Lawsuit: Dismissed Gnomewhisperer and GnomeCorp v Commonwealth of Redmont [2025] FCR 47

Case Filing

IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
CIVIL ACTION


GnomeWhisperer and GnomeCorp
Plaintiffs

v.

Commonwealth of Redmont
Defendant

COMPLAINT
The Plaintiff complains against the Defendant as follows:

WRITTEN STATEMENT FROM THE PLAINTIFFS

On the UTC morning of 16 May 2025, the Department of Commerce made a sudden, unexpected, and jolting announcement: it would be commandeering all financial institutions that offered deposit, withdrawal, and transfer services for a period of thirty-six hours. If these institutions did not stop providing clients with these services, except through in-game ATMs, the Department said that it would impose unspecified sanctions and fines against the financial institutions.

The Plaintiffs in this case are GnomeWhisperer and a company he owns, GnomeCorp. Gnomecorp sells expensive manufactured goods, including netherite armor. This is extremely capital-intensive, as GnomeWhisperer relies heavily on rapid access to capital in order to facilitate the large, expensive purchases required for running GnomeCorp. The government essentially froze his bank accounts during this pause, acutely threatening the ability for GnomeWhisperer to maintain GnomeCorp’s supply chain in an ordinary manner. This caused acute harm to both GnomeWhisperer and GnomeCorp, as the business could not use the financial sector to make online transfers of money in exchange for goods, and could not withdraw money from deposit accounts held in the financial sector in order to provide the cash required for engaging in chestshop transactions.

On what basis did the Department of Commerce base this decision? It didn’t quite say (at least, explicitly). The announcement cited no laws or constitutional clauses as authority to effectively seize control of a major portion of the financial sector by fiat. The only hint at the government’s justification originates from a separate post in the #legal channel of the DemocracyCraft discord, where the Attorney General made reference to Taxation Act 8.3.c. That subsection specifies that “n extraordinary situations, the Department of Commerce has the power to commandeer and take temporary control of a financial institution. This authority is reserved for exceptional circumstances, such as insolvency, near insolvency, financial crises, or situations where the institution's continued operation poses a systemic risk to the financial system or depositors” (emphasis added). But the language in the clause is quite clearly talking about the ability to commandeer a singular financial institution, not the entire financial sector in toto, and this doesn’t provide an authority to order what amounts to blanket freezing of interest-bearing deposit accounts across the whole sector under pain of sanctions or fines.

The Plaintiffs submit that the Department of Commerce has exceeded its authority under the Taxation Act, and in doing so have breached their duty of care towards GnomeWhisperer and GnomeCorp. The Plaintiffs submit that the temporary seizure of GnomeWhisperer’s accounts violate the Constitution of Redmont, as it is unreasonable to attempt to commandeer banks in this manner when the law does not grant the Department of Commerce the authority to do so. For these reasons, the Plaintiffs respectfully ask the court to permanently enjoin the Department of Commerce from enforcing this so-called “bank holiday”, and warn the government against ever attempting to swiftly conduct an illegal seizure of a sector fait accompli again.

Click to expand...

1. On the UTC Morning of 16 May 2025, the Department of Commerce issued an announcement regarding the creation of a so-called “bank holiday” (Evidence P-001).
2. The text of this announcement read:
   1. DOC MANDATED BANK HOLIDAY
      
      Due to classified developments, the DOC is mandating a bank holiday for all financial institutions effective immediately for the next 36 hours. All financial institutions may not allow transfers, deposits, or withdrawals for the entirety of the bank holiday. Failure to do so will result in sanctions and fines. In-game ATMs are exempted from this bank holiday and may continue operating. We will reveal more information as it comes out. At this time, we ask members of the public to be patient as we figure the situation out. Questions about the issue will not be entertained at this time.
      
      Signed
      Avaneesh2008
      Deputy Secretary of Commerce
      
      (Evidence P-001)
3. This announcement instructed financial institutions that they were not allowed to permit customer transfers, deposits, or withdrawals during the period of the bank holiday. An exception was made for in-game ATMs.
4. This announcement threatened unspecified “sanctions and fines” for institutions who allowed transfers, deposits, or withdrawals during the bank holiday.
5. This announcement did not cite any legal basis for the creation of a mandatory “bank holiday’ across the entire financial sector, nor any law specifying penalties that would result from non-compliance.
6. The so-called ‘bank holiday’ in effect temporarily rendered financial firm client assets unable to be accessed by clients pursuant to a government order.
7. By rendering financial firm client assets unable to be accessed by clients, the government temporarily seized these same assets.
8. Shortly thereafter, the Attorney General made a post in the #legal channel on discord. (Evidence P-002)
9. The text of this post stated:
   1. Hello all! Your friendly neighbourhood Attorney General here for a fun fact! The Taxation Act gives the Department of Commerce a non-exhaustive list of suuuuper fun powers they can use to regulate the economy. One relevant subsection you may be interested in is 8.3.c, which I will quote here:
      
      (c) Commandeer: In extraordinary situations, the Department of Commerce has the power to commandeer and take temporary control of a financial institution. This authority is reserved for exceptional circumstances, such as insolvency, near insolvency, financial crises, or situations where the institution's continued operation poses a systemic risk to the financial system or depositors.
      
      This has been "Fun facts with the Attorney General" time! Thanks for listening. Hope to see you tomorrow with a new fun fact!
      (Evidence P-002)
10. On Dec 30, 2023, xEndeavour posted a consolidated Taxation Act on the Forums, which included the same language regarding commandeering as is the current law (Evidence P-003).
11. Plaintiff Gnomewhisperer is a citizen of Redmont.
12. Plaintiff Gnomewhisperer is the sole equity owner of co-Plaintiff GnomeCorp (see: Exhibit P-008).
13. Gnomecorp sells expensive manufactured goods, including netherite armor. Producing these goods requires access to large amounts of capital, which the banking sector helps to facilitate.
14. Gnomewhisperer and Gnomecorp each held accounts at financial institution Volt during the so-called ‘bank holiday’ (Evidence P-004).
15. During the so-called ‘bank holiday’, Volt was prohibited from allowing Gnomewhisperer and Gnomecorp to withdraw or deposit funds in their corresponding Volt bank accounts.
16. Gnomewhisperer publicly objected to the government’s announcement that barred withdrawal and deposit to bank accounts (Evidence P-005).
17. Gnomewhisperer’s council publicly objected to the Commonwealth’s attempt to commandeer large portions of the financial sector under the Taxation Act as overbroad (Evidence P-006).
18. After these objections had been made known to the Department of Justice, and after a motion for emergency injunction in this case had been filed, the Department of Commerce issued another announcement regarding the so-called “bank holiday” (Evidence P-007).
19. The text of the announcement read as follows:
    1. BANK HOLIDAY LIFTING & VANGUARD SEIZURE
       
       Due to unexpected speed by everyone involved, we are able to lift the bank holiday for all banks except Vanguard National Bank and Discover Bank who will remain frozen at this time.
       
       The seizure of Vanguard and Discover bank has begun due to grave liquidity concerns and misrepresentation of financial statements. Deposits are covered by the 50k insurance per person on top of what liquidation of assets cover. Depositors will have first preference when it comes to fulfilling obligations.
       
