Electronically Filed

4/1/2020 11:54 AM
Fourth Judicial Ada County
District,
Phil McGrane, Clerk of the Court
By: Timothy Lamb, Deputy Clerk

Lawrence G. Wasden
Attorney General

Trudy Hanson Fouser, ISB No. 2794

Special Deputy Attorney General
tfouser@gfidaholaw.c0m
Marisa S. Crecelius, ISB No. 8011
mcrecelius@gfidah01aw.com
Emma C. Nowacki, ISB No. 10742
enowacki@gfidaholaw.com
GJORDING FOUSER, PLLC
Plaza One Twenty One
121 North 9th Street, Suite 600
Boise, Idaho 83702
Telephone: 208.336.9777
Facsimile: 208.336.9177
E-service: gfcases@gfidaholaw.com

Attorneys for Defendant Idaho State Department 0f

Education

IN THE DISTRICT COURT OF THE FOURTH JUDICIAL DISTRICT OF

THE STATE OF IDAHO, IN AND FOR THE COUNTY OF ADA

KELLY BRADY,

Plaintiff, Case N0. CV01-20-02683

V.
DEFENDANT’S ANSWER TO
IDAHO STATE DEPARTMENT OF PLAINTIFF’S COMPLAINT AND
EDUCATION, an executive agency 0f the DEMAND FOR JURY TRIAL
State Board 0f Education,

Defendant.

COMES NOW, Defendant Idaho State Department 0f Education (“Defendant”) by and

through its counsel 0f record, Gjording Fouser, PLLC, in answer to Plaintiff’s Complaint and

DEFENDANT’S ANSWER TO PLAINTIFF’S COMPLAINT AND DEMAND FOR JURY TRIAL

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Demand for Jury Trial (“Plaintiff’s Complaint”) on file herein, admit, deny, and allege as

follows:

INTRODUCTION
The following defenses are not stated separately as t0 each claim for relief or

allegation of Plaintiff. Nevertheless, the following defenses are applicable, Where

appropriate, to any and all 0f Plaintiffs claims for relief. In asserting the following defenses,

Defendant does not admit that the burden 0f proving the allegations 01" denials contained in

the defenses is upon Defendant but, t0 the contrary, asserts that by reason of said denials,

and by reason 0f relevant statutory and judicial authority, the burden 0f proving the facts

relevant to many of the defenses and the burden of proving the inverse 0f the allegations

contained in many of the defenses is upon Plaintiff.

FIRST DEFENSE

1. Plaintiff’s Complaint fails t0 state a claim upon Which relief may be granted.

SECOND DEFENSE
2. Defendant denies each and every allegation 0f Plaintiff’s Complaint not herein

expressly and specifically admitted. Defendant specifically denies any liability under the

Complaint. To the extent the allegations call for a conclusion 0f law, that conclusion is

specifically denied.

NATURE OF THE CASE

3. Defendant denies the allegations.

PARTIES
4. As to paragraph 1 of Plaintiff’s Complaint, Defendant admits the allegations.

DEFENDANT’S ANSWER TO PLAINTIFF’S COMPLAINT AND DEMAND FOR JURY TRIAL

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 5. As t0 paragraph 2 of Plaintiff’s Complaint, Defendant admits that Kelly Brady

(“Ms. Brady”) at all times relevant was an employee of the State 0f Idaho, State Department

0f Education. Defendant is Without sufficient knowledge to admit or deny the remaining

allegations and, therefore, they are denied.

JURISDICTION AND VENUE

6. As to paragraphs 3-5 0f Plaintiff’s Complaint, Defendant admits jurisdiction

and venue are proper; Defendant, however, denies the amount in controversy exceeds

$10,000.00.

GENERAL ALLEGATIONS
7. As t0 paragraph 6 0f Plaintiff’s Complaint, Defendant admit that Ms. Brady

was an educator for a number of years, but Defendant has insufficient knowledge t0 admit

0r deny whether Ms. Brady was an educator for 34 years.

8. As t0 paragraph 7 of Plaintiff’s Complaint, Defendant admits that Ms. Brady

was known as a competent and qualified educator, but Defendant denies that Ms. Brady’s

performance was generally considered “outstanding” or that she had a particular “expertise”

above and beyond that of a qualified educator.

