THE STATE OF RIDGEWAY
RIDGEWAY SUPERIOR COURT
thr33six8,
Plaintiff
-against-
CyerMazikeen, Valktyz, Huxdownload
Defendants.
RSC-CV–4515
CIVIL COMPLAINT
Presiding Judge: bommes
I, thr33six8, tentatively proceeding without counsel, hereby bring this motion to quash
the motion to dismiss sent by the defense.
FACTUAL ARGUMENTS
1. The defense wrote in their motion to dismiss, "Defendants spotted Plaintiff’s black
Cavela near the firearms dealer right as he was in the process of purchasing firearms and
placing them in the trunk of his vehicle. When Plaintiff spotted Defendants on his way
out from the firearms dealer, he equipped a firearm and fired multiple shots wounding
Valkytz."
2. I was not purchasing firearms, nor was I putting firearms in the trunk of my vehicle.
3. The defense wrote in their motion to dismiss, "While handcuffed in the back of
Defendants’ vehicle, Valktyz performed a search of Plaintiff’s vehicle and seized illegal
ammunition and firearms which Thr33six8 had previously purchased from the illegal
firearms dealer."
4. There was only a box of .45, a police-issued box of 9mm, and a police-issued box of
5.56, as is in the complaint. The only item in the trunk that could be seen as a recent
purchase from the illegal dealer is the box of .45, but that was not from the illegal dealer.
There were no firearms in the trunk of my car. Police-issued boxes of ammo cannot be
bought at the illegal dealer.
5. The defense wrote in their motion to dismiss, "Plaintiff was trespassing, purchasing
illegal contraband, and was caught red-handed by Defendants."
6. To reiterate, I was not "purchasing illegal contraband."
7. The Sterling Port is private property. Thus, being in it is forbidden, as shown by signs
posted near its two thoroughfares, which are at the car dealership and the RCSO sub
station.
8. This could bring light to a possibility of a misdemeanor being committed whenever a
police officer enters the port, but that is to be heard in another case.
9. The defense wrote in a footnote that "law enforcement rou[t]inely patrol [the Sterling
Heights Port] to ensure individuals are not illegally purchasing weapons from the
firearms dealer."
10. The noun "patrol" is defined by Merriam-Webster as "the action of traversing a district or
beat or of going the rounds along a chain of guards for observation or the maintenance of
security" at sense 1, subsense a.
11. The adverb "routinely" is defined by the same dictionary as "as a matter of regular
occurrence," but it is no secret that routine implies a pattern.
12. Were police officers within Ridgeway routinely patrolling the port, law enforcement
agencies would have a schedule and/or procedure regarding being and movement in the
port, and paths that police officers are to go down to patrol the port would be established.
13. Police officers do go to the port, although their purpose to do so is to catch criminals that
are at the illegal dealer and just that, not to patrol the port since there are other, more
important crimes that police officers must attend that are outside of the port.
14. In other words, police officers do not routinely patrol the port. Rather, they solely check
to see if criminals are at the illegal dealer by looking for cars near the area of cargo that
the illegal dealer is at.
15. The defendants were stealthily observing the group of cargo that the illegal dealer is at.
They, by slowly driving, sometimes pausing for long periods of time whenever behind
cover, in their undercover, green Actila at gear 5, which makes noise of its engine have a
very low pitch, were driving to and from cover, taking paths that were decided on the fly.
The low pitch of the engine is masked by the background noise so that it may not be
heard. Were a criminal to go into the port through the thoroughfare by the car dealership,
then park the car by the illegal dealer, the defendants would drive at a low speed while at
gear 5 to the criminal's vehicle to catch the criminal by surprise.
16. This is not patrolling the port, as the paths taken were decided on the fly and the purpose
of being there was not to provide security, and there were long pauses in between
movements. It is better to say that the defendants were waylaying, which is defined by
Merriam-Webster as "to lie in wait for or attack (someone) from ambush." Their intent to
waylay any criminal that goes into the port is further proven by the hidden looks and
behavior of the defendants, which is maverick when compared to how regular police
officers perform their duties.
17. The defendants, in an undercover, green Actila at max gear to mask its engine's noise
during movement at nighttime, were waylaying for any criminal who may go into the
port to go to the illegal dealer. I must stress that they were not patrolling and could not be
patrolling based on their behavior. Were they patrolling the port, they would be regular
sheriff deputies in a marked car, obviously driving on the port's roads.