       If:
       you are owed debt by Vanguard & Co or any of its subsidiaries, please report this debt to the DOC by making a ticket with proof of the debt's existence.,
       you possess bank notes from Discover Bank ATMs, please also make a ticket and present proof of the deposit claim.,
       
       More information will be revealed as needed.
       
       Signed
       Avaneesh2008
       Deputy Secretary of Commerce
       
       (Evidence P-007)
20. This announcement substantially narrowed the scope of the “bank holiday”, limiting it to two banks and giving specific reasons for intervention.
21. The Department of Commerce, however, has not provided specific public justification for why it ordered Volt and other not-presently-seized banks to refuse client requests to withdraw funds in the first place.
22. In fact, it was unreasonable to order large swathes of the financial sector to engage in a so-called “bank holiday” under pain of fines and sanctions, when the Department of Commerce alleged only grave liquidity issues in Vanguard National Bank and Discover Bank, as well as misrepresentation of financial statements by the same.

1. Violations of Constitutional Rights:
   1. Unreasonable seizure:
      • The Constitution of Redmont §33(15) states that “Every citizen has the right to be secure against unreasonable search or seizure”. In prohibiting citizens from withdrawing their money, the government essentially conducted a temporary seizure of GnomeWhisperer’s funds held in Volt, as well as those of GnomeCorp.
        
        The Department of Commerce did not immediately provide a statutory basis for these seizures, and the closest that we get to a justification from a pertinent government official comes from the Attorney General’s statement referred to in Facts 8-9, which refers to Taxation Act §8.3.c.
        
        As noted in the Plaintiff’s statement, this does not grant the Department of Commerce carte blanche authority to seize or commandeer the entire financial sector. Rather, “n extraordinary situations, the Department of Commerce has the power to commandeer and take temporary control of a financial institution. This authority is reserved for exceptional circumstances, such as insolvency, near insolvency, financial crises, or situations where the institution's continued operation poses a systemic risk to the financial system or depositors” (emphasis added).
        
        The law quite clearly speaks to the commandeer a singular financial institution based on extraordinary situations, not haphazardly freezing the entire financial sector in toto (with exceptions for in-game ATMs). The law does not provide an authority to order what amounts to blanket freezing of interest-bearing deposit accounts across the whole sector under pain of sanctions or fines.
        
        Because this seizure was undertaken without legal authority, and posed an undue burden on clients of financial firms including the two Plaintiffs, it was unreasonable under the law.
        
        In smokeyybunnyyy v. Commonwealth of Redmont [2024] FCR 103, this Court found that “[e]very department within the executive branch has a duty of care to uphold its constitutional obligations”. The Plaintiffs respectfully submit that the Department of Commerce failed to uphold its constitutional obligations when it violated the Plaintiffs’ rights to be free from unreasonable seizure in its fait accompli freezing of withdrawals from the financial sector.
   2. Violations of liberty and security of the person:
      • The Constitution of Redmont §33(15) states that “Every citizen has the right to life, liberty, and security of the person and the right not to be deprived thereof except in accordance with the principles of fundamental justice.” In stating that failure to adhere to the Commonwealth’s unlawful freeze of financial services accounts would render liability to “sanctions and fines”, the Commonwealth did threaten the liberty and security of the Plaintiffs without due process of law. [/I]This jawboning is a violation of the Department of Commerce’s duty of care, as the Commonwealth and its executive branches have constitutional obligations to respect the fundamental rights and freedoms of its citizens.

• Because the Department of Commerce exceeded its legal authority under the Taxation Act fait accompli, the Plaintiffs ask the court to issue a Writ of Mandamus barring Defendant from commandeering or conducting seizures of financial institutions on a non-individual-entity basis.

• The Plaintiffs seek $1 in nominal damages to acknowledge the violation of their constitutional rights.

• In line with the Legal Damages Act, the Plaintiff seeks 30% of the award as legal fees, with a minimum of $6,000.

Evidence:

Spoiler: Exhibit P-001

Spoiler: Exhibit P-002

Spoiler: Exhibit P-003

Spoiler: Exhibit P-004

Spoiler: Exhibit P-005

Spoiler: Exhibit P-006

Spoiler: Exhibit P-007

Spoiler: Exhibit P-008

1. Gnomewhisperer
2. Avaneesh2008
3. xSyncx
4. Juniperfig
5. Freeze_Line
6. Dearev
7. Stoppers
8. xEndeavour

Writ of Summons

@juniperfig is required to appear before the Federal Court in the case of Gnomewhisperer and Gnomecorp v. Commonwealth of Redmont [2025] FCR 47.

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.

Answer to Complaint

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

GnomeWhisperer and GnomeCorp
Plaintiffs

v.

Commonwealth of Redmont
Defendant

I. ANSWER TO COMPLAINT

1. AFFIRM that on the UTC Morning of 16 May 2025, the Department of Commerce issued an announcement regarding the creation of a so-called “bank holiday” (Evidence P-001).
2. AFFIRM that the text of this announcement read:
   • DOC MANDATED BANK HOLIDAY
     Due to classified developments, the DOC is mandating a bank holiday for all financial institutions effective immediately for the next 36 hours. All financial institutions may not allow transfers, deposits, or withdrawals for the entirety of the bank holiday. Failure to do so will result in sanctions and fines. In-game ATMs are exempted from this bank holiday and may continue operating. We will reveal more information as it comes out. At this time, we ask members of the public to be patient as we figure the situation out. Questions about the issue will not be entertained at this time.
     
     Signed
     Avaneesh2008
     Deputy Secretary of Commerce
3. AFFIRM that this announcement instructed financial institutions that they were not allowed to permit customer transfers, deposits, or withdrawals during the period of the bank holiday. An exception was made for in-game ATMs.
4. AFFIRM that this announcement threatened unspecified “sanctions and fines” for institutions who allowed transfers, deposits, or withdrawals during the bank holiday.
5. AFFIRM that this announcement did not cite any legal basis for the creation of a mandatory “bank holiday" across the entire financial sector, nor any law specifying penalties that would result from non-compliance.
6. AFFIRM that the so-called ‘bank holiday’ in effect temporarily rendered financial firm client assets unable to be accessed by clients pursuant to a government order.
7. DENY that by rendering financial firm client assets unable to be accessed by clients, the government temporarily seized these same assets.
8. AFFIRM Shortly thereafter, the Attorney General made a post in the #legal channel on discord. (Evidence P-002)
9. AFFIRM that the text of this post stated:
   • Hello all! Your friendly neighbourhood Attorney General here for a fun fact! The Taxation Act gives the Department of Commerce a non-exhaustive list of suuuuper fun powers they can use to regulate the economy. One relevant subsection you may be interested in is 8.3.c, which I will quote here:
     (c) Commandeer: In extraordinary situations, the Department of Commerce has the power to commandeer and take temporary control of a financial institution. This authority is reserved for exceptional circumstances, such as insolvency, near insolvency, financial crises, or situations where the institution's continued operation poses a systemic risk to the financial system or depositors.
     
