RIDGEWAY SUPERIOR COURT
EPIDERMISGUPTA69,
Plaintiff,
v.
DINO_RAF; in his official capacity as a
Firefighter in the Ridgeway County Fire
Department,
Defendant.
Case No. RSC-CV-850
ANSWER TO COMPLAINT
The DEFENDANT, Dino_Raf, comes now, with counsel, to answer the complaint against
him.
PARTIES
1. Plaintiff Epidermisgupta69 is a citizen of the State of Ridgeway.
2. Defendant Dino_Raf is a Firefighter in the County of Ridgeway, which is an
administrative and political subdivision of the State of Ridgeway.
JURISDICTION AND VENUE
3. Defendant agrees the Superior Court of Ridgeway State has jurisdiction to hear this case.
4. Defendant agrees the venue is proper, but not that any tortious action occurred.
ANSWER
5. Defendant admits, and concludes he does his duty to the best of his ability, even when
obstructed by citizens, like the plaintiff.
6. Defendant agrees; however, this has no bearing on the facts of the case.
7. Defendant agrees; however, this has no bearing on the facts of the case.
8. Defendant agrees; however, this has no bearing on the facts of the case. Nonetheless, the
Defendant and the Department he works for is protected by the public necessity doctrine.
9. Defendant agrees, again this has no bearing on the facts of the case. Once again, this
action is protected by the public necessity doctrine.
10. Defendant agrees.
11. Defendant agrees.
12. Defendant admits.
13. Defendant admits.
14. Defendant disputes in its entirety and will present evidence which will show that the
plaintiff falsified evidence and perjured himself in his civil complaint.
15. Defendant agrees in part. The plaintiff was held in custody by police officers, for the
plaintiff’s actions at this residential fire, in which he scaled the fire ladder, thereby
causing an interference to the Ridgeway County Fire Department as it had to ensure that
its Department policies on safety protocols were adhered to.
FIRST CAUSE OF ACTION
(1 R. Stat. §3114 - Official Misconduct )
16. In reference to paragraph 16, denies all prior allegations not otherwise admitted.
17. Defendant admits with respect to his position in the Ridgeway County Fire Department,
but does not admit any tortious action occurred; indeed, none did.
18. Admitted but irrelevant to this case.
19. Denies the allegations in paragraph 19. Plaintiff did not exceed his legal authority by
responding to a police officer's question about whether or not he would like the Plaintiff
charged for interfering with his duties.
20. Denies the allegations in paragraph 20. The Plaintiff's harm directly stems not from the
Defendant, but from the police officer who arrested him and his own illegal conduct.
COUNTERCLAIM ONE
(1 R. Stat. § 3112 - ABUSE OF A LEGAL PROCESS)
21. When responding to an incident that Firefighters are dispatched to, nobody knows what to
expect. Are we going to be confronted by obstructionists wishing to slow down? Are we
going to be confronted by armed civilians wishing to do harm? Are we going to a Fire
that is fully engulfed? Or are we going to a Fire that has no working fire? But we respond
nonetheless, because that is our lawful duty.
22. When the Defendant and his Truck Company, Truck 28 responded to a Residential fire at
a three-storey apartment building, they got straight to work, trying to knock down the fire
that posed an extreme risk to the public, and an even greater risk to themselves.
23. Whilst setting up the Truck ready to tackle the blaze at the Palmer Apartments, you can
see the plaintiff climb onto the truck whilst the ladder is still lowered (See Defense
Exhibit A). The Plaintiff stayed on the top of the Ladder, until Firefighter’s started to raise
the ladder, when the plaintiff quickly moved to the roof of the Truck.
24. However, the Plaintiff’s reckless actions don’t stop there. The plaintiff waited for the
ladder to be raised to his balcony, before he jumped off the ladder to his balcony. Doing
so, he violated the Criminal Code, at sections 6.05b & c. As such, the Defendant was well
within his rights to request that he be arrested for violating the law.
25. In an attempt to gain unlawful restitution, the Plaintiff filed a frivolous lawsuit, which he
knew encapsulated falsifying evidence and perjuring himself in the State Superior Court.
26. The Plaintiff intentionally excluded the fact that he had climbed on the ladder only
moments before. In fact, in his complaint, he specifically says the Defendant’s statement
that he was on the ladder is a lie.