18. Additionally, their keenness on going without firearms first without warning shows that
the defendants were there to catch criminals, not to provide security to the port. Truly
securing the port would involve immediately taking action against whoever would go into
the port.
19. This is further proven by the fact that the defendants:
a. did not check to see if the Cavela at the scene was mine,
b. searched my person while booking instead of at the scene, the former saving time
spent in the port to leave as soon as possible,
c. and did not check to see if I had a RFLID, which would scathe their probable
cause of the box of .45 being bought from the illegal dealer.
20. Thus, the defendants were waylaying for potential customers of the illegal dealer so they
could quickly arrest them by surprise, not patrolling the area to provide security and to
arrest trespassers.
21. A good example of how waylaying is done in the port is how Deputy goodbugggatti of
the Ridgeway County Sheriff's Office has done it. A combat-seasoned, intelligent deputy,
one time he pretended to check the illegal dealer as I was hiding there, then came back to
attempt to arrest me. He died, but he cleverly informed other police officers of what had
happened, which led to him being able to shoot me after a short pursuit. It's important to
stress that he was not patrolling the port on that day but rather waylaying for criminals,
doing so impressively and excellently. Had he been patrolling the port, he would drive on
the port's roads like every deputy would. Patrolling is for security, meanwhile waylaying
is for catching criminals by surprise.
22. The defense wrote, "Now Plaintiff brings this harassing and frivolous lawsuit against
Defendants seeking damages and injunctive relief."
23. The writing leading up to that sentence is supposed to show the reader how my lawsuit is
frivolous on first sight, as that sentence is in the defense's factual background of the
motion to dismiss. The absence of legal arguments shows the reader that even a layman
could know that the lawsuit is frivolous.
24. Upon reading the sentence, the reader may think that the juxtaposition between the
so-called routine, everyday behaviors of the defendants and my obviously criminal
actions leading up to the lawsuit misleads the reader into thinking of me as Darrell
Brooks, who was a determined pro se defendant best known for his improper behavior in
his criminal case that accused him of being responsible behind a vehicular attack on
Waukesha's Christmas Parade in 2021.
25. It could be said that the defense was warping the facts to mislead readers into thinking in
their biased lens, but that idea is not for me to answer, for I am not in a position to
assume such a humongous presumption of the defense's legal strategy.
26. To conclude, the factual background of the motion to dismiss paints my statement of facts
in a way to show an exaggerated, somewhat misleading sense of frivolosity/frivolousness
arising from the writing of the factual background. This slightly weakens the legal stance
that the defense presents.
LEGAL ARGUMENTS
THERE IS…NO STANDING FOR THE INJUNCTION
1. I will start from a rule-based standpoint. This means that case law will be disregarded
until I transition into analogous standpoints, which rely on case law.
2. Concerning my injunction as relief for 1 R. Stat. § 3201, the tort of violation of rights, the
defense wrote, "Plaintiff’s Complaint suffers from two fatal deficiencies: (1) he has not
alleged a real and immediate threat of future irreparable harm; and (2) even if he had, the
injunction sought would serve to punish Defendants rather than to “redress[]” the
anticipated injury," citing Murthy v. Missouri, 603 U.S. ___ (2024).
3. The statute can give relief "for redress."
4. Redress is defined by Merriam-Webster as "compensation for wrong or loss" at sense 2. It
also defines "to redress" as "to set right," "to make up for," "to remove the cause of (a
grievance or complaint)," and "to exact reparation for." It also lists archaic senses of the
verb, one being "to requite (a person) for a wrong or loss" and the other being "to heal."
5. The constitution of the State of Ridgeway does not have rules regarding injunctions, nor
does the U.S. constitution, if I am right.
6. The cited statute grants relief to "the party injured in an action at law, suit in equity, or
other proper proceeding for redress," making an exception to injunctive relief arising
from specific instances involving judicial officers. This means that there are no rules
regarding what can be granted out of this statute.
7. Therefore, this means that it is up to the judge to decide if an injunction should be
granted, and this means that it is up to the judge to decide the relief.
8. I will now look from an analogous standpoint.
9. The defense cites O'Shea v. Littleton, 414 U.S. 488 (1974), which holds that equitable
relief, involving injunctions, should be judged by "the likelihood of substantial and
immediate irreparable injury, and the inadequacy of remedies at law -- in view of the
conjectural nature of the threatened injury to which respondents are allegedly subjected,
and where there are available other procedures, both state and federal, which could
provide relief."
