RSC-CV-8427 | Defendant Rashhyyyy | Corrected Reply Page 1
THE STATE OF RIDGEWAY
RIDGEWAY SUPERIOR COURT
THR33SIX8, an individual,
Plaintiff,
v.
ALBERTWELLESLEY, in his official capacity as associate director of the Ridgeway State Bar;
RASHHYYYY; and COMPLAINAINTS, pseudonymous defendants.
Defendants.
RSC-CV-8427
DEFENDANT RASHHYYYY'S REPLY IN SUPPORT OF AMENDED MOTION
TO DISMISS
AND NOTICE OF CORRECTED SUPPLEMENTAL EVIDENCE
Presiding Judge: Hon. Arthur_Chen
Defendant: rashhyyyy, pro se
Defendant Rashhyyyy respectfully submits this Reply in further support of the Amended Motion to Dismiss (Doc. 8) and in
response to Plaintiff's Opposition (Doc. 9). This corrected filing supersedes the prior version of Defendant's reply for
purposes of identifying supplemental evidence and citations. It removes unsupported statutory references and does not
assign an exhibit number to the separately identified clip unless the Court has already assigned one.
INTRODUCTION
Plaintiff's Opposition attempts to reduce the disciplinary history to the proposition that Rashhyyyy's July 28 report was the
“direct trigger” and “direct catalysator” of Plaintiff's suspension and resulting losses. Plaintiff's own pleading does not
establish that proposition. The Amended Complaint alleges that the State Bar received evidence from three complaints,
including separate material from two other complainants. Am. Compl. ¶¶18–23.
The Amended Complaint further alleges that the State Bar later investigated multiple alleged violations and that additional
clips and the RSC-CV-3576 summons were presented during the investigation. Am. Compl. ¶¶30–38. The
contemporaneous disciplinary-ticket transcript also records the Board's later statement that it would consolidate the matter
with other complaints, followed by an independent decision to investigate and a later finding of grounds for prosecution.
The corrected supplemental evidence is identified by the Bates number BATES-20260911-2970940998. Defendant does
not label that clip as “Exhibit 16” in this corrected filing.
ARGUMENT
I. PLAINTIFF'S “DIRECT CATALYST” THEORY IS CONTRADICTED BY HIS OWN PLEADING AND
THE BOARD'S DOCUMENTED ACTIONS
Plaintiff repeatedly characterizes Defendant's report as the direct trigger of the interim suspension and all resulting injuries.
But the Amended Complaint itself identifies three complaints and separate evidentiary sources. It specifically alleges that
the Associate Director received evidence from three complaints, identifies Rashhyyyy as the first complainant, identifies a
second complainant's separate statement, and identifies a third complainant's summons and allegations. Am. Compl.
¶¶18–23.
That pleading makes it impossible, on its face, to treat Rashhyyyy's report as the only source of the disciplinary process.
The State Bar later considered multiple allegations and additional evidence. Am. Compl. ¶¶30–38.
The supplemental transcript strengthens this point. On August 10, Board member Kezzera stated that the Board would
“consolidate this with other complaints against thr33six8.” The same ticket later records that a decision had been made to
RSC-CV-8427 | Defendant Rashhyyyy | Corrected Reply Page 2
investigate the attorney, and on August 24 the Board stated that, after investigation, it found grounds for prosecution. Those
are intervening institutional decisions, not an automatic consequence of Defendant's July 28 report.
II. THE TIMELINE FURTHER UNDERMINES PLAINTIFF'S CAUSATION THEORY
The chronology matters. The initial report was made on July 28. Defendant responded to a request for proof, later supplied
a video clip, and separately discussed the Bar Integrity Act on July 30. The ticket then contains a period before the Board's
August 10 consolidation and investigation communications. The Board's formal prosecution decision did not occur until
August 24.
Plaintiff's own pleading also alleges that after the interview the Associate Director told Plaintiff that the Bar would petition
the Supreme Court to disbar him, but later that same day told Plaintiff that his license was no longer on interim suspension.
Am. Compl. ¶¶28–29.
The alleged downstream injuries therefore involve decisions by the State Bar and individual courts after Defendant's report.
