Lawsuit: In Session Privacy Matters (Class Action Group) v. Vanguard Securities LLC [2025] FCR 36

Dartanboy said:
2. All documentation, policies, procedures, or technical diagrams showing how user financial data is shared between Vanguard Securities LLC and Discover Bank.

We have recently established a Privacy Policy: Vanguard & Co Privacy Policy and we already had the ToS: Vanguard Market Access TOS
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Objection


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 is shared" - including technical diagrams and procedures. The referenced documents contain only general statements that data is shared "internally, among affiliates and business units" without any of the requested technical details.

2. The newly created Privacy Policy ("Effective Date: April 10, 2025") cannot possibly contain the technical documentation of data sharing processes that existed during the relevant period (January 2025 to April 10, 2025).

3. The response completely fails to address whether technical documentation, diagrams, or procedural documentation exists, instead substituting general policy documents that do not contain the specific information requested.

The Plaintiff requests the Court find this response non-responsive to the discovery request.



Motion


MOTION TO COMPEL

The Plaintiff respectfully moves this Court to compel the Defendant to produce the technical documentation requested in Document Request 2:

GROUNDS:

1. The Defendant's response cited only their general Privacy Policy (created April 10, 2025) and Terms of Service, neither of which contains any technical details about HOW data is shared between entities.

2. The requested technical documentation is directly relevant to our claims under Privacy Act Section 9(1) regarding improper data sharing between entities.

3. As a financial services provider, the Defendant must have technical documentation detailing data flows, APIs, or database access mechanisms between their affiliated entities. Such documentation is standard in the industry and necessary for technical implementation, auditing, and compliance purposes.

4. The Defendant has AFFIRMED they have "direct access to users' Discover Bank account information" (Answer 4), which necessarily requires technical mechanisms to implement. Documentation of these mechanisms is precisely what our request seeks.

5. The Defendant's citation of a Privacy Policy created AFTER the period of violations is non-responsive to our request for documentation showing how data was shared during the relevant time period.


 
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Dartanboy said:
6. Statistics showing total number of users who accessed VMA services between launch and April 11, 2025.

We do not have easy access to this information, as we don't track such statistics.

7. Documentation showing the total volume of financial transactions processed during the period without a Privacy Policy.

We do not have easy access to this information, as we don't track such statistics.
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Objection


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) produced a detailed breakdown of transactions as Exhibit P-019, clearly demonstrating their ability to track, compile, and produce transaction data.

2. It is technically impossible for a financial services platform to operate without tracking user accounts and transaction data. Such tracking is fundamental to financial operations, regulatory compliance, and basic business functions.

The claim that Vanguard "doesn't track such statistics" while simultaneously presenting detailed transaction records in another case constitutes a false statement made under penalty of perjury. This misrepresentation appears designed to withhold critical information regarding the scale of the privacy violations at issue in this case.



Motion


MOTION TO COMPEL

The Plaintiff respectfully moves this Court to compel the Defendant to produce the documents requested in Document Requests 6 and 7:

GROUNDS:

1. The Defendant's claim that they "don't track such statistics" is demonstrably false for multiple reasons:

a) In Vanguard & Co v Naezaratheus [2025] FCR 32, they submitted Exhibit P-019 containing detailed transaction data, proving they maintain such records.

b) Their own Terms of Service explicitly require they track both user statistics and transaction volumes:

- "VMA will send you confirmations of transactions and periodic account statements, which are the official records of the activity in your Brokerage Account as required by Applicable Law... Periodic statements will be sent for every month in which there is activity but no less than quarterly." (Exhibit P-004 - ToS - Section 2.b)

- "If your Brokerage Account falls below $500 in value, you authorize VMA, in its discretion, to liquidate your securities and close your Brokerage Account." (Exhibit P-004 - ToS - Section 3.b)

- "With certain products or types of accounts, VMA or its agents may produce performance reports. You understand that, in producing such performance reports, VMA and its agents will use reasonable care in compiling such reports and information from sources considered reliable." (Exhibit P-004 - ToS - Section 2.e)

2. The Defendant has AFFIRMED in their Answer to Complaint (9) that "These practices affected all VMA users in a uniform manner." Having acknowledged universal effect, they must possess data on how many users were affected.

