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Motion to grant a protective order and sanctions
NPCWAR
Filing username: NPCWAR
Counsel for: TheUnknownSavagx
SUPERIOR COURT OF RIDGEWAY
COUNTY OF RIDGEWAY
COUNTY OF RIDGEWAY
TheStateOfRidgeway, Case No. RSC-CM-2381
Plaintiff,
vs. Motion to grant a protective
THEUNKNOWNSAVAGX, order and sanctions
Defendant.
DEFENDANT’S MOTION FOR PROTECTIVE ORDER AND SANCTIONS UNDER RID.
R. CRIM. P. 48
1. Defendant THEUNKNOWNSAVAGX, by and through counsel, respectfully
moves this Honorable Court, pursuant to Rid. R. Crim. P. 48 and the Court’s inherent
authority to control the proceedings before it, for (a) a protective order prohibiting the
State and its counsel from any further direct or indirect contact with Defendant
concerning the subject matter of this case, (b) an order precluding the State from
offering any evidence or testimony derived from such improper contact, and (c) referral
of the conduct described below to the Board of Legal Ethics under Rule 48(7). This
motion is supported by the accompanying Declaration of THEUNKNOWNSAVAGX and
the exhibits attached thereto.
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Motion to grant a protective order and sanctions
GROUNDS
A. Legal Standard
2. Rid. RPC 4.2(a) provides that, in representing a client, an attorney “shall not
communicate directly or indirectly about the subject of the representation with a person
the attorney knows to be represented by another attorney in the matter, unless the
attorney has the consent of the other attorney.”
3. Rid. R. Crim. P. 48(11) provides that the sanctions rule “is cumulative and is not
exclusive” and that “nothing in this rule limits the inherent authority of the court to control
the proceedings before it, or the disciplinary authority of the Supreme Court over
attorneys at law.” Rule 48(5)(7) further authorizes, among other sanctions, “the
exclusion of evidence or the preclusion of a witness,” and Rule 48(7) authorizes referral
of an attorney’s conduct to the Board of Legal Ethics.
B. Facts
4. Defendant is represented by the undersigned counsel of record in this matter.
The State’s counsel, Deputy Attorney General Detachment_Result, has been aware of
this representation at all times relevant to this motion, including through the Prosecutor’s
own filings in this case referencing undersigned counsel.
5. On or about September 22, 2026, at approximately 11:07 AM CST, the
Prosecutor initiated direct contact with Defendant outside the presence of, and without
the knowledge or consent of, undersigned counsel, NPCWAR. The Prosecutor
addressed Defendant directly regarding the subject matter of this case, stating in
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Motion to grant a protective order and sanctions
relevant part that certain evidence, namely recordings of interviews conducted with
Defendant and the complainant, previously stored via a third-party service that has since
become permanently unavailable, would not be used at trial, but that the Prosecutor
intended to “ask witnesses about what they spoke about,” and asked Defendant directly,
“is that okay?” A true and correct copy of this exchange is available as Exhibit A in
seperate filing.
6. Defendant did not substantively respond to the Prosecutor’s question and
instead stated that he would consult counsel. Undersigned counsel learned of the
contact shortly thereafter and began filing a motion.
7. This incident is not isolated. In RSC-CM-2779 State of Ridgeway v. NPCWAR
(2026), Detachment_Result made a similar out-of-court contact with the Defendant,
whilst a counsel was available.
C. The Prosecutor’s Conduct Violates Rid. RPC 4.2 and Warrants a Protective
Order
8. The Prosecutor’s September 22, 2026 contact, constitute direct communication
“about the subject of the representation” with a party the Prosecutor knew to be
represented by counsel, without counsel’s consent, in violation of Rid. RPC 4.2(a). The
content of the September 22 message — seeking Defendant’s agreement to a litigation
strategy concerning the use of evidence at trial goes directly to the merits of the
representation and is not incidental or administrative in nature.
9. The recurring nature of this conduct establishes a pattern. This creates an
ongoing risk that Defendant will make statements, agreements, or apparent waivers
without the advice or presence of counsel. A protective order is necessary to prevent
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Motion to grant a protective order and sanctions
further prejudice and to ensure that all communication concerning this case proceeds
through counsel as the Rules of Professional Conduct require.
D. Sanctions Under Rule 48 Are Warranted
10. Because the Prosecutor’s contact sought Defendant’s position on the use of
witness testimony concerning evidence that is no longer available in its original form,
any testimony or evidentiary use flowing from that contact should be precluded under
Rule 48(5)(7), to prevent the State from benefiting from an exchange obtained in
violation of Rid. RPC 4.2.
11. Defendant further requests that the Court refer the Prosecutor’s conduct to
the Board of Legal Ethics under Rule 48(7), given the recurring nature of the contact and
its potential to constitute a pattern of professional misconduct under Rid. RPC 8.3(a) and
8.3(d).
CONCLUSION
12. For the foregoing reasons, Defendant respectfully requests that the Court: (a)
enter a protective order prohibiting the State and its counsel from any further direct or
indirect contact with Defendant concerning this case; (b) preclude the State from offering
any evidence or testimony derived from the improper contact described herein; (c) refer
the Prosecutor’s conduct to the Board of Legal Ethics under Rule 48(7); and (d) grant
such other and further relief as the Court deems just and proper.
Date: 09/22/2026
Respectfully submitted,
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Motion to grant a protective order and sanctions
/s/ NPCWAR, Counsel for Defendant, Bar No. 17132
DECLARATION OF THEUNKNOWNSAVAGXIN SUPPORT OF MOTION FOR
PROTECTIVE ORDER AND SANCTIONS
1. I, THEUNKNOWNSAVAGX, declare as follows:
2. I am the defendant in the above-captioned matter and am represented by
counsel of record. I have personal knowledge of the facts stated in this declaration and,
if called as a witness, could and would testify competently to them.
3. On or about September 22, 2026, at approximately 11:06–11:08 AM CST,
Deputy Attorney General Detachment_Result contacted me directly, outside the
presence of my attorney, regarding the subject matter of this case. A true and correct
screenshot of this exchange is attached in seperate filing as Exhibit A.
4. I declare under penalty of perjury that the foregoing is true and correct.
/s/ THEUNKNOWNSAVAGX,
Defendant
