IN THE SUPERIOR COURT OF RIDGEWAY
FOR THE STATE OF RIDGEWAY
HALO4ASIN,
Plaintiff,
v.
RIDGEWAY PARKS SERVICE,
Defendant.
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Case No. RSC-CV-0750
STATEMENT OF UNDISPUTED
MATERIAL FACTS
PLAINTIFF’S STATEMENT OF UNDISPUTED MATERIAL FACTS IN SUPPORT OF
HIS MOTION FOR SUMMARY JUDGMENT
Plaintiff submits the following statement of material facts as to which there is no genuine
dispute. Citations are to the exhibits of record (Exhibits A-F), the Defendant’s Answer, and the
Court’s Ruling of July 11, 2026.
1. Plaintiff applied to the Defendant for appointment as a full-time Park Ranger in Ranger
Class 22, and is Entry No. 26 on the Defendant’s Application Tracker. (Ex. A; Answer ¶¶
11-13, admitted.)
2. Plaintiff passed the Primary Screening and Application stages; his Final Screening result
is “Failed” and his Outcome is “Failed.” Final Screening includes the
background-investigation review under 4 R. Stat. § 122.401 et seq. (Ex. A; Answer ¶¶
13-14, admitted.)
3. The Defendant’s Application Tracker publicly displayed Plaintiff’s Final Screening and
Outcome as “Failed.” (Ex. A; Ruling § II.)
4. The Application Tracker contained no statement of the reasoning for Plaintiff’s negative
Final Screening result. (Ex. A.)
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5. On June 25, 2026, at approximately 1:12 AM, the Superintendent of the Parks Service
stated the basis for the denial: “So, at the time of reviewing your BGC, it was found that
you had an activity strike within RCFD.” (Ex. D; Answer ¶¶ 1, 15, admitted in
substance.)
6. That statement followed Plaintiff’s inquiries of June 23-25, 2026, including a June 24
message that went unanswered and a June 25 request for clarification. (Ex. D.)
7. Both parties agree that on June 25, 2026, the Superintendent made Plaintiff aware of the
basis for denial. (Ruling § I.)
8. The Ridgeway County Fire Department (“RCFD”) issued Plaintiff two activity warnings:
the first on June 8, 2026 (cycle of June 1-7), and the second on June 15, 2026 (cycle of
June 8-14). (Answer ¶ 16, admitted; Ex. C.)
9. Plaintiff appealed the first warning on June 15, 2026 (Ticket 72); on June 16, 2026,
RCFD’s Deputy Chief identified it as “just a clerical issue” attributable to the logging
bot, and the appeal was processed and the ticket resolved that day. (Ex. F.)
10. RCFD’s Fire Chief acknowledged on or about June 16, 2026 that the first warning
resulted from a clerical logging error, and the warning was formally removed from
Plaintiff’s discipline record on or about June 30, 2026. (Answer ¶ 18, admitted; Exs. E,
F.)
11. Plaintiff appealed the second warning by completing double the required activity in the
cycle of June 15-21, 2026, under RCFD Handbook Policy 605-3, and the warning is
marked appealed on RCFD’s roster. (Exs. C, E.)
12. On June 29, 2026, RCFD’s General Counsel affirmed in his official capacity that both
warnings are appealed and inactive under Policy 605-3 and that no adverse action
currently stands against Plaintiff in relation to his period of employment with RCFD. (Ex.
E; Answer ¶ 19, admitting RCFD’s description.)
13. RCFD lists Plaintiff’s discipline record as “Clean Record.” (Ex. C.)
14. On June 25, 2026, at approximately 1:24 AM, Plaintiff communicated to the
Superintendent, with documentation, that both warnings were appealed, and requested
that the denial be reversed or held pending the appeal’s resolution. (Ex. D.)
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15. The “appealed” notations appeared on RCFD’s roster before the Defendant’s Ranger
Class 22 results were published. (Exs. C, E, F.)
16. The Defendant published its Ranger Class 22 results, excluding Plaintiff, on June 29,
2026. (Answer ¶ 18.)
17. The sole basis the Defendant’s Superintendent stated for the denial was the activity strike
within RCFD. (Ex. D; Answer ¶ 1.)
Respectfully Submitted,
_________________________
/s/ Halo4asin
HALO4ASIN
Plaintiff, Pro Se
Ridgeway State Bar License No. 18110
Dated: July 11, 2026
CERTIFICATE OF SERVICE
I certify that on July 11, 2026, I served a true copy of the foregoing on counsel for the Defendant
via the Court’s e-filing system and the case channel.
_________________________
/s/ Halo4asin
HALO4ASIN
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