Lawsuit: In Session jsrkiwi v Department of Homeland Security [2025] DCR 93

J

jsrkiwi

Citizen
Homeland Security Department
Commerce Department
Supporter
jsrkiwi
jsrkiwi
Police Officer
Joined
Aug 27, 2025
Messages
85

Case Filing


IN THE DISTRICT COURT OF THE COMMONWEALTH OF REDMONT

CIVIL ACTION

jsrkiwi
Plaintiff

v.

Department of Homeland Security
Defendant

COMPLAINT
The Plaintiff complains against the Defendant as follows:

WRITTEN STATEMENT FROM THE PLAINTIFF

The Department of Homeland Security issued multiple trespass fines against the Plaintiff without evidence of lawful prior instructions. The decision is unlawful, procedurally unfair, unsupported by evidence, and has resulted in an unjust fine and an improper criminal record entry. The Plaintiff seeks to have the decision overturned and the record cleared.

Beyond the findings against the Plaintiff personally, this case addresses a recurring defect in DHS enforcement. Multiple citizens have been charged with trespass on the basis of the same “ban-list book” method used by the citizen complainant, Vernicia. Each of those cases suffers from identical procedural failures: no proof of service of non-trespass instructions, no confirmation that the accused ever received any instructions, and no evidence establishing when the alleged notice was created. These errors are systemic, not isolated, and I therefore seek relief that corrects my own charges and any other trespass findings that relied solely on this same unlawful evidentiary practice.
Click to expand...

I. PARTIES
1. jsrkiwi: Plaintiff, a citizen subject to DHS enforcement actions.
2. Department of Homeland Security: Defendant, the government body responsible for determining guilt for summary criminal offences, arresting and imprisoning criminals, issuing fines and record entry challenged in this action.
3. Plaintiff also challenges a broader DHS pattern of issuing trespass charges based on the same defective “ban-list book” method. Additional affected individuals will be added to the witness list as discovery proceeds.
4. Vernicia: Witness, citizen complainant in all relevant trespass cases and creator of the “ban-list books” forming the basis of the charges challenged in this action.
5. Goldendude15: Witness, the Police Officer who handled the complaint by Vernicia, created the criminal record, and fined the Plaintiff.
6. Roryyy_: Witness, Secretary of the Department of Homeland Security.

II. FACTS
1. On 13th November 2025, the Department of Homeland Security (DHS) created a criminal record for the Plaintiff, listing five trespass offences at locations c108 and c995.
2. On 13th November 2025 at 10:37 UTC, the Plaintiff was fined $2,900 for ‘Trespass x5 (First, Second, and Subsequent charges)’; and a wanted point was created for 35 minutes imprisonment.
3. The supporting evidence for the criminal record was five screenshots provided by Vernicia through ticket dhs-25341. These screenshots show:
(i) Sales records showing the sale of coal blocks by the Plaintiff to Vernicia at ‘14h24m ago’;
(ii) The third page of the book outside of one of the entrances to c995. The page is titled ‘ban list’, and the name of the Plaintiff is listed on the third line from the bottom;
(iii) Sales records showing the sale of 27 iron blocks at ‘1d11h23m ago; 300 coal blocks by the Plaintiff to Vernicia at ‘1d12h38m ago’; and the sale of 960 coal by the Plaintiff to Vernicia at ‘1d12h40m ago’.
(iv) Sales records showing the sale of 65 redstone blocks by the Plaintiff to MZCD at ‘11-11-2025 17:13:50’; the sale of 64 redstone by the Plaintiff to MZCD at ‘11-11-2025 17:13:39’; the sale of 66 lapis blocks by the Plaintiff to MZCD at ‘11-11-2025 17:13:30’; and the sale of 116 lapis lazuli by the Plaintiff to MZCD at ‘11-11-2025 17:13:07’.
(v) Sales records showing the sale of 3 iron blocks to MZCD at ‘11-11-2025 16:47:02’.
4. Only one screenshot includes a timestamp: 13 November 2025 at 05:12 (CET). Two others show indirect metadata; two show none.
5. No evidence is held by the DHS that the book outside c995 was updated to include the Plaintiff’s name prior to the Plaintiff transacting on the plots.
6. No instructions or notice banning the Plaintiff from a property has ever been served upon the Plaintiff by Vernicia. The Plaintiff had no reason to believe that he was banned from entering plots c108 or c995.
7. Plaintiff accessed both properties c108 and c995 exclusively by warp (‘/home vernicia’ and ‘/home mzcd’) and did not walk through the entrance, meaning the book shown in the second screenshot was never visible to him.
8. The property owner (Vernicia) has personally observed Plaintiff warping into c995 before and therefore knew Plaintiff would not see any book.
9. The books outside c108 and c995 do not specify what the ban relates to.
10. Plaintiff has knowledge from his work as a Police Trainee of the existence several other individuals who were charged with trespass at properties owned or controlled by the same private citizen, Vernicia.
11. In each of these cases, the method of ‘instruction’ was identical: reliance on a book placed at the property entrance, with no proof of service and no confirmation that the accused ever saw it.
12. In each of these cases, the ‘proof’ used by the DHS to support the conviction of Trespass is identical: a screenshot of the book showing the accused’s name, and a screenshot showing sales records. In each case, there is no evidence that any instruction was properly served by Vernicia to any of the accused individuals, or that the book was updated prior to the sales taking place.
13. The similarity of fact patterns across multiple cases indicates that DHS applied an unofficial, and unlawful low standard specifically when handling trespass complaints originating from Vernicia.
14. At 14:37 UTC on 13th November 2025, The Plaintiff attempted to dispute the charges through a government ticket (dhs-25445). As of 72 hours later, the DHS had not responded to the ticket and the decision remained uncorrected. At 15:47 UTC on 16th November 2025, with the ticket having become the oldest charge-dispute ticket on the DHS tickets list, the Plaintiff closed the ticket, and now files this action.

III. CLAIMS FOR RELIEF
1. Under the Criminal Code, a person commits the offence of Trespass if the person enters or remains in a non-public or restricted area against instructions’; or ‘is a landlord and enters a tenant's region without reasonable prior notice, unless an exemption applies’.
2. The ‘ban-list’ book relied upon by DHS does not constitute a valid instruction under any reasonable interpretation of the Criminal Code, as it provides no description of the conduct prohibited, no proof of service, and no confirmation that the Plaintiff ever received or could have received the alleged notice.
3. Even if the book were capable of constituting a lawful instruction, DHS possesses no evidence that the book was updated to include the Plaintiff’s name prior to his entry into plots c108 and c995, rendering any alleged instruction void for lack of temporal proof.
4. DHS acted arbitrarily and capriciously by issuing criminal findings without any reliable evidence that valid instructions were ever given, and by treating a book placed at an entrance, which the Plaintiff never uses, as if it constituted proper notice, despite there being no proof of service or receipt.
5. DHS relied on ambiguous evidence, as the ‘ban list’ book does not state what the ban relates to, making it legally insufficient to constitute a criminal instruction.
6. DHS therefore violated the administrative due-process principles applicable to agency decisions and exceeded its lawful authority.
7. DHS has engaged in selective enforcement, as demonstrated by multiple individuals being found guilty for Trespass, reliant on identical fact patterns linked to the same citizen complainant, indicating the presence of an unlawful or improperly supervised internal practice.
8. The systemic nature of the problem justifies class-wide administrative relief, as all individuals previously charged using the same defective evidence suffered the same due-process violation.

IV. PRAYER FOR RELIEF
The Plaintiff seeks the following from the Defendant:
1. An order vacating in full the DHS trespass decision against the Plaintiff, and reversing all findings of guilt;
2. An order expunging any related criminal record entry;
3. A refund of $2,900 for the fine imposed against the Plaintiff;
4. A declaration that ‘ban list’ books do not constitute lawful instructions for the purposes of the crime of Trespass, unless properly served to the individual;
6. An order requiring DHS to vacate all prior trespass findings in which the only evidence of ‘instruction’ was a book placed at a property entrance owned or controlled by Vernicia.
7. An order compelling DHS to review and reform its evidentiary and notice standards to prevent recurrence of these unlawful practices.
8. A declaration that DHS’s historical acceptance of these methods constitutes procedural unfairness affecting multiple citizens.
9. Legal fees of $2,000.

V. EVIDENCE ATTACHED
P-001. Criminal record of jsrkiwi (obtained from the DHS).
P-002. Government ticket DHS-25445, through which the Plaintiff attempted to appeal his Trespass conviction.
P-003, P-004, P-005, P-006, P-007. The screenshots that are included as evidence in the criminal record (P-001).
P-009, P-010, P-011, P-012, P-013. Screenshots showing the content of the ‘ban list’ book outside c995, at 16:15 UTC on 13th November 2025.
P-014, P-015, P-016, P-017, P-018. Screenshots showing the content of the ‘ban list’ book outside c108, at 16:18 UTC on 13th November 2025.
P-019, P-020. Screenshots showing the placement of book outside c995.
P-021, P-022. Screenshots showing the placement of the ‘ban list’ book outside c108.

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 16th day of November 2025

 

Attachments

  • P-001.pdf
    P-001.pdf
    3.2 MB · Views: 38
  • P-002.pdf
    P-002.pdf
    797.9 KB · Views: 40
  • P-003.png
    P-003.png
    521.9 KB · Views: 38
  • P-004.png
    P-004.png
    392 KB · Views: 36
  • P-005.png
    P-005.png
    582.4 KB · Views: 34
  • P-006.png
    P-006.png
    975.3 KB · Views: 38
  • P-010.png
    P-010.png
    369.9 KB · Views: 71
  • P-009.png
    P-009.png
    370.2 KB · Views: 69
  • P-007.png
    P-007.png
    683.4 KB · Views: 33
  • P-011.png
    P-011.png
    370.1 KB · Views: 67
  • P-012.png
    P-012.png
    370.4 KB · Views: 63
  • P-015.png
    P-015.png
    675 KB · Views: 67
  • P-014.png
    P-014.png
    676.1 KB · Views: 68
  • P-013.png
    P-013.png
    371.7 KB · Views: 67
  • P-016.png
    P-016.png
    676 KB · Views: 66
  • P-017.png
    P-017.png
    678 KB · Views: 52
  • P-018.png
    P-018.png
    678.7 KB · Views: 55
  • P-019.png
    P-019.png
    707.4 KB · Views: 29
  • P-020.png
    P-020.png
    922.1 KB · Views: 30
  • P-021.png
    P-021.png
    665.1 KB · Views: 33
  • P-022.png
    P-022.png
    1.3 MB · Views: 43
Last edited by a moderator:

Motion


IN THE DISTRICT COURT OF THE COMMONWEALTH OF REDMONT

EMERGENCY MOTION FOR INTERIM ORDER BARRING ARREST AND IMPRISONMENT OF THE PLAINTIFF PENDING RESOLUTION OF THIS ACTION

The Plaintiff respectfully moves this Court, on an emergency basis, for an immediate interim order prohibiting the Department for Homeland Security (“DHS”) from arresting and imprisoning the Plaintiff until the final disposition of this civil action.

1. The DHS has issued a criminal record entry and imposed a custodial penalty of 35 minutes’ imprisonment arising from the trespass findings currently under challenge in this proceeding.
2. The validity of those findings is the direct subject of this litigation, and the Plaintiff seeks their full vacatur.
3. Executing any term of imprisonment before the Court has determined the lawfulness of the charges would irreparably prejudice the Plaintiff, as the harm of an imposed custodial sentence cannot be reversed once carried out.
4. The Plaintiff has acted in good faith by filing this action promptly after the DHS failed to address the dispute ticket (DHS-25445), and the matter is now properly before the Court.
5. Interim relief is necessary to preserve the Court’s ability to grant effective final relief and to prevent the Plaintiff from suffering an irreversible penalty in respect of charges that may be found unlawful.
6. The requested order imposes no prejudice on the Defendant, as it merely maintains the status quo until the Court adjudicates the underlying dispute.

RELIEF REQUESTED
The Plaintiff therefore respectfully requests that the Court issue an order:
1. Prohibiting the DHS from arresting or imposing any custodial sentence upon the Plaintiff arising from the trespass findings currently under challenge; and
2. Maintaining this prohibition until final judgment is entered in this case.

 

Writ of Summons

@Attorney General , is required to appear before the District Court in the case of jsrkiwi v Department of Homeland Security [2025] DCR 93

In the interest of more efficient Courtroom proceedings, the Court will permit responses to motions without prior Court permission. The deadline for said motions shall be 48 hours.

Furthermore, in obedience with Rule 1.4, parties are advised that engaging in conduct that obstructs or interferes with the administration of this Court or its proceedings may be held in Contempt of Court.


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.

 
jsrkiwi said:

Motion


IN THE DISTRICT COURT OF THE COMMONWEALTH OF REDMONT

EMERGENCY MOTION FOR INTERIM ORDER BARRING ARREST AND IMPRISONMENT OF THE PLAINTIFF PENDING RESOLUTION OF THIS ACTION

The Plaintiff respectfully moves this Court, on an emergency basis, for an immediate interim order prohibiting the Department for Homeland Security (“DHS”) from arresting and imprisoning the Plaintiff until the final disposition of this civil action.

1. The DHS has issued a criminal record entry and imposed a custodial penalty of 35 minutes’ imprisonment arising from the trespass findings currently under challenge in this proceeding.
2. The validity of those findings is the direct subject of this litigation, and the Plaintiff seeks their full vacatur.
3. Executing any term of imprisonment before the Court has determined the lawfulness of the charges would irreparably prejudice the Plaintiff, as the harm of an imposed custodial sentence cannot be reversed once carried out.
4. The Plaintiff has acted in good faith by filing this action promptly after the DHS failed to address the dispute ticket (DHS-25445), and the matter is now properly before the Court.
5. Interim relief is necessary to preserve the Court’s ability to grant effective final relief and to prevent the Plaintiff from suffering an irreversible penalty in respect of charges that may be found unlawful.
6. The requested order imposes no prejudice on the Defendant, as it merely maintains the status quo until the Court adjudicates the underlying dispute.

RELIEF REQUESTED
The Plaintiff therefore respectfully requests that the Court issue an order:
1. Prohibiting the DHS from arresting or imposing any custodial sentence upon the Plaintiff arising from the trespass findings currently under challenge; and
2. Maintaining this prohibition until final judgment is entered in this case.

Click to expand...


Court Order


IN THE DISTRICT COURT OF THE COMMONWEALTH OF REDMONT
TEMPORARY INJUNCTION - WRIT OF MANDAMUS


Until such a time an Order is given from this Court, the Department of Homeland Security is enjoined from arresting p:jsrkiwi on the Offense of Trespass entered on 13th November, 2025; If there be a discrepancy between the time in the Complaint and the local time of any DHS official, the record entered by Goldendude15 shall not be made effective. This Order does not bar DHS from enforcing any other law nor offense undertaken by Plaintiff.

This order applies to all Law Enforcement Officers of the Department of Homeland Security. If Plaintiff is arrested after 17:14 EST on November 16th, 2025, the Court will use its contempt powers.

So ordered,
Magistrate Mug.


 
Muggy21 said:

Writ of Summons

@Attorney General , is required to appear before the District Court in the case of jsrkiwi v Department of Homeland Security [2025] DCR 93

In the interest of more efficient Courtroom proceedings, the Court will permit responses to motions without prior Court permission. The deadline for said motions shall be 48 hours.

Furthermore, in obedience with Rule 1.4, parties are advised that engaging in conduct that obstructs or interferes with the administration of this Court or its proceedings may be held in Contempt of Court.


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.

Click to expand...
Your Honor,

I am present on behalf of the Commonwealth.
 
Muggy21 said:

Court Order


IN THE DISTRICT COURT OF THE COMMONWEALTH OF REDMONT
TEMPORARY INJUNCTION - WRIT OF MANDAMUS


Until such a time an Order is given from this Court, the Department of Homeland Security is enjoined from arresting p:jsrkiwi on the Offense of Trespass entered on 13th November, 2025; If there be a discrepancy between the time in the Complaint and the local time of any DHS official, the record entered by Goldendude15 shall not be made effective. This Order does not bar DHS from enforcing any other law nor offense undertaken by Plaintiff.

This order applies to all Law Enforcement Officers of the Department of Homeland Security. If Plaintiff is arrested after 17:14 EST on November 16th, 2025, the Court will use its contempt powers.

So ordered,
Magistrate Mug.


Click to expand...

Motion


IN THE DISTRICT COURT OF THE COMMONWEALTH OF REDMONT
MOTION TO RECONSIDER

Your Honor,

The order is a bit tricky to enforce; I can ping everyone in the DHS to see if they got the message, but I worry that someone may miss a ping or just have a lapse of mind.

To prevent a lapse of mind or otherwise, the Commonweallth would ask that the DHS directed to do as follows:

  1. Archive the existing crime record, removing the wanted star.
  2. At the conclusion of the case, the DHS may create a new crime record for the trespass unless the Court orders otherwise.
This would remove the wanted star for the duration of the case, which would make it so that the individual does not appear wanted to DHS officers. At the end of the case, the DHS would be permitted to create the wanted point anew, thereby allowing us to enforce the imprisonment at an appropriate time absent an order from Your Honor.


 
Last edited:
Franciscus said:

Motion


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

Your Honor,

The order is a bit tricky to enforce; I can ping everyone in the DHS to see if they got the message, but I worry that someone may miss a ping or just have a lapse of mind.

To prevent a lapse of mind or otherwise, the Commonweallth would ask that the DHS directed to do as follows:

  1. Archive the existing crime record, removing the wanted star.
  2. At the conclusion of the case, the DHS may create a new crime record for the trespass unless the Court orders otherwise.
This would remove the wanted star for the duration of the case, which would make it so that the individual does not appear wanted to DHS officers. At the end of the case, the DHS would be permitted to create the wanted point anew, thereby allowing us to enforce the imprisonment at an appropriate time absent an order from Your Honor.


Click to expand...

That's fine, I'll amend my order to DHS to the above.
 

Motion


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

Your Honor,

The Commonwealth seeks to dismiss the eighth alleged claim for relief on the basis of Rule 5.5 (Lack of Claim) and Rule 5.12 (Lack of Personal Jurisdiction).

jsrkiwi said:
III. CLAIMS FOR RELIEF

...

8. The systemic nature of the problem justifies class-wide administrative relief, as all individuals previously charged using the same defective evidence suffered the same due-process violation.

IV. PRAYER FOR RELIEF
The Plaintiff seeks the following from the Defendant:

...

6. An order requiring DHS to vacate all prior trespass findings in which the only evidence of ‘instruction’ was a book placed at a property entrance owned or controlled by Vernicia.
Click to expand...

1. So-called "class-wide administrative relief" involving unnamed parties fails to state a claim for relief under the law.​

In the eighth alleged claim for relief, which is quoted above, the Plaintiff is seeking "class-wide administrative relief", praying that the which the DHS be ordered to vacate "all prior trespass findings" of unnamed parties that were created from a particular evidentiary pattern.

There is not statute that permits this, nor may the Courts grant it. The Federal Court has been fairly unequivocal about this.

1a. The Courts cannot grant class-wide administrative relief without an enabling statute present.​

Can Courts grant class-wide administrative relief without enabling legislation? The Federal Court has been clear: No.

