Lawsuit: Pending Vernicia v. Commonwealth of Redmont [2025] FCR 51

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Franciscus

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Case Filing



PARTIES
1. Vernicia (represented by Mezimoří Legal Department)
2. Commonwealth of Redmont

WRITTEN STATEMENT FROM PLAINTIFF

This case arises from the Commonwealth of Redmont’s unprecedented and unconstitutional action on the UTC morning of 16 May 2025, wherein the Department of Commerce (DOC), without legal basis, ordered a mandatory “bank holiday” that purported to freeze all deposits, withdrawals, and transfers from the vast majority of financial institutions across the country for 36 hours. This sweeping order, which exempted only in-game ATMs, applied under threat of unspecified “sanctions and fines” and did not cite any legal justification at the time of issuance.

The Plaintiff, Vernicia, a prominent business owner, was directly harmed by this action. At the time of the bank holiday, she held an account at Volt, a financial institution the Commonwealth did not accuse of any wrongdoing or instability when seeking to institute the freeze. Due to the DOC’s directive, Vernicia was prohibited from withdrawing, depositing, or transfering funds to or from her account—effectively resulting in the temporary seizure of her property by the government.

Only after public objection from legal counsel and the community did the DOC attempt to publicly justify its actions through a vague reference to the Taxation Act §8.3.c, which permits temporary commandeering of individual financial institutions under extraordinary circumstances. However, this statute does not authorize the mass freezing of the entire financial sector on the mere whim of the DOC. Indeed, within three hours, the DOC reversed much of its initially sweeping order, limiting the freeze to only Vanguard National Bank and Discover Bank—institutions it claimed faced specific financial distress. No public explanation was ever offered for why institutions like Volt were included in the initial blanket freeze prior to the initiation of ensuing litigation.

The Plaintiff respectfully submits that the Commonwealth's actions, taken without proper legal authority, represent a dangerous overreach and a breach of fundamental constitutional rights. The Court’s intervention is necessary to redress this harm and prevent its recurrence.
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II. FACTS
  1. On the UTC Morning of 16 May 2025, the Department of Commerce issued an announcement regarding the creation of a so-called “bank holiday” (Evidence P-001).
  2. The text of this announcement read:
    1. DOC MANDATED BANK HOLIDAY

      Due to classified developments, the DOC is mandating a bank holiday for all financial institutions effective immediately for the next 36 hours. All financial institutions may not allow transfers, deposits, or withdrawals for the entirety of the bank holiday. Failure to do so will result in sanctions and fines. In-game ATMs are exempted from this bank holiday and may continue operating. We will reveal more information as it comes out. At this time, we ask members of the public to be patient as we figure the situation out. Questions about the issue will not be entertained at this time.

      Signed
      Avaneesh2008
      Deputy Secretary of Commerce

      (Evidence P-001)
  3. This announcement instructed financial institutions that they were not allowed to permit customer transfers, deposits, or withdrawals during the period of the bank holiday. An exception was made for in-game ATMs.
  4. This announcement threatened unspecified “sanctions and fines” for institutions who allowed transfers, deposits, or withdrawals during the bank holiday.
  5. This announcement did not cite any legal basis for the creation of a mandatory “bank holiday’ across the entire financial sector, nor any law specifying penalties that would result from non-compliance.
  6. The so-called ‘bank holiday’ in effect temporarily rendered financial firm client assets unable to be accessed by clients pursuant to a government order.
  7. The so-called 'bank holiday' in effect temporarily rendered financial firm clients unable to use their bank accounts as tools to digitally receive funds from others.
  8. By rendering financial firm client assets unable to be accessed by clients, the Commonwealth effectively temporarily seized these same assets.
  9. By rendering financial firm client accounts as unusable for receiving deposits or payments from others, the Commonwealth effectively temporarily seized financial firm infrastructure used by these clients.
  10. The Commonwealth did not obtain a subpoena, court order, nor warrant authorizing the so-called 'bank holiday' as was originally announced.
  11. Shortly thereafter, the Attorney General made a post in the #legal channel on discord. (Evidence P-002)
  12. The text of this post stated:
    1. Hello all! Your friendly neighbourhood Attorney General here for a fun fact! The Taxation Act gives the Department of Commerce a non-exhaustive list of suuuuper fun powers they can use to regulate the economy. One relevant subsection you may be interested in is 8.3.c, which I will quote here:

      (c) Commandeer: In extraordinary situations, the Department of Commerce has the power to commandeer and take temporary control of a financial institution. This authority is reserved for exceptional circumstances, such as insolvency, near insolvency, financial crises, or situations where the institution's continued operation poses a systemic risk to the financial system or depositors.

