<p>1 q EXPEDITE
q No Hearing Set
2 Q Hearing is Set:
Time: 9:00 AM
The Honorable Carol Murphy
STATE OF WASHINGTON
THURSTON COUNTY SUPERIOR COURT
STATE DEPARTMENT OF
CORRECTIONS' ANSWER TO
FIRST AMENDED COMPLAINT
FOR INJUNCTIVE RELIEF
13 DEPARTMENT OF CORRECTIONS,
16 DAVID PIERCY,
Defendant, WASHINGTON STATE DEPARTMENT OF CORRECTIONS, by and
19 through its attorneys of record, ROBERT W. FERGUSON, Attorney General, CASSIE B.
20 vanROOJEN, Assistant Attorney General, respectfully submits the following Answer to First
21 Amended Complaint for Injunctive Relief.
Under CR 8(b), Defendant generally denies each allegation of fact in the Plaintiff's
complaint unless the allegation of fact is expressly admitted. Defendant will not respond to
legal arguments contained in the Plaintiff's complaint and denies allegations if it is unclear if
25 Plaintiff is asserting a factual or legal claim.
DEFENDANT WASHINGTON STATE
DEPARTMENT OF CORRECTIONS'
ANSWER TO FIRST AMENDED
COMPLAINT FOR INJUNCTIVE RELIEF
ATTORNEY GENERAL OF WASHINGTON
PO Box 40116
Olympia, WA 98504-0116
Defendant admits that Plaintiff was formerly incarcerated by the Department of
3 Corrections. Defendant further admits that records regarding Rodriguez were produced to-'
4 Piercy in 2016 in response to a public records request. Defendant admits Rodriquez seeks to
5 prevent release of further records to Piercy through this action. Defendant lacks sufficient
6 knowledge or information regarding the remaining allegations in the Summary portion of the
complaint, and therefore denies the same.
NATURE OF ACTION
Defendant admits that Plaintiff purports to bring this action under
10 RCW 42.56.540 and CR 65 to enjoin Defendant form producing records