IN THE SUPERIOR COURT OF RIDGEWAY
FOR THE STATE OF RIDGEWAY
HALO4ASIN,
Plaintiff,
v.
RIDGEWAY PARKS SERVICE,
Defendant.
)
)
)
)
)
)
)
)
)
)
)
)
Case No. RSC-CV-0750
RESPONSE TO DEFENDANT’S
ADDITIONAL DISPUTED FACTS
PLAINTIFF’S RESPONSE TO DEFENDANT’S STATEMENT OF ADDITIONAL
DISPUTED MATERIAL FACTS
Plaintiff responds to Defendant’s Statement of Additional Disputed Material Facts, ¶¶ 18-25. As
used below, “not of record” means the exhibit cited has not been filed with the Court as of the
date of this response, and Plaintiff reserves the right to respond if it is filed.
18. Undisputed that Defendant contends its coordinator conducted a background
investigation on or about June 20, 2026. Immaterial. The duties imposed by 4 R. Stat. §§
122.402 and 122.404 run to “an appointing authority” - the Ridgeway Parks Service - not
to an individual employee. Which employee performed the task does not alter the
agency’s obligations or the criteria it was permitted to apply.
19. Disputed in part; immaterial in whole. Undisputed that Defendant’s coordinator states
he observed one warning marked appealed. Disputed as to the characterization of the
second warning as “active”: under RCFD Handbook Policy 605-3, an activity warning is
appealed upon completion of double the standard activity cycle. The issuing department’s
General Counsel states the measure: “To complete double the activity cycle, an employee
must submit at least 40 minutes of logged activity during that activity cycle.” Ex. E.
Plaintiff submitted a 40 minute log on June 15, 2026 and a 21 minute log on June 19,
2026 - 61 minutes against a 40 minute requirement. The requirement was therefore
satisfied no later than June 19, 2026, before the determination Defendant says is
1
operative. Disputed further as resting on Exhibits G, H, and I, which are not of record.
Immaterial in any event: an activity warning for failure to submit weekly logs is not a
circumstance within § 122.402(f), whether active or appealed.
20. Disputed. Rests on Exhibit J, which is not of record. Undisputed only to this extent:
Defendant’s assertion that § 122.402(f) was the criterion recorded confirms that
subsection (f) is the sole criterion Defendant invoked, and that Defendant did not invoke
§ 122.402(d) or identify any threshold.
21. Disputed. Rests on Exhibits K and L, which are not of record. Contradicted by
Defendant’s Answer ¶¶ 18 and 20, which affirmatively plead that final results were
published on June 29, 2026 and that the Superintendent’s June 25, 2026 communication
satisfied § 122.404; by Defendant’s Partial Motion to Dismiss, which told the Court that
Exhibit D “conclusively establishes” the specification of reasoning on June 25; and by
Plaintiff’s Exhibit A, a capture of the Application Tracker taken June 21, 2026 that
displays “Failed” without a statement of reasoning. A screenshot cannot establish the
contents of an editable spreadsheet on a past date; the Tracker’s revision history, which is
within Defendant’s exclusive control, has not been produced.
22. Disputed in part; immaterial in whole. Plaintiff does not dispute that a request was
made within an internal channel on or about June 21, 2026. Plaintiff disputes that it
constituted a bona fide review of the specific evidentiary basis for his determination: on
June 23-24, 2026, the same Chief Ranger told Plaintiff that the matter was “[o]ut of my
hands,” that his application was “being denied for previous adverse action,” and - when
asked what adverse action - that it was “[n]ot at my will to say, you could talk to Aaron.”
Ex. D. Rests on Exhibits M and N, which are not of record. Immaterial: a secondary
review does not cure reliance on a criterion the statute does not permit.
23. Disputed. See Response to ¶ 19. The double activity requirement of Policy 605-3 was
satisfied no later than June 19, 2026. Plaintiff’s Statement of Undisputed Material Facts ¶
11 identifies the cycle in which the qualifying activity occurred; it does not state that the
requirement was satisfied only at the close of that cycle, and Defendant’s contrary
reading appears nowhere in Policy 605-3 or in the issuing department’s construction of it.
24. Disputed as immaterial. Rests on Exhibit Q, which is not of record. Defendant’s
internal allocation of responsibility among its employees does not bear on the duties 4 R.
Stat. §§ 122.402 and 122.404 impose on the appointing authority.
25. Disputed. Contradicted by Defendant’s Answer ¶ 20, which affirmatively pled that
the Superintendent’s June 25, 2026 communication “satisfied any notice obligation
2
arising under 4 R. Stat. § 122.404,” and by Defendant’s Partial Motion to Dismiss, which
represented to the Court that Exhibit D “conclusively establishes” that the Superintendent
“specified the precise basis for the denial.” Rests on the Coordinator Declaration and on
exhibits not of record.
Respectfully Submitted,
_________________________
/s/ Halo4asin
HALO4ASIN
Plaintiff, Pro Se
Ridgeway State Bar License No. 18110
Dated: July 16, 2026
CERTIFICATE OF SERVICE
I certify that on July 16, 2026, I served a true copy of the foregoing Response on counsel for the
Defendant via the Court’s e-filing system and the case channel.
_________________________
/s/ Halo4asin
HALO4ASIN
3