As the Federal Court has noted in Privacy Matters v. Nexalin [2025] FCR 36: "Establishing a procedure robust enough to handle a class of people in a lawsuit would be substantial to a point of encroaching upon the powers of the legislative. See Constitution § 2(1)."

In other words: if we are going to have lawsuits that grant class-wide relief that affects people other than named parties, the legislature would need to act. It would be unconstitutional for the Court to create, as a matter of common law or otherwise, some sort of class action procedure to grant relief to anyone other than the named plaintiffs.

As the Federal Court has appeallate jurisdiction over the District Court, and also has original jurisdiction over questions of constitutionality (see: Article 18 of the Constitution), this precedent on constitutionality binds the District Court.

1b. No applicable statutory authority exists for class-wide administrative relief.​

Does statutory authority exist in this context for class-wide administrative relief? The answer is clear: No.

As the Federal Court noted in Privacy Matters v. Nexalin [2025] FCR 36 "[t]here is no statutory authorization for establishing 'classes' of people in a case". While multiple Plaintiffs may join themselves together to file against a defendant as if they were one single entity, there is no means to certify a broad class present in the law - no class action procedure exists in statute that would apply here.

The Plaintiff has not asserted a statute which permits them to seek class-wide administrative relief, and the Commonwealth cannot find one. There is one Plaintiff here, not many; the only claims for relief that the Plaintiff may seek are redress for actions which have harmed the Plaintiff. Absent a contrary showing, the Court should find that no claim for relief here arises from statutory text.

2. The Plaintiff lacks personal jurisdiction to seek class-wide administrative relief.​

Standing, in Redmont, is a three point test defined under Court Rule 2.1. As summarized by the Supreme Court in ToadKing v. Commonwealth of Redmont [2025] SCR 19:

Standing consists of three elements. First, the individual must have suffered an injury caused by a clearly identifiable second party or affected by an application of law. Second, the cause of the injury must be unlawful. Third, the injury must be capable of being remedied by a favorable decision under the relevant law.
Click to expand...

The Plaintiff fails to meet the first element of standing as it pertains to the eighth prayer for relief. Simply put: the Plaintiff does not suffer injury when unnamed third parties are charged with trespass, and is not affected by an application of the law when unnamed third parties are charged with trespass. The Plaintiff therefore lacks standing for such a broad prayer for relief as it pertains to unnamed third parties, warranting dismissal of the claim under Rule 5.12.

3. Conclusion: The District Court should dismiss the eighth claim for relief and its associated prayers.​

Under Rule 5.5, "failure to state a claim for relief" may warrant dismissal. As noted above, a statutory authorization would be required for class-wide administrative relief to be granted, but no such authority exists in statute. The eighth claim for relief lacks legal basis under the law, and should be dismissed on this basis.

Separately, under Rule 5.12, dismissal is warranted when "the plaintiff fails to have sufficient standing in order to pursue the case". As established above, the Plaintiff fails the first prong of the standing test under Rule 2.1 as it pertains to claims for relief on behalf of unnamed third parties; this independently warrants dismissal of the claim.

Therefore, the defense humbly prays that this Court strike the eighth claim for relief, as well as any prayers for relief which rest wholly thereupon.

 
Last edited:

Motion


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

Your honor,

The defense requests leave to:

  1. Amend filings erroneously formatted as if they were in the Federal Court to state that they were filed in the District Court; and
  2. To remove a stray quotation mark in the second paragraph of MTD argument 1b and fix associated italics.

 
Franciscus said:

Motion


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

Your Honor,

The Commonwealth seeks to dismiss the eighth alleged claim for relief on the basis of Rule 5.5 (Lack of Claim) and Rule 5.12 (Lack of Personal Jurisdiction).

1. So-called "class-wide administrative relief" involving unnamed parties fails to state a claim for relief under the law.​

In the eighth alleged claim for relief, which is quoted above, the Plaintiff is seeking "class-wide administrative relief", praying that the which the DHS be ordered to vacate "all prior trespass findings" of unnamed parties that were created from a particular evidentiary pattern.

There is not statute that permits this, nor may the Courts grant it. The Federal Court has been fairly unequivocal about this.

1a. The Courts cannot grant class-wide administrative relief without an enabling statute present.​

Can Courts grant class-wide administrative relief without enabling legislation? The Federal Court has been clear: No.

As the Federal Court has noted in Privacy Matters v. Nexalin [2025] FCR 36: "Establishing a procedure robust enough to handle a class of people in a lawsuit would be substantial to a point of encroaching upon the powers of the legislative. See Constitution § 2(1)."

In other words: if we are going to have lawsuits that grant class-wide relief that affects people other than named parties, the legislature would need to act. It would be unconstitutional for the Court to create, as a matter of common law or otherwise, some sort of class action procedure to grant relief to anyone other than the named plaintiffs.

As the Federal Court has appeallate jurisdiction over the District Court, and also has original jurisdiction over questions of constitutionality (see: Article 18 of the Constitution), this precedent on constitutionality binds the District Court.

1b. No applicable statutory authority exists for class-wide administrative relief.​

Does statutory authority exist in this context for class-wide administrative relief? The answer is clear: No.

As the Federal Court noted in Privacy Matters v. Nexalin [2025] FCR 36 "[t]here is no statutory authorization for establishing 'classes' of people in a case". While multiple Plaintiffs may join themselves together to file against a defendant as if they were one single entity, there is no means to certify a broad class present in the law - no class action procedure exists in statute that would apply here."

The Plaintiff has not asserted a statute which permits them to seek class-wide administrative relief, and the Commonwealth cannot find one. There is one Plaintiff here, not many; the only claims for relief that the Plaintiff may seek are redress for actions which have harmed the Plaintiff (see, for example . Absent a contrary showing, the Court should find that no claim for relief here arises from statutory text.

2. The Plaintiff lacks personal jurisdiction to seek class-wide administrative relief.​

Standing, in Redmont, is a three point test defined under Court Rule 2.1. As summarized by the Supreme Court in ToadKing v. Commonwealth of Redmont [2025] SCR 19:



The Plaintiff fails to meet the first element of standing as it pertains to the eighth prayer for relief. Simply put: the Plaintiff does not suffer injury when unnamed third parties are charged with trespass, and is not affected by an application of the law when unnamed third parties are charged with trespass. The Plaintiff therefore lacks standing for such a broad prayer for relief as it pertains to unnamed third parties, warranting dismissal of the claim under Rule 5.12.

3. Conclusion: The District Court should dismiss the eighth claim for relief and its associated prayers.​

Under Rule 5.5, "failure to state a claim for relief" may warrant dismissal. As noted above, a statutory authorization would be required for class-wide administrative relief to be granted, but no such authority exists in statute. The eighth claim for relief lacks legal basis under the law, and should be dismissed on this basis.

Separately, under Rule 5.12, dismissal is warranted when "the plaintiff fails to have sufficient standing in order to pursue the case". As established above, the Plaintiff fails the first prong of the standing test under Rule 2.1 as it pertains to claims for relief on behalf of unnamed third parties; this independently warrants dismissal of the claim.

Therefore, the defense humbly prays that this Court strike the eighth claim for relief, as well as any prayers for relief which rest wholly thereupon.

Click to expand...
IN THE DISTRICT COURT OF THE COMMONWEALTH OF REDMONT

RESPONSE TO MOTION TO DISMISS

Your Honour,
The Plaintiff submits this response opposing the Commonwealth’s Motion to Dismiss.

The motion to dismiss misunderstands the nature of the eighth claim. Although the Complaint used the phrase “class-wide administrative relief,” the Plaintiff is not seeking class action damages, but a straightforward order directing DHS to correct unlawful administrative decisions made under an unlawful policy. This is something well within the Court’s ordinary remedial authority once a policy is declared unlawful.

I. THE PLAINTIFF’S REFERENCE TO “CLASS-WIDE ADMINISTRATIVE RELIEF” DOES NOT INVOKE A CLASS ACTION
1. Your Honour, in the Complaint, the Plaintiff used the phrase “class-wide administrative relief.” The Commonwealth now treats that phrase as if the Plaintiff were attempting to certify a class, litigate on behalf of unnamed individuals, or obtain damages for persons not before the Court.
2. That is not what the Plaintiff meant, nor what the filing actually seeks.
3. The point of the eighth claim is this:
  1. DHS adopted an unwritten de facto evidentiary policy, allowing Trespass findings without proper proof of “instruction”.
  2. That policy applied systemically and repeatedly, affecting the Plaintiff and many others in the same manner.
  3. If the Court holds the policy unlawful, it necessarily follows that DHS must be ordered to reverse its past administrative actions into compliance with the law.
  4. Directing DHS to correct its own unlawful decisions is not a class action, does not require statutory class-action authority, and does not require the Plaintiff to possess standing on behalf of others.
4. “Class-wide administrative relief” in the Complaint simply refers to the scope of the agency’s corrective duty once the Court has ruled on the legality of its policy, not the creation of a class of litigants.

II. RULE 5.5 DOES NOT APPLY: THE EIGHTH CLAIM STATES A VALID BASIS FOR JUDICIAL REVIEW AND ADMINISTRATIVE CORRECTION
1. Rule 5.5 addresses failure to state a claim. The claim does state one:
  • The Plaintiff alleges an unlawful DHS policy.
  • The Plaintiff seeks a declaration of unlawfulness.
  • The Plaintiff seeks an order requiring DHS to correct administrative decisions that flowed from that policy.
2. Courts routinely issue orders directing government agencies to rescind, vacate, or correct unlawful administrative acts after a legal defect in the underlying policy is established. There is nothing incoherent or unrecognisable about this remedy.
3. The Defence’s argument incorrectly assumes that any relief benefiting more than one person is automatically a “class action” requiring express statutory authorisation. That is simply not true. Administrative correction is not a class action procedure.

III. RULE 5.12 DOES NOT BAR THE CLAIM: THE PLAINTIFF’S STANDING IS BASED SOLELY ON HIS OWN UNLAWFUL TRESPASS FINDING
1. Standing requires:
  1. An injury to the Plaintiff by the Defendant;
  2. Caused by unlawful conduct; and
  3. Remediable by the Court.
2. All three are satisfied. The Plaintiff’s injury is his own Trespass conviction under the DHS policy. That establishes standing to challenge the policy’s legality.
3. The Commonwealth’s argument incorrectly suggests the Plaintiff must have standing on behalf of other individuals for the Court to direct DHS to correct its administrative record. But that is not how judicial review works. Once standing exists to challenge the policy:
  • The Court may craft appropriate remedies for the illegality it finds, including directing an agency to correct the structural consequences of that illegality.
  • This does not require the Plaintiff to rely on injuries suffered by others.
  • It simply recognises that an agency’s unlawful policy cannot remain in force for some people but not others once declared unlawful.
4. The Plaintiff is not asserting standing for third-party claims. He asserts standing for his own claim, and the remedy flows from the Court’s supervisory power over an executive agency.

IV. PRIVACY MATTERS V. NEXALIN [2025] FCR 36 IS DISTINGUISHABLE
1. The Commonwealth relies heavily on Privacy Matters V. Nexalin [2025] FCR 36 (hereinafter referred to as ‘Nexalin’), but that case is fundamentally different.
2. In Nexalin, the Court refused to award damages to unnamed individuals in a putative class action, emphasising that “establishing a procedure robust enough to handle a class of people in a lawsuit would be substantial to a point of encroaching upon the powers of the legislative.”
3. Nexalin involved six named plaintiffs plus 116 additional affected individuals, sought damages for all users, and the Court held there was no statutory mechanism for such broad relief.
4. In this action, the Plaintiff seeks:
  • No damages for anyone other than the Plaintiff.
  • No compensation to unnamed individuals.
5. The Plaintiff asks solely that DHS reverse its own unlawful administrative decisions, which is a normal form of administrative remedy.
6. Nexalin limits damages to named plaintiffs. It does not limit a Court’s power to order a government agency to bring its past actions into compliance with the law.

V. POLICY ARGUMENT
1. If the Commonwealth’s view were correct, then:
  • Even the most egregiously unlawful government policy would permanently stain hundreds of citizens’ records;
  • Only litigants with the time and resources to individually sue would ever receive relief;
  • Unequal treatment would become baked into the system purely because an agency broke the law on too large a scale.
2. Citizens are entitled to assume DHS follows the law. When DHS does not, the law must provide a mechanism to repair the systemic consequences.
3. Refusing such relief would incentivise agencies to violate the law more broadly, since widespread illegality would make their actions harder to correct.

For these reasons, the Plaintiff respectfully requests that the Motion to Dismiss be denied in full.
 
Franciscus said:

Motion


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

Your honor,

The defense requests leave to:

  1. Amend filings erroneously formatted as if they were in the Federal Court to state that they were filed in the District Court; and
  2. To remove a stray quotation mark in the second paragraph of MTD argument 1b and fix associated italics.

Click to expand...
Granted
 
jsrkiwi said:
IN THE DISTRICT COURT OF THE COMMONWEALTH OF REDMONT

RESPONSE TO MOTION TO DISMISS

Your Honour,
The Plaintiff submits this response opposing the Commonwealth’s Motion to Dismiss.

The motion to dismiss misunderstands the nature of the eighth claim. Although the Complaint used the phrase “class-wide administrative relief,” the Plaintiff is not seeking class action damages, but a straightforward order directing DHS to correct unlawful administrative decisions made under an unlawful policy. This is something well within the Court’s ordinary remedial authority once a policy is declared unlawful.

I. THE PLAINTIFF’S REFERENCE TO “CLASS-WIDE ADMINISTRATIVE RELIEF” DOES NOT INVOKE A CLASS ACTION
1. Your Honour, in the Complaint, the Plaintiff used the phrase “class-wide administrative relief.” The Commonwealth now treats that phrase as if the Plaintiff were attempting to certify a class, litigate on behalf of unnamed individuals, or obtain damages for persons not before the Court.
2. That is not what the Plaintiff meant, nor what the filing actually seeks.
3. The point of the eighth claim is this:
  1. DHS adopted an unwritten de facto evidentiary policy, allowing Trespass findings without proper proof of “instruction”.
  2. That policy applied systemically and repeatedly, affecting the Plaintiff and many others in the same manner.
  3. If the Court holds the policy unlawful, it necessarily follows that DHS must be ordered to reverse its past administrative actions into compliance with the law.
  4. Directing DHS to correct its own unlawful decisions is not a class action, does not require statutory class-action authority, and does not require the Plaintiff to possess standing on behalf of others.
4. “Class-wide administrative relief” in the Complaint simply refers to the scope of the agency’s corrective duty once the Court has ruled on the legality of its policy, not the creation of a class of litigants.

II. RULE 5.5 DOES NOT APPLY: THE EIGHTH CLAIM STATES A VALID BASIS FOR JUDICIAL REVIEW AND ADMINISTRATIVE CORRECTION
1. Rule 5.5 addresses failure to state a claim. The claim does state one:
  • The Plaintiff alleges an unlawful DHS policy.
  • The Plaintiff seeks a declaration of unlawfulness.
  • The Plaintiff seeks an order requiring DHS to correct administrative decisions that flowed from that policy.
2. Courts routinely issue orders directing government agencies to rescind, vacate, or correct unlawful administrative acts after a legal defect in the underlying policy is established. There is nothing incoherent or unrecognisable about this remedy.
3. The Defence’s argument incorrectly assumes that any relief benefiting more than one person is automatically a “class action” requiring express statutory authorisation. That is simply not true. Administrative correction is not a class action procedure.

III. RULE 5.12 DOES NOT BAR THE CLAIM: THE PLAINTIFF’S STANDING IS BASED SOLELY ON HIS OWN UNLAWFUL TRESPASS FINDING
1. Standing requires:
  1. An injury to the Plaintiff by the Defendant;
  2. Caused by unlawful conduct; and
  3. Remediable by the Court.
2. All three are satisfied. The Plaintiff’s injury is his own Trespass conviction under the DHS policy. That establishes standing to challenge the policy’s legality.
3. The Commonwealth’s argument incorrectly suggests the Plaintiff must have standing on behalf of other individuals for the Court to direct DHS to correct its administrative record. But that is not how judicial review works. Once standing exists to challenge the policy:
  • The Court may craft appropriate remedies for the illegality it finds, including directing an agency to correct the structural consequences of that illegality.
  • This does not require the Plaintiff to rely on injuries suffered by others.
  • It simply recognises that an agency’s unlawful policy cannot remain in force for some people but not others once declared unlawful.
4. The Plaintiff is not asserting standing for third-party claims. He asserts standing for his own claim, and the remedy flows from the Court’s supervisory power over an executive agency.

IV. PRIVACY MATTERS V. NEXALIN [2025] FCR 36 IS DISTINGUISHABLE
1. The Commonwealth relies heavily on Privacy Matters V. Nexalin [2025] FCR 36 (hereinafter referred to as ‘Nexalin’), but that case is fundamentally different.
2. In Nexalin, the Court refused to award damages to unnamed individuals in a putative class action, emphasising that “establishing a procedure robust enough to handle a class of people in a lawsuit would be substantial to a point of encroaching upon the powers of the legislative.”
3. Nexalin involved six named plaintiffs plus 116 additional affected individuals, sought damages for all users, and the Court held there was no statutory mechanism for such broad relief.
4. In this action, the Plaintiff seeks:
  • No damages for anyone other than the Plaintiff.
  • No compensation to unnamed individuals.
5. The Plaintiff asks solely that DHS reverse its own unlawful administrative decisions, which is a normal form of administrative remedy.
6. Nexalin limits damages to named plaintiffs. It does not limit a Court’s power to order a government agency to bring its past actions into compliance with the law.

V. POLICY ARGUMENT
1. If the Commonwealth’s view were correct, then:
  • Even the most egregiously unlawful government policy would permanently stain hundreds of citizens’ records;
  • Only litigants with the time and resources to individually sue would ever receive relief;
  • Unequal treatment would become baked into the system purely because an agency broke the law on too large a scale.
2. Citizens are entitled to assume DHS follows the law. When DHS does not, the law must provide a mechanism to repair the systemic consequences.
3. Refusing such relief would incentivise agencies to violate the law more broadly, since widespread illegality would make their actions harder to correct.

For these reasons, the Plaintiff respectfully requests that the Motion to Dismiss be denied in full.
Click to expand...


Court Order


IN THE DISTRICT COURT OF THE COMMONWEALTH OF REDMONT
Motion to Dismiss - Department of Homeland Security

Movant wishes for dismissal of Complaint Claim #8 for failure to state a claim and for lack of standing. Non-movant offers arguments in defense and general denial of Movant’s assertion with the applicability of Nexalin.


On review of filings, the Court GRANTS the motion as Non-Movant’s arguments are purely academic.

The Court finds Plaintiff’s Claim #8 to be substantively academic. Although framed as a request for “class-wide administrative relief”, the prayer that DHS be ordered to vacate all prior trespass findings (Prayer #6) effectively seeks a class-action for un-named parties; This Court has no statutory authority to grant class-action relief and is in fact barred by Nexalin from considering it. Further, such a remedy does not address Plaintiff’s personal legal injuries, but would broaden the Court’s inquiry to citizens not involved in this case. This Court is not here to effect systemic changes or generate favourable case law for a particular viewpoint.



