Ridgeway Unified Courts

JUDICIAL COUNCIL OF RIDGEWAY

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This document is for roleplaying purposes only. I am a notary public of the State of Texas in real life. A notary public cannot give legal advice. See Tex. Gov't Code § 406.017. This document does not constitute legal advice. SUPERIOR COURT OF THE STATE OF RIDGEWAY EFFORTLESSYEET, Plaintiff, v. DAVIDDEVIL2, Defendant. No. RSC-CV-739 ANSWER TO THE COMPLAINT Defendant daviddevil2, by and through undersigned counsel, hereby, pursuant to Ridgeway Rule of Civil Procedure 8(b), answers the Complaint and asserts his affirmative defenses. GENERAL DENIAL Unless expressly admitted below, Defendant denies each and every allegation that Plaintiff has set forth in their Complaint. STATEMENT1 1. Admitted. 2. Admitted in part and denied in part. David was not acting in a government capacity. 3. Admitted in part and denied in part. David did not shoot Effortless’ vehicle. 4. Denied. 5. Defendant lacks knowledge or information sufficient to admit or deny the allegations of this paragraph. 6. Denied. 7. Admitted. 8. Admitted. 1 The headings and subheadings listed below correspond to the Complaint. They are noted herein solely for the purposes of convenience, organization, and ease of reference. Repetition of these headings and subheadings is not an admission of their contents. ANSWER - 1 - This document is for roleplaying purposes only. I am a notary public of the State of Texas in real life. A notary public cannot give legal advice. See Tex. Gov't Code § 406.017. This document does not constitute legal advice. 9. Admitted. 10. Admitted. 11. Defendant lacks knowledge or information sufficient to admit or deny the allegations of this paragraph. 12. Defendant lacks knowledge or information sufficient to admit or deny the allegations of this paragraph. VENUE 13. This paragraph sets forth a legal conclusion to which no response is required. To the extent a response is required, denied. PARTIES 14. Denied. 15. Denied. TORTS AND PRAYERS FOR RELIEF All paragraphs under this heading are denied. Defendant avers that Plaintiff is not entitled to any relief. AFFIRMATIVE DEFENSES Defendant sets forth their affirmative defenses. By setting forth these affirmative defenses, Defendant does not assume the burden of proving any fact, issue, or element of a cause of action. FIRST AFFIRMATIVE DEFENSE (Want of Jurisdiction) This Court’s jurisdiction has not been invoked. SECOND AFFIRMATIVE DEFENSE (Lack of Jurisdiction – Parties) This Court lacks jurisdiction over the parties. THIRD AFFIRMATIVE DEFENSE (Improper Venue) Venue is improper in this Court. ANSWER - 2 - This document is for roleplaying purposes only. I am a notary public of the State of Texas in real life. A notary public cannot give legal advice. See Tex. Gov't Code § 406.017. This document does not constitute legal advice. FOURTH AFFIRMATIVE DEFENSE (Reservation) Defendant reserves the right to request leave to amend the answer to assert additional affirmative defenses not asserted herein at any time of which he may become aware of after discovery or other investigation. See generally Town & Country Linen Corp. v. Ingenious Designs LLC, No. 18-CV-5075 (LJL), 2020 WL 3472597, at *14-15 (S.D.N.Y. June 25, 2020) (allowing reservation of the right to move to amend to add affirmative defenses). Defendant prays that the Court— a. Dismiss the Complaint with prejudice; b. Award such other, further, or different relief as may be just and proper. Respectfully submitted. Dated: November 11th, 2022 Palmer, Ridgeway /s/ DorkJacob ——————————————————————————— DORKJACOB Ridgeway Bar No. 17135 Counsel of Record DorkJacob Law 2B Atlee Road Palmer, Ridgeway JacobInAustin#0001 [email protected] Attorney for Defendant ANSWER - 3 -

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