     This has been "Fun facts with the Attorney General" time! Thanks for listening. Hope to see you tomorrow with a new fun fact!
     (Evidence P-002)
10. AFFIRM that on Dec 30, 2023, xEndeavour posted a consolidated Taxation Act on the Forums, which included the same language regarding commandeering as is the current law (Evidence P-003).
11. AFFIRM that Plaintiff Gnomewhisperer is a citizen of Redmont.
12. DENY that Plaintiff Gnomewhisperer is the sole equity owner of co-Plaintiff GnomeCorp. NOTING that no evidence has been submitted to substantiate this claim.
13. DENY that Gnomecorp sells expensive manufactured goods, including netherite armor. Producing these goods requires access to large amounts of capital, which the banking sector helps to facilitate. NOTING that no evidence has been submitted to substantiate this claim.
14. DENY that Gnomewhisperer and Gnomecorp each held accounts at financial institution Volt during the so-called ‘bank holiday’ (Evidence P-004). NOTING that the evidence filed in defense of this claim had been tampered with and is therefore inadmissible.
15. AFFIRM that during the so-called ‘bank holiday’, Volt was prohibited from allowing Gnomewhisperer and Gnomecorp to withdraw or deposit funds in their corresponding Volt bank accounts.
16. AFFIRM that Gnomewhisperer publicly objected to the government’s announcement that barred withdrawal and deposit to bank accounts (Evidence P-005).
17. AFFIRM that Gnomewhisperer’s council publicly objected to the Commonwealth’s attempt to commandeer large portions of the financial sector under the Taxation Act as overbroad (Evidence P-006).
18. AFFIRM that after these objections had been made known to the Department of Justice, and after a motion for emergency injunction in this case had been filed, the Department of Commerce issued another announcement regarding the so-called “bank holiday” (Evidence P-007).
19. AFFIRM that the text of the announcement read as follows:
    • BANK HOLIDAY LIFTING & VANGUARD SEIZURE
      
      Due to unexpected speed by everyone involved, we are able to lift the bank holiday for all banks except Vanguard National Bank and Discover Bank who will remain frozen at this time.
      
      The seizure of Vanguard and Discover bank has begun due to grave liquidity concerns and misrepresentation of financial statements. Deposits are covered by the 50k insurance per person on top of what liquidation of assets cover. Depositors will have first preference when it comes to fulfilling obligations.
      
      If:
      you are owed debt by Vanguard & Co or any of its subsidiaries, please report this debt to the DOC by making a ticket with proof of the debt's existence.,
      you possess bank notes from Discover Bank ATMs, please also make a ticket and present proof of the deposit claim.,
      
      More information will be revealed as needed.
      
      Signed
      Avaneesh2008
      Deputy Secretary of Commerce
      
      (Evidence P-007)
20. AFFIRM that this announcement substantially narrowed the scope of the “bank holiday”, limiting it to two banks and giving specific reasons for intervention.
21. AFFIRM that the Department of Commerce, however, has not provided specific public justification for why it ordered Volt and other not-presently-seized banks to refuse client requests to withdraw funds in the first place.
22. DENY that in fact, it was unreasonable to order large swathes of the financial sector to engage in a so-called “bank holiday” under pain of fines and sanctions, when the Department of Commerce alleged only grave liquidity issues in Vanguard National Bank and Discover Bank, as well as misrepresentation of financial statements by the same.

Motion

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

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

1. Rule 5.5 (Lack of Claim)
The Department of Commerce did not violate the constitutional rights of the Plaintiffs, as the powers used were allotted to the Department of Commerce in emergency situations. It’s vital to note that this whole interaction took no more than 3 hours and was initiated to prevent further harm to depositors or the financial sector at large.

2. Rule 5.12 (Lack of Personal Jurisdiction)
These actions were taken against financial institutions NOT against citizens. The Plaintiffs are not in the financial industry and the harm alleged and claimed by the Plaintiffs seemingly affected Volt, which is not owned or operated by the Plaintiffs.

3. Rule 2.1 (Standing Application)
‘In order for a plaintiff to pursue a case, they must show the following to the court:

1. Suffered some injury caused by a clear second party; or is affected by an application of law.
2. The cause of injury was against the law.
3. Remedy is applicable under relevant law that can be granted by a favorable decision.’

Response

TO OBJECTION

The Defense refers to two images submitted by the Plaintiff in support of the very simple fact that "Gnomewhisperer and Gnomecorp each held accounts at financial institution Volt during the so-called ‘bank holiday’". While this fact is doubtlessly known to be true by the Commonwealth, they allege that the images have been illicitly or improperly tampered with. The Plaintiff submits that [2024] FCR 102 and [2025] FCR 24 do not establish a precedent that the images submitted be improper.

I will first reply to the reference to [2025] FCR 24. The objection in that case had multiple fronts that are dissimilar here, including that one of the specific images was "modified with new text". The evidence presented in this case did not contain any new text, so the purported precedent is quite disanalagous and appeal to this case seems superfluous at best.

The objection raised in [2024] FCR 102 occurred when the Commonwealth (Plaintiff), attempted to include as evidence a screenshot containing scribbled lines to obscure defendant's perjury. In that case (as the judge noted in the ruling) the Plaintiff had also "submitted the entire case in which this happened as evidence". But the judge also notes in that case that there may be exceptions in which redactions are permitted. The judge offers, for example, the ability to obscure the name of anonymous whistleblowers as being permissible.

So, a bar on redactions is not absolute, as the Commonwealth erroneously assumes (or, implies that the court should assume here). Rather, a clear enough principle emerges from the rulings in [2024] FCR 102: the rights of privacy and anonymity are in tension with the practice that all evidence be submitted free of redactions, and courts must balance the two when handling these sorts of improper evidence objections.

Privacy is a respected right in the Commonwealth of Redmont. This right has been recognized both by our Common Law (see: Bank and Trust of Redmont v. Commonwealth of Redmont [2021] SCR 8, where the SUPREME COURT stated that "The court believes that there needs to be a reasonable expectation to privacy, notably in regards to the customer's finances" in light of the 15th charter right, which persists in the constitution to this day) and statutory texts (such as the Privacy Act). As has been long-recognized since Bank and Trust of Redmont v. Commonwealth of Redmont [2021] SCR 8, there is a privacy interest that applies to "customer's finances" in the context of bank holdings. Just as in the case anonymous whistleblowers, we put forward, the court should consider the very real and legitimate privacy interests of the bank account holder in a smilar manner.

The Commonwealth does not specify which portion of either image has been tampered with. However, if taken to mean the redaction of account balances, the Plaintiff believes that the principles outlined in the rulings on objections in [2024] FCR 102 would lead these to be permissible. This is because there exists a legitimate privacy interest in customer's finances that has been long-recognized by the Supreme Court, and the burden for any particular point is extremely low - neither the Defense nor the Plaintiff have made any references to account balances in their complaint nor their response to complaint.

On balance, the Plaintiff puts forth that the Supreme Court-recognized interest in the privacy of a bank customer's finances outweighs the non-harm caused by redaction of a customer's account balance that is not referred to in a defense nor relied upon for the establishment for any fact. To throw out the whole image, as the Commonwealth asks the court to do, would be suboptimal from a practical perspective and unnecessary from a legal one.