Claim #8 is struck.
Prayer(s) #6 is struck.


CORRECTION PRAYER #6 is NOT STRUCK, the Court orders Plaintiff to restrict that Prayer to Plaintiff's allegations only.

So ordered,
Magistrate Mug

 
Muggy21 said:
Thanks. The CW shall have 48 hours to offer an Answer.
Click to expand...
Your Honor,

The Commonwealth respectfully requests an extension of 24 hours to file its answer.
 
Franciscus said:
Your Honor,

The Commonwealth respectfully requests an extension of 24 hours to file its answer.
Click to expand...
Granted, Answer due 11/19/25 @ 7:30 PM EST
 

Answer to Complaint


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

jsrkiwi
Plaintiff

v.

Department of Homeland Security
Defendant



I. ANSWER TO COMPLAINT​

1. AFFIRMS that "On 13th November 2025, the Department of Homeland Security (DHS) created a criminal record for the Plaintiff, listing five trespass offences at locations c108 and c995."
2. AFFIRMS that "On 13th November 2025 at 10:37 UTC, the Plaintiff was fined $2,900 for ‘Trespass x5 (First, Second, and Subsequent charges)’; and a wanted point was created for 35 minutes imprisonment."
3. NEITHER AFFIRMS NOR DENIES:
The supporting evidence for the criminal record was five screenshots provided by Vernicia through ticket dhs-25341. These screenshots show:
(i) Sales records showing the sale of coal blocks by the Plaintiff to Vernicia at ‘14h24m ago’;
(ii) The third page of the book outside of one of the entrances to c995. The page is titled ‘ban list’, and the name of the Plaintiff is listed on the third line from the bottom;
(iii) Sales records showing the sale of 27 iron blocks at ‘1d11h23m ago; 300 coal blocks by the Plaintiff to Vernicia at ‘1d12h38m ago’; and the sale of 960 coal by the Plaintiff to Vernicia at ‘1d12h40m ago’.
(iv) Sales records showing the sale of 65 redstone blocks by the Plaintiff to MZCD at ‘11-11-2025 17:13:50’; the sale of 64 redstone by the Plaintiff to MZCD at ‘11-11-2025 17:13:39’; the sale of 66 lapis blocks by the Plaintiff to MZCD at ‘11-11-2025 17:13:30’; and the sale of 116 lapis lazuli by the Plaintiff to MZCD at ‘11-11-2025 17:13:07’.
(v) Sales records showing the sale of 3 iron blocks to MZCD at ‘11-11-2025 16:47:02’.

4. DENIES that "Only one screenshot includes a timestamp: 13 November 2025 at 05:12 (CET). Two others show indirect metadata; two show none".
5. DENIES that "No evidence is held by the DHS that the book outside c995 was updated to include the Plaintiff’s name prior to the Plaintiff transacting on the plots."
6. NEITHER AFFIRMS NOR DENIES that "No instructions or notice banning the Plaintiff from a property has ever been served upon the Plaintiff by Vernicia". DENIES that "The Plaintiff had no reason to believe that he was banned from entering plots c108 or c995."
7. NEITHER AFFIRMS NOR DENIES that "Plaintiff accessed both properties c108 and c995 exclusively by warp (‘/home vernicia’ and ‘/home mzcd’) and did not walk through the entrance". DENIES that "the book shown in the second screenshot was never visible to him", NOTING that it is plainly visible in the screenshot.
8. NEITHER AFFIRMS NOR DENIES that "[t]he property owner (Vernicia) has personally observed Plaintiff warping into c995 before and therefore knew Plaintiff would not see any book", NOTING that the Commonwealth cannot read Vernicia's memory.
9. NEITHER AFFIRMS NOR DENIES that "The books outside c108 and c995 do not specify what the ban relates to".
10. AFFIRMS that "Plaintiff has knowledge from his work as a Police Trainee of the existence several other individuals who were charged with trespass at properties owned or controlled by the same private citizen, Vernicia".
11. NEITHER AFFIRMS NOR DENIES that "in each of these cases, the method of ‘instruction’ was identical: reliance on a book placed at the property entrance, with no proof of service and no confirmation that the accused ever saw it", NOTING that it is not clear to the Commonwealth what specific cases "each of these cases" refers to.
12. NEITHER AFFIRMS NOR DENIES that "in each of these cases, the proof used by the DHS to support the conviction of Trespass is identical: a screenshot of the book showing the accused’s name, and a screenshot showing sales records. In each case, there is no evidence that any instruction was properly served by Vernicia to any of the accused individuals, or that the book was updated prior to the sales taking place", NOTING that it is not clear to the Commonwealth what specific cases "each of these cases" refers to.
13. DENIES that "The similarity of fact patterns across multiple cases indicates that DHS applied an unofficial, and unlawful low standard specifically when handling trespass complaints originating from Vernicia".
14. NEITHER AFFIRMS NOR DENIES that "At 14:37 UTC on 13th November 2025, The Plaintiff attempted to dispute the charges through a government ticket (dhs-25445). As of 72 hours later, the DHS had not responded to the ticket and the decision remained uncorrected. At 15:47 UTC on 16th November 2025, with the ticket having become the oldest charge-dispute ticket on the DHS tickets list, the Plaintiff closed the ticket, and now files this action."



II. Defenses​

1. Trespass occurred​

Trespass, as is relevant for this case, is defined as occurring when a person "enters or remains in a non-public or restricted area against instructions" (see: CCA Part VIII, Section 12).

Put alternatively, the following may constitute trespass:
  1. Entering a non-public area against instructions;
  2. Remaining in a non-public area against instructions;
  3. Entering a restricted area against instructions; or
  4. Remaining in a restricted area against instructions.
Now that the rule is clear, let's examine application of the rule to the facts and evidence.

1a. Plaintiff's own evidence shows that Plaintiff entered a restricted area​

In previous instances, the Courts found in Walmart co. v. Olisaurus123 and Montilou [2022] FCR 13 (affirmed on appeal in Supreme Court Case Olisaurus123 v. Walmart Co [2022] SCR 3) that "[g]iven the presence of a wall around the plot and the fact that the only entrance point was the roof, a reasonable person should conclude that they are not to enter".

We posit here: if there's a big wall around a plot, and there is a sign at the entrances saying that the area is restricted, the area would be restricted under the law.

Exhibits P-019 and P-020 (and P-003) show something quite clear: a lectern with a sign above it with "RESTRICTED AREA" in uppercase lettering. This clearly marks that the area (in this case, C995) as being restricted. This is incontestable.

1b. Instructions are given by books on lecterns at entrances​

The signs visible in (for example) Exhibits P-019 and P-020 instruct individuals to read the book before entry. Upon opening the books, there is a "ban list". In the whole context, there is nothing else that a ban list could plausibly refer to than those banned from entering the restricted area. This constitutes plain posting of instructions at the entrances to a plot.

1c. Plaintiff entered the area against instructions​

The books are datestamped and clearly mark the Plaintiff as among the individuals banned from the plot. Plaintiff admits to having the entered the property anyway. The Plaintiff claims to have done so by warping (see: seventh factual allegation in the initial complaint), but this does not matter - instructions were clearly posted at the entrance, and the Plaintiff had to have entered the property before setting a warp.

1d. Trespass occurred​

Trespass occurs when an individual enters a restricted area against the instructions. In this case, Plaintiff entered a restricted area despite being on the ban list posted at the entrances. The conclusion here is simple: trespass occurred.

2. Lack of evidence​

Several claims for relief simply lack evidence. For example, Plaintiff claims "selective enforcement, as demonstrated by multiple individuals being found guilty for Trespass, reliant on identical fact patterns linked to the same citizen complainant, indicating the presence of an unlawful or improperly supervised internal practice", but does not provide evidence to this effect. The Plaintiff has a burden of proof in a civil lawsuit here - Plaintiff must prove all claims.

3. Text Me Back Act Timeline​

In the alternative to the above, the Defense raises the question of whether the Text Me Back Act would protect the Commonwealth from suit in this instance.

Under the Text Me Back Act, "Executive Departments are required to provide a final decision on any new applications within a period of 14 days". Plaintiff alleges in the 14th factual allegation that the Plaintiff did not receive a reply within 72 hours, but this would be far short of 14 days.

Under the Text Me Back Act, "application" is intentionally quite broad. While the law initially only applied to employment applications, the law was amended by the Congress with the purpose of handling "[o]ther types of applications with government agencies".

If the Court finds that the Plaintiff's DHS appeal ticket were to constitute an application under the Text Me Back Act, then the Plaintiff would have prematurely closed it of their own volition before a response would have been required under the law. And, if so, the Plaintiff would have deprived the DHS from statutory time to gather a response and ask follow-up questions as permitted under the penumbra of Text Me Back Act 3(2)(a) ("If a Department requests additional information or documentation from the applicant, the 14-day deadline shall restart from the date the applicant provides the requested information").



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 19th day of November 2025

 
Discovery is now open!
Due Date: 11/24/25 @1:00PM EST
 

Motion


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

Your Honor,

The Defense seeks to compel the following from the Plaintiff:

  1. Any Minecraft logs between 11 November and 13 November.
  2. A screenshot of all the Plaintiff’s /home warps that can be obtained by running /homes.
We believe that these logs will help to better establish the movement of the Plaintiff about the map, including to or from the plot c995.

 
Franciscus said:

Motion


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

Your Honor,

The Defense seeks to compel the following from the Plaintiff:

  1. Any Minecraft logs between 11 November and 13 November.
  2. A screenshot of all the Plaintiff’s /home warps that can be obtained by running /homes.
We believe that these logs will help to better establish the movement of the Plaintiff about the map, including to or from the plot c995.

Click to expand...
The Plaintiff does not object to Request No. 1 and will produce his logs as requested.

Regarding request No. 2, the Plaintiff respectfully notes that certain home warps (specifically 'vernicia' and 'mzcd') were removed by the Plaintiff after the criminal charge and possibly after the commencement of this civil action. Accordingly, they no longer appear in the current /homes listing. The Plaintiff will review logs for subsequent days and will disclose those for the day when those warps were deleted. The Plaintiff will also shortly be filing a motion to request logs of the Plaintiff's '/home' activity from staff.
 

Motion


IN THE DISTRICT COURT OF THE COMMONWEALTH OF REDMONT

MOTION TO COMPEL PRODUCTION OF STAFF RECORDS

The Plaintiff respectfully moves this Honourable Court for an Order compelling the Staff Team to produce the records identified below, which are directly relevant to the issues in dispute and necessary for the fair adjudication of this matter.

  1. Any and all server logs reflecting the Plaintiff’s use of the commands “/home vernicia” and “/home mzcd” between 10 November 2025 and 13 November 2025, inclusive.
  2. Any logs or other records showing the teleportation coordinates associated with the Plaintiff’s warps “/home vernicia” and “/home mzcd”.
The Plaintiff submits that these records are within the Staff Team’s custody and control, and their production is necessary to resolve factual disputes concerning the travel of the Plaintiff.

Accordingly, the Plaintiff prays the Court issue an Order directing the Staff Team to disclose the above-specified materials.

 
Franciscus said:

Motion


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

Your Honor,

The Defense seeks to compel the following from the Plaintiff:

  1. Any Minecraft logs between 11 November and 13 November.
  2. A screenshot of all the Plaintiff’s /home warps that can be obtained by running /homes.
We believe that these logs will help to better establish the movement of the Plaintiff about the map, including to or from the plot c995.

Click to expand...
jsrkiwi said:
The Plaintiff does not object to Request No. 1 and will produce his logs as requested.

Regarding request No. 2, the Plaintiff respectfully notes that certain home warps (specifically 'vernicia' and 'mzcd') were removed by the Plaintiff after the criminal charge and possibly after the commencement of this civil action. Accordingly, they no longer appear in the current /homes listing. The Plaintiff will review logs for subsequent days and will disclose those for the day when those warps were deleted. The Plaintiff will also shortly be filing a motion to request logs of the Plaintiff's '/home' activity from staff.
Click to expand...
The Plaintiff provides the following items of discovery requested by the Defendant:

REQUEST 1
Attached are the Minecraft logs listed in Request No. 1 (11–13 November). They are labelled as follows:
P-101: 2025-11-11-1.log
P-102: 2025-11-11-2.log
P-103: 2025-11-12-1.log
P-104: 2025-11-12-2.log
P-105: 2025-11-13-1.log
P-106: 2025-11-13-2.log
P-107: 2025-11-13-3.log
P-108: 2025-11-13-4.log

REQUEST 2
As previously noted, certain home warps (‘vernicia’ and ‘mzcd’) were removed by the Plaintiff after the criminal charge, and therefore do not appear in the current /homes listing.
P-109: Screenshot as requested
P-110: 2025-11-14-1.log (this includes the result of "/homes", "/delhome vernicia", and "/delhome mzcd")
 

Attachments

jsrkiwi said:

Motion


IN THE DISTRICT COURT OF THE COMMONWEALTH OF REDMONT

MOTION TO COMPEL PRODUCTION OF STAFF RECORDS

The Plaintiff respectfully moves this Honourable Court for an Order compelling the Staff Team to produce the records identified below, which are directly relevant to the issues in dispute and necessary for the fair adjudication of this matter.

  1. Any and all server logs reflecting the Plaintiff’s use of the commands “/home vernicia” and “/home mzcd” between 10 November 2025 and 13 November 2025, inclusive.
  2. Any logs or other records showing the teleportation coordinates associated with the Plaintiff’s warps “/home vernicia” and “/home mzcd”.
The Plaintiff submits that these records are within the Staff Team’s custody and control, and their production is necessary to resolve factual disputes concerning the travel of the Plaintiff.

Accordingly, the Plaintiff prays the Court issue an Order directing the Staff Team to disclose the above-specified materials.

Click to expand...

REQUEST TO AMEND MOTION TO COMPEL
The Plaintiff respectfully seeks leave of this Honourable Court to amend the pending Motion to Compel Production of Staff Records to include the following additional request as paragraph 3 of the requested materials:

3. Any logs or other records showing when the lecterns at the following locations were updated during November 2025:
  • 4184, 73, 4134
  • 4079, 73, 4136
  • 2637, 73, 3921
  • 2667, 73, 3921
These records fall within the Staff Team’s custody and control and are necessary for the fair resolution of factual issues concerning the chronology of events under examination.

Accordingly, the Plaintiff prays this Honourable Court permit the amendment and direct the Staff Team to produce the additional materials identified above as part of the original Motion to Compel.
 
jsrkiwi said:
REQUEST TO AMEND MOTION TO COMPEL
The Plaintiff respectfully seeks leave of this Honourable Court to amend the pending Motion to Compel Production of Staff Records to include the following additional request as paragraph 3 of the requested materials:

3. Any logs or other records showing when the lecterns at the following locations were updated during November 2025:
  • 4184, 73, 4134
  • 4079, 73, 4136
  • 2637, 73, 3921
  • 2667, 73, 3921
These records fall within the Staff Team’s custody and control and are necessary for the fair resolution of factual issues concerning the chronology of events under examination.

Accordingly, the Plaintiff prays this Honourable Court permit the amendment and direct the Staff Team to produce the additional materials identified above as part of the original Motion to Compel.
Click to expand...

Denied as excessive. Staff will not search multiple days at multiple locations.
 
jsrkiwi said:

Motion


IN THE DISTRICT COURT OF THE COMMONWEALTH OF REDMONT

MOTION TO COMPEL PRODUCTION OF STAFF RECORDS

The Plaintiff respectfully moves this Honourable Court for an Order compelling the Staff Team to produce the records identified below, which are directly relevant to the issues in dispute and necessary for the fair adjudication of this matter.

  1. Any and all server logs reflecting the Plaintiff’s use of the commands “/home vernicia” and “/home mzcd” between 10 November 2025 and 13 November 2025, inclusive.
  2. Any logs or other records showing the teleportation coordinates associated with the Plaintiff’s warps “/home vernicia” and “/home mzcd”.
The Plaintiff submits that these records are within the Staff Team’s custody and control, and their production is necessary to resolve factual disputes concerning the travel of the Plaintiff.

Accordingly, the Plaintiff prays the Court issue an Order directing the Staff Team to disclose the above-specified materials.

Click to expand...


Court Order


IN THE DISTRICT COURT OF THE COMMONWEALTH OF REDMONT
Order to Compel

On motion from Plaintiff, and not seeing a plausible response from Defendant, the Court orders the production of logs. If the response is prejudicial, the Court will hear from Defendant on reconsideration.

@Staff The Court humbly requests the following be produced by Staff in the Court Docket:

===============================================

  1. Any and all server logs reflecting the Plaintiff’s use of the commands “/home vernicia” and “/home mzcd” between 10 November 2025 and 13 November 2025, inclusive.
  2. Any logs or other records showing the teleportation coordinates associated with the Plaintiff’s warps “/home vernicia” and “/home mzcd”.
  3. Any logs or other records showing the time at which the lectern at the location 4079, 73, 4136 was updated on 11th November 2025.
===============================================

The Court will open a staff ticket and request that a Staff Member (or Staff Team) respond in this thread if possible. If not, the Court will post the entirety of the ticket thread to this forum. No deadline shall be affixed to this order.

So ordered,
Judge Mug.


 
Muggy21 said:
Denied as excessive. Staff will not search multiple days at multiple locations.
Click to expand...
I apologise Your Honour, I am unaware of the methods that staff use to search logs, and was not aware that such a search would be time-consuming for staff to carry out.

Would Your Honour consider including a significantly more limited version of the request:

3. Any logs or other records showing the time at which the lectern at the location 4079, 73, 4136 was updated on 11th November 2025.
 
jsrkiwi said:
I apologise Your Honour, I am unaware of the methods that staff use to search logs, and was not aware that such a search would be time-consuming for staff to carry out.

Would Your Honour consider including a significantly more limited version of the request:

3. Any logs or other records showing the time at which the lectern at the location 4079, 73, 4136 was updated on 11th November 2025.
Click to expand...
Added to original order, marked green underlined texted.

I've made all three requests to Staff for their consideration.
 
Staff-1
1763662092648.png



Staff-2
1763662103903.png



Staff-3
1763662111677.png


Staff-4
1763662118967.png


Staff-5
1763662124324.png
 
Last edited:
Your Honor:

The Defense would like to add the following individual to its witness list:

  1. Vernicia
 

Motion


IN THE DISTRICT COURT OF THE COMMONWEALTH OF REDMONT

MOTION TO COMPEL

Your Honour, the Plaintiff seeks to compel the following from the Defendant:

  • Production of all records and evidence held by the DHS in respect of the five charges against jsrkiwi of Trespass, except for those already entered into evidence in this case;
JUSTIFICATION
The Defendant has denied Fact 5 (“No evidence is held by the DHS that the book outside c995 was updated to include the Plaintiff’s name prior to the Plaintiff transacting on the plots.”). This denial implies the existence of records or documentation in the custody of the DHS regarding the status of the book outside c995.

Without production of this evidence, the Plaintiff cannot properly respond, prepare arguments, or test the accuracy of the DHS’s denial.

