Lawsuit: In Session Vanguard & Co v Naezaratheus [2025] FCR 32

Writ of Summons

@naez is required to appear before the Federal Court in the case of Vanguard & Co v Naezaratheus.

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.

Brief

IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
AMICUS BRIEF

Ladies, gentlemen, enbies, and others. Since former Justice Nacho's ruling in StressedGV v. SalsaStar [2022] FCR 52, a precedent has been set that deported players do not have the same rights as citizens of Redmont. A precedent affirmed in Krix v. The Commonwealth of Redmont [2023] FCR 11 by former Justice dygyee that "[Lord_Donuticus] cannot represent someone in court as [Krix] has been deported."

A precedent affirmed again in gsse v. Commonwealth of Redmont [2024] FCR 101 by former Justice Unseatedduke1, who affirmed that "DC staff has been clear that deported players have no rights in Redmont. Therefore, deported players do not have the right to challenge this in court..."

A precedent yet again affirmed in UnityMaster v. lcn [2025] SCR 2, Chief Justice Aladeen22, writing the court's verdict, specifically mentioned the following: "Finally, at the time of filling this case, the plaintiff was indeed deported. Deported players have no rights in our nation and have no rights to dispute this in court."

When this case was filed, and at the time of posting this Amicus Brief, the defendant Naezaratheus is deported. The defendant currently has no rights in this nation, and as several precedents have established, deported players do not have the right to dispute legal challenges in court, nor do they have the right to appoint someone on their behalf.

Going against these previous decisions could set a very dangerous precedent. I humbly request that the court consider these previous verdicts and how best to resolve the case.

Thank you for your time.

Motion

MOTION TO DISMISS

The Defendant respectfully moves this Court to dismiss under Rule 5.5

I. FAILURE TO FOLLOW CONTRACTUAL REMEDIES
Exhibit P-020 (Vanguard Market Access TOS) explicitly provides the procedure for addressing alleged exploitative trades:

"Customers are strictly prohibited from engaging in trades designed to exploit system mechanics, including placing trades outside of real-life market hours to gain an unfair advantage. If any trade is determined to be exploitative, Vanguard Market Access reserves the right to reverse the trade and undo all associated gains or losses. Customers engaging in exploitative trading practices may have their accounts restricted or suspended at Vanguard’s sole discretion."

My client did not commit any of the prohibited acts listed in the Terms of Service (TOS). The TOS explicitly uses the term 'including'—rather than 'including but not limited to'—which means the specified prohibitions are exhaustive, not illustrative.

As such, my client:

1. Did not exploit any system mechanics, and

2. Did not breach the contract in any manner.

Consequently, the Plaintiff’s Claims for Relief lack any legal basis and must be dismissed under Rule 5.5.

II. In addition, the evidence provided by the Plaintiff is nonsensical and proves nothing. It appears this documentation may have been intended for submission to the Department of Commerce (DOC) months ago regarding a tax exemption, rather than for this proceeding.


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 6th day of April, 2025.

Answer to Complaint

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

Vanguard & Co
Plaintiff

v.

Naezaratheus
Defendant

I. ANSWER TO COMPLAINT

1. The Defendant AFFIRMS paragraph 1 of the complaint regarding the
Plaintiff and Defendant.
2. The Defendant DENIES the general allegations of fraud and theft as
described in the introductory paragraphs of the complaint. The
Defendant asserts that all trading activities were conducted within
the parameters of the Vanguard Market Access (VMA) system, and that
there was no intention to defraud Vanguard & Co. The Defendant
admits to taking advantage of in-game mechanics and strategies to
maximize profits.
3. Regarding Fact 1, the Defendant AFFIRMS that he created a bank
account and deposited $5,000.
4. Regarding Fact 2, the Defendant AFFIRMS that he transferred $5,000 to
Vanguard Market Access (VMA).
5. Regarding Fact 3, the Defendant AFFIRMS that he transferred $10 from
VMA to his bank account.
6. Regarding Fact 4, the Defendant AFFIRMS that he transferred $10 from
his bank account to Voyager.
7. Regarding Fact 5, the Defendant DENIES that the transfer of $21,000
from VMA to his bank account was fraudulent. The Defendant asserts
that this was a result of legitimate trading activity, however
unorthodox.
8. Regarding Fact 6, the Defendant AFFIRMS that he sent $21,000 to
absinf and then at 6:07AM received $1,000 and immediately
transferred that $1,000 to MB
9. Regarding Fact 7, the Defendant DENIES that the transfer of $335,000
from VMA to his bank account was fraudulent. The Defendant asserts
that this was a result of legitimate trading activity, however
unorthodox.
10. Regarding Fact 8, the Defendant AFFIRMS that he transferred $150,000
to Volt and $150,000 to Voyager.
11. Regarding Fact 9, the Defendant AFFIRMS that he transferred $5,000 to
VMA and $30,000 to Volt
12. Regarding Fact 10, the Defendant DENIES that the transfer of
$3.261 million from VMA to his bank account was fraudulent. The
Defendant asserts that this was a result of legitimate trading
activity, however unorthodox.
13. Regarding Fact 11, the Defendant AFFIRMS that he transferred $1
million to Voyager and $2 million to MegaMinerM’s Legacy Account.
14. Regarding Fact 12, the Defendant AFFIRMS that he transferred $260,000
to twilight2660
15. Regarding Fact 13, the Defendant AFFIRMS that he received $1 million
from MegaMinerM’s Legacy Account and transferred it to Voyager.
16. Regarding Fact 14, the Defendant DENIES that the transfer of
$572,800 from VMA to his bank account was fraudulent. The Defendant
asserts that this was a result of legitimate trading activity,
however unorthodox.
17. Regarding Fact 15, the Defendant AFFIRMS that he transferred $500,000
to Gribble and $73,800 to MegaMinerM’s Legacy Account.
18. Regarding Fact 16, the Defendant DENIES that the transfer of $500,000
from VMA to his bank account was fraudulent. The Defendant asserts
that this was a result of legitimate trading activity, however
unorthodox.
19. Regarding Fact 17, the Defendant AFFIRMS that he transferred $500k to
Gribble
20. Regarding Fact 18, the Defendant DENIES that the transfer of $500,000
from VMA to his bank account was fraudulent. The Defendant asserts
that this was a result of legitimate trading activity, however
unorthodox.
21. Regarding Fact 19, the Defendant AFFIRMS that he transferred $500k to
Voyager
22. Regarding Fact 20, the Defendant DENIES that the transfer of
$1.9 million from VMA to his bank account was fraudulent. The
Defendant asserts that this was a result of legitimate trading
activity, however unorthodox.
23. Regarding Fact 21, the Defendant AFFIRMS that he sent $1.9 million to
Voyager.
24. Regarding Fact 22, the Defendant DENIES that the transfer of
$200,000 from VMA to his bank account was fraudulent. The Defendant
asserts that this was a result of legitimate trading activity,
however unorthodox.
25. Regarding Fact 23, the Defendant DENIES that the transfer of
$1.3 million from VMA to his bank account was fraudulent. The
Defendant asserts that this was a result of legitimate trading
activity, however unorthodox, and AFFIRMS that $500,000 was sent
back to VMA
26. Regarding Fact 24, the Defendant AFFIRMS that he transferred $110,001
from VMA to his bank account, and $50,000 back to VMA
27. Regarding Fact 25, the Defendant AFFIRMS that he transferred $22,999
from VMA to his bank account
28. Regarding Fact 26, the Defendant AFFIRMS that he transferred $9,000 to
VMA and then $14,812 from VMA to his bank account
29. Regarding Fact 27, the Defendant AFFIRMS that he transferred
$1.088812 million to Voyager
30. Regarding Fact 28, the Defendant AFFIRMS that he transferred $14,002
from VMA to his bank account, and $7,000 back to VMA
31. Regarding Fact 29, the Defendant DENIES that the transfer of
$517,000 from VMA to his bank account was fraudulent. The Defendant
asserts that this was a result of legitimate trading activity,
however unorthodox.
32. Regarding Fact 30, the Defendant AFFIRMS that he transferred $250,000
to KingBOB99878’s Personal Account
33. Regarding Fact 31, the Defendant DENIES that the transfer of $250,000
from VMA to his bank account was fraudulent. The Defendant asserts
that this was a result of legitimate trading activity, however
unorthodox.
34. Regarding Fact 32, the Defendant DENIES that the transfer of $27,900
from VMA to his bank account was fraudulent. The Defendant asserts
that this was a result of legitimate trading activity, however
unorthodox.
35. Regarding Fact 33, the Defendant DENIES that the transfer of
$49,995 from VMA to his bank account was fraudulent. The Defendant
asserts that this was a result of legitimate trading activity,
however unorthodox.
36. Regarding Fact 34, the Defendant DENIES that the transfer of
$48,995 from VMA to his bank account was fraudulent. The Defendant
asserts that this was a result of legitimate trading activity,
however unorthodox.
37. Regarding Fact 35, the Defendant AFFIRMS that he has $650,894 in his
bank account.
38. Regarding Fact 36, the Defendant acknowledges the trading logs but
DENIES that these trades were inherently fraudulent. The Defendant
maintains that he was exploiting in-game market mechanics, but that
this does not constitute fraud.
39. Regarding Fact 37, the Defendant acknowledges Vanguard Market
Access’ Terms of Service and does not dispute the clarity of "Fair
Trading and Exploit Prevention" as defined, however asserts that the
trades conducted were not explicitly in violation of these terms.

