MCFADYEN et al v. DUKE UNIVERSITY et al

Filing 377

ANSWER to Amended Complaint Defendant Linwood Wilson's Answer to Second Amended Complaint by LINWOOD E. WILSON. (WILSON, LINWOOD)

IN THE UNITED STATES DISTRICT COURT
FOR THE MIDDLE DISTRICT OF NORTH CAROLINA
CIVIL ACTION NUMBER 1:07-CV-00953
RYAN McFADYEN, et al.,
Plaintiffs,
v.

)
)
)
ANSWER OF DEFENDANT
)
LINWOOD WILSON TO
DUKE UNIVERSITY, et al.,
)
SECOND AMENDED
Defendants.
)
COMPLAINT
)
_________________________________________________________________

Linwood Wilson responds as follows to the Second Amended Complaint
filed in this action:
FIRST DEFENSE
Plaintiffs’ Second Amended Complaint violates Rule 8 of the Federal Rules
of Civil Procedure, which requires a complaint to contain a “short and plain
statement of the claim showing that the pleader is entitled to relief.” Instead,
Plaintiffs’ Second Amended Complaint includes a large number of implicit
allegations that are undefined and bases its allegations on a large number of false
premises. It contains 428 pages and 1,388 numbered paragraphs, “most of which
are not relevant to the actual legally-recognized claims that may be available.”
(See D.E. 186 at 221.)
SECOND DEFENSE

Defendant Linwood Wilson denies anything that is not explicitly admitted
in the same terms in which it is alleged. It is not the intention of Defendant Wilson

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to make any implicit admissions of facts, premises, or concepts that are logically,
or otherwise, implied by the allegations within the Second Amended Complaint.
Where facts, premises, or concepts are admitted, Defendant Linwood Wilson will
admit those facts, premises or concepts expressly. Defendant Linwood Wilson
denies all other allegations within this Second Amended Complaint that are not
admitted.
THIRD DEFENSE
Defendant Linwood Wilson has not engaged in discovery regarding the
circumstances of the Plaintiffs’ allegations. Defendant Linwood Wilson thus
expressly reserves the right to move to amend his answer to add additional
responses and defenses as discovery progresses and additional information
regarding this action becomes available.
FOURTH DEFENSE
To the extent that any of the headings contained within the Second
Amended Complaint are construed as allegations, Defendant Linwood Wilson
denies the allegations.
FIFTH DEFENSE
Defendant Linwood Wilson was at all times a civilian investigator with the
State of North Carolina, Administrative Offices of the Court, and worked in the
14th Judicial District under District Attorney Michael Nifong. Mr. Wilson
assumed the position of the District Attorney Investigator (a civil position
described under NC General Statues) in October 2006. Prior to that time
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Defendant Wilson was a worthless check coordinator in the District Attorney’s
office. Defendant Wilson, as a civilian employee, had no power of arrest or
judicial authority. Defendant Wilson’s primary job was to prepare the cases he
was assigned by Defendant Nifong or any other Assistant District Attorney only
for the preparation of trial.
SIXTH DEFENSE
Defendant Linwood Wilson responds as follows to the numbered
allegations contained in the Second Amended Complaint:
To the extent that the heading that precedes Paragraph 1 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
1. Defendant Linwood Wilson specifically denies that he was a part of any
type of “consortium” as alleged within this Second Amended Complaint.
Defendant Linwood Wilson is not even named in this “consortium” allegation. To
the extent that this allegation is found to include Defendant Linwood Wilson then
Defendant Linwood Wilson denies the allegations.
2. Defendant Linwood Wilson specifically denies that he was a part of any
type of “consortium” as alleged within this Second Amended Complaint.
Defendant Linwood Wilson is not even named in this “consortium” allegation. To
the extent that this allegation is found to include Defendant Linwood Wilson then
Defendant Linwood Wilson denies the allegations.

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3. Defendant Linwood Wilson is not even named in this allegation. To the
extent that this allegation is found to include Defendant Linwood Wilson then
Defendant Linwood Wilson denies the allegations.
4. Defendant Linwood Wilson denies the allegations.
5. Upon information and belief, Defendant Linwood Wilson admits that the
North Carolina Attorney General’s office conducted an independent investigation
of the allegations made by Ms. Mangum. Upon information and belief, Defendant
Linwood Wilson admit that on April 11, 2007, the North Carolina Attorney
General dismissed all charges against David Evans, Colin Finnerty, and Reade
Seligmann arising from the rape allegations that are the subject of this Second
Amended Complaint. Defendant Linwood Wilson denies the remaining
allegations.
To the extent that the heading that precedes Paragraph 6 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
6. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
7. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.

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8. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
9. Defendant Linwood Wilson admits that upon information and belief, the
Plaintiffs were undergraduates at Duke University and members of its men’s
lacrosse team during the spring semester of 2006. Defendant Wilson is without
knowledge or information sufficient to form a belief about the truth of the
remaining allegations and, therefore, denies the remaining allegations.
10. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the further allegations.
11. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the further allegations.
12. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations.
13. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations
14. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations
15. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations
16. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations
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17. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations
18. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations.
19. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations
20. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations
21. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations
22. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations.
23. Upon information and belief Defendant Linwood Wilson believes that
Richard Brodhead serves as President of Duke University, including during the
period from March 13, 2006 (the date of Plaintiffs’ party) to the present.
Defendant Linwood Wilson is without knowledge or information sufficient to
form a belief about the truth of the further allegations
24. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the further allegations
25. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the remaining allegations.

6

26. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations.
27. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the further allegations.
28. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations.
29. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the further allegations.
30. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations
31. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations.
32. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations.
33. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations.
34. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations.
35. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations.
36. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations.
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37. The claims against Theresa Arico were dismissed by the Court’s Order
of March 31, 2011. Defendant Linwood Wilson is without knowledge or
information sufficient to form a belief about the truth of the allegations.
38. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations.
39. Defendant Wilson admits that Duke University, former Chairman Steel,
President Brodhead, former Senior Vice President Burness, former Director
Drummond, Chancellor Dzau, former Associate Vice President Graves, former
Director Dean, Sergeant Smith, DUHS and Nurse Levicy are Defendants in this
Action. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the remaining allegations.
40. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the remaining allegations.
41. Defendant Wilson admits that Former Chairman Steel, President
Brodhead, former Senior Vice President Burness, former Director Drummond and
Chancellor Dzau are Defendants in this Action. Defendant Linwood Wilson is
without knowledge or information sufficient to form a belief about the truth of the
remaining allegations.
42. Defendant Wilson admits that Nurse Levicy, DUHS and Duke
University are Defendants named in this Action. Defendant Linwood Wilson is
without knowledge or information sufficient to form a belief about the truth of the
remaining allegations.
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43. Defendant Wilson admits that President Brodhead, former Associate
Vice President Graves, Sergeant Smith, and former Director Dean are Defendants
in this Action. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the remaining allegations.
44. Defendant Wilson admits that President Brodhead, former Associate
Vice President Graves, and former Director Dean are Defendants in this Action.
Defendant Linwood Wilson is without knowledge or information sufficient to
form a belief about the truth of the remaining allegations.
45. Defendant Wilson admits that Sergeant Smith is a Defendant in this
Action. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the remaining allegations.
46. Defendant Wilson admits that Former Director Drummond is a Defendant in
this Action. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the remaining allegations.
47. Defendant Linwood Wilson admits that Former Chairman Steel,
Sergeant Smith, former Director Dean, former Associate Vice President Graves,
and President Brodhead are Defendants in this Action. Defendant Linwood Wilson
is without knowledge or information sufficient to form a belief about the truth of
the remaining allegations.
To the extent that the heading that precedes Paragraph 48 is construed as
allegations, Defendant Linwood Wilson denies the allegations.

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48. Defendant Linwood Wilson admits that the City of Durham is a
municipal corporation formed under the laws of North Carolina. Defendant
Linwood Wilson is without knowledge or information sufficient to form a belief
about the truth of the remaining allegations.
49. Defendant Linwood Wilson admits that Michael Nifong was the
District Attorney for Durham County. Upon information and belief, it is further
admitted that former District Attorney Nifong was disbarred by the North Carolina
State Bar for his actions relating to the prosecution of David Evans, Colin
Finnerty, and Reade Seligmann. Other than reports of the disbarment proceedings,
Defendant Linwood Wilson is without knowledge or information sufficient to
form a belief about the truth of the remaining allegations.
To the extent that the heading that precedes Paragraph 50 is construed as
allegations Defendant Wilson denies the allegations.
50. Upon information and belief, Defendant Linwood Wilson admits that
Patrick Baker was the City Manager for the City of Durham. Defendant Linwood
Wilson is without knowledge or information sufficient to form a belief about the
truth of the remaining allegations.
51. Upon information and belief, Defendant Linwood Wilson admits that
Steven Chalmers was the Chief of Police for the Durham Police Department.
Defendant Linwood Wilson is without knowledge or information sufficient to
form a belief about the truth of the remaining allegations.

10

52. Upon information and belief, Defendant Linwood Wilson admits that
Ronald Hodge was employed by the Durham Police Department. Defendant
Linwood Wilson is without knowledge or information sufficient to form a belief
about the truth of the remaining allegations.
53. Upon information and belief, Defendant Linwood Wilson admits that
Lee Russ was employed by the Durham Police Department. Defendant Linwood
Wilson is without knowledge or information sufficient to form a belief about the
truth of the remaining allegations.
54. Upon information and belief, Defendant Linwood Wilson admits that
Stephen Mihaich was employed by the Durham Police Department. Defendant
Linwood Wilson is without knowledge or information sufficient to form a belief
about the truth of the remaining allegations.
55. Upon information and belief, Defendant Linwood Wilson, admits that
Beverly Council was employed by the Durham Police Department. Defendant
Linwood Wilson is without knowledge or information sufficient to form a belief
about the truth of the remaining allegations.
56. Upon information and belief, Defendant Linwood Wilson admits that
Jeff Lamb was employed by the Durham Police Department and is now retired.
Defendant Linwood Wilson is without knowledge or information sufficient to
form a belief about the truth of the remaining allegations.
57. Upon information and belief, Defendant Linwood Wilson admits that
Michael Ripberger was employed by the Durham Police Department. Defendant
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Linwood Wilson is without knowledge or information sufficient to form a belief
about the truth of the remaining allegations.
58. Upon information and belief, Defendant Linwood Wilson admits that
Laird Evans was employed by the Durham Police Department. Defendant
Linwood Wilson is without knowledge or information sufficient to form a belief
about the truth of the remaining allegations.
59. Upon information and belief, Defendant Linwood Wilson admits that
James Soukup was employed by the Durham Police Department. Linwood Wilson
is without knowledge or information sufficient to form a belief about the truth of
the remaining allegations.
To the extent that the heading that precedes Paragraph 60 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
60. Upon information and belief, Defendant Linwood Wilson admits that
Kammie Michael was employed by the Durham Police Department. Linwood
Wilson is without knowledge or information sufficient to form a belief about the
truth of the remaining allegations.
61. Upon information and belief, Defendant Linwood Wilson admits that
David Addison was employed by the Durham Police Department. Defendant
Linwood Wilson is without knowledge or information sufficient to form a belief
about the truth of the remaining allegations.
To the extent that the heading that precedes Paragraph 62 is construed as
allegations, Defendant Wilson denies the allegations.
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62. Upon information and belief, Defendant Linwood Wilson admits that
Mark Gottlieb was employed by the Durham Police Department. Linwood Wilson
is without knowledge or information sufficient to form a belief about the truth of
the remaining allegations.
63. Upon information and belief, Defendant Linwood Wilson admits that
Benjamin Himan was employed by the Durham Police Department. Linwood
Wilson is without knowledge or information sufficient to form a belief about the
truth of the remaining allegations.
64. Defendant Linwood Wilson admits that he was employed by the
District Attorney for the Fourteenth Judicial District as a civilian employee.
Defendant Wilson admits that he was fired by Interim District Attorney Jim
Hardin, who was appointed by former and now disgraced Governor Michael
Easley, on June 25, 2007. Defendant Linwood Wilson denies the remaining
allegations.
65. Upon information and belief, Defendant Linwood Wilson admits that
Richard Clayton was employed by the Durham Police Department Defendant
Linwood Wilson is without knowledge or information sufficient to form a belief
about the truth of the remaining allegations.
66. Defendant Linwood Wilson denies the allegations.
67. Defendant Linwood Wilson denies the allegations.

13

68. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the remaining allegations and,
therefore, denies the allegations.
69. Defendant Linwood Wilson denies being a Durham Investigator and,
therefore, denies the allegations.
71. Defendant Wilson is without knowledge or information sufficient to
form a belief about the truth of the allegations and, therefore, denies the
allegations.
72. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the remaining allegations and,
therefore, denies the allegations.
To the extent that the heading that precedes Paragraph 73 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
73. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
74. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
75. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
14

76. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
77. Defendant Linwood Wilson specifically denies that he, or anyone acting
on behalf of him, were a part of any type of “consortium” as alleged within this
Second Amended Complaint. Defendant Linwood Wilson denies the remaining
allegations.
To the extent that the heading that precedes Paragraph 78 is construed as
allegations Defendant Linwood Wilson denies the allegations.
78. As a result of the matters alleged in the Second Amended Complaint,
which are denied, Defendant Linwood Wilson admits that the Plaintiffs purport to
allege violations of 42 U.S.C. § 1983, 42 U.S.C. § 1985, 42 U.S.C. § 1986, 42
U.S.C. § 1988, the North Carolina statutes, and the North Carolina common law.
Defendant Linwood Wilson denies that the allegations in the Second Amended
Complaint state claims upon which relief can be granted. Defendant Linwood
Wilson denies the remaining allegations.
79. As a result of the matters alleged in the Second Amended Complaint,
which are denied, Defendant Linwood Wilson admits that these allegations place
jurisdiction in this Court. Defendant Linwood Wilson denies that the allegations in
the Second Amended Complaint state claims upon which relief can be granted.
Defendant Linwood Wilson denies the remaining allegations.

15

80. As a result of the matters alleged in the Second Amended Complaint,
which are denied, Defendant Linwood Wilson admits that these allegations place
jurisdiction in this Court. Defendant Linwood Wilson denies that the allegations in
the Second Amended Complaint state claims upon which relief can be granted.
Defendant Linwood Wilson denies the remaining allegations.
81. As a result of the matters alleged in the Second Amended Complaint,
which are denied, Defendant Linwood Wilson admits these allegations place
venue in the United States District Court for the Middle District of North Carolina.
Defendant Linwood Wilson denies that the allegations in the Second Amended
Complaint state claims upon which relief can be granted. Defendant Linwood
Wilson denies the remaining allegations.
To the extent that the headings that precede Paragraph 82 are construed as
allegations, Defendant Linwood Wilson denies the allegations.
82. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
84. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
85. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
16

86. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
87. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
88. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
89. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
90. Defendant Linwood Wilson admits that a video, referenced as
Attachment 1 to Plaintiffs’ Second Amended Complaint, has been filed with the
Court. Defendant Linwood Wilson is without knowledge or information sufficient
to form a belief about the truth of the allegations and, therefore, denies the
allegations.
91. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.