9. As t0 paragraph 8 of Plaintiff’s Complaint, Defendant admits that

Superintendent Sherri Ybarra received recommendations regarding Ms. Brady for the

position of Director 0f Mastery Education in Idaho, but Defendant has insufficient knowledge

t0 admit 0r deny whether Superintendent Ybarra personally called Ms. Brady and asked her

t0 accept the position. However, Defendant denies that Superintendent Ybarra had extensive

personal knowledge of Ms. Brady’s professionalism and performance as an educator.

DEFENDANT’S ANSWER TO PLAINTIFF’S COMPLAINT AND DEMAND FOR JURY TRIAL

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Defendant further admits that Ms. Brady accepted the position. Defendant denies that Ms.

Brady was solely responsible for creating the Mastery Education Initiative in Idaho Schools.

10. As to paragraph 9 of Plaintiff’s Complaint, Defendant admits that some school

districts began the process 0f adopting the initiative but Defendant denies that the initiative

was solely built under Ms. Brady’s leaders. Answering further, Ms. Brady had the help of

the Jeb Bush Foundation and other entities in implementing the initiative.

11. As to paragraph 10 0f Plaintiff’s Complaint, Defendant admits that Ms. Brady

had received positive evaluations in the past. Defendant further admits that Superintendent

Ybarra 0n occasion praised Ms. Brady for her performance and tried t0 offer Ms. Brady

supportive feedback. Defendant admits that Superintendent Ybarra text messaged Ms.

Brady 0n or about November 9, 2017 the following statement: “Just want to say sorryI didn’t

get to talk to you at ISBA...I heard your presentation was awesome. Thanks for being

3
awesome.’ Answering further, Superintendent Ybarra became aware 0f the fact that the

legislature was critical 0f the Mastery Education Initiative and Ms. Brady’s reports.

Furthermore, sometime before the summer 0f 2019, Superintendent Ybarra learned that Ms.

Brady could n01: handle being in charge 0f both the Mastery Based Education program and

the Content and Curriculum program, as there were certain aspects 0f both programs that

were not being sufficiently managed.

12. As t0 paragraph 11 0f Plaintiff’s Complaint, Defendant admits that

Superintendent Ybarra had confidence in Ms. Brady and allowed her take over the Content

and Curriculum program. Defendant denies that Superintendent Ybarra initially asked Ms.

Brady t0 take over the program when the vacancy became available. Rather it was Ms. Brady

Who suggested that she could take 0n the additional role 0f overseeing Content and

DEFENDANT’S ANSWER TO PLAINTIFF’S COMPLAINT AND DEMAND FOR JURY TRIAL

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Curriculum. Answering further, Superintendent Ybarra still had some concerns and doubts

that any one person could handle both roles, and Superintendent Ybarra communicated her

concerns t0 Ms. Brady.

13. As to paragraph 12 of Plaintiff’s Complaint, Defendant admits that

Superintendent Ybarra, in accordance with her goal 0f providing encouragement to her

directors, may have expressed praise and appreciation for Director Brady’s hard work in

August of 2018 and January 0f 2019. However, Defendant has insufficient knowledge t0

specifically admit that Superintendent Ybarra text messaged Ms. Brady in January 0f 2019,

“Nice job U [sic] rocked it so impressive!!!! I was in the back...Again...thank you for all you

do!!”

14. As to paragraph 13 of Plaintiff’s Complaint, Defendant admits the allegations.

15. As to paragraph 14 0f Plaintiff’s Complaint, Defendant admits the allegations.

16. As to paragraph 15 of Plaintiff’s Complaint, Defendant admits only that

Human Resources Program Manager Sheena Buffi asked questions of Ms. Brady specific to

the employee under investigation. Defendant has insufficient knowledge t0 admit or deny

Whether Human Resources Program Manager Sheena Buffi inquired as t0 the overall

environment at SDE.

17. As 1:0 paragraph 16 of Plaintiff’s Complaint, Defendant has insufficient

knowledge t0 admit 0r deny Whether Ms. Brady stated t0 Human Resources Program

Manager Sheena Buffi that she felt as though the environment at SDE was hostile under the

direction and supervision 0f Superintendent Ybarra, and that people were fearful 0f losing

their jobs. Therefore, Defendant denies the allegations in paragraph 16.

