THE STATE OF RIDGEWAY
IN THE SUPERIOR COURT OF RIDGEWAY
takosull0,
Petitioner,
v.
axcurxd, in his official capacity as a law
enforcement officer in the Ridgeway Sheriff’s
Office, pursuant to 7 R. Stat. § 133.002.
Respondent.
Hon. AlbertWellesley
Case No.: RSC-CV-8627
PETITIONER'S REPLY IN SUPPORT OF FIRST AMENDED PETITION FOR
HABEAS CORPUS AND OPPOSITION TO RESPONDENT'S BRIEF
Petitioner takosull0, proceeding pro se, respectfully submits this Reply in Support of his
First Amended Petition for Habeas Corpus and in Opposition to Respondent's Brief in
Opposition ("Resp. Br."). Respondent's Brief does not rebut the Petition; it misstates the record,
cites a source it never bothers to date, and asks this Court to excuse an unlawful arrest because
the Petitioner "looked guilty" on video. None of that answers the only question that matters at
step one of Zachcasisbeast: were R.C.C. §§ 5.13 and 5.14 actually, lawfully, codified offenses
on August 17, 2026. They were not, and Respondent's own exhibits confirm it.
I. RESPONDENT'S ZACHCASISBEAST ANALYSIS SKIPS THE ACTUAL
THRESHOLD QUESTION
1. Respondent devotes the bulk of its brief, ¶¶ 10–14, to arguing that Petitioner drove
recklessly and had his lights and siren “activated.” That analysis answers nothing, because it
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assumes the very premise in dispute: that R.C.C. §§ 5.13 and 5.14 were lawful, existing offenses
in the first place.
2. Even assuming, as Respondent suggests in Resp. Br. ¶ 12, that the Court should
conduct a hypothetical trial on the premise in dispute, the evidence clearly shows that
Respondent is mistaken. Respondent alleges that because of the foregoing actions demonstrated
by Exhibit A, a “well-informed jury … [would conclude that] … Petitioner drove in a manner
which disregarded the safety of persons and property in his vicinity.” This is not the case,
simply because there were no persons or property remotely within his vicinity. The standard
duty of care of persons and property around the Petitioner only applies if there is actually a
person or piece of real property in the vicinity, which there clearly is not.
3. Additionally, a “well-informed jury” would be provided with the exact and correct
governing authority, not left with ambiguity. Therefore, the jury would be informed that the
alleged R.C.C. §§ 5.13 and 14 are constituted in violation of 6 and 7 of the act. "For purposes of
this hypothetical, Petitioner will use Respondent's suggested citations. For the citation of the
R.C.C. statutes, I will use the link provided in Resp. Br. ¶ 15; and for the Act itself, Petitioner
will use the Senate Trello as suggested in Resp. Br. ¶ 18. Thus, under the circumstances
provided by the Respondent themself, the jury would be informed as follows:
a. R.C.C. § 5.13 – “Whoever installs, displays, or activates an emergency
lighting system on a vehicle without authorization granted under the Security Company
Emergency Lighting Act of 2026, or in violation of Section 6 or Section 7 of that Act.”
b. R.C.C. § 5.14 – “Whoever utilizes a siren without specific authorization
granted under Section 6(d) of the Security Company Emergency Lighting Act of 2026,
or who activates an authorized siren in violation of Section 6(d)(ii) of that Act.”
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c. S12-01 Section 6 –
(a) “DEFAULT RESTRICTION TO WARNING LIGHTING.—A security
company authorized under Section 5 of this Act shall be restricted to the
use of warning lighting only, unless separately authorized to use red and
blue lighting under subsection (b) of this section.”
(b) Paraphrased – The State Police Colonel and Attorney General may jointly
authorize a security company to use red and blue lighting. This additional
authorization is required specifically for red and blue lights.
(c) Paraphrased – Security employees must complete an approved
emergency vehicle operation course before operating vehicles with
red/blue lights or authorized sirens.
(d) “PROHIBITION ON SIRENS.—No security company or security officer
shall utilize a siren, or any device emitting a sound pattern substantially
similar to a siren used by law enforcement or emergency service vehicles,
absent specific written authorization from the Colonel of the State Police
and the Attorney General.
(i) An authorization granted under this subsection shall specifically
identify the security company so authorized, and shall be included
within the public notice required under Section 5(c) of this Act.
(ii) A siren authorized under this subsection shall only be activated
during a genuine emergency, or when the security officer
operating the vehicle has been paged or otherwise summoned by
an on-duty peace officer. “
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d. S12-01 Section 7 –
(a) “AUTHORIZED USES.—A security officer may activate an emergency
lighting system authorized under this Act only for the following
purposes:
(i) To warn approaching motorists of a disabled vehicle, roadway
hazard, or ongoing security operation;
(ii) To facilitate the safe movement of a vehicle escort or convoy for
which the security company has been lawfully retained; or
(iii) To render aid at the scene of a collision or emergency, pending the
arrival of law enforcement or emergency services.”