II. DEFENSES

1. Legitimate Trading Activity: The Defendant maintains that all
trading activity was conducted through the VMA platform, utilizing
in-game mechanics available to all users. The Defendant denies any
intentional misrepresentation or falsification of records. The
scale of the trades does not inherently make them fraudulent.
2. Clear Definition of Exploit: The Defendant acknowledges that
VMA defines "exploits" clearly within its General Trading Rules as
"trades designed to exploit system mechanics, including placing
trades outside of real-life market hours to gain an unfair
advantage." However, the Defendant asserts that the specific trades
in question did not violate this definition. The Defendant's
actions did not involve trading outside of market hours. The
Defendant's understanding of the system mechanics, combined with
his trading strategies, allowed him to capitalize on in-game
opportunities, which, while profitable, do not inherently
constitute an illegal exploit.
3. No Intent to Defraud: The Defendant asserts that he had no
intention to defraud Vanguard & Co. His actions were driven by a
desire to maximize profits through trading within the VMA platform.

III. RESPONSE TO CLAIMS FOR RELIEF

1. Breach of Contract: The Defendant denies breaching the contract,
arguing that his actions, while taking advantage of in-game
mechanics, were not explicitly prohibited by the Terms of Service,
as the trades were not conducted outside of market hours and the
system mechanics in question were not explicitly defined as
prohibited.
2. Fraud: The Defendant vehemently denies the claim of fraud. The
Defendant asserts that all trades were conducted within the VMA
system, and there was no intention to deceive or misrepresent any
information.

IV. PRAYER FOR RELIEF

The Defendant respectfully requests that the Court:

1. Dismiss the Plaintiff’s claims for compensatory damages. The
Defendant argues that the Plaintiff has not provided sufficient
evidence to prove that the Defendant’s actions constitute fraud or
caused direct financial harm.
2. Deny the Plaintiff’s request for punitive damages. The Defendant
asserts that his actions were not malicious, reckless, or in
outrageous disregard for the law.
3. Deny the Plaintiff’s request for legal fees.

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: April 7th, 2025

Motion

MOTION TO STRIKE

My apologies, your honor. I responded to a response, which is not permitted.

Opening Statement

IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
OPENING STATEMENT

Introduction
The Defendant, Naezaratheus, is a fraudster who intentionally and maliciously tricked the Plaintiff, Vanguard & Co, into paying him more than $9.3 Million through a series of fraudulent stock trades, and throughout this filing, it will become clear not only through a Balance of Probabilities (as required for civil suits), but even Beyond a Reasonable Doubt that the Defendant’s actions were intentional, illegal Fraud.

On The Agreed Upon Facts
1. The Defendant has, while disagreeing on whether they were fraudulent, affirmed that every transaction listed in Facts 1-34 as well as the stock trades in Fact 36 did in-fact occur.

2. The Defendant has affirmed their bank account’s balance to be $650,894.

3. The Defendant has affirmed the contents of Vanguard Market Access’ Terms of Service, although disagrees on the meaning.

On The Disagreed Upon Facts
1. Although the Defendant affirms that the stock trades listed in Fact 36 did occur, the Defendant also “DENIES that these trades were inherently fraudulent. The Defendant maintains that he was exploiting … market mechanics, but that this does not constitute fraud.”

On Fraud
Fraud is defined by the Commercial Standards Act (Act of Congress - Commercial Standards Act) as “An intentional or reckless misrepresentation or omission of an important fact, especially a material one, to a victim who justifiably relies on that misrepresentation; and the victim party or entity suffered actual, quantifiable injury or damages as a result of the misrepresentation or omission.”

Now, we recall the Defendant affirmed the Stock Trades of Fact 36, including the eighteen sets of trades where he sold more shares than he owned. Through these trades, the Defendant intentionally or recklessly misrepresented the amount of shares of stocks he owned, and sold them to the Plaintiff. As a result, the Plaintiff suffered an actual, quantifiable injury of $9,303,691.

This is not a stretch, your honor – this case is exactly the definition of Fraud, and there is simply no alternative way to view this.

Conclusion
My client, Vanguard & Co, is the victim of a Grand Fraud, costing the Plaintiff more than $9.3 Million through the deplorable actions of Naezaratheus, who misrepresented his stocks and caused immense damage to the Plaintiff.

It is clear that the Defendant committed Fraud on a massive scale, and there is no two ways about it.

