STATE OF RIDGEWAY
RIDGEWAYFARMING_ALT )
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DOCKET NO. RSC-CV-339
PRESIDING JUDGE. zac2524
Plaintiff
v.
YOUFOUNDSEAL
Defendant
STATE’S RESPONSE TO THE MOTION TO RECUSE
The State of Ridgeway submits this response to the Plaintiff’s motion to recuse.
INTRODUCTION
The Plaintiff’s counsel submitted a motion to recuse on the 15th of May 2022. The Plaintiff
alleged that the presiding judge, the Honorable zac2524, has a “personal bias or prejudice concerning a
party.” See Plaintiff’s Motion to Recuse, on page 1; see also Ridgeway Code of Judicial Conduct (3)(c)
(1)(a). The Plaintiff’s counsel is incorrect in these contentions as the evidence provided by himself
amount to nothing that can even approach the notion of one having a personal bias, or prejudice against
another. For the reasons below, we ask the Court to deny the Plaintiff’s motion to recuse to properly deal
with the relevant issues at hand and to prevent attempts by the Plaintiff to prolong proceedings.
ARGUMENT
I. THE EXHIBITS PROVIDED BY THE PLAINTIFF DO NOT INDICATE ANY
PERSONAL BIAS OR PREJUDICE
The Plaintiff’s counsel has provided the Court with two exhibits outlined and affixed to his
motion to recuse. See Plaintiff’s Motion to Recuse, on page 2. The evidence provided by the Plaintiff is
submitted with little to no context surrounding any of the messages, nor are there any indications that
these messages were directly targeted towards the Plaintiff’s counsel. The evidence does not even come
close to substantiate the allegations that the Presiding Judge is partial against the Plaintiff’s counsel. For
this, we seek to define the words in plain terms. “Personal bias” is a term that is utilized to define a
“judge’s bias against one party in a law suit.” See Personal Bias Definition, Black’s Law Dictionary
Free Online Legal Dictionary (2nd ed), available at the Law Dictionary. Prejudice in this context can be
extended to include the definition for the term, “prejudice of judge,” which is a term used to define the
“favouritism that is shown by a judge to one party that is involved in a law suit.” See Prejudice of Judge
Definition, Black’s Law Dictionary Free Online Legal Dictionary (2nd ed), available at the Law
Dictionary. For formalities we will also include the textbook definition for “prejudice,” which is defined
as “[a] forejudgment; bias; preconceived opinion. A leaning towards one side of a cause for some reason
other than a conviction of its justice.” See Prejudice Definition, Black’s Law Dictionary Free Online
Legal Dictionary (2nd ed), available at the Law dictionary.
With the definitions in mind, we look at the exhibits that the Plaintiff has brought forward in his
motion. The first exhibit introduced by the Plaintiff labeled as “Exhibit A,” provides a GIF of a
conversation between the Honorable zac2524, and insertreality. The GIF does not provide any evidence
that substantiates either the chance that the presiding judge will be partial in his decision, nor does it
provide any proof of a personal bias targeted towards the Plaintiff. It shows the Judge giving the
Plaintiff the “Licensed Attorney” role which every attorney in the State of Ridgeway receives upon the
moment they get nominated and confirmed by the Supreme Court. If the Plaintiff wishes to refer to the
messages sent by insertreality, it is unclear as to whether the Judge realized who insertreality was talking
about, and it does not even come close to the modicum of backing that a motion to recuse needs. Next,
for the second exhibit introduced by the Plaintiff labeled as “Exhibit B,” another GIF is provided which
involves an apology from the Judge, almost one year ago. While there is not an expiration date for one
to believe that an individual continually displays prejudice against oneself, this is not one of those
instances. The Judge merely apologized for his actions and understood that whatever action he
committed prior to that message, was unbecoming of his position and he took it into consideration to
perfect and craft his outlook towards such situations in the future. This dilutes the possibility that the
Judge harbors any ill-will or prejudice against the Plaintiff’s counsel. None of the exhibits above come
to meet the definition that is required for a judge to recuse themselves as required by the Ridgeway Code
of Judicial Conduct.
For the reasons above, we ask the Court to deny the motion to recuse because the exhibits
provided by the Plaintiff fail to meet the definitions that are required to be met for a judge to recuse
himself. The Judge has not exhibited any prejudice, or personal bias towards the Plaintiff’s party.
II. THE PLAINTIFF SHOULD NOT BE ALLOWED TO SIMPLY PROLONG
PROCEEDINGS
The Plaintiff submitted a motion to recuse on May 15th, 2022, and this case was filed and
assigned to the Presiding Judge, zac2524, on May 5th, 2022. The Defense in this matter, submitted a
motion to dismiss on May 13th, 2022. Exhibit A was submitted by the Plaintiff in his motion to recuse,
and the evidence provided date to around May 6th, 2022. The evidence provided in Exhibit B range all
the way to October 12th, 2021. Nearly a year has elapsed since Exhibit B, and the evidence provided in
Exhibit A range to almost a day after filing. The timing points to an attempt made by the Plaintiff to
prolong proceedings as he chooses to make these motions solely because of the Defense’s motion to
dismiss.
The Plaintiff should not be allowed to prolong the proceedings as the deadline nears for a
response to the motion to dismiss. Nothing new has occurred since either of the exhibits provided by the
Plaintiff, and nothing prohibited the Plaintiff from filing for this motion to recuse upon its assignment to
the Presiding Judge. This simply points to an attempt made by the Plaintiff to prolong the proceedings.
III. THE PLAINTIFF HAS FAILED TO PROVIDE SUBSTANTIAL EVIDENCE
The Plaintiff has alleged that the Judge has an “obvious personal bias and prejudice towards
[himself].” The evidence provided the Plaintiff does not prove that at all, and he has only provided two
such pieces of evidence which has previously been proven false in our abovementioned arguments. The
Plaintiff erroneously attempts to mention the Judge’s clerk’s comments. The comments were indeed
unbecoming of a clerk, however, the Judge has informed the clerk to cease. The Judge is not obligated to
provide any relief to the Plaintiff due to the comments of his clerk. See Plaintiff’s Motion to Recuse, on
page 1, at paragraph 3. Because of the Plaintiff’s failure to provide substantial evidence, and his failure
to make points that properly attach any allegations that would entitle the Plaintiff to the entertainment of
such a motion, the motion must be denied.
CONCLUSION
For the reasons above, the State submits this response to the Plaintiff’s motion to recuse.
TURNTABLE5000
Solicitor General
Department of Justice
Counsel of Record
Dated: May 15th, 2022