      This has been "Fun facts with the Attorney General" time! Thanks for listening. Hope to see you tomorrow with a new fun fact!
      (Evidence P-002)
  13. On Dec 30, 2023, xEndeavour posted a consolidated Taxation Act on the Forums, which included the same language regarding commandeering as is the current law (Evidence P-003).
  14. Plaintiff Vernicia is a citizen of Redmont.
  15. Plaintiff Vernicia operates customer-facing business. This includes a well-known large commercial store in Revielle, which sells a large variety of items to players, of which the Commonwealth is aware.
  16. Vernicia held at least one account at financial institution during the so-called 'bank holiday'. This includes at least one account at Volt (see: Evidence P-004).
  17. Vernicia's Volt account contains a positive balance exceeding $60,000 (see: Evidence P-004).
  18. Volt provides clients the ability to perform numerous banking tasks digitally via its Discord server ("digital financial infrastructure"; see: Evidence P-000).
  19. These banking tasks include the ability to transfer money between accounts by an account name or routing number (see: Evidence P-000).
  20. During the so-called ‘bank holiday’, Volt was prohibited from allowing Vernicia to withdraw or deposit funds in her corresponding Volt bank account.
  21. Moreover, during the the so-called ‘bank holiday’, Volt was prohibited from facilitating transfers from third parties to Vernicia's account(s) at Volt via Volt's digital financial infrastructure.
  22. Even the Attorney General, other DoJ Staff, Secretary of Commerce, and/or other DoC staff expressed doubt as to the legality of the so-called "bank holiday" during the active consideration thereof (see: Response to Interrogatory No. 1).
  23. Vernicia’s current counsel publicly objected to the Commonwealth’s attempt to commandeer large portions of the financial sector under the Taxation Act as overbroad (Evidence P-005).
  24. After these objections had been made known to the Department of Justice, the Department of Commerce issued another announcement regarding the so-called “bank holiday” (Evidence P-006).
  25. The text of the announcement read as follows:
    1. BANK HOLIDAY LIFTING & VANGUARD SEIZURE

      Due to unexpected speed by everyone involved, we are able to lift the bank holiday for all banks except Vanguard National Bank and Discover Bank who will remain frozen at this time.

      The seizure of Vanguard and Discover bank has begun due to grave liquidity concerns and misrepresentation of financial statements. Deposits are covered by the 50k insurance per person on top of what liquidation of assets cover. Depositors will have first preference when it comes to fulfilling obligations.

      If:
      you are owed debt by Vanguard & Co or any of its subsidiaries, please report this debt to the DOC by making a ticket with proof of the debt's existence.,
      you possess bank notes from Discover Bank ATMs, please also make a ticket and present proof of the deposit claim.,

      More information will be revealed as needed.

      Signed
      Avaneesh2008
      Deputy Secretary of Commerce

      (Evidence P-006)
  26. This announcement substantially narrowed the scope of the “bank holiday”, limiting it to two banks and giving specific reasons for intervention.
  27. The Department of Commerce, however, has not provided specific public justification for why it ordered Volt and other not-presently-seized banks to refuse client requests to withdraw, deposit, or transfer funds in the first place.
  28. Internally, the Commonwealth did not even run any numbers - nor perform any sort of quantitative analysis - when considering what would have happened had Volt not been frozen during the bank holiday as initially announced (see: Response to Interrogatory No. 2).
  29. In fact, it was unreasonable to order large swathes of the financial sector to engage in a so-called “bank holiday” under pain of fines and sanctions, when the Department of Commerce alleged only grave liquidity issues in Vanguard National Bank and Discover Bank, as well as misrepresentation of financial statements by the same.
  30. The threats of fines and sanctions deprived the Plaintiff of certain liberties – including the liberty to receive funds – under purported penalty of law.
  31. The threat of fines and sanctions placed an undue burden on the liberty and security of the Plaintiff without due process of law.

CLAIMS FOR RELIEF
  1. Violations of Constitutional Rights:
    1. Unreasonable seizure:
      • The Constitution of Redmont §33(15) states that “Every citizen has the right to be secure against unreasonable search or seizure”. In prohibiting citizens from withdrawing their money, the government essentially conducted a temporary seizure of Vernicia's financial accounts, such as the Volt account (and associated tools) mentioned in this complaint and the balance contained therein.

        The Department of Commerce did not immediately provide a statutory basis for these seizures, and the closest that we get to a justification from a pertinent government official comes from the Attorney General’s statement referred to in Facts 10-11, which refers to Taxation Act §8.3.c.

        As noted in the Plaintiff’s statement, this does not grant the Department of Commerce carte blanche authority to seize or commandeer the entire financial sector. Rather, “in extraordinary situations, the Department of Commerce has the power to commandeer and take temporary control of a financial institution. This authority is reserved for exceptional circumstances, such as insolvency, near insolvency, financial crises, or situations where the institution's continued operation poses a systemic risk to the financial system or depositors” (emphasis added).

        The statute quite clearly speaks to the commandeer a singular financial institution based on extraordinary situations, not haphazardly freezing the entire financial sector in toto (with exceptions for in-game ATMs). The law does not provide an authority to order what amounts to blanket freezing of interest-bearing deposit accounts across the whole sector under pain of sanctions or fines.

        Because this seizure was undertaken without legal authority, and posed an undue burden on clients of financial firms including the Plaintiff, it was unreasonable under the law.

        In smokeyybunnyyy v. Commonwealth of Redmont [2024] FCR 103, this Court found that “[e]very department within the executive branch has a duty of care to uphold its constitutional obligations”. The Plaintiff respectfully submits that the Department of Commerce failed to uphold its constitutional obligations when it violated the Plaintiff’s rights to be free from unreasonable seizure in its fait accompli freezing of deposits, transfers, and withdrawals within the financial sector.
    2. Violations of liberty and security of the person:
      • The Constitution of Redmont §33(15) states that “Every citizen has the right to life, liberty, and security of the person and the right not to be deprived thereof except in accordance with the principles of fundamental justice.” In stating that failure to adhere to the Commonwealth’s unlawful freeze of financial services accounts would render liability to “sanctions and fines”, the Commonwealth did threaten the liberty and security of the Plaintiff without due process of law. This jawboning is a violation of the Department of Commerce’s duty of care, as the Commonwealth and its executive branches have constitutional obligations to respect the fundamental rights and freedoms of its citizens.