17

92. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
93. The allegations in Paragraph 93 call for a legal conclusion to which no
response is required. To the extent that a response is required, Defendant Linwood
Wilson denies the allegations.
94. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
95. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
96. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
97. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
98. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.

18

99. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
100. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
101. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
102. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
103. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
104. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
105. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.

19

106. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
107. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
108. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
109. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
110. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
111. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
112 Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.

20

To the extent that the heading that precedes Paragraph 113 is construed as
allegations Defendant Wilson denies the allegations.
113. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
114. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
115. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
116. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
117. Defendant Linwood Wilson specifically denies that he was a part of
any type of “consortium” as alleged within this Second Amended Complaint.
Defendant Wilson denies the remaining allegations.
118. Defendant Linwood Wilson specifically denies that he was a part of
any type of “consortium” as alleged within this Second Amended Complaint.
Defendant Linwood Wilson denies the remaining allegations.

21

119. Defendant Linwood Wilson specifically denies that he was a part of
any type of “consortium” as alleged within this Second Amended Complaint.
Defendant Linwood Wilson denies the remaining allegations.
120. Defendant Linwood Wilson specifically denies that he was a part of
any type of “consortium” as alleged within this Second Amended Complaint.
Defendant Linwood Wilson is without knowledge or information sufficient to
form a belief about the truth of the allegations and, therefore, denies the
allegations.
121. Defendant Linwood Wilson specifically denies that he was a part of
any type of “consortium” as alleged within this Second Amended Complaint.
Defendant Linwood Wilson is without knowledge or information sufficient to
form a belief about the truth of the allegations and, therefore, denies the
allegations.
122. Defendant Linwood Wilson specifically denies that he was a part of
any type of “consortium” as alleged within this Second Amended Complaint.
Defendant Linwood Wilson is without knowledge or information sufficient to
form a belief about the truth of the allegations and, therefore, denies the
allegations.
123. Defendant Linwood Wilson specifically denies that he was a part of
any type of “consortium” as alleged within this Second Amended Complaint.
Defendant Linwood Wilson is without knowledge or information sufficient to

22

form a belief about the truth of the allegations and, therefore, denies the
allegations.
124. Defendant Linwood Wilson specifically denies that he was a part of
any type of “consortium” as alleged within this Second Amended Complaint.
Defendant Linwood Wilson is without knowledge or information sufficient to
form a belief about the truth of the allegations and, therefore, denies the
allegations.
125. Defendant Linwood Wilson specifically denies that he was a part of
any type of “consortium” as alleged within this Second Amended Complaint.
Defendant Linwood Wilson further specifically denies any involvement in
conducting “warrantless raids of student homes and unlawful detention and
interrogation” of any students at Duke University. Defendant Linwood Wilson is
without knowledge or information sufficient to form a belief about the truth of the
remaining allegations and, therefore, denies the remaining allegations as he was
not employed by the State of NC AOC / Durham DA.
126. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the remaining allegations and,
therefore, denies the remaining allegations.
127. Defendant Linwood Wilson specifically denies that he participated in
or condoned in any way any sort of “war” on Duke students. Defendant Linwood
Wilson specifically denies that he was a part of any type of “consortium” as

23

alleged within this Second Amended Complaint. Defendant Linwood Wilson is
without knowledge or information sufficient to form a belief about the truth of the
remaining allegations and, therefore, denies the remaining allegations.
128. Defendant Linwood Wilson specifically denies that he was a part of
any type of “consortium” as alleged within this Second Amended Complaint.
Defendant Linwood Wilson further specifically denies any participation in any
sort of conspiracy as alleged within this Second Amended Complaint. Defendant
Linwood Wilson denies the remaining allegations.
To the extent that the heading that precedes Paragraph 129 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
129. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the remaining allegations and,
therefore, denies the remaining allegations.
130. Defendant Linwood Wilson specifically denies that he was a part of
any type of “consortium” as alleged within this Second Amended Complaint.
Defendant Linwood Wilson is without knowledge or information sufficient to
form a belief about the truth of the remaining allegations and, therefore, denies the
remaining allegations.
131. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.

24

132. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the remaining allegations and,
therefore, denies the remaining allegations.
133. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
134. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the remaining allegations and,
therefore, denies the remaining allegations.
135. Defendant Linwood Wilson specifically denies that he was a part of
any type of “consortium” as alleged within this Second Amended Complaint.
Defendant Linwood Wilson was not even employed by the District Attorney’s
Office during the times set out in this paragraph. Defendant Linwood Wilson is
without knowledge or information sufficient to form a belief about the truth of the
remaining allegations and, therefore, denies the remaining allegations.
136. Defendant Linwood Wilson specifically denies that he was a part of
any type of “consortium” as alleged within this Second Amended Complaint.
Defendant Linwood Wilson is without knowledge or information sufficient to
form a belief about the truth of the remaining allegations and, therefore, denies the
remaining allegations.

25

137. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the remaining allegations.
To the extent that the headings that precede Paragraph 138 are construed as
allegations, Defendant Linwood Wilson denies the allegations.
138. Defendant Linwood Wilson specifically denies that he was a part of
any type of “consortium” as alleged within this Second Amended Complaint.
Defendant Linwood Wilson admits that there is a photograph that has been
inserted into Plaintiffs’ Second Amended Complaint. Defendant Linwood Wilson
is without knowledge or information sufficient to form a belief about the truth of
the remaining allegations since he wasn’t employed with the State or DA’s office
at this time and, therefore, denies the remaining allegations.
139. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
140. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
141. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.

26

142. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
143. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the remaining allegations and,
therefore, denies the remaining allegations.
144. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the remaining allegations and,
therefore, denies the remaining allegations.
To the extent that the headings that precede Paragraph 145 are construed as
allegations, Defendant Linwood Wilson denies the allegations.
145. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations since he was not
employed by the State or DA’s office at that time and, therefore, denies the
allegations.
146. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
147. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations since he was not
employed by the State or DA’s office at that time and, therefore, denies the
allegations.
27

148. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations since he was not
employed by the State of NC AOC / DA’s office at that time and, therefore, denies
the allegations.
149. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations since he was not
employed by the State of NC AOC / DA’s office at that time and, therefore, denies
the allegations.
150. Defendant Linwood Wilson admits that a document, referenced as
Attachment 5 to Plaintiffs’ Second Amended Complaint, has been filed with the
Court. Defendant Linwood Wilson is without knowledge or information sufficient
to form a belief about the truth of the allegations since he was not employed by the
State of NC AOC / DA’s office at that time and, therefore, denies the allegations.
151. Defendant Linwood Wilson admits that a document, referenced as
Attachment 6 to Plaintiffs’ Second Amended Complaint, has been filed with the
Court. Defendant Linwood Wilson is without knowledge or information sufficient
to form a belief about the truth of the allegations since he was not employed by the
State of NC AOC / DA’s office at that time and, therefore, denies the allegations.
152. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations since he was not
employed by the State of NC AOC / DA’s office at that time and, therefore, denies
the allegations.
28

To the extent that the heading that precedes Paragraph 153 is construed as
allegations, the Defendant Linwood Wilson denies the allegations.
153. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations since he was not
employed by the State of NC AOC / DA’s office at that time and, therefore, denies
the allegations.
154 Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations since he was not
employed by the State of NC AOC / DA’s office at that time and, therefore, denies
the allegations.
155. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations since he was not
employed by the State of NC AOC / DA’s office at that time and, therefore, denies
the allegations.
156. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations since he was not
employed by the State of NC AOC / DA’s office at that time and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 157 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
157. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations since he was not
29

employed by the State of NC AOC / DA’s office at that time and, therefore, denies
the allegations.
158. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations since he was not
employed by the State of NC AOC / DA’s office at that time and, therefore, denies
the allegations.
159. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations since he was not
employed by the State of NC AOC / DA’s office at that time and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 160 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
160. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations since he was not
employed by the State of NC AOC / DA’s office at that time and, therefore, denies
the allegations.
161. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations since he was not
employed by the State of NC AOC / DA’s office at that time and, therefore, denies
the allegations.
162. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations since he was not
30

employed by the State of NC AOC / DA’s office at that time and, therefore, denies
the allegations.
163. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations since he was not
employed by the State of NC AOC / DA’s office at that time and, therefore, denies
the allegations.
164. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations since he was not
employed by the State of NC AOC / DA’s office at that time and, therefore, denies
the allegations.
165. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
166. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
167. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
168. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
31

To the extent that the heading that precedes Paragraph 169 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
169. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations since he was not
employed by the State of NC AOC / DA’s office at that time and, therefore, denies
the allegations.
170. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations since he was not
employed by the State of NC AOC / DA’s office at that time and, therefore, denies
the allegations.
To the extent that the headings that precede Paragraph 171 are construed as
allegations, Defendant Linwood Wilson denies the allegations.
171. Defendant Linwood Wilson denies that it was known by him that
Officer Gottlieb was a “rogue officer.” Defendant Linwood Wilson is without
knowledge or information sufficient to form a belief about the truth of the
allegations and, therefore, denies the allegations.
172. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 173 is construed as
allegations, Defendant Linwood Wilson denies the allegations.

32

173. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
174. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
175. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
176. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 177 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
177. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
178. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.

33

179. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 180 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
180. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
181. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
182. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
183. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
184. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 185 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
34

185. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
186. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
187. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
188. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
189. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
190. Defendant Linwood Wilson admit that a document, referenced as
Attachment 7 to Plaintiffs’ Second Amended Complaint, has been filed with the
Court. Defendant Linwood Wilson is without knowledge or information sufficient
to form a belief about the truth of the allegations and, therefore, denies the
allegations.

35

191. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
192. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
193. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
To the extent that the headings that precede Paragraph 194 are construed as
allegations, Defendant Linwood Wilson denies the allegations.
194. Upon information and belief, Defendant Linwood Wilson admits that
evidence has been presented in other legal proceedings arising from this same
series of events, including the criminal proceedings and the State Bar’s
proceedings against Michael Nifong, that on March 13, 2006, members of the
Duke University men’s 2005-2006 lacrosse team attended a party at a house
located in Durham at 610 North Buchanan Boulevard. Defendant Linwood Wilson
is without knowledge or information sufficient to form a belief about the truth of
the allegations and, therefore, denies the allegations.
195. Upon information and belief, Defendants Linwood Wilson admits that
evidence has been presented in other legal proceedings arising from this same
series of events, including the criminal proceedings and the State Bar’s
36

proceedings against Michael Nifong, that some of the members of the 2005-2006
Duke University men’s lacrosse team chose to hire dancers for a party at 610
North Buchanan Boulevard. Defendant Linwood Wilson is without knowledge or
information sufficient to form a belief about the truth of the allegations and,
therefore, denies the allegations.
196. Upon information and belief, Defendant Linwood Wilson admits that
the allegations made in 196 were provided to the District Attorneys Office through
written reports by the Durham Police Department Officers and Lead Investigators
Himan and Gottlieb. Defendant Linwood Wilson is without knowledge or
information sufficient to form a belief about the truth of the allegations and,
therefore, denies the allegations.
197. Upon information and belief, Defendant Linwood Wilson admits that
the allegations made in 196 were provided to the District Attorneys Office through
written reports by the Durham Police Department Officers and Lead Investigators
Himan and Gottlieb. Defendant Linwood Wilson is without knowledge or
information sufficient to form a belief about the truth of the allegations and,
therefore, denies the allegations.
198. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
199. Upon information and belief, Defendant Linwood Wilson admits that
the allegations made in 199 were provided to the District Attorneys Office through
37

written reports by the Durham Police Department Officers and Lead Investigators
Himan and Gottlieb. Defendant Linwood Wilson is without knowledge or
information sufficient to form a belief about the truth of the allegations and,
therefore, denies the allegations.
200. Upon information and belief, Defendant Linwood Wilson admits that
the allegations made in 200 were provided to the District Attorneys Office through
written reports by the Durham Police Department Officers and Lead Investigators
Himan and Gottlieb. Defendant Linwood Wilson is without knowledge or
information sufficient to form a belief about the truth of the allegations and,
therefore, denies the allegations.
201. Upon information and belief, Defendant Linwood Wilson admits that
the allegations made in 201 were provided to the District Attorneys Office through
written reports by the Durham Police Department Officers and Lead Investigators
Himan and Gottlieb. Defendant Linwood Wilson is without knowledge or
information sufficient to form a belief about the truth of the allegations and,
therefore, denies the allegations.
202. Upon information and belief, Defendant Linwood Wilson admits that
the allegations made in 202 were provided to the District Attorneys Office through
written reports by the Durham Police Department Officers and Lead Investigators
Himan and Gottlieb. Defendant Linwood Wilson is without knowledge or
information sufficient to form a belief about the truth of the allegations and,
therefore, denies the allegations.
38

203. Upon information and belief, Defendant Linwood Wilson admits that
the allegations made in 203 were provided to the District Attorneys Office through
written reports by the Durham Police Department Officers and Lead Investigators
Himan and Gottlieb. Defendant Linwood Wilson is without knowledge or
information sufficient to form a belief about the truth of the allegations and,
therefore, denies the allegations.
204. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
205. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
206. Upon information and belief, Defendant Linwood Wilson admits that
the allegations made in 206 were provided to the District Attorneys Office through
written reports by the Durham Police Department Officers and Lead Investigators
Himan and Gottlieb. Defendant Linwood Wilson is without knowledge or
information sufficient to form a belief about the truth of the allegations and,
therefore, denies the allegations.
207. Upon information and belief, Defendant Linwood Wilson admits that
the allegations made in 207 were provided to the District Attorneys Office through
written reports by the Durham Police Department Officers and Lead Investigators
Himan and Gottlieb. Defendant Linwood Wilson is without knowledge or
39

information sufficient to form a belief about the truth of the allegations and,
therefore, denies the allegations.
208. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
209. Upon information and belief, Defendant Linwood Wilson admits that
the allegations made in 209 were provided to the District Attorneys Office through
written reports by the Durham Police Department Officers and Lead Investigators
Himan and Gottlieb. Defendant Linwood Wilson is without knowledge or
information sufficient to form a belief about the truth of the allegations and,
therefore, denies the allegations.
210. Upon information and belief, Defendant Linwood Wilson admits that
the allegations made in 210 were provided to the District Attorneys Office through
written reports by the Durham Police Department Officers and Lead Investigators
Himan and Gottlieb. Defendant Linwood Wilson is without knowledge or
information sufficient to form a belief about the truth of the allegations and,
therefore, denies the allegations.
211. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.

40

212. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
213. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
214 Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations. Upon information and belief, Defendant Linwood Wilson admits
that on April 11, 2007, the North Carolina Attorney General dismissed all charges
against David Evans, Colin Finnerty, and Reade Seligmann arising from the rape
allegations that are the subject of this Second Amended Complaint.
To the extent that the heading that precedes Paragraph 215 is construed as
allegations Defendant Linwood Wilson denies the allegations.
215. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
216. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.

