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 REQUEST FOR
TARGETED PRODUCTION AND MANDATORY IN CAMERA REVIEW
COMES NOW, Defendant, Ridgeway Parks Service (RPS), by and through its counsel, Assistant
Attorney General wynneboy2010, respectfully submits this Opposition to Plaintiff’s Supplemental
Motion demanding immediate production and pre-emptive in camera indexing. Plaintiff’s broad
demands for internal agency data, pre-decisional tracking metrics, and metadata breach protected
legal boundaries. Under Title Five of the Ridgeway Rules of Evidence, the requested materials are
completely protected from disclosure.
I. PLAINTIFF’S REQUESTS INFRINGE UPON THE INVESTIGATORY PRIVILEGE
——————————————————————————————————————————————
Opposition to Motion
- 1 -
Plaintiff explicitly seeks the "actual communications, statements, screenshots, or other evidence"
relied upon during the agency's evaluation. These items fall squarely under Rule 506 (Investigatory
Privilege). The privilege shields law enforcement records and pre-decisional administrative materials.
Disclosing ongoing regulatory files or pre-decisional agency checks strips RPS of its ability to
perform robust background investigations safely.
II. THE TRACKER AND VERSION HISTORY LOGS ARE IMMUNE WORK PRODUCT
Plaintiff’s demand for the internal "tracker/version history and audit information" seeks to pierce
protected system data. Rule 504 explicitly protects work product and trial preparation materials from
adversarial discovery. System logs and back-end audit updates capture the iterative, subjective
methods of agency personnel preparing a final determination. This structural framework constitutes a
non-discoverable operational work product.
III. COERCING IN CAMERA REVIEW LACKS THE REQUIRED LEGAL THRESHOLD
Plaintiff requests that the Court bypass ordinary discovery procedures and mandate an immediate in
camera review of all withheld items. This request violates Ridgeway evidentiary standards. Under
Ridgeway law, a party seeking in camera review must first present independent, non-privileged
evidence creating a reasonable belief that the privilege does not apply. Plaintiff has provided nothing
but speculation regarding the "HKT notation" to challenge the agency’s statutory assessment. Blanket
demands for private judicial filtering, without a proper evidentiary threshold, must be denied.
IV. RIDGEWAY DOES NOT RECOGNIZE DOCUMENT SEALING VIA E-FILING
——————————————————————————————————————————————
Opposition to Motion
- 2 -
Plaintiff asks this Court to order a tiered production or an in camera submission of sensitive material.
However, the Ridgeway e-filing system holds no technical capacity to seal or redact single documents
once transmitted. Under Title Five, any material uploaded to the electronic platform becomes part of
the permanent record and cannot be physically erased or altered by subsequent motion. Forcing RPS
to tender disputed investigative records to the court system risks permanent public exposure of
sensitive background evaluation metrics.
II. RELIEF REQUESTED
For the reasons stated above, Defendant respectfully requests that this Court deny Plaintiff’s request
for targeted production and pre-emptive in camera review.
Date: September 19th, 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
——————————————————————————————————————————————
Opposition to Motion
- 3 -
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 19th day of September, 2026, through the court's automated
filing system.
Date: September 19th, 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
——————————————————————————————————————————————
Opposition to Motion
- 4 -