10. To establish the inadequacy of the monetary relief, I believe the monetary relief that I
request would not be enough to redress the behavior by the defendants in my complaint's
statement of facts as monetary relief would basically be seen as the defendants as a slap
on the wrist, for they would not be punished in their departments nor face trouble with
their LETC certifications had I won this civil case.
11. The possible injuries arising from the injunction not being granted could be one of the
following scenarios:
a. Since Ridgeway has historically had many periods where the
government—including police officers—has acted out of selfish or dishonest
desires, there is a risk that I may face extra, wanton scrutiny from the defendants
during confrontations with them. For clarification, the aforementioned periods of
selfish/dishonest desires are but not solely the following. A dagger (†) indicates
this was in Squareheaddude's State of Ridgeway.
i. State of Ridgeway v. mandatorymorale†
ii. Matrix_oc v. Techiey†
iii. S5-26, Enemy of The State Act†; see generally thr33six8 v. daviddevvil2
et. al., RSC-CV-2091.†
iv. The Ridgeway-Vancouver War of 2023†
b. Upon the dismissal of the civil case, police officers would conduct searches like
the one in question more frequently since the basic green light given by the
dismissal indirectly gives a feeling of arrogance among officers masked as a
feeling of legal safety. E.g. thr33six8 v. o72yss, RSC-CV-3384† (where the
defendant taunted me after my loss, then faced contempt).
12. A fear of the possible scenario in paragraph 11b can extend to the fact that it may lead
officers to be reckless, but that is not at all logical. For that fear, the defense has a point
when they wrote about the fact that the injunction in the complaint does not meet the
prongs of equitable relief. However, I do not believe that is the case, and I wish that the
injunction will be granted, hoping the court will make their own interpretations of the law
in my favor, but at the end of the day, there is no standing in my understanding of the law.
13. Therefore, the injunction by itself does not have standing as the prongs are not met, and
dismissal of the tort is foreseeable. Although, I still believe that monetary relief is not
enough to redress my injuries.
MY SECTION 3201 CLAIM AGAINST CYERMAZIKEEN IS…IMPROPERLY PLED
1. The defense wrote, "Plaintiff’s Complaint sues Defendant CyerMazikeen under 1 R. Stat.
§ 3201 for '$1,000.00 in punitive damages.' Pl’s. Comp. at 1.a. But Section 3201 only
authorizes suits for '[injunctive] order[s] against the government.' Id."
2. Applying the well-known Twiqbal standard, the tort is improperly pled as the relief
requested can not be given according to the statute. On its face, it is improperly pled.
3. Given the chance to rewrite the relief to fit this order, I would. However, I have already
written in my complaint how the statute applies to Defendant CyerMazikeen due to how
authority works within the Ridgeway County Sheriff's Office, so the defense's claim of
the tort's relief not meeting the Twiqbal standard is correct. It is up to the judge to decide
how the tort is handled.
4. Therefore, the tort is improperly pled by itself, but I wish that the court act sua sponte on
their decision regarding the tort. However, this tort's merit would be significantly
improved if the court finds that the search was illegal.
MY SECTION 3114 CLAIM (OFFICIAL MISCONDUCT) IS NOT BARRED BY
QUALIFIED IMMUNITY
1. The defense wrote, "Courts resolving questions of qualified immunity are required to
resolve a “threshold question: Taken in the light most favorable to the party asserting the
injury, do the facts alleged show the officer’s conduct violated a constitutional right? This
must be the initial inquiry," citing Saucier v. Katz, 533 U.S. 194, 201 (2001).
2. I would like to bring attention that the facts alleged in light most favorable to the party
asserting the injury are the main issue in determining cases of qualified immunity.
3. The alleged facts, including the factual arguments I have made in this motion to quash,
show that the defendants were looking to only arrest criminals who go into the port to
buy illegal firearms. Comparing the defense's motion to dismiss and my alleged facts not
just limited to those in the statement of facts, the defense, the search was, by itself,
unreasonable as it was on the fly. Thus, it was not based on a search warrant. And
therefore, it should be automatically seen as unreasonable before judging the search takes
place. See Katz v. United States, 389 U.S. 347 (1967); Agnello v. United States, 269 U.S.
20 (1925).
4. Viewing the search as unreasonable per Katz v. United States, 389 U.S. 347 (1967)
(warrantless searches are "subject only to a few specifically established and well
delineated exceptions"), it must now be proven how the search was reasonable, and I will
disprove the reasonability.
