SUPERIOR COURT OF RIDGEWAY
COUNTY OF RIDGEWAY
THR33SIX8,
Plaintiff,
v.
ALBERTWELLESLEY, et al.,
Defendants.
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Case No.: RSC-CV-8427
This pleading is prepared with the assistance
of counsel
DEFENDANT’S AMENDED OPPOSITION TO MOTION FOR CONTEMPT
Legal Standards
1. Trial courts must be on guard against confusing offenses to their sensibilities with
obstruction to the administration of justice. See In re Little, 404 U.S. 553, 555 (1972) (quoting
Brown v. United States, 356 U.S. 148, 153 (1958).
2. The vehemence of the language used is not alone the measure of the power to punish
for contempt. The fires which it kindles must constitute an imminent, not merely a likely, threat to
the administration of justice. The danger must not be remote or even probable; it must
immediately imperil. See Craig v. Harney, 331 U.S. 367, 376 (1947).
3. Whoever engages in, among other things, “disorderly, contemptuous, or insolent
behavior committed during the sitting of a court of justice, in the immediate view and presence
of the court, and directly tending to interrupt its proceedings or to impair the respect due to its
authority,” commits contempt of court. See Rid. Crim. C. § 1.08(a).
4. But the law of contempt is not made for the protection of judges who may be sensitive to
the winds of public opinion. Judges are supposed to be men of fortitude, able to thrive in a hardy
climate. See Harney, at 376.
5. There is no indication, and the Plaintiff does not argue, that Defendant’s statements
were uttered in a boisterous tone or in any wise actually disrupted the court proceeding. See
Little, at 555 (paraphrased).
6. In the circumstances, the use of the expletive [sic] thus cannot be held to constitute an
imminent threat to the administration of justice. See Eaton v. City of Tulsa, 415 U.S. 697, 698
(1974) (internal quotations omitted).
7. It is not charged that the Defendant here “disobeyed any valid court order, talked loudly,
acted boisterously, or attempted to prevent the judge or any other officer of the court from
carrying on his court duties.” See Holt v. Virginia, 381 U.S. 131, 136 (1965).
8. The parties are advised to chill. Mattel, Inc., v. MCA Records, Inc., 296 F.3d 894, 908
(9th Cir. 2002)
Arguments
I. Contempt Lacks Probable Cause
9. To punish for contempt, it is established law in Ridgeway that, among other things not
relevant to the motion’s allegation, a person must have engaged in “disorderly, contemptuous,
or insolent behavior committed during the sitting of a court of justice, in the immediate view and
presence of the court and directly tending to interrupt its proceedings or to impair the
respect due to its authority.” See Amend. Opp. ¶ 3
10. The Motion only alleges that “It occurred in the immediate view and presence of the
Court while judicial business was pending, directly interrupted the orderly progress of the case,
and impaired the respect due to this Court’s authority.” See Plaint’s Mot. for Cont. ¶ Line 6-8, p.
3. This characterization is wholly incorrect.
11. As a factual predicate, the Motion factually alleges “Defendant rashhyyyy has repeatedly
engaged in the following conduct: characterizing and calling the entire proceeding as a “clown
show”, demanding that the Honourable Arthur_Chen speeds up the proceedings, so “this clown
show can be over”, repeatedly accusing opposing counsel and the Plaintiff of using Artificial
Inteligence [sic] as the main source for their arguments and possibly even for the process, such
as by stating: “fighting with Claude premium” or “Claude DEMON”; calling the Plaintiff a “thug”,
advising others to “STEER CLEAR OF THIS THUG,” and stating that “this case is a final cry for
help” and “park your bus somewhere else.”” See Plaint’s Mot. for Cont. ¶ Lines 22-2, pp. 2-3.
This factual synopsis is gravely exaggerated.
12. In support of the Plaintiff’s Motion, are exhibits attached, which the Plaintiff makes
explicit mention to (Lines 2-3, p. 3). To unpack the complained-of behavior chiefly made in the
aforementioned paragraph, the Defendant called the proceeding a clown show. This is true, but
there is no actual disruption as the motions are merely pending, and Your Honor can readily
access the pleadings through the Docket Sheet.
13. Second, the Defendant pinged the Judge to say “There’s 2 MTDs (Motions to Dismiss) to
rule on,” going on to say “Please can we speed this up so this clown show can be over.” This is
also true, but again does not rise to contempt because the Plaintiff actively is respecting the
authority of the Court by giving a reminder, and simply voices their concern, which does not
disrupt or does not have a tendency to disrupt.
