In the Superior Court of
the State of Ridgeway
Robin5D,
Plaintiff,
v.
drjack0, in their official capacity as Director
of the Law Enforcement Training Center,
Defendant.
Case No. RSC-CV-3343
Complaint in a Civil Action
Hon. Judge t1dtony
Plaintiff Robin5D, in pro per, alleges, for their complaint against the defendants, as follows:
PARTIES
1. Plaintiff Robin5D is a resident of the State of Ridgeway.
2. Defendant drjack0 is a resident of the State of Ridgeway, and the Director of the Law En-
forcement Training Center as appointed by Developer Oversight.
JURISDICTION AND VENUE
3. Plaintiff invokes the jurisdiction of the Superior Court contained in Article V, Section IV
of the state Constitution, giving jurisdiction for “all civil or criminal cases.”
4. Venue is proper as the conduct involved took place within Ridgeway County, State of
Ridgeway.
ESSENTIAL FACTS
5. On or around July 20th, 2024, Plaintiff applied for entry into the Law Enforcement Training
Center’s (hereinafter LETC) training program; specifically, Class 14.
6. By July 24th, 2024, Plaintiff’s “primary screening” and application overall had been ac-
cepted by the Admissions Office of the LETC. However, on or around that date, Plaintiff’s
“applicant screening” was denied.
7. The “applicant screening” phase of LETC’s admissions process does not publicly or pri-
vately disclose reasons for denial at this stage, nor are the results appealable or correctable
by LETC personnel.
8. Given this set of facts, on July 27th, 2024, Plaintiff attempted to file a Freedom of Informa-
tion request under the Information Classification Act (S6-73) to LETC. However, LETC
has no appointed Freedom of Information Officer.
9. As there was no Freedom of Information Officer to make requests available to, Plaintiff
forwarded his request to Defendant in writing through Discord direct messaging on the
aforementioned date.
10. Later that same day, Defendant responded to the request, failing to comply with it, simply
stating: “We do not disclose reasoning for background investigation results, apologies.”
Law Offices of Legacy Legal Group, LLC.
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COUNT 1
1 R. Stat. § 3114 - Official Misconduct
11. Plaintiff incorporates all prior paragraphs of this complaint as part of this cause of action.
12. 1 R. Stat. § 3114 defines official misconduct as “Any individual who is a public servant
and . . . refrains from performing a duty which is imposed upon him by law or is clearly
inherent in the nature of his office.”
13. The Information Classification Act, section 15 states “Every Government Department or
Agency, including that of the judicial and legislative bodies of the State, shall retain a
civilian employee, or designate an existing officer or employee, to serve as a Freedom of
Information Officer.”
14. LETC, under 2 R. Stat. § 6401, is defined as a “government agency.”
15. The Information Classification Act prescribes a duty to LETC, and by extension the De-
fendant, to retain a Freedom of Information Officer.
16. LETC has not, in the two months since the passage and signing of the Information Clas-
sification Act, retained a Freedom of Information Officer.
17. Plaintiff has suffered concrete injury as a result of the Defendant’s failure to appoint
a Freedom of Information Officer, including the deprivation of his legal right to both
request information and have said request complied with under the Information Classi-
fication Act, section 16.
COUNT 2
1 R. Stat. § 3115 - Deprivation of Rights
18. Plaintiff incorporates all prior paragraphs of this complaint as part of this cause of action.
19. 1 R. Stat. § 3115 defines deprivation of rights as “Every person who, under color of any
statute, ordinance, regulation, custom, or usage, subjects, or causes to be subjected, any
citizen of the State of Ridgeway or other person within the jurisdiction thereof to the de-
privation of any rights, privileges, or immunities secured by the Constitution and laws.”
20. As previously established, LETC has a duty to retain a Freedom of Information Officer
and comply with requests under the Information Classification Act.
21. LETC, and by extension Defendant, deprived Plaintiff of his legal right to request infor-
mation and have said request complied with under the Information Classification Act,
section 16.
Law Offices of Legacy Legal Group, LLC.
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PRAYER FOR RELIEF
WHEREFORE, Plaintiff prays that the Court–
22. As to counts 1 and 2, award Plaintiff injunctive relief in the form of an order compelling
LETC and the Defendant to—
a. retain, within a reasonable timeframe to be determined by this Court, a Freedom
of Information Officer, and
b. for said appointee to comply with and respond to Plaintiff’s Freedom of Informa-
tion request.
Dated this 29th day of July, 2024.
Respectfully submitted,
Robin5D
Robin5D, Esq.
R. Bar No. 28105
D: @checkraisefold
Legacy Legal Group, LLC.
Law Offices of Legacy Legal Group, LLC.
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In the Superior Court of
the State of Ridgeway
Robin5D,
Plaintiff,
v.
drjack0, in their official capacity as Director
of the Law Enforcement Training Center,
Defendant.
Case No. RSC-CV-3343
Complaint in a Civil Action
Hon. Judge t1dtony
INITIAL DISCLOSURE
Plaintiff Robin5D, in pro per, submits this document in the aforementioned matter, pursuant to
Rid. Civ. P. 19.
INITIAL DISCOVERY
Plaintiff submits the following articles as initial discovery as to the tortious claims listed within
the civil complaint, pursuant to Rid. Civ. P. 19:
1. Exhibit A - Direct message history between Plaintiff and Defendant.
2. Exhibit B - Freedom of Information request submitted by Plaintiff.
WITNESSES
Plaintiff submits the following articles as their witnesses as to the tortious claims listed within
the civil complaint:
1. Robin5D - Lay Witness
2. drjack0 - Lay Witness
Dated this 29th day of July, 2024.
Respectfully submitted,
Robin5D
Robin5D, Esq.
R. Bar No. 28105
D: @checkraisefold
Legacy Legal Group, LLC.
Law Offices of Legacy Legal Group, LLC.
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