THE STATE OF RIDGEWAY
RIDGEWAY SUPERIOR COURT
ZUZUMBO, an individual,
Plaintiff,
-against-
the LAW ENFORCEMENT TRAINING CENTER, and
the RIDGEWAY COUNTY SHERIFF'S OFFICE,
Defendants.
RSC-CV-####
COMPLAINT
Presiding Judge: Hon. N/A
Plaintiff zuzumbo hereby files this complaint to commence the above-titled civil action. It
is alleged as follows:
PARTIES
1. The Law Enforcement Training Center is "an agency of the state." 9 Rid. Stat. § 221.001.
Its director, see Ibid, is CephalGPT, whose timezone is UTC+01:00. See Exh. 5, infra.
Pursuant to Rid. Rule Civ. Proc. 4(4)(3), its director shall be served in lieu of the Law
Enforcement Training Center.
2. The Ridgeway County Sheriff's Office is "an agency of the County of Ridgeway, at the
direction of the Sheriff[.]" Id., at § 331.001. The sheriff is sagesoup, whose timezone is
UTC–05:00. See Exh. 3, infra. Pursuant to the aforementioned Rule of Civil Procedure,
he shall be served in lieu of the Ridgeway County Sheriff's Office.
3. Plaintiff zuzumbo is a resident of the State of Ridgeway. She is a guardswoman of the
Ridgeway National Guard and an Operator of the Ridgeway Department of
Transportation. Her timezone is UTC+04:00. See Exhs. 6–7, infra.
JURISDICTION AND VENUE
4. This court, which is the Superior Court of the State of Ridgeway, shall "shall exercise
original jurisdiction for all civil and criminal cases or controversies under the rules as set
by the Supreme Court", Rid. Const., Art. Ⅴ, § Ⅳ, and it shall have original jurisdiction
1
over, among other things, "any controversy not otherwise falling within the jurisdiction of
the Supreme Court, Administrative Court, or Magistrate Court as set forth by law". See
generally The Judiciary Act of 2026 § 302, S.B. 002, 11th Sen. (2026); 3 R. Stat. §
131.104(a–e). As the controversy is actionable here, jurisidiction is proper.
5. This court is the proper venue because civil actions shall only take place in the county
where the controversy occurs. See 7 R. Stat. §§ 131.001–131.003. Since this takes place
within the County of Ridgeway, a county of the State of Ridgeway pursuant to 9 R. Stat.
§ 321.001, venue is proper.
STATEMENT OF FACTS
6. On October 2nd, 2026, the Criminal Investigations Divison of the Ridgeway County
Sheriff's Office submitted a "referral…regarding an alleged incident of misconduct
against zuzumbo" to the Law Enforcement Training Center (LETC). Exh. 1, p. 1. The1
referral alleged her to be an alternate account "under 4 R. Stat. § 122.404(a)" (hyperlink
added). Alongside the report, an "extensive report…link[ing] several metrics of account
data to user RealBaconLeaf across Roblox and Discord, and, most notably, shared
ownership of a recording software account as shown in Exhibit A" (hyperlink added) was
provided by the Criminal Investigations Division. Ibid.
7. Then, LETC Investigations Office Staff WGT05, who is a Sergeant of the Ridgeway
State Police's Tactical Support Unit, see Exh. 5, infra, at 4, and Senior Staff
1 The page number refers to a page number of the exhibited document. It does not refer to a page number on this
complaint. This is how the Supreme Court of the United States cites exhibits. E.g., Trump v. Cook, 609 U.S. ____,
____ (2026) (Thomas, J., dissenting) ("The President responded by removing Cook from office. He wrote to her:
'Pursuant to my authority under Article II of the Constitution of the United States and the Federal Reserve Act of
1913, as amended, you are hereby removed from your position on the Board of Governors of the Federal Reserve,
effective immediately.' ECF Doc. 1–3, Exh. B, p. 2"). As I, thr33six8, already said, I cite how they cite.
2
theburnerphone, who is a sergeant of the Palmer Police Department's Special
Investigations Unit, see Exh. 3, infra, at 3, opened an investigation into it.2
8. They found that zuzumbo was an alternate account of RealBaconLeaf and concluded that
her LETC peace officer certification, which she had had since September 28th, see Exh.
2, infra, at 4, should be revoked "[i]n accordance with Developer Order 002 Article Ⅱ."
Exh. 1, p. 1.
9. Plaintiff had not been told about the investigation until she received the report.
10. Plaintiff was not employed by any law enforcement agency. See supra, at 1, ¶ 3.
EVIDENCE
EXHIBITS
# PREVIEW + URL DESCRIPTION
1. The original document of factfinding that Plaintiff was sent. This
document is under theburnerphone's Google Drive.
2. The database of the Law Enforcement Training Center.
2 This refers to where the exhibit is within this complaint, hence the lack of "p." and the infra signal.
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3 The database of the Ridgeway County Sheriff's Office.
