VIRGINIA: IN THE CIRCUIT COURT FOR THE CITY OF LYNCHBURG Ce _) ) ) Plaintiff, ) ) v. ) Case No. CL21000803-00 > ) OFFICER ) ) Defendant. ) ANSWER Defendant Officer QUININE by counsel, respectfully submits this answer to (GREE § ned Complaint: 1. Defendant admits the allegations in paragraph 1 of the Amended Complaint Plainti 2. With respect to paragraph 2, Defendant admits only that he initially made the traffic stop of Plaintiff for reckless driving and suspected eluding, Defendant denies the remaining allegations in paragraph 2. 3. With respect to the allegations in paragraph 3, Defendant admits only that he ordered Plaintiff to exit the vehicle after initiating the traflic stop. Defendant denies the remaining allegations in paragraph 3. 4, Defendant denies the allegations in paragraph 4 5. Defendant denies the allegations in paragraph 5. 6 Defendant denies all allegations in the Amended Complaint not expressly admitted herein. 7. Defendant denies that he is indebted or liable to Plaintiff for the amounts or reasons set forth in the Amended Complaint or for any other amounts or reasons whatsoever.8. Defendant avers that he cannot be held liable by virtue of the doctrines of sovereign, qualified, govemmental, and/or good faith immunity. 9. Defendant avers that he acted lawfully and with legal justification at all times referenced in the Amended Complaint. 10. Defendant avers that his conduct, at all times referenced in the Amended Complaint, was in good faith and reasonable under the cireumstances. 11. Defendant denies that Plaintiff'is entitled to punitive damages or to any damages whatsoever. 12. Defendant reserves the right to amend this answer or rely upon any other defenses that may become available or apparent during the proceedings in this case, including discovery. WHEREFORE, Defendant Officer NEEM respectfully requests that the Court dismiss the Amended Complaint with prejudice and enter judgment in his favor. OFFKEI By: ‘Counsel Julian F. Harf (VSB #90775) Guynn, Waddell, Carroll & Lockaby, P.C. 4158. College Avenuc Salem, VA 24153 Phone: 540-387-2320 Fax: 540-389-2350 Email: julianh@guynnwaddell.com Counsel for Defendant MAY 27 2022 UE ::| Ay ohThereby certify that I have this 26th day of May, 2022, served the foregoing by mailing a true and correct copy of the same to: W. Cameron Warren, Esq. Pack Law Group 423 East Main Street Bedford, VA. 24523 Counsel for Plaintiff Julian F. Har