Rendered from the court's authenticated repository
Searchable full text
3,297 characters extracted
—
STATE OF RIDGEWAY
RIDGEWAYFARMING_ALT )
)
)
)
)
)
)
)
)
)
DOCKET NO. RSC-CV-339
PRESIDING JUDGE. frostbleed
Plaintiff
v.
YOUFOUNDSEAL
Defendant
RESPONSE TO CIVIL COMPLAINT
The State of Ridgeway, in liaison with the Defendant and his counsel, formally submit this joint
response to the civil complaint.
PLEAS
- Trespassing (x1), 1 R. Stat. § 201 – The Defendant pleads NOT LIABLE
- Trover (x1), 1 R. Stat. § 213 – The Defendant pleads NOT LIABLE
DEFENDANT’S AVERMENTS
1. The Defendant is not liable for the tort of trespassing (1 R. Stat. § 201) because the
Defendant is protected by the Rid. Good Samaritan Act (2022).
2. The Defendant is not liable for the tort of trover (1 R. Stat. § 213) because the Defendant is
protected by the Rid. Good Samaritan Act (2022).
AFFIRMATIONS OR DENIALS OF THE PLAINTIFF’S AVERMENTS
1. We disagree with the first contention on the Plaintiff’s Civil Complaint. The Defendant did
not illegally enter the Plaintiff’s vehicle.
2. We agree in part with the second contention. The Plaintiff was indeed cycling through the
seats of his vehicle; however, this was done prior to the Defendant entering his vehicle, and it
was initially done to evade a law enforcement officer.
3. We do not have enough information or knowledge to determine the Plaintiff’s third, fourth,
and fifth contentions. However, voice chat messages are not at all relevant to the elements of
the tort. This shall serve as a denial of the voice chat related contentions. See Rid. R. Civ. P.
(8)(b).
4. For ¶1 of the Plaintiff’s allegations, we disagree. The Plaintiff distorts the elements of the tort
for trespassing (1 R. Stat. § 201). The Defendant had a lawful excuse to enter the Plaintiff’s
vehicle.
5. For ¶2 of the Plaintiff’s allegations, we disagree. The Plaintiff distorts the elements of the tort
for trover (1 R. Stat. § 213). The Defendant had a legal reason to enter the Plaintiff’s vehicle,
therefore, the Plaintiff did not wrongfully take the Plaintiff’s property.
STATEMENT OF FACTS
1. On May 5th, 2022, the Defendant in this case was in a marked Ridgeway State Police vehicle
with Lieutenant BlackMrcow23 with the Ridgeway State Police.
2. An earlier encounter with the Plaintiff displays him attempting to injure the Trooper with an
axe, and then the Plaintiff proceeded to drive away after. During this, the Plaintiff continued
to jump in and out of his vehicle to avoid getting arrested by the law enforcement officer.
This would happen several times during the period in between the first encounter between the
Plaintiff and the Defendant, up to the Plaintiff’s arrest.
3. The Defendant and the Lieutenant encountered the Plaintiff evading from clearly marked and
identified Law Enforcement Officer.
a. The Plaintiff was attempting to evade the Law Enforcement Officer which is an
illegal act. See Ridgeway Criminal Code § 2.09.
4. The Plaintiff continuously evaded from the Officer by jumping and switching seats around
his car to ensure that the Officer could not apprehend him.
5. The Defendant noticed this and rushed to the Officer’s aid by occupying the driver’s seat of
the Plaintiff’s vehicle to prevent the Plaintiff from further evading from the Law
Enforcement Officer.
TURNTABLE5000
Solicitor General
Department of Justice
Counsel of Record
Dated: May 21st, 2022
Document record
File size
128.6 KB
Uploaded
May 5, 2022 12:00 PM
Filed
May 5, 2022 12:00 PM
Filing code
COMPLAINT
Uploaded by
ridgewayfarming_alt
Notes
RSC-CV-339_Defendant_Response.pdf — archived from the Trello docket (https://trello.com/c/314pHUfY)