41

217. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
218. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations, including the allegations contained in subparagraphs A, B, C, and
D and, therefore, denies the allegations.
To the extent that the headings that precede Paragraph 219 are construed as
allegations, Defendant Linwood Wilson denies the allegations.
219. Upon information and belief, Defendant Linwood Wilson admits that
the allegations made in 219 were provided to the District Attorneys Office through
written reports by the Durham Police Department Officers and Lead Investigators
Himan and Gottlieb. Defendant Linwood Wilson is without knowledge or
information sufficient to form a belief about the truth of the allegations and,
therefore, denies the allegations.
220. Upon information and belief, Defendant Linwood Wilson admits that
the allegations made in 220 were provided to the District Attorneys Office through
written reports by the Durham Police Department Officers and Lead Investigators
Himan and Gottlieb. Defendant Linwood Wilson is without knowledge or
information sufficient to form a belief about the truth of the allegations and,
therefore, denies the allegations.

42

221. Upon information and belief, Defendant Linwood Wilson admits that
the allegations made in 221 were provided to the District Attorneys Office through
written reports by the Durham Police Department Officers and Lead Investigators
Himan and Gottlieb that Sgt. Shelton and Officer Stewart arrived at 610 N.
Buchanan Blvd. and walked around the house and no one was present. Defendant
Linwood Wilson is without knowledge or information sufficient to form a belief
about the truth of the remaining allegations and, therefore, denies the remaining
allegations.
222. Defendant Linwood Wilson admits that a video, referenced as
Attachment 8 to Plaintiffs’ Second Amended Complaint, has been filed with the
Court. Defendant Linwood Wilson is without knowledge or information sufficient
to form a belief about the truth of the remaining allegations and, therefore, denies
the remaining allegations.
To the extent that the heading that precedes Paragraph 223 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
223. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
224. Upon information and belief, Defendant Linwood Wilson admits that
the allegations made in 224 were provided to the District Attorneys Office through
written reports by the Durham Police Department Officers and Lead Investigators
Himan and Gottlieb. Defendant Linwood Wilson is without knowledge or
43

information sufficient to form a belief about the truth of the allegations and,
therefore, denies the allegations.
To the extent that the heading that precedes Paragraph 225 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
225. Upon information and belief, Defendant Linwood Wilson admits that
the allegations made in 225 were provided to the District Attorneys Office through
written reports by the Durham Police Department Officers and Lead Investigators
Himan and Gottlieb. Defendant Linwood Wilson is without knowledge or
information sufficient to form a belief about the truth of the allegations and,
therefore, denies the allegations.
226. Defendant Linwood Wilson admits that an audio recording, referenced
as Attachment 9 to Plaintiffs’ Second Amended Complaint, has been filed with the
Court. Upon information and belief, Defendant Linwood Wilson admits that the
allegations made in 226 were provided to the District Attorneys Office through
written or audio reports by the Durham Police Department Officers and Lead
Investigators Himan and Gottlieb. Defendant Linwood Wilson is without
knowledge or information sufficient to form a belief about the truth of the
allegations and, therefore, denies the allegations.
227 Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.

44

228. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
229. Upon information and belief, Defendant Linwood Wilson admits that
the allegations made in 229 were provided to the District Attorneys Office through
written reports by the Durham Police Department Officers and Lead Investigators
Himan and Gottlieb. Defendant Linwood Wilson is without knowledge or
information sufficient to form a belief about the truth of the allegations and,
therefore, denies the allegations.
230. Upon information and belief, Defendant Linwood Wilson admits that
the allegations made in 230 were provided to the District Attorneys Office through
written reports by the Durham Police Department Officers and Lead Investigators
Himan and Gottlieb. Defendant Linwood Wilson is without knowledge or
information sufficient to form a belief about the truth of the allegations and,
therefore, denies the allegations.
231. Upon information and belief, Defendant Linwood Wilson admits that
the allegations made in 231 were provided to the District Attorneys Office through
written reports by the Durham Police Department Officers and Lead Investigators
Himan and Gottlieb. Defendant Linwood Wilson is without knowledge or
information sufficient to form a belief about the truth of the allegations and,
therefore, denies the allegations.

45

232. Upon information and belief, Defendant Linwood Wilson admits that
the allegations made in 232 were provided to the District Attorneys Office through
written reports by the Durham Police Department Officers and Lead Investigators
Himan and Gottlieb. Defendant Linwood Wilson is without knowledge or
information sufficient to form a belief about the truth of the allegations and,
therefore, denies the allegations.
233. Upon information and belief, Defendant Linwood Wilson admits that
the allegations made in 233 were provided to the District Attorneys Office through
written reports by the Durham Police Department Officers and Lead Investigators
Himan and Gottlieb. Defendant Linwood Wilson is without knowledge or
information sufficient to form a belief about the truth of the allegations and,
therefore, denies the allegations.
234 Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 235 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
235. Upon information and belief, Defendant Linwood Wilson admits that
the allegations made in 235 were provided to the District Attorneys Office through
written reports by the Durham Police Department Officers and Lead Investigators
Himan and Gottlieb. Defendant Linwood Wilson is without knowledge or

46

information sufficient to form a belief about the truth of the allegations and,
therefore, denies the allegations.
236. Defendant Linwood Wilson admits that an audio recording, referenced
as Attachment 10 to Plaintiffs’ Second Amended Complaint, has been filed with
the Court. Upon information and belief, Defendant Linwood Wilson admits that
the allegations made in 236 were provided to the District Attorneys Office through
written or oral reports by the Durham Police Department Officers and Lead
Investigators Himan and Gottlieb. Defendant Linwood Wilson is without
knowledge or information sufficient to form a belief about the truth of the
allegations and, therefore, denies the allegations.
237 Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
238. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 239 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
239. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.

47

240. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
241. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
242. Defendant Linwood Wilson admits that an audio segment, referenced
as Attachment 11 to Plaintiffs’ Second Amended Complaint, has been filed with
the Court. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
To the extent that the headings that precede Paragraph 243 are construed as
allegations Defendant Linwood Wilson denies the allegations.
243. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
244. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 245 is construed as
allegations, Defendant Linwood Wilson denies the allegations.

48

245. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
246. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 247 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
247. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
248. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
249. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
250. Upon information and belief, Defendant Linwood Wilson admits that
the allegations made in 250 were provided to the District Attorneys Office through
written reports by the Durham Police Department Officers and Lead Investigators
Himan and Gottlieb. Defendant Linwood Wilson is without knowledge or

49

information sufficient to form a belief about the truth of the allegations and,
therefore, denies the allegations.
251. Upon information and belief, Defendant Linwood Wilson admits that
the allegations made in 251 were provided to the District Attorneys Office through
written reports by the Durham Police Department Officers and Lead Investigators
Himan and Gottlieb. Defendant Linwood Wilson is without knowledge or
information sufficient to form a belief about the truth of the allegations and,
therefore, denies the allegations.
252. Upon information and belief, Defendant Linwood Wilson admits that
the allegations made in 252 were provided to the District Attorneys Office through
written reports by the Durham Police Department Officers and Lead Investigators
Himan and Gottlieb. Defendant Linwood Wilson is without knowledge or
information sufficient to form a belief about the truth of the allegations and,
therefore, denies the allegations.
253. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
254. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 255 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
50

255. Upon information and belief, Defendant Linwood Wilson admits that
the allegations made in 255 were provided to the District Attorneys Office through
written reports by the Durham Police Department Officers and Lead Investigators
Himan and Gottlieb. Defendant Linwood Wilson is without knowledge or
information sufficient to form a belief about the truth of the allegations and,
therefore, denies the allegations.
256. Defendant Linwood Wilson denies the allegations.
257. Defendant Linwood Wilson specifically denies that he or anyone
acting on behalf of him had any involvement in any sort of conspiracy as alleged
within this Second Amended Complaint. Defendant Linwood Wilson denies the
remaining allegations.
258. Defendant Linwood Wilson specifically denies that he or anyone
acting on behalf of him had any involvement in any sort of conspiracy as alleged
within this Second Amended Complaint. Defendant Wilson denies the remaining
allegations.
259. Defendant Linwood Wilson specifically denies that he or anyone
acting on behalf of him had any involvement in any sort of conspiracy as alleged
within this Second Amended Complaint. Defendant Wilson denies the allegations.
260. Defendant Linwood Wilson specifically denies that he or anyone
acting on behalf of him had any involvement in any sort of conspiracy as alleged
within this Second Amended Complaint. Defendant Linwood Wilson denies the
remaining allegations.
51

261. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
262. Upon information and belief, Defendant Linwood Wilson admits that
the allegations made in 262 were provided to the District Attorneys Office through
written reports by the Durham Police Department Officers and Lead Investigators
Himan and Gottlieb. Defendant Linwood Wilson is without knowledge or
information sufficient to form a belief about the truth of the allegations and,
therefore, denies the allegations.
263. Upon information and belief, Defendant Linwood Wilson admits that
the allegations made in 263 were provided to the District Attorneys Office through
written reports by the Durham Police Department Officers and Lead Investigators
Himan and Gottlieb. Defendant Linwood Wilson is without knowledge or
information sufficient to form a belief about the truth of the allegations and,
therefore, denies the allegations.
264. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
265. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.

52

266. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
267. Upon information and belief, Defendant Linwood Wilson admits that
the allegations made in 267 were provided to the District Attorneys Office through
written reports by the Durham Police Department Officers and Lead Investigators
Himan and Gottlieb. Defendant Linwood Wilson is without knowledge or
information sufficient to form a belief about the truth of the allegations and,
therefore, denies the allegations.
268. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
269. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
270. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
.
271. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.

53

To the extent that the heading that precedes Paragraph 272 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
272. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
273. The allegations in Paragraph 273 call for a legal conclusion to which
no response is required. To the extent that a response is required, Defendant
Linwood Wilson is without knowledge or information sufficient to form a belief
about the truth of the allegations and, therefore, denies the allegations.
274 Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
275 Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
276 Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
277. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
To the extent that the headings that precede Paragraph 278 are construed as
54

allegations, Defendant Linwood Wilson denies the allegations.
278. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
279. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
280. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
281. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
282. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
283. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
284. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
55

285. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
286. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
287. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
288. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
289. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
290. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
291. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.

56

292. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
293. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
294. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
295. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
296. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
297. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
298. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.

57

299. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
300. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
301. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 302 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
302. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
303. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
304. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.

58

305. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
306. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
307. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
308. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
309. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
310 Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
311. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.

59

312. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
313. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
314. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 315 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
315. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations, including the allegations in subparagraphs A, B, C, and
D, and, therefore, denies the allegations.
316. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
317. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.

60

318. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
319. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
320. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 321 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
321. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the remaining allegations, including
the allegations contained in subparagraphs A, B, C, D, E, F, G, H, I, J, K, L, and
M, subparts i, ii, and iii of subparagraph I, subparts i, ii, iii, iv, and v of
subparagraph K, and subparts i and ii of subparagraph M, and, therefore, denies
the allegations.
322. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
61

323. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
324. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
325. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
326. Defendant Linwood Wilson is without knowledge or information sufficient to
form a belief about the truth of the allegations and, therefore, denies the
allegations.
327. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
328. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
329. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.

62

330. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
331. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
332. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
To the extent that the headings that precede Paragraph 333 are construed as
allegations, Defendant Linwood Wilson denies the allegations.
333. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
334. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
335. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.

63

336. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
337. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
338. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
339. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
340. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
341. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 342 is construed as
allegations, Defendant Linwood Wilson denies the allegations.

64

342. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
343. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
344. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
345. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 346 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
346. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
347. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
348. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, including the
65

allegations contained in subparagraphs A, B, C, and D, and, therefore, denies the
allegations.
349. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 350 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
350. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
351. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
352. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
353. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
354. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
66

355. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
356. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
357 Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 358 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
358. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
359. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
360. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.

67

361. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
362. Upon information and belief, Defendant Linwood Wilson admits that
the allegations made in 362 were provided to the District Attorneys Office through
written reports by the Durham Police Department Officers and Lead Investigators
Himan and Gottlieb. Defendant Linwood Wilson is without knowledge or
information sufficient to form a belief about the truth of the allegations and,
therefore, denies the allegations.
To the extent that the heading that precedes Paragraph 363 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
363. Upon information and belief, Defendant Linwood Wilson admits that
the allegations made in 363 were provided to the District Attorneys Office through
written reports by the Durham Police Department Officers and Lead Investigators
Himan and Gottlieb. Defendant Linwood Wilson is without knowledge or
information sufficient to form a belief about the truth of the allegations and,
therefore, denies the allegations.
To the extent that the heading that precedes Paragraph 364 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
364. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
68

365. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 366 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
366. Upon information and belief, Defendant Linwood Wilson admits that
the allegations made in 366 were provided to the District Attorneys Office through
written reports by the Durham Police Department Officers and Lead Investigators
Himan and Gottlieb as to Adam, Bret and Matt. Defendant Linwood Wilson is
without knowledge or information sufficient to form a belief about the truth of the
remaining allegations and, therefore, denies the remaining allegations.
367. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
368. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
369. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.

69

370. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
371. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 372 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
372. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
373. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
374. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
375. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, including the
allegations contained in subparagraphs A, B, and C, and, therefore, denies the
allegations.
To the extent that the heading that precedes Paragraph 376 is construed as
70

allegations, Defendant Linwood Wilson denies the allegations.
376. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
377. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
378. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
379. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
380. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
381. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
382. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies

71

the allegations, including the allegations contained in subparagraphs A, B, C, D, E,
F, and G, and, therefore, denies the remaining allegations.
To the extent that the heading that precedes Paragraph 383 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
383. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations, including the allegations contained in subparagraphs A, B, C, D,
and E, and, therefore, denies the allegations.
384. Defendant Linwood Wilson is without knowledge or information sufficient to
form a belief about the truth of the allegations and, therefore, denies the
allegations.
To the extent that the heading that precedes Paragraph 385 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
385. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
386. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
To the extent that the headings that precede Paragraph 387 are construed as
allegations, Defendant Linwood Wilson denies the allegations.

72

387. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
388. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
389. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
390. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations. Defendant Linwood Wilson specifically denies any fabrication
with Mangum to change the timeline. Defendant Linwood Wilson is without
knowledge or information sufficient to form a belief about the truth of the
remaining allegations and, therefore, denies the remaining allegations.
To the extent that the heading that precedes Paragraph 391 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
391. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.

73

392. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 393 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
393 Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
394. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 395 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
395. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
396. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
397. Upon information and belief, Defendant Linwood Wilson admits that,
at some point, the photos referenced in these allegations were provided the District
Attorneys office by either being downloaded from the internet or from Detective
74

Himan. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the remaining allegations and,
therefore, denies the remaining allegations.
398. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
399. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
400. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
401. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 402 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
402. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 403 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
75

403. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations in subparagraphs A, B, C, D, E, and F.

To the extent that the heading that precedes Paragraph 404 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
404. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations in subparagraphs A, B, and C.
To the extent that the heading that precedes Paragraph 405 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
405. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
406. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 407 is construed as
allegations, Defendant Linwood Wilson denies the allegations.

76

407. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
408. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
409. The allegations in Paragraph 409 call for a legal conclusion to which
no response is required. To the extent that a response is required, Defendant
Linwood Wilson denies the allegations.
410. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
411. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
412. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
413. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 414 is construed as
77

allegations, Defendant Linwood Wilson denies the allegations.
414. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations, including the allegations contained in subparagraphs A, B, and C,
and, therefore, denies the allegations.
To the extent that the heading that precedes Paragraph 415 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
415. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
416. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
417. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
418. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 419 is construed as
allegations, Defendant Linwood Wilson denies the allegations.

