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 REPLY IN
SUPPORT OF SUPPLEMENTAL
MOTION
PLAINTIFF’S REPLY IN SUPPORT OF SUPPLEMENTAL MOTION AND
CONDITIONAL PROCEDURAL OBJECTION TO DEFENDANT’S OPPOSITION
Plaintiff Halo4asin, appearing pro se, respectfully replies to Defendant Ridgeway Parks Service’s
Opposition to Plaintiff’s Supplemental Motion for Limited Discovery, Preservation, Protective
Relief, and Leave to Supplement (BATES-20260919-3588586019). Defendant’s Opposition does
not eliminate the factual questions identified in Plaintiff’s motion. It confirms that RPS is relying
on specific, allegedly documented conduct that has not been produced to Plaintiff or introduced
into the judicial record, while asking the Court to deny the narrow discovery necessary to test
that asserted basis. The Supplemental Motion should be granted, or at minimum the Court should
order preservation and targeted production before deciding the remaining protective and
supplementation issues.
I. PLAINTIFF PRESERVES A LIMITED PROCEDURAL OBJECTION, BUT
ADDRESSES THE OPPOSITION ON THE MERITS
1. The docket reflects that Plaintiff’s Supplemental Motion was accepted on September 14,
2026 at approximately 5:38 PM, with an ordinary opposition deadline of September 16,
2026 at 5:38 PM under Rid. R. Civ. P. 7.1(4). The docket further states that failure to
respond within that period constitutes waive under Rule 7.1(9).
2. On September 15, Assistant Attorney General wynneboy2010 advised the Court that he
intended to become new counsel for Defendant but could not file a notice of appearance
because the system reported that existing counsel remained of record and that substitution
was required. He then requested a seventy two hour extension, and the Court responded,
‘sure.’ Plaintiff recognizes the Court’s authority to enlarge the briefing period and does
not ask the Court to disregard that express ruling merely because the automated docket
later marked the motion ripe.
3. Plaintiff nevertheless preserves the procedural point that the extension request was made
before counsel’s substitution had been completed. Plaintiff also notes that Defendant’s
Certificate of Service states that the Opposition was electronically served on September
17, 2026, while the Opposition is dated September 18 and the docket records the
RESPONSE filing at approximately 11:49 PM on September 18. Plaintiff therefore treats
the actual docketed service as the operative service event for purposes of this Reply.
4. If the Court determines that the extension validly encompasses the Opposition, Plaintiff
requests that the Court decide the Supplemental Motion on the merits with this Reply. If
the Court determines otherwise, Plaintiff preserves Rule 7.1(9)’s waiver consequence as
an alternative basis for disregarding the Opposition.
II. THE OPPOSITION CONFIRMS, RATHER THAN DEFEATS, THE NEED FOR
LIMITED DISCOVERY
5. Defendant now identifies the alleged character basis with materially greater specificity
than appeared on the application tracker. The Opposition asserts a pattern of ‘highly
rude, hostile, and disrespectful communications’ toward RPS personnel and alleged
‘public slander’ directed at the agency. Def.’s Opp. at 2. Defendant further represents that
it possesses ‘concrete evidence’ documenting those alleged patterns. Id.
6. Those assertions are not a reason to deny discovery. They are the precise factual materials
Plaintiff’s motion seeks: the actual statements or incidents relied upon, when they were
selected as demerits, who reviewed them, who made or approved the final decision, and
how RPS connected them to the statutory requirement in 4 R. Stat. § 121.102(e) that a
character defect would bring harm to the health of the department or community.
7. Defendant expressly acknowledges that the evidence supposedly justifying the denial
‘has not yet been formally introduced into the judicial record.’ Def.’s Opp. at 3. The
Court therefore cannot presently evaluate whether the cited material exists in the form
described, whether it was actually relied upon when the Final Outcome was entered,
whether it predates or postdates the denial, whether protected petitioning activity was
included, or whether the statutory harm nexus was genuinely assessed.
8. If the evidence is as objective and contemporaneous as Defendant represents, a narrow
production should resolve the dispute quickly and impose little burden. Conversely,
denying discovery because Defendant says it possesses undisclosed evidence would
require Plaintiff and the Court to accept the merits of an unseen administrative record that
Defendant itself relies upon to defeat judicial inquiry.
III. DEFENDANT MISCHARACTERIZES THE HKT ISSUE; PLAINTIFF SEEKS
OBJECTIVE RECORDS, NOT A PREMATURE MISCONDUCT FINDING
9. The Supplemental Motion expressly states that the HKT notation is not offered as
conclusive proof of authorship. It was pleaded as circumstantial evidence justifying
targeted inquiry into timing, authorship, and approval. Plaintiff specifically declined to
request a final finding of retaliation, bad faith, or official misconduct on the existing
record.
