THE STATE OF RIDGEWAY
RIDGEWAY SUPERIOR COURT
THR33SIX8
Plaintiff,
-against-
DOMINODOWNLOAD, in his official capacity as a
corporal of the Ridgeway State Police
pursuant to The Torts And Civil Procedure
Act of 2026 § 205(d)(ⅱ)/7 R. Stat. §
121.404; NISICULT, in his official capacity as a
police officer of the Milton City Police
Department pursuant to The Torts And Civil
Procedure Act of 2026 § 205(d)(ⅱ)/7 R. Stat.
§ 121.404; the RIDGEWAY STATE POLICE; and
the MILTON CITY POLICE DEPARTMENT.
Defendants.
RSC-CV-6949
MOTION TO DEFEAT OPPOSING
SUMMARY JUDGEMENT
Presiding Judge: Hon. EffortlessBrit
thr33six8, proceeding without counsel hereby moves to defeat the defendants' motion for
summary judgement on the grounds that (1) the defendants are not entitled to judgment as a
matter of law and (2) there is a geniune issue of material fact; it is therefore an improper
motion for summary judgment that this court has to deny.
LEGAL STANDARDS
The defendants may move for summary judgment on some or all claims. Rid R. Civ. Pro.
38(b). The defendants say that "an application of the statutory requirements for lethal force,
which we need not discuss here, would clearly demonstrate that the plaintiff was posing an
immediate threat to life by fleeing apprehension while in possession of an assault-style weapon
capable of severe bodily injury to others", which is entitlement to judgment as a matter of law.
Rulings on federal procedure persuade this court to accept this motion to defeat the opposing
motion for summary judgment if I can show that the defendants are not entitled to judgment as a
matter of law, and I have to do more than use weak evidence. See generally AM General LLC v.
Activision Blizzard, Inc., 1:17-cv-08644 (S.D.N.Y. Mar 31, 2020) ECF No. 218. That is the
approach I will take. I will use strong evidence as well as bring up a geniune issue of material
fact
1. Application of 6 R. Stat. § 122.201 et seq. do not give the defendants entitlement to
judgment as a matter of law because said statutes are only applicable as affirmative
defenses to crimes; there is no entitlement as a judgment of law here.
Since the defendants implicitly invoke the principle of iura novit curia by not citing the
"statuatory requirements", I had to do the digging instead of a licensed attorney who could've
cited it faster than I can. After doing the digging, I found out that the claim of "an application of
statuatory requirements" is unfounded.
In the statuatory law of the State of Ridgeway, use of force is justifiable under some
circumstances. However, "justification" is an affirmative defense for crimes. See 6 R. Stat. §
122.001. Justification does not "abolish or impair any remedy for such conduct which is
available in any civil action". Id. at § 122.002. Since motions for summary judgment render
relief, a summary judgment is relief; therefore, this statute cannot be grounds for the
renderance of summary judgment in a civil action because 6 R. Stat. § 122.002 renders Id.
at. § 122.001 et seq. as inapplicable for affecting civil remedies.
2. There is a geniune issue of material fact because the nonmoving party's evidence
corroborates Compl. ¶ 19, which is a material fact (namely, Dominodownload
killing me) that the defendants deny in their answer.
As said before, I need to raise a geniune issue of fact to defeat the opposing motion for
summary judgment. (Keep in mind that the defendants have only said that "there is no genuine
dispute as to the material facts stipulated by the plaintiff, though the government denies their
characterization of them.") "An issue of fact is geniune if the evidence is such that a reasonable
jury could return a verdict for the nonmoving party". 1:17-cv-08644 (S.D.N.Y. Mar 31, 2020)
ECF No. 218 (quoting Gayle v. Gonyea, 313 F.3d 677, 682 (2d Cir. 2002)).
Well, what does the evidence show? My evidence in my premature disclosures corrobates
facts. All the material ones too. My 2nd material exhibit corroborates Compl. ¶ 3, which is a
material fact because it is the only instance of me using deadly force in the complaint. My 3rd
matreial exhibit corroborates Compl. ¶ 19, which is a material fact as it is the fact where
Dominodownload killed me, and it corroborates Compl. ¶ 20, which is a material fact as it is the
fact where nisicult shot at me. So, evidence shows that I did not use my firearm for at least 2
minutes.
Since I did not use my firearm or hurt anyone for 2 minutes, how could Dominodownload
and nisicult gain the probable cause to form the belief that I was a lethal threat? When the
defendants saw me, I was not attacking anyone or running anyone over. I was simply just signing
to masterqv, and we were engaged in a conversation. The defendants, instead, spooked me, so I
began driving away. And as we all know in Ridgeway, you cannot drive and use any tool. How
does fleeing constitute lethal force here? Was I running over an invisible duck?
Comparing this with the defendants' responses to the complaint's pleadings, they denied
that Dominodownload killed me, which was a fact at Compl. ¶ 19. This is a material fact because
it is important in determing whether or not Dominodownload committed a tortious act. Since it is
a material fact that is denied by the defendants, and evidence corroborates the material fact, there
is, indeed, a geniune issue of material fact; therefore, the defendants' motion for summary
judgment is insufficient because the nonmoving party's evidence has proven that there is an
issue of material fact, which is whether or not Defendant Dominodownload killed the
Plaintiff at Compl. ¶ 19.
CONCLUSION
For the forgoing reasons, this court cannot grant the defendants' motion for summary
judgment because (1) there is a geniune issue of material facts, and (2) the defendants are not
entitled to judgment as a matter of law.
RELIEF SOUGHT
As the relief sought for this motion, the plaintiff requests that:
1. this court deny the defendants' motion for summary judgment on all claims stated
in the complaint.
DATED: 2026-07-04T23:55:00Z
Respectfully submitted,
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thr33six8
Plaintiff
/s thr33six8
