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5:13-cv-00077 #23

5:13-cv-00077 #23

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Published by Equality Case Files
Doc 23 - Answer of of State Registrar Janet M. Rainey
Doc 23 - Answer of of State Registrar Janet M. Rainey

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Categories:Types, Business/Law
Published by: Equality Case Files on Aug 28, 2013
Copyright:Attribution Non-commercial

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10/06/2013

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IN THE UNITED STATES DISTRICT COURTFOR THE WESTERN DISTRICT OF VIRGINIAHARRISONBURG DIVISION
JOANNE HARRIS,
et al.
, ))Plaintiffs, )
)
v. ) Civil Action No. 5:13-cv-00077)ROBERT F. McDONNELL, JANET M. )RAINEY, and THOMAS E. ROBERTS, )in their official capacities ))Defendants. )
ANSWER OF JANET M. RAINEY
COMES NOW, Janet M. Rainey, by counsel, in her official capacity, and for her Answer states as follows:1.
 
Janet M. Rainey, the State Registrar, is without knowledge or informationsufficient to form a belief about the truth of allegations personal to Plaintiffs and this statementhas the effect of a denial. Defendant Rainey admits that this action purports to be pursuant to 42U.S.C. § 1983 but denies any violation of the Fourteenth Amendment and further denies that thiscase is proper for class action treatment.2.
 
Defendant Rainey admits that marriage is a fundamental social institution whichantedates the state. She is without knowledge or information sufficient to form a belief about thetruth of the allegations personal to Plaintiffs and this statement has the effect of a denial. Theremaining allegations are denied.3.
 
Defendant Rainey admits that the Constitution of Virginia and the relevantstatutes define marriage as between one man and one woman. The remaining allegations aredenied.
Case 5:13-cv-00077-MFU-RSB Document 23 Filed 08/16/13 Page 1 of 18 Pageid#: 83
 
2
 
4.
 
Defendant Rainey is without knowledge or information sufficient to form a belief about the truth of the allegations personal to Plaintiffs and this statement has the effect of adenial. She further denies that Virginia's definition of marriage causes them legal injury.5.
 
Paragraph 5 consists of conclusory allegations which require no response. To theextent that a response is required it is denied that the miscegenation laws or married women's property acts or the other allegations therein provide a rule of decision for this case.6.
 
Defendant Rainey is without knowledge or information sufficient to form a belief about the truth of allegations personal to Plaintiffs and this statement has the effect of a denial.Defendant Rainey admits that this action purports to be pursuant to 42 U.S.C. § 1983 but deniesany violation of the Fourteenth Amendment and further denies that this case is proper for classaction treatment.7.
 
Defendant Rainey is without knowledge or information sufficient to form a belief about the truth of allegations personal to Plaintiffs and this statement has the effect of a denial.8.
 
Defendant Rainey is without knowledge or information sufficient to form a belief about the truth of allegations personal to Plaintiffs and this statement has the effect of a denial.9.
 
Defendant Rainey is without knowledge or information sufficient to form a belief about the truth of allegations personal to Plaintiffs and this statement has the effect of a denial.10.
 
Defendant Rainey is without knowledge or information sufficient to form a belief about the truth of allegations personal to Plaintiffs and this statement has the effect of a denial.11.
 
Defendant Rainey is without knowledge or information sufficient to form a belief about the truth of allegations personal to Plaintiffs and this statement has the effect of a denial.12.
 
Defendant Rainey is without knowledge or information sufficient to form a belief about the truth of allegations personal to Plaintiffs and this statement has the effect of a denial.
Case 5:13-cv-00077-MFU-RSB Document 23 Filed 08/16/13 Page 2 of 18 Pageid#: 84
 
3
 
13.
 
Defendant Rainey is without knowledge or information sufficient to form a belief about the truth of allegations personal to Plaintiffs and this statement has the effect of a denial.14.
 
Defendant Rainey is without knowledge or information sufficient to form a belief about the truth of allegations personal to Plaintiffs and this statement has the effect of a denial.15.
 
Defendant Rainey is without knowledge or information sufficient to form a belief about the truth of allegations personal to Plaintiffs and this statement has the effect of a denial.16.
 
Defendant Rainey is without knowledge or information sufficient to form a belief about the truth of allegations personal to Plaintiffs and this statement has the effect of a denial.17.
 
Defendant Rainey is without knowledge or information sufficient to form a belief about the truth of allegations personal to Plaintiffs and this statement has the effect of a denial.18.
 
Defendant Rainey is without knowledge or information sufficient to form a belief about the truth of allegations personal to Plaintiffs and this statement has the effect of a denial.19.
 
Defendant Rainey is without knowledge or information sufficient to form a belief about the truth of allegations personal to Plaintiffs and this statement has the effect of a denial.20.
 
Defendant Rainey is without knowledge or information sufficient to form a belief about the truth of allegations personal to Plaintiffs and this statement has the effect of a denial.21.
 
Defendant Rainey is without knowledge or information sufficient to form a belief about the truth of allegations personal to Plaintiffs and this statement has the effect of a denial.22.
 
Defendant Rainey is without knowledge or information sufficient to form a belief about the truth of allegations personal to Plaintiffs and this statement has the effect of a denial.23.
 
Defendant Rainey is without knowledge or information sufficient to form a belief about the truth of allegations personal to Plaintiffs and this statement has the effect of a denial.
Case 5:13-cv-00077-MFU-RSB Document 23 Filed 08/16/13 Page 3 of 18 Pageid#: 85

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