IN THE SUPERIOR COURT OF THE
STATE OF RIDGEWAY
Halo4isin
Plaintiff,
v,
Ridgeway Parks Service,
Defendant.
MOTION TO STRIKE
Hon. RummyLeroux
Docket Number: RSC-CM-0750
DEFENDANT’S OPPOSITION TO PLAINTIFF’S MOTION FOR LEAVE TO SUPPLEMENT
AND RESPONSE TO REQUESTS FOR RECORD PRESERVATION
COMES NOW, Defendant, the Ridgeway Park Service (“RPS”), by and through counsel,
respectfully submits this Opposition to Plaintiff’s "Supplemental Motion for Limited Discovery,
Preservation, Protective Relief, and Leave to Supplement". For the reasons set forth below, Plaintiff’s
request for leave to supplement the pleadings under Rid. R. Civ. P. 16(6) should be denied as futile,
and the accompanying discovery and preservation demands should be rejected.
I. STATEMENT OF CONFERRAL
Pursuant to Rid. R. Civ. P. 7.1(2)(3), counsel for Defendant certifies that they have conferred in good
faith with the pro se Plaintiff regarding the relief sought herein. On the 20th of September, 2026,
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counsel contacted Plaintiff to discuss the issues raised by the post-pleading administrative outcome.
The parties reached an impasse, and a mutual resolution could not be achieved, necessitating court
intervention.
II. BACKGROUND
On August 20, 2026, this Court granted partial summary judgment, directing Defendant to vacate its
prior administrative ruling regarding Plaintiff’s application and to reevaluate Plaintiff at the
background investigation stage without considering prior appealed warnings.
Defendant complied fully with this Court’s mandate. Following a thorough, compliant reevaluation,
Defendant passed Plaintiff through the "Final Screening" phase. Subsequently, Defendant issued a
separate, post-mandate administrative "Failed Final Outcome" determination pursuant to 4 R. Stat. §
121.102(e) based on subjective character evaluations. Plaintiff now seeks leave to supplement the
pleadings to contest this distinct, post-judgment executive action.
III. ARGUMENT
A. Granting Leave to Supplement is Futile Because the Court Lacks Jurisdiction to Review
Subjective Character Evaluations Under 4 R. Stat. § 121.103.
While Rid. R. Civ. P. 16(6) permits the Court discretion to allow supplemental pleadings for
transactions or events occurring after the original complaint, leave should be denied when the
proposed amendment is legally futile.
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Plaintiff’s proposed supplemental claims stem entirely from Defendant's "Failed Final Outcome"
determination made pursuant to 4 R. Stat. § 121.102(e). However, under 4 R. Stat. § 121.103, the
legislature has explicitly insulated the appointing authority's subjective character evaluations from
judicial review. It is a bedrock principle of administrative law in the State of Ridgeway that courts
lack jurisdiction to second-guess, review, or override the subjective hiring discretion explicitly
committed to an executive agency by statute. Because the Court cannot grant the relief Plaintiff seeks,
the proposed supplemental claims fail to state a claim upon which relief can be granted, rendering
amendment futile.
B. The Original Controversy is Moot, and Plaintiff Cannot Use Supplemental Pleadings to
Artificially Extend Final Adjudication.
A supplemental pleading is designed to complement a live controversy, not to serve as an anchor for
entirely new, post-judgment administrative disputes. Here, the original legal controversy over
Plaintiff's background check parameters is over. Defendant fully vacated the prior ruling and
performed the reevaluation exactly as ordered. Because Defendant completely fulfilled the judicial
mandate, the original action is moot. Plaintiff’s subsequent failure to secure employment based on a
separate, subjective character assessment must be pursued, if at all, as an independent administrative
appeal or a separate civil action—not as an unvetted appendage to a fully satisfied mandate.
C. Plaintiff’s Requests for Administrative Record Production and Preservation are Premature
and Improper.
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Because Plaintiff has no operative complaint before the Court, his concurrent demands for limited
discovery, administrative record production, and preservation orders are procedurally defective and
premature. Discovery cannot be initiated for post-judgment events before formal leave to amend has
been granted and an operative complaint is accepted onto the docket. Furthermore, Defendant is
already under separate statutory obligations to maintain its administrative records in the ordinary
course of business, rendering a formal court preservation order unnecessary and duplicative.
IV. CONCLUSION
For the foregoing reasons, Defendant respectfully requests that this Court DENY Plaintiff’s Motion
for Leave to Supplement and DENY Plaintiff’s accompanying requests for record production and
preservation.
WHEREFORE, Defendant respectfully requests that this Court grant its motion and order Plaintiff's
unauthorized new claim and supplemental document stricken from the record.
Dated: September 30, 2026
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Respectfully submitted,
/s/ Wynneboy2010
Assistant Attorney General
Major Crimes Division
Public Integrity Division
R. Bar No. 19204
1100 Lakeside Drive
Annex Building
Palmer Ridgeway 80013
Counsel for the Ridgeway Parks Service
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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 1st day of October, 2026, through the court's automated
filing system.
Date: October 1st, 2026
Respectfully submitted,
/s/ Wynneboy2010
Assistant Attorney General
Major Crimes Division
Public Integrity Division
R. Bar No. 19204
1100 Lakeside Drive
Annex Building
Palmer Ridgeway 80013
Counsel for the Ridgeway Parks Service
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