Motion

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

In the event that original evidence P-004 is struck, the Plaintiff seeks to amend the complaint in order to re-establish a fact well-known to the Commonwealth - that the Plaintiffs do indeed hold financial accounts, including at least 1 account with Volt. The Plaintiff seeks to amend Evidence P-004 as follows:

Spoiler: P-004, amended

Response

TO MOTION TO DISMISS

Plaintiffs respectfully oppose the Commonwealth's Motion to Dismiss, which invokes Rule 5.5 (lack of claim), Rule 5.12 (lack of personal jurisdiction), and Rule 2.1 (standing). As shown below, each asserted ground for dismissal is unfounded under the Laws and Constitution of the Commonwealth Redmont. Plaintiff's Complaint adequately alleges violations of constitutional rights and a breach of the government’s duty of care, thus stating a valid claim. Moreover, this Court has jurisdiction over the Commonwealth’s actions affecting Redmont citizens, and Plaintiffs plainly satisfy the standing requirements. For these reasons, the motion should be denied.


Introduction
Plaintiffs respectfully oppose the Commonwealth's Motion to Dismiss, which invokes Rule 5.5 (lack of claim), Rule 5.12 (lack of personal jurisdiction), and Rule 2.1 (standing). As shown below, each asserted ground for dismissal is unfounded under the Laws and Constitution of the Commonwealth Redmont. Plaintiff's Complaint adequately alleges violations of constitutional rights and a breach of the government’s duty of care, thus stating a valid claim. Moreover, this Court has jurisdiction over the Commonwealth’s actions affecting Redmont citizens, and Plaintiffs plainly satisfy the standing requirements. For these reasons, the motion should be denied.

I. Rule 5.5 – Lack of Claim

Plaintiffs have Stated Valid Legal Claims. The Commonwealths's motion argues no constitutional rights were violated because the Department of Commerce’s actions were authorized by law and done for a brief emergency period. This argument misapplies the law.

Under Redmont’s Constitution, Plaintiffs have a clear cause of action: the Department’s directive commandeering all private financial institutions for a so-called “bank holiday” constitutes an unreasonable seizure of citizens’ property rights, in violation of Part IV, Section 33, Clause 15 of the Constitution. That clause guarantees “[e]very citizen has the right to be secure against unreasonable search or seizure.” By freezing bank transfers and withdrawals with no valid law cited, the government effectively seized control of Plaintiffs’ financial assets and economic liberty, at least temporarily. Such a sweeping deprivation – even for 3 hours – is presumptively unconstitutional absent proper authority and due cause. The brief duration or claimed good intentions (“to prevent harm to depositors”) do not erase the legal injury; even a short-lived infringement of a fundamental right is actionable.

Furthermore, Part IV, Section 33, Clause 14 of the Constitution provides that no citizen may be deprived of life, liberty, or personal security except in accordance with fundamental justice. Here, fundamental justice was lacking: the Department issued an edict commandeering private banks without contemporaneously citing any statute or providing any due process to persons affected by this commandeering, suggesting the action was ultra vires. The Defendant invokes the Taxation Act as purported authorization. However, even if that Act delegates emergency powers, it does not license arbitrary deprivation of rights. In fact, the Taxation Act’s emergency power of commandeering were given restraints by the drafters of the Act: in cases of “extraordinary circumstances, such as insolvency, near insolvency, financial crises, or situations where the institution’s continued operation poses a systemic risk”. It authorizes the Commerce Department to “commandeer and take temporary control” of a troubled financial institution in such exceptional cases – not to impose a blanket freeze on every bank irrespective of their individual financial conditions. The announcement in question identified no failing bank or specific crisis; it simply declared a general “bank holiday” with threat of sanctions.

In other words, the Commonwealth's sweeping and broad action, which the Defense affirms in its response to the complaint that "in effect temporarily rendered financial firm client assets unable to be accessed by clients pursuant to a government order", finds no authority in the text of any law or the Constitution, and Plaintiffs were unable to locate any lawful authority for commandeering private institutions en masse. Thus, the Complaint properly alleges that the Commerce Department acted without lawful power and in contravention of constitutional limits, which states a valid claim for relief. As such, dismissal under Rule 5.5 is unwarranted.

Breach of Duty of Care: In addition to straightforward constitutional violations, the Complaint asserts the Commonwealth breached its duty of care to citizens. Redmont law recognizes that executive agencies owe a duty to act within the bounds of their constitutional and statutory obligations. As the Federal Court held in smokeyybunnyyy v. Commonwealth [2024] FCR 103, “Every department within the executive branch has a duty of care to uphold its constitutional obligations.” And, as the ruling in RaiTheGuy v. Department of Commerce [2025] FCR 29 succinctly notes, when a duty of care "is not upheld, it is considered a breach, and the party who is obliged to uphold the duty can be liable for damages". Here, by overstepping its legal authority and infringing Plaintiffs’ rights, the Department of Commerce breached that duty.

Why does the commonwealth deny that the facts as alleged by the Plaintiff would constitute a breach of duty, which would thus be a valid cause of action? The Commonwealth's motion doesn't say. The best that the Plaintiff can discern is that the Commonwealth is assuming, as it does in its response to the complaint, that "1. Taxation Act §8 gives broad non-exhaustive power to the DOC to protect depositors of deposit-taking institutions", without citing any specific clause in the section or language in the law itself. That being said, taking this to mean the language in clause 3 thereof (i.e. "The Department of Commerce will have the following non-exhaustive powers in relation to regulating financial institutions"), this simply does not create unlimited emergency powers. The section simply enumerates a list of powers and associated conditions when they may be used, while not precluding other laws from granting additional powers. Taking action beyond those limits – such as by effectively commandeering the whole of the interest-bearing banking sector ultra vires and without valid cause, while depriving both Plaintiffs their ability to make or accept payments using their lawfully obtained bank accounts – is a breach of the duty of care the government owes to the public.

In sum, Plaintiffs’ allegations are firmly grounded in concrete legal rights (constitutional provisions and statutory duties), not vague or “undefined” rights. A claim alleging unconstitutional seizure of assets and breach of an executive duty of care is undeniably a cognizable legal claim in Redmont. Just as above, dismissal under Rule 5.5 is unwarranted.

II. Rule 5.12 – Lack of Personal Jurisdiction​

III. Rule 2.1 – Standing​

1. That the Plaintiff suffered some injury caused by a clear second party; OR is affected by an application of law.
2. The cause of injury was against the law.
3. Remedy is applicable under relevant law that can be granted by a favorable decision.

1. Injury in Fact: Plaintiffs suffered a concrete injury as a result of the Department’s actions. The defense claims “neither plaintiff has suffered injury” since the directive targeted banks and Plaintiffs are “not in the financial industry”. This is incorrect. Plaintiffs were citizens or firms beneficially owned by citizens, and each Plaintiff's ability to use their accounts to engage in financial transactions was suspended.
   
   The constitutional rights at issue – the right to be free from unreasonable seizure of one’s property (Const. §33(15)) and the right to not be deprived of liberty or security except by fundamental justice (Const. §33(14)) – are personal rights held by every citizen. An alleged violation of those rights is itself an injury. This has been held in Redmont courts before; when in response to a motion to dismiss In totemundying v. Town of Aventura [2024] DCR 40, the Court noted that "the primary damage here is declining to the Plaintiff their right to post a bid under same conditions as anyone else", the court correctly identified that the violation of rights under the constitution itself constituted damage to the Plaintiff.
   