78

419. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
420. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
421 Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
422. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 423 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
423. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
424. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
425. Upon information and belief, Defendant Linwood Wilson admits that
the allegations made in 425 were provided to the District Attorneys Office through
79

written reports by the Durham Police Department Officers and Lead Investigators
Himan and Gottlieb. Defendant Linwood Wilson is without knowledge or
information sufficient to form a belief about the truth of the allegations and,
therefore, denies the allegations.
426. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
427. Defendant Linwood Wilson admits that the document, which appears
to be a photograph, has been attached to Plaintiffs’ Second Amended Complaint.
Defendant Linwood Wilson is without knowledge or information sufficient to
form a belief about the truth of the allegations and, therefore, denies the
allegations.
428. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
429. Defendant Linwood Wilson specifically denies any participation in
any sort of conspiracy as alleged within this Second Amended Complaint.
Defendant Linwood Wilson is without knowledge or information sufficient to
form a belief about the truth of the allegations and, therefore, denies the
allegations.
430. Defendant Linwood Wilson admits that photographs have been
attached to Plaintiffs’ Second Amended Complaint. Defendant Linwood Wilson is
80

without knowledge or information sufficient to form a belief about the truth of the
allegations and, therefore, denies the allegations.
To the extent that the heading that precedes Paragraph 431 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
431. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
432. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
433. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
434. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 435 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
435. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.

81

436. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
437. Defendant Linwood Wilson admits that a photograph has been
attached to Plaintiffs’ Second Amended Complaint. Defendant Linwood Wilson is
without knowledge or information sufficient to form a belief about the truth of the
allegations and, therefore, denies the allegations.
438. Defendant Linwood Wilson admits that a photograph has been
attached to Plaintiffs’ Second Amended Complaint. Defendant Linwood Wilson is
without knowledge or information sufficient to form a belief about the truth of the
allegations and, therefore, denies the allegations.
To the extent that the heading that precedes Paragraph 439 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
439. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 440 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
440. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.

82

To the extent that the heading that precedes Paragraph 441 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
441. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
442. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
443. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
444. Defendant Linwood Wilson specifically denies any participation in
any sort of conspiracy as alleged within this Second Amended Complaint.
Defendant Linwood Wilson is without knowledge or information sufficient to
form a belief about the truth of the allegations and, therefore, denies the
allegations.
To the extent that the heading that precedes Paragraph 445 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
445. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.

83

446. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
447. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
448. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
449. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
450. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
451. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
453. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.

84

454. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
455. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 456 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
456. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations, including the allegations contained in subparagraphs A, B, C, D,
and E.
457. Defendant Linwood Wilson specifically denies any participation in
any sort of conspiracy as alleged within this Second Amended Complaint.
Defendant Linwood Wilson is without knowledge or information sufficient to
form a belief about the truth of the allegations and, therefore, denies the
allegations.
458. Defendant Linwood Wilson specifically denies any participation in
any sort of conspiracy as alleged within this Second Amended Complaint.
Defendant Linwood Wilson is without knowledge or information sufficient to
form a belief about the truth of the allegations and, therefore, denies the
allegations.
85

To the extent that the heading that precedes Paragraph 459 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
459. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
460. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 461 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
461. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
462. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
463. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
464. Defendant Linwood Wilson specifically denies that he or anyone
acting on behalf of him had any involvement in any sort of conspiracy as alleged

86

within this Second Amended Complaint. Defendant Linwood Wilson is without
knowledge or information sufficient to form a belief about the truth of the
allegations and, therefore, denies the allegations.
465. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 466 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
466. Upon information and belief, Defendant Linwood Wilson admits that
members of the Duke University Police Department provided written statements to
the District Attorney’s Office. Defendant Linwood Wilson is without knowledge
or information sufficient to form a belief about the truth of the remaining
allegations and, therefore, denies the remaining allegations.
467. Upon information and belief, Defendant Linwood Wilson admits that
members of the Duke University Police Department provided written statements to
the District Attorney’s Office. Defendant Linwood Wilson is without knowledge
or information sufficient to form a belief about the truth of the remaining
allegations and, therefore, denies the remaining allegations.
To the extent that the heading that precedes Paragraph 468 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
468. Upon information and belief, Defendant Linwood Wilson admits that
former Duke University Police Officer Mazurek wrote a statement on or about
87

March 29, 2006. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the remaining allegations and,
therefore, denies the remaining allegations.
469. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 470 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
470. Upon information and belief, Defendant Linwood Wilson admits that
former Duke University Police Officer Sara Falcon wrote a statement on or about
March 28, 2006. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the remaining allegations and,
therefore, denies the remaining allegations.
471. Upon information and belief, Defendant Wilson admits that Officer
Sara Falcon made a statement which was put in the file at the District Attorneys
Office. Defendant Linwood Wilson is without knowledge or information sufficient
to form a belief about the truth of the remaining allegations and, therefore, denies
the remaining allegations.
472. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 473 is construed as
88

allegations, Defendant Linwood Wilson denies the allegations.
473. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
474. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
475. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 476 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
476. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations and, therefore, denies the allegations in subparagraphs A and B.
477. Defendant Linwood Wilson specifically denies any participation in
any sort of conspiracy as alleged within this Second Amended Complaint.
Defendant Linwood Wilson is without knowledge or information sufficient to
form a belief about the truth of the remaining allegations and, therefore, denies the
remaining allegations.
To the extent that the headings that precede Paragraph 478 are construed as
allegations, Defendant Linwood Wilson denies the allegations.
89

478. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
479. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 480 is construed as
allegations, Defendant Linwood Wilson denies the allegations.

480. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.

481. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
482. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
483. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.

90

To the extent that the heading that precedes Paragraph 484 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
484. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
485. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
486. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
487. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
488. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
489. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.

91

490. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
491. Defendant Linwood Wilson admits that former District Attorney
Nifong generated significant media coverage regarding the investigation into Ms.
Mangum’s allegations. Defendant Linwood Wilson is without knowledge or
information sufficient to form a belief about the truth of the allegations and,
therefore, denies the allegations.
492. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
493. Defendant Linwood Wilson admits that former District Attorney
Nifong generated significant media coverage regarding the investigation into Ms.
Mangum’s allegations. Defendant Linwood Wilson is without knowledge or
information sufficient to form a belief about the truth of the allegations and,
therefore, denies the allegations.
494. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
495. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
92

To the extent that the heading that precedes Paragraph 496 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
496. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
497. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
498. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
499. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 500 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
500. Defendant Linwood Wilson specifically denies any participation in
any sort of conspiracy as alleged within this Second Amended Complaint.
Defendant Linwood Wilson is without knowledge or information sufficient to
form a belief about the truth of the allegations and, therefore, denies the
allegations.

93

501. Defendant Linwood Wilson specifically denies any participation in
any sort of conspiracy as alleged within this Second Amended Complaint.
Defendant Linwood Wilson is without knowledge or information sufficient to
form a belief about the truth of the remaining allegations and, therefore, denies the
remaining allegations.
502. Defendant Linwood Wilson specifically denies any participation in any sort
of conspiracy as alleged within this Second Amended Complaint. Defendant
Linwood Wilson admits that former District Attorney Nifong generated significant
media coverage regarding the investigation into Ms. Mangum’s allegations.
Defendant Linwood Wilson is without knowledge or information sufficient to
form a belief about the truth of the remaining allegations and, therefore, denies the
remaining allegations, including the allegations contained in subparagraphs A, B,
C, D, E, F, G, H, I, J, K, L, M, N, and O, and, therefore, denies the remaining
allegations.
503. Defendant Linwood Wilson admits that a video, referenced as
Attachment 12 to Plaintiffs’ Second Amended Complaint, has been filed with the
Court. Defendant Linwood Wilson is without knowledge or information sufficient
to form a belief about the truth of the remaining allegations and, therefore, denies
the remaining allegations.
To the extent that the heading that precedes Paragraph 504 is construed as
allegations, Defendant Linwood Wilson denies the allegations.

94

504. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
505. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations, including the allegations contained in subparagraphs A,
B, C, D, E, F, G, and H, and, therefore, denies the allegations.
506. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 507 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
507. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
508. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
509. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.

95

510. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
511. Defendant Linwood Wilson admits that a document, referenced as
Attachment 13 to Plaintiffs’ Second Amended Complaint, has been filed with the
Court. Defendant Linwood Wilson is without knowledge or information sufficient
to form a belief about the truth of the remaining allegations and, therefore, denies
the remaining allegations.
512. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.

513. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
514. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
515. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.

96

516. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
517. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 518 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
518. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
519. Defendant Linwood Wilson admits that a document, referenced as
Attachment 14 to Plaintiffs’ Second Amended Complaint, has been filed with the
Court. Defendant Linwood Wilson is without knowledge or information sufficient
to form a belief about the truth of the remaining allegations and, therefore, denies
the remaining allegations.
520. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
521. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
97

522. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
523. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
524. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 525 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
525. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
526. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
527. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 528 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
98

528. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 529 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
529. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
530. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
531. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
532. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
533. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 534 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
99

534. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 535 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
535. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 536 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
536. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
537. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
538. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.

100

539. Defendant Linwood Wilson is without knowledge or information sufficient to
form a belief about the truth of the allegations and, therefore, denies the
allegations.
540. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
541. Upon information and belief, Defendant Linwood Wilson admits that
on March 25, 2006, former Athletic Director Alleva and President Brodhead made
public statements about the forfeiture of two lacrosse games. Defendant Linwood
Wilson became aware of these statements through the media. Defendant Linwood
Wilson is without knowledge or information sufficient to form a belief about the
truth of the remaining allegations and, therefore, denies the remaining allegations.
542. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
543. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
To the extent that the headings that precede Paragraph 544 are construed as
allegations, Defendant Linwood Wilson denies the allegations.

101

544. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
545. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
546. Defendant Linwood Wilson admits that a video recording, referenced
as Attachment 15 to Plaintiffs’ Second Amended Complaint, has been filed with
the Court. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
547. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
548. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
549. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
550. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, including the
102

allegations contained in subparagraphs A, B, C, and D, and, therefore, denies the
allegations.
551. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 552 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
552. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
553. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 554 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
554. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 555 is construed as
allegations, Defendant Linwood Wilson denies the allegations.

103

555. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
556. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.

557. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
558. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 559 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
559. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
560. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.

104

561. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
562. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 563 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
563. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
564. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 565 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
565. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 566 is construed as
allegations, Defendant Linwood Wilson denies the allegations.

105

566. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
567. Defendant Linwood Wilson specifically denies any participation in
any sort of conspiracy as alleged within this Second Amended Complaint.
Defendant Linwood Wilson is without knowledge or information sufficient to
form a belief about the truth of the allegations and, therefore, denies the
allegations.
To the extent that the heading that precedes Paragraph 568 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
568. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
569. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 570 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
570. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.

106

571. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
572. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
573. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
574. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations, including the allegations contained in subparagraphs A, B, C, and
D, and, therefore, denies these allegations.
575. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
576. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 577 is construed as
allegations, Defendant Linwood Wilson denies the allegations.

107

577. Defendant Linwood Wilson admits that former District Attorney
Nifong generated significant media coverage regarding the investigation into Ms.
Mangum’s allegations. Defendant Linwood Wilson is without knowledge or
information sufficient to form a belief about the truth of the allegations and,
therefore, denies the remaining allegations, including the allegations contained in
subparagraphs A, B, C, D, E, F, G, and H, and, therefore, denies the remaining
allegations.
578. Defendant Linwood Wilson admits that former District Attorney
Nifong generated significant media coverage regarding the investigation into Ms.
Mangum’s allegations. Defendant Linwood Wilson is without knowledge or
information sufficient to form a belief about the truth of the remaining allegations
and, therefore, denies the remaining allegations.
579. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
580. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 581 is construed as
allegations, Defendant Linwood Wilson denies the allegations.

108

581. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
582. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
583. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
To the extent that the headings that precede Paragraph 584 are construed as
allegations, Defendant Linwood Wilson denies the allegations.
584. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 585 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
585. Defendant Linwood Wilson is without knowledge or information sufficient to
form a belief about the truth of the allegations and, therefore, denies the
allegations.
586. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
109

To the extent that the heading that precedes Paragraph 587 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
587. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
588. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
589. Defendant Linwood Wilson specifically denies any participation in
any sort of conspiracy as alleged within this Second Amended Complaint.
Defendant Linwood Wilson specifically denies any “agreement” as alleged within
Paragraph 589. Defendant Linwood Wilson denies the remaining allegations.
590. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
To the extent that the headings that precede Paragraph 591 are construed as
allegations, Defendant Linwood Wilson denies the allegations.
591. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.

110

592. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
593. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 594 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
594. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
595. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 596 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
596. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
597. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
111

598. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
599. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
600. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
601. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
602. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
603. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
604. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.

112

605. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
606. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
607. Defendant Linwood Wilson admits that a photograph has been
attached to Plaintiffs’ Second Amended Complaint. Defendant Linwood Wilson is
without knowledge or information sufficient to form a belief about the truth of the
allegations and, therefore, denies the allegations.
608. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
609. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
610. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 611 is construed as
allegations, Defendant Linwood Wilson denies the allegations.

113

611. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
612. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
613. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
614. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
615. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
616. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
To the extent that the headings that precede Paragraph 617 are construed as
allegations, Defendant Linwood Wilson denies the allegations.

114

617. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
618. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
619. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
620. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 621 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
621. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
622. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.

115

623. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
624. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
625. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
626. Defendant Linwood Wilson admits that former District Attorney
Nifong generated significant media coverage. Defendant Linwood Wilson is
without knowledge or information sufficient to form a belief about the truth of the
remaining allegations, including the allegations contained in
subparagraphs A, B, C, D, and E, and, therefore, denies the allegations.
To the extent that the heading that precedes Paragraph 627 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
627. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
628. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
116

629. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
630. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
631. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations, including the allegations contained in subparagraphs A, B, C, D,
E, F, and G.
632. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
633. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
634. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
635. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
117

636. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
637. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
638. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
639. Defendant Linwood Wilson specifically denies any participation in
any sort of conspiracy as alleged within this Second Amended Complaint.
Defendant Linwood Wilson denies the remaining allegations.
640. Defendant Linwood Wilson specifically denies any participation in
any sort of conspiracy as alleged within this Second Amended Complaint.
Defendant Linwood Wilson denies the remaining allegations.
To the extent that the headings that precede Paragraph 641 are construed as
allegations, Defendant Linwood Wilson denies the allegations.
641. The allegation in Paragraph 641 calls for a legal conclusion to which
no response is required. To the extent that a response is required, Defendant
Linwood Wilson denies the allegations.
642. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, including the
118

allegations contained in subparagraphs A, B, and C, and, therefore, denies the
allegations.
643. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 644 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
644. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 645 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
645. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
646. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
To the extent that the headings that precede Paragraph 647 are construed as
allegations, Defendant Linwood Wilson denies the allegations.
647. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
119

the allegations, including the allegations contained in subparagraphs A, B, C, D,
and E, and, therefore, denies the remaining allegations.
648. Defendant Linwood Wilson admits that former District Attorney
Nifong generated significant media coverage regarding the investigation into Ms.
Mangum’s allegations. Defendant Linwood Wilson is without knowledge or
information sufficient to form a belief about the truth of the allegations, and,
therefore, denies the allegations.
649. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
650. Defendant Linwood Wilson admits that a video, referenced as
Attachment 16 to Plaintiffs’ Second Amended Complaint, has been filed with the
Court. Defendant Linwood Wilson is without knowledge or information sufficient
to form a belief about the truth of the allegations, and, therefore, denies the
allegations.
651. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
652. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.