Opening Statement

IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
OPENING STATEMENT

Your Honor,

The Plaintiff's case against the Defendant rests upon two critical claims: breach of contract and fraud. However, when we examine their own documentation and the applicable laws of the Commonwealth, it becomes evident that neither claim can be substantiated.

Regarding the breach of contract claim, there are several fatal flaws:

1. Vanguard's own Terms establishes an unambiguous method for contract formation. On page two, it explicitly states:

"By signing the agreement, you're agreeing to the Agreements and acknowledging receipt of the disclosures contained in the Booklet..."

It further reinforces this requirement by stating:

"For any like-titled accounts you open in the future, you'll need to sign an Additional Account Acknowledgement where you will confirm that the most current version of the Booklet applies..."

The Defendant never signed any such agreement. No signature was ever solicited, provided, or received. Yet Vanguard now attempts to enforce terms that, according to their own Terms, required signature for acceptance.

2. Vanguard creates a direct contradiction in their acceptance methods. While their Terms requires signature, their login page states:

"By logging in, you agree to our Terms of Service."

This contradiction fails to meet the "clear and unequivocal" communication standard required by Section 4(a) of the Contracts Act.

Even if the Defendant accepts the login page's method of acceptance, their Terms of Service were not reasonably accessible at that point. Users were told they were agreeing to terms they could not readily access or review from the website itself. This undermines the "positive and unambiguous" acceptance requirement of Section 4(b) of the Contracts Act.

3. Turning to the specific trading rules that Vanguard claims were violated, their "Fair Trading and Exploit Prevention" clause states:

"Customers are strictly prohibited from engaging in trades designed to exploit system mechanics, including placing trades outside of real-life market hours to gain an unfair advantage."

While the Defendant acknowledges taking advantage of market mechanics through unorthodox trading strategies, these activities occurred within normal market hours. The prohibition specifically identifies trading "outside of real-life market hours" as the example of prohibited exploitation. The Defendant's activities, though utilizing system mechanics advantageously, do not fall within this specified prohibition.

4. The same section outlines Vanguard's remedy for allegedly exploitative trades: "If any trade is determined to be exploitative, Vanguard Market Access reserves the right to reverse the trade and undo all associated gains or losses." Despite having this contractual remedy available, Vanguard evidently did not identify these trades as exploitative or exercise their right to reverse them at the time they occurred. Instead, they waited until after the funds had been largely transferred before taking any action.

5. Regarding the fraud claim, the Commercial Standards Act Section 6 explicitly defines fraud as: "An intentional or reckless misrepresentation or omission of an important fact, especially a material one, to a victim who justifiably relies on that misrepresentation; and the victim party or entity suffered actual, quantifiable injury or damages as a result of the misrepresentation or omission."

This definition requires four distinct elements, and the plaintiff must prove all four to establish fraud:

1. An intentional or reckless misrepresentation - The Defendant made no false statements whatsoever. When executing trades through Vanguard's platform, he simply used the interface buttons and functions provided to all users, employing unorthodox yet legitimate trading strategies. The system itself processed and approved each transaction. If Vanguard's system permitted these trading activities, this represents a system design issue that the Defendant strategically utilized, not a misrepresentation by the Defendant.
   
   
2. Of an important fact - Even if we were to accept, for argument's sake, that there was some implicit representation about share ownership in each trade, Vanguard's own database contained the definitive record of the Defendant's holdings. Vanguard had perfect information about exactly how many shares the Defendant owned at any given moment. They cannot claim to have been misled about facts that existed in their own records.
   
   
3. Justifiable reliance by the victim - This element is perhaps most clearly absent. Vanguard cannot claim to have justifiably relied on any implied representation when they maintained the authoritative database of all user holdings. As the system operator, they had both the means and responsibility to verify share ownership before executing trades. It is a fundamental principle of fraud law that a party cannot justifiably rely on representations about facts they themselves are in a superior position to verify.
   
   
4. Actual damages resulting from that misrepresentation - While Vanguard may have suffered financial consequences, these resulted from their own system design failures rather than from any misrepresentation by the Defendant. Their system should have had safeguards to prevent transactions that exceeded a user's holdings - a standard feature in properly designed trading platforms.

Motion

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

Justification for Motion

The Defendant respectfully moves this Court to strike all instances of the word "fraud" (or variations thereof) as used by the Plaintiff, Dartanboy, in the case of Vanguard & Co v Naezaratheus. The justification for this motion is as follows:

1. Presumption of Innocence: The Defendant, Naezaratheus, is presumed innocent of any criminal wrongdoing until proven guilty in a court of law.

2. Prejudicial Language: The repeated use of the term "fraud" by the Plaintiff is prejudicial and could unduly influence the Court's judgment before all evidence has been presented and a determination of facts has been made.

3. Lack of Criminal Conviction: There is no indication that the Defendant has been criminally convicted of fraud. Therefore, the use of this term is an unsubstantiated allegation rather than an established fact.

4. Scandalous Language: The use of the term "fraud," without a criminal conviction, could be considered scandalous and impertinent, as it unfairly tarnishes the Defendant's reputation.

Closing Statement

IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
CLOSING STATEMENT

Introduction
Your honor, Naezaratheus is a fraudster; a fraudster who has committed such a massive-scale fraud that it dwarfs even the most heinous of crimes from the past. This is no small-time criminal; this isn't an upstanding citizen who accidentally fell afoul of the law; nay, the Defendant has coldly and carefully calculated his actions, resulting in defrauding my client out of more than $9 Million.

This Closing Statement will debunk the Defense's arguments and explain why the full Prayer for Relief must be upheld.

On The Defense
Let us examine the Defense's arguments, which basically boils down to these false claims:
1. The Defendant only engaged in legitimate trading activities.
2. The contract with Vanguard specifies that only trading outside of market hours is an exploit.
3. The Defendant did not intend to defraud, only to maximize profits.
4. The Terms are ambiguous by having two forms of agreement: signature or logging into their website.
5. Vanguard failed to pursue alternative remedies like reversing the transactions.
6. The Defendant did not make any false statements, if he did they weren't about important facts, and if they were the Plaintiff didn't justifiably rely on them, and if they did it didn't cause damage.

Now, I will show how each of these claims are false:
1. As shown in Exhibit P-019, explained in Fact 36, and then affirmed by the Defense, the Defendant sold more shares than he owned of several stocks several times. This is not a legitimate trading activity, as you cannot sell what you do not own. The Plaintiff has shown, certainly within a balance of probabilities, that these trades were not legitimate. This shows that Defense 1 is false.

2. The contract does specify that trading outside of market hours would be an exploit, however the contract does not state that this is the only way to abuse an exploit. Thus, Defense 2 is false, and nearly Perjury, but lacks the requisite proof of intent for an Objection.

3. Intending to maximize profits and then misrepresenting facts in order to do so qualifies as intent to defraud. Furthermore, the law only says the misrepresentation must be intentional or reckless, not strictly an intent to defraud. Thus, Defense 3 is false.

