Lawsuit: In Session jsrkiwi v Department of Construction & Transportation [2025] FCR 112

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jsrkiwi

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Case Filing



IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
CIVIL ACTION

jsrkiwi
Plaintiff

v.

Department of Construction & Transportation
Defendant


COMPLAINT
The Plaintiff complains against the Defendant as follows:

This action concerns the Department of Construction & Transportation’s repeated failure to enforce its own eviction regulations on government-owned properties, resulting in an inconsistent and arbitrary application of Redmont’s property laws. The Plaintiff asserts that this inaction violates the constitutional principles of equal treatment under the law and fair market competition, falling beyond the bounds of proper administrative discretion.
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I. PARTIES
1. The Plaintiff, jsrkiwi, is a licensed Realtor operating within the Commonwealth of Redmont, engaged in the business of buying, selling, and managing real estate.
2. The Defendant, Department of Construction & Transportation (DCT), is a government agency of the Commonwealth responsible for enforcing property standards, including evictions, demolitions, and auctions pursuant to the Property Standards Act and DCT policies.

II. FACTS
1. The Property Standards Act grants the DCT power and duty to enforce construction standards, expounded in detail within the department’s Evictions Policy.
2. The DCT has consistently enforced these standards against private citizens, including for inactivity, failure to maintain property, and lack of commercial or residential use.
3. However, the DCT has failed to act upon numerous government-owned properties that violate these same standards, creating a double standard that undermines equal application of the law.
4. The following non-exhaustive list of examples illustrate the Defendant’s failure:
(a) Redmont Art Gallery (Government-Owned): Vacant, unused, and serving no valid commercial, artistic or cultural purpose for a prolonged period. The building remains idle, contributing no economic or community value, and would qualify as abandoned under ordinary DCT enforcement standards.
(b) Plot s024: A skyscraper-zoned plot currently occupied by a petrol station and lacks the skyscraper structure required under zoning regulations. In addition, the lack of chest shops selling fuel shows non-compliance by invalid commercial purpose. Despite this, the DCT has taken no enforcement or eviction action.
(c) Plot r050: A government-owned residential property that grants access to a single “friend” smokeyybunnyyy whose last-month playtime is only four hours, and is therefore not compliant with activity requirements. Such inactivity would normally trigger eviction for private owners under DCT evictions policy.
(d) Plots c155/c156/c157/c158 (merged): These merged commercial plots have stood vacant for an extended duration, lacking any active business or commercial use, again in breach of DCT’s commercial purpose rules.
5. In each of these cases, if the plots were privately owned, the DCT’s existing eviction procedures would have resulted in repossession, demolition, or auction.
6. By refusing to apply eviction standards to its own or other government-held properties, the DCT is exercising selective enforcement, violating both the Property Standards Act and the constitutional guarantee of equal treatment under law.
7. The Defendant’s inaction artificially restricts property availability, distorts market supply, and directly harms the Plaintiff’s business as a realtor reliant on fair access to active, tradeable plots.

III. CLAIMS FOR RELIEF
1. The DCT’s refusal to evict government-owned properties constitutes a violation of the Property Standards Act, which imposes a duty upon the Department to establish and enforce property regulations.
2. This selective enforcement infringes the constitutional principle of equal application of law by favouring government properties over private citizens.
3. The Plaintiff has standing as an active Realtor directly impacted by the Department’s inconsistent enforcement, which restricts supply, inflates prices, and damages free and fair market operation.
4. The Federal Court has proper jurisdiction as the case raises a constitutional question on equal treatment and administrative fairness, falling outside the established bounds of lower court jurisdictions.

IV. PRAYER FOR RELIEF
The Plaintiff seeks the following from the Defendant:
1. A declaratory judgment that the DCT’s failure to apply eviction regulations to government-owned properties is unlawful and unconstitutional.
2. Order a mandatory injunction compelling the DCT to enforce its eviction and property standards equally on all properties, including government-owned plots such as the Redmont Art Gallery, s024, r050, and c155/c156/c157/c158.

V. ATTACHED EVIDENCE
1. Photos of the Redmont Art Gallery, taken on 21 October 2025.
2. Photos of s024, taken on 21 October 2025.
3. Screenshot showing the result of “/as info region –region s024”, taken on 21 October 2025.
4. Screenshot showing the result of “/as info region –region r050”, taken on 21 October 2025.
5. Screenshot showing the active status of smokeyybunnyyy, taken on 21 October 2025.
6. Photos of c155/c156/c157/c158 (merged plots), taken on 21 October 2025.
7. Screenshots showing the result of “/as info region” for c155, c156, c157, and c158, taken on 21 October 2025.
8. Screenshot showing the plaintiff’s profession as a realtor.

