RIDGEWAY STATE SUPERIOR COURT
FOR THE
COUNTY OF RIDGEWAY
STATE OF RIDGEWAY
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DOCKET NO. RSC-CM-2362
RESPONSE TO MOTION TO DISMISS
PRESIDING JUDGE: Hon. bommes
Plaintiff
v.
IMAGINEBEINGRATIOED
Defendant
State Attorney bohbazinga, on behalf of the State, submits this above-mentioned
response to the Motion to Dismiss filed by the defendant. Attached shall be a full and complete
response to the arguments presented by Defendant.
DATED: April 1, 2024 Respectfully submitted,
bohbazinga
bohbazinga
State Attorney
Office of the Attorney General
Counsel of Record
ARGUMENT
I. The Right to a Speedy Trial Has Not Been Violated By the State
State confirms that all defendants have the right to a speedy trial, but does not apply in
this instance. In fact, the defendant’s counsel Stickza was assigned during all dates during the
period of scheduling. This sole factor lies independently on the defense who has failed time and
time again to provide a suitable time for the court to conduct business. “Different reasons for
delay are accorded in different weights…Negligence is a more neutral act that should not be
weighed as heavily as acts done in bad faith.” United States v. Lazzara, No. 16-14290 (2017),
citing Barker v. Wingo, 407 U.S. 514 (1972).
In such an instance, it is imperative to analyze where this claim stems from, and it stems
solely on behalf of the defense from failing to properly schedule their time with the court. The
State cannot be found at fault if Defendant’s previous counsel did not wish to effectively
schedule. The State has submitted several dates during this entire ordeal, all of which have fallen
upon deaf ears to opposing counsel.
II. The Statement of Cause Does Corroborate.
Simply put, this issue resolves itself if you just read the statement of cause. “After killing
the complainant, the defendant states that they had to kill them because they thought they had a
warrant…after realizing they had no warrant, they changed their reason for killing the
complainant to them possessing an illegal firearm.” (Statement of Cause, RSC-CM-2362). The
statement shows a clear development in this line of thought, first stemming from the warrant,
evolving into disregard for a possible warrant, to concern of jail over an illegal firearm. Exhibit
A is simply an extension and accumulation of facts and knowledge obtained by the State
Investigators.
III. Arthur_Chen’s Actions Have No Standing on Current Proceedings
Arthur_Chen is not the judge, prosecutor, or opposing counsel in this case. His actions
have no relative influence on the defendant, or the proceedings within this case. To take his
outlandish comments upon face value itself, and to argue they will be used to cause harm to the
case is ludicrous. If anything, the defendant would be jeopardizing this own case and livelihood,
not the State. Opposing counsel also fails to state what crime would even happen, just that one
would. This clear and apparent lack of clarity should result in this motion to dismiss being tossed
on face value. There have been no facts twisted, as Arthur_Chen has no access to them, and this
case has gone past several reviewal layers prior to arriving at the court.
CONCLUSION
For the foregoing reasons, the State recommends to the Court that the motion to dismiss
be thrown out in its entirety.
RIDGEWAY STATE SUPERIOR COURT
FOR THE
COUNTY OF RIDGEWAY
STATE OF RIDGEWAY
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)
)
)
)
DOCKET NO. RSC-CM-2362
RESPONSE TO MOTION TO DISMISS
PRESIDING JUDGE: Hon. bommes
Plaintiff
v.
IMAGINEBEINGRATIOED
Defendant
CERTIFICATE OF SERVICE
I hereby certify that on this date of April 1, 2024, a copy of the foregoing response was
submitted to the Defendant’s via electronic submission.
DATED: April 1, 2024 Respectfully submitted,
bohbazinga
bohbazinga
State Attorney
Office of the Attorney General
Counsel of Record