4. The Terms offer two ways to agree to the Terms: signing them or logging in. Furthermore, it could be seen that logging in is a form of signature, as you must type your username to do so. It is impossible to sign contracts in Redmont (with the exception of signing items in-game, which I believe is a new feature), and contracts are often agreed to by simply stating that they are agreed to. Likewise, agreeing by logging in when it is clear that this is the process counts as signing the contract. Thus, Defense 4 is false.

5. Vanguard didn't fail to pursue alternative remedies. They were unable to do so, as the Defendant quickly transferred the money to other individuals and institutions before Vanguard caught on to the Defendant's fraud. Thus, Defense 5 is misleading at best, but largely false.

6. I don't believe I need to re-iterate the entire case, but it has been shown in complete clarity how the Defendant intentionally or recklessly misrepresented the amount of shares he owned when selling them to Vanguard, and how Vanguard reasonably relied on these misrepresentations and it caused over $9 Million in damages -- it's all there in the Case Filing and Opening Statements. Thus, Defense 6 is false.

On The Prayer for Relief
The Defendant - by cheating, hacking, or otherwise abusing an exploit - violated the contract formed by Naezaratheus' agreement to the terms and usage of Vanguard Market Access. As such, Breach of Contract occurred. Furthermore, the Defendant - by intentionally or recklessly misrepresenting the amount of shares he owned when selling them to Vanguard, and then Vanguard reasonably relying on these misrepresentations and it causing $9,303,691 in damages - committed Fraud against my client.

For the above reasons, the Compensatory damages of $9,303,691 should be fully awarded.

This was not an isolated incident. As shown in Fact 36 and Exhibit P-019, and affirmed by the Defense, this lawsuit shows at least eighteen individual times the Defendant defrauded my client. This Fraud is also so immense, much higher than any other we've ever seen before, as far as I am aware. The Defendant has transferred nearly all of the money away to make it difficult or impossible for Vanguard to recover these funds outside of the courtroom. Finally, the Defendant has shown no remorse.

For the above reasons, the Punitive damages of $5,000,000 should be fully awarded.

Lastly, Legal Fees are given to the counsel of the winning party in all cases, per the Legal Damages Act, and thus Legal Fees of $2,790,000 should be fully awarded to JusticeCompass.

Motion

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

The Defendant has been deported again, and lacks the right to contest this suit in court. We ask for Default Judgement.

Spoiler: Proof

Response

TO OBJECTION

The Plaintiff's objection should be rejected because it attempts to establish a dangerous precedent:

1. The Defendant is no longer deported and has been restored to full citizenship, with all associated rights and protections under the Constitution.

2. The Constitution in Part IV, Section 33 guarantees that "Every citizen is equal before and under the law and has the right to equal protection and equal benefit of the law" and that citizens have "the right to a speedy and fair trial" and "the assistance of legally qualified counsel for their defence".

3. UnityMaster v. lcn [2025] SCR 2 specifically referred to plaintiffs who were deported "at the time of filing this case" - not defendants who regained citizenship during an ongoing proceeding.

4. Adopting the Plaintiff's position would mean that any temporary deportation would permanently strip a citizen of their constitutional rights to defence and representation, even after their citizenship has been fully restored. This interpretation directly contradicts the equal protection clause of the Constitution.

5. Furthermore, the Plaintiff's objection appears to be a tactical attempt to circumvent standard judicial procedures and deny the Defendant their fundamental right to be heard. Such manoeuvring represents a concerning slight against our justice system, which is built upon principles of fairness and equal access. By attempting to exploit a temporary period of deportation to secure a procedural victory, rather than prevailing on the merits of their case, the Plaintiff undermines the very foundations of the judicial process.

6. This Court should be deeply concerned by attempts to use technicalities to deny restored citizens their constitutional rights. Allowing such practices would create a two-tiered system of justice where previously deported citizens would forever face diminished rights, despite their full restoration to citizenship status.

The Defendant has been lawfully restored to citizenship status and is entitled to all constitutional protections, including the right to defend against this lawsuit.

Closing Statement

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 plaintiff has attempted to characterise the Defendants' trading activities as "a massive-scale fraud" and "cold and calculated" criminal behaviour. However, when we examine the evidence through the lens of our legal system rather than moral outrage, it becomes clear that the Plaintiff has failed to meet their burden of proof on both claims.

The Defendant acknowledges utilising unorthodox trading strategies to maximise profits. However, these strategies were executed through Vanguard's own system, using functionality they designed, built, and made available to all users. This case is not about fraudulent behaviour—it is about a financial institution attempting to shift responsibility for their own system design flaws onto a user who simply utilised the system as it functioned.

As I address each of the claims against the Defendant, I ask the Court to focus on the applicable legal standards and not be swayed by the Plaintiff's inflammatory language about "heinous crimes" or appeals to moral judgment. Our legal system requires proof of specific elements for both breach of contract and fraud claims, and as I will demonstrate, the plaintiff has failed to establish these elements.

Your Honour, the plaintiff's breach of contract claim fails at its most fundamental level - there was no valid contract formation between the Defendant and Vanguard regarding the Terms of Service they now seek to enforce. This is not merely a technical objection but goes to the heart of contract law in the Commonwealth of Redmont.

The Contracts Act, Section 4(2), establishes a clear legal test for valid contract formation, requiring five distinct elements:

(a) Offer: "An offer is a clear and unequivocal communication expressing a party's willingness to enter into a contract, either explicitly stated or reasonably inferred from the circumstances."

(b) Acceptance: "Acceptance is the positive and unambiguous response to an offer communicated to the offeror, mirroring the terms of the offer and conveyed through various means."

(c) Consideration: "Consideration, an essential element, involves the exchange of something of value between parties, with sufficiency though not necessarily adequacy."

(d) Intent: "Parties must demonstrate a clear intention to create legal obligations for the contract to be valid."

(e) Capacity: "Parties entering into a contract must possess the legal capacity to do so."

When we apply this test to the facts of this case, it becomes evident that at least three of these elements—offer, acceptance, and intent—were not satisfied.

Vanguard's own Terms, submitted as evidence, explicitly states:

"By signing the agreement, you're agreeing to the Agreements and acknowledging receipt of the disclosures contained in the Booklet..."

It further reinforces this requirement:

"For any like-titled accounts you open in the future, you'll need to sign an Additional Account Acknowledgement where you will confirm that the most current version of the Booklet applies..."

Yet their login page contradictorily states:

"By logging in, you agree to our Terms of Service."

In Bombaz2005 v. The Commonwealth of Redmont [2024] FCR 78, the Court held that "an auction is an offer - a proposal for contract formation - and a new offer constitutes a new contract proposal." The Court further explained that "assumptions cannot be made in contract formation."

Applying this precedent to the current case, we have two fundamentally contradictory offers: one requiring signature and another claiming login constitutes acceptance. This contradiction renders the "offer" unclear and equivocal, failing the first prong of the contract formation test.