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 21st day of October 2025.

 

Attachments

Writ of Summons

@Kaiserin_, is required to appear before the federal Court in the case of jsrkiwi v Department of Construction & Transportation [2025] FCR 112

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.

 
The Commonwealth is present, your Honor.
 
Please present the Defendant's answer in the next 48 hours.
 

Answer to Complaint


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

jsrkiwi
Plaintiff

v.

Department of Construction & Transportation
Defendant

I. ANSWER TO COMPLAINT
1. The Defendant DENIES that the Property Standards Act grants the DCT power and duty to enforce construction standards, expounded in detail within the department’s Evictions Policy. While the Property Standards Act states that the Department of Construction & Transport (DCT) has jurisdiction over enforcing these standards, thus granting them the power to, it does not define any duties regarding this onto the DCT.
2. The Defendant AFFIRMS that the DCT has consistently enforced these standards against private citizens, including for inactivity, failure to maintain property, and lack of commercial or residential use. Under the assumption that "these standards" refers to those standards set within the DCT's eviction policy.
3. The Defendant DENIES that the DCT has failed to act upon numerous government-owned properties that violate these same standards, creating a double standard that undermines equal application of the law. No double standard was created, no equal application of laws was undermined, and the DCT did not fail.
4. The Defendant DENIES that the list of examples given under fact 4 illustrates the Defendant's failure. The Defendant believes that there has not been any failure on the part of the Defendant.
5. The Defendant DENIES that in each of the cases listed under fact 4, if the plots were privately owned, the DCT’s existing eviction procedures would have resulted in repossession, demolition, or auction. The Plaintiff alleges that r050 would be evicted due to a lack of playtime for an added friend, however playtime requirements apply to the owner of the plot, not to added friends.
6. The Defendant DENIES that by refusing to apply eviction standards to its own or other government-held properties, the DCT is exercising selective enforcement, violating both the Property Standards Act and the constitutional guarantee of equal treatment under law. The Defendant does not believe this behavior is occuring, and even if the Court were to find it occured it would not violate the Property Standards Act nor the constitutional guarantee of equal treatment under law.
7. The Defendant DENIES that the Defendant’s inaction artificially restricts property availability, distorts market supply, and directly harms the Plaintiff’s business as a realtor reliant on fair access to active, tradeable plots. The Defendant has not been inactive. There also is and has been a large availability of properties and actively tradeable plots.

II. DEFENCES
1. The Property Standards Act does not state that the DCT has any duties whatsoever, and thus also not that the DCT has a duty to enforce construction standards. The Plaintiff appears to have simply made this up. This claim for relief appears to be frivolous.
2. The Defendant alleges that there has not been any selective enforcement between the Government and private citizens. Even if there had been however, the Plaintiff's claim that this would constitute a breach of a constitutional right is incorrect. The Constitution states as the right that the Plaintiff appears to be referring to: "(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 and, in particular, without unfair discrimination based on political belief or social status". This right however specifically states "Every citizen". The Commonwealth is not a citizen, and even the Plaintiff himself agrees that the Commonwealth has consistently enforced these standards against all citizens, as can be seen under Fact 2 of the Complaint.

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 2nd day of November 2025


 
We shall now be moving towards Discovery. Discovery will end in 5 days. Discovery can be voluntarily ended or extended with both parties agreeing to do so. Please remember the following rules:

Rule 4.2 (Submission Required For Use)​

All material used in legal arguments must have either been included in the case prior to the submission. Material must have been included within the complaint, within the answer, within an amendment to a complaint, within an amendment to an answer, or within a discovery submission. Otherwise the material will be deemed inadmissible and the argument can be voided by the presiding judge.

Rule 4.5 (Consent to End Discovery Early)​

If both parties consent to end Discovery early, they may request the presiding Judicial Officer to move to the next phase of the trial.

Rule 4.9 (Witness Protocol)​

A party may submit a list for witnesses at any time before the end of discovery. In order for a witness to be called during witness testimony, they must be announced under this rule, during discovery. Any witness may be objected to according to the objections laid out within rule 6.3.

