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DOCKET NO.: (X06) UWY-CV21-5028294-S : SUPERIOR COURT
NANCY BURTON : COMPLEX LITIGATION DOCKET
vs. : AT WATERBURY
DAVID PHILIP MASON, ET AL. : MAY 12, 2022
REDDING DEFENDANTS’ ANSWER AND SPECIAL DEFENSES
Pursuant to Practice Book § 10-49, defendants Town of Redding, First Selectman Julia
Pemberton, and Chief Mark O’Donnell (collectively, the “Redding Defendants”) hereby answer and
assert special defenses to plaintiff’s Fifth Amended Complaint, dated and filed on April 12, 2022 [Doc.
328.00], as follows:
1. As to the allegations of Paragraph 1, the Redding Defendants have insufficient
knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her
proof.
2. As to the allegations of Paragraph 2, the Redding Defendants have insufficient
knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her
proof.
3. As to the allegations of Paragraph 3, the Redding Defendants have insufficient
knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her
proof.
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Karsten & Tallberg, LLC • ATTORNEYS AT LAW
500 ENTERPRISE DRIVE, SUITE 4B • ROCKY HILL, CT 06067 • (860) 233-5600 • FAX: (860) 233-5800 • JURIS NO. 424030
4. As to the allegations of Paragraph 4, the Redding Defendants have insufficient
knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her
proof.
5. As to the allegations of Paragraph 5, the Redding Defendants have insufficient
knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her
proof.
6. As to the allegations of Paragraph 6, the Redding Defendants have insufficient
knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her
proof.
7. As to the allegations of Paragraph 7, the Redding Defendants have insufficient
knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her
proof.
8. As to the allegations of Paragraph 8, the Redding Defendants have insufficient
knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her
proof.
9. As to the allegations of Paragraph 9, the Redding Defendants have insufficient
knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her
proof.
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Karsten & Tallberg, LLC • ATTORNEYS AT LAW
500 ENTERPRISE DRIVE, SUITE 4B • ROCKY HILL, CT 06067 • (860) 233-5600 • FAX: (860) 233-5800 • JURIS NO. 424030
10. As to the allegations of Paragraph 10, the Redding Defendants have insufficient
knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her
proof.
11. As to the allegations of Paragraph 11, the Redding Defendants have insufficient
knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her
proof.
12. As to the allegations of Paragraph 12, the Redding Defendants have insufficient
knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her
proof.
13. As to the allegations of Paragraph 13, the Redding Defendants have insufficient
knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her
proof.
14. As to the allegations of Paragraph 14, the Redding Defendants have insufficient
knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her
proof.
15. As to the allegations of Paragraph 15, the Redding Defendants have insufficient
knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her
proof.
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Karsten & Tallberg, LLC • ATTORNEYS AT LAW
500 ENTERPRISE DRIVE, SUITE 4B • ROCKY HILL, CT 06067 • (860) 233-5600 • FAX: (860) 233-5800 • JURIS NO. 424030
16. As to the allegations of Paragraph 16, the Redding Defendants have insufficient
knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her
proof.
17. As to the allegations of Paragraph 17, the Redding Defendants have insufficient
knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her
proof.
18. As to the allegations of Paragraph 18, the Redding Defendants have insufficient
knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her
proof.
19. As to the allegations of Paragraph 19, the Redding Defendants have insufficient
knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her
proof.
20. As to the allegations of Paragraph 20, the Redding Defendants have insufficient
knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her
proof.
21. As to the allegations of Paragraph 21, the Redding Defendants have insufficient
knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her
proof.
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Karsten & Tallberg, LLC • ATTORNEYS AT LAW
500 ENTERPRISE DRIVE, SUITE 4B • ROCKY HILL, CT 06067 • (860) 233-5600 • FAX: (860) 233-5800 • JURIS NO. 424030
22. As to the allegations of Paragraph 22, the Redding Defendants have insufficient
knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her
proof.
23. As to the allegations of Paragraph 23, the Redding Defendants have insufficient
knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her
proof.
24. So much of Paragraph 24 as alleges, “In September 2017, the Redding Zoning
Commission issued a cease and desist order directing plaintiff to reduce the number of goats on her
property to no more than nine within ten days of said order,” is admitted. As to the remaining
allegations of Paragraph 24, the Redding Defendants have insufficient knowledge or information upon
which to form an opinion or belief and, therefore, leave plaintiff to her proof.
25. As to the allegations of Paragraph 25, the Redding Defendants have insufficient
knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her
proof.
26. As to the allegations of Paragraph 26, the Redding Defendants have insufficient
knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her
proof.
27. So much of Paragraph 27 as alleges, “plaintiff filed a land management plan with the
Redding Zoning Commission” is admitted. As to the remaining allegations of Paragraph 27, the
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Karsten & Tallberg, LLC • ATTORNEYS AT LAW
500 ENTERPRISE DRIVE, SUITE 4B • ROCKY HILL, CT 06067 • (860) 233-5600 • FAX: (860) 233-5800 • JURIS NO. 424030
Redding Defendants have insufficient knowledge or information upon which to form an opinion or
belief and, therefore, leave plaintiff to her proof.
28. As to the allegations of Paragraph 28, the Redding Defendants have insufficient
knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her
proof.
29. As to the allegations of Paragraph 29, the Redding Defendants have insufficient
knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her
proof.
30. As to the allegations of Paragraph 30, the Redding Defendants have insufficient
knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her
proof.
31. As to the allegations of Paragraph 31, the Redding Defendants have insufficient
knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her
proof.
32. As to the allegations of Paragraph 32, the Redding Defendants have insufficient
knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her
proof.
33. As to the allegations of Paragraph 33, the Redding Defendants have insufficient
knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her
proof.