120

653. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
654. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 655 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
655. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
656. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
657. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
658. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.

121

659. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 660 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
660. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
661. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
662. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
663. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
664. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.

122

665. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
To the extent that the headings that precede Paragraph 666 are construed as
allegations, Defendant Linwood Wilson denies the allegations.
666. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
667. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
668. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, including the
allegations contained in subparagraphs A, B, C, D, E, F, and G, and, therefore,
denies the allegations.
669. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 670 is construed as
allegations, Defendant Linwood Wilson denies the allegations.

123

670. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
671. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
672. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.

673. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
674. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
675. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 676 is construed as
allegations, Defendant Linwood Wilson denies the allegations.

124

676. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
677. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
678. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, including the
allegations contained in subparagraphs A, B, and C, and, therefore, denies the
allegations.
679. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
680. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
681. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
682. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
125

683. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
684. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
685. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
686. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
687. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
To the extent that the headings that precede Paragraph 688 are construed as
allegations, Defendant Linwood Wilson denies the allegations.
688. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.

126

689. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
690. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
691. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
692. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 693 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
693. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
694. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.

127

695. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
696. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
698. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
699. Defendant Linwood Wilson admits that a video file, referenced as
Attachment 17 to Plaintiffs’ Second Amended Complaint, has been filed with the
Court. Defendant Linwood Wilson is without knowledge or information sufficient
to form a belief about the truth of the allegations, and, therefore, denies the
remaining allegations.
700. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
701. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.

128

702. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 703 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
703. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
704. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
705. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
To the extent that the headings that precede Paragraph 706 are construed as
allegations, Defendant Linwood Wilson denies the allegations.
706. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
707. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.

129

708. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
709. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
710. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
711. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
712. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
713 Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
714. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.

130

715. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
716. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
717. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
718. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
719. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
Defendant Linwood Wilson is without knowledge or information sufficient to
form a belief about the truth of the allegations, and, therefore, denies the
allegations.
721. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.

131

To the extent that the heading that precedes Paragraph 722 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
722. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
723. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
724. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
725. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
726. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
727. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 728 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
132

728. Defendant Linwood Wilson is without knowledge or information sufficient to
form a belief about the truth of the allegations, and, therefore, denies the
allegations.
729. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
730. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 731 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
731. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
732. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
733. Defendant Linwood Wilson is without knowledge or information sufficient to
form a belief about the truth of the allegations, and, therefore, denies the
allegations.

133

734. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
735. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
736. Defendant Linwood Wilson is without knowledge or information sufficient to
form a belief about the truth of the allegations, and, therefore, denies the
allegations.
737. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
738. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
739. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 740 is construed as
allegations, Defendant Linwood Wilson denies the allegations.

134

740. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
741. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
742. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
743. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 744 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
744. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
745. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 746 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
135

746. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
747. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
748. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
749. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
750. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
751. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
752. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.

136

753. Defendant Linwood Wilson admits that a video, referenced as
Attachment 18 to Plaintiffs’ Second Amended Complaint, has been filed with the
Court. Defendant Linwood Wilson is without knowledge or information sufficient
to form a belief about the truth of the allegations, and, therefore, denies the
allegations.
754. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
755. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
756. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
757. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 758 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
758. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
137

759. Defendant Linwood Wilson admits that a chart accompanies the
allegations in Paragraph 759. Defendant Linwood Wilson is without knowledge or
information sufficient to form a belief about the truth of the remaining allegations
and, therefore, denies the remaining allegations.
760. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
761. Defendant Linwood Wilson admits that a document, referenced as
Attachment 19, has been filed with the Court. Defendant Linwood Wilson is
without knowledge or information sufficient to form a belief about the truth of the
remaining allegations and, therefore, denies the remaining allegations.
762. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, including the
allegations contained in subparagraphs A, B, C, and D, and, therefore, denies the
allegations.
763. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
764. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.

138

To the extent that the heading that precedes Paragraph 765 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
765. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
766. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
767. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
768. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 769 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
769. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
770. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
139

771. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
772. Upon information and belief, Defendant Linwood Wilson admits that
the Attorney General’s office issued a report of its review of the evidence arising
from the rape allegations that are the subject of this Second Amended Complaint.
Other than from reading the report of those findings, Defendant Linwood Wilson
is without knowledge or information sufficient to form a belief about the truth of
the allegations, and, therefore, denies the allegations.
To the extent that the heading that precedes Paragraph 773 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
773. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
774. Defendant Linwood Wilson admits that a video, referenced as
Attachment 20 to Plaintiffs’ Second Amended Complaint, has been filed with the
Court. Defendant Linwood Wilson is without knowledge or information sufficient
to form a belief about the truth of the allegations, and, therefore, denies the
allegations.
775. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
140

776. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
777. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
778. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 779 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
779. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 780 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
780. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
781. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
141

782. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations. With respect to subparagraphs B and D, Defendant Linwood
Wilson admits that videos, referenced as Attachments 21 and 22 to Plaintiffs’
Second Amended Complaint, have been filed with the Court. Defendant Linwood
Wilson is without knowledge or information sufficient to form a belief about the
truth of the remaining allegations, including the allegations contained in
subparagraphs A, B, C, D, and E, and, therefore, denies the remaining allegations,
including the allegations contained in subparagraphs A, B, C, D, and E.
783. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 784 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
784. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 785 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
785. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations. Defendant Linwood Wilson is without knowledge or information
142

sufficient to form a belief about the truth of the allegations, including the
allegations contained in subparagraphs A, B, and C, and, therefore, denies the
remaining allegations, including the allegations contained in subparagraphs A, B,
and C.
786. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
787. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
788. Defendant Wilson admits that he was part of an interview conducted
in the DA’s office by Durham Police Detective Himan of Nurse Levicy.
Defendant Linwood Wilson is without knowledge or information sufficient to
form a belief about the truth of the remaining allegations, and, therefore, denies
the remaining allegations.
789. Defendant Linwood Wilson specifically denies that he was part of any
agreement with Defendants Nifong, Gottlieb and Himan and Levicy that Nurse
Levicy would testify to forensic medical evidence that she did not observe and did
not exist. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the remaining allegations, and,
therefore, denies the remaining allegations.

143

790. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
791. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
792. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
793. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
794. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
795. Defendant Linwood Wilson admits that Nurse Levicy responded to
multiple questions about condoms during her interview on January 10, 2007. To
the extent Paragraph 795 characterizes statements made by Nurse Levicy,
Defendant Linwood Wilson denies that characterization. Defendant Linwood
Wilson is without knowledge or information sufficient to form a belief about the
truth of the remaining allegations, and, therefore, denies the remaining allegations.

144

796. Upon information and belief, Defendant Linwood Wilson admits that
Nurse Levicy stated that she “wasn’t surprised when [she] heard no DNA was
found because rape is not about passion or ejaculation but about power.”
Defendant Linwood Wilson also admits that Nurse Levicy called him back to
clarify her statement on the next day. Defendant Linwood Wilson is without
knowledge or information sufficient to form a belief about the truth of the
remaining allegations, and, therefore, denies the remaining allegations.
797. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
798. Defendant Linwood Wilson admits that he met Nurse Levicy and
Investigator Himan on the evening of January 10, 2007. Defendant Linwood
Wilson is without knowledge or information sufficient to form a belief about the
truth of the remaining allegations, and, therefore, denies the remaining allegations.
799. Defendant Linwood Wilson specifically denies any participation in
any sort of conspiracy as alleged within this Second Amended Complaint.
Defendant Linwood Wilson admits that Nurse Levicy called him back to clarify
her statement on the next day. Nurse Levicy’s telephone statement to Defendant
Linwood Wilson was cleary to say, “that in addition to the use of condoms the
other possibility was that no rape occurred”. Defendant Linwood Wilson is
without knowledge or information sufficient to form a belief about the truth of the
remaining allegations, and, therefore, denies the remaining allegations.
145

To the extent that the headings that precede Paragraph 800 are construed as
allegations, Defendant Linwood Wilson denies the allegations.
800. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
801. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
802. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
803. Defendant Linwood Wilson is without knowledge or information sufficient to
form a belief about the truth of the allegations, and, therefore, denies the
allegations, including the allegations contained in subparagraphs A, B, C, D, E, F,
and G, and, therefore, denies the allegations, including the allegations
contained in subparagraphs A, B, C, D, E, F, and G.
804. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 805 is construed as
allegations, Defendant Linwood Wilson denies the allegations.

146

805. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
806. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
807. Defendant Linwood Wilson admits that two videos, referenced as
Attachment 23 to Plaintiffs’ Second Amended Complaint, have been filed with the
Court. Defendant Linwood Wilson is without knowledge or information sufficient
to form a belief about the truth of the remaining allegations, and, therefore, denies
the remaining allegations.
808. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
809. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
810. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.

147

811. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 812 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
812. Defendant Linwood Wilson admits that documents, referenced as
Attachment 24 to Plaintiffs’ Second Amended Complaint, have been filed with the
Court. Defendant Linwood Wilson is without knowledge or information sufficient
to form a belief about the truth of the allegations, and, therefore, denies the
allegations.
813. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
814. Defendant Linwood Wilson specifically denies that he took any
actions that violated “Plaintiffs’ federally protected rights.” Defendant Linwood
Wilson is without knowledge or information sufficient to form a belief about the
truth of the remaining allegations, and, therefore, denies the remaining allegations.
815. Defendant Linwood Wilson admits that a video file, referenced as
Attachment 25, has been filed with the Court. Defendant Linwood Wilson is
without knowledge or information sufficient to form a belief about the truth of the
remaining allegations and, therefore, denies the remaining allegations.

148

To the extent that the heading that precedes Paragraph 816 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
816. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
817. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 818 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
818. Defendant Linwood Wilson specifically denies any participation in
any sort of conspiracy as alleged within this Second Amended Complaint. To the
extent that Paragraph 818 alleges any actions by Defendant Linwood Wilson,
Defendant Linwood Wilson denies the allegations. Defendant Linwood Wilson is
without knowledge or information sufficient to form a belief about the truth of the
remaining allegations and, therefore, denies the remaining allegations.
819. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 820 is construed as
allegations, Defendant Linwood Wilson denies the allegations.

149

820. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
821. To the extent the allegations in Paragraph 821 are construed to include
Defendant Linwood Wilson, Defendant Linwood Wilson denies the allegations.
Defendant Linwood Wilson is without knowledge or information sufficient to
form a belief about the truth of the remaining allegations and, therefore, denies the
remaining allegations.
822. To the extent the allegations in Paragraph 822 are construed to include
Defendant Linwood Wilson, Defendant Linwood Wilson denies the allegations.
Defendant Linwood Wilson is without knowledge or information sufficient to
form a belief about the truth of the remaining allegations and, therefore, denies the
remaining allegations.
To the extent that the heading that precedes Paragraph 823 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
823. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
824. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.

150

825. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
826. To the extent that Paragraph 826 purports to characterize any
statements made by Defendant Linwood Wilson, Defendant Linwood Wilson
denies the characterizations. Defendant Linwood Wilson is without knowledge or
information sufficient to form a belief about the truth of the remaining allegations
and, therefore, denies the remaining allegations.
To the extent that the heading that precedes Paragraph 827 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
827. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
828. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
829. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
830. Defendant Linwood Wilson admits that a video, referenced as
Attachment 26 to Plaintiffs’ Second Amended Complaint, has been filed with the
Court. Defendant Linwood Wilson is without knowledge or information sufficient
151

to form a belief about the truth of the remaining allegations and, therefore, denies
the remaining allegations.
831. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
832. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
833. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
834. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
835. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
836. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.

152

837. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
838. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
839. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
840. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
841. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
842. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
843. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.

153

844. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
845. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
846. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
847. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
848. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
849. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
850. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.

154

851. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
852. Defendant Linwood Wilson admits that a document, referenced as
Attachment 27, has been filed with the Court. Defendant Linwood Wilson is
without knowledge or information sufficient to form a belief about the truth of the
remaining allegations, and, therefore, denies the remaining allegations.
To the extent that the heading that precedes Paragraph 853 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
853. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
854. The allegations in Paragraph 854 call for a legal conclusion to which
no response is required. To the extent that a response is required, Defendant
Linwood Wilson denies the allegations.
855. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
856. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.

155

857. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
858. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
859. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
860. Defendant Linwood Wilson cannot admit or deny this allegation
because it refers to unnamed “others”. To the extent that an answer is required on
behalf of these unnamed “others”, Defendant Linwood Wilson denies the
allegations. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the remaining allegations and,
therefore, denies these remaining allegations.
861. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
862. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.

156

863. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
864. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
865. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
866. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations. To the extent that the allegation “among others”, contained in
paragraph 866, includes Defendant Linwood Wilson, Defendant Linwood Wilson
denies the allegations.
867. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
868. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations. To the extent that the allegation “among others”, contained in
paragraph 868, includes Defendant Linwood Wilson, Defendant Linwood Wilson
denies the allegations.
157

869. Upon information and belief, Defendant Linwood Wilson admits that
the court granted the motion to quash the subpoena for the DukeCard information.
Other than court records, Defendant Linwood Wilson is without knowledge or
information sufficient to form a belief about the truth of the remaining allegations
and, therefore, denies the remaining allegations.
870. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
871. Defendant Linwood Wilson admits that a video file, referenced as
Attachment 28, has been filed with the Court. Defendant Linwood Wilson is
without knowledge or information sufficient to form a belief about the truth of the
remaining allegations and, therefore, denies the remaining allegations.
To the extent that the heading that precedes Paragraph 872 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
872. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
873. Defendant Linwood Wilson specifically denies any participation in
any sort of conspiracy as alleged within this Second Amended Complaint.
Defendant Linwood Wilson is without knowledge or information sufficient to
form a belief about the truth of the allegations, and, therefore, denies the
allegations.
158

To the extent that the heading that precedes Paragraph 874 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
874. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
875. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
876. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations. To the extent that the allegation “among others”, contained in
paragraph 876, includes Defendant Linwood Wilson, Defendant Linwood Wilson
denies the allegations.
877. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
878. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
879. Defendant Linwood Wilson is without knowledge or information sufficient to
form a belief about the truth of the allegations, and, therefore, denies the
allegations.
159

880. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
881. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
882. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
883. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
884. Defendant Linwood Wilson specifically denies that he was a part of
any type of “consortium” as alleged within this Second Amended Complaint.
Defendant Linwood Wilson is without knowledge or information sufficient to
form a belief about the truth of the remaining allegations, and, therefore, denies
the remaining allegations.
885. Defendant Linwood Wilson specifically denies that he was a part of
any type of “consortium” as alleged within this Second Amended Complaint.
Defendant Linwood Wilson is without knowledge or information sufficient to
form a belief about the truth of the remaining allegations, and, therefore, denies
the remaining allegations.
160

886. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
887. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 888 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
888. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
889. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
To the extent that the heading that precedes Paragraph 890 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
890. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
891. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
161

892. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
893. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
894. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
895. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
896. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
To the extent that the headings that precede Paragraph 897 are construed as
allegations, Defendant Linwood Wilson denies the allegations.
897. Upon information and belief, Defendant Linwood Wilson admits that
the North Carolina Attorney General’s office conducted an independent
investigation of the evidence. Other than reports of those findings, Defendant
Linwood Wilson is without knowledge or information sufficient to form a belief

162

about the truth of the remaining allegations and, therefore, denies the remaining
allegations.
898. Upon information and belief, Defendant Linwood Wilson admits that
the North Carolina Attorney General’s office conducted an independent
investigation of the evidence. Other than reports of those findings, Defendant
Linwood Wilson is without knowledge or information sufficient to form a belief
about the truth of the remaining allegations and, therefore, denies the remaining
allegations.
899. Upon information and belief, Defendant Linwood Wilson admits that
the North Carolina Attorney General’s office conducted an independent
investigation of the evidence. Other than reports of those findings, Defendant
Linwood Wilson is without knowledge or information sufficient to form a belief
about the truth of the remaining allegations and, therefore, denies the remaining
allegations. To the extent that Defendant Linwood Wilson is alleged to be part of
“and other defendants”, as alleged in paragraph 899, Defendant Linwood Wilson
denies those allegations.
900. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the remaining allegations and,
therefore, denies the remaining allegations.
To the extent that the heading that precedes Paragraph 901 is construed as
allegations, Defendant Linwood Wilson denies the allegations.

