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IN THE [OWA DISTRICT COURT FOR MARION COUNTY VALERIE BANDSIRA, ANNE BANDSTRA, RYAN BANDSTRA, and JASON BANDSTRA, CASE Vo. LACV0D4670 Plains, ANSWER & COUNTERC! AIM BY DEFENDANT EDOUARD (Gury Tal Demasded) PATRICK EDOUARD, COVENANT REFORMED CHURCH, UNITED REFORMED CHURCHES IN NORTH AMERICA, CLARENCE HETTINGA, ARNOLD VAN DGNSELAAR, NORMAN VAN MERSBERGEN, WILLIAM HARTMAN, and the BOARD. OF ELDERS OF COVENANT REFORMED CHURCH, Defendants PATRICK EDOUARD, Counterclaimant, VALERIE BANDSTRA, ANNE BANDSTRA, RYAN BANDSTRA, and JASON BANDSTR: Counterclaim Defendants, (COMES NOW Defendant Patrick Edouced (“Edouard”) and for his Answer, Affiemative Deferses, and Counterelain ty Painlfls' Petition, states to the court che following 1 Paragraph 1 is admitted, 2. Paragraph 2 is adiited 3 Paragraph 3 is waite 4 Paragraph 4s admitted. 5 Paragraph Sis admit. 6. Paragraph 6s adit 1 Paragraph 7 is denied ‘ar hick of knowledge 8 Paragraph 8 is denied fo lack of knowledge ° PParagrap 9 is adnited 1. Paragraph 10s admit in pat as to venus, ad ded ia pa as legates ‘of unlavful aetions and injries sustained. 1 Pacagraph 11 is dene. 2 Paragraph 12 is denied, 13, Paragraph L? is denied for lack of knowlee ze. 14, Paragragh 14 i admit. 15, Paragranh 1$ is admited 16. Paragraph 16 is admitted, 17, Paragraph 17 is denied 18, Paragraph 18 is denied 19, Paragraphs 19 is denied 20, Paaraphh 20s denied 21. Paragraph 21 is denied Paragraph 22 is dleniod 28. 39, 22, cragraph 23 is denied, Paragreph 24 is denied Paragrep: 25 is denied. Paragraph 26 is deni Paragraph 27 is admitted tothe exten: that Edoward and Anne Bandsta dig ‘mutually kiss at Ange Bandsta's house Paragraph 28 is domed. Paragraph 29 is ade. Paragraph 30 is denied, Paragraph 31 is denied. Paragraph 32 is admitted to the extent that Ryan Bandstra was told that Edousré and Arne Bandstand kissed on December 10, 2010. Paragraph 33 is denied for hack ef knowledge. Paragraph 3 is denied for lack of knowlecge. Parngragh 38 is adie Paragraph 36 is wdmited wo the extent that Valerie Bandstra did state scound this time that Edouard rape het. It is denied that Edouard dig rape her, Is umknoven what meeting is hsing “wferred ta and so the remainder is denied for lack of knowledge. Paragraph 37 is denied for lac of knewledge, Paragraph 38 is denied for luck of knowledge, Paraaraph 39 is denied for luck of knowledge, a 62, Parauraph 40 is Cenied for lack oP knowlege Peragraph Ais Genied aragreph 42 is denied Paraurepl: 43 is denied, Paragraph 44 is denied Paragraph 45 is denice Paragraph 40 is demo Paragraph 47 is danced. ed Paragraph 48 ie Paragraph 49 is denied. Paragraph 50 is denied fer lok of knowhede Paragraph 81 is denied Paragragh 52 is denied Paragraph 53 is denied Paragraph 54 is denied Paragraph 5 is denied. Paragraph 56 is denied Paragraph 57 is denied Paragraph 58 is denied, Paragraph 59 is denied, Paragraph 60 is denied Paragcaph $1 is denied, Paragraph 62 is denied, 6 Parasraph 63 is denied 63. Paragraph 6 is denied 65. Paragraph 65 is deni 66. Paragraph 66 is don:ed 62. Paragraph 67 is denied 6%. Paragraph 68 is denied 69. Paragraph 69 i dene. 7), Pasayragh 70s admitted as to Edouard heing Plains" pastor, but denied as to being P.aintiffe" counseler. Paragruah 71 i denied. Paragragh 72 is denied 2 Paragraph 73s denied 7A, Panagraph 7 is dene. 1s Paragraph 75 is deni. 76. Paraoraph 76 is denied. 77. Paragraph 79 is denied fora lack of knowledge 78 Paingraph 78s deniod 79, Paragraph 79s de 80, Paragraph 80s dena for lck of knowledge si Paragraph 81 is denis 82, Patagraph 82 is denied. 82 Paragraph 83 is denied. 84, Pamgraph 84 is admitted. 85, Parayraph $5 is ened. Sh Paragraph 86 is cenied. 87, Paragraph 87 is denied 88. Paragrept 88 is denied 89, Paragraph 89 is donicd 90, Paragraph 90 is denied 91. Paragraph 91 is denice. 92, Paragraph 92 is dene. 93, Paragraph 93 is aleitted as to emplo knowledge aslo eating ar agency: 94. Paragraph 94 is atte as to Edozard deing an employee ofthe church, but denied “or hick of knowledge as to eing an egent for the Church, an employee crayon for the Elders 93, Pasagraph 95 is denied. 96, Paragraph 96 is denied for luck ef knowlecg, Paragraah 97 is denial fo lack of know erge 98. Paragrash 98 is denied for lack of Knowiedye 99, Paragraph 99 is denied for lack oF knowledge 100, Parazraph 100 s deni for lack of krovwledge 101. Paragraph 161 :s denied for lack of krovstedue. 