Lawsuit: In Session Aladeen v. Redmont Bar Association [2024] FCR 46

Your Honor,

The Redmont Bar Association respectfully requests the dismissal of this case on the grounds of Rule 5.5 Lack of Claim, for the following reasons:

The Plaintiff stated “The RBA Chairperson, no matter who they are, holds the power to VETO any person from joining a committee, it is not in the RBA Charter nor is it in the SMLBA.” This statement by the Plaintiff says the Chairperson no matter who holds the power to VETO. If this was a mistake, we recommend the plaintiffs counsel actually review the complaint before submitting. If this was not a mistake, we are glad you agree. Either way it is essential to recognize the broader responsibilities bestowed upon the RBA Chair under the Super Modern Legal Board Act (SMLBA). As outlined in the SMLBA, the RBA Chair is tasked with overseeing all programs and committees within the association. In exercising this duty, the RBA chair acted within his jurisdiction by intervening to prevent a member from joining a committee for valid reasons. The RBA Charter also mandates that the RBA Chair oversees all programs and committees, thereby affirming the Chairs actions as in line with his prescribed responsibilities.

The Plaintiff alleges that the chair slandered them by disseminating false accusations regarding the circumstances of their departure from the committee. If the Plaintiff perceives themselves as slandered, the appropriate course of action would be to pursue legal recourse against the chair individually, rather than implicating the Redmont Bar Association as a whole. Slander is defined as a false statement that defames another individual. the chairs remarks were based on information conveyed to him by the Plaintiff during a Voice Chat session, and upon clarification from the Plaintiff, the chair promptly retracted his previous statement, negating any defamatory intent. As per the provisions outlined in the Defamation Act, it is incumbent upon the Plaintiff to not only demonstrate harm but also furnish evidence indicating an intent to tarnish reputation. The prompt retraction made by the chair upon being corrected serves as clear indication that there was no deliberate intent to harm the plaintiff.

The Plaintiff asserts that the chair reinforced the veto decision while retracting the initial reasoning, further damaging their reputation. Upon being informed by the Plaintiff that the initial reason was inaccurate, the chair clarified the situation by stating that the Plaintiff's departure was due to other obligations. This clarification does not constitute slander but rather a factual update, ensuring transparency within the committee.

The Plaintiff claims that their reputation within the legal community has been tarnished by the Chairman's actions. The alleged "announcement" was made in a privileged channel accessible only to the RBA council and committee members, thus limiting its exposure. As such, it cannot be deemed damaging to the Plaintiff's reputation beyond this private forum. Again, to mention that if the statement was damaging, they should seek legal damages from the chair themselves, not the RBA.

The Plaintiff's case fails to establish a valid claim actionable in this court. Pursuing this matter further would only serve to expend valuable resources and time without just cause. We ask that you dismiss this case with prejudice.

Your Honor, irrespective of the outcome of this motion, we respectfully request a subpoena for the plaintiff, mandating disclosure of the individual who breached confidentiality by sharing private committee messages to them.

Your Honor, I motion to strike the plaintiffs' purported evidence from the record. Such information is privileged, having been disseminated within a confidential RBA ethics committee channel.

Your Honor,

We request time to respond to this Motion to Dismiss

You have 72 hours to respond to the Motion to Dismiss.

RESPONSE TO THE MOTION TO DISMISS

The motion to dismiss from the Redmont Bar Association doesn’t hold up under scrutiny and is an attempt to hide the clear wrongdoing by the RBA Chair.

First of all, saying the Chair can veto anyone without good reason goes against the rules laid out
in the RBA Charter and SMLBA. The Chair’s power is not unlimited and must follow the rules.
Vetoing a nomination without a good reason is an abuse of power that damages the integrity of the ethics committee.

Secondly, trying to minimize the damaging comments made by the Chairman does not make sense. Spreading false stories about why my client left the committee is defamation, plain and simple. Even if the Chair took it back later, the damage was done. Such unproved claims can destroy my clients professional career and his credibility within the legal community, which leads to the potential harm to his career as an attorney.