 
PLAINTIFF'S WITNESS LIST
The Plaintiff will not be adding any additional witnesses at this time. The witness list, therefore, remains as originally filed:
  • jsrkiwi
  • Vernicia
  • Goldendude15
  • Roryyy_
 
RULE 4.6 EVIDENCE SUBMISSION
Persuant to rule 4.6, the Plaintiff enters the following into evidence:

P-111: The entirety of all Discord direct messages between Vernicia and jsrkiwi as of 21st November 2025.
 

Attachments

  • P-111.png
    P-111.png
    410.1 KB · Views: 30

Brief


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

Your Honor:

The Defense submits the following interrogatories of the Plaintiff consistent with Rule 4.8:

  1. Have you ever entered the property C995 other than by warping to a /home?
  2. Have you ever entered the property c108 other than by warping to a /home?
  3. What does the Plaintiff understand “read before entry” to mean, as shown in exhibits P-003 and P-021?
  4. Why did Plaintiff presume permission to enter c995 when the sign outside it shown in Exhibit P-003 said “restricted area”?
  5. The Plaintiff has alleged in a claim that the DHS “violated the administrative due-process principles applicable to agency decisions”. What are the specific principles that the Plaintiff alleges were violated?

 
jsrkiwi said:

Motion


IN THE DISTRICT COURT OF THE COMMONWEALTH OF REDMONT

MOTION TO COMPEL

Your Honour, the Plaintiff seeks to compel the following from the Defendant:

  • Production of all records and evidence held by the DHS in respect of the five charges against jsrkiwi of Trespass, except for those already entered into evidence in this case;
JUSTIFICATION
The Defendant has denied Fact 5 (“No evidence is held by the DHS that the book outside c995 was updated to include the Plaintiff’s name prior to the Plaintiff transacting on the plots.”). This denial implies the existence of records or documentation in the custody of the DHS regarding the status of the book outside c995.

Without production of this evidence, the Plaintiff cannot properly respond, prepare arguments, or test the accuracy of the DHS’s denial.

Click to expand...

Response



Your Honor,

The Defense opposes this request as the the relevant evidence is already compelled from the staff team and submitted here.

From what I understand, the Plaintiff essentially claims that they need additional files to prepare arguments around the time of book placement. We already have the relative time of the book being updated in Exhibit Staff-2, and the relative time of the Plaintiff’s teleports in Exhibits Staff-3, Staff-4, and Staff-5.

The staff team is going to be the ultimate source of truth on matter of when an item was placed or removed, as well as when an individual ran commands on the server, so we see no compelling reason to go on a further fishing expedition and command the Commonwealth to use its employees’ time in order to find what’s very plainly in the public record in this very case. The plaintiff can very simply use the staff records here for plaintiff’s purposes.

 
jsrkiwi said:

Motion


IN THE DISTRICT COURT OF THE COMMONWEALTH OF REDMONT

MOTION TO COMPEL

Your Honour, the Plaintiff seeks to compel the following from the Defendant:

  • Production of all records and evidence held by the DHS in respect of the five charges against jsrkiwi of Trespass, except for those already entered into evidence in this case;
JUSTIFICATION
The Defendant has denied Fact 5 (“No evidence is held by the DHS that the book outside c995 was updated to include the Plaintiff’s name prior to the Plaintiff transacting on the plots.”). This denial implies the existence of records or documentation in the custody of the DHS regarding the status of the book outside c995.

Without production of this evidence, the Plaintiff cannot properly respond, prepare arguments, or test the accuracy of the DHS’s denial.

Click to expand...

DENIED.


Unless I'm mistaken, the only evidence of the criminal offense (at least for trespass) would be the images in Plaintiff's criminal record entry. Plaintiff as already included this evidence as part of the record when he entered them as part of the Complaint.
 
Judge Mug’s Trial Protocol and Rules

Pursuant to Rule 1.2, these shall be the rules herein imposed for the trial in jsrkiwi v Department of Homeland Security [2025] DCR 93. The timeframes listed for each section may be changed on application for an extension.


==================================================================================================

I. Opening Statements​

  1. Each Party shall submit an Opening Statement to the Court.
  2. The purpose of the Opening Statement is to summarize what the Party intends to prove at trial and to present the strengths of its case.
  3. Opening Statements from both Parties are due within forty-eight (48) hours after the conclusion of Discovery.
  4. The Court will invite both parties to submit their opening statements by the same deadline. The Defendant will have the same deadline as Plaintiff.


II. Presentation of Witness Questions​

  1. Within fourty-eight (48) hours after submitting his or her Opening Statement, each Party must submit all initial questions for witnesses in a single post.
  2. All objections to the submitted witness questions must be filed in one consolidated post.
  3. Objections are due within twenty-four (24) hours after the deadline for submitting witness questions.


III. Witness Summonses & Testimony​

  1. Witnesses shall provide responses as directed by the Court.
  2. Any objections to witness testimony must be submitted within twenty-four (24) hours of the witness's response.


IV. Cross-Examination​

  1. Each Party may conduct cross-examination of any witness.
  2. Cross-examination questions are due within fourty-eight (48) hours after the witness has responded to direct questioning.
  3. Cross-examination questions do not need to be consolidated.
  4. Any objections to cross-examination questions are due within twenty-four (24) hours of submission by the Witness.



V. Closing Statements​

  1. Following the conclusion of all witness testimony and examination, the Court will invite each Party shall submit a Closing Statement.
    • Clearly label any legal arguments (e.g., “1. THEFT IS ILLEGAL” followed by the Party’s reasoning) - This is for the Court's sanity and ease of readability.
  2. Plaintiff shall have 72 Hours to submit a Closing Statement. On submission of Plaintiff's statement, Defendant shall immediately have 72 hours to submit a Closing Statement.


VI. Motions and Objections After Closing Statements​

  1. After both Closing Statements have been submitted, either Party may file post-argument motions or objections (e.g., Motion to Reconsider, Objection for Perjury, etc.).
  2. The Party must notify the Court of its intent to file such motion or objection within twenty-four (24) hours of the Closing Statements being submitted.
  3. Upon advisement from the Court, the Party will have forty-eight (48) hours to submit the requested motion, objection, or brief.
 
Franciscus said:

Brief


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

Your Honor:

The Defense submits the following interrogatories of the Plaintiff consistent with Rule 4.8:

  1. Have you ever entered the property C995 other than by warping to a /home?
  2. Have you ever entered the property c108 other than by warping to a /home?
  3. What does the Plaintiff understand “read before entry” to mean, as shown in exhibits P-003 and P-021?
  4. Why did Plaintiff presume permission to enter c995 when the sign outside it shown in Exhibit P-003 said “restricted area”?
  5. The Plaintiff has alleged in a claim that the DHS “violated the administrative due-process principles applicable to agency decisions”. What are the specific principles that the Plaintiff alleges were violated?

Click to expand...
PLAINTIFF’S RESPONSE TO DEFENCE’S INTERROGATORIES

1. Have you ever entered the property C995 other than by warping to a /home?
Yes.

2. Have you ever entered the property c108 other than by warping to a /home?
Yes.

3. What does the Plaintiff understand “read before entry” to mean, as shown in exhibits P-003 and P-021?
The Plaintiff’s understanding is that “read before entry” refers to the book placed at the entrance of the property.

4. Why did Plaintiff presume permission to enter c995 when the sign outside it shown in Exhibit P-003 said “restricted area”?
The Plaintiff presumed permission to enter c995, because it is lawful for a person to enter a ‘restricted area’ if no instructions to the contrary have been served to him.

5. The Plaintiff has alleged in a claim that the DHS “violated the administrative due-process principles applicable to agency decisions”. What are the specific principles that the Plaintiff alleges were violated?
The plaintiff is referring to the principles that:
  • The DHS should not find a person guilty of a crime without all elements of the crime existing;
  • The DHS should not find a person guilty of a crime without sufficient evidence to support every element of the crime;
  • The DHS should not show preferential treatment towards certain citizens; and
  • Decisions by the DHS should be promptly reversed by the DHS when they were shown to be wrong or unlawful.
 
Your Honor:

Pursuant to Rule 4.6, the Commonwealth enters the following evidence:
1763831429326.png
1763831459435.png
1763831498205.png
1763831537982.png
 
RULE 4.6 EVIDENCE SUBMISSION
This might be improper, since these documents are already preserved on the forum. However, to ensure that the record is complete, the Plaintiff enters the following into evidence under Rule 4.6:
P-201: Testimony by Vernicia in the case jsrkiwi v Trentrick_Lamar [2025] DCR 90 (#39)​
P-202: The repealed Trespassing and Theft Offenses Act, showing the evolution of Congress' definition of the crime of Trespass.​
 

Attachments

Last edited by a moderator:
jsrkiwi said:
RULE 4.6 EVIDENCE SUBMISSION
This might be improper, since these documents are already preserved on the forum. However, to ensure that the record is complete, the Plaintiff enters the following into evidence under Rule 4.6:
P-201: Testimony by Vernicia in the case jsrkiwi v Trentrick_Lamar [2025] DCR 90 (#39)​
​
Click to expand...

Objection


IN THE DISTRICT COURT OF THE COMMONWEALTH OF REDMONT
OBJECTION — RELEVANCE

Your Honor,

Under the objections guide, a relevance objection may be filed when “evidence presented is not relevant to the case”.

The Defense plainly fails to see how the statements of Vernicia on an entirely separate matter is relevant to this case. We therefore ask that the evidence be stricken from the record as plainly irrelevant.

 
Franciscus said:

Objection


IN THE DISTRICT COURT OF THE COMMONWEALTH OF REDMONT
OBJECTION — RELEVANCE

Your Honor,

Under the objections guide, a relevance objection may be filed when “evidence presented is not relevant to the case”.

The Defense plainly fails to see how the statements of Vernicia on an entirely separate matter is relevant to this case. We therefore ask that the evidence be stricken from the record as plainly irrelevant.

Click to expand...
PLAINTIFF'S RESPONSE TO DEFENDANT'S OBJECTION (#42)
Your Honour,

Exhibit P-201 is directly tied to the Plaintiff’s planned questioning of Vernicia. It includes her sworn testimony regarding the context of Exhibit P-111. It is required to prevent Vernicia from giving misleading context regarding Exhibit P-111. The exhibit, therefore, goes to the accuracy and reliability of her forthcoming testimony and should remain in the record.
 
jsrkiwi said:
PLAINTIFF'S RESPONSE TO DEFENDANT'S OBJECTION (#42)
Your Honour,

Exhibit P-201 is directly tied to the Plaintiff’s planned questioning of Vernicia. It includes her sworn testimony regarding the context of Exhibit P-111. It is required to prevent Vernicia from giving misleading context regarding Exhibit P-111. The exhibit, therefore, goes to the accuracy and reliability of her forthcoming testimony and should remain in the record.
Click to expand...
Sustained.

Vernicia's conduct in alleged settlement talks on an irrelevant case is not relevant here.

P-201 struck.
 

Motion


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

Your Honor,

The Defense seeks dismissal of the third claim for relief under Rule 5.5 (Lack of Claim). Under the rule, dismissal may be issued "against an [sic] claim for relief that has insufficient evidence to support the civil or criminal charge".

The third claim for relief is as follows:

3. Even if the book were capable of constituting a lawful instruction, DHS possesses no evidence that the book was updated to include the Plaintiff’s name prior to his entry into plots c108 and c995, rendering any alleged instruction void for lack of temporal proof.
Click to expand...

The central question underlying this motion for is as follows: "Does the Plaintiff lack sufficient evidence to support the civil charge that there is no evidence that the book was updated prior to Plaintiff's entry into plots c108 and c995"? As has been made clear throughout the course of discovery, as we explain below, the answer is Yes, the Plaintiff lacks sufficient evidence here.

Following Your Honor's order to compel, the staff team produced screenshots of several log entries for this Court, numbered Staff-1 through Staff-5. These are in the public domain, and presently in the possession of the Commonwealth.

The log entries in Exhibit Staff-2 indicate the time at which the relevant book was updated, showing that it was "9.77" days ago.

The log entries in Exhibits Staff-3, Staff-4, and Staff-5 indicate the time at which the Plaintiff warped to the properties: "8.92" days ago, "8.99" days ago, and "8.12" days ago. Plaintiff, in factual allegation No. 7, confirms that Plaintiff used these warps to access the property.

Simply put - these warps into the plot occurred after the book was updated. Plaintiff's claim that "the DHS possesses no evidence that the book was updated to include the Plaintiff’s name prior to his entry into plots c108 and c995" itself lacks evidence.

 
Franciscus said:

Motion


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

Your Honor,

The Defense seeks dismissal of the third claim for relief under Rule 5.5 (Lack of Claim). Under the rule, dismissal may be issued "against an [sic] claim for relief that has insufficient evidence to support the civil or criminal charge".

The third claim for relief is as follows:


The central question underlying this motion for is as follows: "Does the Plaintiff lack sufficient evidence to support the civil charge that there is no evidence that the book was updated prior to Plaintiff's entry into plots c108 and c995"? As has been made clear throughout the course of discovery, as we explain below, the answer is Yes, the Plaintiff lacks sufficient evidence here.

Following Your Honor's order to compel, the staff team produced screenshots of several log entries for this Court, numbered Staff-1 through Staff-5. These are in the public domain, and presently in the possession of the Commonwealth.

The log entries in Exhibit Staff-2 indicate the time at which the relevant book was updated, showing that it was "9.77" days ago.

The log entries in Exhibits Staff-3, Staff-4, and Staff-5 indicate the time at which the Plaintiff warped to the properties: "8.92" days ago, "8.99" days ago, and "8.12" days ago. Plaintiff, in factual allegation No. 7, confirms that Plaintiff used these warps to access the property.

Simply put - these warps into the plot occurred after the book was updated. Plaintiff's claim that "the DHS possesses no evidence that the book was updated to include the Plaintiff’s name prior to his entry into plots c108 and c995" itself lacks evidence.

Click to expand...
PLAINTIFF’S RESPONSE TO DEFENDANT’S RULE 5.5 MOTION

Your Honour,

The Defence incorrectly reframes the third claim for relief as a simple evidentiary dispute about when a book was updated. That is not what the claim is about. The claim is part of a broader allegation that the Department of Homeland Security charged the Plaintiff without sufficient evidence to support the elements of the criminal offence, and that this lack of evidentiary standard is systemic enough to warrant injunctive relief.

EVIDENTIARY SUPPORT
Claim 3 concerns DHS’s evidentiary burden at the moment of charging, not later-produced materials.

The Defendant has already conceded, by implication, in their own response to Plaintiff’s Motion to Compel (Filing #36) that the only evidence DHS ever possessed relating to the trespass charge is the images contained in the Plaintiff’s criminal record entry. Your Honour confirmed the same in your ruling on that motion (#37), stating:
Muggy21 said:
Unless I'm mistaken, the only evidence of the criminal offense (at least for trespass) would be the images in Plaintiff's criminal record entry.
Click to expand...

This is crucial, because the third claim for relief concerns DHS’s evidentiary burden at the time they chose to charge, not what staff logs later reveal during litigation. The Defendant attempts to wrongly substitute post-hoc staff logs for contemporaneous evidence. The claim states exactly that: DHS had no evidence establishing that any instruction was valid, updated, or temporally tied to the Plaintiff prior to entry. Your Honour’s own ruling (#37) finds that the DHS possessed nothing beyond five screenshots when issuing the charge. That is more than enough to support the plausibility of the claim.

The staff logs the Defence relies on were never possessed by DHS at the time the charge was issued, and therefore cannot have been part of the DHS’s charging rationale. Therefore, the staff logs are irrelevant to Claim 3.

MISREPRESENTATION OF CLAIM 3 BY THE DEFENDANT
The Defence also misstates the claim. Claim 3 is part of a wider argument: that the DHS charged the Plaintiff without sufficient evidence, and the Plaintiff therefore seeks injunctive relief to improve DHS evidentiary standards.

The Defendant has improperly reduced the claim to the single question “Does the Plaintiff lack sufficient evidence to support the civil charge that there is no evidence the book was updated?”

Claim 3 is not about whether there is sufficient evidence in the here and now. Claim 3 is about whether the DHS possessed sufficient evidence at the time of charging.

CONCLUSION
Since the third claim for relief is directed at DHS’s charging conduct and the adequacy of its evidentiary standards, and since the Defendant and Your Honour have already confirmed that DHS had no contemporaneous evidence establishing the temporal validity of the alleged instruction, the claim easily meets the threshold to survive a Rule 5.5 dismissal.

The motion to dismiss should therefore be denied.
 
The Court is confused atm;

Reaching out to DHS to seek clarity on procedure (I've never arrested someone, I not going to pretend to know what actually happens)
 

Opening Statement


IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
OPENING STATEMENT

Your Honor:

1. Introduction​

This case is not about grand “systemic failures.” It is about a straightforward trespass and a department that did exactly what it is supposed to do: enforce the law on the evidence in front of it.

Our roadmap is simple:
  1. The Plaintiff trespassed on clearly marked plots c108 and c995 after being banned from them.
  2. DHS had a solid evidentiary basis and acted within its legal authority and timelines.
  3. The wider claims of bias and systemic due-process violations are unsupported and should be rejected.

2. The Plaintiff did commit trespass​

he entrances to c108 and c995 are not mysteries. Taking the Court through Exhibit P-003 through P-022: the entrances are marked with obvious “RESTRICTED AREA" and/or "read before entry” signage and lecterns, and inside those entrance books is a ban list containing the Plaintiff's name.

Staff logs (Exhibits Staff-1 through Staff-5) will show that the books were updated to include the Plaintiff and that his later entries occurred after that update. The Plaintiff's own materials show substantial activity at those plots, and at some point those homes had to be set by entering through the front like everyone else.

The Plaintiff’s argument boils down to this: “I warped in, so the rules at the door don’t count.” That is not what the trespass law says. The law prohibits entering a restricted area against instructions. Those instructions were clear, at the entrance, and they named him. He went in anyway. That is trespass.

3. The DHS acted reasonably and lawfully​

When the complaint came in, DHS had: screenshots of the ban list, screenshots of the restricted entrance, shop logs showing the Plaintiff dealing at the plots, and the complainant’s report (Exhibits P-001, P-003 through P-007; Exhibits D-T01 through D-T04). That is more than enough for a charging decision in this environment.

The Plaintiff invokes “administrative due-process principles,” but also complains that his DHS ticket was not answered within 72 hours. The Text Me Back Act gives departments up to 14 days to respond to applications of any sort. Plaintiff's ticket did not die in DHS’s inbox; the Plaintiff closed it himself after about three days. He cannot cut off the appeal process and then accuse the department of ignoring him.

4. The systemic and selective-enforcement claims lack evidence​

The Plaintiff talks about “multiple individuals” and “each of these cases,” but he does not bring the cases: no case numbers, no records, no tickets, no judgments. The Plaintiff has a burden of proof in a civil lawsuit here - Plaintiff must prove all claims. Without concrete cases of comparison, “selective enforcement” is just a label.

What the evidence will actually show is enforcement plainly consistent with the law: when a property owner uses entrance books and ban lists to restrict access, and backs a complaint with screenshots and logs, the DHS correctly applies the trespass law. That is equal treatment, not bias.

