Lawsuit: Pending jsrkiwi v Department of Homeland Security [2025] DCR 93

jsrkiwi

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jsrkiwi
jsrkiwi
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Case Filing


IN THE DISTRICT COURT OF THE COMMONWEALTH OF REDMONT

CIVIL ACTION

jsrkiwi
Plaintiff

v.

Department of Homeland Security
Defendant

COMPLAINT
The Plaintiff complains against the Defendant as follows:

WRITTEN STATEMENT FROM THE PLAINTIFF

The Department of Homeland Security issued multiple trespass fines against the Plaintiff without evidence of lawful prior instructions. The decision is unlawful, procedurally unfair, unsupported by evidence, and has resulted in an unjust fine and an improper criminal record entry. The Plaintiff seeks to have the decision overturned and the record cleared.

Beyond the findings against the Plaintiff personally, this case addresses a recurring defect in DHS enforcement. Multiple citizens have been charged with trespass on the basis of the same “ban-list book” method used by the citizen complainant, Vernicia. Each of those cases suffers from identical procedural failures: no proof of service of non-trespass instructions, no confirmation that the accused ever received any instructions, and no evidence establishing when the alleged notice was created. These errors are systemic, not isolated, and I therefore seek relief that corrects my own charges and any other trespass findings that relied solely on this same unlawful evidentiary practice.

I. PARTIES
1. jsrkiwi: Plaintiff, a citizen subject to DHS enforcement actions.
2. Department of Homeland Security: Defendant, the government body responsible for determining guilt for summary criminal offences, arresting and imprisoning criminals, issuing fines and record entry challenged in this action.
3. Plaintiff also challenges a broader DHS pattern of issuing trespass charges based on the same defective “ban-list book” method. Additional affected individuals will be added to the witness list as discovery proceeds.
4. Vernicia: Witness, citizen complainant in all relevant trespass cases and creator of the “ban-list books” forming the basis of the charges challenged in this action.
5. Goldendude15: Witness, the Police Officer who handled the complaint by Vernicia, created the criminal record, and fined the Plaintiff.
6. Roryyy_: Witness, Secretary of the Department of Homeland Security.

II. FACTS
1. On 13th November 2025, the Department of Homeland Security (DHS) created a criminal record for the Plaintiff, listing five trespass offences at locations c108 and c995.
2. On 13th November 2025 at 10:37 UTC, the Plaintiff was fined $2,900 for ‘Trespass x5 (First, Second, and Subsequent charges)’; and a wanted point was created for 35 minutes imprisonment.
3. The supporting evidence for the criminal record was five screenshots provided by Vernicia through ticket dhs-25341. These screenshots show:
(i) Sales records showing the sale of coal blocks by the Plaintiff to Vernicia at ‘14h24m ago’;
(ii) The third page of the book outside of one of the entrances to c995. The page is titled ‘ban list’, and the name of the Plaintiff is listed on the third line from the bottom;
(iii) Sales records showing the sale of 27 iron blocks at ‘1d11h23m ago; 300 coal blocks by the Plaintiff to Vernicia at ‘1d12h38m ago’; and the sale of 960 coal by the Plaintiff to Vernicia at ‘1d12h40m ago’.
(iv) Sales records showing the sale of 65 redstone blocks by the Plaintiff to MZCD at ‘11-11-2025 17:13:50’; the sale of 64 redstone by the Plaintiff to MZCD at ‘11-11-2025 17:13:39’; the sale of 66 lapis blocks by the Plaintiff to MZCD at ‘11-11-2025 17:13:30’; and the sale of 116 lapis lazuli by the Plaintiff to MZCD at ‘11-11-2025 17:13:07’.
(v) Sales records showing the sale of 3 iron blocks to MZCD at ‘11-11-2025 16:47:02’.
4. Only one screenshot includes a timestamp: 13 November 2025 at 05:12 (CET). Two others show indirect metadata; two show none.
5. No evidence is held by the DHS that the book outside c995 was updated to include the Plaintiff’s name prior to the Plaintiff transacting on the plots.
6. No instructions or notice banning the Plaintiff from a property has ever been served upon the Plaintiff by Vernicia. The Plaintiff had no reason to believe that he was banned from entering plots c108 or c995.
7. Plaintiff accessed both properties c108 and c995 exclusively by warp (‘/home vernicia’ and ‘/home mzcd’) and did not walk through the entrance, meaning the book shown in the second screenshot was never visible to him.
8. The property owner (Vernicia) has personally observed Plaintiff warping into c995 before and therefore knew Plaintiff would not see any book.
9. The books outside c108 and c995 do not specify what the ban relates to.
10. Plaintiff has knowledge from his work as a Police Trainee of the existence several other individuals who were charged with trespass at properties owned or controlled by the same private citizen, Vernicia.
11. In each of these cases, the method of ‘instruction’ was identical: reliance on a book placed at the property entrance, with no proof of service and no confirmation that the accused ever saw it.
12. In each of these cases, the ‘proof’ used by the DHS to support the conviction of Trespass is identical: a screenshot of the book showing the accused’s name, and a screenshot showing sales records. In each case, there is no evidence that any instruction was properly served by Vernicia to any of the accused individuals, or that the book was updated prior to the sales taking place.
13. The similarity of fact patterns across multiple cases indicates that DHS applied an unofficial, and unlawful low standard specifically when handling trespass complaints originating from Vernicia.
14. At 14:37 UTC on 13th November 2025, The Plaintiff attempted to dispute the charges through a government ticket (dhs-25445). As of 72 hours later, the DHS had not responded to the ticket and the decision remained uncorrected. At 15:47 UTC on 16th November 2025, with the ticket having become the oldest charge-dispute ticket on the DHS tickets list, the Plaintiff closed the ticket, and now files this action.

III. CLAIMS FOR RELIEF
1. Under the Criminal Code, a person commits the offence of Trespass if the person enters or remains in a non-public or restricted area against instructions’; or ‘is a landlord and enters a tenant's region without reasonable prior notice, unless an exemption applies’.
2. The ‘ban-list’ book relied upon by DHS does not constitute a valid instruction under any reasonable interpretation of the Criminal Code, as it provides no description of the conduct prohibited, no proof of service, and no confirmation that the Plaintiff ever received or could have received the alleged notice.
3. Even if the book were capable of constituting a lawful instruction, DHS possesses no evidence that the book was updated to include the Plaintiff’s name prior to his entry into plots c108 and c995, rendering any alleged instruction void for lack of temporal proof.
4. DHS acted arbitrarily and capriciously by issuing criminal findings without any reliable evidence that valid instructions were ever given, and by treating a book placed at an entrance, which the Plaintiff never uses, as if it constituted proper notice, despite there being no proof of service or receipt.
5. DHS relied on ambiguous evidence, as the ‘ban list’ book does not state what the ban relates to, making it legally insufficient to constitute a criminal instruction.
6. DHS therefore violated the administrative due-process principles applicable to agency decisions and exceeded its lawful authority.
7. DHS has engaged in selective enforcement, as demonstrated by multiple individuals being found guilty for Trespass, reliant on identical fact patterns linked to the same citizen complainant, indicating the presence of an unlawful or improperly supervised internal practice.
8. The systemic nature of the problem justifies class-wide administrative relief, as all individuals previously charged using the same defective evidence suffered the same due-process violation.

IV. PRAYER FOR RELIEF
The Plaintiff seeks the following from the Defendant:
1. An order vacating in full the DHS trespass decision against the Plaintiff, and reversing all findings of guilt;
2. An order expunging any related criminal record entry;
3. A refund of $2,900 for the fine imposed against the Plaintiff;
4. A declaration that ‘ban list’ books do not constitute lawful instructions for the purposes of the crime of Trespass, unless properly served to the individual;
6. An order requiring DHS to vacate all prior trespass findings in which the only evidence of ‘instruction’ was a book placed at a property entrance owned or controlled by Vernicia.
7. An order compelling DHS to review and reform its evidentiary and notice standards to prevent recurrence of these unlawful practices.
8. A declaration that DHS’s historical acceptance of these methods constitutes procedural unfairness affecting multiple citizens.
9. Legal fees of $2,000.