3. It is technically impossible for a financial institution to operate without tracking user numbers and transaction volumes - such tracking is fundamental to the basic operations of a financial institution.

4. The requested information is directly relevant to establishing the scale of Privacy Act violations for determining punitive damages under Section 5(3)(a) of the Legal Damages Act, which permits consideration of "the nature and extent of the harm."

5. Rule 4.7 requires that "material must be relevant to the case," which this information clearly is, and that materials must be provided "under sanction of contempt of court and perjury."

The Plaintiff respectfully requests that the Court compel the Defendant to produce the user statistics and transaction volume data requested in Document Requests 6 and 7.


 
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Dartanboy said:
2. What specific steps, if any, did Vanguard Securities LLC take to comply with Privacy Act requirements prior to April 11, 2025?

Vanguard has always complied with the Privacy Act. There were no specific steps taken because it has always followed its provisions.
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Objection


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 users, despite being explicitly referenced at login." (Answer 2)

2. "Defendant's Terms of Service claimed there was a 'Disclosures' section containing 'how your personal information is handled by the firm,' but this section does not exist." (Answer 3)

3. "The Defendant collects PII including account numbers and balances and didn't provide users access to information about how this data is collected, stored, or shared." (Answer 7)

These AFFIRMED facts directly establish non-compliance with Privacy Act Sections 5(1)(a) and 4(2), making the statement "Vanguard has always complied with the Privacy Act" demonstrably false by the Defendant's own prior admissions.



Motion


MOTION TO STRIKE

The Plaintiff moves to strike Defendant's response to Interrogatory 2:

"Vanguard has always complied with the Privacy Act";

as demonstrably false and contradictory to Defendant's own admissions in their Answer to Complaint.

 
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 volumes, and technical diagrams, which the Defendant has improperly refused to provide.

2. Should the Court grant our Motions, the Defendant will require a reasonable time to gather and produce these documents.

3. The requested information is essential to establishing the scope and scale of the Privacy Act violations, which is critical for determining appropriate punitive damages.

4. This extension would serve the interests of justice by ensuring all relevant information is available to the Court before proceeding to the next phase of litigation.

The Plaintiff notes that this extension request is made in good faith and not for purposes of delay. We have diligently pursued discovery throughout the existing discovery period and require this extension solely to obtain important information that has been improperly withheld.
 
ToadKing said:

Objection​


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) produced a detailed breakdown of transactions as Exhibit P-019, clearly demonstrating their ability to track, compile, and produce transaction data.

2. It is technically impossible for a financial services platform to operate without tracking user accounts and transaction data. Such tracking is fundamental to financial operations, regulatory compliance, and basic business functions.

The claim that Vanguard "doesn't track such statistics" while simultaneously presenting detailed transaction records in another case constitutes a false statement made under penalty of perjury. This misrepresentation appears designed to withhold critical information regarding the scale of the privacy violations at issue in this case.
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We can certainly look at a list of transactions for an individual, but pulling up every single transaction and manually going through and counting out unique users is not as simple.

Likewise, counting out a total of every single transaction is not easy.

We didn't say it was impossible, simply infeasible.
 
ToadKing said:

Objection​


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 users, despite being explicitly referenced at login." (Answer 2)

2. "Defendant's Terms of Service claimed there was a 'Disclosures' section containing 'how your personal information is handled by the firm,' but this section does not exist." (Answer 3)

3. "The Defendant collects PII including account numbers and balances and didn't provide users access to information about how this data is collected, stored, or shared." (Answer 7)

These AFFIRMED facts directly establish non-compliance with Privacy Act Sections 5(1)(a) and 4(2), making the statement "Vanguard has always complied with the Privacy Act" demonstrably false by the Defendant's own prior admissions.
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Defendnat did not comply with the Plaintiff's interpretation of the Privacy Act, however as shown in the Answer to Complaint, our interpretations clearly differ. Defendant complied with the Privacy Act as far as we can tell.
 
ToadKing said:

Objection​


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 is shared" - including technical diagrams and procedures. The referenced documents contain only general statements that data is shared "internally, among affiliates and business units" without any of the requested technical details.

2. The newly created Privacy Policy ("Effective Date: April 10, 2025") cannot possibly contain the technical documentation of data sharing processes that existed during the relevant period (January 2025 to April 10, 2025).