In A__C et al v. Cheapscape [2021] FCR 121, this Court established that "contracts of sale were made in reliance of a misrepresentation" when there was "a reasonable expectation upon the seller to disclose financial happenings to a potential investor." Similarly, Vanguard had a duty to clearly communicate its terms of acceptance, not to provide contradictory methods.

The second element, acceptance, is equally unsatisfied. The Contracts Act requires that acceptance be "positive and unambiguous." The Defendant never signed any agreement, which Vanguard's own Terms establish as the required method of acceptance.

In BubblyBo v. MysticPhunky [2023] FCR 111, this Court invalidated a contract that was edited after signing, noting that "the contract being edited we have run into the issue of neither side being able to prove the true timing of the edit."

Here, we face a more fundamental issue: Vanguard is attempting to enforce terms that were supposedly accepted through a method (logging in) that contradicts their own explicit requirements (signature). This creates an ambiguity in acceptance that renders any purported contract void.

In Beray20 v. Rylint [2021] FCR 118, this Court outlined the application of the legal test for contract formation, noting that acceptance requires the offeror to agree to the terms proposed. When there are multiple, contradictory methods of acceptance, there can be no clear meeting of the minds, and thus no valid acceptance.

Even if the Court were to accept login as a valid method of acceptance (contrary to Vanguard's own requirements), another fatal flaw exists: the Terms of Service were not reasonably accessible at the point of purported acceptance.

In Ansgard_Ist v. MelisaMinecrft74 [2022] FCR 11, this Court upheld a contract formed through an auction because "the rules have to been accessible at the time, which they were, so everyone who enters can find them easily." The Court specifically noted that the accessibility of terms is essential to contract formation.

In contrast, Vanguard's Terms of Service were not readily accessible from their website. Users were told they were agreeing to terms they could not review at the point of acceptance. As shown in Privacy Matters (Class Action Group) v. Vanguard Securities LLC [2025] FCR 36, Exhibit P-001, the text: "By logging in, you agree to our Terms of Service and Privacy Policy," provides no link or method to view said Terms. Furthermore, nowhere on the website links to, or mentions Vanguard's Terms of Sevice. This fact undermines the "positive and unambiguous" acceptance requirement of Section 4(b) of the Contracts Act, and in effect means the Defendant, and any VMA user for that matter, is supposedly agreeing to terms they can't review.

The third failed element is intent. Section 4(d) of the Contracts Act requires parties to "demonstrate a clear intention to create legal obligations." When a user cannot access or review the terms they are purportedly accepting, they cannot form the requisite intent to be bound by those specific terms.

In Aezal v. Morgan Sheraton & Co. [2023] FCR 43, the Court held that when "terms are ambiguous," the contract itself becomes "null and void." The Court further declared that when "terms set in this deal are ambiguous...the offer made was null in the first place."

Here, the ambiguity exists not only in the terms themselves but in the very method of accepting those terms. Such fundamental ambiguity precludes the formation of the clear intent required for a valid contract.

Let me walk through the logical steps that demonstrate why no contract was formed:

1. Vanguard's Terms explicitly requires signature for acceptance
2. No signature was ever provided by the Defendant
3. Vanguard now claims login constitutes acceptance
4. These methods of acceptance directly contradict each other
5. Contradictory methods of acceptance fail the "clear and unequivocal" requirement for offers
6. Contradictory methods of acceptance also fail the "positive and unambiguous" requirement for acceptance
7. Terms were not accessible at the point of login, further undermining any claim of "positive and unambiguous" acceptance
8. Without clear offer and acceptance, there can be no "clear intention to create legal obligations"
9. Without satisfying these three essential elements, no valid contract was formed
10. Without a valid contract, there can be no breach of contract

Your Honor, if Vanguard is permitted to enforce contractual terms while simultaneously ignoring their own explicit requirements for contract formation, it would create a dangerous precedent in Redmont contract law.

Companies could establish explicit requirements for contract formation in their formal documents, but then enforce different, contradictory requirements when convenient. This would undermine the clear framework established by the Contracts Act and inject uncertainty into all commercial transactions in the Commonwealth.

The plaintiff bears the burden of proving a valid contract was formed. They have failed to do so on multiple grounds. Their own documentation establishes signature as the required method of acceptance, yet no signature was ever provided, solicited, or received.

The contractual foundation of the plaintiff's claim collapses under the weight of these fundamental flaws. Without a valid contract, there can be no breach of contract, and this claim must be dismissed as a matter of law.

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Your Honour, even if the Court were to find that a valid contract existed between the Defenant and Vanguard, the Plaintiff has failed to demonstrate that the Defendants's actions breached the specific terms of that contract.

The "Fair Trading and Exploit Prevention" clause in Vanguard's Terms of Service states:

"Customers are strictly prohibited from engaging in trades designed to exploit system mechanics, including placing trades outside of real-life market hours to gain an unfair advantage."

The plaintiff claims this clause was violated, but a careful reading reveals otherwise. The clause provides a specific example of prohibited conduct: "placing trades outside of real-life market hours." This example serves to clarify the type of activity that constitutes an "exploit" under the terms.

All of the Defendant's trades occurred within normal market hours. The plaintiff does not dispute this fact. Instead, they argue that the term "including" means the list is not exhaustive. While this is true, the example nonetheless defines the scope and nature of what constitutes an "exploit" under the contract.

The plaintiff drafted these terms. It is a fundamental principle of contract interpretation that ambiguities are construed against the drafter. If Vanguard intended to prohibit selling more shares than a user owned, they could have explicitly stated this in their terms. They did not.

Furthermore, the same section outlines Vanguard's remedy for allegedly exploitative trades:

"If any trade is determined to be exploitative, Vanguard Market Access reserves the right to reverse the trade and undo all associated gains or losses."

The plaintiff had a contractual remedy available to them if they believed the Defendants's trades were exploitative. They chose not to exercise this right at the time the trades occurred. Instead, they waited until after the funds had been transferred to other institutions before taking action.

The plaintiff argues they "didn't fail to pursue alternative remedies" but rather "were unable to do so, as the Defendant quickly transferred the money to other individuals and institutions before Vanguard caught on." This argument fails for two reasons:

1. It admits that Vanguard's own system failed to detect the allegedly improper trades in real-time, which is a system design issue, not the Defendants's responsibility.
2. It contradicts the chronology established by the plaintiff's own evidence. According to Facts 5-34 in the complaint, the Defendant's trading activities occurred over a period from March 17 to March 31. This was not a one-time event but a series of transactions over two weeks, during which Vanguard had ample opportunity to exercise their contractual right to reverse trades.

In summary, even if a valid contract existed, the Defendant's activities did not violate the specifically prohibited conduct in the Terms, and Vanguard failed to exercise their contractual remedy when they had the opportunity to do so.

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Your Honour, the plaintiff's fraud claim is the most serious allegation against the Defendant and requires particularly rigorous scrutiny. I draw the Court's attention to an essential legal consideration: under Section 6(1)(a) of the Commercial Standards Act, "A crime classified under any sub-category of Fraud shall not be charged as Fraud for the same offence." This provision underscores the legislature's intent that fraud charges must meet specific statutory requirements, not serve as a catch-all for any commercially disadvantageous behaviour.