4 The database of the Palmer Police Department.
5 The database of the Ridgeway State Police.
6 The database of the Ridgeway National Guard.
7 The database of the Ridgeway Department of Transportation.
TORTS
#1: Deprivation of Rights under Color of Law (7 Rid. Stat. § 121.403)
Tortfeasor: Law Enforcement Training Center
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11. The Law Enforcement Training Center has an implied, limited, and statutory power to
revoke its peace officer certifications. See, e.g., 9 Rid. Stat. §§ 222.208, 222.201; see also
Id., at § 221.207 (granting investigative and adjucative authority into peace officer
misconduct). When investigating Plaintiff and revoking her license, they were acting
under that jurisdiction. See supra, at 2–3, ¶ 6–9.
12. However, Plaintiff was not given a hearing. Supra, at 3, ¶ 9. LETC must have had a
hearing in order for the revocation to be intra vires. 9 Rid. Stat. § 222.203. Because
LETC did not have a hearing, they deprived Plaintiff of her § 222.203 right.
13. Therefore, there is a cause of action for the tort of Deprivation of Rights under Color of
Law, of which the Law Enforcement Training Center is the tortfeasor.
#2: Deprivation of Rights under Color of Law (7 Rid. Stat. § 121.403)
Tortfeasor: Law Enforcement Training Center
14. Further, the Law Enforcement Training Center "shall not conduct investigations into any
wrongdoing or misconduct, and shall rely upon the investigative dispositions and
evidence acquired by law enforcement agency heads, professional conduct organizations
and the Justice Department." Id., at § 222.203; but see Id., at § 221.207 ("The Law
Enforcement Training Center shall have the authority to review investigations of peace
officer misconduct and review law enforcement agency training standards, and may hold
hearings and take sworn testimony to accomplish such duties") (emphasis added). The
definition of a peace officer in those statutes requires employment by a law enforcement
agency. Id., at §§ 211.001 (defining it as "any person, who having completed the training
standards and testing requirements of the Law Enforcement Training Center, has been
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authorized to execute police powers in service to a law enforcement agency"), 211.002
(defining law enforcement agency).
15. The Law Enforcement Training Center relied upon the Ridgeway County Sheriff's
Office's Criminal Investigations Division, which is "a criminal investigative division
which shall be responsible for the investigation of violent crime within the jurisdiction of
the Ridgeway County Sheriff’s Office, or other types of crime as determined by the
Attorney General" in RCSO's Investigations Bureau. Id., at § 331.405. In addition,
neither the Law Enforcement Training Center nor the Criminal Investigations Division
concluded or found that Plaintiff's possession of a peace officer certification on an
alternate account was an intra vires criminal offense.
16. The Law Enforcement Training Center relied upon the ultra vires referral of the Criminal
Investigations Division. Exh. 1.
17. By doing that, the Law Enforcement Training Center deprived Plaintiff of the statutory
custom of only relying upon the determinations of the entities authorized to report to the
Law Enforcement Training Center.
18. As a result, the revocation of Plaintiff's peace officer certification was issued based upon
CID's ultra vires referral and the LETC's subsequent factfinding and conclusions.
19. Therefore, there is another cause of action for the tort of Deprivation of Rights under
Color of Law, of which the Law Enforcement Training Center is the tortfeasor.
#3: Deprivation of Rights under Color of Law (7 Rid. Stat. § 121.403)
Tortfeasor: Ridgeway County Sheriff's Office
20. Even further, the Criminal Investigations Division of the Ridgeway County Sheriff's
Office acted ulta vires when it investigated noncriminal conduct.
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21. Because of the ultra vires investigation and subsequent referral of the facts found thence,
Plaintiff's revocation was summarily revoked, therefore subjecting her a tortious violation
of her rights.
22. Therefore, there is a cause of action for the tort of Deprivation of Rights under Color of
Law, of which the Ridgeway County Sheriff's Office is the tortfeasor.
#4: Deprivation of Rights under Color of Law (7 Rid. Stat. § 121.403)
Tortfeasor: Law Enforcement Training Center
23. Even furthermore, the Law Enforcement Training Center withheld evidence from the
Plaintiff, which is a violation of, inter alia, due process. In order to prevent these
pleadings to become technical, it need not be explained in detail.
24. Therefore, there is a cause of action for the tort of Deprivation of Rights under Color of
Law, of which the Law Enforcement Training Center is the tortfeasor.
PRAYER FOR RELIEF
Plaintiff is entitled to and requests the following:
1. $8,000 in punitive damages from the Law Enforcement Training Center pursuant to 7
Rid. Stat. § 121.403;
2. thereunder, an injunction enjoining the Law Enforcement Training Center reinstate
Plaintiff's peace officer certification;
3. thereunder, a declaration that the Law Enforcement Training Center was acting ultra vires
by relying on the factfinding and conclusions of the Criminal Investigations Division;
4. thereunder, $8,000 in punitive damages from the Ridgeway County Sheriff's Office;
5. thereunder, a declaration that the Criminal Investigations Division was acting ultra vires
when it investigated noncriminal, non-police officer conduct, and;
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6. any other relief that this Court deems proper. See Rid. Rule Civ. Proc. 8(1) ("Relief in the
alternative or of several different types may be demanded.")
Respectfully submitted,
———————————————
/s/ zuzumbo
Plaintiff of the above-titled civil action;
———————————————
/s/ thr33six8
Filer of this document and Attorney of
Plaintiff/Client zuzumbo;
Licensed Attorney in the State of Ridgeway
since July 23rd, 2026 (R.S.B. License
#19302).
Timezone UTC–05:00.
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