Ridgeway Unified Courts

JUDICIAL COUNCIL OF RIDGEWAY

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SUPERIOR COURT OF RIDGEWAY Civil Action No. RSC-CV-2654 DEFENDANT’S FULL ANSWER AND AFFIRMATIVE DEFENSES Pursuant to Rid. R. Civ. P. 7(a), ImThunderr, proceeding by and through their undersigned counsel, hereby submits their response to the numbered paragraphs of Plaintiff’s Complaint. VERIFIED COMPLAINT AND PETITION FOR WRIT OF HABEAS CORPUS The introductory paragraph of Plaintiff’s Complaint contains no substantive factual arguments and draws legal conclusions to which no response is warranted. In the event a response is warranted, Defendant denies the first header. THE INCIDENT 1. Admitted. 2. Admitted. 3. Admitted. 4. Denied. JURISDICTION & VENUE 5. Admitted. 6. Admitted. SEAL_LOVE, Plaintiff, v. IMTHUNDERR, Defendant. PARTIES 7. Admitted. 8. Admitted. FIRST CAUSE OF ACTION (Official Misconduct) 9. All paragraphs under this heading are denied. Defendant asserts that Plaintiffs are not entitled to any relief. SECOND CAUSE OF ACTION (Habeas Corpus) 10.All paragraphs under this heading are denied. Defendant asserts that Plaintiffs are not entitled to any relief. AFFIRMATIVE DEFENSES 11. Defendant sets forth his 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 12. The Second Cause of Action for habeas remedy fails to state a claim upon which relief can be granted. Second Affirmative Defense 13. This action is barred to the extent that Plaintiff’s habeas remedy is not sufficiently plead under state law. Third Affirmative Defense 14. This action is barred because Defendant had good faith to believe that his actions were, at all times during the arrest, reasonable and in compliance with state law. Fourth Affirmative Defense 15.To the extent that Plaintiff seeks punitive damages against Defendant, Plaintiff’s recovery of such damages is limited by Defendant’s immunity from personal liability for actions undertaken in both his individual and official capacity (quasi). PRAYER WHEREFORE, considering the premises set forth herein, Defendant prays that his answer be deemed good and sufficient and all claims by Plaintiff against Defendant be dismissed, with prejudice, and such other and further relief, legal and equitable, be awarded in favor of Defendant. Dated: April 15, 2024. Palmer, Ridgeway. Respectfully submitted, /s/ S. Stickza Stickza Solicitor General Ridgeway Department of Justice 1 County Annex Palmer, Ridgeway 33368 Counsel for Defendant

Response_to_Complaint_-_ImThunderr_(II).pdf

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