SUPERIOR COURT OF THE STATE OF RIDGEWAY
IN AND FOR THE COUNTY OF RIDGEWAY
TonyBlony492,
Plaintiff,
vs.
iiCryptic_LawMD,
Defendant.
____________________________________/
CIVIL DIVISION
CASE NO.: RSC-CV-4274
RIDGEWAY BAR NO.: 10233
JUDGE: Hon. _________
DEFENDANT’S REQUEST FOR JUDICIAL NOTICE, MOTION FOR
SANCTIONS FOR UNSUPPORTED CLAIMS AND NOTICE OF STATUTORY
FEE-SHIFTING
COMES NOW the Defendant, appearing pro se, pursuant to Rid. R. Civ.
P. 41(9), requests from this Honorable Court the following:
DEFENDANT’S MOTION FOR SANCTIONS FOR UNSUPPORTED CLAIMS,
RE: CIVIL COMPLAINT AND EXHIBITS (Dkt. 1)
Request for Judicial Notice
WHEREFORE, pursuant to Rid. R. Evid. 201(5), the Defendant requests
from this Honorable Court that judicial notice of adjudicative fact ought to be
taken for the matter of Thr33six8 v. AlbertWellesley, et al., RSC-CV-8427
(Neither party has a direct link to this matter, other than that the Plaintiff is
represented by the Plaintiff), where Plaintiff is, according to the electronic case
management system, is reflected to be counsel of record for the Plaintiff.
THEREFORE, having taken into consideration the items to be considered
under Rid. R. Evid. 201(5), it is to be noticed that the electronic case
management system for Thr33six8 v. AlbertWellesley, et al., RSC-CV-8427,
demonstrate that Plaintiff served as counsel of record in a matter alleging
abuse of process and tortious interference.
INDEX OF EXHIBITS ATTACHED HERETO:
EXHIBIT A: A copy of the electronic case management system’s
Docket Sheet housing the complaint in Thr33six8 v. AlbertWellesley, et al.,
RSC-CV-8427, found here.
Memorandum of Points and Authorities in Support of a Motion for
Sanctions for Unsupported Claims
Legal Standards of Review
1. Upon the court’s initiative or motion of any party, the court shall
award a reasonable attorney’s fee to be paid to the prevailing party in equal
amounts by the losing party and the losing party’s attorney on any claim or
defense at any time during a civil proceeding or action in which the court finds
that the losing party or the losing party’s attorney knew or should have known
that a claim or defense when initially presented to the court or at any time
before trial, was not supported by the material facts necessary to establish the
claim or defence, or would not be supported by the application of then-existing
law to those material facts, . . .” See Rid. R. Civ. P. 41(9)(1)-(2); see also 7 Rid.
Stat. § 132.301(a)-(b).
2. The filing of complaints, papers, or other motions without taking
the necessary care in their preparation is a separate abuse of the judicial
system, subject to separate sanction. See Cooter & Gell v. Hartmax, 496 U.S.
384, 398 (1990).
3. Our first task is to presume that a legislature says in a statute
“what it means” and means in a statute “what it says there.” Ridgeway Parks
Service, et al., v. SteKing2008, 1 Rid. ___, 5-6 (2022)
4. 7 Rid. Stat. § 132.3011 imposes a duty on attorneys to certify that
1 While the original quote mentions Fed. R. Civ. P. 11, 7 Rid. Stat. § 132.301 ought to be
construed in a similar light as 7 Rid. Stat. § 132.301 imposes the same duty on litigants,
including attorneys, to take proper precautions to ensure sufficiency, and therefore must be
given the same goal in mind: deterrence.
they have conducted a reasonable inquiry and have determined that any
papers filed with the court are well-grounded in fact, legally tenable, and "not
interposed for any improper purpose." An attorney who signs the paper without
such a substantiated belief "shall" be penalized by "an appropriate sanction."