(b) “PROHIBITED USES.—No security officer shall activate an emergency
lighting system for the purpose of initiating a traffic stop, compelling
another vehicle to yield or stop, or otherwise exercising any authority
reserved to a peace officer under any Chapter of the Ridgeway Criminal
Code or Ridgeway Vehicle Code.
4. The hypothetical jury would then consider the facts presented by evidence and weigh
it with the provided law. For Count 1, Unauthorized Use of Emergency Lighting by a Security
Company; contrary to RCC § 5.13, one (1) of the following elements would need to be met:
a. The Petitioner installed an emergency lighting system on a vehicle without
proper authorization granted. Not guilty; no facts have been established that the
Petitioner modified the vehicle he was driving at the time of incident.
b. The Petitioner displayed or activated an emergency lighting system (“ELS”)
without proper authorization granted. Admittedly, a misinformed jury might
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incorrectly conclude that the Petitioner did in fact display and activate their ELS
without proper authorization. However, because the jury would be
“well-informed” they would know that Section (6) of S12-01 states “a security
company … shall be restricted to the use of warning lighting only, unless
separately authorized to use red and blue lighting,” which would bring the jury to
the conclusion of law that the ELS the Petitioner had activated at the time of the
incident was not red and blue lighting, but rather green and white lighting; i.e.,
'warning lighting,’ and thus in compliance with this section. Furthermore, the
other possibility of violation comes from Section (7)(a) if the Petitioner was not
warning “approaching motorists of a disabled vehicle, roadway hazard, or
ongoing security operation,” [(a)(i)] was not facilitating “the safe movement of a
vehicle escort or convoy for which the security company has been lawfully
retained,” [(a)(ii)] was not rendering “aid at the scene of a collision or
emergency, pending the arrival of law enforcement or emergency services,”
[(a)(iii)] or activated an ELS for the purpose of initiating a traffic stop,
compelling another vehicle to yield or stop, or otherwise exercising any authority
reserved to a peace officer under any Chapter of the Ridgeway Criminal Code or
Ridgeway Vehicle Code [(b)]. However, given that multiple security officers
were in Petitioner's vehicle, a reasonable and well-informed jury would conclude
that a security operation was occurring, bringing the conduct within the
protection of Section 7(a)(i) and leading to a verdict of not guilty on this element
as well.
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c. The Petitioner was in violation of Section 6 under the Security Company
Emergency Lighting Act of 2026. As previously stated in ¶¶ 4(a) and (b), a jury
would find that this section was not violated.
d. The Petitioner was in violation of Section 7 under the Security Company
Emergency Lighting Act of 2026. As previously stated in ¶¶ 4(a) and (b), a jury
would find that this section was not violated.
5. Therefore, because a reasonable and well-informed jury would come to the conclusion
that FOUR (4) different elements under one (1) law were not violated, a hypothetical conviction
on Count 1 would be virtually impossible.
6. Secondly, for Count 2, Reckless Driving; contrary to RVC § 3.01, one (1) of the
following elements would need to be met:
a. The Petitioner committed three (3) or more traffic infractions within a timespan
of sixty (60) seconds or less. While Petitioner does not dispute that a jury could
find he was (1) speeding, (2) disobeying a stop sign, and (3) swerving into the
other lane after turning onto Alder Mtn. Road, Petitioner submits that a
reasonable jury would most likely conclude that speeding on a secluded
backroad with no other vehicles present, and swerving into the other lane for a
split second while checking behind him after hearing sirens; consistent with the
duty to yield to emergency vehicles under R.V.C. § 2.10, was not reckless. The
attempt to yield even supports an act of care. Thus, the jury would return a
verdict of not guilty.
b. The Petitioner drove in a manner which disregarded the safety of persons or
property in their vicinity. Because no persons or real property were remotely
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close to the Petitioner’s vicinity, a reasonable jury would come to the legal
conclusion of not guilty.
7. Therefore, because a reasonable and well-informed jury would come to the conclusion
that every element under the statute was not violated, a hypothetical conviction on Count 2
would be virtually impossible.
8. Lastly, for Count 3, Unauthorized Use of a Siren by a Security Company; contrary to
RCC § 5.14, one (1) of the following elements would need to be met:
a. The Petitioner utilized a siren without specific authorization granted under
Section 6(d) of the Security Company Emergency Lighting Act of 2026. Because
the video evidence shows the Petitioner never once activated his siren, any jury
would come to the obvious conclusion of not guilty.
b. The Petitioner activated an authorized siren in violation of Section 6(d)(ii) of the
Security Company Emergency Lighting Act of 2026. As stated previously in ¶
7(a), the Petitioner never once activated his siren, nor was any siren on the
vehicle Petitioner was operating authorized; not guilty.
