THE STATE OF RIDGEWAY
RIDGEWAY SUPERIOR COURT
FALCON_2S,
-against-
ANTILOOTBAG,
Defendant.
Case No. RSC-CV-2210
CIVIL COMPLAINT
Presiding Judge: Koala4life
PLAINTIFFS’ RESPONSE IN OPPOSITION TO THE DEFENDANT’S
AFFIRMATIVE DEFENSES AND MOTION TO DISMISS
The Plaintiff, Falcon_2s by and through counsel, file this response in opposition to
Defendant AntiLootBag’s motion to dismiss the complaint for the reasons set forth below. The
Plaintiff respectfully requests that the Court deny the Defendant’s motion and set aside their
affirmative defenses.
FAILURE TO STATE A VALID CLAIM
The Plaintiff has stated a valid claim that meets the criteria set forth in Rule 8 of the
Ridgeway Rules of Civil Procedure. Under Rule 8, a claim must contain (a) a short and plain
statement of the claim showing that the pleader is entitled to relief, and (2) a demand for
judgment for types of relief to which he deems himself entitled. Additionally, under the pleading
standards set forth in Twombly and Iqbal, a complaint must be plausible on its face, but must
bring forth sufficient factual allegations that nudge a claim across the line from conceivable to
plausible.
Here, the Plaintiff’s Statement of Facts combined with the prayer of relief outline an
overview of the event that caused harm to the plaintiff, and sufficiently shows that he is entitled
to relief. Additionally, the prayer for relief states clearly the types of relief the plaintiff would
like to receive.
Furthermore, in evaluating the claim on the basis of Twombly and Iqbal, the plausibility
of the claim on its face is established in that there are sufficient factual allegations that show that
the defendant was harmed by the defendant’s conduct. The Plaintiff clearly alleges that the
plaintiff had killed him in the statement of facts, nudging the claim beyond plausibility.
AMBIGUITY
The Plaintiff’s allegation and injury is clearly stated in the Statement of Facts The
Plaintiff is alleging that the Plaintiff had killed them and is requesting the Court award punitive
damages for the torts listed on the complaint.
UNJUST ENRICHMENT
The Plaintiff is requesting no more than the maximum amount allowed by law. Pursuant
to 1 R. Stat. § 3102, 1 R. Stat. § 3103, 1 R. Stat. § 3109, the Plaintiff is entitled to a maximum of
$ 2, 500, $ 1,500, and $ 2,500 in punitive damages for each tort respectively. The Plaintiff is not
requesting more money than what he is entitled to by law.
NO DAMAGE TO PLAINTIFF
This is a question of fact that must be decided by the Court during trial with the evidence
gathered during discovery. Regardless of the Defendant’s assertion that they do not assume a
burden of proving any fact issue, or element of a cause of action, in asserting no damage to the
Plaintiff as an affirmative defense, the burden is on the Defendant.
IMPROPER SERVICE
Pursuant to Rule 5c of the Ridgeway Rules of Civil Procedure, service may be made by
any other person duly authorized by law. This category includes the Plaintiff themself and their
representative. In numerous Ridgeway cases, service through direct message by the Plaintiff has
been utilized without issue. As a matter of policy Forcing service by the Sheriff would unduly
burden the department’s limited resources.
Additionally, the Plaintiff utilized service by publication in order to attempt to contact the
Defendant when they were not in any of Ridgeway’s Discord Servers.
NO PROOF OF SERVICE
The Plaintiff has provided adequate proof of service to the Defendant through the case
Discord within the 48 hours allotted to the Plaintiff. Additionally, the court had granted and
utilized service by publication before the Defendant joined any of Ridgeway’s Discord servers.
IMPROPER VENUE
The Plaintiff has stated in his complaint that the venue as “this Court” referring to the
Superior Court of the State of Ridgeway. Additionally, venue is proper since the issues alleged
are not matters that the Federal Courts have Subject Matter Jurisdiction of. Rather, it deals with
State law and State issues.
ASSUMPTION OF RISK
This is a question of fact that must be decided by the Court during trial with the evidence
gathered during discovery. Regardless of the Defendant’s assertion that they do not assume a
burden of proving any fact issue, or element of a cause of action, in using Assumption of Risk as
an affirmative defense, the burden is on the Defendant.
CONSENT
This is a question of fact that must be decided by the Court during trial with the evidence
gathered during discovery. Regardless of the Defendant’s assertion that they do not assume a
burden of proving any fact issue, or element of a cause of action, in asserting consent as an
affirmative defense, the burden is on the Defendant.
CIRCUITRY OF ACTION
The Plaintiff is taking the most direct route to obtain his entitled relief given that the
Defendant had not joined the Discord until almost a week after this case was filed. The Plaintiff
is also not attempting to bring their claims in other lawsuits, or try to bring multiple lawsuits to
obtain relief for the same issue.
LACK OF JURISDICTION
The events have taken place in the City of Palmer, a city that is located within the State of
Ridgeway and is therefore a court of general jurisdiction, this Court may hear the case.
Jurisdiction is invoked clearly in the complaint.
RESERVATION
The Defendant is entitled to this pursuant to the Ridgeway Rules of Civil Procedure . As
this is not an affirmative defense, the Plaintiff raises no issues with this.
DATED: February 12 2024
Respectfully submitted,
Dinnerblaster28454, Esq.
Attorney for the Plaintiff
/s/ Dinnerblaster28454
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Falcon_2s
Plaintiff
/s/ Falcon_2s
