Beruflich Dokumente
Kultur Dokumente
Defendants.
Defendants Sgt. Bobby Donahue, Sgt. Tom Arnold, Officer Mon Notthakun, and
Officer Marshall Titus and the City of Saint Paul (hereinafter the Defendants), as and
1. Deny each and every allegation, matter and thing contained in said
otherwise explained.
admit that the individual Defendants were sworn police officers employed
by the City of St. Paul, but deny the remaining allegations as constituting
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this pleading.
admit that on July 10, 2016, SPPD officers were attempting to locate a
GMC Yukon bearing license plate number 269 PGH and deny the
4. Deny paragraphs 10, 19 (sentence 4), 23 (sentence 4), 26, 27, 33 (sentence
(sentence 2), 48, 50, 51, 52, 53, 54, 55, 56, 57, 58, 59, 60, 61, 62, 63, 64,
65, 66, 67, 68, 69, 70, 71, 72, 73, 74, and 75 of Plaintiffs Complaint.
5. As to the allegations contained in paragraphs 3, 11, 12, 25, 29, 34 (last two
belief as to the truth thereof, and therefore deny the same to put Plaintiff to
his proof.
paragraphs reference the police squad video and state that said video speaks
for itself and that no further answer is required. Defendants further state
extent that said paragraphs require an answer, Defendants deny all the
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not require an answer in this pleading. To the extent that said paragraphs
AFFIRMATIVE DEFENSES
qualified immunity.
10. That Plaintiffs alleged injuries or damages were caused solely by reason of
necessary under the circumstances and authorized by the laws of the United
11. That even if Defendants are liable to Plaintiff under state law, Defendants
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12. That Plaintiffs Complaint fails to state a cause of action upon which relief
may be granted.
WHEREFORE, Defendants deny liability to the Plaintiff and pray that Plaintiff
take nothing against them by his pretended claim for relief herein, and that Plaintiffs
alleged cause of action be dismissed. Defendants demand judgment in their favor along
with their costs and disbursements incurred herein including attorneys fees pursuant to