PRAYER FOR RELIEF
The Plaintiff seeks the following from this Court in light of the injuries suffered from Defendant's actions:

  1. DECLARATORY JUDGEMENT:
    • A judgment declaring that the Commonwealth’s actions – namely the so-called “bank holiday” – were unlawful and unconstitutional. This declaration should specify that Defendants’ conduct violated Plaintiff’s right to freedom from unreasonable seizure and Plaintiff's fundamental liberties, as protected by the Constitution of the Commonwealth of Redmont and enshrined throughout our Common Law.
  2. PERMANENT INJUNCTIVE RELIEF
    • A permanent injunction (via a Writ of Mandamus) prohibiting the Commonwealth (including the Department of Commerce, Department of Justice, Federal Reserve Bank, and all executive agencies) from repeating such unconstitutional and unlawful actions in the future. Specifically, this should bar the Commonwealth from imposing any blanket freezes or “holidays” on financial institutions absent cause specific to a particular institution. The injunction will ensure that no other citizen or businessowner suffers similar unauthorized deprivations of rights in the future.
  3. NOMINAL DAMAGES
    • To acknowledge intangible losses arising from the Commonwealth's deprivation of Plaintiff's constitutional rights, the Plaintiff seeks $7,500 in nominal damages.
  4. LEGAL FEES
    • In line with the Legal Damages Act, the Plaintiff seeks 30% of the award as legal fees, with a minimum of $6,000.
Witness List:
  1. Vernicia
  2. Avaneesh2008
  3. xSyncx
  4. Juniperfig
  5. Freeze_Line
  6. Dearev
  7. Stoppers
  8. xEndeavour
  9. DonTrillions
Evidence:
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By making this submission, I agree I understand the penalties of lying in court and the fact that I am subject to perjury should I knowingly make a false statement in court.

DATED: This 29 day of May 2025

 
Last edited:

Writ of Summons


@juniperfig is required to appear before the Federal Court in the case of Vernicia v. Commonwealth of Redmont [2025] FCR 50.

Failure to appear within 72 hours of this summons will result in a default judgement based on the known facts of the case.

Both parties should make themselves aware of the Court Rules and Procedures, including the option of an in-game trial should both parties request one.

 
The Commonwealth is present, Your Honor.
 

Answer to Complaint


IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
ANSWER TO COMPLAINT

Vernicia
Plaintiff

v.

Commonwealth of Redmont
Defendant

I. ANSWER TO COMPLAINT

  1. AFFIRM that on the UTC Morning of 16 May 2025, the Department of Commerce issued an announcement regarding the creation of a so-called “bank holiday” (Evidence P-001).
  2. AFFIRM that the text of this announcement read:
    1. DOC MANDATED BANK HOLIDAY

      Due to classified developments, the DOC is mandating a bank holiday for all financial institutions effective immediately for the next 36 hours. All financial institutions may not allow transfers, deposits, or withdrawals for the entirety of the bank holiday. Failure to do so will result in sanctions and fines. In-game ATMs are exempted from this bank holiday and may continue operating. We will reveal more information as it comes out. At this time, we ask members of the public to be patient as we figure the situation out. Questions about the issue will not be entertained at this time.

      Signed
      Avaneesh2008
      Deputy Secretary of Commerce

      (Evidence P-001)
  3. AFFIRM that this announcement instructed financial institutions that they were not allowed to permit customer transfers, deposits, or withdrawals during the period of the bank holiday. An exception was made for in-game ATMs.
  4. AFFIRM that this announcement threatened unspecified “sanctions and fines” for institutions who allowed transfers, deposits, or withdrawals during the bank holiday.
  5. AFFIRM that this announcement did not cite any legal basis for the creation of a mandatory “bank holiday’ across the entire financial sector, nor any law specifying penalties that would result from non-compliance.
  6. AFFIRM that the so-called ‘bank holiday’ in effect temporarily rendered financial firm client assets unable to be accessed by clients pursuant to a government order.
  7. AFFIRM that the so-called 'bank holiday' in effect temporarily rendered financial firm clients unable to use their bank accounts as tools to digitally receive funds from others.
  8. DENY that by rendering financial firm client assets unable to be accessed by clients, the Commonwealth effectively temporarily seized these same assets.
  9. DENY that by rendering financial firm client accounts as unusable for receiving deposits or payments from others, the Commonwealth effectively temporarily seized financial firm infrastructure used by these clients.
  10. AFFIRM that the Commonwealth did not obtain a subpoena, court order, nor warrant authorizing the so-called 'bank holiday' as was originally announced.
  11. AFFIRM that shortly thereafter, the Attorney General made a post in the #legal channel on discord. (Evidence P-002)
  12. AFFIRM that the text of this post stated:
    1. Hello all! Your friendly neighbourhood Attorney General here for a fun fact! The Taxation Act gives the Department of Commerce a non-exhaustive list of suuuuper fun powers they can use to regulate the economy. One relevant subsection you may be interested in is 8.3.c, which I will quote here:

      (c) Commandeer: In extraordinary situations, the Department of Commerce has the power to commandeer and take temporary control of a financial institution. This authority is reserved for exceptional circumstances, such as insolvency, near insolvency, financial crises, or situations where the institution's continued operation poses a systemic risk to the financial system or depositors.