While this is a civil proceeding, I would remind the Court that fraud is defined as a criminal offence in Section 6 of the Commercial Standards Act. Per the Judicial Standards Act Section 13, criminal matters require "Proof Beyond a Reasonable Doubt." Even under the civil "Balance of Probabilities" standard, the plaintiff must still establish all elements of fraud, and they have failed to do so.

The statute defines fraud as: "An intentional or reckless misrepresentation or omission of an important fact, especially a material one, to a victim who justifiably relies on that misrepresentation; and the victim party or entity suffered actual, quantifiable injury or damages as a result of the misrepresentation or omission."

This definition requires four distinct elements, and the plaintiff must prove all four to establish fraud:

1. An intentional or reckless misrepresentation
The plaintiff claims the Defendant "intentionally or recklessly misrepresented the amount of shares he owned when selling them to Vanguard." This fundamentally mischaracterises how electronic trading platforms function.

In Creepy505 v. KukkiNekko [2023] DCR 12, the Court established a critical precedent regarding the intentionality element of fraud, stating: "Intentionality or recklessness is very hard to establish when the Plaintiff has not provided any evidence that the Defendant knew or was made aware of the issue at any time." The Court further explained that while fraud might have occurred, "for a Court setting, there is not enough proof provided by the Plaintiff to find that the Defendant committed an act of fraud."

This case presents an identical situation. The Defendant made no affirmative false statements. He simply used the interface and functions provided to all users. Each transaction was processed and approved by Vanguard's own system - a system they designed, maintained, and controlled. The plaintiff has provided no evidence that the defendant knew he was engaging in activities that should have been prevented by Vanguard's system.

In Krisztie v. zko0 [2025] FCR 13, the Court found fraudulent intent largely because the defendant openly "taunted Krisztie for being easy to scam" and "bragged in Discord about their actions." The Court noted these actions "demonstrate full knowledge of their actions being considered a scam and clearly show a deliberate intent to deceive and harm." No such evidence of malicious intent exists in this case.

2. Of an important fact
The plaintiff must establish that the alleged misrepresentation involved an important or material fact. In Aezal v. Morgan Sheraton & Co. [2023] FCR 43, the Court held that when a contract's "terms are ambiguous," the contract itself becomes "null and void." By extension, any alleged misrepresentation regarding ambiguous terms cannot constitute fraud.

Here, even if we were to accept that each trade carried an implicit representation about share ownership, this fact was neither material nor important in the legal sense because:

Vanguard's own database contained the definitive record of the defendant's holdings
Vanguard had perfect information about exactly how many shares the defendant owned
These facts were not hidden from Vanguard - they existed in Vanguard's own records
In lcn v. Blazora Corporation [2025] FCR 18, the Court found fraud occurred where a bond's terms were misrepresented, and these terms were not available to the plaintiff. The critical distinction here is that Vanguard had complete access to all relevant information about the defendant's share ownership at all times.

3. Justifiable reliance by the victim
This element is perhaps the most glaringly absent from the plaintiff's case. In fraud law, a party cannot justifiably rely on representations about facts they themselves are in a superior position to verify.

In Lemonade Corp and VerniciaS v. HoardCo [2022] FCR 37, the Court established that fraud requires not just misrepresentation but proof that satisfies all elements of the legal definition. The Court noted: "Because there was a lack of any proof that the defendant committed fraud, nor do any of the definitions match up with what the Defendant did, this court doesn't believe that the Defendant committed fraud."

Vanguard cannot claim to have justifiably relied on any implied representation about share ownership when:

1. They maintained the authoritative database of all user holdings
2. They designed and controlled the trading platform
3. They had both the means and responsibility to verify share ownership before executing trades
4. Standard industry practice includes automated controls to prevent selling more shares than owned
5. Their system approved each transaction despite having all the necessary information to reject it

This is analogous to a bank claiming fraud when its ATM dispenses too much money despite the bank controlling the ATM's programming and having real-time access to account balances. The reliance element simply cannot be satisfied when the "victim" has superior knowledge and control over the relevant information.

4. Actual damages resulting from that misrepresentation
The final element requires that damages must result directly from the alleged misrepresentation. In RylandW v. The Commonwealth of Redmont [2025] SCR 4, the Court awarded damages only after establishing a clear causal link between the defendant's actions and the plaintiff's injury.

While Vanguard may have suffered financial consequences, these resulted from their own system design failures rather than from any misrepresentation by the Defendant. Their system should have had safeguards to prevent transactions that exceeded a user's holdings - a standard feature in properly designed trading platforms.

The plaintiff's own evidence undermines their case: they allowed these transactions to continue for two weeks without intervention. If their system permitted these trades without verification or safeguards, the resulting damages stem from their own design failures, not from any alleged misrepresentation.

Furthermore, the plaintiff may attempt to characterise the Defendant's trading as "Securities Fraud" under Section 8 of the Commercial Standards Act. However, a careful examination reveals that none of the defined types of securities fraud apply here:

1. This was not insider trading - the Defendant possessed no non-public information
2. This was not market manipulation - the Defendant had no responsibility for any company or asset values
3. This was not third-party misrepresentation - the Defendant did not aid or abet any party in market manipulation
4. This was not embezzlement - no assets were entrusted to the Defendant for conversion

In summary, the plaintiff bears the burden of proving all elements of fraud, and they have failed to establish even one of these elements, let alone all four. As the Court held in Creepy505 v. KukkiNekko, "As the burden of proof lies on the Plaintiff, it is the opinion of the Court that the Plaintiff has not satisfactorily provided proof that the Defendant committed an act of fraud."

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Your Honour, throughout these proceedings, the plaintiff has presented arguments that contain numerous internal inconsistencies and contradictions that further undermine their case.

First, the plaintiff's characterisation of the contract formation process is contradictory. They claim that "The Terms offer two ways to agree to the Terms: signing them or logging in." Yet their own Terms unambiguously require a 'signature'. They cannot now claim that their own explicit requirements were optional or that an entirely different method of acceptance was equally valid. This post-hoc rationalisation does not comport with the basic principles of contract law.

The plaintiff further argues that "logging in is a form of signature, as you must type your username to do so." This is a strained interpretation that has no basis in Redmont law. The Contracts Act specifically requires "positive and unambiguous" acceptance. If merely using a service constituted legal acceptance of terms, the requirement for clear acceptance would be rendered meaningless.

Second, the plaintiff's characterisation of the prohibited activities is inconsistent with their own Terms of Service. The "Fair Trading and Exploit Prevention" clause in their Terms explicitly states: "Customers are strictly prohibited from engaging in trades designed to exploit system mechanics, including placing trades outside of real-life market hours to gain an unfair advantage."

While the term "including" can indicate a non-exhaustive list, the specific example provided serves to illustrate the type of activity Vanguard considered an "exploit." This specific example—trading outside market hours—bears no resemblance to the Defendant's activities, which all occurred within normal market hours. If Vanguard intended to prohibit selling more shares than owned, they had every opportunity to include this as a specific example in their terms. They did not.

