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IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
SUBMISSION OF FOLLOW-UPS REGARDING QUESTION SHEET HANDWRITTEN ANSWERS
IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
CLOSING STATEMENT
Your Honor:
This case is one in which the Commonwealth illegally evicted the Plaintiff, omitted key information from the Plaintiff when the Plaintiff sought to contest his evictions, and then began to auction off his plots (and successfully auctioned one off). An Inspection Manager who had a conflict-of-interest corruptly sought to acquire plots which he illegally evicted. The “Department of Construction and Transportation did not do their due diligence in regards to the matter at hand,” nor “inform[] the plaintiff that [the DCT’s agents] had made a mistake before putting the plot to auction” (see: BananaNova v. Commonwealth of Redmont [2024] FCR 44), causing concrete damages to my client.
This case has been long, full of discovery submissions, and substantial witness questioning. This closing statement will discuss the issues raised and rules as the facts apply to them, and demonstrate that on balance of probabilities we have proven every claim and are entitled to relief in full.
In our complaint, we laid out eight claims for relief. Let us re-examine the key issues posed by each of them, what the law says about these issues, and how the facts apply.
The Plaintiff seeks a declaration from this court that the DCT’s eviction of the Plaintiff’s plots was unlawful, unconstitutional, and void ab initio. The Plaintiff asks this Court to explicitly rule that the eviction executed on July 30, 2025 violated the Evictions Policy and the Plaintiff’s rights, and therefore had no legal effect. Such a declaratory judgment will clarify the parties’ rights and ensure the record reflects that the Government’s actions were illegal.
The Plaintiff asks this Court to issue an order requiring the Commonwealth to return ownership of all wrongly-evicted plots to the Plaintiff immediately. Because the eviction was wrongful, the appropriate remedy is to restore the status quo ante by reinstating the Plaintiff as the rightful owner of each plot. The Plaintiff seeks a permanent injunction compelling the Defendant to reverse any transfer of ownership or auction process initiated for his properties. This Court’s equitable powers permit it to undo the effects of the illegal eviction – just as wrongfully dispossessed tenants or owners are entitled to recover possession of their property.
In this case, we have proven that the Commonwealth unlawfully seized plot r054 and sold it. Compensatory damages are sought equal to the fair market value of this plot; as P-011 establishes, this is at least $27,500.The Plaintiff asks for an award of compensatory damages in an amount to fully compensate the Plaintiff for all quantifiable losses suffered as a direct and proximate result of the Defendant’s actions. This includes the value of any property or items lost due to the eviction, any lost profits or income from the plots during the period of wrongful possession, and any other monetary losses the Plaintiff can prove.
The Plaintiff seeks consequential damages in full, supported by the voluminous evidence in case, and our analysis in our conclusion.The Plaintiff asks for an award of consequential damages for the non-economic injuries inflicted, specifically including Loss of Enjoyment and Humiliation suffered by the Plaintiff. As detailed in Claims for Relief 4 and 5, the Plaintiff endured a diminished ability to enjoy the Redmont community and personal mortification as a result of the Defendant’s conduct. The Legal Damages Act expressly recognizes these intangible harms as compensable. These damages, while not easily reduced to a number, are capped by law except in cases when punitive damages are sought (c.f. Legal Damages Act §7(2)(b)). As the Plaintiff seeks punitive damages in this case, and consequential damages are therefore not capped, the Plaintiff asks that the Court award $150,000 in humiliation damages and $150,000 in loss of enjoyment damages.
The Plaintiff believes that we have demonstrated each and every claim for relief on balance of probabilities. The outrageous nature of this case is evident from the analysis-in-case. It exacerbated by the Commonwealth's actions at trial, where the DCT Secretary-turned-special counsel (Docket Filing No. 9) engaged in repeated antics in Court that resulted in this Court summarily charging perjury (Docket Filing No. 138) and Contempt of Court (Docket Filing No. 185).The Defendant’s actions were not mere negligence but willful and egregious violations of law – evincing reckless disregard for the Plaintiff’s rights and for the rule of law. Punitive damages are warranted, per Legal Damages Act §5(1)(a), “to punish [a defendant] for their outrageous conduct and to deter them and others like them from similar conduct in the future.”
The Commonwealth’s conduct in this case has been egregious and outrageous. Here, the Commonwealth (acting through DCT officials) engaged in a gross abuse of power by illegally evicting plots, then persisted in dishonesty to cover it up even when contested, and showed deep contempt for the Plaintiff throughout the whole process. This kind of conduct strikes at the heart of public trust in government and must be strongly dissuaded.
How should the Commonwealth be dissuaded? Treble damages serve as a strong deterrent to future wrongful conduct and are called for in these heinous and outrageous actions by the Defendants; this Court has granted them in the past, such as in lucaaasserole v Naezaratheus et al. [2025] FCR 50. But, for some violations (such as abstract violations of rights), treble damages may be difficult to calculate, and further specification for a calculation of punitive damages is necessary. And, for damages that occurred as the result of criminal activities, the Federal Court has found it permissible for Plaintiffs to seek punitive damages equal to the amount of fines that would be collected in a criminal proceding (c.f. MegaMinerM v. Blazora Corporation [2025] FCR 27, Section III(2)(E), par. 6).
As such, the Plaintiff prays for Punitive Damages as follows:
- $280,000 in punitive damages for unreasonable seizure, in direct violation of the Plaintiff’s express constitutional rights against the same, equivalent to $35,000 for each of the 8 Plots unlawfully seized;
- $280,000 in punitive damages for violations of Constitutional Duty of Care, as laid out in the second Claim for Relief, equivalent to $35,000 for each of the 8 Plots unlawfully seized;
- $280,000 in punitive damages for violations of Statutory Duty of Care, as laid out in the third Claim for Relief, equivalent to $35,000 for each of the 8 Plots unlawfully seized;
- $300,000 in punitive damages for loss of enjoyment: treble damages resulting from the Commonwealth’s actions described in this Complaint and in this Case,;
- $300,000 in punitive damages for humiliation: treble damages resulting from the Commonwealth’s actions described in this Complaint and in this Case;
- $200,000 in punitive damages for Corruption, equivalent to the maximum monetary penalty for eight charges of Corruption (one for each plot illegally seized) as laid out under the Criminal Code Act;
- $80,000 in punitive damages for Fraud, equivalent to the maximum monetary penalty for eight charges of Fraud (one for each plot illegally seized) as laid out under the Criminal Code Act.
The Plaintiff prays for an award of legal fees equal to 30% of the total monetary relief obtained (or sought, if the Defendant prevails on some claims) in accordance with this provision.Given the complexity of this case and the egregious nature of the Defendant’s conduct, the Plaintiff’s counsel has and will have expended significant time and resources to vindicate the Plaintiff’s rights. Thirty percent of the recovery is a fair and statutorily-supported measure of legal fees, and should be ordered against the Defendant if it is found liable. This not only compensates the Plaintiff’s costs but also encourages capable advocacy in cases where citizens challenge governmental abuse.