3. The response completely fails to address whether technical documentation, diagrams, or procedural documentation exists, instead substituting general policy documents that do not contain the specific information requested.

The Plaintiff requests the Court find this response non-responsive to the discovery request.
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The Terms of Service contain all we have, then. There were no additional documents.
 
ToadKing said:
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 volumes, and technical diagrams, which the Defendant has improperly refused to provide.

2. Should the Court grant our Motions, the Defendant will require a reasonable time to gather and produce these documents.

3. The requested information is essential to establishing the scope and scale of the Privacy Act violations, which is critical for determining appropriate punitive damages.

4. This extension would serve the interests of justice by ensuring all relevant information is available to the Court before proceeding to the next phase of litigation.

The Plaintiff notes that this extension request is made in good faith and not for purposes of delay. We have diligently pursued discovery throughout the existing discovery period and require this extension solely to obtain important information that has been improperly withheld.
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The Defendant opposes an extension; Discovery has already gone on beyond the original length and we have answered all questions and shown all requested documents, within reason (we are not creating new documents that don't exist).

My client has the right to a speedy trial.
 
Dartanboy said:
We can certainly look at a list of transactions for an individual, but pulling up every single transaction and manually going through and counting out unique users is not as simple.

Likewise, counting out a total of every single transaction is not easy.

We didn't say it was impossible, simply infeasible.
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We also sold the technology, and no longer have the means to even access it.
 
Dartanboy said:
AFFIRM that Executive Order 24/23 defines "personal identifiable information (PII) is "any information related to an identifiable person". The Defendant collects PII including account numbers and balances and didn't provide users access to information about how this data is collected, stored, or shared, as evidenced by the JSON data response (P-006)," however NOTE that Executive Orders are defined by the Constitution as "A lawful directive issued by the President in the pursuit of his or her duties. Executive Orders must only be used as a mechanism by which the President can exert powers expressly granted to the Executive within the Constitution." which means that this definition is narrowly tailored to information being handled by the Executive Branch of Redmont's Government.
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DECLARATION TO AMEND:
Answer 7 contains an error due to a misreading of the Facts.

Answer 7 will be amended as follows:

AFFIRM that Executive Order 24/23 defines "personal identifiable information (PII) is "any information related to an identifiable person"."

However DENY that "The Defendant collects PII including account numbers and balances without providing users access to information about how this data is collected, stored, or shared, as evidenced by the JSON data response (P-006)," and NOTE that Executive Orders are defined by the Constitution as "A lawful directive issued by the President in the pursuit of his or her duties. Executive Orders must only be used as a mechanism by which the President can exert powers expressly granted to the Executive within the Constitution." which means that this definition is narrowly tailored to information being handled by the Executive Branch of Redmont's Government.
 

Motion


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 without permission from Cope Holdings" - effectively pointing to Cope Holdings LLC as the current custodian of the requested data.

2. Cope Holdings LLC is a necessary third party with unique access to critical evidence in this case:

a) According to their own announcement (the Plaintiff submits as Exhibit P-009), Cope Holdings LLC acquired Vanguard Market Access and now controls its platform and associated data.

b) Cope Holdings LLC is run by "Stoppers," who was the original developer of the VMA platform, establishing both technical expertise and familiarity with the data structure.

c) In the announcement (P-009), it states that "Your investments and securities will continue uninterrupted," confirming data continuity through the acquisition and current possession of historical user data.

screenshot_20250418_180938_discord-png.54467

3. The requested information remains directly relevant to establishing the scale of Privacy Act violations for determining punitive damages under Section 5(3)(a) of the Legal Damages Act, which permits consideration of "the nature and extent of the harm."

4. As the platform developer and current owner, Cope Holdings LLC would have substantially easier access to the requested user statistics and transaction volume data than any other party.

5. While Cope Holdings LLC is not a named defendant, they are the successor organisation to the relevant business operations and has acquired both the benefits and potential liabilities of those operations.

6. Rule 4.7 permits the Court to order production of materials from parties in possession of relevant evidence, and the Court has inherent authority to ensure complete discovery of critical information.

The Plaintiff respectfully requests that the Court issue an order compelling Cope Holdings LLC to produce the user statistics and transaction volume data originally requested in Document Requests 6 and 7 for the period between VMA's launch and April 11, 2025.

