Ridgeway Unified Courts

JUDICIAL COUNCIL OF RIDGEWAY

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SUPERIOR COURT OF RIDGEWAY Civil Action No. RSC-CV-2874 DEFENDANT’S FULL ANSWER AND AFFIRMATIVE DEFENSES Pursuant to Rid. R. Civ. P. 7(a), the Solicitor General, representing Defendant TacticalDankPatriot, hereby submits their response and affirmative defenses to the numbered paragraphs of Plaintiff’s Complaint. NATURE OF THE ACTION 1. Paragraph 1 contains factual and introductory substance which hinges on legal conclusions to which no response is required. FACTUAL ALLEGATIONS 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted. 6. Admitted and denied. Defendant admits that he detained plaintiff but denies that he aggressively “hauled” the plaintiff; at all times, it was permissible under department use of force modules and in accordance with the law. 7. Admitted. 8. Admitted. WHERESPIZZA_YT, Plaintiff, v. TACTICALDANKPATRIOT, Defendant. 9. Admitted. 10.Admitted. 11.Admitted. 12.Paragraph 12 contains a recital of the challenged state law to which no response is warranted. In the event a response is warranted, it is admitted that Paragraph 12 is an accurate recital of the challenged provision here. 13.Paragraph 13 contains a legal conclusion to which no response is required. In the event that a response is required, Paragraph 13 is denied. JURISDICTION & VENUE 14.Admitted. 15.Admitted. 16.Admitted and denied. It is admitted that the venue is appropriate, but it is denied that any tortious acts or omissions occurred. PARTIES 17.Admitted. 18.Admitted. 19.Admitted. FIRST CAUSE OF ACTION (1 R. Stat. § 3201) 20.All paragraphs under this heading are denied. Defendant asserts that Plaintiffs are not entitled to any relief. AFFIRMATIVE DEFENSES 21. 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 22.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). Dated: May 19, 2024. Palmer, Ridgeway. Respectfully submitted, /s/ S. Stickza Stickza Solicitor General Ridgeway Department of Justice 1 County Annex Palmer, Ridgeway 33368 Counsel for Defendant

RSC-CV-2874_-_Answer_to_Complaint.pdf

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