Now come Defendants Board of Trustees of the Columbus Metropolitan Library (the "Board") and Patrick Losinski (collectively referred to as "Defendants"), by and through counsel and for their Answer to Plaintiff's Complaint admit, deny and state as follows:

1. Defendants are without sufficient knowledge to confirm or deny the truth of the allegations contained in paragraph 1 of the Complaint and therefore deny the same. [Complaint]

2. Defendants deny the allegations of paragraph 2 of the Complaint, except that they admit that the Board is authorized to publish regulations for the Library. In further response, Defendants state that paragraph 2 contains assertions of law for which no answer is required. [Complaint]

3. Defendants deny the allegations of paragraph 3 of the Complaint, except that they admit that Larry Black was previously the Executive Director of the Columbus Metropolitan Library and that Mr. Losinksi is the current Executive Director of the Columbus Metropolitan Library. [Complaint]

4. Defendants are without sufficient knowledge to confirm or deny the allegations of paragraph 4 of the Complaint and therefore deny the same. [Complaint]

5. Defendants deny the allegations of paragraph 5 of the Complaint, except that they admit that Plaintiff was evicted from the Columbus Metropolitan Library for refusing to wear shoes. [Complaint]

6. Defendants deny the allegations of paragraph 6 of the Complaint, except that they admit that Plaintiff was informed that, in order to use the library facilities, he would have to wear shoes. [Complaint]

7. Defendants deny the allegations of paragraph 7 of the Complaint, except that they admit that Plaintiff was asked to leave the library because he refused to wear shoes. [Complaint]

8. Defendants deny the allegations of paragraph 8 of the Complaint, except that they admit that Plaintiff was asked to leave the library because he was not wearing shoes and further state that Plaintiff was issued a one-day eviction. Vonzell Johnson is not a Defendant in this action. [Complaint]

9. Defendants admit the allegations of paragraph 9 of the Complaint. [Complaint]

10. Defendants admit the allegations of paragraph 10 of the Complaint. [Complaint]

11. Defendants deny the allegations of paragraph 11 of the Complaint, except that they admit that the policy requiring shoes also allows for a warning, a request to leave, or a request to wear shoes. [Complaint]

12. Defendants deny the allegations of paragraph 12 of the Complaint. [Complaint]

13. Defendants are without sufficient knowledge to confirm or deny the allegations of paragraph 13 of the Complaint, and therefore deny the same. [Complaint]

14. Defendants deny the allegations of paragraph 14 of the Complaint, except that they admit that Plaintiff wrote letters to Defendant Black. In further response, Defendants state that Plaintiff's letters (and Mr. Black's responses to same) speak for themselves. [Complaint]

15. Defendants deny the allegations of paragraph 15 of the Complaint, except that they admit that Plaintiff wrote to the Board and that Mr. Swaddling responded to Plaintiff's letter. In further response, Defendants state that such correspondence speaks for itself. [Complaint]

16. Defendants deny the allegations of paragraph 16 of the Complaint, except that they admit that Plaintiff sent a letter to Mr. Black and Mr. Black responded. In further response, Defendants state that such correspondence speaks for itself. [Complaint]

17. Defendants deny the allegations of paragraph 17 of the Complaint, except that Defendants admit that Plaintiff brought an action against the Board and other defendants in this Court and that the case was captioned 01 CV-04-3104. [Complaint]

18. Defendants deny the allegations of paragraph 18 of the Complaint, except that Defendants admit that the Board and its co-defendants in the case captioned 01CV-04-3104 removed Plaintiff's action to the United States District Court for the Southern District of Ohio, which granted summary judgment in favor of the Board and its co-defendants on all Plaintiff's claims. Defendants admit that the United States Court of Appeals for the Sixth Circuit affirmed the District Court's decision and that the United States Supreme Court denied Plaintiff's petition for certiorari. [Complaint]

19. Defendants are without sufficient knowledge to confirm or deny the truth of the allegations of paragraph 19 of the Complaint and therefore deny the same. [Complaint]

20. Defendants deny the allegations of paragraph 20 of the Complaint, except that they admit that Plaintiff sent a letter to Mr. Losinski and that Mr. Losinski did not respond. In further response, Defendants state that Plaintiff's letter speaks for itself. [Complaint]

21. Defendants are without sufficient knowledge to confirm or deny the truth of the allegations of paragraph 21 of the Complaint and therefore deny the same. [Complaint]

22. Defendants are without sufficient knowledge to confirm or deny the truth of the allegations of paragraph 22 of the Complaint and therefore deny the same. [Complaint]

23. Defendants deny the allegations of paragraph 23 of the Complaint. [Complaint]

24. Defendants deny the allegations of paragraph 24 of the Complaint. [Complaint]

25. Defendants deny the allegations of paragraph 25 of the Complaint, and further aver that Mr. Black has not been named as a defendant in this action. [Complaint]

26. Defendants deny the allegations of paragraph 26 of the Complaint. [Complaint]

27. Defendants deny each and every allegation not expressly and specifically admitted herein as true.

28. Plaintiff's Complaint is barred as a matter of law by the doctrines of res judicata and collateral estoppel.

29. Plaintiff's Complaint fails to state a claim upon which relief may be granted.

30. Plaintiff's actions, and not those of Defendants, are the proximate, contributing and intervening cause of the harm, if any, Plaintiff suffered.

31. Defendants acted at all times in good faith and with reasonable grounds for believing that their actions were authorized by law, and at no time did they willfully violate any state or federal Constitutional provision. without regard to any class-based distinction.

32. The Defendants are protected by the doctrine of qualified immunity.

33. Plaintiff has failed to mitigate his damages.

34. Plaintiff's claims are barred by the statute of limitations.

WHEREFORE, having fully answered, Defendants pray that

1. Judgment be rendered in their favor and against Plaintiff;

2. This Court dismiss the Complaint with prejudice;

3. Defendants be awarded its costs and disbursements, including reasonable attorney's fees, and

4. This Court grant to Defendants such other relief as justice requires.

I hereby certify that a true and accurate copy of the foregoing Answer to Plaintiff's Complaint was served by regular U.S. mail, postage prepaid, upon Robert A. Neinast, Plaintiff, 8617 Ashford Lane, Pickerington, Ohio 43147, this 23rd day of July, 2004.