9. Therefore, because the Petitioner never once activated his siren, a reasonable and
well-informed jury would come to the conclusion that every element under the statute was not
violated, a hypothetical conviction on Count 3 would be virtually impossible.
10. Due to the foregoing reasons provided in ¶¶ 3–8, a reasonable and well-informed
jury would come to a verdict of not guilty on every charged offense. This, applying the
Zachcasisbeast test, proves Petitioner's innocence and further contradicts Resp. Br. ¶ 14.
11. Finally, even if the Court were to consider the premise in dispute rather than ignore
it, and apply the Zachcasisbeast test to it, that analysis leads to only one conclusion: the Petition
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should be granted . Zachcasisbeast's first prong asks whether the arrest was lawful, i.e., whether
the officer was legally entitled to make it. An arrest for violation of a non-existent, non-codified
offense is unlawful at that first prong as a matter of law. It does not matter how the Petitioner
drove, how his lights looked in third-person view, or how compelling the video is: none of that
can retroactively legislate an offense into existence. Respondent cannot skip to “was the
Petitioner obviously guilty” without first establishing that there was a codified crime to be
guilty of.
12. Petitioner accordingly renews his request that Counts 1 and 3 be found unlawful at
step one of Zachcasisbeast, and states that Respondent's step-two arguments are premature.
II. RESPONDENT MISREPRESENTS THE RECORD — PETITIONER RELIED
ON THE CURRENT, OFFICIAL CODE OF STATUTES, NOT AN "OUTDATED
SPREADSHEET"
13. Respondent's entire due-process argument (¶¶ 15–20) rests on a single factual claim:
that "Petitioner's Exhibit B is an outdated spreadsheet." Resp. Br. ¶ 16. That claim is false, and
the record Respondent itself relies on proves it false.
14. There were, in fact, two documents in circulation. The first, a legacy sheet, is titled
on its own landing page “[OUTDATED] Ridgeway Code of Statutes” and displays, in large red
block lettering, the warning “CAUTION THIS SHEET IS OUTDATED. NEW SHEET: 2026
Ridgeway Code of Statutes,” with a direct link to its replacement.
15. Petitioner did not cite that document. Petitioner's Exhibit B is the very replacement
that landing page directs readers to — the “2026 Ridgeway Code of Statutes.” That document's
own cover page states it is the official “STATE OF RIDGEWAY STATE CODE OF
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STATUTES,” and expressly identifies itself as “MAINTAINED BY THE RIDGEWAY
DEPARTMENT OF STATE, SECRETARY OF STATE ROBLOXRULES756,” the individual
who holds that office as of the filing of this Reply. It carries no red banner, no caution notice, no
watermark, and no cross-reference indicating that it, too, had been superseded. Thus, any
reasonable person would conclude that Exhibit B is the current, controlling document: the
outdated sheet is conspicuously marked as superseded, while Exhibit B carries no such notice,
and that contrast alone would lead a reasonable reader to treat Exhibit B as correct.
16. Respondent's counsel had access to the same public record Petitioner did. Counsel's
representation to this Court that Petitioner relied on an outdated document, when the document
actually cited is the Department of State's own current, self-designated “official” compilation, is
either the product of a failure to verify the record before signing a brief, or a deliberate
misstatement to this Court. Petitioner respectfully requests that the Court disregard ¶¶ 15–16
and 24 of Respondent's Brief accordingly.
III. RESPONDENT OFFERS NO EVIDENCE THAT THE LEGISLATURE'S
WEBSITE ACTUALLY CONTAINED THESE OFFENSES ON THE DATE OF
ARREST
17. Respondent's Brief cites a bare hyperlink ("See here") as proof that R.C.C. §§ 5.13
and 5.14 were "in-fact codified into State law." Resp. Br. ¶ 15. That link resolves only to the
RCS homepage at legislature.rummytech.org/statutes, a landing page inviting the reader to
browse by Title or search by citation. It is not a citation to the actual text of § 5.13 or § 5.14, and
it carries no timestamp, no version history, no "last updated" date, and no indication of what the
site displayed, if anything, on August 17, 2026.
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18. A link to a search homepage is not evidence that a specific offense existed in a
specific form on a specific date. Respondent could have pulled the actual statutory text of §§
5.13 and 5.14 as they purportedly read on the date of arrest and attached it as an exhibit.
Respondent did not do so. Instead, Respondent points this Court to a homepage as it exists
today, following the arrest, and asks the Court to assume retroactively that the offenses were
there all along.
19. The burden of proving that a criminal statute was validly enacted and codified before
it was enforced against a citizen falls on the government, not the citizen. An undated link to a
search portal, offered for the first time in an opposition brief, does not satisfy that burden. If
Respondent has an archived, dated capture of § 5.13 and 5.14 as they appeared in the RCS on
August 17, 2026, Respondent should produce it. It has not.