V. EVIDENCE ATTACHED
P-001. Criminal record of jsrkiwi (obtained from the DHS).
P-002. Government ticket DHS-25445, through which the Plaintiff attempted to appeal his Trespass conviction.
P-003, P-004, P-005, P-006, P-007. The screenshots that are included as evidence in the criminal record (P-001).
P-009, P-010, P-011, P-012, P-013. Screenshots showing the content of the ‘ban list’ book outside c995, at 16:15 UTC on 13th November 2025.
P-014, P-015, P-016, P-017, P-018. Screenshots showing the content of the ‘ban list’ book outside c108, at 16:18 UTC on 13th November 2025.
P-019, P-020. Screenshots showing the placement of book outside c995.
P-021, P-022. Screenshots showing the placement of the ‘ban list’ book outside c108.

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 16th day of November 2025

 

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Motion


IN THE DISTRICT COURT OF THE COMMONWEALTH OF REDMONT

EMERGENCY MOTION FOR INTERIM ORDER BARRING ARREST AND IMPRISONMENT OF THE PLAINTIFF PENDING RESOLUTION OF THIS ACTION

The Plaintiff respectfully moves this Court, on an emergency basis, for an immediate interim order prohibiting the Department for Homeland Security (“DHS”) from arresting and imprisoning the Plaintiff until the final disposition of this civil action.

1. The DHS has issued a criminal record entry and imposed a custodial penalty of 35 minutes’ imprisonment arising from the trespass findings currently under challenge in this proceeding.
2. The validity of those findings is the direct subject of this litigation, and the Plaintiff seeks their full vacatur.
3. Executing any term of imprisonment before the Court has determined the lawfulness of the charges would irreparably prejudice the Plaintiff, as the harm of an imposed custodial sentence cannot be reversed once carried out.
4. The Plaintiff has acted in good faith by filing this action promptly after the DHS failed to address the dispute ticket (DHS-25445), and the matter is now properly before the Court.
5. Interim relief is necessary to preserve the Court’s ability to grant effective final relief and to prevent the Plaintiff from suffering an irreversible penalty in respect of charges that may be found unlawful.
6. The requested order imposes no prejudice on the Defendant, as it merely maintains the status quo until the Court adjudicates the underlying dispute.

RELIEF REQUESTED
The Plaintiff therefore respectfully requests that the Court issue an order:
1. Prohibiting the DHS from arresting or imposing any custodial sentence upon the Plaintiff arising from the trespass findings currently under challenge; and
2. Maintaining this prohibition until final judgment is entered in this case.

 

Writ of Summons

@Attorney General , is required to appear before the District Court in the case of jsrkiwi v Department of Homeland Security [2025] DCR 93

In the interest of more efficient Courtroom proceedings, the Court will permit responses to motions without prior Court permission. The deadline for said motions shall be 48 hours.

Furthermore, in obedience with Rule 1.4, parties are advised that engaging in conduct that obstructs or interferes with the administration of this Court or its proceedings may be held in Contempt of Court.


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.

 

Motion


IN THE DISTRICT COURT OF THE COMMONWEALTH OF REDMONT

EMERGENCY MOTION FOR INTERIM ORDER BARRING ARREST AND IMPRISONMENT OF THE PLAINTIFF PENDING RESOLUTION OF THIS ACTION

The Plaintiff respectfully moves this Court, on an emergency basis, for an immediate interim order prohibiting the Department for Homeland Security (“DHS”) from arresting and imprisoning the Plaintiff until the final disposition of this civil action.

1. The DHS has issued a criminal record entry and imposed a custodial penalty of 35 minutes’ imprisonment arising from the trespass findings currently under challenge in this proceeding.
2. The validity of those findings is the direct subject of this litigation, and the Plaintiff seeks their full vacatur.
3. Executing any term of imprisonment before the Court has determined the lawfulness of the charges would irreparably prejudice the Plaintiff, as the harm of an imposed custodial sentence cannot be reversed once carried out.
4. The Plaintiff has acted in good faith by filing this action promptly after the DHS failed to address the dispute ticket (DHS-25445), and the matter is now properly before the Court.
5. Interim relief is necessary to preserve the Court’s ability to grant effective final relief and to prevent the Plaintiff from suffering an irreversible penalty in respect of charges that may be found unlawful.
6. The requested order imposes no prejudice on the Defendant, as it merely maintains the status quo until the Court adjudicates the underlying dispute.

RELIEF REQUESTED
The Plaintiff therefore respectfully requests that the Court issue an order:
1. Prohibiting the DHS from arresting or imposing any custodial sentence upon the Plaintiff arising from the trespass findings currently under challenge; and
2. Maintaining this prohibition until final judgment is entered in this case.



Court Order


IN THE DISTRICT COURT OF THE COMMONWEALTH OF REDMONT
TEMPORARY INJUNCTION - WRIT OF MANDAMUS


Until such a time an Order is given from this Court, the Department of Homeland Security is enjoined from arresting p:jsrkiwi on the Offense of Trespass entered on 13th November, 2025; If there be a discrepancy between the time in the Complaint and the local time of any DHS official, the record entered by Goldendude15 shall not be made effective. This Order does not bar DHS from enforcing any other law nor offense undertaken by Plaintiff.

This order applies to all Law Enforcement Officers of the Department of Homeland Security. If Plaintiff is arrested after 17:14 EST on November 16th, 2025, the Court will use its contempt powers.

So ordered,
Magistrate Mug.


 

Writ of Summons

@Attorney General , is required to appear before the District Court in the case of jsrkiwi v Department of Homeland Security [2025] DCR 93

In the interest of more efficient Courtroom proceedings, the Court will permit responses to motions without prior Court permission. The deadline for said motions shall be 48 hours.

Furthermore, in obedience with Rule 1.4, parties are advised that engaging in conduct that obstructs or interferes with the administration of this Court or its proceedings may be held in Contempt of Court.


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.

Your Honor,

I am present on behalf of the Commonwealth.
 

Court Order


IN THE DISTRICT COURT OF THE COMMONWEALTH OF REDMONT
TEMPORARY INJUNCTION - WRIT OF MANDAMUS


Until such a time an Order is given from this Court, the Department of Homeland Security is enjoined from arresting p:jsrkiwi on the Offense of Trespass entered on 13th November, 2025; If there be a discrepancy between the time in the Complaint and the local time of any DHS official, the record entered by Goldendude15 shall not be made effective. This Order does not bar DHS from enforcing any other law nor offense undertaken by Plaintiff.

This order applies to all Law Enforcement Officers of the Department of Homeland Security. If Plaintiff is arrested after 17:14 EST on November 16th, 2025, the Court will use its contempt powers.

So ordered,
Magistrate Mug.


Motion


IN THE DISTRICT COURT OF THE COMMONWEALTH OF REDMONT
MOTION TO RECONSIDER

Your Honor,

The order is a bit tricky to enforce; I can ping everyone in the DHS to see if they got the message, but I worry that someone may miss a ping or just have a lapse of mind.

To prevent a lapse of mind or otherwise, the Commonweallth would ask that the DHS directed to do as follows:

  1. Archive the existing crime record, removing the wanted star.
  2. At the conclusion of the case, the DHS may create a new crime record for the trespass unless the Court orders otherwise.
This would remove the wanted star for the duration of the case, which would make it so that the individual does not appear wanted to DHS officers. At the end of the case, the DHS would be permitted to create the wanted point anew, thereby allowing us to enforce the imprisonment at an appropriate time absent an order from Your Honor.


 
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Motion


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

Your Honor,

The order is a bit tricky to enforce; I can ping everyone in the DHS to see if they got the message, but I worry that someone may miss a ping or just have a lapse of mind.

