IN THE SUPERIOR COURT OF THE
STATE OF RIDGEWAY
STATE OF RIDGEWAY,
Plaintiff,
v,
THEUNKNOWNSAVAGX,
Defendant.
MOTION FOR PRETRIAL RELEASE ON
CONDITIONS
Hon.
Docket Number: RSC-CM-2381
1. The State of Ridgeway, by and through its counsel, hereby moves this Honorable Court to
impose conditions upon the Defendant that will ensure their appearance and the safety of
the community pursuant to Rid. R. Crim. P. 7.1(5).
INTRODUCTION
2. The defendant has been charged by Criminal Information in the Superior Court of the
State of Ridgeway with multiple felony and misdemeanor offenses, including two counts
of Perjury, contrary to R.C.C. § 2.10, and two counts of Filing a False Document,
contrary to R.C.C. § 2.08.
3. These charges arise as a result of an investigation, which found reasons to believe that
Defendant had used another’s identity to file two fake legal documents in this Court,
which were submitted under penalty of perjury.
4. As a result, there is a presumption that weighs in favor of strict pretrial release with
conditions.
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5. The Court has the authority to impose a “condition or combination of conditions
sufficient to secure the defendant’s appearance and the safety of victims and witnesses.”
Rid. R. Crim. P. 7.1(6).
BACKGROUND
6. On August 12, 2026, the State Bureau of Investigations (“SBI”) received a tip from the
victim, who complained that the Defendant had filed false documents under his name.
7. SBI investigators examined court filings and discovered two Criminal Complaints (or
rather, Information’s), that were filed using the victim’s name.
8. However, investigators discovered evidence that the Defendant had filed these documents
himself, based on the Court website’s feature of linking Roblox accounts. SBI
Investigators determined that the Defendant had filed two Criminal Complaints under the
victim’s name.
ARGUMENT
9. This Court retains inherent authority to impose reasonable conditions that are appropriate
in aid of its jurisdiction in accordance with principles of law. Chambers v. Nasco, Inc.,
501 U.S. 32 (1991).
10. Although State law does not have codified factors for this Court to consider when making
a decision on pretrial release, the State of Ridgeway moves this Court to consider the
federal factors under under 18 U.S.C. § 1342(g) to consider appropriate pretrial
conditions or detention, which comprises of (1) the nature of the circumstances of the
offense charged; (2) the weight of the evidence against the defendant; (3) the history and
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characteristics of the defendant; and (4) the nature and seriousness of the danger to any
person or the community that would be posed by the defendant’s release.
11. In United States v. Dominguez, the Court held that even where a defendant has offered
evidence to rebut the fourth circumstance, the presumption remains a factor in the court’s
analysis of 18 U.S.C. § 3142(g). United States v. Dominguez, 783 F.2d 702, 707 (7th Cir.
1983).
12. This Court should use its inherent common law authority by considering the factors of 18
U.S.C. § 3142(g) when it comes to determining the appropriate conditions of release for
the defendant because they are charged with felony possession and weapons offenses.
ANALYSIS
13. For the reasons that follow, the State submits that the defendant cannot rebut the
presumption in favor of conditions that are held in federal courts, and that there exists a
combination of conditions that will reasonably assure the safety of the community and
defendant’s appearance, as required by Rid. R. Crim. P. 7.1(6).
A. The Nature and Circumstances of the Offenses Charged
14. As noted above, the Defendant has been charged with multiple fraud-like offenses,
including filing fake documents, personation, and perjury. Although these acts do not
present a physical danger to the community, the Defendant’s conduct does harm the
integrity of the Court’s process, and therefore certain restrictions should be in place to
ensure Defendant cannot continue to personate or lie.
15. Thus, the nature and circumstances of the offenses weigh in favor of pretrial conditions.
B. The Weight of the Evidence Against the Defendant
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16. The evidence against the defendant is strong. Firstly, there is no question as to identity in
this case. SBI Investigators were able to link the Defendant to the fake filings based on
the Court website’s unique Roblox account integration.
17. Secondly, the evidence is Electronically Stored Information, and thus, can be accessed
easily. There is no question as to the authenticity of the evidence, based on the Roblox
account integration, and ESI metadata.
C. The Nature and Seriousness of the Danger to Any Person or the Community
18. The Defendant has 335 arrests, 64 citations, and 50 outstanding warrants. In-fact, just
today, the Defendant was arrested 5 times for serious felony offenses. The Defendant has
never filed a habeas corpus petition to challenge any of these arrests, which were all
effected by competently trained peace officers. Accordingly, the Court should consider
these arrests as legitimate.
19. The Defendant’s criminal history is incredibly violent, but also include repeat offenses
such as false personation, evidence theft, and trespassing into various places. This
behaviour demonstrates a repeat pattern of deceitfulness and lying, which is exactly what
Defendant is accused of here in this case.
20. Despite their repeated arrests, the Defendant continues to commit serious offenses, and
may very well be considered a habitual offender.
21. Thus, this factor weighs heavily in favor of setting strict pretrial conditions.
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MOST APPROPRIATE CONDITIONS
22. Rid. R. Crim. P. 7.1(5) provides statutory conditions that this Court may impose.
Accordingly, the State believes that the following conditions under this statue would (1)
reasonably assure the defendant’s appearance; and (2) the safety of the community:
a. A requirement that the defendant remain a participant in the proceeding
communications, respond to the court there, and report any change of username to
the clerk within twenty-four (24) hours;
b. A requirement that the defendant not renounce residency in the State of Ridgeway
and not leave the State while the matter is pending;
c. An order that the defendant have no contact with WYNNEBOY2010;
d. An order that the defendant refrain from conduct of a kind charged in the
accusatory instrument.
CONCLUSION
23. For all of the reasons set forth above, and other any reasons set forth at any hearing on
this issue, a consideration of the evidence in this case and applicable common-law factors
compel the conclusion that the defendant should be released with strict conditions.
24. WHEREFORE, the State respectfully requests that the Court grant its motion and impose
conditions of release on the defendant.
Date: September 22, 2026
Respectfully submitted,
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