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

1. Paragraph 1 is denied.
2. Paragraph 2 is denied.
3. Paragraph 3 is denied.
4. Paragraph 4 is admitted.
5. Paragraph 5 is admitted.
6. Paragraph 6 is admitted.
7. Paragraph 7 is admitted.
8. With respect to paragraph 8, defendant admits he was the Deputy Mayor of the City of Bloomington, and denies the remainder of the paragraph.
9. Paragraph 9 is admitted.
10. Paragraph 10 is admitted.
11. Paragraph 11 is admitted.
12. Defendant is without sufficient knowledge or information to form a belief as to the truth or falsity of the allegations contained in paragraph 12 of the complaint, and therefore denies them.
13. Defendant is without sufficient knowledge or information to form a belief as to the truth or falsity of the allegations contained in paragraph 13 of the complaint, and therefore denies them.
14. Defendant is without sufficient knowledge or information to form a belief as to the truth or falsity of the allegations contained in paragraph 14 of the complaint, and therefore denies them.
15. Defendant is without sufficient knowledge or information to form a belief as to the truth or falsity of the allegations contained in paragraph 15 of the complaint, and therefore denies them.
16. Defendant is without sufficient knowledge or information to form a belief as to the truth or falsity of the allegation contained in paragraph 16 of the complaint, and therefore denies it.
17. Defendant is without sufficient knowledge or information to form a belief as to the truth or falsity of the allegations contained in paragraph 17 of the complaint, and therefore denies them.
18. Paragraph 18 is admitted.
19. Defendant is without sufficient knowledge or information to form a belief as to the truth or falsity of the allegations contained in paragraph 19 of the complaint, and therefore denies them.
20. Paragraph 20 is denied.
21. Defendant is without sufficient knowledge or information to form a belief as to the truth or falsity of the allegations contained in paragraph 21 of the complaint, and therefore denies them.
22. Paragraph 22 contains no new allegations.
23. Paragraph 23 is denied.
24. Defendant is without sufficient knowledge or information to form a belief as to the truth or falsity of the allegations contained in paragraph 25 of the complaint, and therefore denies them.
25. Paragraph 25 is denied.
26. Paragraph 26 is denied.
27. Paragraph 27 is denied.
28. Paragraph 28 is denied.
29. Paragraph 29 is denied.
30. Paragraph 30 contains no new allegations.
31. Defendant 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.
32. Paragraph 32 is denied.
33. Defendant is without sufficient knowledge or information to form a belief as to the truth or falsity of the allegations contained in paragraph 33 of the complaint, and therefore denies them.
34. Paragraph 34 is denied.
35. Paragraph 35 is denied.
36. Paragraph 36 is denied.
37. Defendant is without sufficient knowledge or information to form a belief as to the truth or falsity of the allegations contained in paragraph 37 of the complaint, and therefore denies them.
38. Paragraph 38 is denied.
39. Paragraph 39 contains no new allegations.
40. Defendant is without sufficient knowledge or information to form a belief as to the truth or falsity of the allegations contained in paragraph 40 of the complaint, and therefore denies them.
41. Paragraph 41 is denied.
42. Defendant is without sufficient knowledge or information to form a belief as to the truth or falsity of the allegations contained in paragraph 42 of the complaint, and therefore denies them.
43. Paragraph 43 is denied.
44. Paragraph 44 is denied.
45. Paragraph 45 is denied.

AFFIRMATIVE DEFENSE -- QUALIFIED IMMUNITY

46. If defendant did the acts alleged in paragraphs 23-28, those acts did not violate a clearly established constitutional right of the Plaintiff.
47. If defendant did the acts alleged in paragraphs 23-28, and those acts constituted a violation of Plaintiff's constitutional rights, defendant could not reasonably have known his conduct violated Plaintiff's constitutional rights.
48. If defendant did the act alleged in paragraph 34, that act did not violate a clearly established constitutional right of the Plaintiff.
49. If defendant did the act alleged in paragraph 34, and that act constituted a violation of Plaintiff's constitutional rights, defendant could not reasonably have known his conduct violated Plaintiff's constitutional rights.

WHEREFORE defendant prays that the complaint be dismissed.