Failure to adhere to the timelines of this rule may subject that party to a contempt of court charge at the presiding judge’s decision. The presiding judge shall include a warning regarding the timeline when summoning the witness.
 
Plaintiff’s request for discovery
Pursuant to rule 4.7, the Plaintiff requests the following from the Defendant:
1. All documents and communications relating to the transfer of s024 into and out of government ownership.
2. All documents and communications relating to the transfer of r050 into and out of government ownership.
3. All documents and communications relating to the transfer of c155/c156/c157/c158 into government ownership.
4. All communications of DCT employees within the past year, where government-owned properties were discussed.
5. All communications of DCT employees within the past year, where non-enforcement of policy in spite of a noted violation was discussed.
6. All communications between the DCT and other government departments, where a DCT policy violation was discussed.
 
Plaintiff’s interrogatories for the Defendant
Pursuant to rule 4.8, the Plaintiff requests answers to the following from the Defendant:
1. Why did the DCGovernment take ownership or control of s024?
2. Why did the DCGovernment take ownership or control of r050?
3. Why does the DCGovernment have ownership of c155/c156/c157/c158?
4. Does the DCT have an unlisted/unwritten policy of not enforcing property standards against buildings in government ownership?
5. Why does the DCT actively not enforce its own property standards against properties owned or controlled by the government?
 

Motion


IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
MOTION TO COMPEL AND MOTION FOR SANCTIONS

The Plaintiff, jsrkiwi, moves this Honourable Court for an order compelling the Defendant to comply with discovery requests and interrogatories, already served pursuant to Rules 4.7 and 4.8.

GROUNDS
1. Discovery is open.
2. The Plaintiff submitted discovery and interrogatory requests on Monday at 18:47 and 18:48.
3. No answers, no objections, no partial compliance have been served by the Defendant as of the filing of this motion (48 hours).
4. These discovery requests are directly linked to the Defendant’s pleaded defence (specifically their denial of selective enforcement and their position that the Property Standards Act does not create obligations). Without the documents and answers, the Plaintiff cannot prepare argument, cross, or witnesses, because the reasons for government retention and non‐eviction are exclusively held by the Defendant.

RELIEF REQUESTED
1. The Plaintiff respectfully seeks:
(a) An order compelling full production for requests 1 through 6 of the Plaintiff’s discovery request (filed Monday 18:47).
(b) An order compelling answers to all interrogatories 1 through 5 (filed Monday 18:48).
2. As the deadline of 48 hours for answering interrogatories (as per rule of procedure 4.8) has passed, the Court should rightfully impose sanctions upon the Defendant. The plaintiff politely suggests that the court ought to:
(a) strike the Defendant’s factual denials, given the Defendant’s ongoing refusal to disclose any factual basis for them, and that the case therefore proceed solely on the remaining questions of law;
(b) deny any objection to the discovery requests and interrogatory requests; and
(c) award costs for wasted time, calculated as $2,500 for additional work reasonably and necessarily caused solely by the Defendant’s non-compliance.

 
The government has 24 hours to respond to the motion. If there is an issue, please let me know.
 
Response to Plaintiff's Request for Discovery:
1. All documents and communications relating to the transfer of s024 into and out of government ownership.
2. All documents and communications relating to the transfer of r050 into and out of government ownership.
3. All documents and communications relating to the transfer of c155/c156/c157/c158 into government ownership.

The Defendant opposes requests 1, 2 and 3 as they are unclear and broad in the manner they are currently stated, which make them infeasible for the Defendant to comply with. If the Plaintiff could specify what communications they would be looking for and from where, the Defendant would be happy to comply with this request. For example, if the Plaintiff intended to mean internal government communications made within the DCT server that mention any of the above mentioned plots then that is something the Defendant would be happy to provide.


4. All communications of DCT employees within the past year, where government-owned properties were discussed.

The Defendant opposes this fourth request for two reasons.

Firstly, the Defendant does not have access to all communications of DCT employees. If DCT employees privately or publicly discuss something with other people that is not at all within the realm of reasonable information to request from the Defendant.

Furthermore, the information itself is also way too broad and irrelevant to this case. The DCT is the Department that builds government-owned properties. Even if this request was limited to discussion within the DCT server, requesting every single communication that was made in an entire year in that server regarding government owned properties would be an incredible amount of information that has nothing to do with this case at all and would be completely unreasonable.

5. All communications of DCT employees within the past year, where non-enforcement of policy in spite of a noted violation was discussed.

