RIDGEWAY SUPERIOR COURT
NEVPLAYSGAMES and
THEAVENGERNICK
Plaintiffs
v. DOCKET NO. RSC-CV-798
STATE OF RIDGEWAY and
LARGETITANIC2
in his official capacity as
GOVERNOR OF THE STATE OF
RIDGEWAY
RESPONSE TO AMENDED
COMPLAINT
Defendant.
RESPONSE TO THE AMENDED CIVIL COMPLAINT
Comes now the Defendant, the State of Ridgeway and largeTitanic2 in his official
capacity as Governor of the same, by and through the undersigned counsel, hereby answering the
civil complaint brought forth against them.
GENERAL DENIAL
Unless otherwise specified, the Defendant denies all allegations in the aforementioned complaint
and disputes that the Plaintiff is entitled to relief.
INTRODUCTION
1. This paragraph sets forth a legal conclusion to which no response is
required. To the extent a response is required, denied.
2. Denied.
3. This paragraph sets forth a legal conclusion to which no response is
required. To the extent a response is required, denied.
4. Denied.
PARTIES
5. Admitted.
6. Admitted.
7. Admitted.
JURISDICTION AND VENUE
8. Admitted.
9. Admitted.
FACTS
10. Admitted.
11. Admitted.
12. Denied.
13. Denied.
14. Denied.
15. Denied.
16. Denied.
17. This paragraph sets forth a legal conclusion to which no response is
required. To the extent a response is required, denied.
18. This paragraph sets forth a legal conclusion to which no response is
required. To the extent a response is required, denied.
19. This paragraph sets forth a legal conclusion to which no response is
required. To the extent a response is required, denied.
20. This paragraph sets forth a legal conclusion to which no response is
required. To the extent a response is required, denied.
21. Denied.
22. Denied.
23. This paragraph sets forth a legal conclusion to which no response is
required. To the extent a response is required, denied.
24. This paragraph sets forth a legal conclusion to which no response is
required. To the extent a response is required, denied.
25. This paragraph sets forth a legal conclusion to which no response is
required. To the extent a response is required, denied.
26. This paragraph sets forth a legal conclusion to which no response is
required. To the extent a response is required, denied.
27. This paragraph sets forth a legal conclusion to which no response is
required. To the extent a response is required, denied.
28. This paragraph sets forth a legal conclusion to which no response is
required. To the extent a response is required, denied.
29. This paragraph sets forth a legal conclusion to which no response is
required. To the extent a response is required, denied.
TORTS AND PRAYERS FOR RELIEF
All paragraphs under this heading are denied. Defendant avers that Plaintiffs are not
entitled to any relief.
AFFIRMATIVE DEFENSES
Defendant sets forth their affirmative defenses. By setting forth these affirmative
defenses, Defendant does not assume the burden of proving any fact, issue, or element of a cause
of action.
FIRST AFFIRMATIVE DEFENSE
Plaintiffs bring action against Defendant for an alleged deprivation of their 14th
amendment rights under the United States constitution for allegedly impeding the ability of
Plaintiffs to seek redress in Ridgeway courts by means of filing expungement petitions. Plaintiffs
claim that “access to the courts is universal, and must not be disallowed to any person,” citing
Boddie v. Connecticut, 401 U.S. 371 (1971) in support. A reading of the opinion in this case
makes it clear that Plaintiffs’ arguments are wholly erroneous and unsupported.
The United States Supreme Court affirmed that “We do not decide that access for all
individuals to the courts is a right that is, in all circumstances, guaranteed by the Due Process
Clause of the Fourteenth Amendment… this right is the exclusive precondition to the adjustment
of a fundamental human relationship.” (Id.) Appellants in this case brought suit against the State
of Connecticut arguing that their petition for divorce was unconstitutionally denied due to their
nonpayment of court fees relating to the filing of their petition. The Court held that Appellant’s
right to petition for divorce could not be denied unless the State could provide a justification
showing otherwise; “Drawing upon the principles established by the cases just canvassed, we
conclude that the State's refusal to admit these appellants to its courts, the sole means in
Connecticut for obtaining a divorce, must be regarded as the equivalent of denying them an
opportunity to be heard upon their claimed right to a dissolution of their marriages, and, in the
absence of a sufficient countervailing justification for the State's action, a denial of due
process.” (Id.) (Emphasis added)
The holding in Boddie is explicitly clear that it does not extend in scope or enforcement
beyond the disillusionment of marriages and does not guarantee a universal right for access to
the courts, as Plaintiffs claim. Furthermore, the State of Ridgeway has clear and sufficient
justification to bar such access to the courts, disregarding the narrowly tailored ruling of the
Supreme Court, by virtue of having a vested interest in preventing and punishing seditionists and
traitors within its borders, seeking to ensure that its employees, sworn to protect the State, are
unwavering in that commitment without serious conflicts rising out of allegiance to a foreign
entity that would preclude them from being fully dedicated to the State of Ridgeway, the oath
they swore to, and the duties they promised to fulfill.
In the words of Goku from Dragon Ball Z, to go even further beyond, the Supreme Court
continued in their ruling to opine that “Resort to the judicial process by these plaintiffs is no
more voluntary in a realistic sense than that of the defendant called upon to defend his interests
in court. For both groups, this process is not only the paramount dispute settlement
technique, but, in fact, the only available one. In this posture, we think that this appeal is
properly to be resolved in light of the principles enunciated in our due process decisions that
delimit rights of defendants compelled to litigate their differences in the judicial forum.” (Id.)
(Emphasis added). Plaintiffs in this case have an actual method of resolving any dispute they
might have with their criminal records by petitioning the court for a Writ of Habeas Corpus via
Judiciary Act § 2.5; petitions for expungement fail to meet the definition of what would be
considered a dispute.
Expungement petitions are also not explicitly a means of redress by definition and
Plaintiffs are not enjoined from seeking redress in the courts by the provisions of the Modified
Sedition Act via a petition for a Writ of Habeas Corpus. Redress fundamentally is the pursuit of a
legal remedy for a wrong, a definition that an expungement petition does not meet. Such
petitions are inherently not a form of redress, rather acting similarly to that of a pardon whereby
a petitioner seeks forgiveness for their misgivings and criminal actions so that their lives are not
affected by their criminal record.
Accordingly, Plaintiffs’ 14th amendment rights are not deprived by enforcement of the
Modified Sedition Act and their claims should be dismissed in their entirety with prejudice.
Date: December 9th, 2022
Respectfully submitted,
TECHIEY
ATTORNEY GENERAL
DEPARTMENT OF JUSTICE
Government Annex, 2nd Floor
Palmer, RW 33328
RSB 17140
COUNSEL OF RECORD
TOTORO987123
ASSISTANT ATTORNEY GENERAL
DEPARTMENT OF JUSTICE
Government Annex, 2nd Floor
Palmer, RW 33328
RSB 17148
RYAN J. SYNDICATE
SOLICITOR GENERAL
DEPARTMENT OF JUSTICE
Government Annex, 2nd Floor
Palmer, RW 33328
RSB 18106
