Ridgeway Unified Courts

JUDICIAL COUNCIL OF RIDGEWAY

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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 KHAZAIN, Plaintiff, v. CLIFFORD2, in his official capacity as Attorney General of the State of Ridgeway; HITHERWGUYS, Defendants. No. RSC-CV-360 AND RELATED ACTION COMPLAINT Khazain, by and through undersigned counsel, hereby brings this civil action and alleges as follows– INTRODUCTION The Original Action 1. On May 2nd, 2022, Defendant Hitherwguys commenced an action against Plaintiff Khazain and alleged that on or about April 11th, 2022, that an individual named OfficerOriginal had shot at Hither and Plaintiff Khazain, in their official capacity as a Volunteer Ranger of the Ridgeway Park Service, had joined in the gun fight by shooting at Hither. See Hitherwguys v. Khazain, No. RSC-CV-332 (2022) (related action) (Exhibit D). Khazain was then investigated by the Ridgeway Park Service. The Service then suspended Defendant for three days and gave Khazain a verbal warning. See In re Khazain, No. 1-22-0089-RPS (Apr. 30, 2022) (Exhibit B). 2. After the related action was commenced, the Government appeared on behalf of the Defendant and represented Khazain. Khazain privately retained DorkJacob Law to advocate for their interests and give legal advice as to this matter, even though their representation was by the Government and not 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. necessarily without some protest by Khazain. After the parties entered into mediation, the Court stayed the proceedings to allow mediation to proceed. 3. This matter came out of mediation on May 8th, 2022, and Defendant Clifford2, in his official capacity as Attorney General of the State of Ridgeway, declared that Khazain was at fault and awarded Hither three thousand dollars. See Letter from Clifford2, Atty. Gen., State of Ridgeway to Khazain (May 8, 2022) (Exhibit C), which turns us to the instant action to challenge the award by the Attorney General. Unlawful Award 4. The award by the Attorney General violates Title 5, Section 303 of the Ridgeway Statutes, which reads very explicitly– “No monetary damage shall be awarded in a case against the government, cases where the government is a party, or cases where the government has intervened.” 5. Seeing as the Attorney General illegally awarded monetary damages to Hither, the Court must strike down the award as unlawful, arbitrary, capricious, and as an abuse of discretion. Conflicting Statutes 6. While Section 303 conflicts with Section 6.5 of the Inaugural Law (Exhibit A) this Court must reconcile the differences of both sections and give effect to both sections. See Marbury v. Madison, 5 U.S. (1 Cranch.) 137, 177 (1803); Frost v. Wenie, 157 U.S. 46, 58 (1895). 7. The differences between the sections makes clear that the award of the Attorney General – if that award gives the Plaintiff(s) exactly what they want – cannot be appealed on the merits, as the Legislature specifically invoked the doctrine of res judicata to bar any appeal. However, because arbitration conducted 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. by the Attorney General constitutes agency action in the ordinary sense,1 the award of monetary damages can be challenged in this Court as unlawful. However, the award cannot be challenged on the merits (i.e. the dollar amount, whether or not it should have been awarded, etc.) JURISDICTION AND VENUE 8. This Court has jurisdiction pursuant to Article V, Section IV of the Constitution of the State of Ridgeway, and Article IV, Section 7 of the Charter of Ridgeway County. 9. Venue is proper in this Court because the incident took place within Ridgeway County. PARTIES 10. Plaintiff Khazain is a resident of Ridgeway County, and principally resides in Palmer, Ridgeway, and is the Defendant in the related action. 11. Defendant Clifford2 is sued in his official capacity as Attorney General of the State of Ridgeway. 12. Defendant Hitherwguys is joined as a Defendant and interested party as they were the Plaintiff in the related action. CAUSE OF ACTION (Administrative Review) 13. Plaintiff repeats and realleges the allegations contained in all preceding paragraphs as if fully set forth herein. 