IN THE SUPERIOR COURT OF THE STATE OF RIDGEWAY
STATE OF RIDGEWAY )
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DOCKET NO. RSC-CM-2642
Judge Presiding: koala4life
Plaintiff
v.
BRANDONNLUV; ROYALTYSYN;
MATRIX_OC
Defendant
STATE’S BILL OF PARTICULARS
The State of Ridgeway, by and through Assistant Attorney General RyanJSyndicate of
the Office of Government Affairs, hereby submits this response to the Defendants’ demand for a
Bill of Particulars.
Particulars As To State Laws Violated In Count 1
1. A state employer is required to treat all employees with “fair and equitable
treatment in all aspects of personnel management [...] with proper regard for their privacy and
constitutional rights.” 2 R. Stat. § 3214. The State alleges that Defendant Brandon’s March 6th,
2024 issuance of administrative leave to Just_Dapper, an employee of the Ridgeway National
Guard, was violative of this statute as retaliatory action as a result of that employee’s personal
speech, in violation of their First Amendment constitutional protection.
2. A state employee “may only be put on administrative leave for allegations which,
if taken as true, would warrant a general discharge or dishonorable discharge” and “if there is a
pending misconduct investigation or criminal investigation.” 2 R. Stat. § 3125; 2 R. Stat. § 3128.
The State alleges that Just_Dapper was knowingly placed on administrative leave by Defendant
Brandon without allegations regarding department policy or state law that, if taken as true, would
warrant a general discharge or dishonorable discharge. Further, the State alleges that there was
no pending misconduct investigation or criminal investigation on Just_Dapper to the knowledge
of Defendant Brandon.
Particulars As To State Laws Violated In Count 2 and 5
3. A state employee is to be “protected against arbitrary action” against them. 2 R.
Stat. § 3219(i). An adverse action is arbitrary if it “takes no accounting of mitigating factors,
circumstances, or liabilities.” The State alleges that Defendants BrandonnLUV and RoyaltySyn
March 9th, 2024 issuance of administrative leave on Just_Dapper and mistypro2 was done
without any accounting of mitigating factors, circumstances, or liabilities as a separate
transaction of crime to Counts 3 and 4.
Particulars As To Action Retaliated Against In Count 3 and 4
4. On March 9th, 2024, mistypro2 and Just_Dapper both raised issues and concerns
about the National Guard’s administration regarding the promotion of another individual. In this
conversation, both individuals raised concerns of free-ranking and political posturing by
Defendants BrandonnLUV and RoyaltySyn. Both individuals would soon be terminated from
service as a constructive dismissal.
Particulars As To State Laws Violated In Count 3 and 4
5. A state employee is to be “protected against arbitrary action” against them. 2 R.
Stat. § 3219(i). An adverse action is arbitrary if it “takes no accounting of mitigating factors,
circumstances, or liabilities.” The State alleges that Defendants BrandonnLUV and RoyaltySyn
March 9th, 2024 issuance of an at-will termination on Just_Dapper and mistypro2 was done
without any accounting of mitigating factors, circumstances, or liabilities as a separate
transaction of crime to Counts 2 and 5.
6. “Employees should be protected against reprisal for the lawful disclosure of
information which the employees reasonably believe evidences [...] a gross waste of resources,
an abuse of authority.” 2 R. Stat. § 3220. The State alleges that Defendants BrandonnLUV and
RoyaltySyn knowingly issued an at-will termination on Just_Dapper and mistypro2 for internally
making aware a gross waste of resources or abuse of authority in the form of free-ranking
nepotism by the Defendants.
7. “All persons who maintain good behavior shall have the right to employment.” 2
R. Stat. § 4101. “All persons shall have the right to seek review from the courts over prejudicial
or harmful practices relating to their employment.” 2 R. Stat. § 4103. “All persons shall have the
right to report misconduct, harassment, waste, fraud, or abuse.” 2 R. Stat. § 4106. The State
alleges that Defendants BrandonnLUV and RoyaltySyn knowingly issued an at-will termination
on Just_Dapper and mistypro2 while maintaining good behavior while reporting waste of
resources and misconduct.
Respectfully Submitted,
/s/ RyanJSyndicate
Assistant Attorney General
Office of Government Affairs
Ridgeway Department of Justice