IV. A DISCORD MESSAGE ANNOUNCING FUTURE CHANGES IS NEITHER
CODIFICATION NOR FAIR NOTICE
20. In Resp. Br. ¶¶ 17–19, Respondent alleges that Petitioner did receive a fair warning
of the offenses charged. Respondent states that Petitioner made a mistake of law and admits that
it would in fact survive if the code of statutes did not contain these charges. Resp. Br. ¶ 17.
Further, in ¶ 18, Respondent claims that the “Government has done its due diligence and
informed the State of newly signed laws, by updating the code of statutes, adding it to the
official Senate Trello and Database, and publicly announcing them in community Discord
servers.” Lastly, in ¶ 19, Respondent sarcastically expressed that the “Petitioner cannot expect
the Government to personally DM him every time a new law is implemented.”
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21. In regard to Resp. Br. ¶ 18, where the Respondent claims that the Government has
done its due diligence and informed the State of newly signed laws, by updating the Code of
Statutes.” Petitioner finds that to be false. “State” refers to the State as a whole, including the
Department of State. As already expressed in ¶ 12, the code of statutes used in Exhibit B is
labeled as “MAINTAINED BY THE RIDGEWAY DEPARTMENT OF STATE, SECRETARY
OF STATE ROBLOXRULES756,” therefore leading any reasonable person to believe that this
is the current updated code of statutes. The State inherently knows this as well, which is why it
marked the outdated sheet, as discussed in ¶ 13, as outdated, thereby providing adequate notice.
22. In further regard to Resp. Br. ¶ 18, the Respondent claims that the Government
provided notice through Discord. However, ignoring the Respondent’s lack of citation, the
Petitioner attempted to find such alleged notice. Petitioner could not, except for one message
from Chief Justice imnotRummy on July 25, 2026. Exhibit E. First, the message defeats itself
on its own terms. It states that the new Code of Statutes will “also be reflected in game” only
“in the coming days.” An announcement that enforcement mechanisms will be updated at some
future point is an admission that they were not updated at the time of posting; let alone by
August 17, 2026, the date of Petitioner's arrest. Second, a message directed “to courts of the
State of Ridgeway,” instructing the judiciary which webpage to treat as controlling, is a judicial
administrative directive, not an act of codification. Codification is a legislative and executive
act, the passage and publication of law in the official statutory compilation; not a chat message
telling judges what to cite. Third, and dispositively, due process requires notice reasonably
calculated to reach the people bound by the law: the citizenry, not merely the bench. A message
buried in a government-updates channel of a Discord server, addressed to courts, is not
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constitutionally adequate notice to Petitioner or any other private citizen under Rogers v.
Tennessee, 532 U.S. 451 (2001), the very case Respondent cites in its own brief. Resp. Br. ¶ 15.
V. RESPONDENT'S “CHECK TRELLO AND DISCORD” ARGUMENT
INVERTS THE BURDEN OF DUE PROCESS
23. Respondent argues that Petitioner “cannot expect the Government to personally DM
him every time a new law is implemented,” Resp. Br. ¶ 19, and that notice was adequate
because it was posted “on the official Senate Trello and Database” and “publicly announc[ed] in
community Discord servers.” Resp. Br. ¶ 18. Petitioner has never demanded a personal DM.
Petitioner demands only that the single document the Department of State itself designates as
“the official and controlling compilation of the statutory law of this State,” maintained by the
sitting Secretary of State and bearing no notice of its own obsolescence, actually contain the law
it claims to compile.
24. That is not an unreasonable burden to place on a citizen. It is the floor, not the
ceiling, of what due process requires of a government before it deprives someone of liberty.
Respondent's position: that citizens must independently cross-reference Trello boards and
monitor multiple Discord servers in real time to determine whether the State's own official code
is complete, is precisely the kind of arbitrary enforcement the Due Process Clause exists to
prevent."
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CONCLUSION
25. Respondent has not rebutted the Petition. Respondent has misrepresented which
exhibit Petitioner relies on, mistaken a private Discord announcement for codification, offered
an undated hyperlink as proof of a fact it must independently establish, and skipped the
threshold legal question in favor of relitigating the facts of an arrest that should never have been
made. For these reasons and those set forth in the Amended Petition, Petitioner respectfully
requests that this Court GRANT the Petition as to Counts 1 and 3, DECLARE the arrest and
detention as to those counts unlawful, and reach the merits of the equitable relief requested
therein.
Respectfully submitted,
/s/ takosull0
Petitioner Pro Se
INDEX OF EXHIBITS
Exhibit E — Evidence of the Petitioner being arrested, dated August 19, 2026.
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