To prevent a lapse of mind or otherwise, the Commonweallth would ask that the DHS directed to do as follows:

  1. Archive the existing crime record, removing the wanted star.
  2. At the conclusion of the case, the DHS may create a new crime record for the trespass unless the Court orders otherwise.
This would remove the wanted star for the duration of the case, which would make it so that the individual does not appear wanted to DHS officers. At the end of the case, the DHS would be permitted to create the wanted point anew, thereby allowing us to enforce the imprisonment at an appropriate time absent an order from Your Honor.



That's fine, I'll amend my order to DHS to the above.
 

Motion


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

Your Honor,

The Commonwealth seeks to dismiss the eighth alleged claim for relief on the basis of Rule 5.5 (Lack of Claim) and Rule 5.12 (Lack of Personal Jurisdiction).

III. CLAIMS FOR RELIEF

...

8. The systemic nature of the problem justifies class-wide administrative relief, as all individuals previously charged using the same defective evidence suffered the same due-process violation.

IV. PRAYER FOR RELIEF
The Plaintiff seeks the following from the Defendant:

...

6. An order requiring DHS to vacate all prior trespass findings in which the only evidence of ‘instruction’ was a book placed at a property entrance owned or controlled by Vernicia.

1. So-called "class-wide administrative relief" involving unnamed parties fails to state a claim for relief under the law.​

In the eighth alleged claim for relief, which is quoted above, the Plaintiff is seeking "class-wide administrative relief", praying that the which the DHS be ordered to vacate "all prior trespass findings" of unnamed parties that were created from a particular evidentiary pattern.

There is not statute that permits this, nor may the Courts grant it. The Federal Court has been fairly unequivocal about this.

1a. The Courts cannot grant class-wide administrative relief without an enabling statute present.​

Can Courts grant class-wide administrative relief without enabling legislation? The Federal Court has been clear: No.

As the Federal Court has noted in Privacy Matters v. Nexalin [2025] FCR 36: "Establishing a procedure robust enough to handle a class of people in a lawsuit would be substantial to a point of encroaching upon the powers of the legislative. See Constitution § 2(1)."

In other words: if we are going to have lawsuits that grant class-wide relief that affects people other than named parties, the legislature would need to act. It would be unconstitutional for the Court to create, as a matter of common law or otherwise, some sort of class action procedure to grant relief to anyone other than the named plaintiffs.

As the Federal Court has appeallate jurisdiction over the District Court, and also has original jurisdiction over questions of constitutionality (see: Article 18 of the Constitution), this precedent on constitutionality binds the District Court.

1b. No applicable statutory authority exists for class-wide administrative relief.​

Does statutory authority exist in this context for class-wide administrative relief? The answer is clear: No.

As the Federal Court noted in Privacy Matters v. Nexalin [2025] FCR 36 "[t]here is no statutory authorization for establishing 'classes' of people in a case". While multiple Plaintiffs may join themselves together to file against a defendant as if they were one single entity, there is no means to certify a broad class present in the law - no class action procedure exists in statute that would apply here.

The Plaintiff has not asserted a statute which permits them to seek class-wide administrative relief, and the Commonwealth cannot find one. There is one Plaintiff here, not many; the only claims for relief that the Plaintiff may seek are redress for actions which have harmed the Plaintiff. Absent a contrary showing, the Court should find that no claim for relief here arises from statutory text.

2. The Plaintiff lacks personal jurisdiction to seek class-wide administrative relief.​

Standing, in Redmont, is a three point test defined under Court Rule 2.1. As summarized by the Supreme Court in ToadKing v. Commonwealth of Redmont [2025] SCR 19:

Standing consists of three elements. First, the individual must have suffered an injury caused by a clearly identifiable second party or affected by an application of law. Second, the cause of the injury must be unlawful. Third, the injury must be capable of being remedied by a favorable decision under the relevant law.

The Plaintiff fails to meet the first element of standing as it pertains to the eighth prayer for relief. Simply put: the Plaintiff does not suffer injury when unnamed third parties are charged with trespass, and is not affected by an application of the law when unnamed third parties are charged with trespass. The Plaintiff therefore lacks standing for such a broad prayer for relief as it pertains to unnamed third parties, warranting dismissal of the claim under Rule 5.12.

3. Conclusion: The District Court should dismiss the eighth claim for relief and its associated prayers.​

Under Rule 5.5, "failure to state a claim for relief" may warrant dismissal. As noted above, a statutory authorization would be required for class-wide administrative relief to be granted, but no such authority exists in statute. The eighth claim for relief lacks legal basis under the law, and should be dismissed on this basis.

Separately, under Rule 5.12, dismissal is warranted when "the plaintiff fails to have sufficient standing in order to pursue the case". As established above, the Plaintiff fails the first prong of the standing test under Rule 2.1 as it pertains to claims for relief on behalf of unnamed third parties; this independently warrants dismissal of the claim.

Therefore, the defense humbly prays that this Court strike the eighth claim for relief, as well as any prayers for relief which rest wholly thereupon.

 
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Motion


IN THE DISTRICT COURT OF THE COMMONWEALTH OF REDMONT
MOTION TO AMEND

Your honor,

The defense requests leave to:

  1. Amend filings erroneously formatted as if they were in the Federal Court to state that they were filed in the District Court; and
  2. To remove a stray quotation mark in the second paragraph of MTD argument 1b and fix associated italics.

 

Motion


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

Your Honor,

The Commonwealth seeks to dismiss the eighth alleged claim for relief on the basis of Rule 5.5 (Lack of Claim) and Rule 5.12 (Lack of Personal Jurisdiction).

1. So-called "class-wide administrative relief" involving unnamed parties fails to state a claim for relief under the law.​

In the eighth alleged claim for relief, which is quoted above, the Plaintiff is seeking "class-wide administrative relief", praying that the which the DHS be ordered to vacate "all prior trespass findings" of unnamed parties that were created from a particular evidentiary pattern.

There is not statute that permits this, nor may the Courts grant it. The Federal Court has been fairly unequivocal about this.

1a. The Courts cannot grant class-wide administrative relief without an enabling statute present.​

Can Courts grant class-wide administrative relief without enabling legislation? The Federal Court has been clear: No.

As the Federal Court has noted in Privacy Matters v. Nexalin [2025] FCR 36: "Establishing a procedure robust enough to handle a class of people in a lawsuit would be substantial to a point of encroaching upon the powers of the legislative. See Constitution § 2(1)."

In other words: if we are going to have lawsuits that grant class-wide relief that affects people other than named parties, the legislature would need to act. It would be unconstitutional for the Court to create, as a matter of common law or otherwise, some sort of class action procedure to grant relief to anyone other than the named plaintiffs.

As the Federal Court has appeallate jurisdiction over the District Court, and also has original jurisdiction over questions of constitutionality (see: Article 18 of the Constitution), this precedent on constitutionality binds the District Court.

1b. No applicable statutory authority exists for class-wide administrative relief.​

Does statutory authority exist in this context for class-wide administrative relief? The answer is clear: No.

As the Federal Court noted in Privacy Matters v. Nexalin [2025] FCR 36 "[t]here is no statutory authorization for establishing 'classes' of people in a case". While multiple Plaintiffs may join themselves together to file against a defendant as if they were one single entity, there is no means to certify a broad class present in the law - no class action procedure exists in statute that would apply here."

The Plaintiff has not asserted a statute which permits them to seek class-wide administrative relief, and the Commonwealth cannot find one. There is one Plaintiff here, not many; the only claims for relief that the Plaintiff may seek are redress for actions which have harmed the Plaintiff (see, for example . Absent a contrary showing, the Court should find that no claim for relief here arises from statutory text.

2. The Plaintiff lacks personal jurisdiction to seek class-wide administrative relief.​

Standing, in Redmont, is a three point test defined under Court Rule 2.1. As summarized by the Supreme Court in ToadKing v. Commonwealth of Redmont [2025] SCR 19:



The Plaintiff fails to meet the first element of standing as it pertains to the eighth prayer for relief. Simply put: the Plaintiff does not suffer injury when unnamed third parties are charged with trespass, and is not affected by an application of the law when unnamed third parties are charged with trespass. The Plaintiff therefore lacks standing for such a broad prayer for relief as it pertains to unnamed third parties, warranting dismissal of the claim under Rule 5.12.

