IN THE SUPERIOR COURT OF THE
STATE OF RIDGEWAY
THR33SIX8
Plaintiff,
v,
DOMINODOWNLOAD, ET AL,
Defendant.
DEFENDANT’S OMNIBUS PROCEDURAL
MOTION: (1) RULE 12(c) MOTION FOR
JUDGMENT ON THE PLEADINGS; (2)
MOTION TO STRIKE SUPPLEMENTAL
DISCLOSURES AND CLAIMS.
Hon. Arthur_Chen
Docket Number: RSC-CV-6949
DEFENDANTS’ OMNIBUS PROCEDURAL MOTION
NOW COME Defendants, by and through their counsel of record, and respectfully submit this
Omnibus Procedural Motion. Defendants move this Court (1) to enter Judgment on the Pleadings in
favor of Defendants pursuant to Ridgeway Rule of Civil Procedure 12(c), and (2) to Strike Plaintiff's
unpermitted Supplemental Disclosures and claims filed on or about July 19, 2026.
MEMORANDUM OF POINTS AND AUTHORITIES
I. LEGAL STANDARD FOR RULE 12(c) JUDGMENT ON THE PLEADINGS
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Opposition to Motion
- 1 -
Under Ridgeway Rule of Civil Procedure 12(c), a party may move for judgment on the pleadings
after the pleadings are closed but early enough not to delay trial. Judgment on the pleadings is
appropriate when there are no genuine issues of material fact remaining, and the moving party is
entitled to judgment as a matter of law. Federal and state jurisprudence establishes that where a
plaintiff's allegations, taken as true, cannot overcome a dispositive legal defense or establish
jurisdiction, the action must be dismissed.
II. THE ORIGINAL CIVIL COMPLAINT IS MOOT AS A MATTER OF LAW
The core of Plaintiff’s initial civil action sought an administrative evaluation or reversal of
background screening metrics under the color of state law. This Court’s prior partial summary
judgment rulings ordered the responding executive agencies to re-evaluate Plaintiff's screening status
by disregarding designated historical warning thresholds.
The undisputed record shows that the executive agency fully and explicitly complied with that
judicial mandate. Plaintiff subsequently advanced through the administrative Final Screening phase.
Because the state actors executed and fulfilled the precise judicial remedy requested in the operative
pleadings, the original active controversy has been fully resolved. It is a well-established principle of
administrative and civil law that when an agency satisfies a court's mandate, the original action
becomes legally moot. There remains no active operational controversy for this Court to enforce or
supervise.
III. PLAINTIFF FAILS TO STATE A CLAIM DUE TO SUBJECTIVE AGENCY DISCRETION
To the extent that Plaintiff attempts to seek judicial reversal of his ultimate non-hiring or employment
outcome, his claims fail as a matter of law under 4 R. Stat. § 121.102(e) and 4 R. Stat. § 121.103.
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Opposition to Motion
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Under 4 R. Stat. § 121.103, the appointing authority evaluates applications and background files
subjectively to determine character and fitness for deployment. Administrative law firmly dictates
that a court lacks the jurisdiction to second-guess, review, or override the subjective hiring discretion
textually reserved to an executive branch agency. Because the final decision was a lawful exercise of
statutory subjective authority, Plaintiff has failed to state a claim upon which this Court can grant
actionable legal or equitable relief.
IV. MOTION TO STRIKE PLAINTIFF'S UNPERMITTED SUPPLEMENTAL CLAIMS AND
DISCLOSURES
On July 19, 2026, Plaintiff unilaterally filed a "Document of Disclosures" (Doc. 15), raising entirely
separate grievances stemming from post-mandate administrative assessments, alongside a supporting
brief seeking the introduction of a leaked training curriculum (Exhibit 8).
Under the Ridgeway Rules of Civil Procedure, a party is strictly prohibited from introducing
post-judgment events, supplementary pleadings, or post-judgment discovery devices without first
moving for and being granted formal leave of court. Plaintiff completely bypassed this mandatory
prerequisite. Because Plaintiff failed to obtain leave of court to supplement his pleadings or expand
his disclosures to encompass separate, post-judgment transactions, the July 19, 2026 filing is
procedurally defective, invalid, and must be struck from the record in its entirety.
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Opposition to Motion
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CONCLUSION
For the foregoing reasons, Defendants respectfully request that this Court GRANT this Omnibus
Motion, ENTER Judgment on the Pleadings dismissing the Complaint with prejudice, and STRIKE
Plaintiff's unauthorized supplemental filings.
DATED: October 1, 2026
Respectfully submitted,
Respectfully submitted,
/s/ Wynneboy2010
Assistant Attorney General
Defense Counsel
R. Bar No. 19204
1100 Lakeside Drive
Annex Building
Palmer Ridgeway 80013
Counsel for the Defense
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Opposition to Motion
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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: October 1st, 2026
Respectfully submitted,
/s/ Wynneboy2010
Assistant Attorney General
R. Bar No. 19204
1100 Lakeside Drive
Annex Building
Palmer Ridgeway 80013
Counsel for the Defense
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Opposition to Motion
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