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Karsten & Tallberg, LLC • ATTORNEYS AT LAW
500 ENTERPRISE DRIVE, SUITE 4B • ROCKY HILL, CT 06067 • (860) 233-5600 • FAX: (860) 233-5800 • JURIS NO. 424030
34. As to the allegations of Paragraph 34, the Redding Defendants have insufficient
knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her
proof.
a. So much of Paragraph 34 (a) as alleges, “First Selectman Julia Pemberton did not
respond to the request,” is admitted. As to the remaining allegations of Paragraph 34 (a), the
Redding Defendants have insufficient knowledge or information upon which to form an opinion
or belief and, therefore, leave plaintiff to her proof.
b. So much of Paragraph 34 (b) as alleges, “First Selectman Julia Pemberton did not
respond to the request,” is admitted. As to the remaining allegations of Paragraph 34 (a), the
Redding Defendants have insufficient knowledge or information upon which to form an opinion
or belief and, therefore, leave plaintiff to her proof.
c. So much of Paragraph 34 (c) as alleges, “First Selectman Julia Pemberton did not
respond to the request,” is admitted. As to the remaining allegations of Paragraph 34 (a), the
Redding Defendants have insufficient knowledge or information upon which to form an opinion
or belief and, therefore, leave plaintiff to her proof.
d. As to the allegations of Paragraph 34 (d), the Redding Defendants have
insufficient knowledge or information upon which to form an opinion or belief and, therefore,
leave plaintiff to her proof.
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Karsten & Tallberg, LLC • ATTORNEYS AT LAW
500 ENTERPRISE DRIVE, SUITE 4B • ROCKY HILL, CT 06067 • (860) 233-5600 • FAX: (860) 233-5800 • JURIS NO. 424030
35. As to the allegations of Paragraph 35, the Redding Defendants have insufficient
knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her
proof.
36. As to the allegations of Paragraph 36, the Redding Defendants have insufficient
knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her
proof.
37. As to the allegations of Paragraph 37, the Redding Defendants have insufficient
knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her
proof.
38. So much of Paragraph 38 as alleges, “Defendant Julia Pemberton has served and
continues to serve as First Selectman of the Town of Redding during the period of time pertinent to this
Amended Complaint,” is admitted. The remaining allegations of Paragraph 38 are denied.
39. Paragraph 39 is denied.
40. Paragraph 40 is admitted.
41. As to the allegations of Paragraph 41, the Redding Defendants have insufficient
knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her
proof.
42. As to the allegations of Paragraph 42, the Redding Defendants have insufficient
knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her
proof.
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Karsten & Tallberg, LLC • ATTORNEYS AT LAW
500 ENTERPRISE DRIVE, SUITE 4B • ROCKY HILL, CT 06067 • (860) 233-5600 • FAX: (860) 233-5800 • JURIS NO. 424030
43. Paragraph 43 is admitted.
44. Paragraph 44 is admitted.
45. As to the allegations of Paragraph 45, the Redding Defendants have insufficient
knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her
proof.
46. As to the allegations of Paragraph 46, the Redding Defendants have insufficient
knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her
proof.
a. As to the allegations of Paragraph 46 (a), the Redding Defendants have
insufficient knowledge or information upon which to form an opinion or belief and, therefore,
leave plaintiff to her proof.
b. As to the allegations of Paragraph 46 (b), the Redding Defendants have
insufficient knowledge or information upon which to form an opinion or belief and, therefore,
leave plaintiff to her proof.
c. As to the allegations of Paragraph 46 (c), the Redding Defendants have
insufficient knowledge or information upon which to form an opinion or belief and, therefore,
leave plaintiff to her proof.
d. As to the allegations of Paragraph 46 (d), the Redding Defendants have
insufficient knowledge or information upon which to form an opinion or belief and, therefore,
leave plaintiff to her proof.
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Karsten & Tallberg, LLC • ATTORNEYS AT LAW
500 ENTERPRISE DRIVE, SUITE 4B • ROCKY HILL, CT 06067 • (860) 233-5600 • FAX: (860) 233-5800 • JURIS NO. 424030
e. As to the allegations of Paragraph 46 (e), the Redding Defendants have
insufficient knowledge or information upon which to form an opinion or belief and, therefore,
leave plaintiff to her proof.
f. As to the allegations of Paragraph 46 (f), the Redding Defendants have
insufficient knowledge or information upon which to form an opinion or belief and, therefore,
leave plaintiff to her proof.
g. As to the allegations of Paragraph 46 (g), the Redding Defendants have
insufficient knowledge or information upon which to form an opinion or belief and, therefore,
leave plaintiff to her proof.
h. As to the allegations of Paragraph 46 (h), the Redding Defendants have
insufficient knowledge or information upon which to form an opinion or belief and, therefore,
leave plaintiff to her proof.
i. So much of Paragraph 46 (i) as alleges, “plaintiff filed a complaint with the
defendant Redding Police Chief Mark O’Donnell,” is admitted. As to the remaining allegations
of Paragraph 46 (i), the Redding Defendants have insufficient knowledge or information upon
which to form an opinion or belief and, therefore, leave plaintiff to her proof.
j. As to so much of Paragraph 46 (j) as alleges, “per order of Chief Mark
O’Donnell,” the Redding Defendants have insufficient knowledge or information upon which to
form an opinion or belief and, therefore, leave plaintiff to her proof. The remaining allegations
of Paragraph 46 (j) are admitted.
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Karsten & Tallberg, LLC • ATTORNEYS AT LAW
500 ENTERPRISE DRIVE, SUITE 4B • ROCKY HILL, CT 06067 • (860) 233-5600 • FAX: (860) 233-5800 • JURIS NO. 424030
k. As to the allegations of Paragraph 46 (k), the Redding Defendants have
insufficient knowledge or information upon which to form an opinion or belief and, therefore,
leave plaintiff to her proof.
l. As to the allegations of Paragraph 46 (l), the Redding Defendants have
insufficient knowledge or information upon which to form an opinion or belief and, therefore,
leave plaintiff to her proof.
m. As to so much of Paragraph 46 (m) as alleges, “per defendant chief O’Donnell,”
the Redding Defendants have insufficient knowledge or information upon which to form an
opinion or belief and, therefore, leave plaintiff to her proof. The remaining allegations of
Paragraph 46 (m) are admitted.
