CIRCUIT COURT OF MILWAUKEE COUNTY MILWAUKEE COUNTY, WISCONSIN State of Wisconsin Plaintiff 2021CF004619 -vsHeather R Rouse Defendant JURY DEMANDED HEREIN ANSWER OF DEFENDANT HEATHER R ROUSE TO THE STATE'S COMPLAINT In the matter before the Court, the Defendant, Heather R. Rouse, stands as a poignant example of the tragic intersection between human vulnerability and criminal exploitation. While the allegations against Ms. Rouse are grave, it is imperative to recognize the context in which these events unfolded—a context marked by her innocence and victimization. Ms. Rouse, who longed for nothing more than the safety of her home and the embrace of her husband, found herself ensnared in the manipulative web of human trafficking, orchestrated by the co-defendant, Derek Hebel. Her involvement in the alleged crime was not the product of free will but the result of coercion and sexual exploitation at the hands of those who sought to use her as a pawn for their own nefarious ends. The Plaintiff's own misconduct casts a shadow over the proceedings, as it is alleged that they compelled Ms. Rouse, under duress, to engage in acts that no person should ever be forced to endure, much less as a means of payment for services. This reprehensible behavior, coupled with the Plaintiff's awareness of Ms. Rouse's dire situation and their decision to exploit it nonetheless, underscores a pattern of predatory conduct that cannot be overlooked. In light of these circumstances, the Defendant's plea of Not Guilty is not merely a formal response to the charges but a resounding declaration of the fundamental injustice that has befallen her. It is with these truths at the forefront that this Answer is respectfully submitted, as we seek to navigate through the complexities of this case and strive for a resolution that acknowledges the full extent of Ms. Rouse's suffering and the overriding need for her vindication. ANSWER 1. Defendant denies the allegations in paragraph 1 of the Complaint as Defendant is without sufficient information to admit or deny and therefore denies the same and puts Plaintiff to their strict proof thereof. 2. Defendant denies the allegations in paragraph 2 of the Complaint as it contains legal conclusions and characterizations to which no response is required; to the extent a response is required, Defendant denies. 3. Defendant denies the allegations in paragraph 3 of the Complaint as it contains legal conclusions and characterizations to which no response is required; to the extent a response is required, Defendant denies. 4. Defendant admits to the allegations in paragraph 4 of the Complaint to the extent that it pleads Not Guilty. 5. Defendant denies the allegations in paragraph 5 of the Complaint as Defendant is without sufficient information to admit or deny and therefore denies the same and puts Plaintiff to their strict proof thereof. 6. Defendant denies the allegations in paragraph 6 of the Complaint as it contains legal conclusions and characterizations to which no response is required; to the extent a response is required, Defendant denies. 7. Defendant denies the allegations in paragraph 7 of the Complaint as Defendant is without sufficient information to admit or deny and therefore denies the same and puts Plaintiff to their strict proof thereof. 8. Defendant denies the allegations in paragraph 8 of the Complaint as Defendant is without sufficient information to admit or deny and therefore denies the same and puts Plaintiff to their strict proof thereof. 9. Defendant denies the allegations in paragraph 9 of the Complaint as it contains legal conclusions and characterizations to which no response is required; to the extent a response is required, Defendant denies. 10. Defendant denies the allegations in paragraph 10 of the Complaint as Defendant is without sufficient information to admit or deny and therefore denies the same and puts Plaintiff to their strict proof thereof. 11. Defendant denies the allegations in paragraph 11 of the Complaint as it contains legal conclusions and characterizations to which no response is required; to the extent a response is required, Defendant denies. 12. Defendant denies the allegations in paragraph 12 of the Complaint as Defendant is without sufficient information to admit or deny and therefore denies the same and puts Plaintiff to their strict proof thereof. 13. Defendant denies the allegations in paragraph 13 of the Complaint as it contains legal conclusions and characterizations to which no response is required; to the extent a response is required, Defendant denies. 14. Defendant denies the allegations in paragraph 14 of the Complaint as Defendant is without sufficient information to admit or deny and therefore denies the same and puts Plaintiff to their strict proof thereof. 15. Defendant denies the allegations in paragraph 15 of the Complaint as it contains legal conclusions and characterizations to which no response is required; to the extent a response is required, Defendant denies. 16. Defendant denies the allegations in paragraph 16 of the Complaint as Defendant is without sufficient information to admit or deny and therefore denies the same and puts Plaintiff to their strict proof thereof. 17. Defendant denies the allegations in paragraph 17 of the Complaint as it contains legal conclusions and characterizations to which no response is required; to the extent a response is required, Defendant denies. 18. Defendant denies the allegations in paragraph 18 of the Complaint as Defendant is without sufficient information to admit or deny and therefore denies the same and puts Plaintiff to their strict proof thereof. 19. Defendant denies the allegations in paragraph 19 of the Complaint as it contains legal conclusions and characterizations to which no response is required; to the extent a response is required, Defendant denies. 20. Defendant denies the allegations in paragraph 20 of the Complaint as Defendant is without sufficient information to admit or deny and therefore denies the same and puts Plaintiff to their strict proof thereof. 21. Defendant denies the allegations in paragraph 21 of the Complaint as it contains legal conclusions and characterizations to which no response is required; to the extent a response is required, Defendant denies. 22. Defendant denies the allegations in paragraph 22 of the Complaint as Defendant is without sufficient information to admit or deny and therefore denies the same and puts Plaintiff to their strict proof thereof. 23. Defendant denies the allegations in paragraph 23 of the Complaint as it contains legal conclusions and characterizations to which no response is required; to the extent a response is required, Defendant denies. 