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ANSWER - 1
0xSyns
4000 Majellan Way, Sterling Heights
D: notsinz
DISTRICT COURT OF THE STATE OF RIDGEWAY
COUNTY OF RIDGEWAY
COUNTHAREBOURG2,
Plaintiff,
vs.
FREEARTIEE,
Defendant
Case No.: RSC-CV-6289
ANSWER
RESPONSES TO ALLEGATIONS
1. In response to Paragraph 1 of the Complaint, Defendant admits the date of the incident.
2. In response to Paragraph 2, Defendant is without knowledge or information sufficient to form a
belief as to the truth of the allegation regarding Plaintiff's purpose for being at the location and
therefore denies the same.
3. In response to Paragraph 3, Defendant denies the allegations as stated. Defendant admits he was
lawfully in his vehicle and only equipped his firearm after perceiving an imminent and deadly
threat from the Plaintiff.
4. In response to Paragraph 4, Defendant denies the allegations. Defendant states that upon exiting
the store, Plaintiff acted in a hostile and threatening manner, causing Defendant to reasonably
believe he was about to be subjected to deadly force. Defendant aimed his rifle in a lawful act of
self-defense.
5. In response to Paragraph 5, Defendant denies the allegations as stated. Defendant admits to
discharging his firearm but asserts that this action was necessary and legally justified to defend
his own life against the threat posed by the Plaintiff.
6. In response to Paragraph 6, Defendant admits that venue is proper.
7. In response to Paragraph 7, Defendant admits the Plaintiff is a citizen of Ridgeway.
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ANSWER - 2
8. In response to Paragraph 8, Defendant admits he is a citizen of Ridgeway.
9. In response to Paragraph 9, which contains legal conclusions to which no response is required,
Defendant denies that his actions constituted the torts of Battery, Assault, or Wrongful Death.
10. In response to Paragraph 10, Defendant objects to the request for a temporary restraining order as
there is no basis for such relief.
11. In response to Paragraph 11, Defendant denies that Plaintiff is entitled to any of the relief sought.
AFFIRMATIVE DEFENSES
FIRST AFFIRMATIVE DEFENSE (Self-Defense)
12. Defendant’s actions were undertaken in lawful self-defense. Defendant was confronted by 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 deadly threat posed by the Plaintiff.
SECOND AFFIRMATIVE DEFENSE (Comparative Fault)
13. Plaintiff's own aggressive, threatening, and unlawful actions were the sole and proximate cause
of the incident and any resulting damages. Any damages awarded to the Plaintiff must be barred
or reduced in proportion to Plaintiff’s own culpable conduct.
THIRD AFFIRMATIVE DEFENSE (Failure to State a Claim)
14. The Complaint, and each cause of action therein, fails to state a claim upon which relief can be
granted because Defendant's actions were legally justified.
FOURTH AFFIRMATIVE DEFENSE (Reservation of Rights)
15. Defendant reserves the right to assert additional affirmative defenses as they may become known
through the course of discovery and investigation.
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ANSWER - 3
Respectfully submitted, /s/0xsyns
0xSyns