DEFENDANT’S ANSWER TO PLAINTIFF’S COMPLAINT AND DEMAND FOR JURY TRIAL

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 18. As t0 paragraph 17 of Plaintiff’s Complaint, Defendant denies that

Superintendent Ybarra received a copy of 0r reviewed the investigative report 0r any written

interviews or statements. Rather, Superintendent Ybarra was briefed 0n the findings 0f the

investigation. Defendant admits that Deputy Superintendent Peter McPherson received a

copy of the report. Defendant denies that Deputy Superintendent Peter McPherson and

Superintendent Ybarra began retaliating against Ms. Brady for her participation in the

investigation.

19. As t0 paragraph 18 of Plaintiffs Complaint, Defendant had insufficient

knowledge t0 admit or deny specifically any conversation that took place between Tim

McMurtry and Ms. Brady. Therefore, Defendant denies the allegations in paragraph 18.

Answering further, Defendant denies that Superintendent Ybarra 0r Deputy Superintendent

McPherson had any knowledge that Ms. Brady had told Tim McMurtry that she felt there

was a hostile workplace at SDE.

20. As to paragraph 19 of Plaintiffs Complaint, Defendant denies that, in April 0f

2019 or at any point thereafter, Superintendent Ybarra was ignoring or attempting t0 isolate

Ms. Brady.

a. Defendant has insufficient knowledge t0 admit 0r deny any Specific

conversations between Mr. McMurtry and Ms. Brady. Therefore, Defendant

denies the allegation in paragraph 19(3).

b. Defendant has insufficient knowledge t0 admit or deny What Ms. Brady

“learned.” Defendant further denies the allegation in paragraph 19(b) that

Superintendent Ybarra had instructed Portia Flynn not t0 speak t0 Ms. Brady.

DEFENDANT’S ANSWER TO PLAINTIFF’S COMPLAINT AND DEMAND FOR JURY TRIAL

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 c. Defendant denies the allegations in paragraph 19(0). Answering further,

Defendant states that Superintendent Ybarra was always friendly and cordial

with Ms. Brady, and Superintendent Ybarra believed that they had a positive

working relationship up until Ms. Brady’s termination.

d. Defendant denies the allegation in paragraph 19(d) but states that if a meeting

were canceled, it was not 0n account of any hostility or ill Will toward Ms.

Brady.

21. As to paragraph 20 0f Plaintiffs Complaint, Defendant admits that 0n or about

May 9, 2019, Superintendent Ybarra and Deputy Superintendent McPherson called Ms.

Brady t0 discuss With her that they were bringing in a co-director t0 share the duties of the

Content and Curriculum and the Mastery Education programs, as the responsibilities 0f both

programs appeared t0 be too much for a single person to handle. Answering further,

Superintendent Ybarra believed that Ms. Brady was receptive t0 sharing the duties With a

co-director, and Ms. Brady did not express any disappointment or concern regarding sharing

the duties.

22. As to paragraph 21 of Plaintiff’s Complaint, Defendant admits Superintendent

Ybarra communicated t0 MS. Brady that running the Content and Curriculum Program and

the Mastery Based Education Program was too much work for a single person, including Ms.

Brady. Defendant further admits that Superintendent Ybarra had praised Ms. Brady in the

past. Answering further, Superintendent Ybarra also had concerns in the past that Ms. Brady

was not adequately completing some 0f the responsibilities 0f the job. Defendant has

insufficient knowledge t0 admit 0r deny Whether Superintendent Ybarra specifically told Ms.

DEFENDANT’S ANSWER TO PLAINTIFF’S COMPLAINT AND DEMAND FOR JURY TRIAL

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Brady that the decision t0 hire a new co-director had nothing t0 do With her performance,

and, therefore, Defendant denies the allegation.

23. As to paragraph 22 of Plaintiff’s Complaint, Defendant admits the allegations

and further states that it was ultimately Superintendent Ybarra that made the decision t0

bring on a co-director.

24. As t0 paragraph 23 0f Plaintiffs Complaint, Defendant has insufficient

knowledge t0 admit 0r deny What Ms. Brady “discovered” 0r believed Ms. Brady knew about

Director Driver. Defendant denies that Superintendent Ybarra offered the position 0f co-

director t0 Director Driver because he is a “personal friend.” However, Defendant admits

that Director Driver was recommended by Deputy Superintendent McPherson. Defendant

has insufficient knowledge at this time to admit or deny the specifics of Ms. Brady and

Director Driver’s experiences in teaching mastery curriculum, but Defendant states that both

Ms. Brady and Director Driver were qualified for the position of co-director. Answering

further, Defendant states that Director Driver had a Masters of Education in Curriculum &

Instruction. Prior to his appointment in June 0f 2019, Director Driver served as a Vice

Principal and had experience as an educator for 7th and 8th grade curriculum. He also had

taught the subjects of Biology, Health, Art and Physical Science.