163

901. Upon information and belief, Defendant Linwood Wilson admits that former
District Attorney Nifong was disbarred by the North Carolina State Bar for his
actions relating to the prosecution of David Evans, Colin Finnerty, and Reade
Seligmann. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the remaining allegations and,
therefore, denies the remaining allegations.
To the extent that the heading that precedes Paragraph 902 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
902. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations. To the extent that Defendant Linwood Wilson is alleged to be
consider as “and others to conceal from the Plaintiffs the exonerating DNA
evidence they were required to produce to Plaintiffs immediately”, Defendant
Linwood Wilson denies the allegations.
903. To the extent Defendant Linwood Wilson is alleged to have “done”
anything in Paragraph 903, Defendant Linwood Wilson denies the allegations.
To the extent that the heading that precedes Paragraph 904 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
904. Defendant Linwood Wilson incorporates by reference and restates his
responses to paragraphs 1 through 903 as if fully set forth herein. Defendant
Linwood Wilson denies the remaining allegations.

164

905. The cause of action alleged in Count 1 does not include or list
Defendant Linwood Wilson as being a named defendant in Count 1. To the extent
a response is required, Defendant Linwood Wilson denies the allegations.
906. The cause of action alleged in Count 1 does not include or list
Defendant Linwood Wilson as being a named defendant in Count 1. To the extent
a response is required, Defendant Linwood Wilson denies the allegations.
907. The cause of action alleged in Count 1 does not include or list
Defendant Linwood Wilson as being a named defendant in Count 1. To the extent
a response is required, Defendant Linwood Wilson denies the allegations.
908. The cause of action alleged in Count 1 does not include or list
Defendant Linwood Wilson as being a named defendant in Count 1. To the extent
a response is required, Defendant Linwood Wilson denies the allegations.
909. The cause of action alleged in Count 1 does not include or list
Defendant Linwood Wilson as being a named defendant in Count 1. To the extent
a response is required, Defendant Linwood Wilson denies the allegations.
910. The cause of action alleged in Count 1 does not include or list
Defendant Linwood Wilson as being a named defendant in Count 1. To the extent
a response is required, Defendant Linwood Wilson denies the allegations. To the
extent that Defendant Linwood Wilson is alleged to have been part of any sort of
conspiracy, Defendant Linwood Wilson denies the allegations.

165

911. The cause of action alleged in Count 1 does not include or list
Defendant Linwood Wilson as being a named defendant in Count 1. To the extent
a response is required, Defendant Linwood Wilson denies the allegations.
912. The cause of action alleged in Count 1 does not include or list
Defendant Linwood Wilson as being a named defendant in Count 1. To the extent
a response is required, Defendant Linwood Wilson denies the allegations.
913. The cause of action alleged in Count 1 does not include or list
Defendant Linwood Wilson as being a named defendant in Count 1. To the extent
a response is required, Defendant Linwood Wilson denies the allegations.
914. The cause of action alleged in Count 1 does not include or list
Defendant Linwood Wilson as being a named defendant in Count 1. To the extent
a response is required, Defendant Linwood Wilson denies the allegations.
915. The cause of action alleged in Count 1 does not include or list
Defendant Linwood Wilson as being a named defendant in Count 1. To the extent
a response is required, Defendant Linwood Wilson denies the allegations.
916. The cause of action alleged in Count 1 does not include or list
Defendant Linwood Wilson as being a named defendant in Count 1. To the extent
a response is required, Defendant Linwood Wilson denies the allegations.
917. The cause of action alleged in Count 1 does not include or list
Defendant Linwood Wilson as being a named defendant in Count 1. To the extent
a response is required, Defendant Linwood Wilson denies the allegations.

166

918. Defendant Linwood Wilson incorporates by reference and restates his
responses to paragraphs 1 through 917 as if fully set forth herein. Defendant
Linwood Wilson denies the remaining allegations.
919. The cause of action alleged in Count 2 does not include or list
Defendant Linwood Wilson as being a named defendant in Count 2. To the extent
a response is required, Defendant Linwood Wilson denies the allegations.
920. The cause of action alleged in Count 2 does not include or list
Defendant Linwood Wilson as being a named defendant in Count 2. To the extent
a response is required, Defendant Linwood Wilson denies the allegations.
921. The cause of action alleged in Count 2 does not include or list
Defendant Linwood Wilson as being a named defendant in Count 2. To the extent
a response is required, Defendant Linwood Wilson denies the allegations.
922. The cause of action alleged in Count 2 does not include or list
Defendant Linwood Wilson as being a named defendant in Count 2. To the extent
a response is required, Defendant Linwood Wilson denies the allegations.
923. The cause of action alleged in Count 2 does not include or list
Defendant Linwood Wilson as being a named defendant in Count 2. To the extent
a response is required, Defendant Linwood Wilson denies the allegations.
924. The cause of action alleged in Count 2 does not include or list
Defendant Linwood Wilson as being a named defendant in Count 2. To the extent
a response is required, Defendant Linwood Wilson denies the allegations.

167

925. The cause of action alleged in Count 2 does not include or list
Defendant Linwood Wilson as being a named defendant in Count 2. To the extent
a response is required, Defendant Linwood Wilson denies the allegations.
926. The cause of action alleged in Count 2 does not include or list
Defendant Linwood Wilson as being a named defendant in Count 2. To the extent
a response is required, Defendant Linwood Wilson denies the allegations.
927. The cause of action alleged in Count 2 does not include or list
Defendant Linwood Wilson as being a named defendant in Count 2. To the extent
a response is required, Defendant Linwood Wilson denies the allegations.
928. The cause of action alleged in Count 2 does not include or list
Defendant Linwood Wilson as being a named defendant in Count 2. To the extent
a response is required, Defendant Linwood Wilson denies the allegations.
To the extent that the heading that precedes Paragraph 929 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
929. The cause of action alleged in Count 3 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
930. The cause of action alleged in Count 3 was dismissed by the Court’s Order
of March 31, 2011. To the extent a response is required, Defendant Linwood
Wilson denies the allegations.

168

931. The cause of action alleged in Count 3 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
932. The cause of action alleged in Count 3 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
933. The cause of action alleged in Count 3 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
934. The cause of action alleged in Count 3 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
935. The cause of action alleged in Count 3 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
936. The cause of action alleged in Count 3 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
937. The cause of action alleged in Count 3 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.

169

938. The cause of action alleged in Count 3 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
939. The cause of action alleged in Count 3 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
940. The cause of action alleged in Count 3 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
To the extent that the heading that precedes Paragraph 941 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
941. The cause of action alleged in Count 4 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
942. The cause of action alleged in Count 4 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
943. The cause of action alleged in Count 4 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.

170

944. The cause of action alleged in Count 4 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
945. The cause of action alleged in Count 4 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
946. The cause of action alleged in Count 4 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
947. The cause of action alleged in Count 4 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
948. The cause of action alleged in Count 4 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
949. The cause of action alleged in Count 4 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
950. The cause of action alleged in Count 4 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.

171

951. The cause of action alleged in Count 4 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
952. The cause of action alleged in Count 4 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
953. The cause of action alleged in Count 4 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
To the extent that the heading that precedes Paragraph 954 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
954. Defendant Linwood Wilson incorporates by reference and restates his
responses to paragraphs 1 through 953 as if fully set forth herein. Defendant
Linwood Wilson denies the remaining allegations.
955. Defendant Linwood Wilson denies the allegations
956. Defendant Linwood Wilson denies the allegations, including
subparagraphs A, B, C, D, E, F, G, H, I. Defendant Linwood Wilson specifically
denies being involved in any “conspiracy” or “acting in concert” as set out in the
Second Amended Complaint.
957. Defendant Linwood Wilson denies the allegations, including
subparagraphs A, B, C, D, E, F, G.
958. Defendant Linwood Wilson denies the allegations.
172

959. Defendant Linwood Wilson denies the allegations.
960. Defendant Linwood Wilson denies the allegations.
961. Defendant Linwood Wilson denies the allegations.
962. Defendant Linwood Wilson denies the allegations.
To the extent that the heading preceding Paragraph 963 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
963. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
964. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
965. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
966. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
967. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.

173

968. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations, and, therefore, denies
the allegations.
969. The cause of action alleged in Count 6 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
970. The cause of action alleged in Count 6 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
971. The cause of action alleged in Count 6 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
972. The cause of action alleged in Count 6 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
973. The cause of action alleged in Count 6 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
974. The cause of action alleged in Count 6 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.

174

975. The cause of action alleged in Count 6 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
976. The cause of action alleged in Count 6 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
977. The cause of action alleged in Count 6 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
To the extent that the heading that precedes Paragraph 978 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
978. The cause of action alleged in Count 7 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
979. The cause of action alleged in Count 7 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
980. The cause of action alleged in Count 7 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.

175

981. The cause of action alleged in Count 7 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
982. The cause of action alleged in Count 7 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
983. The cause of action alleged in Count 7 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
984. The cause of action alleged in Count 7 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
985. The cause of action alleged in Count 7 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
To the extent that the heading that precedes Paragraph 986 is construed as
allegations, Defendant Wilson denies the allegations.
986. The cause of action alleged in Count 8 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.

176

987. The cause of action alleged in Count 8 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
988. The cause of action alleged in Count 8 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
989. The cause of action alleged in Count 8 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
990. The cause of action alleged in Count 8 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
991. The cause of action alleged in Count 8 was dismissed by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
To the extent that the heading that precedes Paragraph 992 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
992. The cause of action alleged in Count 9 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.

177

993. The cause of action alleged in Count 9 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
994. The cause of action alleged in Count 9 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
995. The cause of action alleged in Count 9 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
996. The cause of action alleged in Count 9 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
997. The cause of action alleged in Count 9 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
998. The cause of action alleged in Count 9 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
999. The cause of action alleged in Count 9 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.

178

1000. The cause of action alleged in Count 9 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1001. The cause of action alleged in Count 9 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
To the extent that the heading that precedes Paragraph 1002 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
1002. The cause of action alleged in Count 10 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1003. The cause of action alleged in Count 10 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1004. The cause of action alleged in Count 10 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1005. The cause of action alleged in Count 10 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.

179

1006. The cause of action alleged in Count 10 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1007. The cause of action alleged in Count 10 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
To the extent that the heading that precedes Paragraph 1008 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
1008. The cause of action alleged in Count 11 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
To the extent that the heading that precedes Paragraph 1009 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
1009. The cause of action alleged in Count 11 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1010. The cause of action alleged in Count 11 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1011. The cause of action alleged in Count 11 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
180

1012. The cause of action alleged in Count 11 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1013. The cause of action alleged in Count 11 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1014. The cause of action alleged in Count 11 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1015. The cause of action alleged in Count 11 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1016. The cause of action alleged in Count 11 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1017. The cause of action alleged in Count 11 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1018. The cause of action alleged in Count 11 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.

181

1019. The cause of action alleged in Count 11 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1020. The cause of action alleged in Count 11 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
To the extent that the heading that precedes Paragraph 1021 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
1021. The cause of action alleged in Count 11 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1022. The cause of action alleged in Count 11 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1023. The cause of action alleged in Count 11 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1024. The cause of action alleged in Count 11 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
To the extent that the heading that precedes Paragraph 1025 is construed as
allegations, Defendant Linwood Wilson denies the allegations.

182

1025. The cause of action alleged in Count 11 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1026. The cause of action alleged in Count 11 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1027. The cause of action alleged in Count 11 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1028. The cause of action alleged in Count 11 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1029. The cause of action alleged in Count 11 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1030. The cause of action alleged in Count 11 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1031. The cause of action alleged in Count 11 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
To the extent that the heading that precedes Paragraph 1032 is construed as
183

allegations, Defendant Linwood Wilson denies the allegations.
1032. The cause of action alleged in Count 11 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1033. The cause of action alleged in Count 11 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1034. The cause of action alleged in Count 11 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1035. The cause of action alleged in Count 11 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1036. The cause of action alleged in Count 11 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
To the extent that the heading that precedes Paragraph 1037 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
1037. Defendant Linwood Wilson incorporates by reference and restates his
responses to paragraphs 1 through 1036 as if fully set forth herein. Defendant
Linwood Wilson denies the remaining allegations.