5. Concluding Remarks​

At the end of this case, we will ask the Court to find that:
  • The Plaintiff trespassed on restricted plots after clear notice.
  • DHS had a reasonable evidentiary basis, complied with its mandate, and did not violate any binding procedure.
  • The broader systemic allegations are unproven and should be dismissed along with the requested relief.
For those reasons, the Defendant will respectfully ask that the Plaintiff's claims for relief be rejected and the trespass findings left in place.

 
@jsrkiwi The Court's rules stated that Opening Statements were due 48 hours after end of Discovery.
M

Lawsuit: In Session Post in thread 'jsrkiwi v Department of Homeland Security [2025] DCR 93'

Judge Mug’s Trial Protocol and Rules

Pursuant to Rule 1.2, these shall be the rules herein imposed for the trial in jsrkiwi v Department of Homeland Security [2025] DCR 93. The timeframes listed for each section may be changed on application for an extension.


==================================================================================================

I. Opening Statements​

  1. Each Party shall submit an Opening Statement to the Court.
  2. The purpose of the Opening Statement is to summarize what the Party intends to prove at trial...

Since most other judges would invite parties to Opening Statements (and out of general fairness), the Court will grant a courtesy and give you until 11/27/25 @ 1pm EST to respond.
 
============ WITNESSES TAB ==================
I'm going to have these notes and update as new witnesses (if any are called).

Present Witness List:
(Plaintiff/Defendant) / IGN / - Reason
(P) jsrkiwi
(P/D) Vernicia
(P)Goldendude15
(P)Roryyy_
 
The Plaintiff apologises to Your Honour and this Honourable Court for the delay in filing this opening statement.

Opening Statement


IN THE DISTRICT COURT OF THE COMMONWEALTH OF REDMONT
jsrkiwi v Department of Homeland Security [2025] DCR 93

OPENING STATEMENT

Your Honour, and may it please the court.

This case concerns two issues: the Plaintiff’s innocence on the trespass charge, and the DHS’s procedural failures in bringing that charge. The evidence will show (1) that the Plaintiff is not guilty of trespass under any fair or sensible standard, and (2) that the DHS acted without adequate proof when convicting him. In closing, the Plaintiff will explain why a book left near an entrance cannot operate as valid “instructions” for trespass purposes, and why the Text Me Back Act has no bearing on the matter.

1. THE PLAINTIFF’S INNOCENCE
Logs and screenshots will confirm that the Plaintiff carried out sales to Vernicia and to the business MZCD between 11–13 November 2025. DHS will attempt to rely on these transactions to argue that the Plaintiff entered plots from which he had supposedly been banned. The evidence will instead show that the Plaintiff accessed plots c995 and c108 solely through warp commands (‘/home vernicia’ and ‘/home mzcd’), not by walking through any entrance where the so-called “ban book” was placed.

The Plaintiff will testify that he never saw the updated ban-list book because the relevant entrance was not on the route he used.

The ban-list book itself will be presented. The Plaintiff will show that it is vague, undefined, and unfit for use as notice of prohibited conduct. It does not explain what “ban” means, what actions are forbidden, or what areas are covered. It also contains no term allowing unilateral updates without notice. Even if the Plaintiff had read it, it would not have informed him that he was barred from those plots.

Witness testimony will further show that the Plaintiff was never given any “instructions” by Vernicia.

2. DHS’S PROCEDURAL FAILURES
The Court will see the screenshots DHS relied upon: the ban-book page listing the Plaintiff’s name and the transaction logs. These screenshots cannot sustain a trespass conviction because they do not establish that any instructions were issued before the alleged trespass. DHS has no record of when the book was updated. There is a critical gap in proving that the Plaintiff’s name was listed prior to his entry.

The evidence will also include the Plaintiff’s efforts to dispute the charge through ticket dhs-25445. The Plaintiff followed procedure, attempted to engage with DHS, and received no timely response. Despite this, DHS proceeded to impose a criminal record. The ticket will demonstrate that the Plaintiff acted in good faith while DHS failed to meet basic procedural standards.

CONCLUSION AND RELIEF SOUGHT
At the conclusion of the evidence, the Plaintiff will ask this Court to vacate the trespass finding, expunge the criminal record, and refund the $2,900 fine.

The Plaintiff will further request that the Court recognise DHS’s use of ban-list books, without proper notice or evidentiary safeguards, as unlawful, and accordingly order the DHS to reform its enforcement practices so that no citizen is convicted on such insubstantial proof. The Plaintiff will also ask the Court to order DHS to overturn all past trespass convictions issued under these defective policies.

 
Witness Questions due on 11/29/25 at 5pm EST
 
Franciscus said:

Motion


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

Your Honor,

The Defense seeks dismissal of the third claim for relief under Rule 5.5 (Lack of Claim). Under the rule, dismissal may be issued "against an [sic] claim for relief that has insufficient evidence to support the civil or criminal charge".

The third claim for relief is as follows:


The central question underlying this motion for is as follows: "Does the Plaintiff lack sufficient evidence to support the civil charge that there is no evidence that the book was updated prior to Plaintiff's entry into plots c108 and c995"? As has been made clear throughout the course of discovery, as we explain below, the answer is Yes, the Plaintiff lacks sufficient evidence here.

Following Your Honor's order to compel, the staff team produced screenshots of several log entries for this Court, numbered Staff-1 through Staff-5. These are in the public domain, and presently in the possession of the Commonwealth.

The log entries in Exhibit Staff-2 indicate the time at which the relevant book was updated, showing that it was "9.77" days ago.

The log entries in Exhibits Staff-3, Staff-4, and Staff-5 indicate the time at which the Plaintiff warped to the properties: "8.92" days ago, "8.99" days ago, and "8.12" days ago. Plaintiff, in factual allegation No. 7, confirms that Plaintiff used these warps to access the property.

Simply put - these warps into the plot occurred after the book was updated. Plaintiff's claim that "the DHS possesses no evidence that the book was updated to include the Plaintiff’s name prior to his entry into plots c108 and c995" itself lacks evidence.

Click to expand...


DENIED. This is part of Plaintiff's appeal against the Charges themselves. The Court will make note of your argument
 

Brief


IN THE DISTRICT COURT OF THE COMMONWEALTH OF REDMONT

PLAINTIFF’S CONSOLIDATED LIST OF WITNESS QUESTIONS

Your Honour, the Plaintiff’s consolidated list of witness questions is laid out below.

Witness 1: jsrkiwi, Plaintiff​

Questions re logs, sales, and travel
Questions 1-18 relate to the Plaintiff’s Minecraft logs (exhibits P-101, P-102, P-103, P-104, P-105, P-106, P-107, P-108, and P-110). For ease, lines relevant to these questions have been extracted from the exhibits and have been included in the quotation box below.
P-102 (2025-11-11-2.log) lines 1158, 1160-1162, 1165-1183, 1186-1187, 1198-1201, 1203, 1205, 1209-1210
L1158: [15:30:42] [Render thread/INFO]: [System] [CHAT] Teleporting to vernicia.
L1160: [15:30:49] [Render thread/INFO]: [System] [CHAT] [Shop] You sold 26 Gold Block to Vernicia for $702.
L1161: [15:30:53] [Render thread/INFO]: [System] [CHAT] [Shop] You sold 64 Iron Block to Vernicia for $1,280.
L1162: [15:30:57] [Render thread/INFO]: [System] [CHAT] [Shop] You sold 34 Iron Block to Vernicia for $680.
L1165: [15:31:53] [Render thread/INFO]: [System] [CHAT] [Shop] You sold 64 Coal to Vernicia for $44.80.
L1166: [15:31:54] [Render thread/INFO]: [System] [CHAT] [Shop] You sold 64 Coal to Vernicia for $44.80.
L1167: [15:31:54] [Render thread/INFO]: [System] [CHAT] [Shop] You sold 64 Coal to Vernicia for $44.80.
L1168: [15:31:54] [Render thread/INFO]: [System] [CHAT] [Shop] You sold 64 Coal to Vernicia for $44.80.
L1169: [15:31:55] [Render thread/INFO]: [System] [CHAT] [Shop] You sold 64 Coal to Vernicia for $44.80.
L1170: [15:31:55] [Render thread/INFO]: [System] [CHAT] [Shop] You sold 64 Coal to Vernicia for $44.80.
L1171: [15:31:55] [Render thread/INFO]: [System] [CHAT] [Shop] You sold 64 Coal to Vernicia for $44.80.
L1172: [15:31:56] [Render thread/INFO]: [System] [CHAT] [Shop] You sold 64 Coal to Vernicia for $44.80.
L1173: [15:31:56] [Render thread/INFO]: [System] [CHAT] [Shop] You sold 64 Coal to Vernicia for $44.80.
L1174: [15:31:56] [Render thread/INFO]: [System] [CHAT] [Shop] You sold 64 Coal to Vernicia for $44.80.
L1175: [15:31:57] [Render thread/INFO]: [System] [CHAT] [Shop] You sold 64 Coal to Vernicia for $44.80.
L1176: [15:31:57] [Render thread/INFO]: [System] [CHAT] [Shop] You sold 64 Coal to Vernicia for $44.80.
L1177: [15:31:58] [Render thread/INFO]: [System] [CHAT] [Shop] You sold 64 Coal to Vernicia for $44.80.
L1178: [15:31:58] [Render thread/INFO]: [System] [CHAT] [Shop] You sold 64 Coal to Vernicia for $44.80.
L1179: [15:31:58] [Render thread/INFO]: [System] [CHAT] [Shop] You sold 64 Coal to Vernicia for $44.80.
L1180: [15:31:59] [Render thread/INFO]: [System] [CHAT] [Shop] You sold 64 Coal to Vernicia for $44.80.
L1181: [15:31:59] [Render thread/INFO]: [System] [CHAT] [Shop] You sold 64 Coal to Vernicia for $44.80.
L1182: [15:31:59] [Render thread/INFO]: [System] [CHAT] [Shop] You sold 64 Coal to Vernicia for $44.80.
L1183: [15:32:00] [Render thread/INFO]: [System] [CHAT] [Shop] You sold 64 Coal to Vernicia for $44.80.
L1186: [15:32:08] [Render thread/INFO]: [System] [CHAT] Teleporting to hq.
L1187: [15:32:35] [Render thread/INFO]: [System] [CHAT] Teleporting to vernicia.
L1198: [15:33:09] [Render thread/INFO]: [System] [CHAT] [Shop] You sold 64 Coal Block to Vernicia for $403.
L1199: [15:33:10] [Render thread/INFO]: [System] [CHAT] [Shop] You sold 64 Coal Block to Vernicia for $403.
L1200: [15:33:10] [Render thread/INFO]: [System] [CHAT] [Shop] You sold 64 Coal Block to Vernicia for $403.
L1201: [15:33:11] [Render thread/INFO]: [System] [CHAT] [Shop] You sold 28 Coal Block to Vernicia for $176.31.
L1203: [15:33:23] [Render thread/INFO]: [System] [CHAT] Teleporting to hq.
L1205: [15:33:34] [Render thread/INFO]: [System] [CHAT] Teleporting to vernicia.
L1209: [15:33:42] [Render thread/INFO]: [System] [CHAT] [Shop] You sold 64 Coal Block to Vernicia for $403.
L1210: [15:33:48] [Render thread/INFO]: [System] [CHAT] [Shop] You sold 16 Coal Block to Vernicia for $100.75.

P-102 (2025-11-11-2.log) lines 3124, 3127-3129, 3132-3133, 3148
L3124: [16:46:49] [Render thread/INFO]: [System] [CHAT] Teleporting to mzcd.
L3127: [16:47:02] [Render thread/INFO]: [System] [CHAT] [Shop] You sold 1 Iron Block to b:mzcd for $27.
L3128: [16:47:03] [Render thread/INFO]: [System] [CHAT] [Shop] You sold 1 Iron Block to b:mzcd for $27.
L3129: [16:47:05] [Render thread/INFO]: [System] [CHAT] [Shop] You sold 1 Iron Block to b:mzcd for $27.
L3132: [16:47:21] [Render thread/INFO]: [System] [CHAT] Teleporting to hq.
L3133: [16:47:24] [Render thread/INFO]: [System] [CHAT] Teleporting to vernicia.
L3148: [16:48:07] [Render thread/INFO]: [System] [CHAT] [Shop] You sold 27 Iron Block to Vernicia for $486.

P-102 (2025-11-11-2.log) lines 3391-3392, 3394-3397, 3399, 3404, 3406
L3391: [17:13:03] [Render thread/INFO]: [System] [CHAT] Teleporting to mzcd.
L3392: [17:13:07] [Render thread/INFO]: [System] [CHAT] [Shop] You sold 20 Lapis Lazuli to b:MZCD for $15.
L3394: [17:13:20] [Render thread/INFO]: [System] [CHAT] [Shop] You sold 64 Lapis Lazuli to b:MZCD for $48.
L3395: [17:13:21] [Render thread/INFO]: [System] [CHAT] [Shop] You sold 32 Lapis Lazuli to b:MZCD for $24.
L3396: [17:13:30] [Render thread/INFO]: [System] [CHAT] [Shop] You sold 64 Lapis Block to b:MZCD for $44.80.
L3397: [17:13:31] [Render thread/INFO]: [System] [CHAT] [Shop] You sold 2 Lapis Block to b:MZCD for $1.40.
L3399: [17:13:39] [Render thread/INFO]: [System] [CHAT] [Shop] You sold 64 Redstone to b:MZCD for $48.
L3404: [17:13:49] [Render thread/INFO]: [System] [CHAT] [Shop] You sold 64 Redstone Block to b:MZCD for $44.80.
L3406: [17:13:58] [Render thread/INFO]: [System] [CHAT] [Shop] You sold 1 Redstone Block to b:MZCD for $0.70.

P-103 (2025-11-12-1.log) lines 1078, 1081-1082
L1078: [13:39:09] [Render thread/INFO]: [System] [CHAT] Teleporting to vernicia.
L1081: [13:39:21] [Render thread/INFO]: [System] [CHAT] [Shop] You sold 64 Coal Block to Vernicia for $403.
L1082: [13:39:23] [Render thread/INFO]: [System] [CHAT] [Shop] You sold 50 Coal Block to Vernicia for $314.84.

P-103 (2025-11-12-1.log) line 1148
[13:46:06] [Render thread/INFO]: [System] [CHAT] Homes: house, hq, hills, police, storage, ikea, kiwi, gallery, vernicia, senate, houseofrepresentatives, mzcd, wild_village, ironside, mine, temp, hospital, tesco, foxnews, hive, coral, grinder, grinder1, trentrick, nether, bank, prison, westmill, underthesea

P-105 (2025-11-13-1.log) lines 1096, 1099, 1100
L1096: [15:06:13] [Render thread/INFO]: [System] [CHAT] SPAWN » Taking a trip to the City of Reveille...
L1099: [15:06:25] [Render thread/INFO]: [System] [CHAT] BUS » You have paid $0 for a ticket to the Amberley Bus Stop!
L1100: [15:06:35] [Render thread/INFO]: [System] [CHAT] SERVER » This Display Lectern is locked by Vernicia.

P-110 (2025-11-14-1.log) lines 1830, 1834
L1830: [17:07:12] [Render thread/INFO]: [System] [CHAT] Home vernicia has been removed.
L1834: [17:07:15] [Render thread/INFO]: [System] [CHAT] Home mzcd has been removed.
Click to expand...
1. When the log says “Teleporting to vernicia”, where exactly does that warp drop you?
2. Do you ever pass the physical entrance or doorway when you use the ‘vernicia’ warp?
3. From the spot you warp into when using the ‘vernicia’ warp, can you see the entrance where the book sits?
4. Before DHS charged you, had you ever gone to the entrance of plot c995 to read the book?
5. When the log says “Teleporting to mzcd”, where exactly does that warp drop you?
6. Do you ever pass the physical entrance or doorway when you use the ‘mzcd’ warp?
7. From the spot you warp into when using the ‘mzcd’ warp, can you see the entrance where the book sits?
8. Before DHS charged you, had you ever gone to the entrance of plot c108 to read the book?
9. Based on your normal gameplay, do you ever walk through the entrance at c108 or c995, or do you always teleport straight inside?
10. Were you inside any private area, or solely inside the public shop space that buyers and sellers access?
11. Are these the sort of trades any member of the public is allowed to make at a sell shop?
12. Why are there multiple sequences like Teleport to vernicia → sell items → teleport to hq → teleport back?
13. At any point in these logs is there any indication you approached the door where the book sits?
14. Is there anything in the logs showing you opening and reading the books?
15. At any point in these logs, did you take any action indicating you knew you were banned?
16. When did you create the warps ‘vernicia’ and ‘mzcd’?
17. Do you create warps for other stores?
18. Has anyone ever observed you warping to ‘vernicia’ or ‘mzcd’?

Questions re instructions
19. Did you ever receive any instruction from Vernicia telling you that you were banned from using c995 or c108?
20. Did you ever receive any instruction from any other person telling you that you were banned from using c995 or c108?
21. On 11th November 2025 and 12th November 2025, did you believe that you were banned from the properties c108 and c995? Why?

Questions re the books
Questions 22-28 relate to the books outside plots c108 and c995. For ease, the books’ contents (P-009, P-010, P-011, P-012, P-013, P-014, P-015, P-016, P-017, and P-018) has been linked in the quotation box below.
p-009-png.66997

p-010-png.66998

p-011-png.66999

p-012-png.67000

p-013-png.67001

p-014-png.67002

p-015-png.67003

p-016-png.67004

p-017-png.67005

p-018-png.67006
Click to expand...
22. Did you ever see the books outside c108 and c995 before you were charged with trespass?
23. Before being charged with trespass, had you ever read the books outside c108 or c995?
24. On page 4 of the book (P-012 for c995 and P-017 for c108), what is shown?
25. Look at exhibit P-019, showing one of the entrances to c995. What is visible above the book?
26. Given your answers to questions 24 and 25, why did you enter the entrance of c995 in the past?
27. What is shown on pages 2 and 3 of the books?
28. What does the book state that the ‘ban list’ is for?

Questions re criminal record and appeal attempt
29. When did you find out that you had been found guilty of trespass?
30. Did you make any attempt to appeal or dispute the trespass findings?
31. What was the outcome of any dispute or appeal, and was there any response from the department?
32. Based on your knowledge, is the book outside c995 the only evidence DHS had to support the ‘instruction’ element of their trespass finding against you?


Witness 2: Vernicia​

Questions re instructions
1. When did you add the plaintiff’s name to the ‘ban list’ pages of the books outside the entrances to c108 and c995?
2. How did you notify the plaintiff that he was banned from c108 and c995?
3. Why did you not serve notice to the Plaintiff that he was banned from c108 and c995?
4. Have you ever been warned about toxic behaviour?

