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<br />Denies that DeBruyn stated that he had a "personal belief that a preference to Ramsey <br /> <br /> <br />residents was bad policy because he feared a Ramsey student influx would be based upon <br /> <br /> <br />proximity to [PACT].': <br /> <br /> <br />Lacks information or knowledge sufficient to form a belief as to what plaintiff believes <br /> <br /> <br />PACT is prepared to do, but denies that PACT's current enrollment policy is. erroneous, that <br /> <br /> <br />PACT is not following statutory mandates, and that PACT is damaging plaintiffs son's <br /> <br /> <br />enrollment prospects or that of any other applicant.. States that DeBruyn communicated to <br /> <br />plaintiff that PACT would postpone the kindergarten lottery until April 15th and that PACT was <br /> <br /> <br />willing to work withMDE and with legal counsel regarding the interpretation of S 124D.I0. <br />FIRST AFFIRMATIVE DEFENSE <br />12. The Complaint fails to state a claim upon which relief can be granted. <br />SECOND AFFIRMATIVE DEFENSE <br />13. The Complaint is barred by public policy. <br />THIRD AFFIRMATIVE DEFENSE <br />14. Plaintiff, and those he claims to represent, lack standing. <br />FOURTH AFFIRMATIVE DEFENSE <br />15. Neither plaintiff, nor those he purports to represent, have suffered any injuries or <br />damages. . <br /> <br />FIFTH AFFIRMATIVE DEFENSE <br />16. Plaintiffs action is premature. <br />SIXTH AFFIRMATIVE DEFENSE <br /> <br />17. <br /> <br />Certification of the alleged class, or any class, is not appropriate. <br />SEVENTH AFFIRMATIVE DEFENSE <br />Plaintiff has failed to mitigate his damages. <br /> <br />18. <br /> <br />2155903v4 <br /> <br />3 <br /> <br />-153- <br />