IN THE SUPERIOR COURT OF RIDGEWAY
FOR THE STATE OF RIDGEWAY
HALO4ASIN,
Plaintiff,
v.
RIDGEWAY COUNTY SHERIFF’S
OFFICE;
ERRCORE, in his official capacity;
AZAP634, in his official capacity,
Defendant.
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Case No. RSC-CV-5191
RESPONSE
PLAINTIFF’S RESPONSE REGARDING THE DESIGNATION OF CLASSIFIED
INFORMATION AND THE NOTICE REQUIRED BY 9 R. STAT. SECTION 122.208(b)
Plaintiff respectfully submits this response concerning the Defendants’ designation of material as
classified, and the notice required by 9 R. Stat. Section 122.208(b) before an in camera hearing is
conducted.
I. THE NOTICE REQUIRED HAS NOT BEEN PROVIDED
1. On August 6, 2026, the Court directed the Defendants to “provide the plaintiff notice of
what you’re contending is classified,” and to “just list what the document pertains to.”
2. Section 122.208(b) provides that “[b]efore any hearing is conducted pursuant to the
request of the State of Ridgeway, the State of Ridgeway shall provide the defendant with
notice of the classified information that is at issue, identifying the specific classified
information at issue whenever that information previously has been made available.”
Where the information has not been provided, the notice “may describe by generic
category, in such form as the court may approve.”
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3. Plaintiff has received no such notice, in either form. The only statement of record is
counsel’s assertion that Plaintiff’s “list of questions to be answered requests confidential
SECRET information,” made without identifying which question, or what category of
information any question is said to reach.
4. Plaintiff has served thirteen interrogatories. A blanket assertion across all of them does
not permit Plaintiff to respond, to narrow a question, or to withdraw one. Nor does it
permit the Court to make the item by item determination that Section 122.208(a) requires,
which provides that “[t]he court shall issue a determination in writing for each item of
classified information.”
II. PLAINTIFF DOES NOT OPPOSE THE PROCEDURE, ONLY ITS OMISSION
5. Plaintiff does not oppose in camera review, has said so on the record, and does not seek
public disclosure of any material the Court determines to be sensitive. Plaintiff has
offered production under seal and has offered to accept a summary under Section
122.208(c) where the Court finds a summary provides substantially the same ability to
present his case.
6. Plaintiff asks only that the notice the statute requires precede the determination, so that he
may be heard on which items are genuinely at issue.
III. THE SCOPE OF THE ASSERTION
7. Plaintiff notes that the substance of his interrogatories concerns the reasons for the denial
of his own application: which factors were relied upon, who evaluated them, what
evidence supported them, and what was communicated to him. The Defendants have
already produced a sworn transcription describing those factors. It is unclear what
remains classified once that document has been produced, and the notice required by
subsection (b) would resolve that question.
8. Plaintiff further notes, without objection to the hearing, that Section 122.208 is framed in
terms of protections running to a defendant in a criminal proceeding, and that its
procedures are designed to secure the accused’s ability to make a defense rather than to
limit a civil plaintiff’s discovery.
IV. RELIEF REQUESTED
WHEREFORE, Plaintiff respectfully requests that the Court direct the Defendants to provide the
notice required by Section 122.208(b), identifying by item or by generic category the material
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contended to be classified, prior to or in connection with the Court’s determination; and that the
Court issue its written determination for each item as Section 122.208(a) provides.
CERTIFICATE OF SERVICE
I certify that on this date a true copy of the foregoing was served on counsel for the Defendants
by electronic means through the case channel and e-filing system.
Respectfully Submitted,
_________________________
/s/ Halo4asin
HALO4ASIN
Plaintiff, Pro Se
Ridgeway State Bar License No. 18110
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