184

1038. The cause of action alleged in Count 12 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
To the extent that the headings that precede Paragraph 1039 are construed as
allegations, Defendant Linwood Wilson denies the allegations.
1039. The cause of action alleged in Count 12 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1040. The cause of action alleged in Count 12 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1041. The cause of action alleged in Count 12 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1042. The cause of action alleged in Count 12 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
185

1043. The cause of action alleged in Count 12 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1044. The cause of action alleged in Count 12 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1045. The cause of action alleged in Count 12 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
To the extent that the heading that precedes Paragraph 1046 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
1046. The cause of action alleged in Count 12 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1047. The cause of action alleged in Count 12 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
186

1048. The cause of action alleged in Count 12 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1049. The cause of action alleged in Count 12 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1050. The cause of action alleged in Count 12 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1051. The cause of action alleged in Count 12 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1052. The cause of action alleged in Count 12 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1053. The cause of action alleged in Count 12 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
187

March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1054. The cause of action alleged in Count 12 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
To the extent that the heading that precedes Paragraph 1055 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
1055. The cause of action alleged in Count 12 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1056. The cause of action alleged in Count 12 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1057. The cause of action alleged in Count 12 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1058. The cause of action alleged in Count 12 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
188

March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1059. The cause of action alleged in Count 12 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1060. The cause of action alleged in Count 12 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
To the extent that the heading that precedes Paragraph 1061 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
1061. The cause of action alleged in Count 12 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1062. The cause of action alleged in Count 12 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1063. The cause of action alleged in Count 12 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
189

March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1064. The cause of action alleged in Count 12 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1065. The cause of action alleged in Count 12 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
To the extent that the headings that precede Paragraph 1066 are construed as
allegations, Defendant Linwood Wilson denies the allegations.
1066. The cause of action alleged in Count 12 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1067. The cause of action alleged in Count 12 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1068. The cause of action alleged in Count 12 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
190

March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1069. The cause of action alleged in Count 12 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1070. The cause of action alleged in Count 12 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1071. The cause of action alleged in Count 12 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1072. The cause of action alleged in Count 12 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1073. The cause of action alleged in Count 12 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
191

To the extent that the heading that precedes Paragraph 1074 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
1074. The cause of action alleged in Count 12 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1075. The cause of action alleged in Count 12 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1076. The cause of action alleged in Count 12 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1077. The cause of action alleged in Count 12 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
To the extent that the heading that precedes Paragraph 1078 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
1078. The cause of action alleged in Count 12 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
192

March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1079. The cause of action alleged in Count 12 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1080. The cause of action alleged in Count 12 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1081. The cause of action alleged in Count 12 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1082. The cause of action alleged in Count 12 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1083. The cause of action alleged in Count 12 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
193

1084. The cause of action alleged in Count 12 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1085. The cause of action alleged in Count 12 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1086. The cause of action alleged in Count 12 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1087. The cause of action alleged in Count 12 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
To the extent that the heading that precedes Paragraph 1088 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
1088. The cause of action alleged in Count 12 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
194

1089. The cause of action alleged in Count 12 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1090. The cause of action alleged in Count 12 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1091. The cause of action alleged in Count 12 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1092. The cause of action alleged in Count 12 was dismissed to the extent that it
was asserted against Defendant Linwood Wilson by the Court’s Order of March
31, 2011. To the extent a response is required, Defendant Linwood Wilson denies
the allegations.
1093. The cause of action alleged in Count 12 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1094. The cause of action alleged in Count 12 was dismissed to the extent that it
was asserted against Defendant Linwood Wilson by the Court’s Order of March
195

31, 2011. To the extent a response is required, Defendant Linwood Wilson denies
the allegations.
1095. The cause of action alleged in Count 12 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1096. The cause of action alleged in Count 12 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1097. The cause of action alleged in Count 12 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1098. The cause of action alleged in Count 12 was dismissed to the extent that it
was asserted against Defendant Linwood Wilson by the Court’s Order of March
31, 2011. To the extent a response is required, Defendant Linwood Wilson denies
the allegations.
1099. The cause of action alleged in Count 12 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
196

1100. The cause of action alleged in Count 12 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1101. The cause of action alleged in Count 12 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1102. The cause of action alleged in Count 12 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1103. The cause of action alleged in Count 12 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1104. The cause of action alleged in Count 12 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1105. The cause of action alleged in Count 12 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
197

March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1106. The cause of action alleged in Count 12 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
To the extent that the heading that precedes Paragraph 1107 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
1107. Defendant Linwood Wilson incorporates by reference and restates his
responses to paragraphs 1 through 1106 as if fully set forth herein. Defendant
Linwood Wilson denies the remaining allegations.
1108. The cause of action alleged in Count 13 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1109. The cause of action alleged in Count 13 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1110. The cause of action alleged in Count 13 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of

198

March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1111. The cause of action alleged in Count 13 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1112. The cause of action alleged in Count 13 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1113. The cause of action alleged in Count 13 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1114. The cause of action alleged in Count 13 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1115. The cause of action alleged in Count 13 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
199

1116. The cause of action alleged in Count 13 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1117. The cause of action alleged in Count 13 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1118. The cause of action alleged in Count 13 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1119. The cause of action alleged in Count 13 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1120. The cause of action alleged in Count 13 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1121. The cause of action alleged in Count 13 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
200

March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1122. The cause of action alleged in Count 13 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1123. The cause of action alleged in Count 13 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1124 The cause of action alleged in Count 13 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
To the extent that the heading that precedes Paragraph 1125 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
1125. The cause of action alleged in Count 13 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1126. The cause of action alleged in Count 13 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
201

March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1127. The cause of action alleged in Count 13 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1128. The cause of action alleged in Count 13 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1129. The cause of action alleged in Count 13 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1130. The cause of action alleged in Count 13 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1131. The cause of action alleged in Count 13 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
202

1132. The cause of action alleged in Count 13 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1133. The cause of action alleged in Count 13 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
To the extent that the heading that precedes Paragraph 1134 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
1134. The cause of action alleged in Count 13 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1135. The cause of action alleged in Count 13 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1136. The cause of action alleged in Count 13 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
203

1137. The cause of action alleged in Count 13 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1138. The cause of action alleged in Count 13 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1139. The cause of action alleged in Count 13 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1140. The cause of action alleged in Count 13 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
To the extent that the heading that precedes Paragraph 1141 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
1141. The cause of action alleged in Count 14 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
204

1142. The cause of action alleged in Count 14 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1143. The cause of action alleged in Count 14 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1144. The cause of action alleged in Count 14 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1145. The cause of action alleged in Count 14 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
1146. The cause of action alleged in Count 14 was dismissed to the extent
that it was asserted against Defendant Linwood Wilson by the Court’s Order of
March 31, 2011. To the extent a response is required, Defendant Linwood Wilson
denies the allegations.
To the extent that the heading that precedes Paragraph 1147 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
205

1147. The cause of action alleged in Count 15 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1148. The cause of action alleged in Count 15 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1149. The cause of action alleged in Count 15 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1150. The cause of action alleged in Count 15 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1151. The cause of action alleged in Count 15 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1152. The cause of action alleged in Count 15 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1153. The cause of action alleged in Count 15 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1154. The cause of action alleged in Count 15 was dismissed by the Court’s
206

Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1155. The cause of action alleged in Count 15 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
To the extent that the heading that precedes Paragraph 1156 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
1156. The cause of action alleged in Count 16 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1157. The cause of action alleged in Count 16 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1158. The cause of action alleged in Count 16 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1159. The cause of action alleged in Count 16 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1160. The cause of action alleged in Count 16 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
207

1161. The cause of action alleged in Count 16 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1162. The cause of action alleged in Count 16 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1163. The cause of action alleged in Count 16 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1164. The cause of action alleged in Count 16 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1165. The cause of action alleged in Count 16 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1166. The cause of action alleged in Count 16 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1167. The cause of action alleged in Count 16 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1168. The cause of action alleged in Count 16 was dismissed by the Court’s
208

Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1169. The cause of action alleged in Count 16 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
To the extent that the heading that precedes Paragraph 1170 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
1170. The cause of action alleged in Count 17 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1171. The cause of action alleged in Count 17 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1172. The cause of action alleged in Count 17 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1173. The cause of action alleged in Count 17 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1174. The cause of action alleged in Count 17 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
209

1175. The cause of action alleged in Count 17 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1176. The cause of action alleged in Count 17 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1177. The cause of action alleged in Count 17 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1178. The cause of action alleged in Count 17 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1179. The cause of action alleged in Count 17 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1180. The cause of action alleged in Count 17 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1181. The cause of action alleged in Count 17 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1182. The cause of action alleged in Count 17 was dismissed by the Court’s
210

Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1183. The cause of action alleged in Count 17 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1184. The cause of action alleged in Count 17 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1185. The cause of action alleged in Count 17 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1186. The cause of action alleged in Count 17 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1187. The cause of action alleged in Count 17 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1188. The cause of action alleged in Count 17 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
To the extent that the heading that precedes Paragraph 1189 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
211

1189. Defendant Linwood Wilson incorporates by reference and restates his
responses to paragraphs 1 through 1188 as if fully set forth herein. Defendant
Linwood Wilson denies the remaining allegations.
1190. Defendant Linwood Wilson specifically denies being part of any
conspiracy as alleged in the Second Amended Complaint. Defendant Linwood
Wilson denies the allegations.
1191. Defendant Linwood Wilson denies the allegations.
1192. Defendant Linwood Wilson denies the allegations.
1193. Defendant Linwood Wilson denies the allegations.
1194. Defendant Linwood Wilson denies the allegations.
1195. Defendant Linwood Wilson denies the allegations.
1196. Defendant Linwood Wilson is not alleged in Paragraph 1196. To the
extent that Defendant Linwood Wilson is required to respond, Defendant Linwood
Wilson denies the allegations.
1197. Defendant Linwood Wilson denies the allegations.
1198. Defendant Linwood Wilson is without knowledge or
information sufficient to form a belief about the truth of the allegations and,
therefore, Defendant Linwood Wilson denies the allegations.
1199. Defendant Linwood Wilson denies the allegations.
1200. Defendant Linwood Wilson denies the allegations.
1201. Defendant Linwood Wilson denies the allegations.
1202. Defendant Linwood Wilson denies the allegations.
212

To the extent that the heading that precedes Paragraph 1203 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
1203. The cause of action alleged in Count 19 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1204. The cause of action alleged in Count 19 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1205. The cause of action alleged in Count 19 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1206. The cause of action alleged in Count 19 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1207. The cause of action alleged in Count 19 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1208. The cause of action alleged in Count 19 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1209. The cause of action alleged in Count 19 was dismissed by the Court’s

213

Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1210. The cause of action alleged in Count 19 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1211. The cause of action alleged in Count 19 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1212. The cause of action alleged in Count 19 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
To the extent that the heading that precedes Paragraph 1213 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
1213. The cause of action alleged in Count 20 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1214. The cause of action alleged in Count 20 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1215. The cause of action alleged in Count 20 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
214

1216. The cause of action alleged in Count 20 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1217. The cause of action alleged in Count 20 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1218. The cause of action alleged in Count 20 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1219. The cause of action alleged in Count 20 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1220. The cause of action alleged in Count 20 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1221. The cause of action alleged in Count 20 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1222. The cause of action alleged in Count 20 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
To the extent that the heading that precedes Paragraph 1223 is construed as
215

allegations, Defendant Linwood Wilson denies the allegations.
1223. Defendant Linwood Wilson incorporates by reference and restates his
responses to paragraphs 1 through 1222 as if fully set forth herein. Defendant
Linwood Wilson denies the remaining allegations.
1224. The cause of action alleged in Count 21 does not include or list
Defendant Linwood Wilson as being a named defendant in Count 21. To the
extent a response is required, Defendant Linwood Wilson denies the allegations.
1225. The cause of action alleged in Count 21 does not include or list
Defendant Linwood Wilson as being a named defendant in Count 21. To the
extent a response is required, Defendant Linwood Wilson denies the allegations.
1226. The cause of action alleged in Count 21 does not include or list
Defendant Linwood Wilson as being a named defendant in Count 21. To the
extent a response is required, Defendant Linwood Wilson denies the allegations.
1227. The cause of action alleged in Count 21 does not include or list
Defendant Linwood Wilson as being a named defendant in Count 21. To the
extent a response is required, Defendant Linwood Wilson denies the allegations.
1228. The cause of action alleged in Count 21 does not include or list
Defendant Linwood Wilson as being a named defendant in Count 21. To the
extent a response is required, Defendant Linwood Wilson denies the allegations.
1229. The cause of action alleged in Count 22 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
216

1230. The cause of action alleged in Count 22 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1231. The cause of action alleged in Count 22 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1232. The cause of action alleged in Count 22 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1233. The cause of action alleged in Count 22 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1234. The cause of action alleged in Count 22 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
To the extent that the heading that precedes Paragraph 1235 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
1235. The cause of action alleged in Count 23 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1236. The cause of action alleged in Count 23 was dismissed by the Court’s

217

Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1237. The cause of action alleged in Count 23 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1238. The cause of action alleged in Count 23 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1239. The cause of action alleged in Count 23 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1240. The cause of action alleged in Count 23 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1241. The cause of action alleged in Count 23 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1242. The cause of action alleged in Count 23 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1243. The cause of action alleged in Count 23 was dismissed by the Court’s

218

Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1244. The cause of action alleged in Count 23 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1245. The cause of action alleged in Count 23 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1246. The cause of action alleged in Count 23 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1247. The cause of action alleged in Count 23 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1248. The cause of action alleged in Count 23 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
To the extent that the heading that precedes Paragraph 1249 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
1249. Defendant Linwood Wilson incorporates by reference and restates his
responses to paragraphs 1 through 1248 as if fully set forth herein. Defendant
Linwood Wilson denies the remaining allegations.
219

1250. The cause of action alleged in Count 24 does not include or list
Defendant Linwood Wilson as being a named defendant in Count 24. To the
extent a response is required, Defendant Linwood Wilson denies the allegations.
1251. The cause of action alleged in Count 24 does not include or list
Defendant Linwood Wilson as being a named defendant in Count 24. To the
extent a response is required, Defendant Linwood Wilson denies the allegations.
1252. The cause of action alleged in Count 24 does not include or list
Defendant Linwood Wilson as being a named defendant in Count 24. To the
extent a response is required, Defendant Linwood Wilson denies the allegations.
1253. The cause of action alleged in Count 24 does not include or list
Defendant Linwood Wilson as being a named defendant in Count 24. To the
extent a response is required, Defendant Linwood Wilson denies the allegations.
1254. The cause of action alleged in Count 24 does not include or list
Defendant Linwood Wilson as being a named defendant in Count 24. To the
extent a response is required, Defendant Linwood Wilson denies the allegations.
1255. The cause of action alleged in Count 24 does not include or list
Defendant Linwood Wilson as being a named defendant in Count 24. To the
extent a response is required, Defendant Linwood Wilson denies the allegations.
1256. The cause of action alleged in Count 24 does not include or list
Defendant Linwood Wilson as being a named defendant in Count 24. To the
extent a response is required, Defendant Linwood Wilson denies the allegations.

220

1257. The cause of action alleged in Count 24 does not include or list
Defendant Linwood Wilson as being a named defendant in Count 24. To the
extent a response is required, Defendant Linwood Wilson denies the allegations.
1258. The cause of action alleged in Count 24 does not include or list
Defendant Linwood Wilson as being a named defendant in Count 24. To the
extent a response is required, Defendant Linwood Wilson denies the allegations.
1259. The cause of action alleged in Count 24 does not include or list
Defendant Linwood Wilson as being a named defendant in Count 24. To the
extent a response is required, Defendant Linwood Wilson denies the allegations.
1260. The cause of action alleged in Count 24 does not include or list
Defendant Linwood Wilson as being a named defendant in Count 24. To the
extent a response is required, Defendant Linwood Wilson denies the allegations.
1261. Defendant Linwood Wilson incorporates by reference and restates his
responses to paragraphs 1 through 1260 as if fully set forth herein. Defendant
Linwood Wilson denies the remaining allegations.
1262. The cause of action alleged in Count 25 does not include or list
Defendant Linwood Wilson as being a named defendant in Count 25. To the
extent a response is required, Defendant Linwood Wilson denies the allegations.
1263. The cause of action alleged in Count 25 does not include or list
Defendant Linwood Wilson as being a named defendant in Count 25. To the
extent a response is required, Defendant Linwood Wilson denies the allegations.