      This has been "Fun facts with the Attorney General" time! Thanks for listening. Hope to see you tomorrow with a new fun fact!
      (Evidence P-002)
  13. AFFIRM that on Dec 30, 2023, xEndeavour posted a consolidated Taxation Act on the Forums, which included the same language regarding commandeering as is the current law (Evidence P-003).
  14. AFFIRM that Plaintiff Vernicia is a citizen of Redmont.
  15. AFFIRM that Plaintiff Vernicia operates customer-facing business. This includes a well-known large commercial store in Revielle, which sells a large variety of items to players, of which the Commonwealth is aware.
  16. AFFIRM that Vernicia held at least one account at financial institution during the so-called 'bank holiday'. This includes at least one account at Volt (see: Evidence P-004).
  17. AFFIRM that Vernicia's Volt account contains a positive balance exceeding $60,000 (see: Evidence P-004).
  18. AFFIRM that Volt provides clients the ability to perform numerous banking tasks digitally via its Discord server ("digital financial infrastructure"; see: Evidence P-000).
  19. AFFIRM that these banking tasks include the ability to transfer money between accounts by an account name or routing number (see: Evidence P-000).
  20. AFFIRM that during the so-called ‘bank holiday’, Volt was prohibited from allowing Vernicia to withdraw or deposit funds in her corresponding Volt bank account.
  21. AFFIRM that moreover, during the the so-called ‘bank holiday’, Volt was prohibited from facilitating transfers from third parties to Vernicia's account(s) at Volt via Volt's digital financial infrastructure.
  22. AFFIRM that Vernicia’s current counsel publicly objected to the Commonwealth’s attempt to commandeer large portions of the financial sector under the Taxation Act as overbroad (Evidence P-005).
  23. NEITHER AFFIRM OR DENY that after these objections had been made known to the Department of Justice, the Department of Commerce issued another announcement regarding the so-called “bank holiday” (Evidence P-006).
  24. AFFIRM that the text of the announcement read as follows:
    1. BANK HOLIDAY LIFTING & VANGUARD SEIZURE

      Due to unexpected speed by everyone involved, we are able to lift the bank holiday for all banks except Vanguard National Bank and Discover Bank who will remain frozen at this time.

      The seizure of Vanguard and Discover bank has begun due to grave liquidity concerns and misrepresentation of financial statements. Deposits are covered by the 50k insurance per person on top of what liquidation of assets cover. Depositors will have first preference when it comes to fulfilling obligations.

      If:
      you are owed debt by Vanguard & Co or any of its subsidiaries, please report this debt to the DOC by making a ticket with proof of the debt's existence.,
      you possess bank notes from Discover Bank ATMs, please also make a ticket and present proof of the deposit claim.,

      More information will be revealed as needed.

      Signed
      Avaneesh2008
      Deputy Secretary of Commerce

      (Evidence P-006)
  25. AFFIRM that this announcement substantially narrowed the scope of the “bank holiday”, limiting it to two banks and giving specific reasons for intervention.
  26. AFFIRM that the Department of Commerce, however, has not provided specific public justification for why it ordered Volt and other not-presently-seized banks to refuse client requests to withdraw, deposit, or transfer funds in the first place.
  27. DENY that in fact, it was unreasonable to order large swathes of the financial sector to engage in a so-called “bank holiday” under pain of fines and sanctions, when the Department of Commerce alleged only grave liquidity issues in Vanguard National Bank and Discover Bank, as well as misrepresentation of financial statements by the same.
  28. DENY that the threats of fines and sanctions deprived the Plaintiff of certain liberties – including the liberty to receive funds – under purported penalty of law.
  29. DENY that the threat of fines and sanctions placed an undue burden on the liberty and security of the Plaintiff without due process of law.

II. DEFENSES

1. Taxation Act §8 gives broad non-exhaustive power to the DOC to protect depositors of deposit-taking institutions.
2. There are no restrictions outlined in the Taxation Act that would prevent the DoC from enacting this power.
3. The first imposed 36 hours reduced later (to 3 hours) shows how swiftly the DoC acted to protect depositor interests and the financial industry at large.
4. The DoC took control of the financial industry for the protection of the depositors of deposit-taking institutions of Redmont.
5. By operating a financial institution banks are expected to follow laws and regulations set forth by the DoC outlined in Commercial Standards Act §4 - Powers of the Commerce Department & Taxation Act §8 - Powers of the Department of Commerce .
6. The Government acknowledges the risks of Commercial Banks and insure funds up to a certain point as outlined in Taxation Act §9 - Deposit Guarantee.
7. This power as exercised is in line with ‘reasonable limits prescribed by law that are justified in a free and democratic society’ as expressed in our Constitution.
8.The DoC determined that the perceived insecurity of the economic climate at the time was an extraordinary situation which is necessitated for these powers be used, as outlined in the Taxation Act.

By making this submission, I agree I understand the penalties of lying in court and the fact that I am subject to perjury should I knowingly make a false statement in court.

DATED: This 1st day of June 2025

 
We will now be entering discovery, discovery will last 5 days starting now.
 
Your honor,

Brief


IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
REQUESTS FOR DISCOVERY

In line with Rule 4.7 (Request for Discovery, Opposing Party Movement), the Plaintiff requests the following items from the Commonwealth:

  1. Copies of all documents submitted by the Defense during discovery of Gnomewhisperer and GnomeCorp v Commonwealth of Redmont [2025] FCR 47, except those which pertained specifically to bank balances held by GnomeWhisperer and/or GnomeCorp;
  2. Any conversations by employees of the Department of Commerce, Federal Reserve Bank, Department of Justice, or other relevant Commonwealth executive agencies, which pertain to the stability of Volt between the UTC dates 11 May 2025 and 17 May 2025 and are in the possession of the Commonwealth, Attorney General, Solicitor(s) General, Secretary of Commerce, Deputy Secretary of Commerce, Federal Reserve Bank Governor or Lieutenant Governor, or any other Commonwealth employees of the Department of Commerce, Department of Justice, or Federal Reserve Bank.