Questions re the books
Questions 5-11 relate to the books outside plots c108 and c995. For ease, the books’ contents (P-009, P-010, P-011, P-012, P-013, P-014, P-015, P-016, P-017, and P-018) has been linked in a quotation box below.
p-009-png.66997

p-010-png.66998

p-011-png.66999

p-012-png.67000

p-013-png.67001

p-014-png.67002

p-015-png.67003

p-016-png.67004

p-017-png.67005

p-018-png.67006
Click to expand...
5. In the books outside c108 and c995, what do they state is the specific conduct that people whose name appears on the ‘ban list’ are banned from doing?
6. Where in these books does it state that the contents can be unilaterally updated and amended without notice?
7. Do the rules on page 4 of the books apply to everyone, or just to people listed on the ‘ban list’?
8. Look at exhibit P-019, showing one of the entrances to c995. You have designated c995 as a ‘restricted area’, have you not?
9. Based on your answers to questions 7 and 8, is everyone banned from c995?
10. What does it mean ‘this plot is part of MZ’?
11. Do you consider c108 and c995 to all be part of the same organisation?


Witness 3: Goldendude15, Police Officer​

1. Please look at the discord ticket (exhibits D-T01, D-T02, D-T03, and D-T04) and the Plaintiff’s criminal record (exhibit P-001). What procedure did you follow when evaluating the complaint from Vernicia?
2. Did you verify that the Plaintiff had received any prior notice or ban instruction before issuing the trespass charge?
3. Did you confirm that the ‘ban list’ in the book was updated before the sales transactions that formed the basis for the trespass charges?
4. Have you used the ‘ban-list’ book method before in other trespass cases? Did the same evidentiary standards apply?
5. In your view, does a book placed outside a property entrance (without proof of service) meet the legal requirement of “instruction” for trespass under the Criminal Code?


Witness 4: Roryyy_, Secretary of Homeland Security​

1. Is there an official or unofficial DHS policy that treats a property-owner’s ‘ban-list’ book placed outside a property entrance as a valid instruction of trespass ban?
2. Is there a requirement for proof of service or confirmation that the accused saw the book or was informed of a ban?
3. Have there been prior cases where DHS convicted people based solely on this ‘ban-list’ book evidence?
4. What standard of proof does DHS require before entering a criminal record for trespass arising from private citizen complaints using ‘ban-list’ books?
5. In your view, does a book placed outside a property entrance (without proof of service) meet the legal requirement of “instruction” for trespass under the Criminal Code?

 

Brief


IN THE DISTRICT COURT OF THE COMMONWEALTH OF REDMONT
SUBMISSION OF WITNESS QUESTIONS

Vernicia​

  1. The brick wall in Exhibit P-006 - what does it surround?
  2. Regarding the brick wall in Exhibit P-019 - what does it surround?
  3. Regarding the brick wall in Exhibit P-020 - what does it surround?
  4. What is the relationship, if any, between the brick wall in Exhibit P-006 and Exhibit P-019?
  5. The door in Exhibit P-021 - what does it lead into?
  6. The opening of the stone brick structure in Exhibit P-022 - what does it lead into?
  7. Why are there books on lecterns outside of your plot c995?
  8. Why are there books on lecterns outside of your plot c108?
  9. Please take a look at the staff logs in Exhibits Staff-1 and Staff-2. What is the written book that was placed in these logs?
  10. Regarding the book shown in Exhibits P-009 through P-013, where did you place copies of this book?
    1. When did you place these copies?
  11. What does it mean when someone is on the "ban list' shown in the books within Exhibits P-003 through P-022?
  12. In Exhibit P-010, it appears that "Rorryyy_" is on your ban list. Why is he on this ban list?
  13. In Exhibit D-T02 and D-T03, there are multiple strings of blue text ending in ".png". What were these strings of blue text at the time that you send them in the ticket?

 
Objections due all questions due on 11/30/25 @ 10pm EST; Extensions will be granted if requested within the window.

@Franciscus @jsrkiwi

For any objections, please don`t spam objection boxes! Put it all into one and just refer to the question
For example:

Goldendude15 Q1, <objection>, <reason>
Goldendude15 Q3, <objection>,<reason>
 
jsrkiwi said:

Brief


IN THE DISTRICT COURT OF THE COMMONWEALTH OF REDMONT

PLAINTIFF’S CONSOLIDATED LIST OF WITNESS QUESTIONS

Your Honour, the Plaintiff’s consolidated list of witness questions is laid out below.

Witness 1: jsrkiwi, Plaintiff​

Questions re logs, sales, and travel
Questions 1-18 relate to the Plaintiff’s Minecraft logs (exhibits P-101, P-102, P-103, P-104, P-105, P-106, P-107, P-108, and P-110). For ease, lines relevant to these questions have been extracted from the exhibits and have been included in the quotation box below.

1. When the log says “Teleporting to vernicia”, where exactly does that warp drop you?
2. Do you ever pass the physical entrance or doorway when you use the ‘vernicia’ warp?
3. From the spot you warp into when using the ‘vernicia’ warp, can you see the entrance where the book sits?
4. Before DHS charged you, had you ever gone to the entrance of plot c995 to read the book?
5. When the log says “Teleporting to mzcd”, where exactly does that warp drop you?
6. Do you ever pass the physical entrance or doorway when you use the ‘mzcd’ warp?
7. From the spot you warp into when using the ‘mzcd’ warp, can you see the entrance where the book sits?
8. Before DHS charged you, had you ever gone to the entrance of plot c108 to read the book?
9. Based on your normal gameplay, do you ever walk through the entrance at c108 or c995, or do you always teleport straight inside?
10. Were you inside any private area, or solely inside the public shop space that buyers and sellers access?
11. Are these the sort of trades any member of the public is allowed to make at a sell shop?
12. Why are there multiple sequences like Teleport to vernicia → sell items → teleport to hq → teleport back?
13. At any point in these logs is there any indication you approached the door where the book sits?
14. Is there anything in the logs showing you opening and reading the books?
15. At any point in these logs, did you take any action indicating you knew you were banned?
16. When did you create the warps ‘vernicia’ and ‘mzcd’?
17. Do you create warps for other stores?
18. Has anyone ever observed you warping to ‘vernicia’ or ‘mzcd’?

Questions re instructions
19. Did you ever receive any instruction from Vernicia telling you that you were banned from using c995 or c108?
20. Did you ever receive any instruction from any other person telling you that you were banned from using c995 or c108?
21. On 11th November 2025 and 12th November 2025, did you believe that you were banned from the properties c108 and c995? Why?

Questions re the books
Questions 22-28 relate to the books outside plots c108 and c995. For ease, the books’ contents (P-009, P-010, P-011, P-012, P-013, P-014, P-015, P-016, P-017, and P-018) has been linked in the quotation box below.

22. Did you ever see the books outside c108 and c995 before you were charged with trespass?
23. Before being charged with trespass, had you ever read the books outside c108 or c995?
24. On page 4 of the book (P-012 for c995 and P-017 for c108), what is shown?
25. Look at exhibit P-019, showing one of the entrances to c995. What is visible above the book?
26. Given your answers to questions 24 and 25, why did you enter the entrance of c995 in the past?
27. What is shown on pages 2 and 3 of the books?
28. What does the book state that the ‘ban list’ is for?

Questions re criminal record and appeal attempt
29. When did you find out that you had been found guilty of trespass?
30. Did you make any attempt to appeal or dispute the trespass findings?
31. What was the outcome of any dispute or appeal, and was there any response from the department?
32. Based on your knowledge, is the book outside c995 the only evidence DHS had to support the ‘instruction’ element of their trespass finding against you?


Witness 2: Vernicia​

Questions re instructions
1. When did you add the plaintiff’s name to the ‘ban list’ pages of the books outside the entrances to c108 and c995?
2. How did you notify the plaintiff that he was banned from c108 and c995?
3. Why did you not serve notice to the Plaintiff that he was banned from c108 and c995?
4. Have you ever been warned about toxic behaviour?

Questions re the books
Questions 5-11 relate to the books outside plots c108 and c995. For ease, the books’ contents (P-009, P-010, P-011, P-012, P-013, P-014, P-015, P-016, P-017, and P-018) has been linked in a quotation box below.

5. In the books outside c108 and c995, what do they state is the specific conduct that people whose name appears on the ‘ban list’ are banned from doing?
6. Where in these books does it state that the contents can be unilaterally updated and amended without notice?
7. Do the rules on page 4 of the books apply to everyone, or just to people listed on the ‘ban list’?
8. Look at exhibit P-019, showing one of the entrances to c995. You have designated c995 as a ‘restricted area’, have you not?
9. Based on your answers to questions 7 and 8, is everyone banned from c995?
10. What does it mean ‘this plot is part of MZ’?
11. Do you consider c108 and c995 to all be part of the same organisation?


Witness 3: Goldendude15, Police Officer​

1. Please look at the discord ticket (exhibits D-T01, D-T02, D-T03, and D-T04) and the Plaintiff’s criminal record (exhibit P-001). What procedure did you follow when evaluating the complaint from Vernicia?
2. Did you verify that the Plaintiff had received any prior notice or ban instruction before issuing the trespass charge?
3. Did you confirm that the ‘ban list’ in the book was updated before the sales transactions that formed the basis for the trespass charges?
4. Have you used the ‘ban-list’ book method before in other trespass cases? Did the same evidentiary standards apply?
5. In your view, does a book placed outside a property entrance (without proof of service) meet the legal requirement of “instruction” for trespass under the Criminal Code?


Witness 4: Roryyy_, Secretary of Homeland Security​

1. Is there an official or unofficial DHS policy that treats a property-owner’s ‘ban-list’ book placed outside a property entrance as a valid instruction of trespass ban?
2. Is there a requirement for proof of service or confirmation that the accused saw the book or was informed of a ban?
3. Have there been prior cases where DHS convicted people based solely on this ‘ban-list’ book evidence?
4. What standard of proof does DHS require before entering a criminal record for trespass arising from private citizen complaints using ‘ban-list’ books?
5. In your view, does a book placed outside a property entrance (without proof of service) meet the legal requirement of “instruction” for trespass under the Criminal Code?

Click to expand...
Muggy21 said:
Objections due all questions due on 11/30/25 @ 10pm EST; Extensions will be granted if requested within the window.

@Franciscus @jsrkiwi

For any objections, please don`t spam objection boxes! Put it all into one and just refer to the question
For example:

Goldendude15 Q1, <objection>, <reason>
Goldendude15 Q3, <objection>,<reason>
Click to expand...

Objection


IN THE DISTRICT COURT OF THE COMMONWEALTH OF REDMONT
SUBMISSION OF OBJECTIONS TO WITNESS QUESTIONS

Your Honor:

The defense submits objections of the following witness questions, and as follows:

Witness 1: jsrkiwi​

Question 2 ("Do you ever pass the physical entrance or doorway when you use the ‘vernicia’ warp?") and Question 6 ("Do you ever pass the physical entrance or doorway when you use the ‘mzcd’ warp?").​

OBJECTION - LEADING QUESTIONS​

Your Honor,

In Redmont, “questions that suggest the desired answer or include information the examiner seeks to confirm” are considered leading questions (objections guide).

These questions include information that the examiner (plaintiff's counsel/plaintiff) seeks to confirm, regarding the passage through physical entrances or doorways.

Question 3 ("From the spot you warp into when using the ‘vernicia’ warp, can you see the entrance where the book sits?") and Question 7 ("From the spot you warp into when using the ‘mzcd’ warp, can you see the entrance where the book sits?")​

OBJECTION - LEADING QUESTIONS​

Your Honor,

These questions include information that the examiner (plaintiff's counsel/plaintiff) would appear to seek to confirm (i.e. that the Plaintiff can "see the entrance where the book sits").

Question 4 ("Before DHS charged you, had you ever gone to the entrance of plot c995 to read the book?") and Question 8 ("Before DHS charged you, had you ever gone to the entrance of plot c108 to read the book?").​

OBJECTION - LEADING QUESTIONS​

Your Honor,

This question includes information that the examiner (plaintiff's counsel/plaintiff) seeks to confirm. This one is especially leading, as it asks the Plaintiff to confirm whether or not they'd gone to the entrance of c995 to read the book, as if that was the purpose of going to the plot.

OBJECTION - RELEVANCE​

Your Honor,

The question asks if the Plaintiff has ever gone to a plot to read the book. The Defense argues that the purpose of visiting a plot is not relevant to this case.

Question 9 ("Based on your normal gameplay, do you ever walk through the entrance at c108 or c995, or do you always teleport straight inside?").​

OBJECTION - COMPOUND QUESTION​

Your Honor,

Per the Objections Guide, "A question that includes multiple inquiries" is a compound question, and it's objectionable because it "can confuse the witness". This appears to ask a bunch of different inquiries in one question. The question asks:
  1. Whether the witness ever walks through the entrance at c108
  2. Whether the witness ever walks through the entrance at c995
  3. Whether the witness "always" teleports straight inside (presumably at either plot).
These items should be asked separately; it is possible (for example) that the witness may have at times walked through the entrance at c108 and not at c995.

OBJECTION - LEADING QUESTIONS​

Your Honor,

This question includes information that the examiner (plaintiff's counsel/plaintiff) seeks to confirm (i.e. if the Plaintiff were to "always teleport straight inside" or if the Plaintiff were to "ever walk through the entrance at c108 or c995").

Question 10 ("Were you inside any private area, or solely inside the public shop space that buyers and sellers access?").​

OBJECTION - LEADING QUESTIONS​

Your Honor,

This question includes information that the examiner (plaintiff's counsel/plaintiff) seeks to confirm (i.e. if the Plaintiff were to have been "inside any private area" or if the Plaintiff were to "solely inside the public shop space that buyers and sellers access"). This also leads the witness against any other sort of answers that one might possibly give, such as being in a public space but not in the shop space.

OBJECTION - COMPOUND QUESTION​

Your Honor,

Per the Objections Guide, "A question that includes multiple inquiries" is a compound question, and it's objectionable because it "can confuse the witness". This appears to ask a bunch of different inquiries in one question. The question asks:
  1. Whether the witness was inside a private area
  2. Whether the witness, alternatively, was inside a "public shop space that buyers and sellers access"
These items should be asked separately, or alternatively in an open ended manner that permits the witness to describe for themself where they were.

Question 11 ("Are these the sort of trades any member of the public is allowed to make at a sell shop?"​

OBJECTION - LEADING QUESTIONS​

Your Honor,

This question includes information that the examiner (plaintiff's counsel/plaintiff) seeks to confirm (i.e. if "these" were "the sort of trades any member of the public is allowed to make at a sell shop".

OBJECTION - AMBIGUOUS​

Your Honor,

This is essentially a "yes" or "no" question asking about "the sort of trades", but this feels a bit unclear regarding what is meant by that.

Question 13 ("At any point in these logs is there any indication you approached the door where the book sits?")​

OBJECTION - CALLS FOR CONCLUSION​

Your Honor,

The question is essentially asking the witness to analyze the logs and come up with an opinion regarding whether or not there is evidence in the logs that the witness "approached the door where the book sits". This appears to be a subjective opinion, and the witness is not established as an expert on the analysis of Minecraft logs.

OBJECTION - LEADING QUESTIONS​

Your Honor,

This question includes information that the examiner (plaintiff's counsel/plaintiff) seeks to confirm, namely whether there is "is there any indication" in logs regarding whether the witness "approached the door where the book sits".

Question 14 ("Is there anything in the logs showing you opening and reading the books?")​

OBJECTION - COMPOUND QUESTION​

Your Honor,

Per the Objections Guide, "A question that includes multiple inquiries" is a compound question, and it's objectionable because it "can confuse the witness". This appears to ask a bunch of different inquiries in one question. The question's use of "and" here seems to include multiple inquiries here; it can only be answered in the affirmative if the logs showed both opening and reading the books.

OBJECTION - CALLS FOR CONCLUSION​

Your Honor,

The question is essentially asking the witness to analyze the logs and come up with an opinion regarding whether or not there is evidence in the logs that shows the witness "openinging and reading the books". This appears to be a subjective opinion, and the witness is not established as an expert on the analysis of Minecraft logs.

OBJECTION - LEADING QUESTIONS​

Your Honor,

This question includes information that the examiner (plaintiff's counsel/plaintiff) seeks to confirm, namely whether there is "anything in the logs" regarding whether the witness opened and read books.

Question 15. ("At any point in these logs, did you take any action indicating you knew you were banned?")​

OBJECTION - LEADING QUESTIONS​

Your Honor,

This question includes information that the examiner (plaintiff's counsel/plaintiff) seeks to confirm, namely whether there the Plaintiff took "any action indicating" that the witness knew that the witness was banned.

Question 17. ("Do you create warps for other stores?")​

OBJECTION - RELEVANCE​

Your Honor,

This case is about trespass for two stores - c108 and c995. I do not see how the creation of warps for other stores would be relevant here.

Question 18. ("Has anyone ever observed you warping to ‘vernicia’ or ‘mzcd’?")​

OBJECTION - SPECULATION​

Your Honor,

I do not believe that we have a foundation in evidence to establish whether the witness would have knowledge of whether others actually saw them warping - while third persons be able to testify to this fact, it's not obvious that the individual who may claim to have been seen would have this knowledge. Under the Objections guide, "Witnesses should only provide testimony about their own direct experiences and thoughts".

OBJECTION - LEADING QUESTIONS​

Your Honor,

In Redmont, “questions that suggest the desired answer or include information the examiner seeks to confirm” are considered leading questions (objections guide).

Again, this question includes information that the examiner (plaintiff's counsel/plaintiff) seeks to confirm, namely whether the "anyone ever observed " the Plaintiff warping to/from the relevant points.

Question 19. ("Did you ever receive any instruction from Vernicia telling you that you were banned from using c995 or c108?"​

OBJECTION - COMPOUND QUESTION​

Your Honor,

This question asks the witness about information pertaining to two separate plots - c995 and c108. Asking a "yes" or "no" question that joins them with a disjunctive conjunction ("or") turns this into a compound question where the witness is being asked essentially two queries at once.

​

OBJECTION - LEADING QUESTIONS​

Your Honor,

In this case, Plaintiff's counsel (Plaintiff) is asking witness (Plaintiff) to testify regarding whether the Plaintiff-witness-counsel "receive[d] any instruction from Vernicia", thereby including information the Plaintiff seeks to confirm.


Question 20. ("Did you ever receive any instruction from any other person telling you that you were banned from using c995 or c108?")​

OBJECTION - COMPOUND QUESTION​

Your Honor,

This question asks the witness about information pertaining to two separate plots - c995 and c108. Asking a "yes" or "no" question that joins them with a disjunctive conjunction ("or") turns this into a compound question where the witness is being asked essentially two queries at once.


OBJECTION - LEADING QUESTIONS​

Your Honor,

In this case, Plaintiff's counsel (Plaintiff) is asking witness (Plaintiff) to testify regarding whether the Plaintiff-witness-counsel believed that they "receive[d] any instruction from any other person ", thereby including information the Plaintiff seeks to confirm.

Question 21. ("On 11th November 2025 and 12th November 2025, did you believe that you were banned from the properties c108 and c995? Why?"​

OBJECTION - Compound Question​

Your Honor,

This plainly asks two questions. There are even two separate question marks. It also asks if the Plaintiff believed that they were banned from c108 and c995, which is another element of compounding here; two separate plots are mentioned.

OBJECTION - LEADING QUESTIONS​

Your Honor,

In this case, Plaintiff's counsel (Plaintiff) is asking witness (Plaintiff) to testify regarding whether the Plaintiff-witness-counsel believed that they "were banned from the properties c108 and c995", thereby including information the Plaintiff seeks to confirm.