The Defendant opposes this request, both the response to the first three requests applies here, as well as the first reason given to oppose the fourth request. If the Plaintiff could clarify both a location (e.g. DCT server) and specific search term(s) they would be looking for that is specific and relevant then the Defendant would be happy to comply with this request.

6. All communications between the DCT and other government departments, where a DCT policy violation was discussed.

The Defendant agrees to this request. The Defendant intends to provide the requested informationto the best of their ability before the end of discovery.


Response to Plaintiff's Interrogatories:
1. Plot s024 was evicted as can be seen here
2. Plot r050 was evicted as can be seen here
3. Because the Government acquired ownership of these plots.
4. There is no such unwritten or unlisted policy, however it is common sense that certain eviction reasons would not apply to government plots (e.g. playtime requirements do not make sense for government accounts that are not actively played on)

To question 5 the Defendant makes the following Objection:

Objection


IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
OBJECTION - ASSUMES FACTS NOT IN EVIDENCE
This question assumes that the DCT actively does not enforce its own property standards against properties owned or controlled by the government, which is not a fact in evidence of this case.




Response to Plaintiff's Motion to Compel and Sanction:
Your Honor, the Defendant humbly apologizes for not being aware sooner of the interrogatories that were filed by Plaintiff and not responding to the Interrogatories within the timeline stated in the Court Rules and Procedure. Defendant hereby would like to ask for an extension to the deadlines stated in the Court Rules and Procedures to still allow for the response given in the section above to be taken into account by the Court. The Defendant would like to note that the Court Rules and Procedures were recently changed to add a stipulation that "Judicial Officers shall notify the respective party in a case whenever they are required to deliver a filling, argument, or statement. This includes Opening Statements, Closing Statements or any other submissions required by the court. Failure to notify may justify an extension of deadlines if a party can show that they were unaware of their turn." and that no prior notice was given by a Judicial Officer until the most recent notice and that Defendant has replied within the deadline set within this notice.

Considering the above, the Defendant respectfully requests that the court:
1. Does not grant Plaintiff's request for an order compelling full production for requests 1 through 5 of the Plaintiff’s discovery request, taking into account the Defendant's oppositional statements to those requests as made within this filing.

2. Does not grant Plaintiff's request for an order compelling full production for request 6 of the Plaintiff's discovery request, as the Defendant does not oppose it.

3. Does not grant Plaintiff's request for an order compelling answers to all interrogatories 1 through 5, as the Defendant has now either answered to or objected to all five interrogatories.

4. Does not grant any of the sanctions requested by the Plaintiff considering the previous lack of notice from a Judicial Officer and the fact that Defendant has now properly answered to all requests made within the deadline set by the Judicial Officer to respond to Plaintiff's motion.
 
Defendant hereby requests an extension of discovery for the following reasons:
- The matters discussed in the previous filing are still pending, and discovery is set to end in about 5 minutes.
- The Defendant needs some extra time to properly comply with the Discovery Request to which they agreed
- The Defendant thinks that the Plaintiff should have the opportunity to reword or refile their discovery requests in line with the problems raised by the Defendant in their previous filing, such that the Plaintiff can get the information they are looking for.
 
gribble19 said:
Defendant hereby requests an extension of discovery for the following reasons:
- The matters discussed in the previous filing are still pending, and discovery is set to end in about 5 minutes.
- The Defendant needs some extra time to properly comply with the Discovery Request to which they agreed
- The Defendant thinks that the Plaintiff should have the opportunity to reword or refile their discovery requests in line with the problems raised by the Defendant in their previous filing, such that the Plaintiff can get the information they are looking for.
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PLAINTIFF’S NOTICE OF NO OBJECTION TO EXTENSION OF DISCOVERY

The Plaintiff does not object to an extension of discovery time.
 
PLAINTIFF’S SUPPLEMENTAL REQUEST FOR DISCOVERY

Pursuant to Rule 4.7, the Plaintiff requests the following from the Defendant:

1. Plot s024
All documents, messages, communications, or memos within DCT or other government department Discord servers or the DC forum containing the text “s024”, with a start date of after 5 August 2025 and limited to the period until 21 October 2025.

2. Plot r050
All documents, messages, communications, or memos within DCT or other government department Discord servers or the DC forum containing the text “r050”, with a start date of after 1 June 2025 and limited to the period until 21 October 2025.