Third, the plaintiff attempts to excuse their failure to exercise their contractual remedy by claiming they "were unable to do so, as the Defendant quickly transferred the money to other individuals and institutions before Vanguard caught on." This contradicts their own evidence. According to their own complaint:

On March 19, the Defendant transferred $21,000 from VMA (Fact 5)
On March 19, the Defendant transferred $335,000 from VMA (Fact 7)
On March 21, the Defendant transferred $3.261 million from VMA (Fact 10)
And this pattern continued through March 31 (Facts 14-34)
These transfers occurred over a period of two weeks, not in a single rapid transaction. The plaintiff failed to detect the alleged problem over multiple days and multiple transactions, which speaks to a fundamental system design failure, not fraud.

Fourth, the plaintiff's fraud claim relies on a circular argument. They claim the Defendant misrepresented the number of shares he owned, but they were the sole authority on share ownership through their database. They claim they relied on this misrepresentation, but they were in the best position to verify the actual share count. They claim damages resulted from this misrepresentation, but any damages resulted from their own failure to implement basic system controls.

Finally, the plaintiff repeatedly appeals to moral outrage rather than legal standards, describing the Defendant's actions as "heinous," "cold and calculated," and "massive-scale fraud." These inflammatory characterisations serve to distract from the legal deficiencies in their case. The question before this Court is not whether the Defendant's actions were morally praiseworthy, but whether they constituted a breach of contract or fraud under the law of Redmont. The plaintiff has failed to demonstrate either.

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Your Honour, the evidence before this Court leads to only one conclusion: the plaintiff has failed to establish both breach of contract and fraud claims as a matter of law and fact. This is not a marginal case. The plaintiff's claims collapse under the weight of legal scrutiny, contractual interpretation, and Vanguard's own documented practices.

The factual record is unambiguous. Vanguard's own Terms, submitted as evidence, explicitly state:

"By signing the agreement, you're agreeing to the Agreements and acknowledging receipt of the disclosures contained in the Booklet..."

It further reinforces this requirement:

"For any like-titled accounts you open in the future, you'll need to sign an Additional Account Acknowledgement where you will confirm that the most current version of the Booklet applies..."

These are not casual suggestions. They are explicit contractual requirements drafted by Vanguard's own legal team. The Defendant did not sign any agreement. No signature was solicited. No signature was received. No electronic signature alternative was proposed.
In Aezal v. Morgan Sheraton & Co. [2023] FCR 43, this Court established that when "terms are ambiguous," the contract itself becomes "null and void." Vanguard created a direct contradiction in their methods of acceptance that renders any contract unenforceable as a matter of Redmont law.
What the plaintiff asks this Court to do is extraordinary—to enforce contractual terms while simultaneously ignoring their own explicit requirements for contract formation. No precedent in Redmont law supports such a position. The breach of contract claim fails because no valid contract existed.

The plaintiff's fraud claim is even more seriously deficient. Section 6 of the Commercial Standards Act requires four distinct elements:

1. An intentional or reckless misrepresentation
2. Of an important fact
3. Justifiable reliance by the victim
4. Actual damages resulting from that misrepresentation

The evidentiary record conclusively demonstrates the absence of each element.

First, the Defendant made no affirmative misrepresentations. He used Vanguard's system as designed and deployed. In Creepy505 v. KukkiNekko [2023] DCR 12, this Court established that intentionality "is very hard to establish when the Plaintiff has not provided any evidence that the Defendant knew or was made aware of the issue at any time." Vanguard has provided no evidence that the Defendant knew he was exploiting a system flaw rather than using legitimate functionality.

Second, Vanguard cannot claim misrepresentation about facts contained in their own authoritative database. In lcn v. Blazora Corporation [2025] FCR 18, this Court found fraud specifically because information was withheld. Here, Vanguard had complete access to all trading data in real-time.
Third, justifiable reliance is categorically impossible when:

1. Vanguard maintained the authoritative database of all user holdings
2. Vanguard designed and controlled the trading platform
3. Vanguard programmed the system that approved every transaction
4. Vanguard had both the means and responsibility to verify share ownership before execution
5. Vanguard allowed these transactions to continue for two full weeks

The law does not permit a party to claim fraud when they have superior knowledge of and control over the very facts they claim were misrepresented. This is not a close legal question—it is a fundamental principle of fraud law.

Fourth, any damages stemmed from Vanguard's own system design failures. In RylandW v. The Commonwealth of Redmont [2025] SCR 4, the Court awarded damages only after establishing a clear causal link between the defendant's actions and the plaintiff's injury. Here, the causal link is to Vanguard's own system design.
The Plaintiff's Evidentiary and Logical Contradictions
The plaintiff's case is further weakened by its internal contradictions:

They claim the Defendant "quickly transferred money" to evade detection, yet their own evidence (Facts 5-34) shows transactions occurring over a two-week period—ample time for their system to detect and prevent further trades.
They argue logging in constitutes agreement while their own Terms explicitly require a signature. They cannot have it both ways.
They specifically designed their "Fair Trading and Exploit Prevention" clause to prohibit "placing trades outside of real-life market hours," yet now claim it should be read far more broadly.
They had a contractual remedy available—"if any trade is determined to be exploitative, Vanguard Market Access reserves the right to reverse the trade"—yet failed to exercise it over multiple days and transactions.

Precedent and Justice - The Lemonade Corp Standard
In Lemonade Corp and VerniciaS v. HoardCo [2022] FCR 37, this Court established a critical precedent: "Because there was a lack of any proof that the defendant committed fraud nor do any of the definitions match up with what the Defendant did, this court doesn't believe that the Defendant committed fraud."
The same standard must be applied here. None of the fraud definitions in the Commercial Standards Act match what the Defendant did. This is not a technicality—it is the rule of law. We cannot create new definitions of fraud to accommodate Vanguard's system design failures.

Conclusion
Your Honour, this is not a case of competing interpretations or marginal legal questions. The evidence is clear:

1. No valid contract was formed due to Vanguard's own explicit signature requirements
2. None of the four required elements of fraud have been established
3. Vanguard's own system approved every transaction over a two-week period

The plaintiff bears the burden of proof on all claims. They have failed to meet this burden by any legal standard. For these reasons, I respectfully urge this Court to dismiss both claims and deny the plaintiff's prayer for relief in its entirety.

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Your Honour, while the plaintiff's claims fail on their legal merits, I must address the extraordinary nature of the requested damages and their severe constitutional and economic implications. This is not merely a secondary consideration—it strikes at the heart of our constitutional framework, the separation of powers, and the economic stability of the Commonwealth.

The Unprecedented Scale of Requested Damages
The plaintiff seeks $14,303,691 in total damages—a staggering sum that represents approximately 38% of Redmont's entire GDP of $37.6 million, according to the official DemocracyCraft Economic Dashboard. This is more than 121 times the Defendant's total in-game assets of $117,859.06—a disparity so extreme it can only be described as punitive rather than compensatory.

