IN THE SUPERIOR COURT OF
THE STATE OF RIDGEWAY
Halo4asin
Plaintiff,
v,
Ridgeway Parks Service,
Defendant.
MOTION FOR LEAVE TO FILE A
SURREPLY
Hon. RummyLeroux
Docket Number: RSC-CM-0750
DEFENDANT’S MOTION FOR LEAVE TO FILE A SURREPLY
Defendant Ridgeway Parks Service ("RPS"), by and through its counsel of record, respectfully
moves this Court for an order granting leave to file the attached Surreply in response to
Plaintiff’s Reply in Support of Motion for Leave to Supplement and Limited Record Relief,
which was dated October 2, 2026. In support of this Motion, Defendant states as follows:
1. Pursuant to Ridgeway Rule of Civil Procedure 7.1(5), no further paper shall be filed on a
motion after a reply has been transmitted without explicit leave of court.
2. On October 2, 2026, Plaintiff transmitted a Reply that introduces entirely new statutory
frameworks, mischaracterizes this Court’s prior orders, and raises distinct discovery arguments
that could not have been reasonably anticipated or fully addressed in Defendant's initial
Opposition.
3. Specifically, Plaintiff’s Reply introduces a brand-new statutory argument under 4 R. Stat. §
123.501(b)-(g), claiming it establishes a non-discretionary "right to a clear and defined reason for
denial" and "court review over prejudicial or harmful employment practices" to bypass the
subjective discretion shield of 4 R. Stat. § 121.103.
4. Furthermore, Plaintiff’s Reply sets forth an unprecedented, circular discovery theory under
Rule 19, seeking a "first tier of limited production" (including application tracker history and
Google Sheet audit trails) before the Court even rules on the threshold issue of whether
supplementation is legally permissible under Rule 16(6).
5. Because Plaintiff introduces these novel interpretations of § 123.501 and seeks to alter the
procedural sequencing of discovery and supplementation for the first time in a reply brief,
Defendant has had no prior opportunity to brief these issues.
6. Basic fairness, due process, and the necessity of maintaining an accurate record for statutory
compliance review require that Defendant be permitted to respond. The proposed Surreply is
concise and strictly confined to rebutting these newly raised points.
MEET AND CONFER CERTIFICATION
Pursuant to Rid. R. Civ. P. 7.1(2)(3), counsel for Defendant certifies that they have conferred in
good faith with the Plaintiff regarding the relief sought in this motion. Plaintiff objects to the
filing of a surreply, necessitating this formal motion.
PRAYER FOR RELIEF
Defendant respectfully requests that this Court grant this Motion for Leave to File a Surreply and
order the Clerk to accept the attached Surreply for filing.
Dated: October 6, 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
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 6th 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 ParksService
