Ridgeway Unified Courts

JUDICIAL COUNCIL OF RIDGEWAY

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SUPERIOR COURT OF RIDGEWAY Civil Action No. DEFENDANTS’ FULL ANSWER AND AFFIRMATIVE DEFENSES Pursuant to Rid. R. Civ. P. 7(a), Defendants ggutslasher and Haunntings, by and through their undersigned attorneys, hereby submit their response to the numbered paragraphs of Plaintiff’s Complaint. INTRODUCTION 1. Defendants are without knowledge or information to form a sufficient belief as to the validity of the allegations set forth in Paragraph 1. 2. Denied. JURISDICTION & VENUE 3. Admitted. 4. Admitted/Denied. Defendants deny that any tortious actions took place at all. PARTIES 5. Defendants are without knowledge or information to form a sufficient belief as to the validity of the allegations set forth in Paragraph 5. 6. Admitted. 7. Admitted. FALCON_2S, Plaintiff, v. ORBXS; GGUTSLASHER; HAUNNTINGS, Defendants. 8. Admitted. CAUSES OF ACTION 9. All paragraphs under this heading are denied. Defendant asserts that Plaintiffs are not entitled to any relief. AFFIRMATIVE DEFENSES 10. Defendants set 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 Failure to State a Claim 11. Plaintiff’s Complaint should be dismissed in its entirety because it fails to state a claim upon which relief can be granted. a. “[T]hreadbare recitals of the elements of a cause of action, supported by mere conclusory statements, do not suffice” Ashcroft v. Iqbal, 556 U.S. 662, 1950 (2009). Indeed, even though this Court must take all of the factual allegations in the complaint as true, it is not “bound to accept as true a legal conclusion couched as a factual allegation.” Id. at 678. Furthermore, the rules generally require a “plausible 'short and plain' statement of the plaintiffs claim, not an exposition of his legal argument.” Skinner v. Switzer, 562 U.S. 2011, 7 (2011).” 12. Plaintiff’s First and Second Causes of Action are a mere recitation of the elements for his claim, constituting an insufficient pleading of his case. WHEREFORE, Defendant respectfully requests that this Court: a. Dismiss Plaintiff’s Complaint with Prejudice and enter judgment in Defendant’s favor; b. Award Defendants all attorneys’ fees, costs, and interests incurred and associated with the above-entitled matter; and c. Grant such and further relief deemed necessary to effectuate dismissal and repayment of fees by this Court. Dated: February 16, 2024 Palmer, Ridgeway. Respectfully Submitted. /s/ S. Stickza Stickza, Esq. Counsel of Record Cohn, Cicero, & Goodrich LLC Suite 1B, Palmer Suites Palmer, RW 27841 (111) 222-3333 [email protected] Attorney for Defendants

Answer_to_Complaint_-_Orxbs%3B_Ggut%3B_Haunntings.pdf

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