Your Honor, as some of the above requested information may only be shared in closed court, the Plaintiff also moves as follows:

Motion


IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
MOTION FOR CLOSED COURT SESSION

Your honor,

As in Gnomewhisperer and GnomeCorp v Commonwealth of Redmont [2025] FCR 47, the Plaintiff expects that the Defense will only be able to submit certain requested documents in a closed court. Therefore, as in that case, the Plaintiff requests a closed court session be opened for this case.

 
Franciscus said:
Your honor,

Brief


IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
REQUESTS FOR DISCOVERY

In line with Rule 4.7 (Request for Discovery, Opposing Party Movement), the Plaintiff requests the following items from the Commonwealth:

  1. Copies of all documents submitted by the Defense during discovery of Gnomewhisperer and GnomeCorp v Commonwealth of Redmont [2025] FCR 47, except those which pertained specifically to bank balances held by GnomeWhisperer and/or GnomeCorp;
  2. Any conversations by employees of the Department of Commerce, Federal Reserve Bank, Department of Justice, or other relevant Commonwealth executive agencies, which pertain to the stability of Volt between the UTC dates 11 May 2025 and 17 May 2025 and are in the possession of the Commonwealth, Attorney General, Solicitor(s) General, Secretary of Commerce, Deputy Secretary of Commerce, Federal Reserve Bank Governor or Lieutenant Governor, or any other Commonwealth employees of the Department of Commerce, Department of Justice, or Federal Reserve Bank.


Your Honor, as some of the above requested information may only be shared in closed court, the Plaintiff also moves as follows:

Motion


IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
MOTION FOR CLOSED COURT SESSION

Your honor,

As in Gnomewhisperer and GnomeCorp v Commonwealth of Redmont [2025] FCR 47, the Plaintiff expects that the Defense will only be able to submit certain requested documents in a closed court. Therefore, as in that case, the Plaintiff requests a closed court session be opened for this case.

Click to expand...
Motion for closed court session granted
 
Your honor:

Brief


IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
SUBMISSION OF INTERROGATORIES

Pursuant to Rule 4.8 (Interrogatories), the Plaintiff submits the following interrogatories which the Defendant must answer truthfully and to the best of their ability:

  1. Yes or no:
    • Did, at any point during the active consideration of the so-called "bank holiday" and prior to its initial announcement, the Attorney General, other DoJ Staff, Secretary of Commerce, or other DoC staff express doubt as to the legality of the so-called "bank holiday"?
  2. Yes or no:
    • Did, at any point during the active consideration of the so-called "bank holiday" and prior to its initial announcement, the Department of Justice, Department of Commerce, or Federal Reserve Bank conduct any quantitative analysis on the predicted impact of the seizure of Vanguard on Volt in the absence of a bank holiday?

 
Franciscus said:
Your honor,

Brief


IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
REQUESTS FOR DISCOVERY

In line with Rule 4.7 (Request for Discovery, Opposing Party Movement), the Plaintiff requests the following items from the Commonwealth:

  1. Copies of all documents submitted by the Defense during discovery of Gnomewhisperer and GnomeCorp v Commonwealth of Redmont [2025] FCR 47, except those which pertained specifically to bank balances held by GnomeWhisperer and/or GnomeCorp;
  2. Any conversations by employees of the Department of Commerce, Federal Reserve Bank, Department of Justice, or other relevant Commonwealth executive agencies, which pertain to the stability of Volt between the UTC dates 11 May 2025 and 17 May 2025 and are in the possession of the Commonwealth, Attorney General, Solicitor(s) General, Secretary of Commerce, Deputy Secretary of Commerce, Federal Reserve Bank Governor or Lieutenant Governor, or any other Commonwealth employees of the Department of Commerce, Department of Justice, or Federal Reserve Bank.

Click to expand...

Your honor:

Motion


IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
MOTION TO COMPEL

It has been approximately 28 hours since the requests for Discovery under Rule 4.7 were made, and no response has been provided by the Commonwealth as to whether or not they intend to provide such information - whether in open or closed Court.

I ask that this Court compel the Commonwealth to provide the requested information within 24 hours.

 
Your honor:

Brief


IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
SUBMISSION OF FURTHER INTERROGATORIES

Pursuant to Rule 4.8 (Interrogatories), the Plaintiff submits the following additional 3 interrogatories which the Defendant must answer truthfully and to the best of their ability:

  1. Why did the Commonwealth find it necessary to freeze the ability of Volt's customers to deposit, withdraw, and transfer funds during the so-called "bank holiday"?
  2. In the view of the Commonwealth, how does the Commonwealth define a "seizure" as used in Const. 32(15)?
  3. In the view of the Commonwealth, how does the Commonwealth define "liberty" as used in Const. 32(14)?

 
Franciscus said:
Your honor:

Brief


IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
SUBMISSION OF INTERROGATORIES

Pursuant to Rule 4.8 (Interrogatories), the Plaintiff submits the following interrogatories which the Defendant must answer truthfully and to the best of their ability:

  1. Yes or no:
    • Did, at any point during the active consideration of the so-called "bank holiday" and prior to its initial announcement, the Attorney General, other DoJ Staff, Secretary of Commerce, or other DoC staff express doubt as to the legality of the so-called "bank holiday"?
  2. Yes or no:
    • Did, at any point during the active consideration of the so-called "bank holiday" and prior to its initial announcement, the Department of Justice, Department of Commerce, or Federal Reserve Bank conduct any quantitative analysis on the predicted impact of the seizure of Vanguard on Volt in the absence of a bank holiday?