27. 1. R. Stat. § 3112 states, “Any individual who abuses a legal process such as a court
proceeding… by means of providing vexatious, fraudulent or frivolous complaints to get
another in trouble shall be liable”.
28. The Plaintiff abused this very court proceeding by providing a fraudulent and frivolous
complaint to get the Defendant, Dino_Raf in trouble. If he had succeeded, this would
have led to unconscionable injury to the plaintiff, such as prosecution and even internal
disciplinary action by the Ridgeway County Fire Department. As such, he is liable for
‘Abuse of a Legal Process’.
COUNTERCLAIM TWO
(1. R. Stat. § 3108 - CIVIL FRAUD)
29. Further to our previous Counterclaim, the Defendant realleges that the Defendant
provided a Fraudulent and Frivolous Civil Complaint to the Superior Court of Ridgeway
State, in an attempt to gain an unlawful payment of restitution.
30. When the Defendant submitted his civil complaint to the Ridgeway Superior Court, he
alleged that the Defendant lied to the Police Officer, he alleged that the Defendant
committed a crime by making a false report to a Police Officer. We know that the Plaintiff
was lying, we know the Plaintiff perjured himself on a court document.
31. If we look at Defense Exhibit A & Plaintiff Exhibit A, we see that the Plaintiff attempted
to make an unlawful gain, by falsifying his evidence by altering the evidence he intended
to use in this process. The Plaintiff knowingly provided the court with a false narrative of
the events that occurred on that day. By doing so, the Plaintiff committed ANOTHER
CRIME, Tampering with Evidence.
32. The Plaintiff’s reckless actions caused reputational harm to the Defendant, and brought
his character and the Ridgeway County Fire Department into disrepute. As such, the
Defendant is entitled to relief from the Plaintiff.
33. 1. R. Stat. § 3108 states, “Any individual who intentionally deceives another party to
secure unfair or unlawful gain, or to deprive a victim of a legal right shall be fraud”
34. The Plaintiff intentionally deceived the Superior Court by submitting an altered and
fabricated video that does not show the entire incident and portrays the narrative that the
Defendant did in fact make a false report, when in reality, the Defendant did not. By
intentionally excluding the surrounding circumstances from the video and his complaint,
the Plaintiff tried to hoodwink this court. Indeed, the Plaintiff, in an official document
submitted to the courts, lies. He climbed a ladder at the scene and we have video evidence
to prove it.
35. The Plaintiff intentionally deceived the Superior Court to secure an unlawful gain, we
know this because the Plaintiff’s Civil complaint requests that the Defendant pays him a
sum of money for supposed misconduct. We know that the Defendant’s actions were
lawful and he did nothing wrong. The only person who did wrong is the Plaintiff through
submitting a perjured complaint to this court. He knows if he told the truth, he wouldn’t
be able to sue government officials to get money.
PRAYERS FOR RELIEF
THEREFORE, the Defendant requests the court grant the following relief in order to correct the
Plaintiff’s Fraudulent and Criminal actions, as alleged in this counterclaim:
36. To Declare the Plaintiff is liable for Counterclaim One, for Abusing a Legal Process.
a. Order the Plaintiff to cease all court proceedings that are frivolous, vexatious or
fraudulent, including this one.
37. Injunctive relief with respect to counterclaim one in the form of a restraining order
preventing the Plaintiff from submitting filings or documents to the civil court without a
licensed lawyer first signing off. This court is authorized to issue this relief pursuant to
1 R. Stat. § 3112 (iii).
38. To Declare the Plaintiff is liable for Counterclaim Two, for Civil Fraud.
a. Order the Plaintiff to withdraw all remarks that alleges the Defendant committed
Official Misconduct.
39. Injunctive relief with respect to counterclaim two preventing the Plaintiff from submitting
fraudulent legal documents to the Superior Court.
Dated, 7th January, 2023
Respectfully Submitted.
TOTORO987123
Solicitor General,
Department of Justice
MATTHEWSANDRINGHAM
General Counsel & Captain,
Ridgeway County Fire Department
Counsel for the Defendant
APPENDIX OF EVIDENCE
Exhibit A: Helmet Cam from Dino_Raf
Exhibit B: Civil Complaint from the Plaintiff
Exhibit C: Plaintiff’s Exhibit A