25. As to paragraph 24 of Plaintiff’s Complaint, Defendant admits that in June 0f

2019, Director Driver started in the position as co-director of Content and Curriculum and

Mastery Education. Defendant has insufficient knowledge t0 admit 0r deny Whether Director

Driver ever stated that he was “here t0 clean up Kelly Brady’s mess,” and, therefore,

Defendant denies the allegations. Answering further, Defendant denies that Superintendent

Ybarra had any knowledge 0f Director Driver saying anything disparaging about Ms. Brady’s

DEFENDANT’S ANSWER TO PLAINTIFF’S COMPLAINT AND DEMAND FOR JURY TRIAL

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performance. However, Director Driver did communicate t0 Superintendent Ybarra in the

weeks following his appointment that Ms. Brady was sometimes difficult t0 work With and

uncooperative.

26. As t0 paragraph 25 of Plaintiff’s Complaint, Defendant denies that Director

Driver stated on July 16, 2019 that Ms. Brady would only be in charge 0f Mastery Education

from then 0n out. Defendant further denies any suggestion that a meeting was intentionally

sprung on Ms. Brady. Rather, it was Ms. Brady Who refused to attend a meeting. Answering

further, Superintendent Ybarra wanted Director Driver and Ms. Brady t0 work together,

with Director Driver focusing on Common Core and Ms. Brady focusing 0n Mastery

Education.

27. As t0 paragraph 26 of Plaintiff’s Complaint, Defendant admits that Ms. Brady

attended a conference in Big Sky, Montana, and held herself out as a representative from

SDE. Defendant has insufficient knowledge to admit 0r deny whether anyone at SDE

approved Ms. Brady holding herself out as a representative at the conference. Defendant also

has insufficient knowledge t0 admit 0r deny what occurred at the conference, and, therefore,

Defendant denies the remaining allegation in paragraph 26.

28. As t0 paragraph 27 of Plaintiff’s Complaint, Defendant admits the allegations.

To explain further, Ms. Brady was placed on paid administrative leave because she was being

investigated in response t0 allegations by her subordinates 0f misconduct and Violations 0f

several policies, such as the Respectful Workplace Policy, the IT Data Security Policy, and

SDE procurements policies. Furthermore, as the investigation into MS. Brady evolved,

subordinates 0f Ms. Brady made further allegations against her, including, but not limited

t0, the following:

DEFENDANT’S ANSWER TO PLAINTIFF’S COMPLAINT AND DEMAND FOR JURY TRIAL

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 a. Ms. Brady stated that a co-worker was 0n the autism spectrum;

b. Ms. Brady made disparaging comments about a co-worker’s performance t0

another co-worker and the Team;

C. Ms. Brady made hand gestures that mocked another co-worker’s arthritic

condition;

d. Ms. Brady made statements about the sexual orientation 0f a co-worker;

e. Ms. Brady walked out 0f the July 16, 2019 meeting; and

f. Ms. Brady calling a co-worker “pigeon toed” or “knock kneed.”

29. As t0 paragraph 28 of Plaintiff’s Complaint, Defendant admits that Deputy

Superintendent McPherson related to Ms. Brady that he was concerned about the allegations

against Ms. Brady. Defendant further admits that Deputy Superintendent McPherson’s prior

feedback to Ms. Brady about her performance was mostly positive.

30. As t0 paragraph 29 of Plaintiff’s Complaint, Defendant admits that Deputy

Superintendent McPherson had provided Plaintiff with an exemplary performance

evaluation in April of 2018. Defendant has insufficient knowledge t0 admit or deny Whether

Deputy Superintendent McPherson addressed specific performance concerns With Ms. Brady

following her return from the conference in Big Sky.

31. As t0 paragraph 30 0f Plaintiff’s Complaint, Defendant has insufficient

knowledge t0 admit 0r deny the allegations in paragraph 3O and, therefore, Defendant denies

the allegations.

32. As t0 paragraph 31 0f Plaintiff’s Complaint, Defendant admits that on August

12, 2019, Ms. Brady was provided With her termination letter. Defendant further admits that

the letter stated that investigation had not concluded. Answering further, Defendant had

DEFENDANT’S ANSWER TO PLAINTIFF’S COMPLAINT AND DEMAND FOR JURY TRIAL

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completed the investigation process and findings but had not finalized the written formal

investigative report.