3. Plots c155/c156/c157/c158
All documents, messages, communications, or memos within DCT or other government department Discord servers or the DC forum containing the text “c155”, “c156”, “c157”, or “c158”, with a start date of after 24 July 2025 and limited to the period until 21 October 2025.

4. DCT employee communications regarding government-owned properties
All documents, messages, communications, or memos within the DCT Discord server containing the text “DCGovernment”, with a start date of after 22 July 2025 and limited to the period until 21 October 2025.


PLAINTIFF’S NOTICE OF PARTIAL WITHDRAWAL OF PRIOR DISCOVERY REQUESTS

The Plaintiff hereby withdraws Requests 1 through 5 of the prior discovery request served on Monday 3rd November 2025 at 6:47pm, without prejudice, in light of the filing of the Amended Discovery Requests served concurrently with this notice.

The remaining discovery request (no.6) remains unaffected.
 

Motion


IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
SUPPLEMENT TO PLAINTIFF’S MOTION TO COMPEL AND MOTION FOR SANCTIONS

The Plaintiff supplements the pending Motion to Compel as follows.

1. After the filing of the Motion to Compel, the Defendant served purported interrogatory responses.

2. Those responses remain non-responsive and obstructive.

3. In interrogatories:
- Interrogatory 1 and 2: the Defendant cites historic evictions that pre-date the most recent Government acquisition, and do not answer the reason for present Government retention. For the avoidance of doubt, the context of the request is the ownership of the properties as at 21 October 2025, when this suit was filed. Furthermore, these evictions would have brought the properties into GovDevelop ownership, not the ownership of DCGovernment.
- Interrogatory 3: the Defendant’s answer is facially evasive (“because the Government acquired ownership of these plots”).
- Interrogatory 4: the Defendant avoids answering the actual question (whether there is a policy of non-enforcement) and instead offers an irrelevant justification.
- Objection to Interrogatory 5 was untimely, as the objection was only made after the Motion to Compel was filed, and is therefore waived under Rule 4.8.


RELIEF RE-STATED
In light of the above, the Plaintiff renews and maintains the relief already sought, including sanctions, and asks the Court to grant the pending Motion to Compel in full.

 
PLAINTIFF’S PROVISIONAL WITNESS LIST

Pursuant to Rule 4.9

Witnesses:

jsrkiwi – Plaintiff
Testimony: Lay facts necessary to establish standing, including personal observations of government-owned properties, and the effect of DCT’s enforcement practices on the supply of property plots.

Katto - Secretary of the DCT
Testimony: Standard procedures for enforcement. Policy regarding selective enforcement or exemptions for government plots.

Kaiserin_ - current owner of s024
Testimony: How he came to own s024 when the property was government owned as at 21st October 2025, and no public auction of the property has taken place since 3rd August 2025.

An economist (expert witness), once one has been found who undertakes expert witness work
Testimony: Lay facts necessary to establish standing, including that any prolonged government ownership of property plots will have an impact upon market supply.
Expert witness fee disclosure: This witness will be paid $2,500 for their time giving expert testimony.

Any other government employee identified as relevant through discovery communications
 

Motion


PLAINTIFF’S MOTION TO RECUSE ATTORNEY GENERAL KAISERIN_ FROM OVERSIGHT OF THIS CASE

The Plaintiff respectfully moves this Honourable Court to order that Attorney General Kaiserin_ be excluded from overseeing, supervising, or otherwise exerting influence over this case, for the following reasons:

1. Kaiserin_, as Attorney General, is the direct superior of Defendant's counsel, and will be reviewing and overseeing the case.

2. Plaintiff intends to call Kaiserin_ as a witness regarding their ownership of s024. It is fundamentally inappropriate for them to supervise a case in which they are a material witness, as this could compromise their impartiality or the perception thereof.

RELIEF REQUESTED
Plaintiff respectfully requests that the Court:
1. Order Attorney General Kaiserin_ be recused from overseeing, supervising, discussing, or otherwise exercising influence over this case.
2. Grant any other relief the Court deems just and proper to ensure a fair and impartial proceeding.

 
Please stop posting motions at this time. I am going to place the court in recess from the time of the last post (not this post). I am at a conference IRL and will need time to review everything since this discovery is complex. If you need to make a response, please notify this court so I can approve the response.
 
I am going to work through the motions one by one.

The initial motion to compel & sanction + response:

jsrkiwi said:

Motion


IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
MOTION TO COMPEL AND MOTION FOR SANCTIONS

The Plaintiff, jsrkiwi, moves this Honourable Court for an order compelling the Defendant to comply with discovery requests and interrogatories, already served pursuant to Rules 4.7 and 4.8.