102, Paragraph 102 is denied 103, Paragraph 105 is denied 104. Paragraph 104 is deri. 105. Paragraph 10S is denied. 106. Piraraph 196s adie 107.Peragreph 197 is ada 108. Paragrap 108 is denied for lack of knowledge. 109.Paragraph 109 is denied 110.Paragraph 110 is denied 111. Paragraph 191i deated. 112, Paragraph 1:2 is dened 113. Paragraph 113 ie denied 114.Paragraph 114 is denied fut lack of knowtedge 115. Paragraph 115 is denied for lack of knowledge. 116. Paragraph 116 is denied for lack of knowlege. 117, Paragraph 117 is denied for lack of knowledge. 118. Paragraph 118 is denied for lack of knowledge, 119.Parageaph 119 is denied for lack of knowledge. NERAL DENIAL 120. To the extent tkat Edouard bas not responded to an allegation in any paragraph, Defendant denies the allega‘ion therein, ADDITIONAL FACTS RELATED TO DEFENDANT EDOUARD'S AFFIRMATIVE LL 124, 176. 129, 130. DEFEN: ND COUNTERG IM ilovant re leges and incoeporates ts responses to parwgraphs 1 through 120 as if fully sot out herein. Edouurd and Plaintiff Valeie Bendstea engages in a consensual aftr beginning in 2006 ana edi 2097 Edouard never provided mental health services to Valesie Busta Plaintit® Vaeris Bandstra initiated sexual activity with Faouant on numnerons Edouard and PlaintiT Anne Bandstra engaged in a consensual affair beginring in 2008 and ending in December 2010. Plein Anne Busdstra isitiated sexual activity with Edouard on numerous Fdauard never provided mental health services to Arne Bantsira, Plaintiff Anne Bandstra was caught in her extramarital affair with Edouard by her husbune, Plaintiff Ryan Bardstra Pluintift Valerie andsira was having an affair with a third party, Ramiro Cruz Montomayor ia 2010. Plainti Valerie Bandsira's hushand, Plain iff Jase Sandsta, discon ‘Bandstra's affair with Montemayor in the spr 1g 0F 2070, The affair berween Montemayor and Valerie Bandstra was the eause of marital strife betwsen Valerie Bandstra and Jason Bandstra, 15 134. Las. 136. 40, Plaintiff Valerie Bandstra only frst cluimesd Béouard had raped her ater Valerie Bandsta discovered Edcuurd was having an affair with Anne Bandstra, and ater sve al been cau in her afte with Montemayor Plainti Vere Bands filse em af rape eased ew other women ta flsely claim Edouard had raped them. AFFIRMATIVE DEFE! Plains have od to state a claim upon which rliofcan be grante Planets" clans may be barred by the doctrines of estoppel laces, standing, ‘waiver and other eyuitable doctrines us discovery may establish Plant" claims may be subject to comparative faut under Towa Code section 668 leit claims may be barred by the statute of limitations. Plaie:ifis may have file! to mitigate their damages and, therefore, any recovery by Plactifs should 20: include any less witch Pleinffs could have prevented by remo care and diligence Plontifs'asious may bar the rele? sought by Pai under due eeuituble doctrine of unclean hanes I Plainifis sustained any damages as alleged in Plantifs' Petition, whieh Defendant Edouard specifelly denies the assessineat af exemplary or punitive damages violates Defendant Edouard’s constitutional rights under the Fifth, Sixth, Fighth and Fourtcomt Amendments of the United States Constitution and comparable provisions of the Towa Constitution. 141, _Dafencant Edouard reserves the right amend his Answer to assert such allizmative defenses as may kecome available through discovery. WIIEREFORE, Dofeudest requests tha: PlaintiNi Petition be dismissed at Plains costs COUNTERCLAIMS COUNT 1: DEFAMATION (LIBEL & SLANDER) AGAINST VALERIE BANDSTRA 142, Paragraphs 1-141 are replended and incorporated as if Silly sot forth herein 143. Begins:ny on or ahout Dacember 14,2010, Plantf? Valerie Bandra began cvlly (ling eaividus tha she bl boon raped by Edouard, 144, Plain Vaterie Bandstra made shese oral statements that she was raped by Edouard to members of Covenant Reformed Church, to menbers othe community, und to other thied patios, 145, Or or avout January 18,2011, Paintiff aleve Hinestra made an oral statement «law enforsorsent elaimning Edouard had raped 146. Onor about January 24,2011, Plain F Valerie Bandstea made a wring aceusing Edouard of raping her which was given to law enforeenwent Throughout 2011 and 20:2 Plainttf Valerie Bandstea contin to make statements te people known and unknavsn:0 Edouard that Edouard hat rape her. 118, Throughout 2011, Plaintiff Valeie Benstea encouraged cequaintances and strangers google” Edous so that they would read her eluims of rape on the internet, 10