47. So much of Paragraph 47 as alleges “On or about April 2020, the State of Connecticut,
per Gov. Ned Lamont, declared a state of emergency in Connecticut due to the COVID-19 pandemic,
which declaration remained in effect for more than a year,” is admitted. As to the remaining allegations
of Paragraph 47, the Redding Defendants have insufficient knowledge or information upon which to
form an opinion or belief and, therefore, leave plaintiff to her proof.
48. So much of Paragraph 48 as alleges, “In coordination with . . . the Redding Police
Department,” is denied. As to the remaining allegations of Paragraph 48, the Redding Defendants have
insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave
plaintiff to her proof.
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Karsten & Tallberg, LLC • ATTORNEYS AT LAW
500 ENTERPRISE DRIVE, SUITE 4B • ROCKY HILL, CT 06067 • (860) 233-5600 • FAX: (860) 233-5800 • JURIS NO. 424030
49. So much of Paragraph 49 as alleges, “the intent of . . . the Redding Police Department
and Chief O’Donnell – was to cause the goats to be killed or injured in a collision with oncoming
vehicles,” is denied. It is further denied that “it was understood by . . . the Redding Police Department
and Chief O’Donnell that should the scheme go as planned and the goats be killed or injured as a
consequence of being chased in a stampede across the road, plaintiff would be wrongfully charged with
animal cruelty, a misdemeanor, and . . . the Redding Police Department would be held blameless.” As
to the remaining allegations of Paragraph 49, the Redding Defendants have insufficient knowledge or
information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof
50. So much of Paragraph 50 as alleges, “the Redding police did arrest plaintiff on a warrant
signed by the Hon. Robert A. D’Andrea,” is admitted. It is further admitted that, “DeLuca later
participated in the arrest of the plaintiff.” As to the remaining allegations of Paragraph 50, the Redding
Defendants have insufficient knowledge or information upon which to form an opinion or belief and,
therefore, leave plaintiff to her proof.
51. So much of Paragraph 51 as alleges, “The Redding Police Department . . . issu[ed] a
press release announcing plaintiff’s arrest,” is admitted. The remaining allegations of Paragraph 51 are
denied.
52. Paragraph 52 is denied.
53. As to the allegations of Paragraph 53, the Redding Defendants have insufficient
knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her
proof.
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Karsten & Tallberg, LLC • ATTORNEYS AT LAW
500 ENTERPRISE DRIVE, SUITE 4B • ROCKY HILL, CT 06067 • (860) 233-5600 • FAX: (860) 233-5800 • JURIS NO. 424030
54. So much of Paragraph 54 as alleges, “plaintiff filed a complaint with defendant Redding
Police Chief O’Donnell requesting the arrest and prosecution of defendants Carmody, Gibbons and
Mason, with regard to the April 30, 2021 incident,” is admitted. As to the remaining allegations of
Paragraph 54, the Redding Defendants have insufficient knowledge or information upon which to form
an opinion or belief and, therefore, leave plaintiff to her proof.
55. As to the allegations of Paragraph 55, the Redding Defendants have insufficient
knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her
proof.
56. As to the allegations of Paragraph 56, the Redding Defendants have insufficient
knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her
proof.
57. As to the allegations of Paragraph 57, the Redding Defendants have insufficient
knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her
proof.
58. As to the allegations of Paragraph 58, the Redding Defendants have insufficient
knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her
proof.
59. So much of Paragraph 59 as alleges, “in the company of two Redding Police Department
officers,” is admitted. As to the remaining allegations of Paragraph 59, the Redding Defendants have
13
Karsten & Tallberg, LLC • ATTORNEYS AT LAW
500 ENTERPRISE DRIVE, SUITE 4B • ROCKY HILL, CT 06067 • (860) 233-5600 • FAX: (860) 233-5800 • JURIS NO. 424030
insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave
plaintiff to her proof.
60. As to the allegations of Paragraph 60, the Redding Defendants have insufficient
knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her
proof
61. As to the allegations of Paragraph 61, the Redding Defendants have insufficient
knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her
proof.
62. As to the allegations of Paragraph 62, the Redding Defendants have insufficient
knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her
proof.
63. As to the allegations of Paragraph 63, the Redding Defendants have insufficient
knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her
proof.
64. As to the allegations of Paragraph 64, the Redding Defendants have insufficient
knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her
proof.
65. As to the allegations of Paragraph 65, the Redding Defendants have insufficient
knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her
proof.
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Karsten & Tallberg, LLC • ATTORNEYS AT LAW
500 ENTERPRISE DRIVE, SUITE 4B • ROCKY HILL, CT 06067 • (860) 233-5600 • FAX: (860) 233-5800 • JURIS NO. 424030
66. As to the allegations of Paragraph 66, the Redding Defendants have insufficient
knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her
proof.
67. As to the allegations of Paragraph 67, the Redding Defendants have insufficient
knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her
proof.
68. As to the allegations of Paragraph 68, the Redding Defendants have insufficient
knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her
proof.
69. As to the allegations of Paragraph 69, the Redding Defendants have insufficient
knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her
proof.
70. As to the allegations of Paragraph 70, the Redding Defendants have insufficient
knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her
proof.
71. As to the allegations of Paragraph 71, the Redding Defendants have insufficient
knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her
proof.
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Karsten & Tallberg, LLC • ATTORNEYS AT LAW
500 ENTERPRISE DRIVE, SUITE 4B • ROCKY HILL, CT 06067 • (860) 233-5600 • FAX: (860) 233-5800 • JURIS NO. 424030
72. As to the allegations of Paragraph 72, the Redding Defendants have insufficient
knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her
proof.
73. As to the allegations of Paragraph 73, the Redding Defendants have insufficient
knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her
proof.
74. As to the allegations of Paragraph 74, the Redding Defendants have insufficient
knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her
proof.
75. As to the allegations of Paragraph 75, the Redding Defendants have insufficient
knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her
proof.
76. Paragraph 76 is denied.
77. So much of Paragraph 77 as alleges “and invade her home,” is denied. The remaining
allegations of Paragraph 77 are admitted.