3. Conclusion: The District Court should dismiss the eighth claim for relief and its associated prayers.​

Under Rule 5.5, "failure to state a claim for relief" may warrant dismissal. As noted above, a statutory authorization would be required for class-wide administrative relief to be granted, but no such authority exists in statute. The eighth claim for relief lacks legal basis under the law, and should be dismissed on this basis.

Separately, under Rule 5.12, dismissal is warranted when "the plaintiff fails to have sufficient standing in order to pursue the case". As established above, the Plaintiff fails the first prong of the standing test under Rule 2.1 as it pertains to claims for relief on behalf of unnamed third parties; this independently warrants dismissal of the claim.

Therefore, the defense humbly prays that this Court strike the eighth claim for relief, as well as any prayers for relief which rest wholly thereupon.

IN THE DISTRICT COURT OF THE COMMONWEALTH OF REDMONT

RESPONSE TO MOTION TO DISMISS

Your Honour,
The Plaintiff submits this response opposing the Commonwealth’s Motion to Dismiss.

The motion to dismiss misunderstands the nature of the eighth claim. Although the Complaint used the phrase “class-wide administrative relief,” the Plaintiff is not seeking class action damages, but a straightforward order directing DHS to correct unlawful administrative decisions made under an unlawful policy. This is something well within the Court’s ordinary remedial authority once a policy is declared unlawful.

I. THE PLAINTIFF’S REFERENCE TO “CLASS-WIDE ADMINISTRATIVE RELIEF” DOES NOT INVOKE A CLASS ACTION
1. Your Honour, in the Complaint, the Plaintiff used the phrase “class-wide administrative relief.” The Commonwealth now treats that phrase as if the Plaintiff were attempting to certify a class, litigate on behalf of unnamed individuals, or obtain damages for persons not before the Court.
2. That is not what the Plaintiff meant, nor what the filing actually seeks.
3. The point of the eighth claim is this:
  1. DHS adopted an unwritten de facto evidentiary policy, allowing Trespass findings without proper proof of “instruction”.
  2. That policy applied systemically and repeatedly, affecting the Plaintiff and many others in the same manner.
  3. If the Court holds the policy unlawful, it necessarily follows that DHS must be ordered to reverse its past administrative actions into compliance with the law.
  4. Directing DHS to correct its own unlawful decisions is not a class action, does not require statutory class-action authority, and does not require the Plaintiff to possess standing on behalf of others.
4. “Class-wide administrative relief” in the Complaint simply refers to the scope of the agency’s corrective duty once the Court has ruled on the legality of its policy, not the creation of a class of litigants.

II. RULE 5.5 DOES NOT APPLY: THE EIGHTH CLAIM STATES A VALID BASIS FOR JUDICIAL REVIEW AND ADMINISTRATIVE CORRECTION
1. Rule 5.5 addresses failure to state a claim. The claim does state one:
  • The Plaintiff alleges an unlawful DHS policy.
  • The Plaintiff seeks a declaration of unlawfulness.
  • The Plaintiff seeks an order requiring DHS to correct administrative decisions that flowed from that policy.
2. Courts routinely issue orders directing government agencies to rescind, vacate, or correct unlawful administrative acts after a legal defect in the underlying policy is established. There is nothing incoherent or unrecognisable about this remedy.
3. The Defence’s argument incorrectly assumes that any relief benefiting more than one person is automatically a “class action” requiring express statutory authorisation. That is simply not true. Administrative correction is not a class action procedure.

III. RULE 5.12 DOES NOT BAR THE CLAIM: THE PLAINTIFF’S STANDING IS BASED SOLELY ON HIS OWN UNLAWFUL TRESPASS FINDING
1. Standing requires:
  1. An injury to the Plaintiff by the Defendant;
  2. Caused by unlawful conduct; and
  3. Remediable by the Court.
2. All three are satisfied. The Plaintiff’s injury is his own Trespass conviction under the DHS policy. That establishes standing to challenge the policy’s legality.
3. The Commonwealth’s argument incorrectly suggests the Plaintiff must have standing on behalf of other individuals for the Court to direct DHS to correct its administrative record. But that is not how judicial review works. Once standing exists to challenge the policy:
  • The Court may craft appropriate remedies for the illegality it finds, including directing an agency to correct the structural consequences of that illegality.
  • This does not require the Plaintiff to rely on injuries suffered by others.
  • It simply recognises that an agency’s unlawful policy cannot remain in force for some people but not others once declared unlawful.
4. The Plaintiff is not asserting standing for third-party claims. He asserts standing for his own claim, and the remedy flows from the Court’s supervisory power over an executive agency.

IV. PRIVACY MATTERS V. NEXALIN [2025] FCR 36 IS DISTINGUISHABLE
1. The Commonwealth relies heavily on Privacy Matters V. Nexalin [2025] FCR 36 (hereinafter referred to as ‘Nexalin’), but that case is fundamentally different.
2. In Nexalin, the Court refused to award damages to unnamed individuals in a putative class action, emphasising that “establishing a procedure robust enough to handle a class of people in a lawsuit would be substantial to a point of encroaching upon the powers of the legislative.”
3. Nexalin involved six named plaintiffs plus 116 additional affected individuals, sought damages for all users, and the Court held there was no statutory mechanism for such broad relief.
4. In this action, the Plaintiff seeks:
  • No damages for anyone other than the Plaintiff.
  • No compensation to unnamed individuals.
5. The Plaintiff asks solely that DHS reverse its own unlawful administrative decisions, which is a normal form of administrative remedy.
6. Nexalin limits damages to named plaintiffs. It does not limit a Court’s power to order a government agency to bring its past actions into compliance with the law.

V. POLICY ARGUMENT
1. If the Commonwealth’s view were correct, then:
  • Even the most egregiously unlawful government policy would permanently stain hundreds of citizens’ records;
  • Only litigants with the time and resources to individually sue would ever receive relief;
  • Unequal treatment would become baked into the system purely because an agency broke the law on too large a scale.
2. Citizens are entitled to assume DHS follows the law. When DHS does not, the law must provide a mechanism to repair the systemic consequences.
3. Refusing such relief would incentivise agencies to violate the law more broadly, since widespread illegality would make their actions harder to correct.

For these reasons, the Plaintiff respectfully requests that the Motion to Dismiss be denied in full.
 

Motion


IN THE DISTRICT COURT OF THE COMMONWEALTH OF REDMONT
MOTION TO AMEND

Your honor,

The defense requests leave to:

  1. Amend filings erroneously formatted as if they were in the Federal Court to state that they were filed in the District Court; and
  2. To remove a stray quotation mark in the second paragraph of MTD argument 1b and fix associated italics.

Granted
 
IN THE DISTRICT COURT OF THE COMMONWEALTH OF REDMONT

RESPONSE TO MOTION TO DISMISS

Your Honour,
The Plaintiff submits this response opposing the Commonwealth’s Motion to Dismiss.

The motion to dismiss misunderstands the nature of the eighth claim. Although the Complaint used the phrase “class-wide administrative relief,” the Plaintiff is not seeking class action damages, but a straightforward order directing DHS to correct unlawful administrative decisions made under an unlawful policy. This is something well within the Court’s ordinary remedial authority once a policy is declared unlawful.

I. THE PLAINTIFF’S REFERENCE TO “CLASS-WIDE ADMINISTRATIVE RELIEF” DOES NOT INVOKE A CLASS ACTION
1. Your Honour, in the Complaint, the Plaintiff used the phrase “class-wide administrative relief.” The Commonwealth now treats that phrase as if the Plaintiff were attempting to certify a class, litigate on behalf of unnamed individuals, or obtain damages for persons not before the Court.
2. That is not what the Plaintiff meant, nor what the filing actually seeks.
3. The point of the eighth claim is this:
  1. DHS adopted an unwritten de facto evidentiary policy, allowing Trespass findings without proper proof of “instruction”.
  2. That policy applied systemically and repeatedly, affecting the Plaintiff and many others in the same manner.
  3. If the Court holds the policy unlawful, it necessarily follows that DHS must be ordered to reverse its past administrative actions into compliance with the law.
  4. Directing DHS to correct its own unlawful decisions is not a class action, does not require statutory class-action authority, and does not require the Plaintiff to possess standing on behalf of others.
4. “Class-wide administrative relief” in the Complaint simply refers to the scope of the agency’s corrective duty once the Court has ruled on the legality of its policy, not the creation of a class of litigants.

