Rendered from the court's authenticated repository
Searchable full text
2,912 characters extracted
—
REPLY AND AFFIRMATIVE DEFENSES - 1
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
insertreality
Deputy Solicitor General
Ridgeway Department of Justice
Email: [email protected]
SUPERIOR COURT OF THE STATE OF RIDGEWAY
COUNTY OF RIDGEWAY
Activated113,
Plaintiff,
vs.
canyoudrown,
Defendant
)
)
)
)
)
)
)
)
)
)
Case No.: No. RSC-CV-3038
DEFENSE REPLY TO CIVIL COMPLAINT
AND AFFIRMATIVE DEFENSES
REPLY TO STATEMENT OF FACTS
1. Admitted, Defense demands strict proof thereof.
2. Admitted, Defense demands strict proof thereof.
3. Admitted, Defense demands strict proof thereof.
4. Defense admits that another vehicle made a right turn, the rest of prong 4 is without
knowledge, thus denied, and Defense demands strict proof thereof.
5. Admitted, Defense demands strict proof thereof.
6. Admitted, Defense demands strict proof thereof.
7. Admitted, Defense demands strict proof thereof.
8. Admitted, Defense demands strict proof thereof.
9. Admitted, Defense demands strict proof thereof.
10. Prong 10 consist of legal conclusions rather that factual allegations, and is, therefore, denied.
11. Defendant is without knowledge, therefore denied, Defense demands strict proof thereof.
REPLY AND AFFIRMATIVE DEFENSES - 2
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
REPLY TO FIRST CAUSE OF ACTION
1. The Defendant need not issue a reply, however, to the extend anything in this paragraph can
be used against Defendant, same is denied and demand strict proof thereof.
2. Admitted.
3. Admitted.
4. Denied, Defense demands strict proof thereof.
5. Denied, Defense demands strict proof thereof.
AFFIRMATIVE DEFENSES
The Defendant asserts the following Affirmative Defenses:
FIRST AFFIRMATIVE DEFENSE
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
her individual and official capacity.
SECOND AFFIRMATIVE DEFENSE
To the extent that Plaintiff seeks monetary damages, including punitive and compensatory
damages, the claims set forth in the Complaint are barred because Plaintiff has engaged in acts and
conduct which render him in pari delicto.
THIRD AFFIRMATIVE DEFENSE
To the extent that Plaintiff seeks equitable relief, including injunctions and declaratory relief, the
claims set forth in the Complaint are barred because Plaintiff has engaged in improper conduct regarding
the subject matter of his claim.
RESERVATION OF OTHER AFFIRMATIVE DEFENSES
The answering Defendant reserves the right to allege other affirmative defenses, as it may
become known through the course discovery.
REPLY AND AFFIRMATIVE DEFENSES - 3
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Dated this 2nd day of July, 2024
insertreality
Deputy Solicitor General
Ridgeway Department of
Justice
Document record
File size
122.0 KB
Uploaded
Jun 14, 2024 12:00 PM
Filed
Jun 14, 2024 12:00 PM
Filing code
COMPLAINT
Uploaded by
activated113
Notes
activated113 v. canyoudrown Reply.pdf — archived from the Trello docket (https://trello.com/c/4z5p406W)