 
ToadKing said:

Motion


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 without permission from Cope Holdings" - effectively pointing to Cope Holdings LLC as the current custodian of the requested data.

2. Cope Holdings LLC is a necessary third party with unique access to critical evidence in this case:

a) According to their own announcement (the Plaintiff submits as Exhibit P-009), Cope Holdings LLC acquired Vanguard Market Access and now controls its platform and associated data.

b) Cope Holdings LLC is run by "Stoppers," who was the original developer of the VMA platform, establishing both technical expertise and familiarity with the data structure.

c) In the announcement (P-009), it states that "Your investments and securities will continue uninterrupted," confirming data continuity through the acquisition and current possession of historical user data.

screenshot_20250418_180938_discord-png.54467

3. The requested information remains directly relevant to establishing the scale of Privacy Act violations for determining punitive damages under Section 5(3)(a) of the Legal Damages Act, which permits consideration of "the nature and extent of the harm."

4. As the platform developer and current owner, Cope Holdings LLC would have substantially easier access to the requested user statistics and transaction volume data than any other party.

5. While Cope Holdings LLC is not a named defendant, they are the successor organisation to the relevant business operations and has acquired both the benefits and potential liabilities of those operations.

6. Rule 4.7 permits the Court to order production of materials from parties in possession of relevant evidence, and the Court has inherent authority to ensure complete discovery of critical information.

The Plaintiff respectfully requests that the Court issue an order compelling Cope Holdings LLC to produce the user statistics and transaction volume data originally requested in Document Requests 6 and 7 for the period between VMA's launch and April 11, 2025.

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Might we respond to the Motion? There seems to be an misunderstanding.

Edit: Nevermind; I keep misreading. Tough day. Strike this request please.
 
ToadKing said:

Motion


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 without permission from Cope Holdings" - effectively pointing to Cope Holdings LLC as the current custodian of the requested data.

2. Cope Holdings LLC is a necessary third party with unique access to critical evidence in this case:

a) According to their own announcement (the Plaintiff submits as Exhibit P-009), Cope Holdings LLC acquired Vanguard Market Access and now controls its platform and associated data.

b) Cope Holdings LLC is run by "Stoppers," who was the original developer of the VMA platform, establishing both technical expertise and familiarity with the data structure.

c) In the announcement (P-009), it states that "Your investments and securities will continue uninterrupted," confirming data continuity through the acquisition and current possession of historical user data.

screenshot_20250418_180938_discord-png.54467

3. The requested information remains directly relevant to establishing the scale of Privacy Act violations for determining punitive damages under Section 5(3)(a) of the Legal Damages Act, which permits consideration of "the nature and extent of the harm."

4. As the platform developer and current owner, Cope Holdings LLC would have substantially easier access to the requested user statistics and transaction volume data than any other party.

5. While Cope Holdings LLC is not a named defendant, they are the successor organisation to the relevant business operations and has acquired both the benefits and potential liabilities of those operations.

6. Rule 4.7 permits the Court to order production of materials from parties in possession of relevant evidence, and the Court has inherent authority to ensure complete discovery of critical information.

The Plaintiff respectfully requests that the Court issue an order compelling Cope Holdings LLC to produce the user statistics and transaction volume data originally requested in Document Requests 6 and 7 for the period between VMA's launch and April 11, 2025.

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Objection


BREACH OF PROCEDURE

Rule 4.7 allows the request, and by the Judge forcible showing, of documents from the opposing party.

It does not allow 3rd parties to be forced into doing so.

 

Motion


MOTION TO END DISCOVERY

The Defense, while unaware of exactly how many users and transactions there were, is happy to admit both were significantly large numbers.

We don't want this case to drag on and on and on chasing down the exact number. We ask the Plaintiff to agree to end discovery.

 
Dartanboy said:

Motion


MOTION TO END DISCOVERY

The Defense, while unaware of exactly how many users and transactions there were, is happy to admit both were significantly large numbers.

We don't want this case to drag on and on and on chasing down the exact number. We ask the Plaintiff to agree to end discovery.

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Response


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 properly assess appropriate punitive damages under Section 5(3)(a) of the Legal Damages Act, which specifically permits consideration of "the nature and extent of the harm."

