FILED 18 JAN 08 PM 3:35 sup't??l??ts??lft?ttb E-FILED CASE NUMBER: 17-2-28384-3 SUPERIOR COURT OF WASHINGTON FOR KING COUNTY JOHN URQUHART, No. 17-2-28384?3 SEA Plaintiff, and ANSWER, AFFIRMATIVE DEFENSES AND BRIAN BARNES, COUNTERCLAIMS Defendant. Defendant, Mr. Barnes, answers the allegations in Plaintiff's Complaint for Damages (?Complaint") as follows: I. ANSWER 1. On March 26, 2014, John Urquhart (?Mn Urquhart?) sexually assaulted Brian Barnes Barnes?), and Mr. Barnes reported Mr. Urquhart to law enforcement. This defamation suit brought by Mr. Urquhart is an abusive attempt by the former Sheriff of King County and former candidate for public office to deflect accountability, punish, retaliate against and damage the reputation of a private citizen, Mr. Barnes. 2. As to Paragraph 1.1 of the Complaint, Mr. Barnes denies that he falsely or maliciously accused Mr. Urquhart of sexual assault because Mr. Urquhart did in fact . . . Sexual Violence Legal Services Answer, Affirmative Defenses and Counterclaims vwce Seattle King Snohomish - Page 1 of 16 2024 3rd Avenue, Seattle, we 93121 Tel: 206.832.3632 riddhim@ywcaworks.org Tel: 206.436.8664 mjewell@ywcaworks.org assault Mr. Barnes with sexual motivation on March 26, 2014. Mr. Barnes further denies that he has made defamatory or false statements about Mr. Urquhart or attempted to harm him. As to the remaining allegations of Paragraph 1.1, Mr. Barnes lacks sufficient knowledge and information to form a belief as to the truth of the remaining allegations and accordingly denies those allegations. 3. As to Paragraph 1.2 of the Complaint, Mr. Barnes admits that he properly reported inappropriate conduct at the King County Sheriff's Office. Mr. Barnes denies that he has a ?habit and routine practice? of ?targeting superiors" or that he complained falsely, acted with any malice or other intent to specifically harm or injure Mr. Urquhart, and Mr. Barnes denies the remaining allegations in Paragraph 1.2 of the Complaint. 4. Mr. Barnes lacks sufficient knowledge and information to form a belief whether Mr. Urquhart's reputation as a Sheriff of King County has been harmed and therefore denies that allegation in Paragraph 1.3 of the Complaint. Mr. Barnes further denies that Mr. Urquhart was defamed by Mr. Barnes, whether on the "eve of this November 2017 election" or at another time relevant to the allegations in Mr. Urquhart's Complaint. Mr. Barnes denies that any harm that Mr. Urquhart?s reputation as Sheriff may have suffered was caused by Mr. Barnes and denies the remaining allegations in Paragraph 1.3 of the Complaint. 5. As to Paragraphs 2.1 and 2.2 of the Complaint, Mr. Barnes admits that Mr. Urquhart was a former Sheriff of King County and admits that Mr. Urquhart is a current resident of King County. Mr. Barnes further admits that he is currently a resident and law enforcement officer residing in Massachusetts and that he separated from employment with the King County Sheriff's Office during Mr. Urquhart's tenure as . . exual Violence Le al Services Answer, Affirmative Defenses and Counterclaims ?lmy, Seattle Kim: I Snohomish - Page 2 of 15 2024 3rd Avenue, Seattle, ww 93121 Tel: 206.832.3632 riddhim@ywcaworks.org Tel: 205.436.3664 mjewell@ywcaworks.org Sheriff. Mr. Barnes denies the remaining allegations of Paragraphs 2.1 and 2.2 of the Complaint. 6. As to Paragraphs 3.1 and 3.2, Mr. Barnes admits thatjurisdiction and venue are proper before this Court, admits that the Benton Police Department investigated Mr. Urquhart for sexual assault, and denies the remaining allegations. 