IN THE SUPERIOR COURT OF RIDGEWAY
FOR THE STATE OF RIDGEWAY
HALO4ASIN,
Plaintiff,
v.
RIDGEWAY PARKS SERVICE,
Defendant.
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Case No. RSC-CV-0750
PLAINTIFF’S SUPPLEMENTAL
MOTION
PLAINTIFF’S SUPPLEMENTAL MOTION FOR LIMITED DISCOVERY,
PRESERVATION, PROTECTIVE RELIEF, AND LEAVE TO SUPPLEMENT
Plaintiff Halo4asin, appearing pro se, respectfully moves for narrowly tailored relief concerning
Defendant’s post order Final Outcome determination. The present record shows that the court
ordered background reevaluation ultimately resulted in a passed Final Screening, followed by a
separate failed Final Outcome. Defendant later attributed that final denial to 4 R. Stat. §
121.102(e), stating only that Plaintiff’s “character outweighs any other merits demonstrated.”
New circumstantial evidence raises a substantial question as to who authored or entered that
rationale and whether it was the contemporaneous basis for the denial. Plaintiff therefore seeks
preservation and limited production before requesting any final finding of retaliation, bad faith,
or official misconduct.
I. RELEVANT PROCEDURAL HISTORY
1. On August 20, 2026, the Court granted Plaintiff’s motion for partial summary judgment
in part, ordered Defendant to vacate the prior “Failed” Final Screening result, and
directed Defendant to reevaluate Plaintiff’s application, particularly the background
investigation, in conformity with 4 R. Stat. § 122.402 within seven days.
2. The Court had previously held, in its July 11, 2026 ruling, that when RPS publicly posts a
background based denial it has chosen the moment of denial, and the reasoning required
by § 122.404 must be supplied at that moment rather than later.
3. During the ordered reevaluation, Application Coordinator BobbyBobitheBobbian, whose
Discord username was identified to Plaintiff as lspdunit234, advised Plaintiff on August
21 that the previously appealed RCFD warnings would be disregarded. After Plaintiff
supplied evidence that the remaining moderation issue had been appealed, the coordinator
stated: “for now I see no reason to not pass you,” and then stated that the matter would be
handed to Superintendent ItzCrazyAaron.
4. The application tracker subsequently reflected Plaintiff’s Final Screening as Passed while
the Final Outcome was Failed.
5. On September 13, 2026, Plaintiff separately requested from the Superintendent and the
application coordinator the specific reason for the Final Outcome, the criterion or
authority relied upon, the factual basis supporting it, and the person or persons who made
or approved that determination.
6. At approximately 7:42 PM Eastern Time on September 13, Plaintiff contemporaneously
advised the application coordinator that there was no note or reason shown on the tracker
and preserved a screenshot reflecting a Failed Final Outcome without a displayed
explanation.
7. The coordinator responded that the background check stage was complete, that he was no
longer responsible for the outcome stage, and directed Plaintiff to the Superintendent.
II. DEFENDANT LATER ADDED A CHARACTER BASED RATIONALE
8. The tracker was later updated to state: “Applicant failed based on 4 R. Stat. § 121.102(e)
as of 9/14/2026 3:02 AM HKT. Applicant’s character outweighs any other merits
demonstrated.”
9. Section 121.102(e) permits an appointing authority to demerit an applicant for “character
defects which would bring harm to the health of the department or community.” The
entry does not identify the alleged defect, the conduct supporting it, or the nexus between
that conduct and harm to the Parks Service or community.
10. Section 121.103 further requires an appointing authority, during the vacancy process, to
indicate all attributes of merit and demerit and subjectively weigh each application. The
tracker entry states a conclusion that character outweighed Plaintiff’s merits, but does not
identify what merits or demerits were actually considered.
11. The Civil Service Employee Bill of Rights provides a right to an unbiased review of
application materials, a clear and defined reason for denial, information pertaining to that
reason, conformity of the denial with legislative act, and the right to freely petition the
courts without harm. 4 R. Stat. § 123.501(b)-(e), (h).
III. THE HKT ENTRY CREATES A MATERIAL AUTHORSHIP AND TIMING
ISSUE
12. The character based tracker notation identifies its decision time using Hong Kong Time
(“HKT”). Plaintiff has reviewed Defendant’s own personnel/database timezone entries
and observed that the application coordinator, BobbyBobitheBobbian/lspdunit234, is the
only listed RPS person whose timezone is HKT.
