IN THE SUPERIOR COURT OF THE
STATE OF RIDGEWAY
Halo4isin
Plaintiff,
v,
Ridgeway Parks Service,
Defendant.
OPPOSITION TO MOTION
Hon. EffortlessBrit
Docket Number: RSC-CM-0750
DEFENDANT’S OPPOSITION TO PLAINTIFF'S SUPPLEMENTAL MOTION FOR LIMITED
DISCOVERY, PRESERVATION, PROTECTIVE RELIEF, AND LEAVE TO SUPPLEMENT
COMES NOW, Defendant Ridgeway Parks Service (“RPS”), by and through counsel, respectfully
submits this Opposition to Plaintiff’s Supplemental Motion for Limited Discovery, Preservation,
Protective Relief, and Leave to Supplement.
Plaintiff’s motion relies entirely on speculative, circumstantial timeline deductions to construct an
artificial narrative of administrative bad faith. In reality, Defendant’s final determination was the
direct result of a substantive, authorized character evaluation that perfectly accords with operative
statutory authority and this Court’s prior mandates. Because the administrative record contains
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reliable, objective evidence of Plaintiff's disqualifying conduct, his motion for expedited discovery
and protective sanctions lacks legal or factual merit and should be denied.
I. MEMORANDUM OF POINTS AND AUTHORITIES
A. The Final Outcome Rationale is Grounded in Substantive, Documented Character Defects
Plaintiff erroneously asserts that the agency’s 4 R. Stat. § 121.102(e) determination was a post hoc
fabrication or lacked a factual nexus to the health and harmony of the department. To the contrary,
Defendant’s review revealed that Plaintiff has engaged in a consistent pattern of highly rude, hostile,
and disrespectful communications directed at Ridgeway Parks Service employees. Furthermore,
Plaintiff has repeatedly engaged in public slander targeted at undermining the integrity of the agency
he now seeks to join.
Under 4 R. Stat. § 121.102(e), an appointing authority is expressly authorized to demerit an applicant
for character defects that threaten harm to the department or the community. An applicant who
routinely abuses public servants and disseminates defamatory statements about the agency lacks the
requisite character, cooperativeness, and judgment demanded of an RPS representative. Defendant
possesses concrete evidence documenting these disruptive behavioral patterns. This evidence directly
supports the agency's conclusion under 4 R. Stat. § 121.103 that Plaintiff's severe character
deficiencies decisively outweigh any basic technical merits demonstrated in his application materials.
B. Plaintiff’s Allegations of Timing and Authorship Fail to Raise a Material Factual Dispute
Plaintiff spends considerable length analyzing shared database time stamps in Hong Kong Time
(“HKT”) to imply that Application Coordinator BobbyBobitheBobbian improperly fabricated the
denial. This speculative deduction does not amount to a legal showing of official misconduct or bad
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faith. The Application Coordinator explicitly informed Plaintiff that his role in the background
investigation stage was complete and that responsibility for the ultimate evaluation outcome rested
strictly with the Superintendent. The final entry represents an authorized, validated agency
determination. The fact that the underlying evidence justifying this denial has not yet been formally
introduced into the judicial record does not mean it does not exist, nor does it transform a valid
administrative decision into an actionable procedural violation.
C. The Requested Limited Discovery and Protective Orders are Unwarranted and Disruptive
Plaintiff demands an intrusive expedited discovery schedule requiring production of version histories,
audit trails, and specific identifying details within forty-eight (48) hours. Broad requests targeting
systemic metadata are highly disruptive and legally groundless where the agency has already
provided its clear, explicit statutory rationale under 4 R. Stat. § 121.102(e) and possesses the core
evidence to substantiate it at the appropriate evidentiary phase.
Furthermore, Plaintiff’s request for a protective order barring agency personnel from continuing basic
application workflow duties functions as an unearned, sweeping injunction. The plaintiff openly
admits the current record does not establish any retaliation or misconduct. Because the underlying
administrative action is substantively justified by Plaintiff's own behavior, there is no good cause to
disrupt the regular operations of the Ridgeway Parks Service or grant leave to supplement the
pleadings.
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II. RELIEF REQUESTED
Defendant respectfully requests that this Court:
1. Deny Plaintiff's Supplemental Motion for Limited Discovery and Preservation in its entirety.
2. Deny Plaintiff's request for temporary protective relief against agency personnel.
3. Deny Plaintiff leave to file a supplemental pleading.
Date: September 18th, 2026
Respectfully submitted,
/s/ Wynneboy2010
Assistant Attorney General
Major Crimes Division
Public Integrity Division
R. Bar No. 19204
1100 Lakeside Drive
Annex Building
Palmer Ridgeway 80013
Counsel for the State of Ridgeway
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CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing State's Opposition was electronically
served upon Plaintiff, Halo4asin, on this 17th day of September, 2026, through the court's automated
filing system.
Date: September 18th, 2026
Respectfully submitted,
/s/ Wynneboy2010
Assistant Attorney General
Major Crimes Division
Public Integrity Division
R. Bar No. 19204
1100 Lakeside Drive
Annex Building
Palmer Ridgeway 80013
Counsel for the State of Ridgeway
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