7. As to the allegations in Paragraph 4.1 of the Complaint, Mr. Barnes admits that he separated from employment with the King County Sheriff?s Office and that he is currentiy employed in law enforcement in Massachusetts. Mr. Barnes denies that he was actively involved in a Facebook or other campaign that defamed or made malicious or false statements about Mr. Urquhart. Mr. Barnes denies that he published covert, defamatory social media posts to harm Mr. Urquhart's reputation. Mr. Barnes denies that he falsely or maliciously claimed that he was sexually assaulted by Mr. Urquhart, because Mr. Barnes was in fact sexually assaulted by Mr. Urquhart. Mr. Barnes denies that Mr. Urquhart's reputation as sheriff was damaged during the time period relevant to this Complaint and denies that Mr. Urquhart?s reputation was harmed by statements of Mr. Barnes. Mr. Barnes admits that Mr. Urquhart shared information with the Seattle Times which was subsequently shared by the Seattle Times with Mr. Barnes. lvlr. Barnes lacks sufficient knowledge and information to form a belief as to the full extent of the information shared by Mr. Urquhart with the Seattle Times and therefore denies the allegation that information about a ?Mr. Bergeron" Facebook account was included in the information shared by Mr. Urquhart with the Seattle Times. Mr. Barnes denies that he made or published statements that were defamatory per se of Mr. Urquhart or that Mr. Urquhart is otherwise entitled to claim per se damages in this matter. Mr. Barnes . . . Sexual lv'iolence Legal Services Answer, Affirmative Defenses and Counterclaims Seattle King Snohomish - Page 3 of 15 2o24 3rd Avenue, Seattle, WA 98121 Tel: 206.832.3632 riddhim@ywcaworks.org Tel: 206.436.8664 mieweli@ywcaworks.org denies that he maliciously or falsely or otherwise exposed Mr. Urquhart to contempt or ridicule or deprived Mr. Urquhart of the benefit of public confidence or social intercourse. Mr. Barnes admits that Mr. Urquhart is a public figure and was a candidate for reelection as Sheriff of King County during the November 2017 election. Mr. Barnes denies that he made or published statements about Mr. Urquhart that were malicious or untrue or made for the purpose of harming the reputation of Mr. Urquhart. As to the remaining allegations in Paragraph 4.1, Mr. Barnes lacks sufficient knowledge and information to form a belief as to the truth of those allegations and accordingly denies those allegations. 8. As to the allegations in Paragraph 4.2 of the Complaint, Mr. Barnes admits that on November 1, 2017', the Seattle Times published a story about failure by county negotiators to seek required approval from King County Executive Dow Constantine, despite agreeing to pay [Mr. Barnes] an amount weii above the $100, 000 threshoioi that required the executive?s permission.? Mr. Barnes admits that the writer of the story in question attributed quotes to both of the parties to this action. Mr. Barnes denies that he initiated contact or attempted to solicit contact by the Seattie Times or other media. Mr. Barnes denies that that he made malicious. false or defamatory statements about Mr. Urquhart to the Seattie Times. Mr. Barnes denies that his report of sexual assault by former Sheriff Urquhart was a false report or that it was made maliciously or with an intent to defame Mr. Urquhart. Mr. Barnes also denies that former Sheriff Urquhart's reputation as sheriff has been actually damaged or damaged per se during the period of time relevant to this Complaint. Mr. Barnes denies that Mr. Urquhart has pleaded special damages with adequate specificity in his Complaint. As to the remaining . . . Sexual Violence Legal Services Answer, Affin'natlve Defenses and Counterclalms Seattle King 1 Snohomish - Page 4 of 15 2024 3rd Avenue, Seattle, we 93121 Tel: 206.832.3632 riddhim@ywcaworks.org Tel: 206.436.8654 allegations in Paragraph 4.2, Mr. Barnes lacks sufficient knowledge and information to form a belief as to the truth of those allegations and accordingly