5. In Arizona v. Gant, 556 U.S. 332 (2009), the Supreme Court held their rejection of a
broad reading of New York v. Belton, 453 U.S. 454 (1981) that "would permit a vehicle
search incident to a recent occupant’s arrest even if there were no possibility the arrestee
could gain access to the vehicle at the time of the search."
6. The Supreme Court also held their unpersuasion of the petitioner's/Arizona's
aforementioned reading of Belton that "balances law enforcement interests with an
arrestee’s limited privacy interest in his vehicle. The State seriously undervalues the
privacy interests at stake, and it exaggerates both the clarity provided by a broad reading
of Belton and its importance to law enforcement interests. A narrow reading of Belton
and Thornton, together with this Court’s other Fourth Amendment decisions (citations
omitted), permit an officer to search a vehicle when safety or evidentiary concerns
demand."
7. It is important to note that in Gant, the Supreme Court held that "police may search the
passenger compartment of a vehicle incident to a recent occupant’s arrest only if it is
reasonable to believe that the arrestee might access the vehicle at the time of the search or
that the vehicle contains evidence of the offense of arrest."
8. At "passenger compartment," that would invalidate a lot of occurrences when law
enforcement searched the trunk of a car. However, that is de minimis.
9. As I believe the defendants did not see that I was an occupant of the Cavela at the scene
and made no attempts to verify any belief of the Cavela being mine then, that would
make the search unreasonable as Gant applies to arrestees who are recent occupants of a
vehicle.
10. Had the defendants seen that I was an occupant of the Cavela, they would and could only
have probable cause of the following crimes upon seeing me when pulling up to where I
was while moving towards the Cavela:
a. the misdemeanor of trespassing by being in the port,
b. the misdemeanor of unlawful possession of a firearm by having a Solami in plain
sight,
c. the misdemeanor of brandishing by having the Solami unholstered, pointing in the
defendant's general direction,
d. and the felony of aggravated assault class Ⅱ by appearing to be ready to attack
the Actila that was pulling up.
11. Absolutely none of these crimes are directly related to buying firearms and ammo
illegally through the illegal dealer. Were the search compliant with Gant, it would be
based on probable cause that I had just bought the Solami or other illegal items from the
illegal dealer.
12. After the search, I was only arrested for unlawful possession of a firearm and attempted
murder, not for trespassing. To perform a Gant-compliant search on the Cavela with
probable cause of those crimes, the defendants would search my vehicle to find more
evidence that one or all of those crimes is being committed, has been committed, or will
be committed.
13. However, the defense wrote, "Plaintiff’s vehicle was searched after Defendants caught
Plaintiff red-handed fleeing an illegal firearms transaction and after Plaintiff opened fire
when Defendants approached his vehicle." Again, the defense did not (at the scene's time)
and could not have probable cause that I bought a firearm from the illegal dealer. At best,
they had reasonable suspicion by the fact that I was near the illegal dealer.
14. Thus, the idea that the search is reasonable on the probable cause of the incorrect fact that
I was buying firearms is invalid.
15. As that incorrect fact was the reason that the defendants approached me, that means the
search was invalid as it was based on faulty probable cause and a then-unproven
connection between me and the Cavela, but the latter is de minimis.
16. Citing Katz, The defense also wrote, "the next, sequential step is to ask whether the right
was clearly established * * * in light of the specific context of the case."
17. When I was arrested at the port, I quickly questioned the search of the Cavela and the
seizure of three items that were in it. By itself, a question of the constitutionality of the
search had been established since I asked that.
18. Since that has been established, it meets the two prongs that the defense wrote about
Katz—(1) the alleged facts show a rights violation (although per the principle of iura
novit curia, the judge may determine which right(s) was/were violated, but it is best to
say that it was the 4th amendment), and (2) the question of the search's legality was
immediately established by my aforementioned behavior.
19. Therefore, the tort passes Katz, but Pearson v. Callahan, 555 U.S. 223 (2009), the
leading case of qualified immunity, still remains.
20. There, the Supreme Court held that "qualified immunity applies unless the official's
conduct violated such a [clearly established] right (citation omitted)."
21. Again, the legality of the search was immediately brought to light by my protests.
Therefore, it passes Pearson.
22. Therefore, qualified immunity does not protect the defendants from the tort of Official
Misconduct.
CONCLUSION
1. For the forgoing writing, I request this motion to quash the motion to dismiss be granted.
DATED: July 4th, 2025
Respectfully submitted,
——―――――――――――――
thr33six8
Plaintiff
/s/ thr33six8