Such damages would not merely impoverish the Defendant—they would create an impossible financial burden that could never be satisfied. This would effectively create a government-sanctioned negative balance of approximately $14.19 million. The implications of this extend far beyond this individual case.

Unauthorized Currency Creation Violates Federal Reserve Act
Section 6 of the Federal Reserve Act explicitly states:

"The Board of Governors must vote on a motion to mint new currency into the economy by a supermajority."

The Act further specifies in Section 6(1)(a)(i):

"The Federal Reserve solely has the power to determine when the government is to mint funds, the Commerce Secretary must action the minting of funds upon request, while establishing that the motion has gained a supermajority."

When a court imposes a financial penalty that exceeds a defendant's total assets, creating a negative balance, it effectively generates new currency that did not previously exist in the economy. This currency creation occurs without the oversight, approval, or economic controls established by the Federal Reserve Act.

Creating nearly $14.19 million in new currency through a negative balance would constitute a direct violation of the Federal Reserve's exclusive authority to mint currency. Neither the courts nor the plaintiff have the constitutional or statutory authority to create new currency in this manner.

Severe Inflationary Impact
The Federal Reserve Act establishes in Section 3(1) that a primary responsibility of the Federal Reserve is "maintaining a healthy job market and keeping prices stable." Creating new currency equivalent to 38% of the GDP would directly undermine price stability.

The monthly appropriations for all government departments combined—including State, Justice, Commerce, and others—total approximately $4.2 million according to the April 2025 Appropriations Act. The plaintiff is requesting damages equivalent to nearly four times the entire monthly government budget of Redmont.

The economic data displayed on the DemocracyCraft Economic Dashboard already shows concerning inflation metrics of -11.31%. Adding 38% of the GDP in artificial currency would exacerbate these issues dramatically, potentially leading to:

1. Hyperinflation affecting all citizens
2. Devaluation of currency held by all citizens
3. Market distortions across all sectors
4. Collapse of economic planning and stability
5. Undermining of the purchasing power of government wages established in the Economic Standards Act

Imposing these damages would violate numerous constitutional rights guaranteed to all citizens under Part IV of the Constitution of Redmont:

1. Equal Protection Under the Law - Section 33(13)
"Every citizen is equal before and under the law and has the right to equal protection and equal benefit of the law without unfair discrimination."

Creating an insurmountable negative balance would establish a permanent financial underclass, denying the Defendants equal protection and the benefit of the law. A citizen with a -$14.19 million balance could never hope to recover financially, creating a de facto separate legal status. This violates the core principle of equality before the law.

2. Liberty and Security of Person - Section 33(14)
"Every citizen has the right to life, liberty, and security of the person and the right not to be deprived thereof except in accordance with the principles of fundamental justice."

A citizen with a -$14.19 million balance could not meaningfully participate in economic life—a severe restriction on liberty that fails to accord with fundamental justice. Economic participation is a fundamental aspect of liberty in a market economy, and imposing an inescapable debt effectively deprives a citizen of this liberty without proper justification.

3. Inalienable Rights - Section 33(7)
"Rights cannot be withheld on the basis of criminality, rights are inalienable."

Even if the Court were to find liability (which it should not), the resulting punishment cannot deprive the Defendant of inalienable economic rights. The Constitution explicitly recognises that rights remain attached to individuals regardless of alleged wrongdoing. Creating an inescapable financial burden effectively withholds economic rights in perpetuity.

4. Right to Fair Trial - Section 33(9)
"Any citizen, criminal or otherwise will have the right to a speedy and fair trial."

A fair trial necessarily includes proportional remedies. Imposing damages that are 121 times a defendant's total assets is disproportional by definition. Proportionality is a foundational principle of justice, and without it, the guarantee of a fair trial becomes meaningless.

5. Freedom of Assembly and Association - Sections 33(11) and 33(12)
The Constitution guarantees "Freedom of Peaceful Assembly" and "Freedom of Association." These rights become meaningless if a citizen is permanently barred from economic participation, as economic capacity is often a prerequisite to meaningful social engagement in a market society.

Violating the Separation of Powers
The appropriations process established by the Appropriations Process Act of 2024 vests the power of the purse exclusively with Congress. Section 5 of that Act clearly outlines the budget request process, and Section 6 establishes that "A Representative may propose an Appropriations Bill to Congress for approval by a simple majority in both chambers."

By imposing damages that would create new currency, the Court would effectively be appropriating funds—a power constitutionally reserved for the legislative branch. This would constitute a serious breach of the separation of powers doctrine that underpins our constitutional system.

Existing Legal Precedents Against Excessive Judgments
The Court has consistently recognised limitations on disproportionate remedies:

In Krisztie v. zko0 [2025] FCR 13, the Court reduced a request for $100,000 in punitive damages to $10,000, noting that the larger figure "seems arbitrary" and finding "no legal reasoning or precedent to award such an extravagant amount."
In RylandW v. The Commonwealth of Redmont [2025] SCR 4, the Court granted only $35,000 in punitive damages for a significant constitutional violation.
In lcn v. Blazora Corporation [2025] FCR 18, while the Court awarded significant damages against a non-responsive defendant, the total award of $203,263.03 was proportional to the nature of the case and did not approach even 1% of GDP.
The $14,303,691 requested by the plaintiff is orders of magnitude larger than any previous award in Redmont's legal history and lacks any proportionality to the alleged harm.

Alternatives That Respect Constitutional and Economic Framework
If the Court does find any liability (which we firmly maintain it should not), there are constitutionally sound alternatives:

1. Limit any damages to my client's actual assets ($117,859.06)
2. Structure any remedy as restitution of specific identifiable funds
3. Consider non-monetary remedies that would not create artificial currency
4. Apply a remedy that maintains the defendant's ability to participate in economic life
5. Issue a declaratory judgment without monetary penalty

Universal Basic Income Protection
The Universal Basic Income Act establishes that "For every 15 minutes of playtime, player's holding 'Profession' and 'Regular' jobs shall be paid $20 from the DCGovernment balance." This legislation was enacted to "protect people from financial hardship, and [provide] Basic Income [that] grants them the protection they need to ensure that they can afford to succeed."

Creating a permanent negative balance would effectively nullify the protections of this Act for my client, contradicting the legislative intent to provide a financial safety net for all citizens.

Conclusion
Your Honour, put simply.. If the plaintiff's requested damages are granted, it would:

1. Violate multiple explicit constitutional guarantees
2. Intrude upon the Federal Reserve's exclusive currency creation authority
3. Breach the separation of powers doctrine
4. Create severe inflationary consequences affecting all citizens
5. Establish a dangerous precedent of disproportionate remedies
6. Effectively create a permanent underclass of citizenship

Even if the Court were to find liability on either claim (which the evidence does not support), the plaintiff's prayer for relief must be denied as constitutionally impermissible, economically reckless, and fundamentally unjust.

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