Plaintiff does not plead facts establishing that each later consequence was caused by Rashhyyyy rather than by those
intervening decisions.
III. THE FRAUD THEORY DOES NOT IDENTIFY A FALSE STATEMENT IN THE JULY 28 REPORT
Plaintiff's Opposition reframes the fraud claim around an alleged misrepresentation concerning the Bar Integrity Act. The
actual report quoted in the Amended Complaint does not state that the Act applied, does not state an effective date, and
does not say that the report was made after the Act. Am. Compl. ¶19.
The contemporaneous ticket likewise shows the original July 28 report as a factual account of an alleged arrest and firearm
offense. The later discussion of the Bar Integrity Act appears separately on July 30. In that later discussion, Defendant
quoted the statutory language concerning an “ACTIVE CRIMINAL” and argued from the supplied video.
The distinction is critical. A later legal argument about the meaning or application of legislation is not the same statement as
the original factual report. Plaintiff must identify a materially false representation made by Defendant. The quoted July 28
report does not contain the representation Plaintiff now attributes to it.
IV. PLAINTIFF'S RELIANCE ON SEC v. CAPITAL GAINS DOES NOT ESTABLISH A DUTY TO
DISCLOSE
Plaintiff cites S.E.C. v. Capital Gains Research Bureau, 375 U.S. 180, 193 (1963), in support of the proposition that fraud
can involve omissions. Defendant does not dispute that Plaintiff has cited that authority. The problem is that Plaintiff still
must identify the duty that allegedly required Defendant to make the omitted disclosure.
The Opposition does not identify a Ridgeway provision, contractual relationship, fiduciary relationship, or other source
establishing that a private complainant had a legal duty to independently brief the State Bar about legislative timing when
reporting an alleged arrest. Without such a duty, Plaintiff's omission theory is not established merely by calling the omission
fraudulent.
V. THE RECORD DOES NOT SUPPORT THE CLAIM THAT DEFENDANT “DECEIVED” THE STATE
BAR
Plaintiff alleges that Defendant successfully deceived the State Bar. Am. Compl. Tort #5. The chronology does not support
that characterization. Defendant reported the alleged arrest, answered a request for proof by identifying witnesses, later
supplied a video clip, and subsequently made a separate legal argument concerning the Bar Integrity Act.
Most importantly, the State Bar did not simply accept Defendant's report and immediately impose the entire set of
consequences Plaintiff now alleges. Plaintiff's own pleading says the Associate Director received evidence from three
complaints, and the disciplinary process later involved multiple alleged violations and additional evidence. Am. Compl.
¶¶18–23, 30–38.
The ticket then records the Board's own decision to consolidate the matter with other complaints and to investigate it. That
record is inconsistent with the proposition that Defendant secretly controlled or dictated the State Bar's decision.
RSC-CV-8427 | Defendant Rashhyyyy | Corrected Reply Page 3
VI. THE ABUSE-OF-PROCESS CLAIM DOES NOT ESTABLISH AN IMPROPER USE OF PROCESS
Plaintiff alleges that Defendant knew a disciplinary complaint could result in adverse action and characterizes the complaint
as vexatious. But the fact that a complaint may foreseeably lead to an investigation does not itself establish that the process
was used improperly.
The pleaded and recorded conduct shows a complaint to the body responsible for attorney discipline, a response to a
request for proof, later evidentiary material, and subsequent independent Board action. The Amended Complaint does not
establish that Defendant controlled the later proceedings or that the State Bar's process was merely a vehicle for a private
objective of Defendant.
VII. TORTIOUS INTERFERENCE FAILS FOR THE SAME CAUSATION DEFECT
Plaintiff alleges that Defendant's complaint caused the license suspension and prevented Plaintiff from representing clients.
Am. Compl. Tort #4. But the same pleading identifies other complainants, other allegations, additional evidence, a later
investigation, and later judicial decisions affecting individual cases.
Plaintiff lists numerous cases affected during the interim suspension, but does not plead a specific causal connection
between each claimed loss and Rashhyyyy's July 28 report. The intervening decisions of the State Bar and the individual
courts cannot simply be treated as though they were actions taken by Defendant.