Click to expand...
Your honor:

Motion


IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
MOTION FOR DEFAULT JUDGEMENT

Under Rule 4.8 (Interrogatories), “Answers to Interrogatories must be made within 48 hours of being asked.”

48 hours have come and gone. The Commonwealth, with all its resources, has simply failed to respond as required.

For this reason, the Plaintiff asks the court to enter a default judgement in this case against the Commonwealth, and to hold the Attorney General in contempt for failing to provide responses in line with court rules.

 
Your Honor, the Defense respectfully requests an extension of 48 hours for their response to the 5 interrogatories submitted by the Plaintiff.
 
gribble19 said:
Your Honor, the Defense respectfully requests an extension of 48 hours for their response to the 5 interrogatories submitted by the Plaintiff.
Click to expand...

Your honor,

May the Plaintiff’s counsel respond to this request? The Plaintiff’s counsel would like to speak to the Defense’s not providing documents requested in discovery (or to object to any requests), the timeline imposed by the requested extension, and how this might affect the Plaintiff’s ability to conduct effective discovery in this case; we request permission to submit a brief on these topics.
 
Franciscus said:
Your honor,

May the Plaintiff’s counsel respond to this request? The Plaintiff’s counsel would like to speak to the Defense’s not providing documents requested in discovery (or to object to any requests), the timeline imposed by the requested extension, and how this might affect the Plaintiff’s ability to conduct effective discovery in this case; we request permission to submit a brief on these topics.
Click to expand...
Granted. You have 24 hours.
 
gribble19 said:
Your Honor, the Defense respectfully requests an extension of 48 hours for their response to the 5 interrogatories submitted by the Plaintiff.
Click to expand...

Response


Your honor:

I. The Commonwealth has Consistently Failed to Produce Information in this Case​

Ia. The Commonwealth has not Provided Readily Available Documents in Discovery

On 2 June 2025, one day prior, the Plaintiff made known related discovery requests on the Commonwealth. The discovery requests sought, inter alia:
  1. Copies of all documents the Commonwealth had disclosed in a prior, related case (GnomeWhisperer and GnomeCorp v. Commonwealth of Redmont [2025] FCR 47); and
  2. Any internal communications by Department of Commerce, Federal Reserve Bank, or Department of Justice employees pertaining to the stability of the Volt currency between 11 May 2025 and 17 May 2025.
While the second request may take time to gather, the materials for the first request had already been gathered and produced by the Commonwealth in the GnomeWhisperer case, indicating they are readily available to the Commonwealth. But, despite at least the first request being composed of documents readily available to the Commonwealth (though some, like in GnomeWhisperer v Commonwealth, are certainly classified and for reasons of classification can only be produced by the Commonwealth and in closed court) no documents request has been fulfilled by the Commonwealth thus far.

Ib. The Commonwealth has also Failed to Timely Respond to Interrogatories

On 3 June 2025, during the discovery phase of this case, the Plaintiff submitted two interrogatories. The Court’s Rule 4.8 (Interrogatories) required the Commonwealth to either answer these interrogatories "within 48 hours of being asked" and to lodge any objections within 24 hours. Because these were filed on 2:49 P.M. EDT on 3 June 2025 the Defense’s answers for the these two interrogatories were due by 2:49 P.M. EDT on 5 June 2025, 48 hours after service. The Defense did not object to these interrogatories.

Despite these clear obligations, the Defense produced no answers by the deadline, nor did it file any timely objection to the interrogatories. The 48-hour period elapsed without any response from the Commonwealth whatsoever, even though the information requested is (in our view) extremely important to the case. Only after the deadline had passed – and after Plaintiff moved for a default judgment due to the Defense’s non-compliance and total non-response – did the Defense come forward with a cursory request for a 48-hour extension to respond. Notably, the Defense’s extension request was presented with no explanation or justification whatsoever for its failure to meet the original deadline; it was a bare plea for more time, coming after the default-triggering deadline had already expired.

II. Granting an Extension would be Unduly Prejudicial to the Plaintiff and Reward the Defense’s Dilatory Tactics
Allowing the Defense an extension at this stage would significantly prejudice the Plaintiff and reward non-compliance.

The Plaintiff has a right to a fair and prompt discovery process. Every day of delay hampers the Plaintiff’s ability to uncover the truth and prepare for the next phases of trial, including by identifying witnesses and gathering evidence for submission during the late phases of discovery that might be relevant should the Commonwealth reply to an interrogatory in a particular way.

The length of the discovery process and the timely filing requirements regarding interrogatories are closely related. Under Rule 4.3 (Required Days of Discovery), discovery is initially set for five days. Under Rule 4.4, interrogatories are due 72 hours prior to the end of discovery, with responses given no more than 48 hours later. This guarantees the parties to have at least 24 hours after the responses to interrogatories are due in order to finalize discovery items, such as by making additional requests, submitting additional evidence, or amending complaints to incorporate information learned during discovery - such as in response to interrogatories.

Your honor ordered the beginning of discovery at 6:36 P.M. EDT on 3 June 2025, and for it to last 5 days; this would cause discovery to end at 6:36 P.M. EDT on 8 June 2025. The two interrogatories for which the Commonwealth has failed to reply timely were asked over one day before the final deadline to submit interrogatories under Rule 4.4. This was on purpose - the Plaintiff was expecting (in line with Court rules) to have substantial time after the Commonwealth's responses to make amendments to the Complaint, gather additional evidence in response, and modify witness lists.