II. RULE 5.5 DOES NOT APPLY: THE EIGHTH CLAIM STATES A VALID BASIS FOR JUDICIAL REVIEW AND ADMINISTRATIVE CORRECTION
1. Rule 5.5 addresses failure to state a claim. The claim does state one:
  • The Plaintiff alleges an unlawful DHS policy.
  • The Plaintiff seeks a declaration of unlawfulness.
  • The Plaintiff seeks an order requiring DHS to correct administrative decisions that flowed from that policy.
2. Courts routinely issue orders directing government agencies to rescind, vacate, or correct unlawful administrative acts after a legal defect in the underlying policy is established. There is nothing incoherent or unrecognisable about this remedy.
3. The Defence’s argument incorrectly assumes that any relief benefiting more than one person is automatically a “class action” requiring express statutory authorisation. That is simply not true. Administrative correction is not a class action procedure.

III. RULE 5.12 DOES NOT BAR THE CLAIM: THE PLAINTIFF’S STANDING IS BASED SOLELY ON HIS OWN UNLAWFUL TRESPASS FINDING
1. Standing requires:
  1. An injury to the Plaintiff by the Defendant;
  2. Caused by unlawful conduct; and
  3. Remediable by the Court.
2. All three are satisfied. The Plaintiff’s injury is his own Trespass conviction under the DHS policy. That establishes standing to challenge the policy’s legality.
3. The Commonwealth’s argument incorrectly suggests the Plaintiff must have standing on behalf of other individuals for the Court to direct DHS to correct its administrative record. But that is not how judicial review works. Once standing exists to challenge the policy:
  • The Court may craft appropriate remedies for the illegality it finds, including directing an agency to correct the structural consequences of that illegality.
  • This does not require the Plaintiff to rely on injuries suffered by others.
  • It simply recognises that an agency’s unlawful policy cannot remain in force for some people but not others once declared unlawful.
4. The Plaintiff is not asserting standing for third-party claims. He asserts standing for his own claim, and the remedy flows from the Court’s supervisory power over an executive agency.

IV. PRIVACY MATTERS V. NEXALIN [2025] FCR 36 IS DISTINGUISHABLE
1. The Commonwealth relies heavily on Privacy Matters V. Nexalin [2025] FCR 36 (hereinafter referred to as ‘Nexalin’), but that case is fundamentally different.
2. In Nexalin, the Court refused to award damages to unnamed individuals in a putative class action, emphasising that “establishing a procedure robust enough to handle a class of people in a lawsuit would be substantial to a point of encroaching upon the powers of the legislative.”
3. Nexalin involved six named plaintiffs plus 116 additional affected individuals, sought damages for all users, and the Court held there was no statutory mechanism for such broad relief.
4. In this action, the Plaintiff seeks:
  • No damages for anyone other than the Plaintiff.
  • No compensation to unnamed individuals.
5. The Plaintiff asks solely that DHS reverse its own unlawful administrative decisions, which is a normal form of administrative remedy.
6. Nexalin limits damages to named plaintiffs. It does not limit a Court’s power to order a government agency to bring its past actions into compliance with the law.

V. POLICY ARGUMENT
1. If the Commonwealth’s view were correct, then:
  • Even the most egregiously unlawful government policy would permanently stain hundreds of citizens’ records;
  • Only litigants with the time and resources to individually sue would ever receive relief;
  • Unequal treatment would become baked into the system purely because an agency broke the law on too large a scale.
2. Citizens are entitled to assume DHS follows the law. When DHS does not, the law must provide a mechanism to repair the systemic consequences.
3. Refusing such relief would incentivise agencies to violate the law more broadly, since widespread illegality would make their actions harder to correct.

For these reasons, the Plaintiff respectfully requests that the Motion to Dismiss be denied in full.


Court Order


IN THE DISTRICT COURT OF THE COMMONWEALTH OF REDMONT
Motion to Dismiss - Department of Homeland Security

Movant wishes for dismissal of Complaint Claim #8 for failure to state a claim and for lack of standing. Non-movant offers arguments in defense and general denial of Movant’s assertion with the applicability of Nexalin.


On review of filings, the Court GRANTS the motion as Non-Movant’s arguments are purely academic.

The Court finds Plaintiff’s Claim #8 to be substantively academic. Although framed as a request for “class-wide administrative relief”, the prayer that DHS be ordered to vacate all prior trespass findings (Prayer #6) effectively seeks a class-action for un-named parties; This Court has no statutory authority to grant class-action relief and is in fact barred by Nexalin from considering it. Further, such a remedy does not address Plaintiff’s personal legal injuries, but would broaden the Court’s inquiry to citizens not involved in this case. This Court is not here to effect systemic changes or generate favourable case law for a particular viewpoint.



Claim #8 is struck.
Prayer(s) #6 is struck.


CORRECTION PRAYER #6 is NOT STRUCK, the Court orders Plaintiff to restrict that Prayer to Plaintiff's allegations only.

So ordered,
Magistrate Mug

 
Thanks. The CW shall have 48 hours to offer an Answer.
Your Honor,

The Commonwealth respectfully requests an extension of 24 hours to file its answer.
 
Your Honor,

The Commonwealth respectfully requests an extension of 24 hours to file its answer.
Granted, Answer due 11/19/25 @ 7:30 PM EST
 

Answer to Complaint


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

jsrkiwi
Plaintiff

v.

Department of Homeland Security
Defendant




I. ANSWER TO COMPLAINT​

1. AFFIRMS that "On 13th November 2025, the Department of Homeland Security (DHS) created a criminal record for the Plaintiff, listing five trespass offences at locations c108 and c995."
2. AFFIRMS that "On 13th November 2025 at 10:37 UTC, the Plaintiff was fined $2,900 for ‘Trespass x5 (First, Second, and Subsequent charges)’; and a wanted point was created for 35 minutes imprisonment."
3. NEITHER AFFIRMS NOR DENIES:
The supporting evidence for the criminal record was five screenshots provided by Vernicia through ticket dhs-25341. These screenshots show:
(i) Sales records showing the sale of coal blocks by the Plaintiff to Vernicia at ‘14h24m ago’;
(ii) The third page of the book outside of one of the entrances to c995. The page is titled ‘ban list’, and the name of the Plaintiff is listed on the third line from the bottom;
(iii) Sales records showing the sale of 27 iron blocks at ‘1d11h23m ago; 300 coal blocks by the Plaintiff to Vernicia at ‘1d12h38m ago’; and the sale of 960 coal by the Plaintiff to Vernicia at ‘1d12h40m ago’.
(iv) Sales records showing the sale of 65 redstone blocks by the Plaintiff to MZCD at ‘11-11-2025 17:13:50’; the sale of 64 redstone by the Plaintiff to MZCD at ‘11-11-2025 17:13:39’; the sale of 66 lapis blocks by the Plaintiff to MZCD at ‘11-11-2025 17:13:30’; and the sale of 116 lapis lazuli by the Plaintiff to MZCD at ‘11-11-2025 17:13:07’.
(v) Sales records showing the sale of 3 iron blocks to MZCD at ‘11-11-2025 16:47:02’.