denies those aHega?ons. 9. As to the allegations in Paragraphs 4.3, 4.4, 4.4.1, 4.4.2, 4.4.3, 4.5, 4.5.1, 4.5.2, 4.5.3, 4.5.4, 4.5.5, 4.5.6, 4.5.7 and 4.5.8 of the Complaint, Mr. Barnes admits that he has served more than 15 years in law enforcement, including public service in Massachusetts and in King County, beginning in October of 2006. Mr. Barnes admits that on or about May 21, 2015, Mr. Urquhart entered on behalf of the King County Sheriff?s Office a Settlement Agreement (?Agreement" or ?the May Agreement?) with Mr. Barnes to settle pending claims as referenced by the Seattfe Times on November 1, 201? and included particular promises by Mr. Barnes and by Mr. Urquhart on behalf of KCSO. Mr. Barnes denies that Mr. Urquhart honored his promises in the May Agreement and denies that Mr. Urquhart has truthfully summarized the events leading up to the May Agreement. Mr. Barnes denies Mr. Urguhart?s false claim that Mr. Barnes has a "habit and routine practice of targeting superiors with false complaints" and has conducted a "long-running campaign to embarrass anyone in his chain of command who has criticized [his] job performance.? Mr. Barnes denies that Mr. Urquhart?s prejudicial mischaracterization of Mr. Barnes?s actions up to 15 years ago are probative or relevant in Mr. Urquhan?s defamation Complaint. As to Mr. Barnes's KCSO personnel file, official and unofficial investigative, disclosure request or complaint forms, internal KCSO reports, internal KCSO memoranda, KCSO employee SMS messages or emails dated March 20th, October 1st, 2nd, 3rd and 16th of 2014 or other documents in the custody of Mr. Urquhart or K080, and which are referenced by Mr. . . . Sexual Violence Legal Services Answer, Affirmative Defenses and Counterclaims Seattle King I Shohomish - Page 5 of 15 2024 3rd Avenue, Seattle, we. 98121 Tel: 206.832.3632 riddhim@ywcaworks.org Tel: 206.435.8664 1 mjewell@ywcaworks.org Urquhart in his Complaint, Mr. Barnes lacks unrestricted access to those materials, and he therefore lacks sufficient knowledge and information to form a belief as to the truth of the allegations and accordingly those allegations are denied. As to the remaining allegations of Paragraph 4.3, Mr. Barnes lacks sufficient knowledge and information to form a belief as to the truth of the allegations and accordingly those allegations are denied. Mr. Barnes furthermore denies any allegations in Paragraphs 4.3, 4.4, 4.4.1, 4.4.2, 4.4.3, 4.5, 4.5.1, 4.5.2, 4.5.3, 4.5.4, 4.5.5, 4.5.6, 4.5.7 and 4.5.8 of the Complaint which are not specifically admitted. 10. As to Paragraphs 4.6, 5.1, 5.2 and 5.3 of the Complaint, Mr. Barnes denies that he made or published defamatory statements about Mr. Urquhart or that his statements substantially or irrevocably or otherwise caused damage to Mr. Urquhart's reputation. Mr. Barnes denies that Mr. Urquhart is entitled actual or presumed damages, whether nominal or substantial. Mr. Barnes denies that Mr. Urquhart?s allegations entitle him to recover money damages, actual or presumed damages, or any other legal or equitable relief and denies any allegation in Paragraphs 4.6, 5.1, 5.2 or 5.3 which is not specifically admitted. 11. As to all of the allegations in Mr. Urquhart's Complaint, any allegation that is not specifically admitted is denied. ll. AFFIRMATIVE DEFENSES 12. Mr. Urquhart's claim is barred because Mr. Barnes?s statements are true. 13. Mr. Urquhart has failed to state a claim for which relief can be granted. 