GROUNDS
1. Discovery is open.
2. The Plaintiff submitted discovery and interrogatory requests on Monday at 18:47 and 18:48.
3. No answers, no objections, no partial compliance have been served by the Defendant as of the filing of this motion (48 hours).
4. These discovery requests are directly linked to the Defendant’s pleaded defence (specifically their denial of selective enforcement and their position that the Property Standards Act does not create obligations). Without the documents and answers, the Plaintiff cannot prepare argument, cross, or witnesses, because the reasons for government retention and non‐eviction are exclusively held by the Defendant.

RELIEF REQUESTED
1. The Plaintiff respectfully seeks:
(a) An order compelling full production for requests 1 through 6 of the Plaintiff’s discovery request (filed Monday 18:47).
(b) An order compelling answers to all interrogatories 1 through 5 (filed Monday 18:48).
2. As the deadline of 48 hours for answering interrogatories (as per rule of procedure 4.8) has passed, the Court should rightfully impose sanctions upon the Defendant. The plaintiff politely suggests that the court ought to:
(a) strike the Defendant’s factual denials, given the Defendant’s ongoing refusal to disclose any factual basis for them, and that the case therefore proceed solely on the remaining questions of law;
(b) deny any objection to the discovery requests and interrogatory requests; and
(c) award costs for wasted time, calculated as $2,500 for additional work reasonably and necessarily caused solely by the Defendant’s non-compliance.

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gribble19 said:
Response to Plaintiff's Request for Discovery:
1. All documents and communications relating to the transfer of s024 into and out of government ownership.
2. All documents and communications relating to the transfer of r050 into and out of government ownership.
3. All documents and communications relating to the transfer of c155/c156/c157/c158 into government ownership.

The Defendant opposes requests 1, 2 and 3 as they are unclear and broad in the manner they are currently stated, which make them infeasible for the Defendant to comply with. If the Plaintiff could specify what communications they would be looking for and from where, the Defendant would be happy to comply with this request. For example, if the Plaintiff intended to mean internal government communications made within the DCT server that mention any of the above mentioned plots then that is something the Defendant would be happy to provide.


4. All communications of DCT employees within the past year, where government-owned properties were discussed.

The Defendant opposes this fourth request for two reasons.

Firstly, the Defendant does not have access to all communications of DCT employees. If DCT employees privately or publicly discuss something with other people that is not at all within the realm of reasonable information to request from the Defendant.

Furthermore, the information itself is also way too broad and irrelevant to this case. The DCT is the Department that builds government-owned properties. Even if this request was limited to discussion within the DCT server, requesting every single communication that was made in an entire year in that server regarding government owned properties would be an incredible amount of information that has nothing to do with this case at all and would be completely unreasonable.

5. All communications of DCT employees within the past year, where non-enforcement of policy in spite of a noted violation was discussed.

The Defendant opposes this request, both the response to the first three requests applies here, as well as the first reason given to oppose the fourth request. If the Plaintiff could clarify both a location (e.g. DCT server) and specific search term(s) they would be looking for that is specific and relevant then the Defendant would be happy to comply with this request.

6. All communications between the DCT and other government departments, where a DCT policy violation was discussed.

The Defendant agrees to this request. The Defendant intends to provide the requested informationto the best of their ability before the end of discovery.


Response to Plaintiff's Interrogatories:
1. Plot s024 was evicted as can be seen here
2. Plot r050 was evicted as can be seen here
3. Because the Government acquired ownership of these plots.
4. There is no such unwritten or unlisted policy, however it is common sense that certain eviction reasons would not apply to government plots (e.g. playtime requirements do not make sense for government accounts that are not actively played on)

To question 5 the Defendant makes the following Objection:

Objection


IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
OBJECTION - ASSUMES FACTS NOT IN EVIDENCE
This question assumes that the DCT actively does not enforce its own property standards against properties owned or controlled by the government, which is not a fact in evidence of this case.




