Ridgeway Unified Courts

JUDICIAL COUNCIL OF RIDGEWAY

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THE STATE OF RIDGEWAY RIDGEWAY SUPERIOR COURT UN91570135 (formerly known as nyyple), Plaintiff, v. Noobynoob6666 (otherwise known as SebastianDonovan), Patrol Officer in the Palmer Police Department, in his quasi-official capacity. Defendant. Case No. RSC-CV-3009 CIVIL COMPLAINT Presiding Judge: siteowner Plaintiff UN91570135, formerly known as nyyple, (“Plaintiff”), by and through her undersigned counselors, hereby brings this action against Defendant Noobynoob6666, otherwise known as SebastianDonovan, (“Defendant”) in his individual and official capacity and to substantiate her action alleges the following: STATEMENT OF FACTS 1. On or about June 7th, 2024, Plaintiff was driving a taxi in Palmer in a commercial plaza. 2. While the Plaintiff was driving through the commercial plaza at approximately 20MPH, a car accident with a taxi and Credit Union Security vehicle occurred to their right. 3. After driving forward, a third-party witness exits the Sheriff’s car and the Plaintiff proceeds on with driving. 4. After making a right turn, the Plaintiff stops to ensure there’s no law enforcement vehicles pulling her over. 5. After making a second right turn, behind the commercial plaza (and after noticing a Sheriff’s car following right behind her), the Plaintiff immediately yields to law enforcement and remains seated in their vehicle. 6. Defendant exits their car and immediately detains the Plaintiff stating “That’s a hit and run charge.” 7. Defendant drives the Plaintiff over for an arrest, with the Plaintiff responding with “I’m calling my lawyer.” 8. Following that statement, the Plaintiff then states “Wait, but I didn’t run”, followed by, “I pulled over.” VENUE 9. This Court has original jurisdiction over this Complaint under Article V, Section IV of the Ridgeway Constitution; “There shall be a Superior court which shall exercise original jurisdiction for all civil and criminal cases…” 10. Venue is proper as the actions occurred within Ridgeway County, which is a county located in the State of Ridgeway. PARTIES 11. Plaintiff UN91570135, is a citizen and resident of the State of Ridgeway. 12. Defendant Noobynoob6666, is a citizen and resident of the State of Ridgeway and a Patrol Officer with the Palmer Police Department. FIRST CAUSE OF ACTION 1 R. Stat § 3104 False Imprisonment Against Defendant Noobynoob6666 13. Plaintiff incorporates the allegations within all prior paragraphs within this Complaint as if they were fully set wherein. 14. Whereas, the Ridgeway Constitution protects citizens against deprivation of liberty without due process, stating “...nor can any person be justly deprived of liberty…” Rid. Const. Art. I, Sec VI; 15. Whereas, false imprisonment is defined in 1 R. Stat § 3104 as “without legal authority or justification, restrains or restricts a person's movement within an area”; the Defendant, without legal authority or justification, restrained the Plaintiff’s movement by detaining and then sentencing her to jail for an alleged “hit-and-run” offense. SECOND CAUSE OF ACTION 1 R. Stat § 3114 Official Misconduct Against Defendant Noobynoob6666 16. Plaintiff incorporates the allegations within all prior paragraphs within this Complaint as if they were fully set wherein. 17. Whereas, State law protects citizens from being victims of Official Misconduct; 18. Whereas, Official Misconduct is defined in 1 R. Stat § 3104 as “Any individual who is a public servant and commits an act relating to his office but constitutes an unauthorized exercise of his official functions, where a reasonable person with his training, expertise, and experiences should know that such act is unauthorized; or refrains from performing a duty which is imposed upon him by law or is clearly inherent in the nature of his office.” 19. Defendant, exercising his official functions in an unauthorized manner, detained Plaintiff and then violated Plaintiff’s rights to liberty by falsely imprisoning her. Defendant should have been aware of this due to his LETC certification. PRAYERS FOR RELIEF WHEREFORE, the Plaintiff prays for judgment against Defendant as follows– A. Plaintiff requests six thousand dollars ($6000) in punitive damages B. For declaratory judgment that Defendant’s conduct was an unauthorized exercise of his official functions and exceeded the scope of their authority under law and department policy. C. For such other, or further, or different legal and equitable relief the Court may deem necessary. CENTER FOR INDIVIDUAL RIGHTS /s/______________________ Singhski, Esq. Ridgeway Bar No.25100 Counsel of Record President, Center for Individual Rights T: (505) 503-4455 E: [email protected] D: singhski

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