14. Mr. Urquhart's claim violates Mr. Barnes's qualified privilege or immunity. . . . Sexual Violence Legal Services Answer, Affirmative Defenses and Counterclalms vwce Seattie King Smhomish - Page 6 of 15 2024 3rd Avenue, Seattle, we 93121 Tel: 205.832.3532 1 riddhim?ywcaworksorg Tel: 206.436.8654 1 mjewell@ywcaworks.org 15. Mr. Barnes?s statements are protected by rights of petition, speech and press guaranteed by the Washington State and US. Constitutions. Mr. Urquhart?s Complaint is accordingly subject to stricter procedural and evidentiary requirements because Mr. Urquhart is a public figure and, during the period of time relevant to his Complaint, a public official who was standing for reelection to public office. The subject matter of his Complaint targets public and other privileged interests, including but not limited to a criminal complaint and criticism by news media of his actions as a public figure and official who had presented himself for consideration by voters as a candidate for public office. a) Mr. Urquhart?s Complaint is subject to a "clear and convincing? burden of proof and is not supported by sufficient evidence. b) Mr. Urquhart?s Complaint is not supported by sufficient proof for a prima facie or other showing of actual malice by Mr. Barnes. G) Mr. Urquhart's Complaint is not supported by sufficient proof to entitle him to claim per se damages. 16. Mr. Urquhart's claim is barred by the statute of limitations. Mr. Urquhart's claim violates RCW 4.24.510, et seq. 18. Mr. Urquhart?s claim violates equitable estoppel. 19. Mr. Urquhart?s claim violates collateral estoppel or res judicata. 20. Mr. Urquhart's claim relies on statements and documents which are subject to legal or other privilege or legal protections. 21. Mr. Urquhart?s consented to publication or republication of statements by Mr. Barnes as evidenced by Mr. Urquhart?s service as a public official; his standing as a Answer, Affirmative Defenses and Counterclaims gi??jsh - Page 7 of 15 2024 3rd Avenue, Seattle, wa 93121 Tel: 206.832.3632 I riddhim@ywcaworks.org Tel: 206.436.8664 mjewell@ywcaworks.org candidate for public office; his statements of or concerning Mr. Barnes to the Seattle Times, other media and to third parties; and other conduct. 22. Mr. Urquhart complains of avoidable consequences and otherwise had a duty to mitigate any harm. COUNTERCLAIMS IN ADDITION to the foregoing Answer and Affirmative Defenses, Defendant Mr. Barnes alleges and counterclaims against Mr. Urquhart: A. DEFAMATION 23. Mr. Urquhart is a public figure and was a public official during the period of time relevant to his Complaint. Mr. Urquhart was elected and served as Sheriff of King County from January 2013 through December 31, 201?. Mr. Urquhart had submitted his candidacy for reelection as Sheriff to the voters of King County for the November 2017' King County Sheriff election, but he was not elected. Prior to Election Day on November 6th, 201?, Mr. Urquhart was referenced repeatedly in stories published by the Seattle Times and other social and news media. As part of his campaign, Mr. Urquhart sought publication of media stories, in part, to familiarize voters with his campaign. Prior to publication of the November tst, 201? Seattle Times article referenced at Paragraph 4.1 of his Complaint, Mr. Urquhart shared information with the Seattle Times. Such information shared by Mr. Urquhart included false information of or concerning Mr. Barnes: Urquhart described Barnes as ?an organizational terrorist? . . . [and] handed over a stack of records last month to The [Seattle] Times to illustrate that the deputy has harassed or made complaints against more than 30 people, with incidents dating back to 2003, about three years before he was hired at the Sheriff?s Office. . . . Sexual Violence Legal Services Answer, Affirmative Defenses and Counterclaims YWCA Seattle I King Snghomish - Page 8 of 15 mm 3rd Avenue, Seattle, WA 93121 Tel: 206.832.3632 riddhim@ywcaworks.org Tel: 206.436.8664 mjeweli@ywcaworks.org [Mn] Urquhart . . . accused Barnes of concocting lies that are . . purely evil.? After