Ridgeway Unified Courts

JUDICIAL COUNCIL OF RIDGEWAY

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IN THE SUPERIOR COURT OF RIDGEWAY CYBERPHILIAC, Plaintiff, v. MATRIX_OC, in his individual capacity and quasi-official capacity as Commander-in-Chief of the Ridgeway National Guard, Defendant. § § § § § § § § § § § § Civil Action No. RSC-CV-3153 DEFENDANT’S ANSWER TO COMPLAINT AND AFFIRMATIVE DEFENSES Pursuant to Rid. R. Civ. P. 7(a), Defendant Matrix_Oc hereby submits his response and affirmative defenses to the numbered paragraphs of Plaintiff’s Complaint. STATEMENT OF FACTS 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted. 6. Admitted. 7. Admitted. 8. Admitted. 9. Admitted. 10. Admitted. 11. Admitted. 12. Admitted. 13. Admitted and denied. It is admitted that the swing of the baton injured Plaintiff. It is denied that the baton inflicted injury upon Dataglitchs. 14. Admitted and denied. It is admitted they fled to the vehicle. It is denied—or, unknown— why they fled the vehicle or for what purpose. 15. Admitted. 16. Admitted. 17. Denied. 18. Admitted. 19. Denied. 20. Denied. 21. Admitted. 22. Paragraph 22 draws a legal conclusion to which no response is required. If a response is required, Paragraph 22 is denied. 23. Paragraph 23 draws a legal conclusion to which no response is required. If a response is required, Paragraph 23 is denied. 24. Paragraph 24 draws a legal conclusion to which no response is required. If a response is required, Paragraph 24 is denied. 25. Paragraph 25 draws a legal conclusion to which no response is required. If a response is required, Paragraph 25 is denied. 26. Paragraph 26 draws a legal conclusion to which no response is required. If a response is required, Paragraph 26 is denied. JURISDICTION AND VENUE 27. Admitted. 28. Admitted. 29. Admitted. PARTIES 30. Admitted. 31. Admitted. FIRST CAUSE OF ACTION Battery (Violation of Rid. Civil Claims Act, 1 R. Stat. § 3102) 32. Defendant incorporates by reference its answers to the preceding Paragraphs as if set forth at length herein 33. Denied. Paragraph 33 states conclusions of law to which no responsive pleading is required. To the extent a responsive pleading is required, the allegations in Paragraph 33 is denied. 34. Denied. Paragraph 34 states conclusions of law to which no responsive pleading is required. To the extent a responsive pleading is required, the allegations in Paragraph 34 is denied. SECOND CAUSE OF ACTION Deprivation of Rights (Violation of Rid. Civil Claims Act, 1 R. Stat. § 3115) 35. Defendant incorporates by reference its answers to the preceding Paragraphs as if set forth at length herein. 36. Denied. Paragraph 36 states conclusions of law to which no responsive pleading is required. To the extent a responsive pleading is required, the allegations in Paragraph 36 is denied. 37. Denied. Paragraph 37 states conclusions of law to which no responsive pleading is required. To the extent a responsive pleading is required, the allegations in Paragraph 37 is denied. THIRD CAUSE OF ACTION Official Misconduct (Violation of Rid. Civil Claims Act, 1 R. Stat. § 3114) 38. Defendant incorporates by reference its answers to the preceding Paragraphs as if set forth at length herein. 39. Denied. Paragraph 39 states conclusions of law to which no responsive pleading is required. To the extent a responsive pleading is required, the allegations in Paragraph 39 is denied. 40. Denied. Paragraph 40 states conclusions of law to which no responsive pleading is required. To the extent a responsive pleading is required, the allegations in Paragraph 40 is denied. PRAYER FOR RELIEF WHEREFORE, Defendant denies that Plaintiff is entitled to any of the relief requested. AFFIRMATIVE DEFENSES First Affirmative Defense 1. 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.

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