Response to Plaintiff's Motion to Compel and Sanction:
Your Honor, the Defendant humbly apologizes for not being aware sooner of the interrogatories that were filed by Plaintiff and not responding to the Interrogatories within the timeline stated in the Court Rules and Procedure. Defendant hereby would like to ask for an extension to the deadlines stated in the Court Rules and Procedures to still allow for the response given in the section above to be taken into account by the Court. The Defendant would like to note that the Court Rules and Procedures were recently changed to add a stipulation that "Judicial Officers shall notify the respective party in a case whenever they are required to deliver a filling, argument, or statement. This includes Opening Statements, Closing Statements or any other submissions required by the court. Failure to notify may justify an extension of deadlines if a party can show that they were unaware of their turn." and that no prior notice was given by a Judicial Officer until the most recent notice and that Defendant has replied within the deadline set within this notice.

Considering the above, the Defendant respectfully requests that the court:
1. Does not grant Plaintiff's request for an order compelling full production for requests 1 through 5 of the Plaintiff’s discovery request, taking into account the Defendant's oppositional statements to those requests as made within this filing.

2. Does not grant Plaintiff's request for an order compelling full production for request 6 of the Plaintiff's discovery request, as the Defendant does not oppose it.

3. Does not grant Plaintiff's request for an order compelling answers to all interrogatories 1 through 5, as the Defendant has now either answered to or objected to all five interrogatories.

4. Does not grant any of the sanctions requested by the Plaintiff considering the previous lack of notice from a Judicial Officer and the fact that Defendant has now properly answered to all requests made within the deadline set by the Judicial Officer to respond to Plaintiff's motion.
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jsrkiwi said:
PLAINTIFF’S NOTICE OF PARTIAL WITHDRAWAL OF PRIOR DISCOVERY REQUESTS

The Plaintiff hereby withdraws Requests 1 through 5 of the prior discovery request served on Monday 3rd November 2025 at 6:47pm, without prejudice, in light of the filing of the Amended Discovery Requests served concurrently with this notice.

The remaining discovery request (no.6) remains unaffected.
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As I see it, discovery requests 1-5 have been withdrawn. Request no. 6. is as follows, "6. All communications between the DCT and other government departments, where a DCT policy violation was discussed." Defendant does not oppose this request, but requests that an order not be filed. Defendant also requests more time in discovery. We will get to that momentarily, but I will allow time for the Defendant to produce the material.

As for the interrogatories, questions 1-4 were answered. Question 5 was objected to. Question 5 is as follows: "Why does the DCT actively not enforce its own property standards against properties owned or controlled by the government?" This question was objected to under the following reasoning, "This question assumes that the DCT actively does not enforce its own property standards against properties owned or controlled by the government, which is not a fact in evidence of this case."

Interrogatories fall under rule 4.8. They have an automatic 24 hour time for objections. The wording is "must be made." The objection was lodged on Thursday (11/6/2025) at 7:36 PM (EST), which is three days after when the interrogatory was made. The objection was not made within 24 hours after the interrogatory was requested, and therefore it must be denied.

Defendant is requested to provide the interrogatory answer during the extension of discovery. Additionally due to a strong response from the defendant, I not be applying sanctions at this time.



Request to Extend Discovery:
gribble19 said:
Defendant hereby requests an extension of discovery for the following reasons:
- The matters discussed in the previous filing are still pending, and discovery is set to end in about 5 minutes.
- The Defendant needs some extra time to properly comply with the Discovery Request to which they agreed
- The Defendant thinks that the Plaintiff should have the opportunity to reword or refile their discovery requests in line with the problems raised by the Defendant in their previous filing, such that the Plaintiff can get the information they are looking for.
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jsrkiwi said:
PLAINTIFF’S NOTICE OF NO OBJECTION TO EXTENSION OF DISCOVERY

The Plaintiff does not object to an extension of discovery time.
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Granted. I am granting 120 hours of extra discovery in this matter.



Other issues:
jsrkiwi said:
PLAINTIFF’S SUPPLEMENTAL REQUEST FOR DISCOVERY

Pursuant to Rule 4.7, the Plaintiff requests the following from the Defendant:

1. Plot s024
All documents, messages, communications, or memos within DCT or other government department Discord servers or the DC forum containing the text “s024”, with a start date of after 5 August 2025 and limited to the period until 21 October 2025.

2. Plot r050
All documents, messages, communications, or memos within DCT or other government department Discord servers or the DC forum containing the text “r050”, with a start date of after 1 June 2025 and limited to the period until 21 October 2025.

3. Plots c155/c156/c157/c158
All documents, messages, communications, or memos within DCT or other government department Discord servers or the DC forum containing the text “c155”, “c156”, “c157”, or “c158”, with a start date of after 24 July 2025 and limited to the period until 21 October 2025.