4. DENIES that "Only one screenshot includes a timestamp: 13 November 2025 at 05:12 (CET). Two others show indirect metadata; two show none".
5. DENIES that "No evidence is held by the DHS that the book outside c995 was updated to include the Plaintiff’s name prior to the Plaintiff transacting on the plots."
6. NEITHER AFFIRMS NOR DENIES that "No instructions or notice banning the Plaintiff from a property has ever been served upon the Plaintiff by Vernicia". DENIES that "The Plaintiff had no reason to believe that he was banned from entering plots c108 or c995."
7. NEITHER AFFIRMS NOR DENIES that "Plaintiff accessed both properties c108 and c995 exclusively by warp (‘/home vernicia’ and ‘/home mzcd’) and did not walk through the entrance". DENIES that "the book shown in the second screenshot was never visible to him", NOTING that it is plainly visible in the screenshot.
8. NEITHER AFFIRMS NOR DENIES that "[t]he property owner (Vernicia) has personally observed Plaintiff warping into c995 before and therefore knew Plaintiff would not see any book", NOTING that the Commonwealth cannot read Vernicia's memory.
9. NEITHER AFFIRMS NOR DENIES that "The books outside c108 and c995 do not specify what the ban relates to".
10. AFFIRMS that "Plaintiff has knowledge from his work as a Police Trainee of the existence several other individuals who were charged with trespass at properties owned or controlled by the same private citizen, Vernicia".
11. NEITHER AFFIRMS NOR DENIES that "in each of these cases, the method of ‘instruction’ was identical: reliance on a book placed at the property entrance, with no proof of service and no confirmation that the accused ever saw it", NOTING that it is not clear to the Commonwealth what specific cases "each of these cases" refers to.
12. NEITHER AFFIRMS NOR DENIES that "in each of these cases, the proof used by the DHS to support the conviction of Trespass is identical: a screenshot of the book showing the accused’s name, and a screenshot showing sales records. In each case, there is no evidence that any instruction was properly served by Vernicia to any of the accused individuals, or that the book was updated prior to the sales taking place", NOTING that it is not clear to the Commonwealth what specific cases "each of these cases" refers to.
13. DENIES that "The similarity of fact patterns across multiple cases indicates that DHS applied an unofficial, and unlawful low standard specifically when handling trespass complaints originating from Vernicia".
14. NEITHER AFFIRMS NOR DENIES that "At 14:37 UTC on 13th November 2025, The Plaintiff attempted to dispute the charges through a government ticket (dhs-25445). As of 72 hours later, the DHS had not responded to the ticket and the decision remained uncorrected. At 15:47 UTC on 16th November 2025, with the ticket having become the oldest charge-dispute ticket on the DHS tickets list, the Plaintiff closed the ticket, and now files this action."




II. Defenses​

1. Trespass occurred​

Trespass, as is relevant for this case, is defined as occurring when a person "enters or remains in a non-public or restricted area against instructions" (see: CCA Part VIII, Section 12).

Put alternatively, the following may constitute trespass:
  1. Entering a non-public area against instructions;
  2. Remaining in a non-public area against instructions;
  3. Entering a restricted area against instructions; or
  4. Remaining in a restricted area against instructions.
Now that the rule is clear, let's examine application of the rule to the facts and evidence.

1a. Plaintiff's own evidence shows that Plaintiff entered a restricted area​

In previous instances, the Courts found in Walmart co. v. Olisaurus123 and Montilou [2022] FCR 13 (affirmed on appeal in Supreme Court Case Olisaurus123 v. Walmart Co [2022] SCR 3) that "[g]iven the presence of a wall around the plot and the fact that the only entrance point was the roof, a reasonable person should conclude that they are not to enter".

We posit here: if there's a big wall around a plot, and there is a sign at the entrances saying that the area is restricted, the area would be restricted under the law.

Exhibits P-019 and P-020 (and P-003) show something quite clear: a lectern with a sign above it with "RESTRICTED AREA" in uppercase lettering. This clearly marks that the area (in this case, C995) as being restricted. This is incontestable.

1b. Instructions are given by books on lecterns at entrances​

The signs visible in (for example) Exhibits P-019 and P-020 instruct individuals to read the book before entry. Upon opening the books, there is a "ban list". In the whole context, there is nothing else that a ban list could plausibly refer to than those banned from entering the restricted area. This constitutes plain posting of instructions at the entrances to a plot.

1c. Plaintiff entered the area against instructions​

The books are datestamped and clearly mark the Plaintiff as among the individuals banned from the plot. Plaintiff admits to having the entered the property anyway. The Plaintiff claims to have done so by warping (see: seventh factual allegation in the initial complaint), but this does not matter - instructions were clearly posted at the entrance, and the Plaintiff had to have entered the property before setting a warp.

1d. Trespass occurred​

Trespass occurs when an individual enters a restricted area against the instructions. In this case, Plaintiff entered a restricted area despite being on the ban list posted at the entrances. The conclusion here is simple: trespass occurred.

2. Lack of evidence​

Several claims for relief simply lack evidence. For example, Plaintiff claims "selective enforcement, as demonstrated by multiple individuals being found guilty for Trespass, reliant on identical fact patterns linked to the same citizen complainant, indicating the presence of an unlawful or improperly supervised internal practice", but does not provide evidence to this effect. The Plaintiff has a burden of proof in a civil lawsuit here - Plaintiff must prove all claims.

3. Text Me Back Act Timeline​

In the alternative to the above, the Defense raises the question of whether the Text Me Back Act would protect the Commonwealth from suit in this instance.

Under the Text Me Back Act, "Executive Departments are required to provide a final decision on any new applications within a period of 14 days". Plaintiff alleges in the 14th factual allegation that the Plaintiff did not receive a reply within 72 hours, but this would be far short of 14 days.

Under the Text Me Back Act, "application" is intentionally quite broad. While the law initially only applied to employment applications, the law was amended by the Congress with the purpose of handling "[o]ther types of applications with government agencies".

If the Court finds that the Plaintiff's DHS appeal ticket were to constitute an application under the Text Me Back Act, then the Plaintiff would have prematurely closed it of their own volition before a response would have been required under the law. And, if so, the Plaintiff would have deprived the DHS from statutory time to gather a response and ask follow-up questions as permitted under the penumbra of Text Me Back Act 3(2)(a) ("If a Department requests additional information or documentation from the applicant, the 14-day deadline shall restart from the date the applicant provides the requested information").




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 19th day of November 2025

 
Discovery is now open!
Due Date: 11/24/25 @1:00PM EST
 

Motion


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

Your Honor,

The Defense seeks to compel the following from the Plaintiff:

  1. Any Minecraft logs between 11 November and 13 November.
  2. A screenshot of all the Plaintiff’s /home warps that can be obtained by running /homes.
We believe that these logs will help to better establish the movement of the Plaintiff about the map, including to or from the plot c995.

 

Motion


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

Your Honor,

The Defense seeks to compel the following from the Plaintiff:

  1. Any Minecraft logs between 11 November and 13 November.
  2. A screenshot of all the Plaintiff’s /home warps that can be obtained by running /homes.
We believe that these logs will help to better establish the movement of the Plaintiff about the map, including to or from the plot c995.

The Plaintiff does not object to Request No. 1 and will produce his logs as requested.

Regarding request No. 2, the Plaintiff respectfully notes that certain home warps (specifically 'vernicia' and 'mzcd') were removed by the Plaintiff after the criminal charge and possibly after the commencement of this civil action. Accordingly, they no longer appear in the current /homes listing. The Plaintiff will review logs for subsequent days and will disclose those for the day when those warps were deleted. The Plaintiff will also shortly be filing a motion to request logs of the Plaintiff's '/home' activity from staff.
 

Motion


IN THE DISTRICT COURT OF THE COMMONWEALTH OF REDMONT

MOTION TO COMPEL PRODUCTION OF STAFF RECORDS


The Plaintiff respectfully moves this Honourable Court for an Order compelling the Staff Team to produce the records identified below, which are directly relevant to the issues in dispute and necessary for the fair adjudication of this matter.

  1. Any and all server logs reflecting the Plaintiff’s use of the commands “/home vernicia” and “/home mzcd” between 10 November 2025 and 13 November 2025, inclusive.
  2. Any logs or other records showing the teleportation coordinates associated with the Plaintiff’s warps “/home vernicia” and “/home mzcd”.
The Plaintiff submits that these records are within the Staff Team’s custody and control, and their production is necessary to resolve factual disputes concerning the travel of the Plaintiff.