10. The Opposition responds that the HKT inference is speculative and states that the
Application Coordinator’s background review role had ended and that responsibility for
the ultimate evaluation rested with the Superintendent. Def.’s Opp. at 2-3. If that account
is accurate, the version history, audit trail, and communications sought by Plaintiff should
confirm it. The records therefore have obvious probative value regardless of which
party’s present inference proves correct.
11. The relevant question is not whether HKT alone proves wrongdoing. The relevant
question is whether the § 121.102(e) rationale was the contemporaneous basis of the
Failed Final Outcome, when the rationale was first entered, who authored or approved it,
and what material was actually before the decisionmaker at that time. Those are ordinary
record questions capable of objective resolution through the limited production requested.
IV. THE NEWLY ASSERTED ‘SLANDER’ AND COMMUNICATIONS THEORY
MAKES THE FACTUAL RECORD PARTICULARLY IMPORTANT
12. RPS may lawfully consider an authorized demerit only within the governing civil service
framework. Section 121.102(e) concerns character defects that would bring harm to the
health of the department or community. Section 121.103 requires the appointing authority
to indicate attributes of merit and demerit and subjectively weigh the application. Section
123.501 separately protects unbiased review, a clear and defined reason or denial, access
to information concerning that reason, conformity with legislative act, and the right to
petition the courts without harm.
13. Because Defendant now relies in part on alleged public statements attacking RPS, the
Court should determine what statements are actually being referenced. Criticism,
complaints, litigation statements, and court petitioning are not interchangeable with
knowingly false defamatory statements. Production is necessary to determine whether
RPS relied on ordinary interpersonal conduct, genuinely defamatory material, protected
petitioning activity, or some combination of those categories.
14. Plaintiff does not ask the Court on this motion to decide whether any particular statement
was defamatory or whether § 123.501(h) was violated. Plaintiff asks only that Defendant
identify and produce the actual material it says formed the basis of the adverse
determination so those questions can be resolved on evidence rather than
characterization.
V. THE REQUESTED PROTECTIVE RELIEF IS NARROW AND CAN BE TIERED
15. Defendant characterizes the requested protective relief as a sweeping injunction
disrupting ordinary agency operations. Def.’s Op. at 3. The motion is considerably
narrower. It asks only that the Application Coordinator and any person identified as an
author or approver of the challenged entry refrain from further discretionary action on
Plaintiff's application while the Court determines who made the challenged decision and
on what basis.
16. If the Court is not prepared to enter that limited restriction now, Plaintiff requests the
following lesser alternative: immediate preservation; production of the challenged
administrative record and audit information; and an order that no responsive record be
deleted, altered, overwritten, or materially modified pending completion of production.
The Court may then determine whether a decisionmaker firewall is necessary after
reviewing the production.
VI. LEAVE TO SUPPLEMENT SHOULD NOT BE DENIED BEFORE THE POST
ORDER FACTS ARE KNOWN
17. The challenged Final Outcome and § 121.102(e) rationale arose after the operative
pleading and as a direct product of the Court ordered reevaluation. Plaintiff’s request
under Rid. R. Civ. P 10(d) is intentionally conditional: Plaintiff seeks leave to supplement
after production only if the evidence supports a claim arising from the post pleading
events.
18. The Opposition asks the Court to deny leave while simultaneously contending that
decisive evidence remains outside the judicial record. That sequencing would foreclose a
potentially proper supplemental claim before the record necessary to evaluate it has been
produced. At minimum, leave should be deferred until after the targeted production rather
than denied with prejudice now.
VII. REQUEST FOR RELIEF
For these reasons, Plaintiff respectfully requests that the Court:
A. Grant Plaintiff’s Supplemental Motion in full;
B. Alternatively, order immediate preservation and targeted production of: (1) the actual
communications, statements, screenshots, or other evidence relied upon for the asserted §
121.102(e) character determination; (2) the tracker/version history and audit information
showing when the Failed Final Outcome and later rationale were entered or modified and
by whom; (3) the identity of every person who recommended, made, entered, edited, or
approved the decision; and (4) the merit/demerit assessment required by §§
121.101-121.103;
C. If Defendant contends any responsive material is privileged or confidential, require
submission to the Court in camera together with a description sufficient to permit review
of the withholding, rather than denying discovery altogether;
D. Enter the limited protective relief requested in the Supplemental Motion or, in the
alternative, prohibit deletion, alteration, overwriting, or material modification of
responsive application records pending production and reserve the decisionmaker firewall
issue until after production;
E. Grant conditional leave under Rid. R. Civ. P. 10(d), or alternatively defer ruling on leave
until after the ordered production rather than denying supplementation before the post
order record is known;
F. To the extent the Court concludes Defendant’s extension did not authorize the Opposition
filed, enforce Rule 7.1(9)’s waiver provision; and
G. Grant such other and further relief as the Court deems just and proper.
Respectfully Submitted,
_________________________
Halo4asin
Plaintiff, Pro Se
Dated: September 14, 2026