   By the same logic, Plaintiffs being denied the normal use of their bank accounts (even temporarily) and being subjected to an unauthorized government freeze constitutes an injury-in-fact. Additionally, if Plaintiffs had business transactions or personal needs during the freeze, they were concretely affected (the Complaint can be reasonably read to imply such adverse effects). In short, Plaintiffs were “affected by an application of law” (or here, an executive directive with claimed force of law) as Rule 2.1’s first prong requires.
   
   
2. Illegality of the Cause: The second prong asks whether the cause of injury was against the law. Plaintiffs easily satisfy this by alleging that the Department’s actions violated the Constitution and lacked statutory authority. The defense argues the cause of injury “was certainly not against the law, as the Taxation Act allotted these powers”. This assertion is highly dubious. As explained in Part I, no statute or constitutional provision actually authorized the sweeping bank freeze at issue. The Taxation Act’s emergency powers are limited to true financial emergencies (insolvency or systemic collapse) and contemplate taking control of a specific institution in trouble – not a blanket prohibition on all withdrawals absent any due process. If the Commonwealth contends a lawful “bank holiday” power exists, it has pointed to no text in the law that permits it, and it has affirmed in its response to the Complaint that the announcement itself “did not cite any legal basis” for its mandate.
   
   In the absence of clear authority, the executive branch’s unilateral action is ultra vires (beyond its powers) and thus “against the law.” Moreover, even if some statute could be stretched to cover this scenario, any such application would conflict with the Constitution’s protections. The Constitution is the supreme law of Redmont, and any executive act that contravenes it is unlawful per se. Plaintiffs allege constitutional violations (for example, unreasonable seizure), which by definition alleges that the government’s act was not in accordance with law.
   
   Thus, Rule 2.1’s second criterion is met: the injury flows from conduct that was ultra vires and unconstitutional, i.e. “against the law.”
3. Availability of Remedy. The availability of a remedy is not contested by the Defense, and for good reason: they trivially exist. Nominal damages exist (in part) to acknowledge the violations of rights in the absence of compensatory damages. Declaratory or injunctive relief can also be issued by the Court to make clear that the Commerce Department’s initial directive was unlawful and to prevent similar unauthorized bank prohibitions in the future.

Motion

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

The Plaintiff moves that the sentence in Defense's Response to complaint:

• "NOTING that the evidence filed in defense of this claim had been tampered with and is therefore inadmissible"

1. The evidence in question (Exhibit P-004) has never been ruled inadmissable by any court of law; and
2. This Court has since overruled the objection from the Commonwealth regarding the admission of this evidence.

Motion

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

Fact 12 of the original complaint stated that "Plaintiff Gnomewhisperer is the sole equity owner of co-Plaintiff GnomeCorp."

The Plaintiffs seek to amend this line to read "Plaintiff Gnomewhisperer is the sole equity owner of co-Plaintiff GnomeCorp (see: Exhibit P-008)".

Moreover, the Plaintiffs seek to introduce the following screenshot (which was obtained when running the in-game /business command) into the complaint by amendment. The location of this shall be immediately subsequent to and below the location of Exhibit P-007:

Spoiler: Exhibit P-008

Motion

MOTION TO DISBAR

I, Plura72 ask that the couet disbar the defense

Motion

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

Your honor, the plaintiff respectfully asks that the quoted motion filed by a non-party who is not counsel to either party be stricken from the record of this case.

Response

TO OBJECTION

As much as the Plaintiff would insinuate, it is not for the Commonwealth to speculate on whether or not citizens hold an account with one or any financial institution. In regard to the case at hand, it is for the Plaintiff to prove that they have accounts with financial institutions.

In evidence PO-001, the Solicitor General was strictly talking about the validity of the emergency injunction and was not speaking in an official capacity for the Commonwealth.

In evidence PO-002, Sir_Dogeington was at the time not representing the DOJ in the present case. As can be seen in the message Dogeington was basing his analysis on his present understanding of the law. An understanding of the law can change, and this comment does not hold any bearing over the current trial.

Brief

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

Under Rule 4.7 (Request for Discovery, Opposing Party Movement), "[p]rior to the end of Discovery, a party may move to request documents, messages, or screenshots from the opposing party."

Reserving the right to make additional requests prior to the end of Discovery, the Plaintiff hereby submits a formal request for discovery with respect to the following items:

1. Any and all written or electronic documents or communications created, edited, or published after 31 January 2025 that are in possession of the Commonwealth or Commonwealth's counsel, provided that:
   1. Such documents or communications contain public information with respect to any of the balance sheet, holdings, income, cash flow, or other financial information regarding Vanguard National Bank, its owners, or its sister firms.
2. Any and all written or electronic documents or communications created, edited, or published after 31 January 2025 that are in possession of the Commonwealth or Commonwealth's counsel, provided that:
   1. Such documents or communications contain public information with respect to any of the balance sheet, holdings, income, cash flow, or other financial information regarding any registered financial institution other than Vanguard National Bank, its owners, or its sister firms.
3. Any and all written or electronic documents or communications created, edited,or published after 31 March 2025 and before 03:39 UTC on 16 May 2025 that are in possession of the Commonwealth or Commonwealth's counsel, provided that any of the following applies:
   1. Such documents contain any analysis or description of macroeconomic conditions, including but not limited to:
      1. Money supply;
      2. Velocity of money;
      3. Savings rates; or
      4. Interest rates;
   2. OR, such documents contain any analysis or description of systemic, idiosyncratic, systematic, or other risks in the financial sector, including but not limited to:
      1. Market concentration;
      2. Creditworthiness of financial institutions;
      3. Maturity of financial sector internal controls writ large;
      4. Maturity of internal controls at particular financial institutions or conglomerates;
      5. Financial protections for consumers;
4. Any and all written or electronic documents or communications created, edited, or published after 31 March 2025 and before 03:39 UTC on 16 May 2025 and that that are in possession of the Commonwealth or Commonwealth's counsel, provided that:
   1. Such documents or communications contain any discussion of, or reference to, the legality or prudence of implementing the so-called "bank holiday" of 16 May 2025 or any specific part thereof.
5. Any and all written or electronic documents or communications created or published during or after 03:39 UTC on 16 May 2025 and that that are in possession of the Commonwealth or Commonwealth's counsel, provided that:
   1. Such documents or communications contain any discussion of, or reference to, the legality or prudence of implementing the so-called "bank holiday" on 16 May 2025.
6. Any and all written or electronic communications issued by any Department of Commerce employee containing in any place therein any of the (case-insensitive) strings: "vanguard", "discover", "db", "vnb", "vb", "vb-atm", "db-atm", "balance sheet", "volt", "bank", "voyager", "ryze", "exchange", "stock", "default", "debt", "crisis", "financial", "seize", "seizure", "freeze", "holiday", "liquid", "solvent", "emergency", "fed", "reserve", "taxation", "deposit", "CD", "invest", "fraud", "asset", "liability", "account", "transfer", "deposit", "withdraw", "withdrawal", "bank run", "run on the bank", "sanction", "profit", "loss", "atm", or "Nex"; issued between 00:01 UTC on 1 May 2025 and 23:59 UTC on 21 May 2025, in any:
   1. direct message,
   2. group message, or
   3. channel of the following discord servers administered by the Commonwealth, an executive branch, a municipality, or DemocracyCraft staff:
      1. DemocracyCraft (<Join the DemocracyCraft Discord Server!>)
      2. Oakridge (<Join the Oakridge Discord Server!>)
      3. Aventura (<Join the Aventura Discord Server!>)
      4. Congress of Redmont (<Join the Congress of Redmont Discord Server!>)
      5. Dept. Justice (<Join the Dept. Justice Discord Server!>)
      6. Dept. Homeland Security (<Join the Dept. Homeland Security Discord Server!>)
      7. Federal Reserve Bank (<Join the Federal Reserve Bank Discord Server!>)
      8. Dept. Commerce (<Join the Dept. Commerce Discord Server!>)
      9. Dept. State (<Join the Dept. State Discord Server!>)
      10. Dept. Construction and Transportation (<Join the Dept. Construction & Transportation Discord Server!>)
      11. Dept. Education (<Join the Dept. Education Discord Server!>)
      12. Dept. Health (<Join the Dept. Health Discord Server!>)
      13. Dept. Interior (<Join the Dept. Interior Discord Server!>)
      14. Dept. Public Affairs (<Join the Dept. Public Affairs Discord Server!>)
7. Any and all written or electronic communications issued by any Department of Justice employee containing in any place therein any of the (case-insensitive) strings: "vanguard", "discover", "db", "vnb", "vb", "vb-atm", "db-atm", "balance sheet", "volt", "bank", "voyager", "ryze", "exchange", "stock", "default", "debt", "crisis", "financial", "seize", "seizure", "freeze", "holiday", "liquid", "solvent", "emergency", "fed", "reserve", "taxation", "deposit", "CD", "invest", "fraud", "asset", "liability", "account", "transfer", "deposit", "withdraw", "withdrawal", "bank run", "run on the bank", "sanction", "profit", "loss", "atm", or "Nex"; issued between 00:01 UTC on 1 May 2025 and 23:59 UTC on 21 May 2025, in any:
   1. direct message,
   2. group message, or
   3. channel of the following discord servers administered by the Commonwealth, an executive branch, a municipality, or DemocracyCraft staff:
      1. DemocracyCraft (<Join the DemocracyCraft Discord Server!>)
      2. Oakridge (<Join the Oakridge Discord Server!>)
      3. Aventura (<Join the Aventura Discord Server!>)
      4. Congress of Redmont (<Join the Congress of Redmont Discord Server!>)
      5. Dept. Justice (<Join the Dept. Justice Discord Server!>)
      6. Dept. Homeland Security (<Join the Dept. Homeland Security Discord Server!>)
      7. Federal Reserve Bank (<Join the Federal Reserve Bank Discord Server!>)
      8. Dept. Commerce (<Join the Dept. Commerce Discord Server!>)
      9. Dept. State (<Join the Dept. State Discord Server!>)
      10. Dept. Construction and Transportation (<Join the Dept. Construction & Transportation Discord Server!>)
      11. Dept. Education (<Join the Dept. Education Discord Server!>)
      12. Dept. Health (<Join the Dept. Health Discord Server!>)
      13. Dept. Interior (<Join the Dept. Interior Discord Server!>)
      14. Dept. Public Affairs (<Join the Dept. Public Affairs Discord Server!>)
8. Any and all written or electronic communications issued by the President of the Commonwealth of Redmont containing in any place therein any of the (case-insensitive) strings: "vanguard", "discover", "db", "vnb", "vb", "vb-atm", "db-atm", "balance sheet", "volt", "bank", "voyager", "ryze", "exchange", "stock", "default", "debt", "crisis", "financial", "seize", "seizure", "freeze", "holiday", "liquid", "solvent", "emergency", "fed", "reserve", "taxation", "deposit", "CD", "invest", "fraud", "asset", "liability", "account", "transfer", "deposit", "withdraw", "withdrawal", "bank run", "run on the bank", "sanction", "profit", "loss", "atm", or "Nex"; issued between 00:01 UTC on 1 May 2025 and 23:59 UTC on 21 May 2025, in any:
   1. direct message,
   2. group message, or
   3. channel of the following discord servers administered by the Commonwealth, an executive branch, a municipality, or DemocracyCraft staff:
      1. DemocracyCraft (<Join the DemocracyCraft Discord Server!>)
      2. Oakridge (<Join the Oakridge Discord Server!>)
      3. Aventura (<Join the Aventura Discord Server!>)
      4. Congress of Redmont (<Join the Congress of Redmont Discord Server!>)
      5. Dept. Justice (<Join the Dept. Justice Discord Server!>)
      6. Dept. Homeland Security (<Join the Dept. Homeland Security Discord Server!>)
      7. Federal Reserve Bank (<Join the Federal Reserve Bank Discord Server!>)
      8. Dept. Commerce (<Join the Dept. Commerce Discord Server!>)
      9. Dept. State (<Join the Dept. State Discord Server!>)
      10. Dept. Construction and Transportation (<Join the Dept. Construction & Transportation Discord Server!>)
      11. Dept. Education (<Join the Dept. Education Discord Server!>)
      12. Dept. Health (<Join the Dept. Health Discord Server!>)
      13. Dept. Interior (<Join the Dept. Interior Discord Server!>)
      14. Dept. Public Affairs (<Join the Dept. Public Affairs Discord Server!>)
9. Any and all written or electronic communications issued by any Department of Justice employee containing in any place therein any of the (case-insensitive) strings: "Gnome", "Gnomewhisperer", "Gnomecorp", or "Baivo"; issued between 00:01 UTC on 16 May 2025 and 04:59 UTC on 21 May 2025, in any:
   1. direct message,
   2. group message, or
   3. channel of the following discord servers administered by the Commonwealth, an executive branch, a municipality, or DemocracyCraft staff:
      1. DemocracyCraft (<Join the DemocracyCraft Discord Server!>)
      2. Oakridge (<Join the Oakridge Discord Server!>)
      3. Aventura (<Join the Aventura Discord Server!>)
      4. Congress of Redmont (<Join the Congress of Redmont Discord Server!>)
      5. Dept. Justice (<Join the Dept. Justice Discord Server!>)
      6. Dept. Homeland Security (<Join the Dept. Homeland Security Discord Server!>)
      7. Federal Reserve Bank (<Join the Federal Reserve Bank Discord Server!>)
      8. Dept. Commerce (<Join the Dept. Commerce Discord Server!>)
      9. Dept. State (<Join the Dept. State Discord Server!>)
      10. Dept. Construction and Transportation (<Join the Dept. Construction & Transportation Discord Server!>)
      11. Dept. Education (<Join the Dept. Education Discord Server!>)
      12. Dept. Health (<Join the Dept. Health Discord Server!>)
      13. Dept. Interior (<Join the Dept. Interior Discord Server!>)
      14. Dept. Public Affairs (<Join the Dept. Public Affairs Discord Server!>)
10. Any and all written or electronic communications issued by any Department of Justice employee containing in any place therein any of the (case-insensitive) strings: "Gnome", "Gnomewhisperer", "Gnomecorp", or "Baivo", issued between 00:01 UTC on 16 May 2025 and 04:59 UTC on 21 May 2025, in any:
    1. direct message,
    2. group message, or
    3. channel of the following discord servers administered by the Commonwealth, an executive branch, a municipality, or DemocracyCraft staff:
       1. DemocracyCraft (<Join the DemocracyCraft Discord Server!>)
       2. Oakridge (<Join the Oakridge Discord Server!>)
       3. Aventura (<Join the Aventura Discord Server!>)
       4. Congress of Redmont (<Join the Congress of Redmont Discord Server!>)
       5. Dept. Justice (<Join the Dept. Justice Discord Server!>)
       6. Dept. Homeland Security (<Join the Dept. Homeland Security Discord Server!>)
       7. Federal Reserve Bank (<Join the Federal Reserve Bank Discord Server!>)
       8. Dept. Commerce (<Join the Dept. Commerce Discord Server!>)
       9. Dept. State (<Join the Dept. State Discord Server!>)
       10. Dept. Construction and Transportation (<Join the Dept. Construction & Transportation Discord Server!>)
       11. Dept. Education (<Join the Dept. Education Discord Server!>)
       12. Dept. Health (<Join the Dept. Health Discord Server!>)
       13. Dept. Interior (<Join the Dept. Interior Discord Server!>)
       14. Dept. Public Affairs (<Join the Dept. Public Affairs Discord Server!>)
11. Any and all written or electronic communications issued by the President of the Commonwealth of Redmont containing in any place therein any of the (case-insensitive) strings: "Gnome", "Gnomewhisperer", "Gnomecorp", or "Baivo", issued between 00:01 UTC on 16 May 2025 and 04:59 UTC on 21 May 2025, in any:
    1. direct message,
    2. group message, or
    3. channel of the following discord servers administered by the Commonwealth, an executive branch, a municipality, or DemocracyCraft staff:
       1. DemocracyCraft (<Join the DemocracyCraft Discord Server!>)
       2. Oakridge (<Join the Oakridge Discord Server!>)
       3. Aventura (<Join the Aventura Discord Server!>)
       4. Congress of Redmont (<Join the Congress of Redmont Discord Server!>)
       5. Dept. Justice (<Join the Dept. Justice Discord Server!>)
       6. Dept. Homeland Security (<Join the Dept. Homeland Security Discord Server!>)
       7. Federal Reserve Bank (<Join the Federal Reserve Bank Discord Server!>)
       8. Dept. Commerce (<Join the Dept. Commerce Discord Server!>)
       9. Dept. State (<Join the Dept. State Discord Server!>)
       10. Dept. Construction and Transportation (<Join the Dept. Construction & Transportation Discord Server!>)
       11. Dept. Education (<Join the Dept. Education Discord Server!>)
       12. Dept. Health (<Join the Dept. Health Discord Server!>)
       13. Dept. Interior (<Join the Dept. Interior Discord Server!>)
       14. Dept. Public Affairs (<Join the Dept. Public Affairs Discord Server!>)