Mr. Urquhart shared false information with the Seattie Times, Mr. Barnes was asked by a Seattie Times reporter to comment on the information about Mr. Barnes that was given to the Seattie Times by Mr. Urquhart. Mr. Barnes did not initiate or solicit contact with the Seattie Times about the November 1, 2017 news story. There is a compelling public interest during an election in questions of public interest, including but not limited to questions pertinent to candidates seeking election to the office of Sheriff of King County. In order to serve that public interest, the Seattie Times and other media investigated and published stories about Mr. Urquhart prior to November 6, 201? and at other times. 24. Mr. Barnes was a private figure during the period of time relevant to Mr. Urquhart's Complaint. Mr. Barnes?s defamation claim must satisfy a negligence standard because Mr. Barnes is a private figure. On March 26th, 2014, Mr. Urquhart sexually assaulted Mr. Barnes during Mr. Urquhart?s tenure as Sheriff of the KCSO. Mr. Barnes felt ashamed and intimidated by Mr. Urquhart?s assault. Eventually, Mr. Barnes reported the sexual assault to law enforcement. Mr. Barnes did not initiate or solicit contact by the Seattie Times for the November 1, 2017 Seaitie Times article referenced at Paragraph 4.1 of Mr. Urquhart?s Complaint. It was Mr. Urquhart who first shared information of or concerning Mr. Barnes with the Seattie Times and other media. Mr. Barnes was then asked by the Seattie Times to respond to the information about Mr. Barnes, which Mr. Urquhart had shared with the Seaitie Times. Mr. Barnes did not seek to publicize the matters published in the Seattie Times in the November 1, 2017 article . . Sexual Vi fence Le alServi Answer, Affirmative Defenses and Counterclaims YWCA Segue King Snohgersish - Page 9 of 15 2024 3rd Avenue, Seattle, WA 93121 Tel: 205.832.3632 riddhim@ywcaworks.org Tel: 206.436.8664 mjewell@ywcaworks.org referenced in Mr. Urquhart?s Complaint. The Seattle Times investigated and published the November 1, 2017 article referenced in Mr. Urquhart?s Complaint. Mr. Barnes was contacted by the Seattle Times and other media after Mr. Urquhart's shares information about Mr. Barnes with those media, which caused Mr. Barnes to experience severe emotional distress. Mr. Barnes declined to speak to a number ofjournalists and was forced to change his phone number and email address in effort to avoid media contact and reestablish some semblance of privacy 25. Mr. Urquhart's statements of or concerning Mr. Barnes are unprotected by absolute or qualified immunity orprivileqe, or constitute an abuse of such a privilege or immunity. On or about May 21, 2015, Mr. Urquhart signed the May Agreement with Mr. Barnes on behalf of KCSO to resolve pending claims. As part of the May Agreement, Mr. Barnes agreed to separate from employment with KCSO. In the Agreement, Mr. Urquhart agreed that shall not disparage Deputy Barnes.? In the Agreement, Mr. Urquhart agreed that the definition of KCSO included ?Mr. Urquhart? and other individuals. Mr. Urquhart further agreed to provide a positive letter of reference for Mr. Barnes to present to prosoective future employers. In the Agreement, Mr. Urquhart agreed not to "render any findings or other determination, andior recommend or impose any discipline, related to, or in connection with" an internal investigation of Mr. Barnes by KCSO or ?any other allegations that have been or may be brought against or regarding? Mr. Barnes. During the time period relevant to these Counterclaims, Mr. Urquhart was subject to the Agreement and to other legal and professional duties intended to protect his employees, the public and Mr. Barnes. By abusing and acting outside the scope of the privileges or immunities conferred upon him as alleged herein, Sexual Vioience Legal Services Answer, Af?rmative Defenses and Counterclalms vwca Seattle King I Sn?homish - Page 10 of 15 2024 3rd Avenue, Seattle, WA 98121 Tel: 206.832.3632 riddhim@ywcawork5.org Tel: 206.436.8664 1 mjewell@ywcaworks.org Mr. Urquhart lost any protection of such privileges or immunities which may have applied. 