78. So much of Paragraph 78 as alleges, “and the tactics they were unscrupulously employing
to harass her and interfere with the Mothers Milk Project,” is denied. As to the remaining allegations of
Paragraph 78, the Redding Defendants have insufficient knowledge or information upon which to form
an opinion or belief and, therefore, leave plaintiff to her proof
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Karsten & Tallberg, LLC • ATTORNEYS AT LAW
500 ENTERPRISE DRIVE, SUITE 4B • ROCKY HILL, CT 06067 • (860) 233-5600 • FAX: (860) 233-5800 • JURIS NO. 424030
79. So much of Paragraph 79 as alleges, “the warrant issued by Judge D’Andrea purports to
authorize a search of plaintiff’s home,” is admitted. The remaining allegations of Paragraph 79 are
denied.
80. So much of Paragraph 80 as alleges, “in the company of . . . members of the Redding
Police Department and Redding First Selectman Julia Pemberton,” is admitted. As to the remaining
allegations of Paragraph 80, the Redding Defendants have insufficient knowledge or information upon
which to form an opinion or belief and, therefore, leave plaintiff to her proof
81. As to the allegations of Paragraph 81, the Redding Defendants have insufficient
knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her
proof.
a. As to the allegations of Paragraph 81 (a), the Redding Defendants have
insufficient knowledge or information upon which to form an opinion or belief and, therefore,
leave plaintiff to her proof.
b. As to the allegations of Paragraph 81 (b), the Redding Defendants have
insufficient knowledge or information upon which to form an opinion or belief and, therefore,
leave plaintiff to her proof.
c. As to the allegations of Paragraph 81 (c), the Redding Defendants have
insufficient knowledge or information upon which to form an opinion or belief and, therefore,
leave plaintiff to her proof.
17
Karsten & Tallberg, LLC • ATTORNEYS AT LAW
500 ENTERPRISE DRIVE, SUITE 4B • ROCKY HILL, CT 06067 • (860) 233-5600 • FAX: (860) 233-5800 • JURIS NO. 424030
d. As to the allegations of Paragraph 81 (d), the Redding Defendants have
insufficient knowledge or information upon which to form an opinion or belief and, therefore,
leave plaintiff to her proof.
e. As to the allegations of Paragraph 81 (e), the Redding Defendants have
insufficient knowledge or information upon which to form an opinion or belief and, therefore,
leave plaintiff to her proof.
f. As to the allegations of Paragraph 81 (f), the Redding Defendants have
insufficient knowledge or information upon which to form an opinion or belief and, therefore,
leave plaintiff to her proof.
g. As to the allegations of Paragraph 81 (g), the Redding Defendants have
insufficient knowledge or information upon which to form an opinion or belief and, therefore,
leave plaintiff to her proof.
h. As to the allegations of Paragraph 81 (h), the Redding Defendants have
insufficient knowledge or information upon which to form an opinion or belief and, therefore,
leave plaintiff to her proof.
i. As to the allegations of Paragraph 81 (i), the Redding Defendants have
insufficient knowledge or information upon which to form an opinion or belief and, therefore,
leave plaintiff to her proof.
82. So much of Paragraph 82 as alleges, “members of the defendant Redding Police
Department . . . unlawfully removed items of plaintiff’s personal property inside and outside her home . .
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Karsten & Tallberg, LLC • ATTORNEYS AT LAW
500 ENTERPRISE DRIVE, SUITE 4B • ROCKY HILL, CT 06067 • (860) 233-5600 • FAX: (860) 233-5800 • JURIS NO. 424030
. and committed the following acts of deliberate animal cruelty,” is denied. As to the remaining
allegations of Paragraph 82, the Redding Defendants have insufficient knowledge or information upon
which to form an opinion or belief and, therefore, leave plaintiff to her proof.
a. So much of Paragraph 82 (a) as alleges, “and without proper legal cause based on
a search and seizure warrant fraudulently secured,” is denied. The remaining allegations of
Paragraph 82 (a) are admitted.
b. As to the allegations of Paragraph 82 (b), the Redding Defendants have
insufficient knowledge or information upon which to form an opinion or belief and, therefore,
leave plaintiff to her proof.
c. As to the allegations of Paragraph 82 (c), the Redding Defendants have
insufficient knowledge or information upon which to form an opinion or belief and, therefore,
leave plaintiff to her proof.
d. As to the allegations of Paragraph 82 (d), the Redding Defendants have
insufficient knowledge or information upon which to form an opinion or belief and, therefore,
leave plaintiff to her proof.
e. As to the allegations of Paragraph 82 (e), the Redding Defendants have
insufficient knowledge or information upon which to form an opinion or belief and, therefore,
leave plaintiff to her proof.
19
Karsten & Tallberg, LLC • ATTORNEYS AT LAW
500 ENTERPRISE DRIVE, SUITE 4B • ROCKY HILL, CT 06067 • (860) 233-5600 • FAX: (860) 233-5800 • JURIS NO. 424030
f. As to the allegations of Paragraph 82 (f), the Redding Defendants have
insufficient knowledge or information upon which to form an opinion or belief and, therefore,
leave plaintiff to her proof.
83. As to the allegations of Paragraph 83, the Redding Defendants have insufficient
knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her
proof.
84. So much of Paragraph 84 as alleges, “Hon. Susan Quinn Cobb, entered an Order for
Temporary Care and Custody on April 19, 2021 (“Order”),” is admitted. As to the remaining allegations
of Paragraph 84, the Redding Defendants have insufficient knowledge or information upon which to
form an opinion or belief and, therefore, leave plaintiff to her proof.
85. As to the allegations of Paragraph 85, the Redding Defendants have insufficient
knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her
proof.
86. Paragraph 86 contains plaintiff’s request to the Court, which requires no response. To the
extent a response is required, the Redding Defendants deny that the Court can take the judicial notice
requested by plaintiff.