Such a sanction may, but need not, include payment of the other parties'
expenses. Although the statute must be read in light of concerns that it will
spawn satellite litigation and chill vigorous advocacy, any interpretation must
give effect to the statute’s central goal of deterrence. Hartmax, at 393 (1990)
(heavily paraphrased).
5. Courts have the inherent power to manage their own proceedings
and to control the conduct of those who appear before them. In invoking the
inherent power to punish conduct which abuses the judicial process, a court
must exercise discretion in fashioning an appropriate sanction, which may
range from dismissal of a lawsuit to an assessment of attorney's fees. Although
the "American Rule" prohibits the shifting of attorney's fees in most cases, an
exception allows courts to exercise their inherent power to assess such fees as
a sanction when a party has acted in bad faith, vexatiously, wantonly, or for
oppressive reasons, . . .” Chambers v. Nasco, Inc., 501 U.S. 32 (1991) (internal
citations omitted) (paraphrased).
6. For purposes of this Subtitle, the term “Administrative Proceeding”
is limited to misconduct and internal affairs investigations of departments or
agencies. See 7 Rid. Stat. § 111.001.
7. The general rule is that a litigant cannot recover his counsel fees,
but that rule does not apply when the opposing party has acted in bad faith,
including bad faith in the conduct of the litigation. In view of a court's power
over members of its bar, if it may tax counsel fees against a party who has
litigated in bad faith, it certainly may assess those expenses against counsel
who willfully abuse judicial processes. See Roadway Express, Inc., v. Piper, 447
U.S. 752 (1980).
8. The mere filing of a bar charge is not ‘use’ of a judicial process” as
required for abuse of process. Accursio v. Tree House, at ¶39 Ariz. (2026)
(internal citation omitted).
9. We have described the bar as a public corporation created as an
administrative arm of the court for the purpose of assisting in matters of
admission and discipline of attorneys. In those two areas, the bar's role has
consistently been articulated as that of an administrative assistant to or
adjunct of this court, which nonetheless retains its inherent judicial authority
to disbar or suspend attorneys. See In re Rose, 22 Cal. 4th 430 Cal. Rptr. 2d
298, 993 P.2d 956 (2000).
10. The freedom includes exhibits attached to the complaint,
Rid. R. Civ. P. 7(2)(4), or documents referenced in the pleading if they are
central to the claim. Taking all facts pleaded in the complaint as true
and construing all inferences in the plaintiff’s favor, we review the complaint
and all exhibits attached to the complaint. Bogie v. Rosenberg, No. 12-1923,
at 6 (7th Cir. 2013) (paraphrased).
11. Other papers permitted by these rules include a memorandum
or brief, a notice, a stipulation, an offer of judgment, a designation of the
record, an affidavit, a proof of service, a proposed order, and an exhibit or
item of documentary evidence offered in support of a pleading or motion.
See Rid. R. Civ. P. 7(2)(4) (emphasis added).
12. An attorney shall not knowingly make a false statement of fact
or law to a tribunal or fail to correct a false statement of material fact or
law previously made to the tribunal by the attorney. See Rid. R. Pro. C.
3.3(a)(1) (emphasis added).
13. The Ridgeway State Bar shall be an administrative board of the
Supreme Court of the State of Ridgeway, under judiciary administration, at the
direction of the Director of the State Bar, and to which all practicing attorneys
must be admitted prior to legal practice. See 3 Rid. Stat. § 151.002.
Analysis
A. Plaintiff’s claim is Explicitly Barred by Existing Law
14. The plain text of 7 Rid. Stat. § 111.001 reads simply that an
“administrative proceeding” is LIMITED to misconduct AND internal affairs
investigations of departments or agencies, (emphasis added).
15. Plaintiff is expected to counter that the State Bar, a component
of the Supreme Court, is an agency under this definition. This is patently and
unequivocally false.