14. Third, the Defendant repeatedly accuses the Plaintiff of the use of Artificial Intelligence.
This is true, and it is also true that the Defendant even pings Detachment_Result, a prosecutor,
to see if there is a prosecution going on for fraudulently signing pleadings. These acts are
nothing more than zealous acts of advocacy, and makes an accusation, however many there
may be, in good faith.
15. Fourth, the Defendant makes other relevant statements such as calling the Plaintiff a
“thug,” “claude lawyer” (potentially a reference to the previously mentioned allegations), “claude
DEMON,” among others. These name-callings are true to have happened, but because the
Defendant is pro se and is navigating an inherently strenuous matter, two motions to dismiss,
that’s no joke for a pro se Defendant who may or may not have time commitments that interfere
with the drafting and argumentation process.
16. The Supreme Court has plainly held that “In the circumstances, the use of the explective
[sic] thus cannot be held to constitute an imminent threat to the administration of justice.” See
Eaton, at 698.
17. Further, the Supreme Court, in a stroke of retroactive genius, likely predicted the law of
contempt to be abused in this manner, which is why the Supreme Court also clarified that “The
vehemence of the language used is not alone the measure of the power to punish for contempt.
The fires which it kindles must constitute an imminent, not merely a likely, threat to the
administration of justice. The danger must not be remote or even probable; it must immediately
imperil.” See Harney, at 376.
18. The Defendant’s utterances, however vehement they may have been, did not
immediately imperil the administration of justice, and the Plaintiff certainly doesn’t allege the
same.
19. It is not charged that the Defendant here “disobeyed any valid court order, talked loudly,
acted boisterously, or attempted to prevent the judge or any other officer of the court from
carrying on his court duties.” Holt, at 136.
II. Defendant Actually Validated the Authority of the Court by Respecting its
Time
20. As previously established in paras. 10 and 12, the Defendant pinged the Judge about
the two motions to Dismiss and asked when it will be over.
21. The Defendant expressly reminded the Court about the two motions and wanted an
update regarding the case’s status, notwithstanding the vehemence of the language used in the
process of doing so.
22. Regardless, the Defendant’s reminder to the Court serves as an integral pillar of respect
as it values judicial economy and raises a valid point about judicial administration, to operate
effectively and efficiently.
23. Should the Defendant have not reminded the Court at all and entertained the Plaintiff’s
counsel’s statements, it would have been more disrespectful to the Court and would not have
been conducive to respecting the authority it’s due.
III. Defendant Ethically Raised an Argument about Artificial Intelligence Use
24. As mentioned before, the Plaintiff raised concerns regarding Plaintiff’s counsel’s alleged
use of Artificial Intelligence, notwithstanding the vehemence.
25. Raising a good-faith point is not and shall not be evidence to form contempt of court. It is
established in Harney that the fires the statements kindle must immediately imperil the
administration of justice, and does not allow even remote or probable imperil, it must be
immediate.
26. The artificial intelligence accusation does not immediately imperil the administration of
justice, notwithstanding the fires it has so evidently kindled by its vehemence.
IV. Holding the Defendant in Contempt Appeals to Judicial Infortitude and
Defeats the Purpose of Contempt
27. If the Court does not accept the previously mentioned arguments, there must be one
thing of note: Judges are men of fortitude, not subject to the wind of public opinion. As the
Supreme Court has clearly and unequivocally stated, “the law of contempt is not made for the
protection of judges who may be sensitive to the winds of public opinion. Judges are supposed
to be men of fortitude, able to thrive in a hardy climate.” Harney, at 396.
28. Further, “trial courts must be on guard against confusing offenses to their sensibilities
with obstruction to the administration of justice.” Little, at 555; Brown, at 153.
29. Holding the Defendant in contempt of court only appeals to these sensibilities, which the
Supreme Court directly advises against and admonishes.
30. Further, Plaintiff’s counsel asks this Court to weaponize contempt sanctions against
behavior that Plaintiff’s counsel regularly exhibits, as shown by the Plaintiff’s counsel’s exhibits.
Given that established precedent protects the underlying statements, the movant would
significantly benefit from the principal holding in Mattel: “The parties are advised to chill,” 296
F.3d, at 908
Conclusion
WHEREFORE the Defendant respectfully requests this Honorable Court to
DENY IN FULL the Motion for Contempt submitted by Plaintiff.
DATED: SEPTEMBER 21, 2026 Respectfully Submitted,
/s/ rashhyyyy
rashhyyyy
Defendant, pro se