26. Mr. Urquhart defamed Mr. Barnes. After signing the Agreement, Mr. Urquhart published unprivileged and false statements of or concerning Mr. Barnes. When publishing such statements, Mr. Urquhart knew the statements were false, in part because positive information and context about Mr. Barnes were omitted, and false statements were included. Mr. Urquhart published the statements directly with the malicious intent of damaging Mr. Barnes?s reputation for truthfulness, or he did so negligently, or he caused or directed others to do so on his behalf. Such statements by Mr. Urquhart were defamatory statements, which included but were not limited the following: a) In May of 2016, Mr. Urquhart caused orfailed to prevent Mr. Barnes's name from being falsely published on ?The Brady List? in King County of dishonest police officers. b) Mr. Urquhart made false statements of or concerning Mr. Barnes to The Seattle Times, describing lVlr. Barnes as ?an organizational terrorist? and accusing him of making up lies that are . . purely evil.? c) On December 4th, 2017, Mr. Urquhart falsely stated during a radio interview that Mr. Barnes had been ?fired? from his employment with KCSO. d) On information and belief, Mr. Urquhart published these and other false statements to third parties in a malicious effort to impeach and destroy Mr. Barnes's reputation for truthfulness in advance of the November 6, 2017 Election Day, including . . . Sex alVi alService Answer, Affirmative Defenses and Counterclaims ng? Segt?eieK??g Snohoniish - Page 11 of 15 2024 3rd Avenue, Seattle, WA 98121 Tel: 206.832.3632 riddhim@ywcaworks.org Tel: 206.436.8664 effort to recruit a third party to prevent Mr. Barnes from receiving employment after Mr. Barnes left KCSO. Mr. Urquhart damaged Mr. Barnes?s reputation. Mr. Barnes believes that Mr. Urquhart's selective use of investigative and personnel documents as well as false statements to attack Mr. Barnes's reputation for truthfulness was part of Mr. Urquhart?s customary approach to deflecting accountability while he was Sheriff of KCSO. Mr. Barnes believes that Mr. Urquhart has interfered in more than one otherwise neutral KCSO investigation by using his power as Sheriff to improperly influence an investigator. Mr. Barnes believes that Mr. Urquhart also used his authority to improperly influence whether the findings of an investigation would be formally classified with a designation resulting in disclosure outside of KCSO. Further, Mr. Barnes believes that Mr. Urquhart used his power as ?Loudermill Chief? to also decide on what, if any, discipline to impose on the individual investigated. Mr. Barnes believes that, as Sheriff, Mr. Urquhart thought he was above the rules that other KCSO law enforcement personnel were bound by duty to follow. 28. After Mr. Urquhart forced Mr. Barnes out of K080 and, effectively, out of King County, Mr. Urquhart then acted maliciously to attack Mr. Barnes's reputation with false information. Mr. Urquhart's false statements and actions alleged herein falsety portrayed Mr. Barnes as a liar and an undesirable employee despite Mr. Urquhart?s promises made in the Agreement between K080 and Mr. Barnes. Mr. Urquhart's publication of such falsehoods were defamatory per as by exposing Mr. Barnes to hatred, contempt, ridicule and obloquy; by depriving Mr. Barnes of the benefit of public confidence and social intercourse in and outside of King County; and by injuring