2. The Defendant's sudden willingness to admit to "significantly large numbers" directly contradicts their previous claim that they "don't track such statistics" and demonstrates they either:
a) Previously provided false information in discovery responses, or
b) Have the ability to access specific data, but are attempting to avoid producing it

3. The Defendant has AFFIRMED in their Answer to Complaint (9) that "These practices affected all VMA users in a uniform manner." Exact figures are crucial for several reasons:
a) To establish a factual basis for appropriate punitive damages proportional to the scale of violations
b) To verify the full scope of Privacy Act violations
c) To provide the Court with concrete evidence rather than intentionally vague characterizations

4. The Defendant's desire to avoid "drag[ging] on and on" does not outweigh the Plaintiff's right to relevant discovery, especially when the Defendant has repeatedly obstructed legitimate discovery requests through contradictory statements and improper objections.

6. Rule 4.1 explicitly states that the purpose of Discovery is "to enable fairness by allowing the parties to view the information so that they may properly formulate their legal arguments." The Defendant's vague characterization denies this fairness.

The Plaintiff respectfully requests that the Court deny Defendant's Motion to End Discovery and order the production of specific user statistics and transaction volumes as previously requested.

 
ToadKing said:
The Defendant's sudden willingness to admit to "significantly large numbers" directly contradicts their previous claim that they "don't track such statistics" and demonstrates they either:
a) Previously provided false information in discovery responses, or
b) Have the ability to access specific data, but are attempting to avoid producing it
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Objection


PERJURY

There is a 3rd possibility, and it happens to be the truth:
c) We know that a lot of people have used the system, because a lot of people have asked for support in some way.

We can also deduce from a log of all transactions that there is a large amount, without actually counting them.

 
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. Articles of Incorporation for Vanguard & Co..

3. Any operating agreements or bylaws governing the relationship between Vanguard Securities LLC and other Vanguard & Co. subsidiaries.

4. Registration documents filed with the Department of Commerce relating to Vanguard Securities LLC's.

5. Any service agreements between Vanguard Securities LLC and Discover Bank governing data sharing.

6. Balance sheets for Vanguard Securities LLC for the period January 2025 through April 2025.

7. Balance sheets for Vanguard & Co. for the period January 2025 through April 2025.

8. Revenue statements showing transaction fees and other income generated through VMA for the period January 2025 through April 2025.

9. Any compliance checklists used to ensure VMA met privacy requirements prior to launch.

10. Any legal reviews or opinions obtained regarding Privacy Act compliance prior to launch.

11. Database schemas showing what user information is stored and how it is organised.

12. Data retention schedules for user information collected through VMA.

13. Internal audit reports regarding operational compliance with stated policies.

14. Records of any prior complaints about privacy practices received through support tickets.

15. Communications with Cope Holdings LLC regarding the transfer of user data during the acquisition.

These documents are directly relevant to establishing the scale, scope, intentionality, and corporate context of the Privacy Act violations already AFFIRMED by the Defendant.

The Plaintiffs would like to reiterate the point - "proprietary information" has no basis in discovery rules. Rule 4.7 requires only that "material must be relevant to the case."
 
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ToadKing said:
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. Articles of Incorporation for Vanguard & Co..

3. Any operating agreements or bylaws governing the relationship between Vanguard Securities LLC and other Vanguard & Co. subsidiaries.

4. Registration documents filed with the Department of Commerce relating to Vanguard Securities LLC's.

5. Any service agreements between Vanguard Securities LLC and Discover Bank governing data sharing.

6. Balance sheets for Vanguard Securities LLC for the period January 2025 through April 2025.

7. Balance sheets for Vanguard & Co. for the period January 2025 through April 2025.

8. Revenue statements showing transaction fees and other income generated through VMA for the period January 2025 through April 2025.

10. Any compliance checklists used to ensure VMA met privacy requirements prior to launch.

11. Any legal reviews or opinions obtained regarding Privacy Act compliance prior to launch.

12. Database schemas showing what user information is stored and how it is organised.

13. Data retention schedules for user information collected through VMA.

14. Internal audit reports regarding operational compliance with stated policies.

15. Records of any prior complaints about privacy practices received through support tickets.

16. Communications with Cope Holdings LLC regarding the transfer of user data during the acquisition.

These documents are directly relevant to establishing the scale, scope, intentionality, and corporate context of the Privacy Act violations already AFFIRMED by the Defendant.

