no response is required; if one is required, denied.
22. Paragraph 22 contains one or more legal conclusions to which no
answer is required; if one is required, denied.
23. Paragraph 23 contains one or more legal conclusions to which no
answer is required; if one is required, denied.
24. Paragraph 24 contains one or more legal conclusions to which no
answer is required; if one is required, denied.
25. Paragraph 25 contains one or more legal conclusions to which no
answer is required; if one is required, denied.
26. Paragraph 26 contains one or more legal conclusions to which no
answer is required; if one is required, denied.
27. Paragraph 27 contains one or more legal conclusions to which no
answer is required; if one is required, denied.
28. Paragraph 28 contains one or more legal conclusions to which no
answer is required; if one is required, denied.
29. Paragraph 29 contains one or more legal conclusions to which no
answer is required; if one is required, denied.
30. Paragraph 30 contains one or more legal conclusions to which no
answer is required; if one is required, denied.
31. Paragraph 31 contains one or more legal conclusions to which no
answer is required; if one is required, denied.
32. Paragraph 32 contains one or more legal conclusions to which no
answer is required; if one is required, denied.
33. Paragraph 33 contains one or more legal conclusions to which no
answer is required; if one is required, denied.
34. Paragraph 34 contains one or more legal conclusions to which no
answer is required; if one is required, denied.
35. Paragraph 36 contains one or more legal conclusions to which no
answer is required; if one is required, denied.
36. Paragraph 37 contains one or more legal conclusions to which no
answer is required; if one is required, denied.
37. Paragraph 37 contains one or more legal conclusions to which no
answer is required; if one is required, denied.
SECOND CAUSE OF ACTION
38. Paragraph 38 contains one or more legal conclusions to which no
answer is required; if one is required, denied.
39. Paragraph 39 contains one or more legal conclusions to which no
answer is required; if one is required, denied.
40. Paragraph 40 contains one or more legal conclusions to which no
answer is required; if one is required, denied.
41. Paragraph 41 contains one or more legal conclusions to which no
answer is required; if one is required, denied.
42. Paragraph 42 contains one or more legal conclusions to which no
answer is required; if one is required, denied.
43. Paragraph 43 contains one or more legal conclusions to which no
answer is required; if one is required, denied.
44. Paragraph 44 contains one or more legal conclusions to which no
answer is required; if one is required, denied.
THIRD CAUSE OF ACTION
45. Paragraph 45 contains one or more legal conclusions to which no
answer is required; if one is required, denied.
46. Paragraph 38 contains one or more legal conclusions to which no
answer is required; if one is required, denied.
47. Paragraph 47 contains one or more legal conclusions to which no
answer is required; if one is required, denied.
48. Paragraph 48 contains one or more legal conclusions to which no
answer is required; if one is required, denied.
49. Paragraph 49 contains one or more legal conclusions to which no
answer is required; if one is required, denied.
50. Paragraph 50 contains one or more legal conclusions to which no
answer is required; if one is required, denied.
FOURTH CAUSE OF ACTION
51. Paragraph 51 contains one or more legal conclusions to which no
answer is required; if one is required, denied.
52. Paragraph 52 contains one or more legal conclusions to which no
answer is required; if one is required, denied.
53. Paragraph 53 contains one or more legal conclusions to which no
answer is required; if one is required, denied.
54. Paragraph 54 contains one or more legal conclusions to which no
answer is required; if one is required, denied.
55. Paragraph 55 contains one or more legal conclusions to which no
answer is required; if one is required, denied.
56. Paragraph 56 contains one or more legal conclusions to which no
answer is required; if one is required, denied.
57. Paragraph 57 contains one or more legal conclusions to which no
answer is required; if one is required, denied.
58. Paragraph 58 contains one or more legal conclusions to which no
answer is required; if one is required, denied.
59. Paragraph 59 contains one or more legal conclusions to which no
answer is required; if one is required, denied.
60. Paragraph 60 contains one or more legal conclusions to which no
answer is required; if one is required, denied.
61. Paragraph 61 contains one or more legal conclusions to which no
answer is required; if one is required, denied.
62. Paragraph 62 contains one or more legal conclusions to which no
answer is required; if one is required, denied.
PRAYER FOR RELIEF
63. Paragraph 63 contains one or more legal conclusions to which no
answer is required; if one is required, denied.
64. Paragraph 64 contains one or more legal conclusions to which no
answer is required; if one is required, denied.
65. Paragraph 65 contains one or more legal conclusions to which no
answer is required; if one is required, denied.
66. Paragraph 66 contains one or more legal conclusions to which no
answer is required; if one is required, denied.
DEFENDANT’S FIRST AFFIRMATIVE DEFENSE
(Failure to State a Claim)
1. The Court should deny relief because Plaintiff has failed to state a
claim upon which relief can be granted.
DEFENDANT’S FIRST AFFIRMATIVE DEFENSE
(Unclean Hands)
2. The Court should deny relief because Plaintiff has unclean hands.
DEFENDANT’S FIRST AFFIRMATIVE DEFENSE
(Official Immunity)
3. The Court should deny relief pursuant to the doctrines of sovereign
immunity, qualified immunity, and/or absolute immunity.
4. Defendant reserves the right to assert further affirmative defenses.
Dated: July 30, 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 Defendant
Certificate of Service
I, the undersigned counsel, do hereby certify that a copy of this document
and its contents have, on July 30, 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 30, 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 Defendant