24. Defendant denies the allegations in paragraph 24 of the Complaint as Defendant is without sufficient information to admit or deny and therefore denies the same and puts Plaintiff to their strict proof thereof. 25. Defendant denies the allegations in paragraph 25 of the Complaint as it contains legal conclusions and characterizations to which no response is required; to the extent a response is required, Defendant denies. 26. Defendant denies the allegations in paragraph 26 of the Complaint as Defendant is without sufficient information to admit or deny and therefore denies the same and puts Plaintiff to their strict proof thereof. 27. Defendant denies the allegations in paragraph 27 of the Complaint as it contains legal conclusions and characterizations to which no response is required; to the extent a response is required, Defendant denies. 28. Defendant denies the allegations in paragraph 28 of the Complaint as Defendant is without sufficient information to admit or deny and therefore denies the same and puts Plaintiff to their strict proof thereof. 29. Defendant denies the allegations in paragraph 29 of the Complaint as it contains legal conclusions and characterizations to which no response is required; to the extent a response is required, Defendant denies. 30. Defendant denies the allegations in paragraph 30 of the Complaint as Defendant is without sufficient information to admit or deny and therefore denies the same and puts Plaintiff to their strict proof thereof. 31. Defendant denies the allegations in paragraph 31 of the Complaint as it contains legal conclusions and characterizations to which no response is required; to the extent a response is required, Defendant denies. 32. Defendant denies the allegations in paragraph 32 of the Complaint as Defendant is without sufficient information to admit or deny and therefore denies the same and puts Plaintiff to their strict proof thereof. DEFENSES 1. Insufficiency of Service of Process: The Defendant asserts that the service of process was not in compliance with the jurisdiction's rules governing service, thereby failing to confer proper notice. 2. Failure to State a Claim: The complaint fails to allege facts sufficient to constitute a cause of action against the Defendant. 3. Lack of Personal Jurisdiction: The court lacks personal jurisdiction over the Defendant as the Defendant does not have sufficient minimum contacts with the forum. 4. Statute of Limitations: The claim or claims are barred in whole or in part because they were not filed within the time period required by law. 5. Self-Defense: The Defendant asserts that any actions taken were in self-defense, defense of others, or defense of property. 6. Insufficient Evidence: The evidence presented is insufficient to support the charges against the Defendant. 7. Constitutional Violation: The Defendant's constitutional rights have been violated, including but not limited to the Fourth, Fifth, Sixth, and Fourteenth Amendments. 8. Mistake of Fact: The Defendant asserts that any actions taken were based on a mistake of fact, negating any requisite criminal intent. 9. Improper Venue: The venue of the action is not proper as the alleged events did not occur within the jurisdiction of the court. 10. Double Jeopardy: The Defendant has been previously tried for the same offense, and thus the current action is barred by the principle of double jeopardy. AFFIRMATIVE DEFENSES 1. Alibi: The Defendant was not present at the time and place of the alleged crime and therefore could not have committed the alleged offense. 2. Duress: The Defendant asserts that any actions taken were the result of coercion or threats of immediate harm to the Defendant or others. 3. Entrapment: The Defendant was induced to commit the alleged offense by law enforcement officers or their agents who originated the idea of the act and encouraged its commission. 4. Insanity: At the time of the alleged offense, the Defendant was suffering from a mental disease or defect that rendered them incapable of understanding the wrongfulness of their actions. 5. Intoxication: The Defendant asserts that any actions taken were the result of involuntary intoxication, negating any requisite criminal intent. 6. Necessity: The Defendant's actions were taken out of necessity to prevent a greater harm. 7. Infancy: The Defendant asserts that at the time of the alleged offense, they were under the age of majority and therefore not criminally responsible for their actions. 8. Withdrawal: If the Defendant was a participant in a crime, they effectively withdrew from the criminal activity prior to the commission of the offense. 9. Justification: The Defendant's actions were justified under the circumstances as they were taken to avoid an imminent and greater harm. 10. Ineffective Assistance of Counsel: The Defendant's previous counsel failed to provide effective legal representation, which prejudiced the Defendant's position and warrants relief. REQUESTED RELIEF WHEREFORE, Defendant Heather Rouse, by and through her undersigned counsel, respectfully requests that this Court: a. Enter judgment in favor of Defendant Heather Rouse on all claims asserted against her; b. Issue a judicial determination of the rights, duties, and obligations of the parties, declaring such rights, duties, and obligations in favor of Defendant Heather Rouse; c. Award Defendant Heather Rouse economic, non-economic, actual, statutory, emotional, general, and punitive damages in an amount to be determined at trial, which should be at least in excess of the jurisdictional minimum of this Court; d. Grant Defendant Heather Rouse attorney's fees, including any appropriate multiplier, along with the costs and expenses of litigation; e. Dismiss the Complaint with prejudice and deny Plaintiff any relief requested therein; f. Award Defendant Heather Rouse such other and further relief as the Court deems just and equitable under the circumstances. JURY TRIAL DEMANDED Defendant Heather Rouse hereby demands a trial by jury on all issues so triable. Respectfully submitted, /s/ [Your Name] [Your Name] Attorney for Defendant Heather Rouse [Bar Number] [Your Firm's Name] [Your Firm's Address] [Your Firm's Phone Number] [Your Firm's Email Address] Dated: [Insert Date] CERTIFICATE OF SERVICE The undersigned hereby certifies that a copy of the foregoing was served upon the following parties via electronic mail (email) on this 30th day of March 2024, pursuant to Civ.R. 5(B)(2)(f): Paul Leonard Tiffin District Attorney Safety Building, Room 423 Milwaukee, WI 53233 Attorney for Plaintiff Kerri Terann Cleghorn 1916 Hess Drive Holiday, FL 34691 Attorney for Defendant /s/ [Your Name] [Your Name] ([Your Bar Number])
