ADMINISTRATIVE COURT OF RIDGEWAY
Administrative Claim No. RSC-AD-2774
RESPONDENT’S FULL ANSWER TO ADMINISTRATIVE COMPLAINT
Pursuant to 2 R. Stat. § 3305, the Palmer Police Department, proceeding by
and through the Ridgeway Solicitor General, hereby submits their response to the
numbered paragraphs of Petitioner’s Complaint.
INTRODUCTION
1. Paragraph 1 contains a legal conclusion to which no response is required. In the
event that a response is required, Paragraph 1 is denied.
2. Denied.
3. Paragraph 3 contains factual substance to which no response is required.
4. Paragraph 4 contains a legal conclusion to which no response is required. In the
event that a response is required, Paragraph 4 is denied.
5. Paragraph 5 contains a legal conclusion to which no response is required. In the
event that a response is required, Paragraph 5 is denied.
JURISDICTION & VENUE
6. Admitted.
7. Admitted.
8. Admitted.
9. Admitted.
BLOXWATCH_CD; VARKRUS,
Petitioners,
v.
PALMER POLICE DEPARTMENT,
Respondent.
PARTIES
10.Admitted.
11.Admitted.
12.Admitted.
FACTS
I. Employment Cycle.
13.Admitted.
14.Admitted.
15.Admitted.
16.Admitted/Denied. Palmer Police Department admits that there are three stages
but denies that satisfactory performance of those stages guarantee employment.
17.Admitted.
18.Admitted.
19.Admitted.
20.Admitted.
21.Admitted.
II. BloxWatch_CD.
22.Admitted/Denied. Palmer Police Department admits that BloxWatch_CD applied
but denies that he had any good-faith intentions because such a conclusion,
lacking evidence to the contrary, would be speculative in nature.
23.Admitted.
24.Admitted.
25.Admitted.
26.Admitted.
27.Admitted.
28.Paragraph 28 contains factual substance to which no response is required.
29.Paragraph 29 contains factual substance to which no response is required.
30.Paragraph 30 contains factual substance to which no response is required.
31.Admitted.
32.Paragraph 32 contains factual substance to which no response is required.
33.Paragraph 33 contains factual substance to which no response is required.
34.Admitted.
35.Admitted.
36.Paragraph 36 contains factual substance to which no response is required.
37.Paragraph 37 contains factual substance to which no response is required.
38.Paragraph 38 contains a legal conclusion to which no response is required. In the
event that a response is required, Paragraph 38 is denied.
39.Paragraph 39 contains a legal conclusion to which no response is required. In the
event that a response is required, Paragraph 39 is denied.
40.Paragraph 40 contains a legal conclusion to which no response is required. In the
event that a response is required, Paragraph 40 is denied.
III. Varkrus.
41.Admitted/Denied. Palmer Police Department admits that Varkrus applied but
denies that he had any good-faith intentions because such a conclusion, lacking
evidence to the contrary, would be speculative in nature.
42.Admitted.
43.Admitted.
44.Admitted.
45.Admitted.
46.Admitted.
47.Paragraph 47 contains factual substance to which no response is required.
48.Paragraph 48 contains factual substance to which no response is required.
49.Paragraph 49 contains factual substance to which no response is required.
50.Admitted.
51.Paragraph 51 contains factual substance to which no response is required.
52.Paragraph 52 contains factual substance to which no response is required.
53.Admitted.
54.Admitted.
55.Paragraph 55 contains factual substance to which no response is required.
56.Paragraph 56 contains factual substance to which no response is required.
57.Paragraph 57 contains factual substance to which no response is required.
58.Paragraph 58 contains a legal conclusion to which no response is required. In the
event that a response is required, Paragraph 58 is denied.
59.Paragraph 59 contains a legal conclusion to which no response is required. In the
event that a response is required, Paragraph 59 is denied.
60.Paragraph 60 contains a legal conclusion to which no response is required. In the
event that a response is required, Paragraph 60 is denied.
IV. Varkrus.
61.Admitted.
62.Denied. Palmer Police Department carefully reviewed the applications of
BloxWatch_CD and Varkrus after complaints of the same. By using its
department-wide methods of background checks, it affirmed its previous denial.
63.Paragraph 63 contains factual substance to which no response is required.
64.Paragraph 64 contains factual substance to which no response is required.
FIRST CAUSE OF ACTION
Unfair Hiring Practices – 2 R. Stat. § 3241
65.Paragraph 65 contains factual substance to which no response is required.
66.Admitted.
67.Admitted.
68.Admitted.
69.Paragraph 69 contains a legal conclusion to which no response is required. In the
event that a response is required, Paragraph 69 is denied.
70.Paragraph 79 contains a legal conclusion to which no response is required. In the
event that a response is required, Paragraph 70 is admitted.
I. BloxWatch_CD
71.Admitted.
72.Paragraph 72 contains a legal conclusion to which no response is required. In the
event that a response is required, Paragraph 72 is admitted.
73.Denied. Palmer Police Department employs a variety of methods and balances to
determine if an applicant is within the scope of an alternative account. Broad
discretion is left to agencies to determine what falls in such a scope.
74.Paragraph 74 contains factual substance to which no response is required.
75.Paragraph 75 contains factual substance to which no response is required.
76.Paragraph 76 contains factual substance to which no response is required.
77.Paragraph 77 contains factual substance to which no response is required.
78.Paragraph 78 contains a legal conclusion to which no response is required. In the
event that a response is required, Paragraph 78 is denied.
II. Varkrus.
79.Admitted.
80.Paragraph 72 contains a legal conclusion to which no response is required. In the
event that a response is required, Paragraph 80 is admitted.
81.Denied. Palmer Police Department employs a variety of methods and balances to
determine if an applicant is within the scope of an alternative account. Broad
discretion is left to agencies to determine what falls in such a scope.
82.Paragraph 82 contains factual substance to which no response is required.
83.Paragraph 83 contains factual substance to which no response is required.
84.Paragraph 84 contains a legal conclusion to which no response is required. In the
event that a response is required, Paragraph 84 is denied.
AFFIRMATIVE DEFENSES
1. Respondent sets forth its affirmative defenses. By setting forth these affirmative
defenses, Respondent 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. Respondent reserves the right to assert further affirmative defenses as they
become evident through discovery investigation.
Third Affirmative Defense
4. All actions taken by Respondent with respect to Petitioners were supported by
legitimate state interests.
Fourth Affirmative Defense
5. Respondent’s actions were in good faith conformity with and/or reliance on
administrative regulation, order, ruling, approval, interpretation, or practice.
Dated: May 7, 2024.
Palmer, Ridgeway.
Respectfully submitted,
/s/ S. Stickza
Stickza
Solicitor General
Ridgeway Department of Justice
1 County Annex
Palmer, Ridgeway 33368