When the Commonwealth requested a 48-hour extension to submit their response at 5:41 PM on 6 June, with under 49 hours remained during discovery. Even if Your Honor had instantaneously granted the Commonwealth's request, the Plaintiff would have been left with less than 1 hour after a response was due to make changes to our complaint, gather evidence, update witness lists, and perform other necessary tasks before discovery ended.

This would have been an absurd situation, and would have been unduly prejudicial to the Plaintiff's ability to vigorously pursue this case. This goes to the heart of the purpose of discovery which, as Rule 4.1 (Scope and Purpose of Discovery) notes, "is to enable fairness by allowing the parties to view the information so that they may properly formulate their legal arguments" (emphaisis mine).

By missing the 48-hour window for two interrogatory answers, the Defense has already caused a delay. And granting an extension several hours after the answers were due would only compound that delay in a manner unfavorable to the Plaintiff - all because the Commonwealth (and all its resources) failed to answer two "yes or no" questions in a timely manner.

III. Conclusion: The Extension Request is Untimely, Lacks Good Cause, and would Unduly Harm the Plaintiff

The Defense’s eleventh-hour request for an extension should be denied because it was made after the deadline had already passed and fails to meet the standards for motions or extensions under court procedures. If the Defense genuinely needed more time to compile its responses, the proper course would have been to ask for an extension of discovery before the response deadline expired, or at least before Plaintiff moved to seek a default judgement as a remedy for non-compliance with standard deadlines.

In a similar situation in MrFluffy2U94 v. Commonwealth of Redmont [2025] FCR 41, the defendant failed to appear by the set deadline and later attempted to excuse this failure and submit a late response. The plaintiff’s counsel objected, noting that the request from the Commonwealth was not a proper motion and that "there is simply no excuse for the Commonwealth to miss this". The Court in that case refused to entertain the late, informal request and proceeded toward default judgment.

While the above occurred at a different point during the trial - the two issues are quite similar in principle. But here, the Court should be even less sympathetic to the Commonwealth's informal and tardy request; the Commonwealth’s extension request was filed as a one-line plea after the deadline, without any cause shown for the delay. There was no claim of unforeseen hardship, no explanation of why already-known documents could not be or have not been produced. Nothing at all.

Nothing. What is this Court supposed to make of that?

It’s clear that the Commonwealth here falls far short of any reasonable or required standard for relief. It is effectively a request for the Court to overlook a blatant procedural default for no stated reason. Granting such a request would undermine the integrity of the discovery, and would be unduly harmful to the Plaintiff. As this Court in MrFluffy2U94 v. Commonwealth noted, when a deadline passes and default is looming, the Commonwealth's “incompetence is not an excuse”. The same principle applies here. The Defense’s post-deadline, unsupported request is not only late; the Commonwealth also has provided not even an attempt at an excuse for the its own lackadaisical and contemptuous behavior.

The request for extension should be denied, and default judgement should be granted.



 
Your Honor, taking into consideration the Plaintiff's worries regarding their inability to properly take further actions in Discovery based on the defense's responses to the interrogatories, as well as considering the size and complexity of this case in general, the defense respectfully requests an extension to Discovery of 72 hours from the original deadline.
 
gribble19 said:
Your Honor, taking into consideration the Plaintiff's worries regarding their inability to properly take further actions in Discovery based on the defense's responses to the interrogatories, as well as considering the size and complexity of this case in general, the defense respectfully requests an extension to Discovery of 72 hours from the original deadline.
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Granted
 
MOTION FOR DEFAULT JUDGEMENT
Denied. At least for now.

MOTION TO COMPEL
Granted. The defense in this case has failed for multiple days to participate in the discovery process at all. The defense has 24 hours from this order to provide both the answers to interrogations and the requested evidence in the closed court session otherwise this case will go to default judgement. Take this as your one and only warning.
 
RESPONSE TO INTERROGATORIES
1. Yes or no:
  • Did, at any point during the active consideration of the so-called "bank holiday" and prior to its initial announcement, the Attorney General, other DoJ Staff, Secretary of Commerce, or other DoC staff express doubt as to the legality of the so-called "bank holiday"?
Yes

2. Yes or no:
  • Did, at any point during the active consideration of the so-called "bank holiday" and prior to its initial announcement, the Department of Justice, Department of Commerce, or Federal Reserve Bank conduct any quantitative analysis on the predicted impact of the seizure of Vanguard on Volt in the absence of a bank holiday?
No

3. Why did the Commonwealth find it necessary to freeze the ability of Volt's customers to deposit, withdraw, and transfer funds during the so-called "bank holiday"?

The DoC found it necessary to freeze the ability of Volt's customers to deposit, withdraw, and transfer funds, as it did with all banks, to prevent a run on the banks.

4. In the view of the Commonwealth, how does the Commonwealth define a "seizure" as used in Const. 32(15)?

Seizure is the act of taking the possessions of an individual into the possession of the Commonwealth through legal means.

5. In the view of the Commonwealth, how does the Commonwealth define "liberty" as used in Const. 32(14)?

Liberty is the right of Redmont Citizens to be free from undue restrictions on their way of life.
 

