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This document is a document filed in a mock court in the State of Ridgeway on Roblox.com. I am a notary public of
the State of Texas in real life. A notary public cannot give legal advice or accept fees for legal advice. See Tex. Gov't
Code § 406.017. This document does not constitute legal advice in any way, shape, or form.
SUPERIOR COURT OF THE STATE OF RIDGEWAY
RIDGEWAY FINANCIAL BANKING
HOLDINGS, a corporation,
Plaintiff,
v.
IBM03, in their official capacity as
Secretary of State of the State of
Ridgeway; BANK OF RIDGEWAY, an
incorporated entity in the State of
Ridgeway; XNICKGAMERYTX,
Defendants.
No. RSC-CV-348
COMPLAINT
Ridgeway Financial Banking Holdings S.A., by and through undersigned
counsel, hereby brings this civil action and alleges as follows–
INTRODUCTION
1. This action is brought to enforce Plaintiff Ridgeway Financial Banking
Holdings S.A. (hereinafter the “Corporation”)’s right to the trade name and
business name “Bank of Ridgeway” as Defendant ibm03, in their official capacity
as Secretary of State of the State of Ridgeway, registered “Bank of Ridgeway”
twice erroneously.
2. On January 29th, 2022, the Corporation, by and through its Chief Executive
Officer Samianz12, registered “Bank of Ridgeway” as a sole proprietorship in the
State of Ridgeway. Samianz then put the Bank under the management of the
Corporation and lawfully issued common stock in the Corporation which also
holds a stake in the Bank of Ridgeway among other subsidiaries.
3. Then, on April 16th, 2022, Defendant XNickGamerYTX also registered
“Bank of Ridgeway” as a sole proprietorship in the State of Ridgeway. Nick has
been operating the Bank ever since then as the legitimate Bank of Ridgeway,
COMPLAINT - 1 - DorkJacob Law
5 Cyrus Acres
Milton, Ridgeway
This document is a document filed in a mock court in the State of Ridgeway on Roblox.com. I am a notary public of
the State of Texas in real life. A notary public cannot give legal advice or accept fees for legal advice. See Tex. Gov't
Code § 406.017. This document does not constitute legal advice in any way, shape, or form.
whereas the Corporation has had and operated the Bank of Ridgeway as a
subsidiary of the Corporation by selling common stock in the Bank.
4. Nick, thus, is infringing on the Corporation’s exclusive right to operate the
Bank under the name “Bank of Ridgeway”, and is also infringing on the
Corporation’s common law trademark of the name.1
JURISDICTION AND VENUE
5. This Court has jurisdiction pursuant to Article IV, Section 7 of the Charter of
Ridgeway County.
6. Venue is proper in this Court because the incident took place within
Ridgeway County.
PARTIES
7. Plaintiff Ridgeway Financial Banking Holdings S.A. is a corporation that
specializes in financial services in the State of Ridgeway.
8. Defendant ibm03 is sued in their official capacity as Secretary of State of the
State of Ridgeway.
9. Defendant Bank of Ridgeway is a sole proprietorship formed by Defendant
XNickGamerYTX on April 16th, 2022, and is sued as an interested party.
10. Defendant XNickGamerYTX is the owner of Defendant Bank of Ridgeway
and is sued as an interested party.
CAUSE OF ACTION
(Administrative Review)
11. The Corporation repeats and realleges the allegations contained in all
preceding paragraphs as if fully set forth herein.
1 To avoid the mixing of administrative review and common law trademark legal
standards, the latter claim will be raised in Samianz12 v. XNickGamerYTX, No. RSC-CV-341
(filed May 6, 2022 3:07 PM) (Eagleeye785, J.)
COMPLAINT - 2 - DorkJacob Law
5 Cyrus Acres
Milton, Ridgeway
This document is a document filed in a mock court in the State of Ridgeway on Roblox.com. I am a notary public of
the State of Texas in real life. A notary public cannot give legal advice or accept fees for legal advice. See Tex. Gov't
Code § 406.017. This document does not constitute legal advice in any way, shape, or form.
12. Defendant ibm03, in their official capacity as Secretary of State of the State
of Ridgeway registered the “Bank of Ridgeway” as owned by XNickGamerYTX in
April 2022, when the Corporation registered a business under the same name in
January 2022.
13. Thus, the Secretary of State’s registration of the Bank to XNickGamerYTX
was arbitrary, capricious, an abuse of discretion, and/or otherwise not in
observance of procedure required by law.
PRAYER FOR RELIEF
Wherefore, the Corporation prays that the Court–
a. Declare that the registration of “Bank of Ridgeway” granted to
XNickGamerYTX was either or all arbitrary, capricious, an abuse of discretion, or
otherwise not in observance of procedure required by law;
b. Declare that the registration of “Bank of Ridgeway” granted to
XNickGamerYTX is null and void;
c. Award any and all further relief.
Respectfully submitted.
Dated: May 16th, 2022
Milton, Ridgeway
/s/ DorkJacob
———————————————————————————
DORKJACOB
Ridgeway Bar No. 17135
Counsel of Record
DorkJacob Law
5 Cyrus Acres
Milton, Ridgeway
JacobInAustin#0001
[email protected]
Attorney for Plaintiff
COMPLAINT - 3 - DorkJacob Law
5 Cyrus Acres
Milton, Ridgeway
Document record
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May 7, 2022 12:00 PM
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May 7, 2022 12:00 PM
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COMPLAINT
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ridgeway financial banking holdings
Notes
Complaint.pdf — archived from the Trello docket (https://trello.com/c/IvcrM5Wy)