Accordingly, the Plaintiff prays the Court issue an Order directing the Staff Team to disclose the above-specified materials.

 

Motion


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

Your Honor,

The Defense seeks to compel the following from the Plaintiff:

  1. Any Minecraft logs between 11 November and 13 November.
  2. A screenshot of all the Plaintiff’s /home warps that can be obtained by running /homes.
We believe that these logs will help to better establish the movement of the Plaintiff about the map, including to or from the plot c995.

The Plaintiff does not object to Request No. 1 and will produce his logs as requested.

Regarding request No. 2, the Plaintiff respectfully notes that certain home warps (specifically 'vernicia' and 'mzcd') were removed by the Plaintiff after the criminal charge and possibly after the commencement of this civil action. Accordingly, they no longer appear in the current /homes listing. The Plaintiff will review logs for subsequent days and will disclose those for the day when those warps were deleted. The Plaintiff will also shortly be filing a motion to request logs of the Plaintiff's '/home' activity from staff.
The Plaintiff provides the following items of discovery requested by the Defendant:

REQUEST 1
Attached are the Minecraft logs listed in Request No. 1 (11–13 November). They are labelled as follows:
P-101: 2025-11-11-1.log
P-102: 2025-11-11-2.log
P-103: 2025-11-12-1.log
P-104: 2025-11-12-2.log
P-105: 2025-11-13-1.log
P-106: 2025-11-13-2.log
P-107: 2025-11-13-3.log
P-108: 2025-11-13-4.log

REQUEST 2
As previously noted, certain home warps (‘vernicia’ and ‘mzcd’) were removed by the Plaintiff after the criminal charge, and therefore do not appear in the current /homes listing.
P-109: Screenshot as requested
P-110: 2025-11-14-1.log (this includes the result of "/homes", "/delhome vernicia", and "/delhome mzcd")
 

Attachments

Motion


IN THE DISTRICT COURT OF THE COMMONWEALTH OF REDMONT

MOTION TO COMPEL PRODUCTION OF STAFF RECORDS


The Plaintiff respectfully moves this Honourable Court for an Order compelling the Staff Team to produce the records identified below, which are directly relevant to the issues in dispute and necessary for the fair adjudication of this matter.

  1. Any and all server logs reflecting the Plaintiff’s use of the commands “/home vernicia” and “/home mzcd” between 10 November 2025 and 13 November 2025, inclusive.
  2. Any logs or other records showing the teleportation coordinates associated with the Plaintiff’s warps “/home vernicia” and “/home mzcd”.
The Plaintiff submits that these records are within the Staff Team’s custody and control, and their production is necessary to resolve factual disputes concerning the travel of the Plaintiff.

Accordingly, the Plaintiff prays the Court issue an Order directing the Staff Team to disclose the above-specified materials.


REQUEST TO AMEND MOTION TO COMPEL
The Plaintiff respectfully seeks leave of this Honourable Court to amend the pending Motion to Compel Production of Staff Records to include the following additional request as paragraph 3 of the requested materials:

3. Any logs or other records showing when the lecterns at the following locations were updated during November 2025:
  • 4184, 73, 4134
  • 4079, 73, 4136
  • 2637, 73, 3921
  • 2667, 73, 3921
These records fall within the Staff Team’s custody and control and are necessary for the fair resolution of factual issues concerning the chronology of events under examination.

Accordingly, the Plaintiff prays this Honourable Court permit the amendment and direct the Staff Team to produce the additional materials identified above as part of the original Motion to Compel.
 
REQUEST TO AMEND MOTION TO COMPEL
The Plaintiff respectfully seeks leave of this Honourable Court to amend the pending Motion to Compel Production of Staff Records to include the following additional request as paragraph 3 of the requested materials:

3. Any logs or other records showing when the lecterns at the following locations were updated during November 2025:
  • 4184, 73, 4134
  • 4079, 73, 4136
  • 2637, 73, 3921
  • 2667, 73, 3921
These records fall within the Staff Team’s custody and control and are necessary for the fair resolution of factual issues concerning the chronology of events under examination.

Accordingly, the Plaintiff prays this Honourable Court permit the amendment and direct the Staff Team to produce the additional materials identified above as part of the original Motion to Compel.

Denied as excessive. Staff will not search multiple days at multiple locations.
 

Motion


IN THE DISTRICT COURT OF THE COMMONWEALTH OF REDMONT

MOTION TO COMPEL PRODUCTION OF STAFF RECORDS


The Plaintiff respectfully moves this Honourable Court for an Order compelling the Staff Team to produce the records identified below, which are directly relevant to the issues in dispute and necessary for the fair adjudication of this matter.

  1. Any and all server logs reflecting the Plaintiff’s use of the commands “/home vernicia” and “/home mzcd” between 10 November 2025 and 13 November 2025, inclusive.
  2. Any logs or other records showing the teleportation coordinates associated with the Plaintiff’s warps “/home vernicia” and “/home mzcd”.
The Plaintiff submits that these records are within the Staff Team’s custody and control, and their production is necessary to resolve factual disputes concerning the travel of the Plaintiff.

Accordingly, the Plaintiff prays the Court issue an Order directing the Staff Team to disclose the above-specified materials.



Court Order


IN THE DISTRICT COURT OF THE COMMONWEALTH OF REDMONT
Order to Compel

On motion from Plaintiff, and not seeing a plausible response from Defendant, the Court orders the production of logs. If the response is prejudicial, the Court will hear from Defendant on reconsideration.

@Staff The Court humbly requests the following be produced by Staff in the Court Docket:

===============================================

  1. Any and all server logs reflecting the Plaintiff’s use of the commands “/home vernicia” and “/home mzcd” between 10 November 2025 and 13 November 2025, inclusive.
  2. Any logs or other records showing the teleportation coordinates associated with the Plaintiff’s warps “/home vernicia” and “/home mzcd”.
  3. Any logs or other records showing the time at which the lectern at the location 4079, 73, 4136 was updated on 11th November 2025.
===============================================

The Court will open a staff ticket and request that a Staff Member (or Staff Team) respond in this thread if possible. If not, the Court will post the entirety of the ticket thread to this forum. No deadline shall be affixed to this order.

So ordered,
Judge Mug.


 
Denied as excessive. Staff will not search multiple days at multiple locations.
I apologise Your Honour, I am unaware of the methods that staff use to search logs, and was not aware that such a search would be time-consuming for staff to carry out.

Would Your Honour consider including a significantly more limited version of the request:

3. Any logs or other records showing the time at which the lectern at the location 4079, 73, 4136 was updated on 11th November 2025.
 
I apologise Your Honour, I am unaware of the methods that staff use to search logs, and was not aware that such a search would be time-consuming for staff to carry out.

Would Your Honour consider including a significantly more limited version of the request:

3. Any logs or other records showing the time at which the lectern at the location 4079, 73, 4136 was updated on 11th November 2025.
Added to original order, marked green underlined texted.

I've made all three requests to Staff for their consideration.
 
Staff-1
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Staff-2
1763662103903.png



Staff-3
1763662111677.png


Staff-4
1763662118967.png


Staff-5
1763662124324.png
 
Last edited:
Your Honor:

The Defense would like to add the following individual to its witness list:

  1. Vernicia
 

Motion


IN THE DISTRICT COURT OF THE COMMONWEALTH OF REDMONT

MOTION TO COMPEL

Your Honour, the Plaintiff seeks to compel the following from the Defendant:

  • Production of all records and evidence held by the DHS in respect of the five charges against jsrkiwi of Trespass, except for those already entered into evidence in this case;
JUSTIFICATION
The Defendant has denied Fact 5 (“No evidence is held by the DHS that the book outside c995 was updated to include the Plaintiff’s name prior to the Plaintiff transacting on the plots.”). This denial implies the existence of records or documentation in the custody of the DHS regarding the status of the book outside c995.

Without production of this evidence, the Plaintiff cannot properly respond, prepare arguments, or test the accuracy of the DHS’s denial.

