FILED 17 MAY 24 PM 3:34 Hon. Veronica Alicea-Galvan KING COUNTY SUPERIOR COURT CLE E-FILED CASE NUMBER: 17-2-09152 SUPERIOR COURT OF WASHINGTON FOR KING COUNTY DELVONN HECKARD, No. Plaintiff, ANSWER TO AMENDED V. COMPLAINT (CORRECTED) FOR DAMAGES: CHILD SEX ABUSE MAYOR EDWARD MURRAY, ILLEGAL CHILD PROSTITUTION Defendant. Defendant Mayor Edward Murray (?Defendant?) answers Plaintiff Delvonn Heckard?s (?Plaintiff?) Amended Complaint (Corrected) for Damages: Child Sex Abuse Illegal Child Prostitution (the ?Complaint?), as follows: I. PARTIES 1. Defendant lacks knowledge or information suf?cient to form a belief as to the truth of the allegations in Paragraph 1 relating to Plaintiff, his actions, or his motivations and therefore denies them. Defendant denies any inappropriate contact with Plaintiff or any minor. Defendant denies that he has a ?hit team.? The content of footnote 2, other than information related, to the alleged spelling of Plaintiff?s name, is a legal argument to which no response is required, but to the extent a response is required, Defendant denies the statements in footnote 2. To the extent not expressly admitted, Defendant denies any remaining allegations in Paragraph 1. 2. Defendant admits he was 61 years old at the time the Complaint was filed and is a resident of Seattle, Washington. Defendant further admits he previously resided LAW OFFICES OF ANSWER TO AMENDED COMPLAINT EBEL NAWROT HELGREN (CORRECTED) FOR DAMAGES, ETC. Page 1 600 University Street, Suite 2700 Seattle, Washington 98101-3143 (206) 467-1316 at 303 Harvard Avenue East, Apt 304 in Seattle, Washington. This information is publically available. Defendant denies that the incidents referenced in Paragraph 2 occurred. To the extent not expressly admitted, Defendant denies any remaining allegations in Paragraph 2. II. FACTS 3. Defendant lacks knowledge or information suf?cient to form a belief as to the truth of the allegations in Paragraph 3 relating to Plaintiff, his actions, or his motivations and therefore denies them. Defendant denies any inappropriate contact with Plaintiff, including the allegations of sentence 5 of Paragraph 3. Defendant notes that his Old phone number and apartment layout are publically available. To the extent not expressly admitted, Defendant denies any remaining allegations in Paragraph 3. 4. Defendant denies any inappropriate contact with Plaintiff, including the allegations in sentences 1?6 Of Paragraph 4. Defendant lacks knowledge or information suf?cient to form a belief as to the truth of the allegations in Paragraph 4 relating to Plaintiff, his thoughts, his actions, his statements, or his motivations and therefore denies them. To the extent not expressly admitted, Defendant denies any remaining allegations in Paragraph 4. 5. Defendant denies any inappropriate contact with Plaintiff, including the allegations in sentences 1, and 3?4 of Paragraph 5. Defendant lacks knowledge or information suf?cient to form a belief as to the truth of the allegations in Paragraph 5 relating tO Plaintiff, his drug use, his criminal history, his actions, or his motivations and therefore denies them. Defendant denies that he has ever had a mole on his genitals. Defendant notes that a medical exam has established the falsity of this claim showing that no such thing exists and there is no evidence of the removal of any such mole. Defendant further notes that he informed Plaintiff that he is willing to submit to an independent examination at the University of Washington with the understanding that the case should LAW OFFICES OF ANSWER TO AMENDED COMPLAINT EBEPNAWROT pac (CORRECTED) FOR DAMAGES, ETC. Page 2 (206) 467-1816 be dropped if the ?rst examination results are con?rmed, but Plaintiff has been unwilling to agree. Defendant admits to his hair color, which is also readily apparent given the color of the rest of his hair. To the extent not expressly admitted, Defendant denies any remaining allegations in Paragraph 5. 