14. Defendant Clifford2, in his official capacity as the Attorney General of the State of Ridgeway, unlawfully awarded monetary damages to Defendant Hitherwguys in the related actions, and thus committed unlawful agency action which is arbitrary, capricious, and an abuse of discretion. 1 Generally, agency action “includes the whole or a part of an agency rule, order, license, sanction, relief, or the equivalent or denial thereof, or failure to act”. 5 U.S.C. § 551. COMPLAINT - 3 - 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. PRAYER FOR RELIEF Wherefore, Plaintiff prays that the Court– a. Declare that the award of monetary damages in the related action is unlawful; b. Vacate the award as to the unlawful monetary damages; c. Declare that the Attorney General committed unlawful agency action; d. Vacate such agency action as to the unlawful award of monetary damages; e. Award such other, further, or different relief as may be just and proper. Respectfully submitted. Dated: May 10th, 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 - 4 - DorkJacob Law 5 Cyrus Acres Milton, Ridgeway TABLE OF EXHIBITS Exhibit A – Section 6.5 of the Inaugural Law Exhibit B – Case Report In re Khazain, No. 1-22-0089-RPS (Apr. 30, 2022) Exhibit C – Award Letter Exhibit D – Complaint Hitherwguys v. Khazain, No. RSC-CV-332 (2022) Exhibit E – Judgment Hitherwguys v. Khazain, No. RSC-CV-332 (2022) EXHIBIT A specific employees, and the office for which the designated employee works shall make reasonable efforts to accommodate the request. (j) The Special Counsel shall assign the duties and supervise the work of such employees while they are assigned to the Special Counsel. If necessary, the Special Counsel may request that additional personnel be hired or assigned from outside the Attorney General's Office. (k) All personnel in theAttorney General's Office shall cooperate to the fullest extent possible with the Special Counsel. (l) The Special Counsel may hire special investigators as he sees fit to investigate a claim under his jurisdiction. SUBSECTION 6.5. AUTHORITY TO ACT AS MEDIATOR OR ADJUDICATOR (a) The Attorney General shall mediate all claims to-where a government department or agency has a legal claim against another government department or agency. (i) The findings of the Attorney General shall be res judicata and not appealable. (b) In civil cases against an agent of; or the government, the Attorney General shall attempt to mediate and serve as initial arbitrator. (i) No case against an agent of; or the government shall be heard by the civil courts without there first being an attempt at mediation. (ii) If the Attorney General finds in favor of the plaintiff against the government, that decision shall be final and unappealable so long as the relief demanded is granted. (iii) If the Attorney General finds in favor of the government, or does not grant all relief demanded, then the plaintiff may proceed with a civil action in the State courts. SUBSECTION 6.6 THE SOLICITOR GENERAL (a) There shall be a Solicitor General who is appointed by the Attorney General. (b) The Solicitor General shall appear in all cases where the government is a party or has an interest. (c) The Solicitor General shall handle all appeals, criminal or civil. (d) The Solicitor General must be a bona fide attorney-at-law. (e) The Solicitor General shall hire or retain attorneys-at-law to work in his office. (f) If one so exists, the Solicitor General and the Attorney General shall be admitted into the Supreme Court Bar. EXHIBIT B EXHIBIT C Ridgeway Department of Justice Office of the Attorney General May 8, 2022 Mr. Khazain Ridgeway Park Service Re: Order to Pay Damages Khazain: Following the filing of a civil case against you that alleged a systematic rights violation subsequent to your use of force on April 30, 2022, the Department of Justice is ordering you to pay damages to the Plaintiff, Hitherwguys, in the amount of $3,000. This is the result of a 2 R. Stat. § 240 mediation. The damages are ordered to be paid by Sunday, May 15th, 2022 given that the Plaintiff makes reasonable attempts to ensure availability. In the event that you fail to abide by this order, you will be liable in your individual capacity for the damages consistent with 2 R. Stat. § 213. Respectfully, CLIFFORD2 Attorney General Department of Justice EXHIBIT D STATE OF RIDGEWAY SUPERIOR COURT Hitherwguys Plaintiff, v. Khazain Defendant. CIVIL COMPLAINT Docket No. RSC-CV-332 PARTIES 1. Mr. Hitherwguys, the Plaintiff, is a citizen of the State of Ridgeway. 