IN THE SUPERIOR COURT OF THE STATE OF RIDGEWAY
FOR THE COUNTY OF RIDGEWAY
CIVIL COMPLAINT
Plaintiff BattalionGavin, by and through undersigned counsel, hereby brings this
civil action against Defendants Ridgeway Times Inc. and JuliaRWilson, and alleges as
follows:
PARTIES
1. Plaintiff BattalionGavin is a resident of the State of Ridgeway and a Patrol
Officer within the City of Palmer Police Department.
2. Defendant Ridgeway Times is a registered media business within the State of
Ridgeway and a major news outlet.
3. Defendant JuliaRWilson is a resident of the State of Ridgeway and the current
Editor-in-Chief at the Ridgeway Times.
JURISDICTION & VENUE
4. This court assumes original jurisdiction over all criminal and civil actions
pursuant to Article V, § IV of the Ridgeway Constitution.
5. Venue is proper because the events giving rise to this action occurred within
Ridgeway County and the State of Ridgeway Discord server, where the actions of
persons communicating are subject to the laws of the state.
STATEMENT OF FACTS
6. On or about July 19th, 2025, Defendant JuliaRWilson, acting within her role as
Editor-in-Chief at the Ridgeway Times, published numerous news articles within
the Ridgeway Times and State of Ridgeway Discord servers directly mentioning the
plaintiff.
7. The news articles contained direct allegations of racism and misconduct against
Mr. BattalionGavin, citing “reports” of “instances of unprofessional conduct.”
8. The defendants did not substantiate their claims of racism or misconduct with
any video or photographic evidence, or confirmed testimony from any individuals
who have experienced the alleged misconduct.
9. Plaintiff is currently in good standing within the Palmer Police Department,
having recently been promoted from Recruit Officer to Patrol Officer after
successfully completing his probation, and has since been assigned as a Secondary
Operator within the Tactical Response unit.
10. Plaintiff does not possess any disciplinary actions made against him at the
Palmer Police Department, and has not been investigated at any point by the
Internal Affairs office for misconduct.
11. Plaintiff, knowing that his own record is completely spotless, issued a cease and
desist letter later that evening to Defendant JuliaRWilson, requesting that the
articles be removed due to their defamatory nature.
12. As of the filing of this civil action, the articles and their contents remain publicly
available within the Ridgeway Times and State of Ridgeway Discord servers,
exposing Plaintiff to unwarranted reputational harm.
COUNT 1
Misappropriation of Name or Likeness (R. (2nd) Torts § 652(c))
13. Plaintiff reincorporates and re-alleges the preceding paragraphs.
14. The Restatement of Torts identifies the appropriation of name or likeness as a
civil cause of action where “one who appropriates to his own use or benefit the name
or likeness of another is subject to liability to the other for invasion of his privacy.”
15. Defendants obtained several videos of Plaintiff’s name and likeness, including an
altercation between Plaintiff and a suspect during the course of his duties.
16. The videos were attached to supplement Defendant’s allegations against Plaintiff
in order to paint the Plaintiff as reckless and unfit for the role of a Patrol Officer.
17. The videos do not support the Defendants’ allegations in any meaningful way.
18. Defendants clearly benefit from publishing news articles against Plaintiff to
incentivize viewership and growth of their audience.
19. Defendants acted with reckless disregard for the truth, having received and
analyzed the videos through tips and media sources, and utilized them to push their
damaging narrative anyways.
COUNT 2
Publicity Placing Person in False Light (R. (2nd) Torts § 652(e))
20. Plaintiff reincorporates and re-alleges the preceding paragraphs.
21. The Restatement of Torts identifies publicity placing a person in false light as a
civil cause of action where “one who gives who gives publicity to a matter concerning
another that places the other before the public in a false light is subject to liability to
the other for invasion of his privacy, if the false light in which the other was placed
would be highly offensive to a reasonable person, and the actor had knowledge of or
acted in reckless disregard as to the falsity of the publicized matter and the false
light in which the other would be placed.”
22. Defendants publicized Plaintiff’s interaction with criminal suspects while on-duty
in his role as a Patrol Officer.
23. Defendants did so through the posting of a news article containing several videos
of Plaintiff exercising his powers as a law enforcement officer within his jurisdiction
in an attempt to further their false narrative.
24. As a certified individual within the Law Enforcement Training Center and a
police officer, depictions of Plaintiff engaging in misconduct and racist behavior is
highly offensive to the views and beliefs of the plaintiff.
25. Defendants acted with reckless disregard for the truth, having received and
analyzed the videos through tips and media sources, and utilized them to push their
damaging narrative anyways.
PRAYER FOR RELIEF
Plaintiff BattalionGavin respectfully requests this Court to issue the following relief:
a. Punitive damages in the amount of $10,000 for each cause of action, totaling the
sum of $20,000;
b. Compensatory damages in an amount of $250 for the emotional turmoil experienced
in relation to the defendants’ tortious conduct;
c. Declaratory relief that the defendants acted with reckless disregard for the truth;
d. Injunctive relief compelling the defendants to issue a public apology for their
actions, to be posted within the same place defendants published their articles in
question;
e. Injunctive relief compelling the defendants to never again make or cause to be made
untruthful statements about the plaintiff;
f. Legal costs incurred by bringing this action, and;
g. Such other relief that the Court deems just and proper.
23rd July 2025 Respectfully submitted,
vloqsouls
Ridgeway Bar No. 11109
Nicklaus & Feelings LLP.
Counsel for Plaintiff
