"The allegations in the statement of claim of a purported conspiracy somehow orchestrated by this defendant, involving not only the other personal defendants but also numerous administrative personnel of a correctional facility, and that this defendant was somehow capable of manipulating the operation of such a correctional facility to the extent alleged in the statement of claim, is beyond any rational possibility or air of reality. The allegations in the statement of claim are patently absurd on their face."
"The claim against this defendant knowingly lacks merit, is frivolous and vexatious, is an abuse of the process of this honourable court, and is utterly irresponsible being designed for the collateral and improper purpose of maximizing publicity and notoriety."
"The defendant denies that the purported surreptitious video pled by the plaintiff evidences either directly or indirectly a conspiracy to threaten or cause harm to the plaintiff, and holds the plaintiff to the strict proof thereof."
"To the best of this defendant's knowledge the video depicts snippets of a private social gathering in a private residence and relates to a private, jocular discussion in the supposed privacy of a friend's home where this defendant was discussing and imitating as a joke, the pre-match rant of a professional wrestler."