VIII. PLAINTIFF'S OWN PLEADING SHOWS THAT THE DISCIPLINARY PROCESS CONSIDERED
MATTERS OTHER THAN RASHHHYYYY'S REPORT
The August 10 notice, as pleaded by Plaintiff, identified five alleged violations. Am. Compl. ¶¶30–35. The later interview
involved additional clips and the RSC-CV-3576 summons. Am. Compl. ¶38. These allegations themselves establish that
the disciplinary process was broader than the single report attributed to Rashhyyyy.
The transcript provides additional contemporaneous confirmation. The Board expressly stated that it would consolidate the
matter with other complaints, then separately announced an investigation and later issued its prosecution decision.
IX. PLAINTIFF'S REQUEST FOR $18,000 IN PUNITIVE DAMAGES SHOULD NOT BE USED TO
RESCUE DEFECTIVE TORT CLAIMS
Plaintiff's Amended Complaint requests $18,000 in punitive damages from Defendant Rashhyyyy. Am. Compl. Prayer ¶3.
The punitive-damages demand cannot establish the missing elements of Abuse of Process, Tortious Interference, or Fraud.
Because the underlying claims fail for the reasons stated above, the punitive request should likewise be dismissed or
denied.
X. CORRECTED SUPPLEMENTAL EVIDENCE
A. Complete disciplinary-ticket transcript
The complete Discord transcript of the #thr33six8-disciplinary-investigation ticket is identified in Defendant's supplemental
filing as Exhibit 15. It records the original report, requests for proof, later video evidence, the July 30 statutory discussion,
and the Board's August 10 and August 24 communications.
B. Video clip — Bates BATES-20260911-2970940998
The video clip previously identified by Defendant is corrected in this filing to the Bates identifier
BATES-20260911-2970940998. Defendant relies on the clip as corroborating evidence relevant to the factual incident and
to the later July 30 discussion recorded in the disciplinary ticket. No exhibit number is assigned to the clip by this filing.
KEY TIMELINE
Date / Time Event
07/28/2026 23:14 Defendant identifies user thr33six8 and Bar No. 19302.
07/28/2026 23:15 Defendant reports the alleged attempted-murder/firearm arrest and states that witnesses can attest to it.
07/28/2026 23:20 When asked for proof, Defendant states that multiple people can attest to the offense.
RSC-CV-8427 | Defendant Rashhyyyy | Corrected Reply Page 4
Date / Time Event
07/29/2026 23:33 Defendant supplies a Medal clip.
07/30/2026 01:48 Defendant separately discusses the Bar Integrity Act and the definition of “ACTIVE CRIMINAL.”
08/10/2026 Board member Kezzera states: “The Board will consolidate this with other complaints against thr33six8.”
08/10/2026 Kezzera states that a decision has been made to investigate the attorney.
08/24/2026 Board decision states that, after investigation, there are grounds for prosecution.
CONCLUSION
Plaintiff's Opposition does not cure the defects identified in Defendant's Amended Motion to Dismiss. Plaintiff's own
allegations establish multiple complaints and multiple sources of evidence; the disciplinary record shows later independent
Board action; and the specific fraud theory concerning the Bar Integrity Act is not supported by the text of Defendant's July
28 report.
The corrected supplemental evidence further demonstrates that the original report did not contain the statutory
representation Plaintiff now attributes to it and that the Board later consolidated the matter with other complaints and
independently investigated it.
REQUEST FOR RELIEF
For the foregoing reasons, Defendant Rashhyyyy respectfully requests that the Court:
1. GRANT Defendant's Amended Motion to Dismiss (Doc. 8);
2. DISMISS the claims asserted against Rashhyyyy for Abuse of Process, Tortious Interference, and Fraud, to the extent
dismissal with prejudice is authorized by the Court's rules;
3. DISMISS or strike Plaintiff's punitive-damages demand against Rashhyyyy to the extent permitted by the Court's rules;
and
4. CONSIDER the supplemental disciplinary-ticket transcript and the video identified by Bates No.
BATES-20260911-2970940998 in resolving the pending motion, subject to the Court's rules governing supplemental
evidence.
Respectfully submitted,
/s/ rashhyyyy
Rashhyyyy
Defendant, pro se
Dated: September 11, 2026