87. Paragraph 87 is denied.
88. Paragraph 88 is denied.
89. Paragraph 89 is denied.
90. Paragraph 90 is denied.
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Karsten & Tallberg, LLC • ATTORNEYS AT LAW
500 ENTERPRISE DRIVE, SUITE 4B • ROCKY HILL, CT 06067 • (860) 233-5600 • FAX: (860) 233-5800 • JURIS NO. 424030
COUNT ONE: DEFAMATION (As to Defendant Elinor Carmody)
91. Paragraph 91 is not directed at the Redding Defendants and, as such, no answer is
required as to the Redding Defendants. To the extent that a response is required of the Redding
Defendants, the answers provided to Paragraphs 1 through 90 of this Complaint are incorporated by
reference herein as Paragraph 91 of Count One as though set forth herein.
92. Paragraph 92 is not directed at the Redding Defendants and, as such, no answer is
required as to the Redding Defendants. To the extent that a response is required of the Redding
Defendants, the Redding Defendants have insufficient knowledge or information upon which to form an
opinion or belief and, therefore, leave plaintiff to her proof.
93. Paragraph 93 is not directed at the Redding Defendants and, as such, no answer is
required as to the Redding Defendants. To the extent that a response is required of the Redding
Defendants, the Redding Defendants have insufficient knowledge or information upon which to form an
opinion or belief and, therefore, leave plaintiff to her proof.
94. Paragraph 94 is not directed at the Redding Defendants and, as such, no answer is
required as to the Redding Defendants. To the extent that a response is required of the Redding
Defendants, the Redding Defendants have insufficient knowledge or information upon which to form an
opinion or belief and, therefore, leave plaintiff to her proof.
95. Paragraph 95 is not directed at the Redding Defendants and, as such, no answer is
required as to the Redding Defendants. To the extent that a response is required of the Redding
21
Karsten & Tallberg, LLC • ATTORNEYS AT LAW
500 ENTERPRISE DRIVE, SUITE 4B • ROCKY HILL, CT 06067 • (860) 233-5600 • FAX: (860) 233-5800 • JURIS NO. 424030
Defendants, the Redding Defendants have insufficient knowledge or information upon which to form an
opinion or belief and, therefore, leave plaintiff to her proof.
96. Paragraph 96 is not directed at the Redding Defendants and, as such, no answer is
required as to the Redding Defendants. To the extent that a response is required of the Redding
Defendants, Paragraph 96 contains legal conclusions to which no response is required.
As to that portion of Count One as alleges, “WHEREFORE, plaintiff seeks compensatory and
punitive damages in the amount of $10 million,” it is denied that plaintiff is entitled to the recovery she
seeks.
COUNT TWO: INVASION OF PRIVACY (As to Defendants Town of Redding, Redding Police
Chief Mark O’Donnell, First Selectman Julia Pemberton, Elinor Carmody, Dennis Gibbons and
David Philip Mason)
91. The answers provided to Paragraphs 1 through 96 of Count One are incorporated by
reference herein as Paragraph 91 of Count Two.
92. Paragraph 92 is denied.
93. Paragraph 93 is denied.
a. Paragraph 93 (a) is denied.
b. Paragraph 93 (b) is denied.
c. Paragraph 93 (c) is denied.
d. Paragraph 93 (d) is denied.
e. Paragraph 93 (e) is denied.
f. Paragraph 93 (f) is denied.
22
Karsten & Tallberg, LLC • ATTORNEYS AT LAW
500 ENTERPRISE DRIVE, SUITE 4B • ROCKY HILL, CT 06067 • (860) 233-5600 • FAX: (860) 233-5800 • JURIS NO. 424030
g. Paragraph 93 (g) is denied.
h. Paragraph 93 (h) is denied.
As to that portion of Count Two as alleges, “WHEREFORE, plaintiff seeks compensatory and
punitive damages in the amount of $10 million and injunctive relief,” it is denied that plaintiff is entitled
to the recovery she seeks.
COUNT THREE: ILLEGAL SEARCH AND SEIZURE (As to Defendants Town of Redding,
Redding Police Chief Mark O’Donnell, First Selectman Julia Pemberton, Elinore Carmody,
Dennis Gibbons and David Philip Mason)
91. The answers provided to Paragraphs 1 through 90 of Count One are incorporated by
reference herein as Paragraph 91 of Count Three.
92. Paragraph 92 is denied.
93. So much of Paragraph 93 as alleges, “otherwise legally impermissible” and “in violation
of the Fourth Amendment to the United States Constitution,” is denied. It is further denied that the
“actions and orders issued to plaintiff by the Redding
Preview
DOCKET NO.: (X06) UWY-CV21-5028294-S : SUPERIOR COURT NANCY BURTON : COMPLEX LITIGATION DOCKET vs. : AT WATERBURY DAVID PHILIP MASON, ET AL. : MAY 12, 2022 REDDING DEFENDANTS’ ANSWER AND SPECIAL DEFENSES Pursuant to Practice Book § 10-49, defendants Town of Redding, First Selectman Julia Pemberton, and Chief Mark O’Donnell (collectively, the “Redding Defendants”) hereby answer and assert special defenses to plaintiff’s Fifth Amended Complaint, dated and filed on April 12, 2022 [Doc. 328.00], as follows: 1. As to the allegations of Paragraph 1, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 2. As to the allegations of Paragraph 2, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 3. As to the allegations of Paragraph 3, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 1 Karsten & Tallberg, LLC • ATTORNEYS AT LAW 500 ENTERPRISE DRIVE, SUITE 4B • ROCKY HILL, CT 06067 • (860) 233-5600 • FAX: (860) 233-5800 • JURIS NO. 424030 4. As to the allegations of Paragraph 4, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 5. As to the allegations of Paragraph 5, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 6. As to the allegations of Paragraph 6, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 7. As to the allegations of Paragraph 7, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 8. As to the allegations of Paragraph 8, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 9. As to the allegations of Paragraph 9, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 2 Karsten & Tallberg, LLC • ATTORNEYS AT LAW 500 ENTERPRISE DRIVE, SUITE 4B • ROCKY HILL, CT 06067 • (860) 233-5600 • FAX: (860) 233-5800 • JURIS NO. 424030 10. As to the allegations of Paragraph 10, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 11. As to the allegations of Paragraph 11, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 12. As to the allegations of Paragraph 12, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 13. As to the allegations of Paragraph 13, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 14. As to the allegations of Paragraph 14, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 15. As to the allegations of Paragraph 15, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 3 Karsten & Tallberg, LLC • ATTORNEYS AT LAW 500 ENTERPRISE DRIVE, SUITE 4B • ROCKY HILL, CT 06067 • (860) 233-5600 • FAX: (860) 233-5800 • JURIS NO. 424030 16. As to the allegations of Paragraph 16, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 17. As to the allegations of Paragraph 17, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 18. As to the allegations of Paragraph 18, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 19. As to the allegations of Paragraph 19, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 20. As to the allegations of Paragraph 20, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 21. As to the allegations of Paragraph 21, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 4 Karsten & Tallberg, LLC • ATTORNEYS AT LAW 500 ENTERPRISE DRIVE, SUITE 4B • ROCKY HILL, CT 06067 • (860) 233-5600 • FAX: (860) 233-5800 • JURIS NO. 424030 22. As to the allegations of Paragraph 22, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 23. As to the allegations of Paragraph 23, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 24. So much of Paragraph 24 as alleges, “In September 2017, the Redding Zoning Commission issued a cease and desist order directing plaintiff to reduce the number of goats on her property to no more than nine within ten days of said order,” is admitted. As to the remaining allegations of Paragraph 24, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 25. As to the allegations of Paragraph 25, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 26. As to the allegations of Paragraph 26, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 27. So much of Paragraph 27 as alleges, “plaintiff filed a land management plan with the Redding Zoning Commission” is admitted. As to the remaining allegations of Paragraph 27, the 5 Karsten & Tallberg, LLC • ATTORNEYS AT LAW 500 ENTERPRISE DRIVE, SUITE 4B • ROCKY HILL, CT 06067 • (860) 233-5600 • FAX: (860) 233-5800 • JURIS NO. 424030 Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 28. As to the allegations of Paragraph 28, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 29. As to the allegations of Paragraph 29, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 30. As to the allegations of Paragraph 30, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 31. As to the allegations of Paragraph 31, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 32. As to the allegations of Paragraph 32, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 33. As to the allegations of Paragraph 33, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 6 Karsten & Tallberg, LLC • ATTORNEYS AT LAW 500 ENTERPRISE DRIVE, SUITE 4B • ROCKY HILL, CT 06067 • (860) 233-5600 • FAX: (860) 233-5800 • JURIS NO. 424030 34. As to the allegations of Paragraph 34, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. a. So much of Paragraph 34 (a) as alleges, “First Selectman Julia Pemberton did not respond to the request,” is admitted. As to the remaining allegations of Paragraph 34 (a), the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. b. So much of Paragraph 34 (b) as alleges, “First Selectman Julia Pemberton did not respond to the request,” is admitted. As to the remaining allegations of Paragraph 34 (a), the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. c. So much of Paragraph 34 (c) as alleges, “First Selectman Julia Pemberton did not respond to the request,” is admitted. As to the remaining allegations of Paragraph 34 (a), the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. d. As to the allegations of Paragraph 34 (d), the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 7 Karsten & Tallberg, LLC • ATTORNEYS AT LAW 500 ENTERPRISE DRIVE, SUITE 4B • ROCKY HILL, CT 06067 • (860) 233-5600 • FAX: (860) 233-5800 • JURIS NO. 424030 35. As to the allegations of Paragraph 35, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 36. As to the allegations of Paragraph 36, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 37. As to the allegations of Paragraph 37, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 38. So much of Paragraph 38 as alleges, “Defendant Julia Pemberton has served and continues to serve as First Selectman of the Town of Redding during the period of time pertinent to this Amended Complaint,” is admitted. The remaining allegations of Paragraph 38 are denied. 39. Paragraph 39 is denied. 40. Paragraph 40 is admitted. 41. As to the allegations of Paragraph 41, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 42. As to the allegations of Paragraph 42, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 8 Karsten & Tallberg, LLC • ATTORNEYS AT LAW 500 ENTERPRISE DRIVE, SUITE 4B • ROCKY HILL, CT 06067 • (860) 233-5600 • FAX: (860) 233-5800 • JURIS NO. 424030 43. Paragraph 43 is admitted. 44. Paragraph 44 is admitted. 45. As to the allegations of Paragraph 45, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 46. As to the allegations of Paragraph 46, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. a. As to the allegations of Paragraph 46 (a), the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. b. As to the allegations of Paragraph 46 (b), the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. c. As to the allegations of Paragraph 46 (c), the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. d. As to the allegations of Paragraph 46 (d), the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 9 Karsten & Tallberg, LLC • ATTORNEYS AT LAW 500 ENTERPRISE DRIVE, SUITE 4B • ROCKY HILL, CT 06067 • (860) 233-5600 • FAX: (860) 233-5800 • JURIS NO. 424030 e. As to the allegations of Paragraph 46 (e), the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. f. As to the allegations of Paragraph 46 (f), the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. g. As to the allegations of Paragraph 46 (g), the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. h. As to the allegations of Paragraph 46 (h), the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. i. So much of Paragraph 46 (i) as alleges, “plaintiff filed a complaint with the defendant Redding Police Chief Mark O’Donnell,” is admitted. As to the remaining allegations of Paragraph 46 (i), the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. j. As to so much of Paragraph 46 (j) as alleges, “per order of Chief Mark O’Donnell,” the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. The remaining allegations of Paragraph 46 (j) are admitted. 10 Karsten & Tallberg, LLC • ATTORNEYS AT LAW 500 ENTERPRISE DRIVE, SUITE 4B • ROCKY HILL, CT 06067 • (860) 233-5600 • FAX: (860) 233-5800 • JURIS NO. 424030 k. As to the allegations of Paragraph 46 (k), the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. l. As to the allegations of Paragraph 46 (l), the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. m. As to so much of Paragraph 46 (m) as alleges, “per defendant chief O’Donnell,” the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. The remaining allegations of Paragraph 46 (m) are admitted. 