Motion

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

Your honor,

It has come to my attention that there was an editing error in the above request for discovery—the wrong agency was referred to in request 10, rendering requests 9 and 10 as being accidentally duplicates.

For this reason, I ask that the language:

• “Any and all written or electronic communications issued by any Department of Justice”

• “Any and all written or electronic communications issued by any Department of Commerce”

Motion

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

Your honor,

We are over 1/4 of the way through discovery at this point. The Plaintiff noted its requests of the defense earlier, and (while they have not objected to any requests) the defense has yet to respond letting us know if they intend to comply with these requests for production of documents and communications. In the meantime, while the Attorney General has acknowledged the posting of the requests for discovery in a public forum (see: Exhibit P-MC1), and joined in on a public discord call on the DemocracyCraft discord that included another counsel for the defense (Sir_Dogeington, see: Exhibit P-MC2).

Because no response whatsoever has thus far been received, and both the Attorney General and Sir_Dogeington appear to have been active in the meantime, I ask that this court compel the defense to produce the discovery requested in the Request for Discovery brief above prior to 12:47 P.M. UTC on Saturday, 24 May 2025.

The reasons for our requests are straightforward and pertain to the subject of this case:

1. The Commonwealth in its defenses stated that "[t]he first imposed 36 hours reduced later (to 3 hours) shows how swiftly the DoC acted to protect depositor interests and the financial industry at large" and that "[t]he DoC took control of the financial industry for the protection of the depositors of deposit-taking institutions of Redmont." By requesting these documents from the Commonwealth, the Plaintiff hopes to scrutinize these defenses by examining whether what decision-makers wrote or said actually aligns with these defenses.
2. The Commonwealth, in its Response to Complaint, denied that "it was unreasonable to order large swathes of the financial sector to engage in a so-called “bank holiday” under pain of fines and sanctions, when the Department of Commerce alleged only grave liquidity issues in Vanguard National Bank and Discover Bank, as well as misrepresentation of financial statements by the same'. By obtaining the discovery documents from the Commonwealth, the Plaintiff hopes to scrutinize whether or not the Commonwealth did indeed only recognize grave liquidity issues in Vanguard National Bank and Discover Bank.
3. The Commonwealth denies, in its Response to Complaint, that "that Gnomewhisperer and Gnomecorp each held accounts at financial institution Volt during the so-called ‘bank holiday". By requesting information on messages containing "Gnome", "Gnomewhisperer", "Gnomecorp", or "Baivo" (Gnomewhisperer's discord name), the Plaintiff hopes to scrutinize whether or not this denial was undertaken in good faith, as well as any actions taken by the Department of Justice or Department of Commerce to investigate this claim (as such actions may have caused injuries, like violations of privacy, which the Plaintiff would seek to amend to this complaint if found).
4. The Commonwealth broady denies that the so-called "Bank Holiday" was illegal. The Plaintiff seeks to find evidence, for example, whether or not concerns were raised internally and ignored by decision-makers, whether the Commonwealth considered/rejected less sweeping interventions that would have achieved its goals without burdening client rights, and the general attitude of the Commonwealth towards compliance with the rights and freedoms guaranteed by the Constitution in this matter.
5. The Plaintiff seeks general economic information in order to assess the reasonability of Commonwealth's action in light of the broader economy's and financial sector's health.

Spoiler: Exhibit P-MC1

Spoiler: Exhibit P-MC2

Motion

IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
MOTION TO EXTEND DISCOVERY

Your Honor has granted 72 hours total discovery. It is Plaintiff's counsel's understanding that Rule 4.8 (Interrogatories), which states that "[r]equests for Interrogatories must be made 72 hours prior to the end of discovery", requires the Plaintiff to request interrogatories no later than 72 hours prior to the termination of discovery. The Plaintiff would like to submit interrogatories, but due to the timeline for discovery provided, the Plaintiff understands it is not possible to do so during the discovery period.

The Plaintiff requests that discovery be extended until 11:47 P.M. UTC on Monday, 26 May 2025. This would provide for a total extension of discovery by 2 days, and would give Plaintiff ample time to request interrogatories should a ruling on this motion be given in the next 12-18 hours.

In case that a ruling cannot come so quickly, the Plaintiff would ask that discovery simply be extended by one day more than requested in the above paragraph, which would also permit the posing of interrogatories to be attained.