221

1264. The cause of action alleged in Count 25 does not include or list
Defendant Linwood Wilson as being a named defendant in Count 25. To the
extent a response is required, Defendant Linwood Wilson denies the allegations.
1265. The cause of action alleged in Count 25 does not include or list
Defendant Linwood Wilson as being a named defendant in Count 25. To the
extent a response is required, Defendant Linwood Wilson denies the allegations.
1266. The cause of action alleged in Count 25 does not include or list
Defendant Linwood Wilson as being a named defendant in Count 25. To the
extent a response is required, Defendant Linwood Wilson denies the allegations.
1267. The cause of action alleged in Count 25 does not include or list
Defendant Linwood Wilson as being a named defendant in Count 25. To the
extent a response is required, Defendant Linwood Wilson denies the allegations.
To the extent that the heading that precedes Paragraph 1268 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
1268. Defendant Linwood Wilson incorporates by reference and restates his
responses to paragraphs 1 through 1267 as if fully set forth herein. Defendant
Linwood Wilson denies the remaining allegations.
1269. The cause of action alleged in Count 26 does not include or list
Defendant Linwood Wilson as being a named defendant in Count 26. To the
extent a response is required, Defendant Linwood Wilson denies the allegations.

222

1270. The cause of action alleged in Count 26 does not include or list
Defendant Linwood Wilson as being a named defendant in Count 26. To the
extent a response is required, Defendant Linwood Wilson denies the allegations.
1271. The cause of action alleged in Count 26 does not include or list
Defendant Linwood Wilson as being a named defendant in Count 26. To the
extent a response is required, Defendant Linwood Wilson denies the allegations.
1272. The cause of action alleged in Count 26 does not include or list
Defendant Linwood Wilson as being a named defendant in Count 26. To the
extent a response is required, Defendant Linwood Wilson denies the allegations.
1273. The cause of action alleged in Count 26 does not include or list
Defendant Linwood Wilson as being a named defendant in Count 26. To the
extent a response is required, Defendant Linwood Wilson denies the allegations.
1274. The cause of action alleged in Count 26 does not include or list
Defendant Linwood Wilson as being a named defendant in Count 26. To the
extent a response is required, Defendant Linwood Wilson denies the allegations.
1275. The cause of action alleged in Count 26 does not include or list
Defendant Linwood Wilson as being a named defendant in Count 26. To the
extent a response is required, Defendant Linwood Wilson denies the allegations.
1276. The cause of action alleged in Count 26 does not include or list
Defendant Linwood Wilson as being a named defendant in Count 26. To the
extent a response is required, Defendant Linwood Wilson denies the allegations.
To the extent that the heading that precedes Paragraph 1277 is construed as
223

allegations, Defendant Wilson denies the allegations.
1277. The cause of action alleged in Count 27 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1278. The cause of action alleged in Count 27 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1279. The cause of action alleged in Count 27 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1280. The cause of action alleged in Count 27 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1281. The cause of action alleged in Count 27 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1282. The cause of action alleged in Count 27 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
To the extent that the heading that precedes Paragraph 1283 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
1283. The cause of action alleged in Count 28 was dismissed by the Court’s
224

Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1284. The cause of action alleged in Count 28 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1285. The cause of action alleged in Count 28 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1286. The cause of action alleged in Count 28 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1287. The cause of action alleged in Count 28 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1288. The cause of action alleged in Count 28 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
To the extent that the heading that precedes Paragraph 1289 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
1289. The cause of action alleged in Count 29 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
225

1290. The cause of action alleged in Count 29 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1291. The cause of action alleged in Count 29 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1292. The cause of action alleged in Count 29 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1293. The cause of action alleged in Count 29 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1294. The cause of action alleged in Count 29 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1295. The cause of action alleged in Count 29 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1296. The cause of action alleged in Count 29 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1297. The cause of action alleged in Count 29 was dismissed by the Court’s
226

Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1298. The cause of action alleged in Count 29 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1299. The cause of action alleged in Count 29 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1300. The cause of action alleged in Count 29 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
To the extent that the heading that precedes Paragraph 1301 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
1301. The cause of action alleged in Count 30 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1302. The cause of action alleged in Count 30 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1303. The cause of action alleged in Count 30 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
227

1304. The cause of action alleged in Count 30 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1305. The cause of action alleged in Count 30 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1306. The cause of action alleged in Count 30 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1307. The cause of action alleged in Count 30 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1308. The cause of action alleged in Count 30 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
To the extent that the heading that precedes Paragraph 1309 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
1309. The cause of action alleged in Count 31 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1310. The cause of action alleged in Count 31 was dismissed by the Court’s

228

Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1311. The cause of action alleged in Count 31 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1312. The cause of action alleged in Count 31 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1313. The cause of action alleged in Count 31 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1314. The cause of action alleged in Count 31 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1315. The cause of action alleged in Count 31 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1316. The cause of action alleged in Count 31 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1317. The cause of action alleged in Count 31 was dismissed by the Court’s

229

Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
To the extent that the heading that precedes Paragraph 1318 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
1318. Defendant Linwood Wilson incorporates by reference and restates his
responses to paragraphs 1 through 1317 as if fully set forth herein. Defendant
Linwood Wilson denies the remaining allegations.
1319. The cause of action alleged in Count 32 does not include or list
Defendant Linwood Wilson as being a named defendant in Count 32. To the
extent a response is required, Defendant Linwood Wilson denies the allegations.
1320. The cause of action alleged in Count 32 does not include or list
Defendant Linwood Wilson as being a named defendant in Count 32. To the
extent a response is required, Defendant Linwood Wilson denies the allegations.
1321. The cause of action alleged in Count 32 does not include or list
Defendant Linwood Wilson as being a named defendant in Count 32. To the
extent a response is required, Defendant Linwood Wilson denies the allegations.
1322. The cause of action alleged in Count 32 does not include or list
Defendant Linwood Wilson as being a named defendant in Count 32. To the
extent a response is required, Defendant Linwood Wilson denies the allegations.
1323. The cause of action alleged in Count 32 does not include or list
Defendant Linwood Wilson as being a named defendant in Count 32. To the
extent a response is required, Defendant Linwood Wilson denies the allegations.
230

1324. The cause of action alleged in Count 32 does not include or list
Defendant Linwood Wilson as being a named defendant in Count 32. To the
extent a response is required, Defendant Linwood Wilson denies the allegations.
1325. The cause of action alleged in Count 32 does not include or list
Defendant Linwood Wilson as being a named defendant in Count 32. To the
extent a response is required, Defendant Linwood Wilson denies the allegations.
To the extent that the heading that precedes Paragraph 1326 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
1326. The cause of action alleged in Count 33 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1327. The cause of action alleged in Count 33 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1328. The cause of action alleged in Count 33 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1329. The cause of action alleged in Count 33 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1330. The cause of action alleged in Count 33 was dismissed by the Court’s

231

Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1331. The cause of action alleged in Count 33 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
To the extent that the heading that precedes Paragraph 1332 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
1332. The cause of action alleged in Count 34 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1333. The cause of action alleged in Count 34 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1334. The cause of action alleged in Count 34 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1335. The cause of action alleged in Count 34 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1336. The cause of action alleged in Count 34 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
232

1337. The cause of action alleged in Count 34 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1338. The cause of action alleged in Count 34 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1339. The cause of action alleged in Count 34 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
To the extent that the heading that precedes Paragraph 1340 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
1340. To the extent that the contents of Paragraph 1340 are allegations,
Defendants Linwood Wilson denies the allegations.
1341. Defendant Linwood Wilson incorporates by reference and restates his
responses to paragraphs 1 through 1340 as if fully set forth herein. Defendant
Linwood Wilson denies the remaining allegations.
1342. The cause of action alleged in Count 35 does not include or list
Defendant Linwood Wilson as being a named defendant in Count 35. To the
extent a response is required, Defendant Linwood Wilson denies the allegations.
1343. The cause of action alleged in Count 35 does not include or list
Defendant Linwood Wilson as being a named defendant in Count 35. To the
extent a response is required, Defendant Linwood Wilson denies the allegations.
233

1344. The cause of action alleged in Count 35 does not include or list
Defendant Linwood Wilson as being a named defendant in Count 35. To the
extent a response is required, Defendant Linwood Wilson denies the allegations.
1345. The cause of action alleged in Count 35 does not include or list
Defendant Linwood Wilson as being a named defendant in Count 35. To the
extent a response is required, Defendant Linwood Wilson denies the allegations.
1346. The cause of action alleged in Count 35 does not include or list
Defendant Linwood Wilson as being a named defendant in Count 35. To the
extent a response is required, Defendant Linwood Wilson denies the allegations.
1347. The cause of action alleged in Count 35 does not include or list
Defendant Linwood Wilson as being a named defendant in Count 35. To the
extent a response is required, Defendant Linwood Wilson denies the allegations.
To the extent that the heading that precedes Paragraph 1348 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
1348. The cause of action alleged in Count 36 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1349. The cause of action alleged in Count 36 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1350. The cause of action alleged in Count 36 was dismissed by the Court’s

234

Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1351. The cause of action alleged in Count 36 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1352. The cause of action alleged in Count 36 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1353. The cause of action alleged in Count 36 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
To the extent that the heading that precedes Paragraph 1354 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
1354. The cause of action alleged in Count 37 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1355. The cause of action alleged in Count 37 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1356. The cause of action alleged in Count 37 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
235

1357. The cause of action alleged in Count 37 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1358. The cause of action alleged in Count 37 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1359. The cause of action alleged in Count 37 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
To the extent that the heading that precedes Paragraph 1360 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
1360. The cause of action alleged in Count 38 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1361. The cause of action alleged in Count 38 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1362. The cause of action alleged in Count 38 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1363. The cause of action alleged in Count 38 was dismissed by the Court’s

236

Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1364. The cause of action alleged in Count 38 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1365. The cause of action alleged in Count 38 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
To the extent that the heading that precedes Paragraph 1366 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
1366. The cause of action alleged in Count 39 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1367. The cause of action alleged in Count 39 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1368. The cause of action alleged in Count 39 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1369. The cause of action alleged in Count 39 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
237

1370. The cause of action alleged in Count 39 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1371. The cause of action alleged in Count 39 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
To the extent that the heading that precedes Paragraph 1372 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
1372. The cause of action alleged in Count 40 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1373. The cause of action alleged in Count 40 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1374. The cause of action alleged in Count 40 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1375. The cause of action alleged in Count 40 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1376. The cause of action alleged in Count 40 was dismissed by the Court’s

238

Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1377. The cause of action alleged in Count 40 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1378. The cause of action alleged in Count 40 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1379. The cause of action alleged in Count 40 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1380. The cause of action alleged in Count 40 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
1381. The cause of action alleged in Count 40 was dismissed by the Court’s
Order of March 31, 2011. To the extent a response is required, Defendant
Linwood Wilson denies the allegations.
To the extent that the heading that precedes Paragraph 1382 is construed as
allegations, Defendant Linwood Wilson denies the allegations.
1382. Defendant Linwood Wilson incorporates by reference and restates his
responses to paragraphs 1 through 1381 as if fully set forth herein. Defendant
Linwood Wilson denies the remaining allegations.
239

1383. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
1384. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
1385. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
1386. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
1387. Defendant Linwood Wilson is without knowledge or information
sufficient to form a belief about the truth of the allegations and, therefore, denies
the allegations.
1388. Defendant Linwood Wilson denies the allegations, including the
allegations contained in subparagraphs A, B, C, D, and E.
FIRST AFFIRMATIVE DEFENSE
To the extent Plaintiffs seek to hold Defendant Linwood Wilson
responsible for the action or inaction of the City of Durham, the Durham
Defendants, the Duke University Defendants, the Duke University Police
Defendants, or the Duke SANE Defendants, Defendant Wilson incorporates any
240

defenses asserted by, or available to, the City of Durham, the Durham Defendants,
the Duke University Defendants, the Duke University Police Defendants, or the
Duke SANE Defendants.
SECOND AFFIRMATIVE DEFENSE
To the extent that Defendant Linwood Wilson, is determined to be a state actor,
then Defendant Linwood Wilson is entitled to the same privileges and immunities
as any other state actor including prosecutorial immunity and qualified immunity.
THIRD AFFIRMATIVE DEFENSE
Plaintiffs have waived and/or are estopped from asserting any and all claims they
may have or have had against Defendant Linwood Wilson.
FOURTH AFFIRMATIVE DEFENSE
The damages sustained by Plaintiffs, if any, were proximately caused by the
intervening and superseding acts of other persons or parties over whom
Defendant Linwood Wilson had no control and for whose conduct Defendant
Linwood Wilson is not reasonably responsible. These intervening and superseding
acts were not reasonably foreseeable to Defendant Linwood Wilson. These acts
bar and/or diminish Plaintiffs’ recovery, if any, against Defendant Linwood
Wilson. By way of example, these intervening and superseding acts include, but
are not limited to, the false rape allegations made by Crystal Mangum and the
actions of former District Attorney Michael Nifong in directing the investigation
of those allegations.

241

FIFTH AFFIRMATIVE DEFENSE
Plaintiffs failed to mitigate their damages.
SIXTH AFFIRMATIVE DEFENSE
Plaintiffs’ claims are barred by the applicable statutes of limitations and periods of
limitations and repose. To the extent that any of Plaintiffs’ claims are equitable in
nature, they are barred by the doctrine of laches.
SEVENTH AFFIRMATIVE DEFENSE
Any award of punitive damages violates the United States Constitution, the
Constitution of the State of North Carolina, and other applicable state and federal
laws, in that an award of punitive damages is impermissible in this case because it
would (1) constitute an excessive fine and forfeiture in contravention of the Eighth
Amendment of the United States Constitution and corresponding state constitution
provisions, (2) violate the Defendant Linwood Wilson’s right to due process and
equal protection of the laws in contravention of the Fourteenth Amendment to the
United States Constitution and corresponding state constitution provisions, (3)
violate Defendant Linwood Wilson’s right to procedural safeguards provided
by the Sixth Amendment to the United States Constitution for alleged penal
conduct, including but not limited to permitting imposition of punitive damages
with a burden of proof less than “beyond a reasonable doubt”, and (4) bear no
proportional or rational relationship to any actual damages or to the type of
conduct involved and violates the United States Constitution the Constitution of
the State of North Carolina, and other applicable laws, including but not limited to
242

the provisions of Chapter 1D of the North Carolina General Statutes. Defendant
Linwood Wilson reserves the right to assert any additional and further defenses as
may be revealed during discovery or upon receipt of additional information.
JURY TRIAL DEMAND
Defendant Linwood Wilson respectfully demand trial by jury on all issues so
triable in this action.
PRAYER FOR RELIEF
WHEREFORE, Defendant Linwood Wilson requests that this Court:
1. Dismiss this action with prejudice;
2. Denies any relief to Plaintiffs; and
3. For such other and further relief as the Court deems just and proper.

This the 14th day of June, 2011.
/s/ Linwood Wilson, Pro Se
6910 Innesbrook Way
Bahama, North Carolina 27503
Telephone: [phone]
Email: [e-mail]

243

CERTIFICATE OF SERVICE
I hereby certify that on June 14, 2011, I electronically filed the foregoing Answer
of Defendant Linwood Wilson with the Clerk of the Court using the CM/ECF
system, which will send notification of such filing to all counsel of record.
This 14th day of June, 2011.
/s/ Linwood Wilson, Pro Se
6910 Innesbrook Way
Bahama, North Carolina 27503
Telephone: [phone]
Email: [e-mail]

244