33. As t0 paragraph 32 0f Plaintiffs Complaint, Defendant denies the allegations

and denies any implication that there is a culture 0f hostility at SDE under the direction 0f

Superintendent Ybarra. Rather, Superintendent Ybarra orders an investigation by either the

Idaho Division 0f Human Resources, the Attorney General’s Office, 0r an outside investigator

regarding every allegation 0f hostile work environment, discrimination 0r retaliation.

Superintendent Ybarra does not tolerate harassment, hostility, discrimination, retaliation,

or Violations 0f policy Within her department. Furthermore, Superintendent Ybarra takes

appropriate personnel action against employees Who engage in hostility, discrimination,

Violations of policy, 0r retaliation against other employees. As such, Superintendent Ybarra

ordered the termination 0f Ms. Brady When Violations 0f policy were substantiated in an

investigation.

FIRST CLAIM FOR RELIEF

(Violation of the Idaho Protection of Public Employees Act against
Defendant SDE)

34. As t0 paragraph 33 0f Plaintiff’s Complaint, such paragraph re-alleges and

incorporates the allegations made in paragraphs 1-32, and such allegations are admitted or

denied as stated above.

35. As t0 paragraph 34 Plaintiff’s Complaint, Defendant admits the allegations.

36. As to paragraph 35 of Plaintiff’s Complaint, Defendant admits that Ms. Brady

participated and gave information in an investigation into an employee creating a hostile

work environment. Defendant denies that Ms. Brady’s participation rose to the level 0f

“protected activity” under I.C. 6-2104(2). Answering further, if Ms. Brady made a statement

DEFENDANT’S ANSWER TO PLAINTIFF’S COMPLAINT AND DEMAND FOR JURY TRIAL

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about Superintendent Ybarra’s leadership, Defendant denies that Superintendent Ybarra

was aware of the statement.

37. As t0 paragraph 36 0f Plaintiff’s Complaint, Defendant denies the allegations.

Answering further, Defendant is unaware of any statement that Ms. Brady made regarding

“issues 0f waste resulting from the hostile work environment and bullying...” Defendant

further denies that Ms. Brady made any such communication (as alleged in paragraph 35) t0

any individual in leadership at SDE.

38. As t0 paragraph 37 0f Plaintiff’s Complaint, Defendant denies that it engaged

in any retaliatory acts and further denies that Ms. Brady communicated waste issues in good

faith. Answering further, Defendant denies ostracizing Ms. Brady and failing t0 communicate

With Ms. Brady. Defendant admits that Superintendent Ybarra hired a co-director to help

out Ms. Brady, Who was unable t0 adequately perform as Director 0f both Mastery Education

and Content and Curriculum programs. Furthermore, Defendant admits only that it placed

Ms. Brady on leave pending an investigation after learning 0f allegations from Ms. Brady’s

subordinates that Ms. Brady acted unprofessionally and created a hostile work environment

for her staff.

39. As to paragraph 38 0f Plaintiff’s Complaint, Defendant denies that it

terminated Ms. Brady based on any retaliatory motive. Answering further, Defendant

terminated MS. Brady’s employment because the allegations by her subordinates 0f her

unprofessionalism, hostility toward subordinates, and various Violations of policy were

substantiated after the Attorney General’s Office conducted a lengthy investigation into

those allegations.

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 40. As t0 paragraph 39 0f Plaintiff’s Complaint, Defendant denies the allegations,

including that Ms. Brady engaged in protected activity or that Defendant took adverse

actions against her as a result of any alleged protected activity.

41. As t0 paragraph 40 0f Plaintiff’s Complaint, Defendant denies the allegations.

42. As to paragraph 41 of Plaintiffs Complaint, Defendant denies the allegations.

PRAYER FOR RELIEF

43. While Plaintiff’s “Prayer for Relief” does not require a response, insofar as an

answer is deemed necessary, Defendant denies the allegations as set forth in this section 0f

Plaintiff’s Complaint, and denies that Plaintiff is entitled to the requested relief 01" t0 any

relief whatsoever. Defendant further denies that Plaintiff is entitled to a jury trial t0

determine Whether she is entitled t0 any relief as stated in her Complaint.