Motion


IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
MOTION TO AMEND
Your honor,

The Plaintiff seeks to amend the Complaint to add the following facts, and to renumber the Complaint consequently as-needed:

  • After Fact 21:
    • 22. Even the Attorney General, other DoJ Staff, Secretary of Commerce, and/or other DoC staff expressed doubt as to the legality of the so-called "bank holiday" during the active consideration thereof (see: Response to Interrogatory No. 1).
  • After current Fact 26, which will be re-numbered to Fact 27 upon the above amendment:
    • 28. Internally, the Commonwealth did not even run any numbers - nor perform any sort of quantitative analysis - when considering what would have happened had Volt not been frozen during the bank holiday as initially announced (see: Response to Interrogatory No. 2).



Furthermore:

Brief


IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
REQUESTS FOR DISCOVERY

In line with Rule 4.7 (Request for Discovery, Opposing Party Movement), the Plaintiff requests the following additional items from the Commonwealth:

  • Any copies of any qualitative analysis on the predicted impact of the seizure of Vanguard on Volt in the absence of a bank holiday, such that these analyses were used any point during the active consideration of the so-called "bank holiday" and prior to its initial announcement to the public.

 
Franciscus said:

Motion


IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
MOTION TO AMEND
Your honor,

The Plaintiff seeks to amend the Complaint to add the following facts, and to renumber the Complaint consequently as-needed:

  • After Fact 21:
    • 22. Even the Attorney General, other DoJ Staff, Secretary of Commerce, and/or other DoC staff expressed doubt as to the legality of the so-called "bank holiday" during the active consideration thereof (see: Response to Interrogatory No. 1).
  • After current Fact 26, which will be re-numbered to Fact 27 upon the above amendment:
    • 28. Internally, the Commonwealth did not even run any numbers - nor perform any sort of quantitative analysis - when considering what would have happened had Volt not been frozen during the bank holiday as initially announced (see: Response to Interrogatory No. 2).



Furthermore:

Brief


IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
REQUESTS FOR DISCOVERY

In line with Rule 4.7 (Request for Discovery, Opposing Party Movement), the Plaintiff requests the following additional items from the Commonwealth:

  • Any copies of any qualitative analysis on the predicted impact of the seizure of Vanguard on Volt in the absence of a bank holiday, such that these analyses were used any point during the active consideration of the so-called "bank holiday" and prior to its initial announcement to the public.

Click to expand...
Motion to Amend Granted.
 
Franciscus said:

Brief


IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
REQUESTS FOR DISCOVERY

In line with Rule 4.7 (Request for Discovery, Opposing Party Movement), the Plaintiff requests the following additional items from the Commonwealth:

  • Any copies of any qualitative analysis on the predicted impact of the seizure of Vanguard on Volt in the absence of a bank holiday, such that these analyses were used any point during the active consideration of the so-called "bank holiday" and prior to its initial announcement to the public.

Click to expand...

Motion


IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
MOTION TO COMPEL

Your honor,

As has been such throughout this case, the Commonwealth has not swiftly responded whatsoever to this request. I ask that the Court order the Commonwealth to produce these documents within 24 hours.

 

Motion


IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
MOTION TO DISMISS

The Defense moves that the complaint in this case be dismissed, and in support thereof, respectfully alleges:

1. Rule 5.9 (Collateral Estoppel) of the Court Rules and Procedures states that "A Motion to Dismiss may be filed if a case with a similar or, more exceptionally, same fact set has already been previously litigated."

2. Gnomewhisperer and GnomeCorp v Commonwealth of Redmont [2025] FCR 47 clearly has a fact set extremely similar to the fact set of this case. [2025] FCR 47 pertains to the exact same situation as this case does and the similarities between the fact sets are obvious, with most facts in this case being direct copies of facts from [2025] FCR 47. [2025] FCR 47 was specifically dismissed with prejudice and therefore constitutes a litigated case.

3. The Plaintiff may argue that Collateral Estoppel should not apply in this case as Plaintiff is not the same plaintiff as the one in [2025] FCR 47. However, precedent has shown that Collateral Estoppel still applies when the two cases with similar fact sets have different plaintiffs. Nacholebraa v. Milkcrack [2024] FCR 10 was dismissed "based on the fact that the facts of this case are very similar to those already tried and decided upon." after a motion to reconsider a motion to dismiss was made, which brought up pepper5980 v. FTGWop [2023] DCR 4 and claimed that this would be valid grounds for dismissal under Rule 5.9. It is obvious that the plaintiffs in [2042] FCR 10 and [2023] DCR 4 are entirely different, and yet a motion to dismiss due to the similarity of the fact set to that of a case which was already tried was still accepted.

4. The Plaintiff may argue that Collateral Estoppel should not apply in this case as [2025] FCR 47 was dismissed with prejudice and did not reach a verdict. However, precedent has shown that Collateral Estoppel also applies to cases which have been dismissed with prejudice. In Bardiya_King v. CrackedAmeoba1 [2024] DCR 29 the Defendant filed a motion to dismiss because the fact set of the case was incredibly similar to the fact set of another case which was dismissed with prejudice. This Motion to Dismiss was granted and [2024] DCR 29 was dismissed with prejudice as the other case had been. Precedent thus shows that when a case is dismissed with prejudice it is considered litigated for the sake of the application of Rule 5.9.

 
Your honor,

The Plaintiff respectfully requests right to reply to this motion to dismiss.
 
Franciscus said:
Your honor,

The Plaintiff respectfully requests right to reply to this motion to dismiss.
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Moreover, we request specifically the right to reply in closed court, as certain details relevant to the dismissal of the Gnomewhisperer case that the Plaintiff believes to be extremely relevant here are under seal of closed court.
 
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