IN THE SUPERIOR COURT OF RIDGEWAY
FOR THE STATE OF RIDGEWAY
HALO4ASIN,
Plaintiff,
v.
RIDGEWAY PARKS SERVICE,
Defendant.
)
)
)
)
)
)
)
)
)
)
)
)
Case No. RSC-CV-0750
REPLY
PLAINTIFF’S REPLY IN SUPPORT OF MOTION FOR LEAVE TO SUPPLEMENT
AND LIMITED RECORD RELIEF
Plaintiff Halo4asin, appearing pro se, respectfully replies to Defendant Ridgeway Parks Service’s
corrected Opposition to Plaintiff’s Motion for Leave to Supplement and Response to Requests
for Record Preservation. The Opposition repeats three propositions: that the post order Final
Outcome is beyond judicial review, that this action became moot after the August 20
reevaluation, and that limited record production cannot occur before supplementation. The
Court’s September 30 Memorandum and Order already resolves the first two premises for the
present posture: the action lacks final adjudication, the Failed Final Outcome arose directly from
the court ordered reevaluation, and a concrete and ongoing injury subject to judicial review
remains before the Court. Mem. & Order at 2-3 (Sept. 30, 2026). The remaining question is how
that live post order dispute should proceed under Rule 16(6).
I. THE OPPOSITION’S “POST JUDGMENT” AND MOOTNESS
PREMISES CONFLICT WITH THE SEPTEMBER 30 ORDER
Defendant again characterizes the Final Outcome as a separate “post judgment” executive action.
There is, however, no final judgment. The Court expressly found the opposite and denied
Defendant’s request to close the case. It further found that the Failed Final Outcome arose
directly from the reevaluation ordered in this action and constitutes an ongoing injury subject to
judicial review.
Rule 16(6)(1) addresses later occurring events. On motion and reasonable notice, the Court may
permit a supplemental pleading setting out a transaction, occurrence, or event that happened after
the pleading to be supplemented. The Rule does not require a new action merely because the
relevant event occurred later. Here, the challenged Final Outcome did not arise from an unrelated
transaction; it was the result of the reevaluation the Court ordered in this case. Defendant
therefore has not shown that supplementation is procedurally unavailable.
II. SECTION 121.103 CONFERS DISCRETION IN WEIGHING; IT DOES
NOT CREATE IMMUNITY FROM STATUTORY REVIEW
Defendant states that 4 R. Stat. § 121.103 “explicitly insulated” subjective character evaluations
from judicial review. The statutory text contains no such insulation. Section 121.102(e) permits
an appointing authority to demerit an applicant for “[c]haracter defects which would bring harm
to the health of the department or community.” Section 121.103 then requires the appointing
authority to “indicate all attributes of merit and demerit” and permits those attributes to be
weighed subjectively according to the appointing authority’s own principles.
Plaintiff does not ask the Court to choose how much weight RPS should assign to a lawful merit
or demerit. The proposed supplemental dispute concerns whether RPS identified an actual §
121.102(e) demerit, whether the required connection to harm existed, whether the merits and
demerits were indicated as § 121.103 requires, and whether the denial complied with other
mandatory civil service protections. Those are questions of statutory compliance, not judicial
weighing.
Section 123.501 confirms the distinction. It protects applicants from biased review, provides a
right to a clear and defined reason for denial, a right to request information concerning that
reason, a right to demand that a denial conform with legislative act, and a right to seek court
review over prejudicial or harmful employment practices. 4 R. Stat. § 123.501(b)-(g). Defendant
cites no separate statute, rule, or Ridgeway authority establishing the categorical immunity it
describes. Reading § 121.103 as total immunity would also conflict with these express
protections. Defendant therefore has not established futility merely by labeling the decision
subjective.
III. DEFENDANT’S PREMATURITY ARGUMENT SUPPORTS
SEQUENCING, NOT DENIAL OF ALL RELIEF
Defendant next argues that Plaintiff has “no operative complaint” and therefore cannot obtain
production. The first statement is incorrect. The original pleading remains operative; what does
not yet exist is an operative supplemental pleading. Rule 16(6)(2) expressly provides that a
supplemental pleading does not supersede the original and that both are read together.
Rule 19 permits nonprivileged discovery relevant to a claim or defense and proportional to the
needs of the pending action. The Court has already found that the post order Final Outcome
remains part of a live controversy arising from its reevaluation order. Defendant also
affirmatively relies on the supposed lawfulness and completeness of that reevaluation. The
timing, authorship, factual basis, and statutory merit/demerit record therefore bear directly on
issues Defendant itself has placed before the Court.
The requested categories are narrow and familiar. On July 29, 2026, this Court issues a subpoena
duces tecum requiring production of the RPS application tracker and Google Sheet version
history, including notes, comments, status amendments, and relevant timestamps. The present
request seeks the same type of administrative record for the later reevaluation.
If the Court concludes that some discovery should follow, rather than precede, an operative
supplemental pleading, that does not support denying leave as futile. The Court may instead
grant leave under Rule 16(6), direct Plaintiff to file the supplemental pleading within a time fixed
by the Court, and then permit targeted production. Alternatively, the Court may order a first tier
of limited production before deciding the final scope of supplementation. Either sequence avoids
the circular result urged by Defendant, in which leave is denied because the supporting record
has not yet been produced while production is denied because leave has not yet been granted.
IV. PRESERVATION IS NOW LARGELY UNDISPUTED
Defendant represents that it is already obligated to preserve its administrative records. Plaintiff
accepts that representation. Rule 26(7) independently requires a party to take reasonable steps to
preserve relevant electronically stored information once the duty attaches. Accordingly, the
Court need not enter duplicative relief if it is satisfied that Defendant acknowledges and will
comply with that duty. Plaintiff asks only that preservation of the tracker history, audit
information, evaluation records, and other responsive material remain in effect while the Court
resolves supplementation and production.
V. THERE IS NO UNAUTHORIZED SUPPLEMENTAL PLEADING TO
STRIKE
Defendant again asks the Court to strike an “unauthorized new claim and supplemental
document.” The September 30 Memorandum and Order already found that Plaintiff has not filed
an operative supplemental complaint and that the Rule 16(6) request is properly before the Court.
There is therefore no unauthorized supplemental pleading to strike. To the extent Defendant
seeks to eliminate the pending motion itself, that request should be denied because the Court
expressly ordered Defendant to respond to that motion and its accompanying limited record
requests.
VI. RELIEF REQUESTED
For the foregoing reasons, Plaintiff respectfully requests that the Court: (A) reject Defendant’s
renewed mootness and categorical immunity arguments; (B) grant leave under Rid. R. Civ. P.
16(6) and permit Plaintiff to file a supplemental pleading within a time fixed by the Court; (c)
upon or in connection with that supplementation, order targeted production of the tracker/version
history and audit information concerning the post order Final Outcome, the identity of persons
who made, recommended, entered, edited, or approved the determination, the specific §
121.101-121.103; (D) alternatively, if the Court prefers to review the administrative record
before allowing supplementation, order that same limited first tier production and defer final
determination of leave until production is complete; (E) treat preservation as undisputed in light
of Defendant’s representation and Rule 26(7), or enter such preservation direction as the Court
deems necessary; and (F) deny Defendant’s request to strike any supposed unauthorized
supplemental briefing because none presently exists.
Respectfully Submitted,
_________________________
Halo4asin
Plaintiff, Pro Se
Dated: September 14, 2026
