STATE OF RIDGEWAY
LX1NAS
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DOCKET NO. RSV-CV-2700
Plaintiff
v.
STATE OF RIDGEWAY
Defendant
PLAINTIFF’S RESPONSE TO THE DEFENDANT’S MOTION TO DISMISS
ARGUMENT
1. The plaintiff is not seeking a pre-enforcement challenge, the State of Ridgeway is the
correct defendant.
As previously mentioned, and contrary to the defendant’s motion, the plaintiff is not seeking a
pre-enforcement challenge, being contrary to the facts in the case. “No plaintiff, in this case, has
been arrested and prosecuted for violating the disputed provisions of the Code, so plaintiffs case
constitutes a ‘pre-enforcement’ challenge” Seegars v. Gonzalez, 396 F.3d 1248, 1251. As the
plaintiff, Mr. Lx1nas had been arrested under the provisions of the disputed clause of the
Wildlife Act, an action of the nature the defendant claims do not apply to this case. The plaintiff
is seeking relief from the State of Ridgeway, the correct defendant, the State enacted said
inaugural laws, making the state as a whole liable for said statutes. Epperson v. Arkansas, 393
U.S. 97 (1968) is a prime example of this, having the State of Arkansas as a defendant for a
constitutional violation made by a statute.
2. The plaintiff is not an animal and is entitled to file suit against the State of Ridgeway.
As previously stated in the complaint brought by the plaintiff, Mr. Lx1nas is a citizen of the State
of Ridgeway, entitled to “find a certain remedy, by having recourse to the laws, for all injuries or
wrongs which one may receive in person, property or character;” Ridgeway State Constitution
§1(1). The defendant’s arguments have no solid base, even being contradicted by the challenged
law in question; “Wildlife or an “Animal” is any person with a tail or cat ears.” Wildlife
Conservation Act §3(b)(i); I would like to quote again: “any person”, the law is contradicting
itself, awarding humanity to individuals with a tail or cat ears. According to the
Merriam-Webster Dictionary (“The dictionary by Merriam-Webster is America's most trusted
online dictionary for English word definitions, meanings, and pronunciation. #wordsmatter.”), a
person is “one (such as a human being, a partnership, or a corporation) that is recognized by law
as the subject of rights and duties”. This is a prime example of contradictions found in the
defendant’s argument and the disputed law. As defined by Merriam-Webster Dictionary, an
animal is “less advanced in the scale of evolutionary development as distinguished from human
beings”. What the law and the defense are arguing is that human beings, not even people now,
should be stripped from their evolutional development for wearing a fake tail or cat ears. The
plaintiff is fully entitled to relief, not only as a citizen of the State of Ridgeway, but as a human
being, with fundamental, intrinsic rights.
Respectfully Submitted,
Plaintiff Lx1nas
By their Attorneys,
/s/ AZAD9L
Counsel of Record
RSB#11102
/s/ Mytrius
Counsel of Record
RSB#17106