13. Plaintiff does not offer the HKT notation as conclusive proof of authorship. It is,
however, circumstantial evidence tending to identify the coordinator as a person with
knowledge of, or involvement in, the entry and is sufficient to justify targeted production
of the tracker’s version history and audit trail.
14. That circumstantial evidence is significant because, hours after the stated HKT decision
time, Plaintiff documented that no reason appeared on the tracker, and because the same
coordinator had previously stated both that he saw no reason not to pass Plaintiff and that
the Final Outcome was outside his responsibility.
15. The record therefore presents a concrete factual question: whether § 121.102(e) was the
actual contemporaneous reason for the Final Outcome, who selected that ground, when
the explanation was entered, and what evidence supposedly supported the character
finding.
IV. LIMITED DISCOVERY AND PRESERVATION ARE WARRANTED
16. This Court has already ordered production in this action of the RPS application tracker
and Google Sheet version history relating to Plaintiff’s application, including notes,
comments, amendments of application status, and the date and time of relevant changes.
The same categories of records are directly material to the newly entered Final Outcome
and character rationale.
17. A narrow production limited to the period beginning with the court ordered reevaluation
and ending with the present will determine whether the new rationale was
contemporaneous or post hoc without reopening broad discovery.
18. Plaintiff also requests preservation of the underlying audit trail, notes, comments,
evaluation records, and nonprivileged communications so that potentially dispositive
metadata is not lost while the Court considers this motion.
19. Because the new character based denial occurred after the operative pleadings, Plaintiff
further requests leave under Rid. R. Civ. P. 10(d) to file a supplemental pleading after the
ordered production if the evidence supports an additional claim arising from the post
pleading conduct.
V. PROTECTIVE RELIEF SHOULD BE NARROW AT THIS STAGE
20. Plaintiff is concerned that the post order sequence may reflect arbitrary or retaliatory
decisionmaking. The present evidence, however, does not yet conclusively establish who
entered the character rationale or why it was selected. Plaintiff therefore does not ask the
Court on this motion to make a final finding that any individual committed retaliation or
official misconduct.
21. Pending production, Plaintiff requests a narrow protective order prohibiting the
application coordinator and any person who authored or approved the challenged §
121.102(e) entry from taking further action on Plaintiff’s application, except to preserve
records or comply with Court ordered production.
22. If discovery establishes that a public servant knowingly used an unauthorized official
function, deliberately withheld a legally required duty, or selected a post hoc ground to
impair Plaintiff’s protected civil service rights, Plaintiff reserves the right to seek
supplemental relief under 7 R. Stat. §§ 121.403-121.404, including injunctive relief
restraining that individual from performing the screening or application functions proven
to have been misused.
VI. RELIEF REQUESTED
A. Order Defendant to preserve immediately all application tracker data, Google Sheet
version history, audit logs, notes, comments, formulas, cell edit history, and
nonprivileged communications concerning Plaintiff’s Final Outcome and the §
121.102(e) rationale.
B. Order Defendant, within forty eight (48) hours, to produce the version history and audit
trail sufficient to identify when the Failed Final Outcome was first entered, when the §
121.102(e) explanation was first entered or modified, and the account or person
responsible for each change.
C. Order Defendant to identify every person who made, recommended, entered, edited, or
approved the Final Outcome or § 121.102(e) character determination.
D. Order Defendant to identify each specific character defect, act, incident, statement, or
course of conduct relied upon, the factual material supporting each ground, and how each
was determined to threaten the health of the Parks Service or community.
E. Order Defendant to identify the attributes or merit and demerit considered and weighed
under 4 R. Stat. §§ 121.101-121.103.
F. Pending production, prohibit the application coordinator and any identified author or
approver of the challenged entry from taking further discretionary action on Plaintiff’s
application, except preservation and compliance with Court orders.
G. Grant Plaintiff leave under Rid. R. Civ. P. 10(d) to file a supplemental pleading within
forty eight (48) hours after production if the newly produced evidence supports a claim
arising from the post pleading conduct.
H. Grant such other and further relief as the Court deems just and proper.
Respectfully Submitted,
_________________________
Halo4asin
Plaintiff, Pro Se
Dated: September 14, 2026
