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SUPERIOR COURT OF RIDGEWAY
Civil Action No. RSC-CV-2780
DEFENDANT’S FULL ANSWER AND AFFIRMATIVE DEFENSES
Pursuant to Rid. R. Civ. P. 7(a), Defendant KeenPack, proceeding by and
through the Ridgeway Solicitor General, hereby submits their response to the
numbered paragraphs of Plaintiff’s Complaint.
PARTIES
1. Admitted.
2. Admitted.
JURISDICTION AND VENUE
3. Admitted.
4. Admitted.
FACTS
5. Admitted.
6. Admitted.
7. Admitted.
8. Admitted.
9. Admitted.
10.Admitted.
ROBIN5D,
Plaintiff,
v.
KEENPACK,
Defendant.
CAUSE OF ACTION
FIRST CAUSE OF ACTION
1 R. Stat. § 3114 – Official Misconduct
11.All paragraphs under this heading are denied. Defendant asserts that Plaintiffs are
not entitled to any relief.
AFFIRMATIVE DEFENSES
1. Defendant sets forth its 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
2. The Complaint fails to state a claim upon which relief may be granted.
Second Affirmative Defense
3. 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).
Third Affirmative Defense
4. To the extent applicable, Defendants assert and preserve the defenses of absolute
and qualified immunity.
Fourth Affirmative Defense
5. Defendants are immune from liability because they acted at all times in good
faith, lawfully, and in the performance of their official duties.
Fifth Affirmative Defense
6. Defendant reserves the right to assert further affirmative defenses as they become
evident through discovery investigation.
Dated: May 7, 2024.
Palmer, Ridgeway.
Respectfully submitted,
/s/ S. Stickza
Stickza
Solicitor General
Ridgeway Department of Justice
1 County Annex
Palmer, Ridgeway 33368
Document record
File size
161.1 KB
Uploaded
May 2, 2024 12:00 PM
Filed
May 2, 2024 12:00 PM
Filing code
COMPLAINT
Uploaded by
Robin5D
Notes
RSC-CV-2780 - Answer to Complaint.pdf — archived from the Trello docket (https://trello.com/c/nNhRGpKy)
