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RIDGEWAY SUPERIOR COURT
NEVPLAYSGAMES and
THEAVENGERNICK, on behalf of all
other similarly situated,
Plaintiff,
v.
STATE OF RIDGEWAY; largeTitanic2
in his official capacity as Governor of
the State of Ridgeway,
Defendant.
Case No. RSC-CV-798
MOTION FOR DISCOVERY
MOTION FOR DISCOVERY
In accordance with Rid. R. Civ. P. Rule 19, the Plaintiff in the above entitled matter
hereby moves to discover the following items in addition to the Defenses’ initial discovery
obligations:
1. All discussions, plans, directives, orders or otherwise within the Governor’s
administration regarding the enforcement of the Modified Sedition Act;
2. All discussions, plans, directives, orders, actions or otherwise related to the enforcement
of the Modified Sedition Act within the Ridgeway County Sheriff’s Office, Ridgeway
County Transit Authority, Ridgeway County Fire Department, Law Enforcement Training
Center, Ridgeway National Guard, Ridgeway Parks Service, Ridgeway State Police,
Palmer Police Department, and any other agency not mentioned;
3. A copy of all messages, memos, or otherwise sent to those in violation of the act that has
material relation to the enforcement of the act, alleged violation of the act, ultimatums
regarding employment because of the act or otherwise between any State agency and
their employee;
4. The evidence used to support the Governor’s findings for Executive Order 3 regarding
incompatible offices within the two States;
5. Evidence, indications, or testimony that suggest that Boulder County, Colorado is a State
that materially poses a security threat to the State of Ridgeway;
6. Names and associated ranks of all individuals in the State of Ridgeway who are actively
in violation of the law, and would be terminated if not for the injunction; and
7. Any expert testimony or opinions collected with respect to this case
Respectfully Submitted.
STICKZA
Managing Partner
COHN, CICERO, & GOODRICH, LLC
Suite 3B, Palmer Apartments
Palmer, RW 33328
D: stick#0677
E: [email protected]
CLIFFORD2
Counsel
10 000
TURNTABLE5000
Counsel
10 000
HOLYROMANRYAN
Advocate
10 000
Counsel for the Plaintiff
Document record
File size
51.3 KB
Uploaded
Dec 7, 2022 12:00 PM
Filed
Dec 7, 2022 12:00 PM
Filing code
COMPLAINT
Uploaded by
nevplaysgames
Notes
RSC-CV-798 - Motion for Discovery.pdf — archived from the Trello docket (https://trello.com/c/WGLWLL3O)