47. So much of Paragraph 47 as alleges “On or about April 2020, the State of Connecticut, per Gov. Ned Lamont, declared a state of emergency in Connecticut due to the COVID-19 pandemic, which declaration remained in effect for more than a year,” is admitted. As to the remaining allegations of Paragraph 47, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 48. So much of Paragraph 48 as alleges, “In coordination with . . . the Redding Police Department,” is denied. As to the remaining allegations of Paragraph 48, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 11 Karsten & Tallberg, LLC • ATTORNEYS AT LAW 500 ENTERPRISE DRIVE, SUITE 4B • ROCKY HILL, CT 06067 • (860) 233-5600 • FAX: (860) 233-5800 • JURIS NO. 424030 49. So much of Paragraph 49 as alleges, “the intent of . . . the Redding Police Department and Chief O’Donnell – was to cause the goats to be killed or injured in a collision with oncoming vehicles,” is denied. It is further denied that “it was understood by . . . the Redding Police Department and Chief O’Donnell that should the scheme go as planned and the goats be killed or injured as a consequence of being chased in a stampede across the road, plaintiff would be wrongfully charged with animal cruelty, a misdemeanor, and . . . the Redding Police Department would be held blameless.” As to the remaining allegations of Paragraph 49, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof 50. So much of Paragraph 50 as alleges, “the Redding police did arrest plaintiff on a warrant signed by the Hon. Robert A. D’Andrea,” is admitted. It is further admitted that, “DeLuca later participated in the arrest of the plaintiff.” As to the remaining allegations of Paragraph 50, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 51. So much of Paragraph 51 as alleges, “The Redding Police Department . . . issu[ed] a press release announcing plaintiff’s arrest,” is admitted. The remaining allegations of Paragraph 51 are denied. 52. Paragraph 52 is denied. 53. As to the allegations of Paragraph 53, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 12 Karsten & Tallberg, LLC • ATTORNEYS AT LAW 500 ENTERPRISE DRIVE, SUITE 4B • ROCKY HILL, CT 06067 • (860) 233-5600 • FAX: (860) 233-5800 • JURIS NO. 424030 54. So much of Paragraph 54 as alleges, “plaintiff filed a complaint with defendant Redding Police Chief O’Donnell requesting the arrest and prosecution of defendants Carmody, Gibbons and Mason, with regard to the April 30, 2021 incident,” is admitted. As to the remaining allegations of Paragraph 54, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 55. As to the allegations of Paragraph 55, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 56. As to the allegations of Paragraph 56, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 57. As to the allegations of Paragraph 57, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 58. As to the allegations of Paragraph 58, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 59. So much of Paragraph 59 as alleges, “in the company of two Redding Police Department officers,” is admitted. As to the remaining allegations of Paragraph 59, the Redding Defendants have 13 Karsten & Tallberg, LLC • ATTORNEYS AT LAW 500 ENTERPRISE DRIVE, SUITE 4B • ROCKY HILL, CT 06067 • (860) 233-5600 • FAX: (860) 233-5800 • JURIS NO. 424030 insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 60. As to the allegations of Paragraph 60, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof 61. As to the allegations of Paragraph 61, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 62. As to the allegations of Paragraph 62, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 63. As to the allegations of Paragraph 63, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 64. As to the allegations of Paragraph 64, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 65. As to the allegations of Paragraph 65, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 14 Karsten & Tallberg, LLC • ATTORNEYS AT LAW 500 ENTERPRISE DRIVE, SUITE 4B • ROCKY HILL, CT 06067 • (860) 233-5600 • FAX: (860) 233-5800 • JURIS NO. 424030 66. As to the allegations of Paragraph 66, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 67. As to the allegations of Paragraph 67, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 68. As to the allegations of Paragraph 68, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 69. As to the allegations of Paragraph 69, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 70. As to the allegations of Paragraph 70, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 71. As to the allegations of Paragraph 71, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 15 Karsten & Tallberg, LLC • ATTORNEYS AT LAW 500 ENTERPRISE DRIVE, SUITE 4B • ROCKY HILL, CT 06067 • (860) 233-5600 • FAX: (860) 233-5800 • JURIS NO. 424030 72. As to the allegations of Paragraph 72, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 73. As to the allegations of Paragraph 73, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 74. As to the allegations of Paragraph 74, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 75. As to the allegations of Paragraph 75, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 76. Paragraph 76 is denied. 77. So much of Paragraph 77 as alleges “and invade her home,” is denied. The remaining allegations of Paragraph 77 are admitted. 78. So much of Paragraph 78 as alleges, “and the tactics they were unscrupulously employing to harass her and interfere with the Mothers Milk Project,” is denied. As to the remaining allegations of Paragraph 78, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof 16 Karsten & Tallberg, LLC • ATTORNEYS AT LAW 500 ENTERPRISE DRIVE, SUITE 4B • ROCKY HILL, CT 06067 • (860) 233-5600 • FAX: (860) 233-5800 • JURIS NO. 424030 79. So much of Paragraph 79 as alleges, “the warrant issued by Judge D’Andrea purports to authorize a search of plaintiff’s home,” is admitted. The remaining allegations of Paragraph 79 are denied. 