6. Defendant denies any inappropriate contact with Plaintiff, or any other minor, including the allegations in sentences 2, and 4?5 of Paragraph 6. Defendant notes it is possible that over the past 30 years, Defendant may have crossed paths with Plaintiff given Defendant?s long-standing political and community activism and extensive social connections. Defendant lacks knowledge or information suf?cient to form a belief as to the truth of the allegations in Paragraph 6 relating to Plaintiff, his actions, or his motivations and therefore denies them. To the extent not expressly admitted, Defendant denies any remaining allegations in Paragraph 6. 7. Defendant denies any inappropriate contact with Plaintiff, or any other minor. To the extent any remaining allegations in paragraph 7 require a response, Defendant denies them. 8. Defendant lacks knowledge or information suf?cient to form a belief as to the truth of the allegations in Paragraph 8 relating to Plaintiff, his actions, his thoughts, his family members, his medical treatment, his drug use, or his motivations and therefore denies them. Defendant has no recollection of speaking with Plaintiff by phone or otherwise but Defendant has spoken with many people over the years due to Defendant?s long-standing political and community activism and extensive social connections. To the extent not expressly admitted, Defendant denies any remaining allegations in Paragraph 8. 9. Defendant denies any inappropriate contact with Plaintiff or any minor, including the allegations in sentences 2, 5, and 7 of Paragraph 9. Defendant lacks knowledge or information suf?cient to form a belief as to the truth of the allegations in Paragraph 9 relating to Plaintiff or his agents, their records, their actions, their beliefs, LAW OFFICES OF ANSWER TO AMENDED COMPLAINT EBELNAWROT HELGREN (CORRECTED) FOR DAMAGES, ETC. Page 3 600 Suieeme Seattle, Washington 98101-3143 (206) 467-1816 their motivations, or their legal strategies and therefore denies them. Defendant notes that the allegations come on the cusp of a mayoral campaign and the actions of Plaintiff?s counsel are inconsistent with the allegations of Paragraph 9. Defendant lacks knowledge or information suf?cient to form a belief as to the truth of the allegations in Paragraph 9 relating to the alleged beliefs of ?some people? and therefore denies them. Defendant states that Plaintiff has not made any ?nancial demands of him and denies that the demands alleged in sentence 7 of Paragraph 9 occurred. Defendant has no recollection of accepting collect calls from Plaintiff but Defendant has accepted collect calls routinely over the years due to Defendant?s long-standing political and community activism and extensive social connections. To the extent not expressly admitted, Defendant denies any remaining allegations in Paragraph 9. 10. Defendant knew both Mr. Simpson and Mr. Anderson but denies that he engaged in any inappropriate conduct or inappropriate relationship with Mr. Simpson or Mr. Anderson. Their accusations against him are false. Defendant denies the allegations in sentence 3 of Paragraph 10 and states that these accusations were thoroughly investigated at the time and found to be without merit as no charges were ever ?led. Defendant lacks knowledge or information suf?cient to form a belief as to the truth of the allegations in Paragraph 10 relating to Plaintiff, Mr. Simpson, Mr. Anderson, their actions, or their motivations, and therefore denies them. To the extent not expressly admitted, Defendant denies any remaining allegations in Paragraph 10. ll. Defendant lacks knowledge or information suf?cient to form a belief as to the truth of the allegations in Paragraph 11 relating to Plaintiff, his actions, or his motivations and therefore denies them. Defendant admits that prior to the ?ling of the Amended Complaint, he did not know the true identity of Plaintiff. Defendant admits that since Plaintiff ?led this lawsuit, Defendant has participated in public interviews, made public statements, and has been examined by a doctor. Defendant notes that this LAW OFFICES OF ANSWER TO AMENDED COMPLAINT EBEL NAWROT HELGREN (CORRECTED) FOR DAMAGES, ETC Page 4 600 University Street, Suite 2700 Seattle, Washington 98101-3 E43 . (206) 467-1816 OCDWNOUUI-PODNA