2. Mr. Khazain, the Defendant, in his official capacity as a Volunteer Park Ranger of the Ridgeway Parks Service. JURISDICTION 1. Article V, Section IV of the Ridgeway State Constitution empowers this Court to hear “all civil or criminal cases or controversies”. ALLEGATIONS On or about the date of 11 April 2022; 1. Plaintiff was peacefully and civilly conducting his business as a citizen of the State of Ridgeway. 2. While standing outside near the Palmer Police Department station, Plaintiff was shot at by Mr. OfficerOriginal, a Tourist in the State of Ridgeway. 3. Plaintiff, in self-defense, shoots back, and along with nearby law enforcement officers, causes the death of Mr. OfficerOriginal. 4. After Mr. OfficerOriginal is killed, Plaintiff reloads his pistol facing away from any nearby persons to replenish the bullets he shot at Mr. OfficerOriginal. 5. While reloading his pistol, Plaintiff is shot in the back by Defendant several seconds after the shooting has stopped. 6. A nearby witness to the situation, Mr. Marces_RBLX, a Park Ranger Grade I in the Ridgeway Parks Service, comments “wrong person” in response to Defendant’s actions. 7. After Mr. Marces_RBLX explains to Defendant that he shot the wrong person, Defendant says “he was?” “well then” “that puts things into perspective”, realizing his error in shooting and killing Defendant and admitting to his mistake. On or about the date of 19 April 2022; 8. Plaintiff submitted a complaint to the Ridgeway Parks Service Internal Affairs against Defendant 9. During the investigation, both Plaintiff and Defendant were interviewed by Ridgeway Parks Service Internal Affairs, as found in Exhibit C and Exhibit D. On or about the date of 30 April 2022; 10. The Ridgeway Parks Service Internal Affairs finds Defendant in violation of both the use of force policy and jurisdiction policy. 11. The defendant is recommended to be issued a 3-day suspension and verbal warning. TORTS IN QUESTION 1. 1 R. Stat. § 209 - Wrongful Death PRAYERS FOR RELIEF 1. Plaintiff prays the Court finds Defendant liable for the aforementioned torts. 2. Plaintiff seeks monetary relief amounting to $3,000 in both redress and punitive damages and $625 in compensatory damages. a. $2,500 for 1 R. Stat. § 209 - Wrongful Death b. $143 for the loss of Plaintiff’s Salvo Snub pistol c. $70 for the loss of Plaintiff’s 2 boxes of 9mm ammunition d. $287 for Plaintiff’s pain and suffering and related costs of replacing Plaintiff’s possessions lost as a result of Defendant’s actions e. $625 for the Plaintiff’s legal fees, which includes both the filing fee and hiring of legal counsel. 3. Plaintiff also seeks any additional relief as deemed appropriate by the Court that is not requested herein. EVIDENCE 1. Exhibit A - Defendant shooting and killing Plaintiff during the situation in question. 2. Exhibit B - RPS Internal Affairs Report (Case#1-22-0089-RPS) 3. Exhibit C - Defendant’s testimony to RPS Internal Affairs 4. Exhibit D - Plaintiff’s testimony to RPS Internal Affairs 5. Witnesses will be presented during the discovery phase. Date: 05/02/22 /s/OfficerVideoGame Attorney for Plaintiff Mytrius & Associates Counsel of Record /s/HolyRomanRyan Attorney for Plaintiff Mytrius & Associates EXHIBIT E ADM F. 500 (Rev. 03/22) Order and Judgment SUPERIOR COURT OF THE STATE OF RIDGEWAY HITHERWGUYS ) ) ) ) ) ) ) ) ) ) DOCKET NO. RSC-CV-332 Plaintiff v. KHAZAIN Defendant ORDER AND JUDGMENT In accordance with a settlement agreed upon by both parties, the court orders Defendant to pay $3,000 in monetary damages, directly to Plaintiff, by May 15, 2022, at 11:59 PM EST, unless he is able to show cause as to why such deadline should be extended. Failure by Defendant to pay Plaintiff the ordered damages through a court fine shall result in the issuance of an arrest warrant in Defendant’s name for contempt of court. SO ORDERED, ADJUDGED AND DECREED. At Palmer, Ridgeway, this 9th day of May, 2022. /s/ zac2524 CHIEF JUDGE

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