MARIANNE MOORE, Plaintiff
vs.
WILLIAM HUNT,
JAMES W. RILEY, and
CITY OF BLOOMINGTON

ANSWER BY WILLIAM HUNT


Defendant William Hunt, by his attorney, responds to the allegations of the complaint as follows:
1. Denies the rhetorical allegations in paragraph 1.
2. Admits jurisdiction as alleged in paragraphs 2-4, but denies the allegation that plaintiff's constitutional rights were violated.
3. Admits the allegations contained in paragraph 5-7.
4. Is without sufficient knowledge or information to form a belief as to the truth or falsity of the allegations contained in paragraphs 8-10 of the complaint, and therefore denies them.
5. Admits paragraph 11.
6. Denies paragraph 12.
7. Denies paragraph 13.
8. Denies paragraph 14.
9. Denies paragraph 15.
10. Denies paragraph 16.
11. Denies paragraph 17.
12. Admits paragraph 18.
13. Denies paragraph 19.
14. Denies paragraph 20.
15. Denies paragraph 21.
16. Paragraph 22 contains no allegations.
17. Is without sufficient knowledge or information to form a belief as to the truth or falsity of the allegations contained in paragraphs 23-26 of the complaint, and therefore denies them.
18. Denies paragraphs 27-28.
19. Is without sufficient knowledge or information to form a belief as to the truth or falsity of the allegations contained in paragraph 29 of the complaint, and therefore denies them.
20. Paragraph 30 contains no allegations.
21. Is without sufficient knowledge or information to form a belief as to the truth or falsity of the allegations contained in paragraph 31 of the complaint, and therefore denies them.
22. Denies paragraph 32.
23. Admits paragraph 33.
24. Denies paragraphs 34-35.
25. Is without sufficient knowledge or information to form a belief as to the truth or falsity of the allegations contained in paragraph 36-37 of the complaint, and therefore denies them.
26. Denies paragraph 38.
27. Paragraph 39 contains no allegations.
28. Denies paragraph 40.
29. Is without sufficient knowledge or information to form a belief as to the truth or falsity of the allegations contained in paragraphs 41-42 of the complaint, and therefore denies them.
30. Denies paragraph 43.
31. Is without sufficient knowledge or information to form a belief as to the truth or falsity of the allegations contained in paragraph 44 of the complaint, and therefore denies them.
32. Denies paragraph 45.

FIRST AFFIRMATIVE DEFENSE

33. In the event that defendant Hunt is found to have made sexual advances to Plaintiff as alleged in paragraphs 14-15, he is entitled to qualified immunity because he could not reasonably have known that his private conduct constituted a violation of constitutional law.

SECOND AFFIRMATIVE DEFENSE

34. In the event that defendant Hunt is found to have fired Plaintiff in whole or part because she spoke to a reporter about her sexual harassment complaint and the defendants' response, he is entitled to qualified immunity because firing a disruptive employee did not at the time clearly violate an established constitutional right.

THIRD AFFIRMATIVE DEFENSE

35. In the event that defendant Hunt is found to have given plaintiff a bad recommendation when she applied for another job, he is entitled to qualified immunity because he could not reasonably have known that the giving of a bad recommendation to an employee fired for poor performance violated a constitutional right.

DEMAND FOR JURY TRIAL

Defendant demands a trial by jury on all issues.