Question 22. ("Did you ever see the books outside c108 and c995 before you were charged with trespass?")​

OBJECTION - LEADING QUESTIONS​

Your Honor,

In this case, Plaintiff's counsel (Plaintiff) is asking witness (Plaintiff) to testify regarding whether the Plaintiff-witness-counsel saw "the books outside c108 and c995", thereby including information the Plaintiff seeks to confirm.

Question 23. ("Before being charged with trespass, had you ever read the books outside c108 or c995?")​

OBJECTION - COMPOUND QUESTION​

This question asks the witness about information pertaining to two separate plots - c995 and c108. Asking a "yes" or "no" question that joins them with a disjunctive conjunction ("or") turns this into a compound question where the witness is being asked essentially two queries at once.

OBJECTION - LEADING QUESTIONS​

Your Honor,

In this case, Plaintiff's counsel (Plaintiff) is asking witness (Plaintiff) to testify regarding whether the Plaintiff-witness-counsel saw "read the books outside c108 or c995", thereby including information the Plaintiff seeks to confirm.

Question 31. ("What was the outcome of any dispute or appeal, and was there any response from the department?")​

OBJECTION - COMPOUND QUESTION​

Your Honor,

This is asking two substantial queries:
  1. Whether the department responded; and
  2. What the outcome of any dispute/appeal was.
These should be severed and asked separately, if at all.

Question 32. ("Based on your knowledge, is the book outside c995 the only evidence DHS had to support the ‘instruction’ element of their trespass finding against you?")​

OBJECTION - LEADING QUESTIONS​

Your Honor,

In this case, Plaintiff's counsel (Plaintiff) is asking witness (Plaintiff) to testify regarding whether the Plaintiff-witness-counsel believes that "the book outside c995 the only evidence DHS had to support the ‘instruction’ element of their trespass finding against", thereby including information the Plaintiff seeks to confirm.

Witness 2: Vernicia​

Question 3. ("Why did you not serve notice to the Plaintiff that he was banned from c108 and c995?")​

OBJECTION - ARGUMENTATIVE​

Your Honor:

Rather than neutrally asking what the witness did, the question frames her as having failed in a duty and more or less asks her to defend herself. The question should be rephrased neutrally, especially on direct.

OBJECTION - ASSUMES FACTS NOT IN EVIDENCE​

Your Honor,

In question 2, the Plaintiff asks the witness the question "How did you notify the plaintiff that he was banned from c108 and c995?".

Here, we are making an assumption - that no such notification was made. This needs to be established before such a question like this is made - we cannot assume the answer to the second question before it is answered.

Question 4. ("Have you ever been warned about toxic behaviour?")​

OBJECTION - PRIVILEGE​

Your Honor,

Under Server Rule 1, "Politicizing staff actions, for the sake of roleplay or otherwise, is strictly prohibited. There must be an undeniable separation between staffing and state and this is heavily policed." If a warning for toxicity were issued by staff, it cannot be used in the context of roleplay.

We therefore assert a staff rules privilege regarding this question, as it appears to directly ask about whether a staff punishment action occurred for use in roleplay purposes.

OBJECTION - RELEVANCE​

Your Honor,

Whether the witness has received a staff warning is not relevant to this case's substance.

OBJECTION - LEADING QUESTIONS​

Your Honor,

These questions include information that the examiner (plaintiff's counsel/plaintiff) seeks to confirm, regarding the existence or not of a staff warning for toxicity.

Question 5. ("In the books outside c108 and c995, what do they state is the specific conduct that people whose name appears on the ‘ban list’ are banned from doing?")​

OBJECTION – AMBIGUOUS / CALLS FOR A CONCLUSION​

Your Honor,

The question is unclear as to what “specific conduct” means and invites the witness to interpret or characterize the legal effect of the book, rather than simply state what the text says. Counsel should rephrase the question to ask the witness to identify or read the relevant wording.

Question 6. ("Where in these books does it state that the contents can be unilaterally updated and amended without notice?")​

OBJECTION - LEADING QUESTIONS and ASSUMES FACTS NOT IN EVIDENCE​

Your Honor,

The question a loaded proposition (“can be unilaterally updated and amended without notice”) and pushes the witness to agree there’s no such text – that's leading because it suggests the desired answer.

It also assumes that any authority to update must be written in the book itself; that hasn’t been established and is really a legal theory, not a fact already in evidence.

Question 8. ("Look at exhibit P-019, showing one of the entrances to c995. You have designated c995 as a ‘restricted area’, have you not?")​

OBJECTION - LEADING QUESTIONS​

Your Honor,

This is a classic leading question - the Plaintiff is including the information they seek to confirm, and then ask the witness "have you not?" in order to confirm it. This is among the most leading questions in the batch.

Question 9. ("Based on your answers to questions 7 and 8, is everyone banned from c995?")​

OBJECTION - CALLS FOR CONCLUSION​

Your Honor,

This question seeks to ask the witness to provide an opinion based upon prior (not yet given) answers regarding a legal conclusion (whether everyone is banned from c995).

Question 10. ("What does it mean ‘this plot is part of MZ’?")​

OBJECTION - RELEVANCE​

Your Honor,

The Defense does not see how this would plausibly be relevant to any claim for relief or factual allegation.

Question 11. ("Do you consider c108 and c995 to all be part of the same organisation?")​

OBJECTION - RELEVANCE​

Your Honor,

Again, the Defense does not see how this would plausibly be relevant to any claim for relief or factual allegation.

Witness 3: Goldendude15​

Question 2. ("Did you verify that the Plaintiff had received any prior notice or ban instruction before issuing the trespass charge?")​

OBJECTION - LEADING QUESTIONS​

Your Honor,

These questions include information that the examiner (plaintiff's counsel/plaintiff) seeks to confirm, regarding whether or not the witness had "verif[ied] that the Plaintiff had received any prior notice or ban instruction before issuing the trespass charge". The Plaintiff should be directed to use open-ended questions.

Question 3. ("Did you confirm that the ‘ban list’ in the book was updated before the sales transactions that formed the basis for the trespass charges?")​

OBJECTION - LEADING QUESTIONS​

Your Honor,

These questions include information that the examiner (plaintiff's counsel/plaintiff) seeks to confirm, regarding whether or not the witness had confirmed "that the ‘ban list’ in the book was updated before the sales transactions that formed the basis for the trespass charges". The Plaintiff should be directed to use open-ended questions.

Question 4. ("Have you used the ‘ban-list’ book method before in other trespass cases? Did the same evidentiary standards apply?")​

OBJECTION - COMPOUND QUESTION​

Your Honor,

This is seeking to include multiple inquiries in one question. There are multiple sentences with multiple distinct questions here.

​

OBJECTION - LEADING QUESTIONS​

Your Honor,

These questions include information that the examiner (plaintiff's counsel/plaintiff) seeks to confirm. The Plaintiff should be directed to use open-ended questions.

Question 5. ("In your view, does a book placed outside a property entrance (without proof of service) meet the legal requirement of 'instruction' for trespass under the Criminal Code?")​

OBJECTION - CALLS FOR CONCLUSION​

Your Honor,

The question is asking the witness to give a legal opinion.

Witness 4: Roryyy_​

Question 1 ("Is there an official or unofficial DHS policy that treats a property-owner’s ‘ban-list’ book placed outside a property entrance as a valid instruction of trespass ban?")​

OBJECTION - COMPOUND QUESTION​

Your Honor,

This is asking two separate cognizable queries:
  1. Whether an unofficial policy exists;
  2. Whether an ofificial policy exists.
These should be severed.

OBJECTION - LEADING QUESTIONS​

These questions include information that the examiner (plaintiff's counsel/plaintiff) seeks to confirm. The Plaintiff should be directed to use open-ended questions.

Question 3 ("Have there been prior cases where DHS convicted people based solely on this ‘ban-list’ book evidence?")​

OBJECTION - AMBIGUOUS​

Your Honor,

It is unclear what "this 'ban-list' book evidence" means or how it would apply to others. The ban-list book evidence in this case pertains to one individual.

Question 5 ("In your view, does a book placed outside a property entrance (without proof of service) meet the legal requirement of “instruction” for trespass under the Criminal Code?")​

OBJECTION - CALLS FOR CONCLUSION​

Your Honor,

This asks for a legal opinion.

 
PLAINTIFF’S RESPONSE TO DEFENDANT’S OBJECTIONS TO WITNESS QUESTIONS

Your Honour, I’ve included the Defendant’s objections in quotation boxes throughout for clarity. Many of the objections are repetitive, so the Plaintiff addresses them in groups where relevant, for efficiency.

To save the Court’s time, a consolidated list of question amendments, and proposed alternatives in the event of objections being sustained, is provided at the end of this response instead of throughout.

Hostile witnesses: Vernicia, Goldendude15, Roryyy_​

For the sake of brevity, the Plaintiff addresses all leading question objections to these three witnesses in one section.

Witnesses Vernicia, Goldendude15, and Roryyy_ have interests opposed to the Plaintiff’s, and are therefore treated as hostile witnesses. Vernicia made the police complaint; Goldendude15 processed it, found the Plaintiff guilty, and issued a fine; Roryyy_, as Secretary of Homeland Security, oversees the Defendant department. Leading questions are, therefore, permissible.

Witness 1: jsrkiwi​

Questions 2, 3, 6, and 7 (Defendant’s objection: leading)
Franciscus said:

Question 2 ("Do you ever pass the physical entrance or doorway when you use the ‘vernicia’ warp?") and Question 6 ("Do you ever pass the physical entrance or doorway when you use the ‘mzcd’ warp?").​

OBJECTION - LEADING QUESTIONS​

Your Honor,

In Redmont, “questions that suggest the desired answer or include information the examiner seeks to confirm” are considered leading questions (objections guide).

These questions include information that the examiner (plaintiff's counsel/plaintiff) seeks to confirm, regarding the passage through physical entrances or doorways.

Question 3 ("From the spot you warp into when using the ‘vernicia’ warp, can you see the entrance where the book sits?") and Question 7 ("From the spot you warp into when using the ‘mzcd’ warp, can you see the entrance where the book sits?")​

OBJECTION - LEADING QUESTIONS​

Your Honor,

These questions include information that the examiner (plaintiff's counsel/plaintiff) would appear to seek to confirm (i.e. that the Plaintiff can "see the entrance where the book sits").
Click to expand...
These questions are simple yes/no questions; they do not embed a contested fact. Therefore, the Plaintiff asks Your Honour to overrule these objections.

Questions 4 and 8 (Defendant’s objections: leading and relevance)
Franciscus said:

Question 4 ("Before DHS charged you, had you ever gone to the entrance of plot c995 to read the book?") and Question 8 ("Before DHS charged you, had you ever gone to the entrance of plot c108 to read the book?").​

OBJECTION - LEADING QUESTIONS​

Your Honor,

This question includes information that the examiner (plaintiff's counsel/plaintiff) seeks to confirm. This one is especially leading, as it asks the Plaintiff to confirm whether or not they'd gone to the entrance of c995 to read the book, as if that was the purpose of going to the plot.

OBJECTION - RELEVANCE​

Your Honor,

The question asks if the Plaintiff has ever gone to a plot to read the book. The Defense argues that the purpose of visiting a plot is not relevant to this case.
Click to expand...
Re leading: Asking whether the witness has ever visited a certain location, and read a book at that location, is a straightforward factual question. The Plaintiff disagrees with the Defendant’s assertion that the question presupposes a special purposeful visit to the plot.

Re relevance: The Defendant’s own response makes clear that a key question of fact in this case is whether the Plaintiff had read the books in question. This question is directly pertinent to those facts.

Question 9 (Defendant’s objections: compound and leading)
Franciscus said:

Question 9 ("Based on your normal gameplay, do you ever walk through the entrance at c108 or c995, or do you always teleport straight inside?").​

OBJECTION - COMPOUND QUESTION​

Your Honor,

Per the Objections Guide, "A question that includes multiple inquiries" is a compound question, and it's objectionable because it "can confuse the witness". This appears to ask a bunch of different inquiries in one question. The question asks:
  1. Whether the witness ever walks through the entrance at c108
  2. Whether the witness ever walks through the entrance at c995
  3. Whether the witness "always" teleports straight inside (presumably at either plot).
These items should be asked separately; it is possible (for example) that the witness may have at times walked through the entrance at c108 and not at c995.

OBJECTION - LEADING QUESTIONS​

Your Honor,

This question includes information that the examiner (plaintiff's counsel/plaintiff) seeks to confirm (i.e. if the Plaintiff were to "always teleport straight inside" or if the Plaintiff were to "ever walk through the entrance at c108 or c995").
Click to expand...
Your Honour, the Plaintiff does not oppose the objection.

Questions 10 and 11 (Defendant’s objections: leading, compound, and ambiguous)
Franciscus said:

Question 10 ("Were you inside any private area, or solely inside the public shop space that buyers and sellers access?").​

OBJECTION - LEADING QUESTIONS​

Your Honor,

This question includes information that the examiner (plaintiff's counsel/plaintiff) seeks to confirm (i.e. if the Plaintiff were to have been "inside any private area" or if the Plaintiff were to "solely inside the public shop space that buyers and sellers access"). This also leads the witness against any other sort of answers that one might possibly give, such as being in a public space but not in the shop space.

OBJECTION - COMPOUND QUESTION​

Your Honor,

Per the Objections Guide, "A question that includes multiple inquiries" is a compound question, and it's objectionable because it "can confuse the witness". This appears to ask a bunch of different inquiries in one question. The question asks:
  1. Whether the witness was inside a private area
  2. Whether the witness, alternatively, was inside a "public shop space that buyers and sellers access"
These items should be asked separately, or alternatively in an open ended manner that permits the witness to describe for themself where they were.

Question 11 ("Are these the sort of trades any member of the public is allowed to make at a sell shop?"​

OBJECTION - LEADING QUESTIONS​

Your Honor,

This question includes information that the examiner (plaintiff's counsel/plaintiff) seeks to confirm (i.e. if "these" were "the sort of trades any member of the public is allowed to make at a sell shop".

OBJECTION - AMBIGUOUS​

Your Honor,

This is essentially a "yes" or "no" question asking about "the sort of trades", but this feels a bit unclear regarding what is meant by that.
Click to expand...
Your Honour, the Plaintiff does not oppose these objections.

Question 13 (Defendant’s objections: calls for conclusion and leading)
Franciscus said:

Question 13 ("At any point in these logs is there any indication you approached the door where the book sits?")​

OBJECTION - CALLS FOR CONCLUSION​

Your Honor,

The question is essentially asking the witness to analyze the logs and come up with an opinion regarding whether or not there is evidence in the logs that the witness "approached the door where the book sits". This appears to be a subjective opinion, and the witness is not established as an expert on the analysis of Minecraft logs.

OBJECTION - LEADING QUESTIONS​

Your Honor,

This question includes information that the examiner (plaintiff's counsel/plaintiff) seeks to confirm, namely whether there is "is there any indication" in logs regarding whether the witness "approached the door where the book sits".
Click to expand...
This question asks the witness to examine the logs and present the lines when he approached the entrance where the books sit. It does not require him to conclude on whether he did in fact approach the entrance where the books sit.

This would be an improper question if the witness were unable to competently interpret logs. In such a case, the witness would be unable to give an objective fact (e.g. “the logs show me accessing the book at this time”) and would merely be able to offer a conclusion to a fact at issue (e.g. “yes I approached that entrance”). However, this is not the case, and in any case ought to have been brought as an incompetence objection.

Question 14 (Defendant’s objections: compound, calls for conclusion, and leading)
Franciscus said:

Question 14 ("Is there anything in the logs showing you opening and reading the books?")​

OBJECTION - COMPOUND QUESTION​

Your Honor,

Per the Objections Guide, "A question that includes multiple inquiries" is a compound question, and it's objectionable because it "can confuse the witness". This appears to ask a bunch of different inquiries in one question. The question's use of "and" here seems to include multiple inquiries here; it can only be answered in the affirmative if the logs showed both opening and reading the books.

OBJECTION - CALLS FOR CONCLUSION​

Your Honor,

The question is essentially asking the witness to analyze the logs and come up with an opinion regarding whether or not there is evidence in the logs that shows the witness "openinging and reading the books". This appears to be a subjective opinion, and the witness is not established as an expert on the analysis of Minecraft logs.

OBJECTION - LEADING QUESTIONS​

Your Honor,

This question includes information that the examiner (plaintiff's counsel/plaintiff) seeks to confirm, namely whether there is "anything in the logs" regarding whether the witness opened and read books.
Click to expand...
Re compound: This question is not compound, as opening and reading are the same action in Minecraft.

Re calls for conclusion: This question asks the witness to examine the logs and present the lines when he opened a book. It does not require him to conclude on whether he did in fact open a book.

Re leading: This is a straightforward request for factual information from the witness’s own knowledge of logs. It does not presuppose any particular answer.

Question 15 (Defendant’s objection: leading)
Franciscus said:

Question 15. ("At any point in these logs, did you take any action indicating you knew you were banned?")​

OBJECTION - LEADING QUESTIONS​

Your Honor,

This question includes information that the examiner (plaintiff's counsel/plaintiff) seeks to confirm, namely whether there the Plaintiff took "any action indicating" that the witness knew that the witness was banned.
Click to expand...
Your Honour, the Plaintiff does not oppose the objection, and humbly withdraws the question.

Question 17 (Defendant’s objection: relevance)
Franciscus said:

Question 17. ("Do you create warps for other stores?")​

OBJECTION - RELEVANCE​

Your Honor,

This case is about trespass for two stores - c108 and c995. I do not see how the creation of warps for other stores would be relevant here.
Click to expand...
A key part of the Defendant’s answer to complaint is the DHS’ denial that “the book shown in the second screenshot was never visible to him”. In support of this disputed fact, the Plaintiff needs to show that he warps into the relevant plots (dealt with in other questions) and that warping into stores is a standard navigational tool, and part of his normal behaviour.

Question 18 (Defendant’s objection: leading)
Franciscus said:

Question 18. ("Has anyone ever observed you warping to ‘vernicia’ or ‘mzcd’?")​

OBJECTION - SPECULATION​

Your Honor,

I do not believe that we have a foundation in evidence to establish whether the witness would have knowledge of whether others actually saw them warping - while third persons be able to testify to this fact, it's not obvious that the individual who may claim to have been seen would have this knowledge. Under the Objections guide, "Witnesses should only provide testimony about their own direct experiences and thoughts".

OBJECTION - LEADING QUESTIONS​

Your Honor,

In Redmont, “questions that suggest the desired answer or include information the examiner seeks to confirm” are considered leading questions (objections guide).

Again, this question includes information that the examiner (plaintiff's counsel/plaintiff) seeks to confirm, namely whether the "anyone ever observed " the Plaintiff warping to/from the relevant points.
Click to expand...
Your Honour, the Plaintiff does not oppose these objections.

Questions 19 and 20 (Defendant’s objection: compound and leading)
Franciscus said:

Question 19. ("Did you ever receive any instruction from Vernicia telling you that you were banned from using c995 or c108?"​

OBJECTION - COMPOUND QUESTION​

Your Honor,

This question asks the witness about information pertaining to two separate plots - c995 and c108. Asking a "yes" or "no" question that joins them with a disjunctive conjunction ("or") turns this into a compound question where the witness is being asked essentially two queries at once.