examination showed the allegations made relating to Defendant?s anatomy are false, and that his offer to undergo a second medical examination by a doctor at the University of Washington has not been accepted. The remainder of Paragraph 11 consists of speculation relating to Defendant?s legal strategy, to which no response is required. To the extent not expressly admitted, Defendant denies any remaining allegations in Paragraph 11. CHILDHOOD SEX ABUSE 12. Defendant denies any inappropriate contact with Plaintiff, including the allegations in sentences 1 and 2 of Paragraph 12. The remainder of Paragraph 12 consists of legal conclusions and a recitation of legislative intent to which no response is required. The content of Washington?s statutes speaks for itself and Defendant refers to the full content of those documents. To the extent not expressly admitted, Defendant denies any remaining allegations in Paragraph 12. IV. STATUTE OF LIMITATIONS: RCW 4.16.340 13. Paragraph 13 consists of portions of Washington statutes. The content of Washington?s statutes speaks for itself and Defendant refers to the full content of those documents. To the extent any allegations in Paragraph 13 require a response, Defendant denies them. 14. Defendant denies any inappropriate contact with Plaintiff, including the allegations in the last sentence of Paragraph 14. Defendant lacks knowledge or information sufficient to form a belief as to the truth of the allegations in Paragraph 14 relating to Plaintiff, his actions, or his motivations and therefore denies them. The remainder of Paragraph 14 consists of legal conclusions and a recitation of legislative intent to which no responses are required. The content of Washington?s statutes and case law speak for themselves and Defendant refers to the full content of those documents. Defendant denies any remaining allegations in Paragraph 14. LAW OFFICES OF ANSWER TO AMENDED COMPLAINT MONAUL EBEA (CORRECTED) FOR DAMAGES, ETC. Page 5 {206) 467~1816 V. PRAYER FOR RELIEF 15. Defendant denies that Plaintiff is entitled to any of the relief requested in sections of the Prayer For Relief. VI. AFFIRMATIVE AND OTHER DEFENSES By stating any of the defenses set forth below, Defendant does not assume a burden of proof he does not have. 1. Plaintiff has failed to state a claim upon which relief can be granted. 2. Plaintiff?s claims are barred, in whole or in part, by the applicable statutes of limitations. 3. Plaintiff injuries, if any, were caused by individuals and entities over which Defendant had no control. 4. To the extent relevant, Plaintiff?s claims are barred by RCW 9A.44.030. By stating any of the defenses set forth above, Defendant reserves the right to plead additional defenses as may be warranted by ongoing discovery. Defendant likewise reserves the right to argue legal theories in addition to or in lieu of those speci?cally identi?ed here as the facts in this matter may warrant, including, without limitation, additional or further facts hereafter learned through discovery or during the course of this action. I VII. PRAYER FOR RELIEF WHEREFORE, having answered Plaintiff?s Complaint, Defendant requests the following relief: A. For dismissal of Plaintiff claims, with prejudice; B. For an award of Defendant?s reasonable attomeys? fees and costs incurred in answering and responding to Plaintiff? claims; and LAW OFFICES OF ANSWER TO AMENDED COMPLAINT EBEL NAWROT HELGREN m, (CORRECTED) FOR DAMAGES, ETC. Page 6 600 University Street, Suite 2700 Seattle, Washington 98101-3143 (206) 467-1816 C. For such other and further relief as the Court deems just and equitable. DATED this day of May, 2017. MCNAUL EBEL NAWROT HELGREN PLLC By: Robert M. Sulkin, WSBA No. 15425 Malaika M. Eaton, WSBA No. 32837 600 University Street, Suite 2700 Seattle, Washington 98101 Telephone (206) 467-1816 rsulkin@mcnaul.com meaton@mcnaul.com Attorneys for Defendant LAW OFFICES OF DEF.9 ANSWER TO AMENDED COMPLAINT MCNAUL EBEL NAWROT HELGREN PLLC (CORRECTED) FOR AM AGES, ETC. Page 7 600 Umvers?y Street, Sum: 2700 Seattle, Washington 98101-3143 (206) 467?1816 3759~001 gdche4009.004 2017-05-24