80. So much of Paragraph 80 as alleges, “in the company of . . . members of the Redding Police Department and Redding First Selectman Julia Pemberton,” is admitted. As to the remaining allegations of Paragraph 80, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof 81. As to the allegations of Paragraph 81, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. a. As to the allegations of Paragraph 81 (a), the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. b. As to the allegations of Paragraph 81 (b), the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. c. As to the allegations of Paragraph 81 (c), the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 17 Karsten & Tallberg, LLC • ATTORNEYS AT LAW 500 ENTERPRISE DRIVE, SUITE 4B • ROCKY HILL, CT 06067 • (860) 233-5600 • FAX: (860) 233-5800 • JURIS NO. 424030 d. As to the allegations of Paragraph 81 (d), the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. e. As to the allegations of Paragraph 81 (e), the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. f. As to the allegations of Paragraph 81 (f), the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. g. As to the allegations of Paragraph 81 (g), the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. h. As to the allegations of Paragraph 81 (h), the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. i. As to the allegations of Paragraph 81 (i), the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 82. So much of Paragraph 82 as alleges, “members of the defendant Redding Police Department . . . unlawfully removed items of plaintiff’s personal property inside and outside her home . . 18 Karsten & Tallberg, LLC • ATTORNEYS AT LAW 500 ENTERPRISE DRIVE, SUITE 4B • ROCKY HILL, CT 06067 • (860) 233-5600 • FAX: (860) 233-5800 • JURIS NO. 424030 . and committed the following acts of deliberate animal cruelty,” is denied. As to the remaining allegations of Paragraph 82, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. a. So much of Paragraph 82 (a) as alleges, “and without proper legal cause based on a search and seizure warrant fraudulently secured,” is denied. The remaining allegations of Paragraph 82 (a) are admitted. b. As to the allegations of Paragraph 82 (b), the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. c. As to the allegations of Paragraph 82 (c), the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. d. As to the allegations of Paragraph 82 (d), the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. e. As to the allegations of Paragraph 82 (e), the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 19 Karsten & Tallberg, LLC • ATTORNEYS AT LAW 500 ENTERPRISE DRIVE, SUITE 4B • ROCKY HILL, CT 06067 • (860) 233-5600 • FAX: (860) 233-5800 • JURIS NO. 424030 f. As to the allegations of Paragraph 82 (f), the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 83. As to the allegations of Paragraph 83, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 84. So much of Paragraph 84 as alleges, “Hon. Susan Quinn Cobb, entered an Order for Temporary Care and Custody on April 19, 2021 (“Order”),” is admitted. As to the remaining allegations of Paragraph 84, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 85. As to the allegations of Paragraph 85, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 86. Paragraph 86 contains plaintiff’s request to the Court, which requires no response. To the extent a response is required, the Redding Defendants deny that the Court can take the judicial notice requested by plaintiff. 87. Paragraph 87 is denied. 88. Paragraph 88 is denied. 89. Paragraph 89 is denied. 90. Paragraph 90 is denied. 20 Karsten & Tallberg, LLC • ATTORNEYS AT LAW 500 ENTERPRISE DRIVE, SUITE 4B • ROCKY HILL, CT 06067 • (860) 233-5600 • FAX: (860) 233-5800 • JURIS NO. 424030 COUNT ONE: DEFAMATION (As to Defendant Elinor Carmody) 91. Paragraph 91 is not directed at the Redding Defendants and, as such, no answer is required as to the Redding Defendants. To the extent that a response is required of the Redding Defendants, the answers provided to Paragraphs 1 through 90 of this Complaint are incorporated by reference herein as Paragraph 91 of Count One as though set forth herein. 92. Paragraph 92 is not directed at the Redding Defendants and, as such, no answer is required as to the Redding Defendants. To the extent that a response is required of the Redding Defendants, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 93. Paragraph 93 is not directed at the Redding Defendants and, as such, no answer is required as to the Redding Defendants. To the extent that a response is required of the Redding Defendants, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 94. Paragraph 94 is not directed at the Redding Defendants and, as such, no answer is required as to the Redding Defendants. To the extent that a response is required of the Redding Defendants, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 95. Paragraph 95 is not directed at the Redding Defendants and, as such, no answer is required as to the Redding Defendants. To the extent that a response is required of the Redding 21 Karsten & Tallberg, LLC • ATTORNEYS AT LAW 500 ENTERPRISE DRIVE, SUITE 4B • ROCKY HILL, CT 06067 • (860) 233-5600 • FAX: (860) 233-5800 • JURIS NO. 424030 Defendants, the Redding Defendants have insufficient knowledge or information upon which to form an opinion or belief and, therefore, leave plaintiff to her proof. 96. Paragraph 96 is not directed at the Redding Defendants and, as such, no answer is required as to the Redding Defendants. To the extent that a response is required of the Redding Defendants, Paragraph 96 contains legal conclusions to which no response is required. As to that portion of Count One as alleges, “WHEREFORE, plaintiff seeks compensatory and punitive damages in the amount of $10 million,” it is denied that plaintiff is entitled to the recovery she seeks. COUNT TWO: INVASION OF PRIVACY (As to Defendants Town of Redding, Redding Police Chief Mark O’Donnell, First Selectman Julia Pemberton, Elinor Carmody, Dennis Gibbons and David Philip Mason) 91. The answers provided to Paragraphs 1 through 96 of Count One are incorporated by reference herein as Paragraph 91 of Count Two. 92. Paragraph 92 is denied. 93. Paragraph 93 is denied. a. Paragraph 93 (a) is denied. b. Paragraph 93 (b) is denied. c. Paragraph 93 (c) is denied. d. Paragraph 93 (d) is denied. e. Paragraph 93 (e) is denied. f. Paragraph 93 (f) is denied. 22 Karsten & Tallberg, LLC • ATTORNEYS AT LAW 500 ENTERPRISE DRIVE, SUITE 4B • ROCKY HILL, CT 06067 • (860) 233-5600 • FAX: (860) 233-5800 • JURIS NO. 424030 g. Paragraph 93 (g) is denied. h. Paragraph 93 (h) is denied. As to that portion of Count Two as alleges, “WHEREFORE, plaintiff seeks compensatory and punitive damages in the amount of $10 million and injunctive relief,” it is denied that plaintiff is entitled to the recovery she seeks. COUNT THREE: ILLEGAL SEARCH AND SEIZURE (As to Defendants Town of Redding, Redding Police Chief Mark O’Donnell, First Selectman Julia Pemberton, Elinore Carmody, Dennis Gibbons and David Philip Mason) 91. The answers provided to Paragraphs 1 through 90 of Count One are incorporated by reference herein as Paragraph 91 of Count Three. 92. Paragraph 92 is denied. 93. So much of Paragraph 93 as alleges, “otherwise legally impermissible” and “in violation of the Fourth Amendment to the United States Constitution,” is denied. It is further denied that the “actions and orders issued to plaintiff by the Redding