​

OBJECTION - LEADING QUESTIONS​

Your Honor,

In this case, Plaintiff's counsel (Plaintiff) is asking witness (Plaintiff) to testify regarding whether the Plaintiff-witness-counsel "receive[d] any instruction from Vernicia", thereby including information the Plaintiff seeks to confirm.


Question 20. ("Did you ever receive any instruction from any other person telling you that you were banned from using c995 or c108?")​

OBJECTION - COMPOUND QUESTION​

Your Honor,

This question asks the witness about information pertaining to two separate plots - c995 and c108. Asking a "yes" or "no" question that joins them with a disjunctive conjunction ("or") turns this into a compound question where the witness is being asked essentially two queries at once.

​

OBJECTION - LEADING QUESTIONS​

Your Honor,

In this case, Plaintiff's counsel (Plaintiff) is asking witness (Plaintiff) to testify regarding whether the Plaintiff-witness-counsel believed that they "receive[d] any instruction from any other person ", thereby including information the Plaintiff seeks to confirm.
Click to expand...
Your Honour, the Plaintiff does not oppose these objections.

Question 21 (Defendant’s objections: compound and leading)
Franciscus said:

Question 21. ("On 11th November 2025 and 12th November 2025, did you believe that you were banned from the properties c108 and c995? Why?"​

OBJECTION - Compound Question​

Your Honor,

This plainly asks two questions. There are even two separate question marks. It also asks if the Plaintiff believed that they were banned from c108 and c995, which is another element of compounding here; two separate plots are mentioned.

OBJECTION - LEADING QUESTIONS​

Your Honor,

In this case, Plaintiff's counsel (Plaintiff) is asking witness (Plaintiff) to testify regarding whether the Plaintiff-witness-counsel believed that they "were banned from the properties c108 and c995", thereby including information the Plaintiff seeks to confirm.
Click to expand...
Re compound: Vernicia considers c995 and c108 to all be “part of MZ”. Is it reasonable to expect that the Plaintiff would be banned from both simultaneously. The second part is a follow-up question, which is allowed.

Re leading: The fact that Vernicia intended to ban the Plaintiff from the plots is not in dispute, the question is whether or when did the Plaintiff become aware.

Questions 22 and 23 (Defendant’s objection: compound and leading)
Franciscus said:

Question 22. ("Did you ever see the books outside c108 and c995 before you were charged with trespass?")​

OBJECTION - LEADING QUESTIONS​

Your Honor,

In this case, Plaintiff's counsel (Plaintiff) is asking witness (Plaintiff) to testify regarding whether the Plaintiff-witness-counsel saw "the books outside c108 and c995", thereby including information the Plaintiff seeks to confirm.

Question 23. ("Before being charged with trespass, had you ever read the books outside c108 or c995?")​

OBJECTION - COMPOUND QUESTION​

This question asks the witness about information pertaining to two separate plots - c995 and c108. Asking a "yes" or "no" question that joins them with a disjunctive conjunction ("or") turns this into a compound question where the witness is being asked essentially two queries at once.

OBJECTION - LEADING QUESTIONS​

Your Honor,

In this case, Plaintiff's counsel (Plaintiff) is asking witness (Plaintiff) to testify regarding whether the Plaintiff-witness-counsel saw "read the books outside c108 or c995", thereby including information the Plaintiff seeks to confirm.
Click to expand...
Re leading: The books have already been established by prior questions, allowing the books to be mentioned in follow-up questions.

Re compound: Vernicia considers c995 and c108 to all be “part of MZ”. Is it reasonable to expect that the Plaintiff’s name would be added to the books outside both simultaneously.

Question 31 (Defendant’s objection: compound)
Franciscus said:

Question 31. ("What was the outcome of any dispute or appeal, and was there any response from the department?")​

OBJECTION - COMPOUND QUESTION​

Your Honor,

This is asking two substantial queries:
  1. Whether the department responded; and
  2. What the outcome of any dispute/appeal was.
These should be severed and asked separately, if at all.
Click to expand...
Your Honour, the Plaintiff does not oppose this objection.

Question 32 (Defendant’s objection: leading)
Franciscus said:

Question 32. ("Based on your knowledge, is the book outside c995 the only evidence DHS had to support the ‘instruction’ element of their trespass finding against you?")​

OBJECTION - LEADING QUESTIONS​

Your Honor,

In this case, Plaintiff's counsel (Plaintiff) is asking witness (Plaintiff) to testify regarding whether the Plaintiff-witness-counsel believes that "the book outside c995 the only evidence DHS had to support the ‘instruction’ element of their trespass finding against", thereby including information the Plaintiff seeks to confirm.
Click to expand...
Your Honour, the Plaintiff does not oppose this objection.

Witness 2: Vernicia​

Question 3 (Defendant’s objection: argumentative and assumes facts not in evidence)
Franciscus said:

Question 3. ("Why did you not serve notice to the Plaintiff that he was banned from c108 and c995?")​

OBJECTION - ARGUMENTATIVE​

Your Honor:

Rather than neutrally asking what the witness did, the question frames her as having failed in a duty and more or less asks her to defend herself. The question should be rephrased neutrally, especially on direct.

OBJECTION - ASSUMES FACTS NOT IN EVIDENCE​

Your Honor,

In question 2, the Plaintiff asks the witness the question "How did you notify the plaintiff that he was banned from c108 and c995?".

Here, we are making an assumption - that no such notification was made. This needs to be established before such a question like this is made - we cannot assume the answer to the second question before it is answered.
Click to expand...
Re argumentative: There is no implication of a ‘failure of duty’, as the Defendant claims.

Re assumes facts not in evidence: The underlying fact presupposed by question 3 is established in the answer to question 2. It is further shown through the absence of any notice within exhibit P-111.

Question 4 (Defendant’s objection: privilege, relevance, leading)
Franciscus said:

Question 4. ("Have you ever been warned about toxic behaviour?")​

OBJECTION - PRIVILEGE​

Your Honor,

Under Server Rule 1, "Politicizing staff actions, for the sake of roleplay or otherwise, is strictly prohibited. There must be an undeniable separation between staffing and state and this is heavily policed." If a warning for toxicity were issued by staff, it cannot be used in the context of roleplay.

We therefore assert a staff rules privilege regarding this question, as it appears to directly ask about whether a staff punishment action occurred for use in roleplay purposes.

OBJECTION - RELEVANCE​

Your Honor,

Whether the witness has received a staff warning is not relevant to this case's substance.

OBJECTION - LEADING QUESTIONS​

Your Honor,

These questions include information that the examiner (plaintiff's counsel/plaintiff) seeks to confirm, regarding the existence or not of a staff warning for toxicity.
Click to expand...
This question relates to a line of inquiry that was eliminated, and its inclusion here appears to have been inadvertent. The Plaintiff apologises, and requests that Your Honour strike this question.

Question 5 (Defendant’s objection: ambiguous, calls for conclusion)
Franciscus said:

Question 5. ("In the books outside c108 and c995, what do they state is the specific conduct that people whose name appears on the ‘ban list’ are banned from doing?")​

OBJECTION – AMBIGUOUS / CALLS FOR A CONCLUSION​

Your Honor,

The question is unclear as to what “specific conduct” means and invites the witness to interpret or characterize the legal effect of the book, rather than simply state what the text says. Counsel should rephrase the question to ask the witness to identify or read the relevant wording.
Click to expand...
The question does not ask for commentary. It simply asks the witness to identify and read any section from the book which specifies what conduct is ‘banned’. This is a simple factual question.

Question 6 (Defendant’s objection: leading, assumes facts not in evidence)
Franciscus said:

Question 6. ("Where in these books does it state that the contents can be unilaterally updated and amended without notice?")​

OBJECTION - LEADING QUESTIONS and ASSUMES FACTS NOT IN EVIDENCE​

Your Honor,

The question a loaded proposition (“can be unilaterally updated and amended without notice”) and pushes the witness to agree there’s no such text – that's leading because it suggests the desired answer.

It also assumes that any authority to update must be written in the book itself; that hasn’t been established and is really a legal theory, not a fact already in evidence.
Click to expand...
Re leading: This is a hostile witness, and so leading questions are permitted (Please refer to the section at the beginning of this response entitled “Hostile witnesses: Vernicia, Goldendude15, and Roryyy_”).

Re assumes facts not in evidence: The question does not assume any fact. The Defendant admits in their objection that the ‘fact’ the objection relates to is a legal theory, not a fact.

Question 8 (Defendant’s objection: leading)
Franciscus said:

Question 8. ("Look at exhibit P-019, showing one of the entrances to c995. You have designated c995 as a ‘restricted area’, have you not?")​

OBJECTION - LEADING QUESTIONS​

Your Honor,

This is a classic leading question - the Plaintiff is including the information they seek to confirm, and then ask the witness "have you not?" in order to confirm it. This is among the most leading questions in the batch.
Click to expand...
This is a hostile witness, and so leading questions are permitted (Please refer to the section at the beginning of this response entitled “Hostile witnesses: Vernicia, Goldendude15, and Roryyy_”).

Question 9 (Defendant’s objection: calls for conclusion)
Franciscus said:

Question 9. ("Based on your answers to questions 7 and 8, is everyone banned from c995?")​

OBJECTION - CALLS FOR CONCLUSION​

Your Honor,

This question seeks to ask the witness to provide an opinion based upon prior (not yet given) answers regarding a legal conclusion (whether everyone is banned from c995).
Click to expand...
Your Honour, the Plaintiff does not oppose the objection, and humbly withdraws the question.

Questions 10 and 11 (Defendant’s objection: relevance)
Franciscus said:

Question 10. ("What does it mean ‘this plot is part of MZ’?")​

OBJECTION - RELEVANCE​

Your Honor,

The Defense does not see how this would plausibly be relevant to any claim for relief or factual allegation.

Question 11. ("Do you consider c108 and c995 to all be part of the same organisation?")​

OBJECTION - RELEVANCE​

Your Honor,

Again, the Defense does not see how this would plausibly be relevant to any claim for relief or factual allegation.
Click to expand...
The Plaintiff transited from c108 to c995 on the afternoon of 11 November 2025. The DHS treated this as two separate trespass charges. The Plaintiff seeks to challenge this, because if both plots are part of the same organisation, there ought to only be one charge of trespass.

Therefore, these questions are directly relevant to the Plaintiff’s claim.

Witness 3: Goldendude15​

Questions 2 and 3 (Defendant’s objection: leading)
Franciscus said:

Question 2. ("Did you verify that the Plaintiff had received any prior notice or ban instruction before issuing the trespass charge?")​

OBJECTION - LEADING QUESTIONS​

Your Honor,

These questions include information that the examiner (plaintiff's counsel/plaintiff) seeks to confirm, regarding whether or not the witness had "verif[ied] that the Plaintiff had received any prior notice or ban instruction before issuing the trespass charge". The Plaintiff should be directed to use open-ended questions.

Question 3. ("Did you confirm that the ‘ban list’ in the book was updated before the sales transactions that formed the basis for the trespass charges?")​

OBJECTION - LEADING QUESTIONS​

Your Honor,

These questions include information that the examiner (plaintiff's counsel/plaintiff) seeks to confirm, regarding whether or not the witness had confirmed "that the ‘ban list’ in the book was updated before the sales transactions that formed the basis for the trespass charges". The Plaintiff should be directed to use open-ended questions.
Click to expand...
This is a hostile witness, and so leading questions are permitted (Please refer to the section at the beginning of this response entitled “Hostile witnesses: Vernicia, Goldendude15, and Roryyy_”).

Question 4 (Defendant’s objection: compound and leading)
Franciscus said:

Question 4. ("Have you used the ‘ban-list’ book method before in other trespass cases? Did the same evidentiary standards apply?")​

OBJECTION - COMPOUND QUESTION​

Your Honor,

This is seeking to include multiple inquiries in one question. There are multiple sentences with multiple distinct questions here.

​

OBJECTION - LEADING QUESTIONS​

Your Honor,

These questions include information that the examiner (plaintiff's counsel/plaintiff) seeks to confirm. The Plaintiff should be directed to use open-ended questions.
Click to expand...
Re compound: The second question is a follow-up to the first.

Re leading: This is a hostile witness, and so leading questions are permitted (Please refer to the section at the beginning of this response entitled “Hostile witnesses: Vernicia, Goldendude15, and Roryyy_”).

Question 5 (Defendant’s objection: calls for conclusion)
Franciscus said:

Question 5. ("In your view, does a book placed outside a property entrance (without proof of service) meet the legal requirement of 'instruction' for trespass under the Criminal Code?")​

OBJECTION - CALLS FOR CONCLUSION​

Your Honor,

The question is asking the witness to give a legal opinion.
Click to expand...
Ordinarily, this objection would be valid. However, this witness was the police officer who processed the complaint, found the Plaintiff guilty, and fined him. As such, they had to have made a determination on this question of law as part of that process of finding the Plaintiff guilty. Part of the Plaintiff’s claim relates to the DHS’ error in respect of this specific legal question. Therefore, it is relevant and necessary to know the opinion of the DHS on this question of law.

Witness 4: Roryyy_​

Question 1 (Defendant’s objection: compound and leading)
Franciscus said:

Witness 4: Roryyy_​

Question 1 ("Is there an official or unofficial DHS policy that treats a property-owner’s ‘ban-list’ book placed outside a property entrance as a valid instruction of trespass ban?")​

OBJECTION - COMPOUND QUESTION​

Your Honor,

This is asking two separate cognizable queries:
  1. Whether an unofficial policy exists;
  2. Whether an ofificial policy exists.
These should be severed.

OBJECTION - LEADING QUESTIONS​

These questions include information that the examiner (plaintiff's counsel/plaintiff) seeks to confirm. The Plaintiff should be directed to use open-ended questions.
Click to expand...
Re compound: The question does not ask whether two policies exist. It asks whether a policy exists, irrespective of whether it is official or unofficial policy.

Re leading: This is a hostile witness, and so leading questions are permitted (Please refer to the section at the beginning of this response entitled “Hostile witnesses: Vernicia, Goldendude15, and Roryyy_”).

Question 3 (Defendant’s objection: ambiguous)
Franciscus said:

Question 3 ("Have there been prior cases where DHS convicted people based solely on this ‘ban-list’ book evidence?")​

OBJECTION - AMBIGUOUS​

Your Honor,

It is unclear what "this 'ban-list' book evidence" means or how it would apply to others. The ban-list book evidence in this case pertains to one individual.
Click to expand...
The Plaintiff submits that the meaning of ‘ban list book’ is evident from the context of the question.

Question 5 (Defendant’s objection: calls for conclusion)
Franciscus said:

Question 5 ("In your view, does a book placed outside a property entrance (without proof of service) meet the legal requirement of “instruction” for trespass under the Criminal Code?")​

OBJECTION - CALLS FOR CONCLUSION​

Your Honor,

This asks for a legal opinion.

[/Objection]
Click to expand...
Ordinarily, this objection would be valid. However, this witness is the Secretary of Homeland Security, and so the actions of the DHS are under his charge. Part of the Plaintiff’s claim relates to the DHS’ error in their answer to this specific legal question. Therefore, it is relevant and necessary to know the opinion of the DHS on this question of law.


Question amendments where Plaintiff does not oppose the Defendant’s Objections​

The Plaintiff does not oppose objections to the questions numbered below, and therefore requests leave to amend the questions as follows:

Witness 1 (jsrkiwi)
9a. How do you travel to plot c995?
9b. How do you travel to plot c108?
10a. When you were on plot c995, describe the areas you were in.
10b. When you were on plot c108, describe the areas you were in.
11a. When you were on plot c995, what activities were you engaged in?
11b. When you were on plot c108, what activities were you engaged in?
15. Withdrawn
18. Do you have any reason to believe that Vernicia has seen you enter c995?
19a. What communications, if any, did Vernicia have with you regarding access to c995?
19b. What communications, if any, did Vernicia have with you regarding access to c108?
20a. Did anyone else communicate to you any restrictions on your access to c995?
20b. Did anyone else communicate to you any restrictions on your access to c108?
31a. What was the outcome of the dispute or appeal?
31b. Did you receive any response from the department?
31c. If yes, what was it?
32. Besides the book outside c995, are you aware of any other evidence DHS presented to support their trespass claim?

Witness 2 (Vernicia)
4. Withdrawn
9. Withdrawn

Question amendments if the Court sustains an objection​

In the event of Your Honour sustaining objections in respect of questions numbered below, the Plaintiff requests leave to amend the questions as follows:

Witness 1 (jsrkiwi)
2. When you use the ‘vernicia’ warp, what do you see immediately around you?
3. Withdraw question
4. Prior to being charged by DHS, did you ever read the book by the entrance to plot c995?
6. When you use the ‘mzcd’ warp, what do you see immediately around you?
7. Withdraw question
8. Prior to being charged by DHS, did you ever read the book by the entrance to plot c108?
13. Do these logs show you accessing the book outside c995?
14. What, if anything, do the logs show in relation to your interaction with any books?
17. What is your usual practice regarding the creation of warps?
21a. On 11th November 2025, did you believe you were banned from c995?
21b. On 11th November 2025, did you believe you were banned from c108?
21c. On 12th November 2025, did you believe you were banned from c995?
21d. On 12th November 2025, did you believe you were banned from c108?
22a. Before you were charged with trespass, what, if anything, did you notice outside c995?
22b. Did you notice anything that might indicate restricted access?
22c. Were there any objects or postings outside the property?
22d. If yes, what did those objects or postings state?
23a. Before you were charged with trespass, what, if anything, did you notice outside c108?
23b. Did you notice anything that might indicate restricted access?
23c. Were there any objects or postings outside the property?
23d. If yes, what did those objects or postings state?

Witness 2 (Vernicia)
3. If you did not notify the Plaintiff, why did you choose not to notify him?
5. Please read from the ban-list book outside c995: what does the book say to be prohibited for persons whose names appear on the ban list?
6. Does the book state anywhere that the list may be changed or amended in future?

Witness 3 (Goldendude15)
2. Prior to issuing the trespass charge against the Plaintiff, what steps did you take to verify that he had received any prior notice or instruction banning him from the property?
3. What records did you check to verify the date on which the ban-list book was last updated relative to the sales transactions in question?
4a. Have you ever used a ban-list book as the basis for trespass charges in any other case?
4b. In those cases, how did you determine whether the ban-list constituted valid instruction?
5. In your view, what constitutes valid instruction under DHS policy when using a ban-list book?

Witness 4 (Roryyy_)
1a. Does DHS have any official policy regarding the use of ban-list books placed outside property entrances as notice for trespass?
1b. Is there any unofficial common practice regarding the use of ban-list books placed outside property entrances as notice for trespass?
3. Are you aware of any prior trespass convictions by DHS where the only evidence of notice or instruction was a ban-list book posted outside the entrance and no proof of service or other instruction to the defendant?
 
Your Honor,

The defense requests a sidebar so as to avoid clogging the thread with procedural questions.
 
You must log in or register to reply here.
Back
Top