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SUPERIOR COURT OF THE STATE OF RIDGEWAY
BattalionGavin
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DOCKET NO. RSC-AD-2399
Plaintiff
v.
Ridgeway County Fire Department
Defendant
DEFENDANT’S REPLY TO THE ADMINISTRATIVE COMPLAINT
JURISDICTION AND VENUE
1. Admit
2. Admit
3. Admit
4. Admit
FACTUAL ALLEGATIONS
5. Admit
6. Admit
7. Deny; Plaintiff’s application was denied because they failed the “Final Screening” phase of the
application process which involves a background check conducted by an employee of the
Internal Review Board.
8. Admit
9. Deny; Plaintiff does not actively serve as a law enforcement officer, and their record is not
flawless in that they were criminally indicted for several felony charges in October, 2022 and
again in February, 2023.
10. Admit
11. Admit
12. Deny; Plaintiff’s background check did not satisfy statutory background check requirements
under 2 R. Stat. § 3235, specifically sub-section viii.
13. Admit
CAUSES OF ACTION
14. Deny; Defendant denies that Plaintiff is entitled to relief under 2 R. Stat. § 3240 for the reasons
described above.
15. Admit
16. Deny; 2 R. Stat. § 3233 establishes the criteria under which a person’s activity outside of the
State of Ridgeway can be evaluated during a background check.
17. Deny; see paragraph 12
18. Deny; it is a requirement that all applicants pass a background check in order to be employed
19. Deny; Defendant denies that Plaintiff is entitled to relief for the tort of “impediation of
privileges” for the reasons described above.
20. Admit
21. Deny; see paragraph 12
Respectfully submitted,
/s/ Hecxtro
Hecxtro, Esq.
Deputy Attorney General
Ridgeway Department of Justice
Counsel for the Defendant
Document record
File size
80.9 KB
Uploaded
Mar 5, 2024 12:00 PM
Filed
Mar 5, 2024 12:00 PM
Filing code
ADMINISTRATIVE_APPLICATION
Uploaded by
battaliongavin
Notes
Reply.pdf — archived from the Trello docket (https://trello.com/c/Gphtl582)