Mr. Barnes in his . . . Sexual Violence Legal Servicer. Answer, Affirmative Defenses and Counterclaims YWCA Seattle Snohornish - Page 12 of 15 2024 3rd Avenue, Seattle, WA 93121 Tel: 206.332.3632 riddhim@ywcaworks.org Tel: 206.435.8664 mjewell@ywcaworks.org profession of law enforcement. As a direct and proximate result of Mr. Urquhart's false statements which were published as described herein, Mr. Barnes suffered, and will continue to suffer, harm to his reputation, lost income, severe emotional and distress. B. BREACH OF THE COVENANT OF GOOD FAITH AND FAIR DEALING 29. Mr. Barnes repeats and incorporates the allegations of Paragraphs 23 through 28 above as if fully restated in this Paragraph. 30. By and through his actions described above, Mr. Urquhart breached the implied covenant of good faith and fair dealing legally embodied by the Agreement. 31. As a direct and proximate result of Mr. Urquhart's breach of the implied covenant of good faith and fair dealing, Mr. Barnes has suffered and will continue to suffer damage to his reputation, lost income and severe emotional and distress. C. TORTIOUS INTERFERENCE WITH CONTRACT 32. Mr. Barnes repeats and incorporates the allegations of Paragraphs 23 through 28 above as if fully restated in this Paragraph. 33. By and through his actions described above, Mr. Urquhart tortiously interfered with the Agreement between Mr. Barnes and King County and, in doing so, intentionally deprived Mr. Barnes of the benefits and value accruing to him from performance under the Agreement. 34. As a direct and proximate result of Mr. Urquhart's tortious interference with the Agreement between Mr. Barnes and King County, Mr. Barnes has suffered and will . Sexual Violence Le al Services Answer, Affirmative Defenses and Counterclaims Seam King Snohomish - Page 13 of 15 2o24 3rd Avenue, Seattle, ws 93121 Tel: 206.832.3632 riddhim@ywcaworks.org Tel: 206.436.8664 mjewell@ywcaworks.org continue to suffer damage to his reputation, lost income and severe emotional and distress. D. OUTRAGE 35. Mr. Barnes repeats and incorporates the allegations of Paragraphs 21 through 28 above as if fully restated in this Paragraph. 36. By and through his actions described above, Mr. Urquhart intentionally or recklessly caused emotional distress to Mr. Barnes by extreme and outrageous conduct and is liable for severe emotional distress resulting from such conduct. IV. REQUESTED WHEREFORE, Mr. Barnes respectfully requests that this Honorable Court enter personal judgment against Mr. Urquhart and in favor of Mr. Barnes for presumed damages, either nominal or substantial, in an amount to be proved at trial, for money damages sufficient to reasonably and fairly compensate Mr. Barnes for the total amount of such actual damages as were caused by Mr. Urquhart, including past and future economic and noneconomic damages, damage to reputation, pain and suffering, moving costs, legal fees and costs of suit, in an amount to be proved at the trial of this matter, as well as other interim or final relief supported by evidence and law or equity. If! Sexual lifiolence Le al Services Answer, Affirmative Defenses and Counterclalms vaA Seattle Kin: snohgmish - Page 14 of 15 2o24 3rd Avenue, Seattle, WA 98121 Tel: 266.832.3632 riddhim@ywcaworks.org Tel: 206.436.8664 1 mjewell@ywcaworks.org Signed at Seattle, WA on January 8, 2018. Answer, Affirmative Defenses and Ccunterclaims -Page 15 01?15 Respectfully submitted, Sexual Violence Legal Services of YWCA Seattle King Snchemish Weft/W Riddhi?Mukhcpad?yay, I RA No. 42759 Monte Jewell, WSBA No. 2190 2024 Third Avenue Seattle, WA 98121 Tel: (206) 832-3632 (206) 436-8664 Email: riddhim@ywcaw0rks.crg Sexual Violence Legal Services YWCA Seattle King 2024 3rd Avenue, Seattle, WA 98121 Tel: 206.832.3632 1 Tel: 205.436.8564