Brief

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

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

1. Yes or no:
   • Prior to the initial announcement of the so-called "bank holiday", did the Department of Commerce or Department of Justice at any time consider measures that would have restricted the financial sector less, such as by selecting fewer financial institutions to freeze or exempting additional sorts of transactions from such a freeze, relative to that which was sought in the initial bank holiday announcement?
2. Yes or no:
   • Was it truly necessary that Volt be frozen during the period of the so-called "bank holiday" in order to stabilize the economy and financial sector?
3. Yes or no:
   • If a bank were to freeze an account and deny a customer the ability to withdraw or transfer their funds, would that bank have been considered to have seized those funds?
   • Is the Department of Commerce, under the laws of the Commonwealth of Redmont and the Constitution thereof, explicitly granted the power to mandate bank holidays?
4. Yes or no:
   • When evaluating whether or not to deny that Gnomewhisperer and Gnomecorp each held accounts at financial institution Volt during the so-called ‘bank holiday’, did the Commonwealth, Attorney General, or any DOJ employee acting on behalf of the Commonwealth or Attorney, reach out to Volt or an officer thereof and obtain information regarding the existence of GnomeWhisperer's account there?
   • When evaluating whether or not to deny that Gnomewhisperer and Gnomecorp each held accounts at financial institution Volt during the so-called ‘bank holiday’, did the Commonwealth, Attorney General, or any DOJ employee acting on behalf of the Commonwealth or Attorney, obtain information regarding the existence of GnomeWhisperer's account there?
5. Yes or no:
   • Has, at any time following the initial public announcement of the so-called "bank holiday", the Commonwealth attempted to access or actually accessed private information about GnomeWhisperer's finances without the use of a valid subpoena, court order, or warrant?
   • Has, at any time following the initial public announcement of the so-called "bank holiday", the Commonwealth accessed private information about GnomeWhisperer's finances without the use of a valid subpoena, court order, nor warrant?

Response

We are asking, simply, whether the Commonwealth holds that "it was truly necessary that Volt be frozen during the period of the so-called 'bank holiday' in order to stabilize the economy and financial sector". This is not an opinion - either Volt being frozen was required to stabilize the economy and financial sector or it was not; the request is extremely straightforward.

Response

Question 3 is relevant to the case, and asks a factual question of law of the Commonwealth. This is not an opinion - either the laws of the Commonwealth consider this a seizure or they do not. Moreover, this question is obviously related to fact No. 7, which was denied by the Commonwealth in their initial response to complaint.

Response

Your honor, the question is very simple. We are asking if the Commonwealth or its agents reached out to Volt and did obtain information regarding the existence of GnomeWhisperer's account there. If it the case that the Commonwealth or its agents did both, they can truthfully answer in the affirmative. If it is the case that the Commonwealth or its agents did not do both, they can truthfully answer in the negative. This is extremely straightforward, and the Commonwealth and its counsel is plainly intelligent enough to understand this question.

Response

Your honor,

The fifth interrogatory question does not ask "if the event had happened AND if information had been obtained" (emphasis mine). In fact, the question does not use the term "and" once, nor any other sort of conjunctive language tying multiple questions together; the Commonwealth's counsel is either lying or confused.

As such the Plaintiff's counsel would ask that you overrule this objection as being falsely premised.

Motion

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

Your honor,

I had anticipated replies to objections taking longer than actually was required. As such, I ask that you please consider this request be stricken as moot.

Motion

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

Consistent with Rule 3.3 (Amendment to Complaint), the Plaintiff asks that the above witness list be amended to read as follows:

1. Gnomewhisperer
2. Avaneesh2008
3. xSyncx
4. Juniperfig
5. 1950minecrafter
6. Freeze_Line
7. Dearev
8. Stoppers
9. Omegabiebel
10. DonTrillions
11. Nexalin
12. xEndeavour

Motion

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

Your Honor,

The evidence that the court has compelled is classified to a CABINET level, all conversations pertaining to the decision process that ultimately led to the "bank holiday" is classified in this manner, as well as the evidence used to justify the "bank holiday." The Defense is willing to share this evidence, but it must be in closed court as to maintain the integrity of the cabinet.

The precedent for a motion of this type was set in [2024] FCR 70 and in [2024] FCR 76.

Response

IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
RESPONSE TO OBJECTION

Your honor,

According to the Objections Guide, a "relevance" objection is permitted "when evidence presented is not relevant to the case, or a witness is asked an irrelevant question". Because a witness list does not itself present evidence, and does not ask any questions of witnesses, a "relevance" objection is nonsensical here. This alone is enough to overrule the motion by the Commonwealth.

What's more, the objection fails even on its own grounds, as the witnesses listed are indeed relevant to the disputed facts of this case.

The Plaintiff understands the following:

• 1950minecrafter is the President of the Commonwealth of Redmont, and can provide testimony surrounding Fact No. 22, which relates to the reasonableness of the Commonwealth's decision to freeze all banks.
• Freeze_Line was the Attorney General during much of the investigation into Vanguard, and can testify around any considerations of alternatives to the so-called "bank holiday" discussed or not discussed during his time at the helm of the DOJ. This relates to Fact No. 22, which relates to the reasonableness of the Commonwealth's decision to freeze all banks.
• Dearev is the current head of the Redmont Bureau of Investigations, and can provide testimony regarding the extent of financial risk discovered during such investigations. This is relevant to which relates to the reasonableness of the Commonwealth's decision to freeze all banks.
• Stoppers is a Lieutenant Governor of the Federal Reserve, and can provide Fact No. 22, which relates to the reasonableness of the Commonwealth's decision to freeze all banks in light of the broader financial situation.
• Omegabiebel is an employee of Volt, and can provide testimony related to disputed fact No. 14 (regarding the existence or non-existence of Plaintiff's account there). Moreover, Omegabiebel can provide testimony regarding the financial strength and robustness of Volt Bank, which clearly relates to Fact No. 22's assertions regarding the reasonableness of the Commonwealth's decision to freeze all banks.
• DonTrillions is an employee of Volt, and can provide testimony related to disputed fact No. 14 (regarding the existence or non-existence of Plaintiff's account there). Moreover, DonTrillions can provide testimony regarding the financial strength and robustness of Volt Bank, which clearly relates to Fact No. 22's assertions regarding the reasonableness of the Commonwealth's decision to freeze all banks. On top of that, DonTrillions is a Governor of the Federal Reserve, which adds additional layers to testimony around Fact No. 22.
• Nexalin ran Vanguard, which is of obvious relation to Fact No. 22 as the allegations surrounding Vanguard directly play into the reasonability of the government's decision to freeze all banks.
• xEndeavour was present in the witness list from the get-go, before the Commonwealth had responded in the affirmative regarding Fact No. 10 in which xEndeavour was directly mentioned by name. It is strange that the Commonwealth only objects now, and even stranger that the government asks that this witness be removed even before they issue a final amended Response to Complaint; as the Response to Complaint can be amended after discovery should substantial changes be made to complaint in the 72 hours prior to the end of discovery, and the Plaintiff reserves the right to make such changes, the Plaintiff seeks to keep the witness on their witness list for now.

Motion

IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
MOTION TO EXTEND DISCOVERY

In light of the recent flurry of activity in this case, and to provide Your Honor with additional time to consider all pending motions and objections during the discovery period, Plaintiff requests a 24-hour extension to discovery.