16. Firstly, there is an unbroken chain of jurisprudence that holds
that the State Bar functions as a regulatory authority, not an agency. Any
complaint filed by the State Bar is merely a grievance, not a judicial process
nor an administrative proceeding. For example, in both Arizona (See Accursio,
at 39) and California (See Rose, 22 Cal. 4th 430 (2000)), both Supreme Courts
have consistently held, and that this statute seems to mirror, that the State
Bar is nothing more than an administrative aid to the Supreme Court, which
truly holds disciplinary authority over attorneys.
17. Further, this is backed up by our Supreme Court’s
interpretation of statutory construction. In SteKing, 1 Rid. ____ (2022), the
Ridgeway Supreme Court noted that “our first task is to presume that a
legislature says in a statute “what it means” and means in a statute “what it
says there.” See SteKing, at 5-6 (2026); see also Connecticut Nat’l Bank v.
Germain, 503 U.S. 249, 253-254 (1992).
18. In addition, this interpretation is backed by the Ridgeway
Statutes, particular 3 Rid. Stat. § 151.002, where it states that “[T]he Ridgeway
State Bar shall be an administrative board of the Supreme Court of the State of
Ridgeway, under judiciary administration, at the direction of the Director of the
State Bar, and to which all practicing attorneys must be admitted prior to legal
practice.”
19. Secondly, our Rules permit the filing of exhibits or other
documentary evidence offered in support of a pleading, which a civil complaint
is. Therefore, review of sufficiency shall be equally afforded to exhibits to
support a finding of a lack of support by material facts.
20. It is a material fact that under Exhibit B (See Dkt. 1.2, Def’s
Exh’s), the only thing shown is Defendant withdrawing the agreement because
of an error with the meeting of the minds, a requisite element in a contract.
B. Plaintiff Failed to Exercise the ‘Necessary Care’ Required of
Licensed Counsel
21. Defendant reincorporates paras. 13-18 to offer a failure to
exercise proper care.
22. The filing of complaints, papers, or other motions without
taking the necessary care in their preparation is a separate abuse of the
judicial system, subject to separate sanction. See Hartmax, at 398 (1990).
23. Furthermore, the Plaintiff’s failure to exercise necessary care is
not just hypothetical. As demonstrated by the public docket sheet set forth in
Defendant’s Request for Judicial Notice (Exhibit A), the Plaintiff advanced the
exact erroneous statutory interpretation in Thr33six8 v. AlbertWellesley, et al.,
RSC-CV-8427. Having made and improperly construed this language in the
previously cited matter, the Plaintiff cannot reasonably and in good faith
attribute the baseless filing of the action to bad oversight or a lapse in
research. Repeating a facially deficient interpretation exhibits a gross and
intentional lack of the professional care mandated of licensed counsel.
24. It is clear that the Plaintiff failed to take necessary care in their
preparation of the civil action against Plaintiff and in compiling exhibits
requisite to supporting their pleading.
25. To support the previous paragraph, Defendant points to Rid. R.
Pro. C. 3.3(a)(1), which implicitly, inter alia, deems the failure to correct the
record of a previously asserted false statement of material fact or law by the
attorney an act against candor towards the tribunal.
C. Mandatory Fee-Shifting Sanctions Must be Enforced to Deter
Abuse
26. Defendant reincorporates and incorporates paragraphs 13-22.
27. It is clear that the Plaintiff, by filing the civil action with such
unnecessary care, filed an unsupported claim worthy of sanction under the
Rules of Civil Procedure and established precedent.
Conclusion
For the foregoing reasons, the Defendant respectfully requests that
the Motion for Sanctions for unsupported claims be GRANTED and that the
Court enforces the mandate of 7 Rid. Stat. § 132.301 by calculating a
reasonable defense fee and ordering the Plaintiff to pay it as a fine forthwith to
the Clerk of Court.
DATED: September 20, 2026 Respectfully Submitted,
/s/ iiCryptic_LawMD
iiCryptic_LawMD
Defendant, pro se
RSB#10233