THIRD DEFENSE
Plaintiff had, and continues t0 have, the ability and opportunity t0 mitigate the

damages alleged With respect to the subject matter 0f this action and has failed to mitigate

said damages.

FOURTH DEFENSE
Plaintiff’s claims may be barred by the doctrine 0f after-acquired evidence.

FIFTH DEFENSE

Defendant, at all times relevant t0 the claims at issue, engaged in good faith efforts

to comply with all applicable laws.

SIXTH DEFENSE

Defendant states that, even if Plaintiff is able t0 prove that a prohibited factor

motivated the Defendant’s alleged employment action, Which Defendant expressly denies,

DEFENDANT’S ANSWER TO PLAINTIFF’S COMPLAINT AND DEMAND FOR JURY TRIAL

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the same action would have been taken absent such motivation and, therefore, the Plaintiff’s

claims must fail.

SEVENTH DEFENSE
Plaintiff has waived, 0r by her conduct estopped from asserting, the causes 0f action

contained in the Complaint.

EIGTH DEFENSE

Plaintiff seeks t0 recover damages that are Wholly speculative in nature and

unsupported by a reasonable, good faith basis.

NINTH DEFENSE
Plaintiff’s claims are barred under the substantial truth doctrine.

TENTH DEFENSE
Defendant’s actions were taken for legitimate, and non-retaliatory reasons.

ELEVENTH DEFENSE
Plaintiff cannot recover punitive damages because at n0 time did Defendant act with

malice 0r reckless indifference.

TWELTH DEFENSE
Any recoverable damages under Plaintiff’s First Claim for relief is limited by statute,

and Plaintiff is precluded from recovering general and punitive damages.

THIRTEENTH DEFENSE
Plaintiff’s claims are barred by the doctrine 0f unclean hands.

RESERVATION OF RIGHTS
Discovery has not yet commenced, and the result 0f discovery may reveal additional

defenses to Defendant. Therefore, Defendant reserves the right, after discovery has been

DEFENDANT’S ANSWER TO PLAINTIFF’S COMPLAINT AND DEMAND FOR JURY TRIAL

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completed, t0 amend this Answer t0 add additional defenses supported by the facts. Failure

t0 include such defenses in this Answer should not be deemed a waiver 0f any right t0 further

amend this Answer.

REQUEST FOR ATTORNEY FEES

As a result of the filing of Plaintiff’s Complaint, Defendant has been required t0 retain

legal counsel t0 defend this action and is entitled t0 recover attorney fees, pursuant to the

provisions contained in Idaho Code § 12-120(3), §6-918A, and Rule 54 0f the Idaho Rules 0f

Civil Procedure, and any other applicable rules 0r statutes.

WHEREFORE, Defendant prays for judgment as follows:

1. Plaintiff’s Complaint be dismissed With prejudice, and that judgment be

entered for Defendant and against Plaintiff, and that Plaintiff take nothing thereby.

2. For costs, including reasonable attorney fees to be set by the Court.

3. For such other and further relief as the Court may deem proper.

DATED this lst day 0f April, 2020.

GJORDING FOUSER, PLLC

By
Trudy Hanson Fouser — Of the Firm
Marisa S. Crecelius — Of the Firm
Emma C. Nowacki — Of the Firm
Attorneys for Defendant Idaho State Department
of Education

DEFENDANT’S ANSWER TO PLAINTIFF’S COMPLAINT AND DEMAND FOR JURY TRIAL

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 CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this 1“ day 0f April, 2020, a true and correct copy 0f the

foregoing was served on the f0 llowing by the manner indicated:

Erika Birch U.S. Mail, postage prepaid

DD Hand-Delivered
erika@idahoiobiustice.com
T. Guy Hallam Overnight Mail
Euv@idahoi0biustice.com Facsimile
@DDD
Strindberg & Scholnick, LLC Email:
1516 W. Hays Street iCourt E-File
Boise, Idaho83702

JeffHepworth U.S. Mail, postage prepaid

Grady Hepworth Hand-Delivered
courtservice@idalawver.com Overnight Mail
Hepworth Law Offices
@DDDDD
Facsimile
PO Box 2815 Email:
Boise, Idaho 83701 iCourt E-File

/47/
Emma
WW C A/aW'
C. Nowacki

DEFENDANT’S ANSWER TO PLAINTIFF’S COMPLAINT AND DEMAND FOR JURY TRIAL

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