Recent content by ToadKing

IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT CLOSING STATEMENT Your Honour, this case fundamentally revolves around two critical questions: 1. Was there a valid contract between the Defendant and Vanguard? 2. Did the Defendants' actions constitute fraud under the laws of Redmont? The...

BREACH OF PROCEDURE The Plaintiff objects to the Defendant's additional comments outside of their original Rule 4.7 opposition response. The Defendant has the right to comment on any additional information, but they should do so in the correct manner. The Plaintiff respectfully asks the court...

TO OPPOSITION The Plaintiff respectfully submits the following responses to Defendant's opposition to the additional discovery requests: 1. Rule 4.7 (Request for Discovery, Opposing Party Movement) is a request for further documents. The Defendant appears to mistake this as a Rule 4.8...

Pursuant to Rule 4.7 (Request for Discovery, Opposing Party Movement), the Plaintiff requests the Defendant to produce the following additional materials relevant to the case: 1. Articles of Incorporation for Vanguard Securities LLC, showing its legal formation and corporate purpose. 2...

TO MOTION TO END DISCOVERY The Plaintiff respectfully opposes the Defendant's Motion to End Discovery for the following reasons: 1. The Defendant's vague admission that user numbers and transactions were "significantly large numbers" is deliberately imprecise and insufficient for the Court to...

MOTION TO COMPEL The Plaintiff respectfully moves this Court to compel Cope Holdings LLC to produce the documents originally requested from the Defendant in Document Requests 6 and 7: GROUNDS: 1. The Defendant claims they "sold the technology, and no longer have the means to even access it...

Pursuant to Rule 4.4 (Request for Extension of Discovery), the Plaintiff respectfully requests a 14-day extension of the discovery period for the following reasons: 1. The Plaintiff has filed multiple Motions to Compel for the production of documents relating to user statistics, transaction...

PERJURY The Plaintiff objects to Defendant's response to Interrogatory 2 on the grounds of perjury. This response directly contradicts the Defendant's own AFFIRMED admissions in their Answer to Complaint, where they explicitly acknowledged: 1. "No Privacy Policy existed or was accessible to...

PERJURY The Plaintiff objects to the Defendant's responses to Document Requests 6 and 7 on the grounds of perjury. This response is demonstrably false based on the following: 1. In the ongoing case of Vanguard & Co v Naezaratheus [2025] FCR 32, the Defendant (as Plaintiff in that case)...

NON-RESPONSIVE The Plaintiff objects to the Defendant's response to Document Request 2 as non-responsive. This response fails to address the specific request for technical documentation in the following ways: 1. The request explicitly asked for documentation showing "HOW user financial data...

Pursuant to Rule 3.3 (Amendment to Complaint), the Plaintiff amends the Prayer for Relief section of the Complaint as follows: IV. PRAYER FOR RELIEF The Plaintiff seeks the following from the Defendant: 1. Punitive damages in the amount of $50,000 per Plaintiff for the Defendant's outrageous...

TO MOTION TO DISMISS The Plaintiff respectfully opposes Defendant's Motion to Dismiss and submits that the motion fundamentally misinterprets the standing requirements of Rule 2.1: 1. Rule 2.1 explicitly states that a plaintiff must show they "Suffered some injury caused by a clear second...

1. In what tangible and measurable way were the Plaintiffs damaged by the Defendant's alleged violations? The Plaintiffs did not suffer quantifiable financial losses as a result of the Defendant's violations. The tangible impact experienced was the deprivation of our statutory rights under the...

TO OBJECTIONS 2. What specific steps, if any, did Vanguard Securities LLC take to comply with Privacy Act requirements prior to April 11, 2025? This interrogatory is directly relevant to establishing whether Vanguard's violations were deliberate or merely negligent, which is central to the...

TO MOTION TO RECONSIDER The Defendant's motion to reconsider should be denied for the following reasons: 1. The Plaintiff was not deported at the time this case was filed. UnityMaster v. lcn [2025] SCR 2 specifically addressed situations where the plaintiff "was indeed deported" "at the time...