The Plaintiffs would like to reiterate the point - "proprietary information" has no basis in discovery rules. Rule 4.7 requires only that "material must be relevant to the case."
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Your honor, the Plaintiff had the opportunity to post interrogatories already. Discovery was even extended to allow it.

Since there is now much less than 72 hours remaining, we ask these requests be denied.

The Plaintiff cannot indefinitely extend this lawsuit to keep digging. They should've prepared the case beforehand. My client has a Constitutional Right to a Speedy Trial.
 
ToadKing said:
12. Database schemas showing what user information is stored and how it is organised.
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We would also like to note that this information is (probably) protected by IRL Intellectual Property laws. It will not be produced for a Minecraft court.

(For IRL legal reasons, this is not IRL legal advice)
 
Dartanboy said:
Your honor, the Plaintiff had the opportunity to post interrogatories already. Discovery was even extended to allow it.

Since there is now much less than 72 hours remaining, we ask these requests be denied.

The Plaintiff cannot indefinitely extend this lawsuit to keep digging. They should've prepared the case beforehand. My client has a Constitutional Right to a Speedy Trial.
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Response


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 (Interrogatories) request. The original filing explicitly states: "Pursuant to Rule 4.7 (Request for Discovery, Opposing Party Movement)".

2. The Defendant argues that the Plaintiff had ample opportunity to conduct discovery, yet fails to acknowledge that Rule 4.1 explicitly provides for the purpose of discovery: "to allow all material to enter the court prior to the beginning of arguments for the sake of fairness." This principle ensures that both parties have access to the necessary information to prepare their legal arguments thoroughly and justly.

3. There are still 28 hours remaining in the discovery period. Moreover, the Plaintiff has requested an extension, recognising that the case is more complex than initially understood. That complexity warrants further document requests to uncover the full scope of relevant facts.

4. Granting the Plaintiff’s request at this stage is not a tactic to delay proceedings, but rather a reasonable effort to ensure that the trial proceeds on a complete and accurate record. These requests serve not only the Plaintiff’s interest but also that of the Defendant, as they help ensure that the trial is conducted on fair and well-informed grounds.

 
In addition, your honor, the Plaintiff is attempting to open-wide every form of document they can think of, from irrelevant information like balance sheets to Attorney-Client privileged documents like legal opinions on policies.

To allow this request would make every business' internal affairs public knowledge. This cannot be approved.

(This is an opposition under Rule 4.7)
 
Dartanboy said:
In addition, your honor, the Plaintiff is attempting to open-wide every form of document they can think of, from irrelevant information like balance sheets to Attorney-Client privileged documents like legal opinions on policies.

To allow this request would make every business' internal affairs public knowledge. This cannot be approved.

(This is an opposition under Rule 4.7)
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Objection


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 strike the Defendant's comments from the record.

 
IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
ORDER OF THE COURT

Case [2025] FCR 36
Between:
Privacy Matters, Class Action Group
v
Vanguard Securities, LLC

CONTEMPT OF COURT
The court hereby holds both parties, and their respective legal firms if one exists in one charge of contempt of court each. Both parties are filing a frivolous and unmaintainable count of submissions to the court in a way to simply argue over the same couple of points in a movant-response-movant structure. The court room isn't a place where you can simply submit an infinite loop of arguments while the Judge isn't looking. Literally, as I write to submit this order, there has been THREE NEW MESSAGES on the thread. Both of you are knowledgeable attorneys. Do you genuinely think this is a good way to conduct any litigation? What advantage do you think you will gain in the court by filing erroneous motions objections and responses like this?

I understand the desire to respond to whatever argument the opposition has made, but frankly, this is ridiculous. All further submissions will be denied and held in contempt until I can sort through the heap of chaotic submissions reaching well above 20 in count since my last filing TWELVE HOURS AGO. THAT AVERAGES ALMOST TWO AN HOUR.

Filed this 30th of April, 2025.
@ToadKing @Dartanboy @Vernicia
 
Greetings. Following the resignation of the Honourable Colonel_Kai, I will be taking over this case. Please allow some time to sort through the pile of content you have placed at my feet.
 
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