4. DCT employee communications regarding government-owned properties
All documents, messages, communications, or memos within the DCT Discord server containing the text “DCGovernment”, with a start date of after 22 July 2025 and limited to the period until 21 October 2025.
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Noted. @gribble19, please post a response in the next 24 hours if you want to oppose this.

jsrkiwi said:

Motion


IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
SUPPLEMENT TO PLAINTIFF’S MOTION TO COMPEL AND MOTION FOR SANCTIONS

The Plaintiff supplements the pending Motion to Compel as follows.

1. After the filing of the Motion to Compel, the Defendant served purported interrogatory responses.

2. Those responses remain non-responsive and obstructive.

3. In interrogatories:
- Interrogatory 1 and 2: the Defendant cites historic evictions that pre-date the most recent Government acquisition, and do not answer the reason for present Government retention. For the avoidance of doubt, the context of the request is the ownership of the properties as at 21 October 2025, when this suit was filed. Furthermore, these evictions would have brought the properties into GovDevelop ownership, not the ownership of DCGovernment.
- Interrogatory 3: the Defendant’s answer is facially evasive (“because the Government acquired ownership of these plots”).
- Interrogatory 4: the Defendant avoids answering the actual question (whether there is a policy of non-enforcement) and instead offers an irrelevant justification.
- Objection to Interrogatory 5 was untimely, as the objection was only made after the Motion to Compel was filed, and is therefore waived under Rule 4.8.


RELIEF RE-STATED
In light of the above, the Plaintiff renews and maintains the relief already sought, including sanctions, and asks the Court to grant the pending Motion to Compel in full.

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Denied. The defendant answered questions 1-4 fine. They must still provide an answer to question 5 as stated above.

jsrkiwi said:
PLAINTIFF’S PROVISIONAL WITNESS LIST

Pursuant to Rule 4.9

Witnesses:

jsrkiwi – Plaintiff
Testimony: Lay facts necessary to establish standing, including personal observations of government-owned properties, and the effect of DCT’s enforcement practices on the supply of property plots.

Katto - Secretary of the DCT
Testimony: Standard procedures for enforcement. Policy regarding selective enforcement or exemptions for government plots.

Kaiserin_ - current owner of s024
Testimony: How he came to own s024 when the property was government owned as at 21st October 2025, and no public auction of the property has taken place since 3rd August 2025.

An economist (expert witness), once one has been found who undertakes expert witness work
Testimony: Lay facts necessary to establish standing, including that any prolonged government ownership of property plots will have an impact upon market supply.
Expert witness fee disclosure: This witness will be paid $2,500 for their time giving expert testimony.

Any other government employee identified as relevant through discovery communications
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Noted. Though I am informing you that you need to establish who the witness is. If I don't know by the end of discovery, they will not be called.

jsrkiwi said:

Motion


PLAINTIFF’S MOTION TO RECUSE ATTORNEY GENERAL KAISERIN_ FROM OVERSIGHT OF THIS CASE

The Plaintiff respectfully moves this Honourable Court to order that Attorney General Kaiserin_ be excluded from overseeing, supervising, or otherwise exerting influence over this case, for the following reasons:

1. Kaiserin_, as Attorney General, is the direct superior of Defendant's counsel, and will be reviewing and overseeing the case.

2. Plaintiff intends to call Kaiserin_ as a witness regarding their ownership of s024. It is fundamentally inappropriate for them to supervise a case in which they are a material witness, as this could compromise their impartiality or the perception thereof.

RELIEF REQUESTED
Plaintiff respectfully requests that the Court:
1. Order Attorney General Kaiserin_ be recused from overseeing, supervising, discussing, or otherwise exercising influence over this case.
2. Grant any other relief the Court deems just and proper to ensure a fair and impartial proceeding.

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Denied. Just because the witness is hostile to your interests in this case is not a grounds for recusal. I am also unaware of any mechanism beyond a COI (which this situation does not fall under) that would be cause for a lawyer to be forcibly recused by a judge.



To reiterate, I am granting 120 hours of extra discovery. There is new supplemental 4.7 requests and an interrogatory that needs resolution.
 
We're a little more than 12 hours away of the end of extended discovery. I am going to assume both sides have been busy and forgot about this case, so I will extend discovery another 72 hours. I would like to avoid a bunch of motions regarding failure to comply/sanctions if possible because I have a busy week ahead of me, so please try to work amongst yourselves to get the material needed so we can proceed with opening statements.
 
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