 
PLAINTIFF'S WITNESS LIST
The Plaintiff will not be adding any additional witnesses at this time. The witness list, therefore, remains as originally filed:
  • jsrkiwi
  • Vernicia
  • Goldendude15
  • Roryyy_
 
RULE 4.6 EVIDENCE SUBMISSION
Persuant to rule 4.6, the Plaintiff enters the following into evidence:

P-111: The entirety of all Discord direct messages between Vernicia and jsrkiwi as of 21st November 2025.
 

Attachments

  • P-111.png
    P-111.png
    410.1 KB · Views: 11

Brief


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

Your Honor:

The Defense submits the following interrogatories of the Plaintiff consistent with Rule 4.8:

  1. Have you ever entered the property C995 other than by warping to a /home?
  2. Have you ever entered the property c108 other than by warping to a /home?
  3. What does the Plaintiff understand “read before entry” to mean, as shown in exhibits P-003 and P-021?
  4. Why did Plaintiff presume permission to enter c995 when the sign outside it shown in Exhibit P-003 said “restricted area”?
  5. The Plaintiff has alleged in a claim that the DHS “violated the administrative due-process principles applicable to agency decisions”. What are the specific principles that the Plaintiff alleges were violated?

 

Motion


IN THE DISTRICT COURT OF THE COMMONWEALTH OF REDMONT

MOTION TO COMPEL

Your Honour, the Plaintiff seeks to compel the following from the Defendant:

  • Production of all records and evidence held by the DHS in respect of the five charges against jsrkiwi of Trespass, except for those already entered into evidence in this case;
JUSTIFICATION
The Defendant has denied Fact 5 (“No evidence is held by the DHS that the book outside c995 was updated to include the Plaintiff’s name prior to the Plaintiff transacting on the plots.”). This denial implies the existence of records or documentation in the custody of the DHS regarding the status of the book outside c995.

Without production of this evidence, the Plaintiff cannot properly respond, prepare arguments, or test the accuracy of the DHS’s denial.

Response



Your Honor,

The Defense opposes this request as the the relevant evidence is already compelled from the staff team and submitted here.

From what I understand, the Plaintiff essentially claims that they need additional files to prepare arguments around the time of book placement. We already have the relative time of the book being updated in Exhibit Staff-2, and the relative time of the Plaintiff’s teleports in Exhibits Staff-3, Staff-4, and Staff-5.

The staff team is going to be the ultimate source of truth on matter of when an item was placed or removed, as well as when an individual ran commands on the server, so we see no compelling reason to go on a further fishing expedition and command the Commonwealth to use its employees’ time in order to find what’s very plainly in the public record in this very case. The plaintiff can very simply use the staff records here for plaintiff’s purposes.

 

Motion


IN THE DISTRICT COURT OF THE COMMONWEALTH OF REDMONT

MOTION TO COMPEL

Your Honour, the Plaintiff seeks to compel the following from the Defendant:

  • Production of all records and evidence held by the DHS in respect of the five charges against jsrkiwi of Trespass, except for those already entered into evidence in this case;
JUSTIFICATION
The Defendant has denied Fact 5 (“No evidence is held by the DHS that the book outside c995 was updated to include the Plaintiff’s name prior to the Plaintiff transacting on the plots.”). This denial implies the existence of records or documentation in the custody of the DHS regarding the status of the book outside c995.

Without production of this evidence, the Plaintiff cannot properly respond, prepare arguments, or test the accuracy of the DHS’s denial.


DENIED.


Unless I'm mistaken, the only evidence of the criminal offense (at least for trespass) would be the images in Plaintiff's criminal record entry. Plaintiff as already included this evidence as part of the record when he entered them as part of the Complaint.
 
Judge Mug’s Trial Protocol and Rules

Pursuant to Rule 1.2, these shall be the rules herein imposed for the trial in jsrkiwi v Department of Homeland Security [2025] DCR 93. The timeframes listed for each section may be changed on application for an extension.


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I. Opening Statements

  1. Each Party shall submit an Opening Statement to the Court.
  2. The purpose of the Opening Statement is to summarize what the Party intends to prove at trial and to present the strengths of its case.
  3. Opening Statements from both Parties are due within forty-eight (48) hours after the conclusion of Discovery.
  4. The Court will invite both parties to submit their opening statements by the same deadline. The Defendant will have the same deadline as Plaintiff.



II. Presentation of Witness Questions

  1. Within fourty-eight (48) hours after submitting his or her Opening Statement, each Party must submit all initial questions for witnesses in a single post.
  2. All objections to the submitted witness questions must be filed in one consolidated post.
  3. Objections are due within twenty-four (24) hours after the deadline for submitting witness questions.



III. Witness Summonses & Testimony

  1. Witnesses shall provide responses as directed by the Court.
  2. Any objections to witness testimony must be submitted within twenty-four (24) hours of the witness's response.



IV. Cross-Examination

  1. Each Party may conduct cross-examination of any witness.
  2. Cross-examination questions are due within fourty-eight (48) hours after the witness has responded to direct questioning.
  3. Cross-examination questions do not need to be consolidated.
  4. Any objections to cross-examination questions are due within twenty-four (24) hours of submission by the Witness.




V. Closing Statements

  1. Following the conclusion of all witness testimony and examination, the Court will invite each Party shall submit a Closing Statement.
    • Clearly label any legal arguments (e.g., “1. THEFT IS ILLEGAL” followed by the Party’s reasoning) - This is for the Court's sanity and ease of readability.
  2. Plaintiff shall have 72 Hours to submit a Closing Statement. On submission of Plaintiff's statement, Defendant shall immediately have 72 hours to submit a Closing Statement.



VI. Motions and Objections After Closing Statements

  1. After both Closing Statements have been submitted, either Party may file post-argument motions or objections (e.g., Motion to Reconsider, Objection for Perjury, etc.).
  2. The Party must notify the Court of its intent to file such motion or objection within twenty-four (24) hours of the Closing Statements being submitted.
  3. Upon advisement from the Court, the Party will have forty-eight (48) hours to submit the requested motion, objection, or brief.
 

Brief


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

Your Honor:

The Defense submits the following interrogatories of the Plaintiff consistent with Rule 4.8:

  1. Have you ever entered the property C995 other than by warping to a /home?
  2. Have you ever entered the property c108 other than by warping to a /home?
  3. What does the Plaintiff understand “read before entry” to mean, as shown in exhibits P-003 and P-021?
  4. Why did Plaintiff presume permission to enter c995 when the sign outside it shown in Exhibit P-003 said “restricted area”?
  5. The Plaintiff has alleged in a claim that the DHS “violated the administrative due-process principles applicable to agency decisions”. What are the specific principles that the Plaintiff alleges were violated?

PLAINTIFF’S RESPONSE TO DEFENCE’S INTERROGATORIES

1. Have you ever entered the property C995 other than by warping to a /home?
Yes.

2. Have you ever entered the property c108 other than by warping to a /home?
Yes.

3. What does the Plaintiff understand “read before entry” to mean, as shown in exhibits P-003 and P-021?
The Plaintiff’s understanding is that “read before entry” refers to the book placed at the entrance of the property.

4. Why did Plaintiff presume permission to enter c995 when the sign outside it shown in Exhibit P-003 said “restricted area”?
The Plaintiff presumed permission to enter c995, because it is lawful for a person to enter a ‘restricted area’ if no instructions to the contrary have been served to him.

5. The Plaintiff has alleged in a claim that the DHS “violated the administrative due-process principles applicable to agency decisions”. What are the specific principles that the Plaintiff alleges were violated?
The plaintiff is referring to the principles that:
  • The DHS should not find a person guilty of a crime without all elements of the crime existing;
  • The DHS should not find a person guilty of a crime without sufficient evidence to support every element of the crime;
  • The DHS should not show preferential treatment towards certain citizens; and
  • Decisions by the DHS should be promptly reversed by the DHS when they were shown to be wrong or unlawful.
 
Your Honor:

Pursuant to Rule 4.6, the Commonwealth enters the following evidence:
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