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 RENEWED MOTION FOR A PRELIMINARY INJUNCTION Plaintiff Khazain, by and through undersigned counsel, hereby, pursuant to Ridgeway Rule of Civil Procedure 47, renews their motion for a preliminary injunction enjoining and restraining Defendant Clifford2, in his official capacity as Attorney General of the State of Ridgeway from enforcing the monetary damages awarded to Defendant Hitherwguys. Plaintiff respectfully requests that the Court rule on the injunction on or before May 15th, 2022 at 11:59 PM Eastern Time. A memorandum in support is attached hereto. Respectfully submitted. Dated: May 13th, 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 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 MEMORANDUM OF LAW IN SUPPORT OF RENEWED MOTION FOR A PRELIMINARY INJUNCTION DORKJACOB Ridgeway Bar No. 17135 Counsel of Record DorkJacob Law 5 Cyrus Acres Milton, Ridgeway JacobInAustin#0001 [email protected] Attorney for Plaintiff 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. LEGAL STANDARD “A plaintiff seeking a preliminary injunction must establish [1] that he is likely to succeed on the merits, [2] that he is likely to suffer irreparable harm in the absence of preliminary relief, [3] that the balance of equities tips in his favor, and [4] that an injunction is in the public interest.” Winter v. Natural Res. Def. Council, Inc., 555 U.S. 7, 20 (2008). ARGUMENT I. Khazain is likely to succeed on the merits Section 6.5 permits the Attorney General to make a finding “in favor of the plaintiff against the government,” and “that decision shall be final and unappealable so long as the relief demanded is granted.” However, the other statute, Section 303, prohibits any monetary damages from being awarded in any case involving the Government. After all, the related action was against an agent of the Government – such cases are construed to be cases against the Government itself. See 5 R. Stat. § 304. The Senate specifically exposed the Government to liability for its agents' actions, and the Senate prohibited monetary damages from being awarded in any case involving the Government. The Attorney General’s indirect proposed construction of the two statutes that the Senate’s decision to limit the Government’s liability in terms of monetary damages means diddly squat in mediation proceedings and awards resulting from mediation is a preposterous statutory construction, and does not give full effect to the Senate’s decision. After all, it is this Court’s duty to give full effect to the two conflicting statutes.1 1 “[T]he [C]ourt must seek to harmonize two potentially conflicting statutes: ‘We must read the statutes to give effect to each if we can do so while preserving their sense and purpose.’” Chevron, Inc.. v. Hammond, 726 F.2d 483, 490 n.8 (9th Cir. 1984) (citing Watt v. Alaska, 451 U.S. 259, 267 (1981)). MEMORANDUM OF LAW IN SUPPORT OF MOTION FOR A PRELIMINARY INJUNCTION - 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. Thus, because the Government’s preposterous statutory construction fails even basic statutory interpretation guidelines, it must be assumed that Khazain will be likely to succeed on the merits – and especially because the Senate’s very clear and unequivocal instruction that no monetary damages shall be awarded in a case involving the Government, the Government has a high burden to carry to convince this Court that some exception applies, or to ignore Section 303 altogether. II. Khazain will suffer irreparable harm without an injunction While the Court in the related action indirectly believes that the monetary damages can be refunded to Khazain by Hitherwguys if he prevails in this case or in the related action (perhaps on a motion for relief from judgment – wait one minute, I’m pretty sure he can’t make that motion because the Government is the judge, jury, attorney, and executioner!), it is not in the interest of justice to require a party to give up half of the money in their bank account while that party attempts to challenge the judgment. Never before in the history of any justice system has there been a requirement to pay out an award first to the alleged aggravated party2 in order to appeal or seek relief from a judgment awarding monetary damages, especially under the threat of being literally imprisoned for attempting to exercise your right to due process and refusing to pay the alleged aggrieved party pending the outcome of the appeal or motion for relief from judgment, or some other post-judgment motion or proceeding to challenge the judgment or award in some way or another. As well as, if Khazain is forced to pay the fine, he may be denied the right to appeal or challenge the judgment and/or award of the Court in the related action by paying the fine, as paying the fine could be seen as admitting guilt. 2 Though sometimes courts will require awards of monetary damages to be kept in some type of escrow bank account depending the final outcome of the matter in order to ensure that either way, the potential final judgment will be satisfied wherever the balance strikes. MEMORANDUM OF LAW IN SUPPORT OF MOTION FOR A PRELIMINARY INJUNCTION - 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. The Court in the related action is holding a gun to Plaintiff’s head to pay the fine or be sent to jail even though Khazain is seeking to challenge the award given by the Attorney General in this proceeding. In the related action Court’s words (zac2524, J.)– “Just because you [are] suing the Plaintiff, you are not immune from having to pay the [award]. I will not rule differently or expedite the other case in any way to intentionally make it easier for you to avoid paying the [award]. You should focus on this case separately from the other one.” zac2524#1117 to Pim#4584 (Khazain), Discord Message No. 973960730888011776 (May 11, 2022 9:52 AM CT). The Court in the related action has no intention of staying the judgment and allowing Khazain to have even a modicum of due process. Khazain has been denied due process at every stage in the related proceeding – he can’t speak for himself in that proceeding, he can’t file any papers, and he was not given the opportunity to participate in mediation proceedings. Yet he’s on the hook for $3,000. What kind of justice system does America have if we allow that?3 III. The balance of the equities tip in Khazain’s favor Without an injunction, Khazain will be forced to pay a fine, possibly admit guilt by paying the fine, and thus be forever barred from challenging the pure unlawfulness of the monetary damages awarded by the Attorney General. With an injunction, Hitherwguys just has to wait for the award money that they are supposedly entitled to – they aren't, by the way, if that wasn’t made clear by now – and they have already waited since the related action was commenced. The balance of the equities tips sharply in Khazain’s favor as their rights in this proceeding and in the related action are at risk of being denied to him, whereas Hitherwguys has no rights that hang in the balance. 3 Plaintiff reserves this argument – denial of due process in the related action – but does not press the issue in this proceeding as it currently stands. MEMORANDUM OF LAW IN SUPPORT OF MOTION FOR A PRELIMINARY INJUNCTION - 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. IV. An injunction is in the public interest The public has a clear interest in ensuring that the laws are applied to the letter. See Newton v. Rumery, 480 U.S. 386, 400 (1987) (“The public has an interest in seeing its laws faithfully executed. But, officials may give more weight to the private interest in seeing a civil claim settled than to the public interest in seeing the guilty convicted.”) Without an injunction, any person who becomes a government employee, commits some sort of tortious act while acting as an agent of the Government, gets sued for monetary damages, and they lose in Court will be on the hook for those monetary damages even though the Senate limited the Government’s liability as to monetary damages, and that limitation of liability also applies to agents of the Government. CONCLUSION Injustice anywhere is a threat to justice everywhere. Khazain has an injustice hanging over them that they are attempting to lift off of them. This Court must allow Khazain to challenge that perceived injustice. The motion should be granted. Respectfully submitted. Dated: May 13th, 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 MEMORANDUM OF LAW IN SUPPORT OF MOTION FOR A PRELIMINARY INJUNCTION - 4 - DorkJacob Law 5 Cyrus Acres Milton, Ridgeway

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