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SUPERIOR COURT OF THE STATE OF RIDGEWAY
andysofun
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DOCKET NO. RSC-AD-2534
Plaintiff
v.
Palmer Police Department
Defendant
DEFENDANT’S REPLY TO THE ADMINISTRATIVE COMPLAINT
JURISDICTION
1. Deny; 2 R. Stat. § 3117 does not provide this court jurisdiction to hear this matter.
2. Admit
3. Admit
STATEMENT OF FACTS
4. Admit
5. Admit
6. Admit
7. Deny; the issuance of the plaintiff’s administrative demerit was posted in the “dept-actions”
channel of the Palmer Police Department Discord server, a channel which is publicly available
for anyone to view.
8. Admit
9. Admit
10. Admit
11. Admit
STATEMENT OF POLICY AND LAW
12. Deny; an announcement was made on or about March 9th by Corporal Xotlkz stating that patrol
logs were due Sunday, March 10th, at 11:59 CET/CEST. A hyperlink was included in this
message which provided the patrol log deadline in the individual user’s local timezone. A second
“reminder” message was posted twenty-four hours prior to the deadline to submit patrol logs.
Plaintiff’s patrol log was submitted after this deadline. The patrol log deadline was not
ambiguous nor was the plaintiff’s failure to enter a patrol log by that deadline.
13. Admit
14. Admit
15. Admit
16. Admit
17. Deny; department command had given prior notice to all officers that the end of the patrol log
cycle was on Sunday, March 10th, at 11:59 CET/CEST. Plaintiff did not submit their patrol log
by that deadline.
18. Deny; see paragraph 17.
19. Deny; the policy the plaintiff was issued an administrative demerit under is clear and
unambiguous in that one patrol log, at least thirty minutes in length, must be submitted per week.
Department command has the authority to determine when the deadline for patrol logs is.
Department command gave the plaintiff adequate notice of their determined deadline for patrol
logs.
20. Admit
21. Deny; the plaintiff’s inference was not reasonable because an announcement was made by
department command indicating when their predetermined deadline for patrol logs was. It is not
reasonable to disregard this announcement nor the “reminder” announcement posted.
22. Deny; see paragraphs 12, 17, 19, and 21.
CONCLUSION
23. Deny; see paragraphs 12, 17, 19, and 21.
24. Deny; the defendant denies that the plaintiff is entitled to any relief for the reasons described in
detail above.
Respectfully submitted,
/s/ Hecxtro
Hecxtro, Esq.
Deputy Attorney General
Ridgeway Department of Justice
Counsel of Record
Document record
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Mar 23, 2024 12:00 PM
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Mar 23, 2024 12:00 PM
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ADMINISTRATIVE_APPLICATION
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andysofun
Notes
andysofun v. PPD Reply.pdf — archived from the Trello docket (https://trello.com/c/xakIY9IF)
