IN THE CIRCUIT COURT, FOURTHJUDICIAL CIRCUIT, IN AND FOR DUVAL COUNTY, FLORIDACASE NO.: 16-2013-CA-007407DIVISION:BERNARD ALBERT KRUIDBOS,Plaintiff,v.ANGELA B. COREY, in her official capacity asSTATE ATTORNEY FOR THE FOURTHJUDICIAL CIRCUIT OF FLORIDA,Defendant./DEFENDANT ANGELA B. COREY’S, IN HER OFFICIAL CAPACITY AS STATEATTORNEY FOR THE FOURTH JUDICIAL CIRCUIT OF FLORIDA, ANSWER ANDAFFIRMATIVE AND OTHER DEFENSES TO COUNT II IN THE AMENDEDCOMPLAINT AND COUNTERCLAIMS
Pursuant to Fla. R. Civ. P. 1.110(c) and (d), Defendant Angela B. Corey, in her OfficialCapacity as State Attorney for the Fourth Judicial Circuit of Florida (“State Attorney”), answersCount II in the Amended Complaint and asserts affirmative and other defenses thereto and asgrounds states as follows:As to the three paragraphs preceding Count I, State Attorney admits the allegations inthose paragraphs except that she denies any wrongdoing whatsoever and asserts that Plaintiff violated critical job duties, engaged in egregious conduct, and exposed the public to risk of serious harm, leaving State Attorney with no choice but to terminate Plaintiff’s employment.
State Attorney filed a motion to dismiss Count I in the Amended Complaint; thus, paragraphs 1-8, which pertain toCount I in the Amended Complaint, need not be answered in this pleading.
Filing # 10369258 Electronically Filed 02/17/2014 08:44:20 PM