Also, saying that clarifying why my client left the committee was just giving the facts is misleading. By sticking to the veto and changing the story, the Chair kept making people doubt my clients honesty and suitability for the Ethics Committee, which hurts his reputation even more. This shift of explanations not only proves the lack of accountability on part of the Chair but also creates confusion and mistrust among the members of the ethics committee.

Lastly, saying the damage to my clients reputation was only in private chats within the RBA isn’t true. As a member of the legal community, my clients reputation matters outside of just the RBA. What the Chair did affected how people see me in the whole legal community, as the members of the channel who read the veto can have a poor image of him. The actions of the Chair extends much further from the private communications, potentially impacting my clients professional opportunities and relationships within the legal community.

In conclusion, the motion to dismiss does not deal with the real issues of this case and tries to avoid responsibility for what the Chair did. We ask that the court to rejects the motion and lets this case go to trial, where the evidence will show what really happened.

Apart from this , we disagree with the subpoena request to find out who leaked private information, as it’s not relevant here. And we object to striking the evidence from the record, as it’s of extreme importance to completely understand the context and implications of the Chairs actions.

The Motion to Dismiss is hereby denied. There is clearly a case that has yet to go through the proper arguments, and the claim against the Defendant is valid. Additionally, the request to subpoena is denied, as who leaked the images from a confidential channel is irrelevant to the case. The Motion to Strike is also denied.

We will now move onto Discovery. Please submit any evidence and any witnesses you have within 7 days.

Due to Justice Neemfy's resignation I will be taking over this case.

Given Discovery is now over, we will be moving onto Opening Statements.
The Plaintiff has 72 hours to provide their Opening Statement.

Your Honor, The plaintiff has failed to submit their opening statement within the 72-hour timeframe allotted to them. We respectfully request that you hold them in contempt and allow us to move on with this case.

Thank You.

Due to the Plaintiff missing their Opening Statement I will be holding them in Contempt. Simply put this is the case that they started and thus should be in attendance throughout this case.

The Defense has 72 hours to file their Opening Statement.

RelaxedGV said:

Due to the Plaintiff missing their Opening Statement I will be holding them in Contempt. Simply put this is the case that they started and thus should be in attendance throughout this case.

The Defense has 72 hours to file their Opening Statement.

Click to expand...

Your honor, I was just hired by the plaintiff. Seems there was some difficulty with Sumo being raised to the bench so he had to seek new counsel. I ask the court be reasonable. I request a 24 hour extension so that we may have a fair trial.

Alexander P. Love said:

Your honor, I was just hired by the plaintiff. Seems there was some difficulty with Sumo being raised to the bench so he had to seek new counsel. I ask the court be reasonable. I request a 24 hour extension so that we may have a fair trial.

Click to expand...

Your Honor. Mr. Love is speaking out of turn. The RBA is in the process of preparing our opening statements. As you mentioned earlier, the plaintiff should have been present throughout this trial. The plaintiff themselves are a licensed attorney and should have requested an extension sooner.

Your Honor, we also request that you disallow Mr. Love from representing this client. Mr. Love was a member of the RBA council during the filing of this case and had access to privileged channels where the council discussed strategy. This presents a clear conflict of interest under the Futurist Legal Framework Bill, which defines a conflict of interest in the legal context as the situation where the same legal counsel represents both the defense and the plaintiff simultaneously in the same case. Mr. Love was part of the council when this case was filed, making him part of the legal team representing the RBA.

Redmont Bar Association said:

OBJECTION
Breach of Procedure
​

Your Honor. Mr. Love is speaking out of turn. The RBA is in the process of preparing our opening statements. As you mentioned earlier, the plaintiff should have been present throughout this trial. The plaintiff themselves are a licensed attorney and should have requested an extension sooner.

Your Honor, we also request that you disallow Mr. Love from representing this client. Mr. Love was a member of the RBA council during the filing of this case and had access to privileged channels where the council discussed strategy. This presents a clear conflict of interest under the Futurist Legal Framework Bill, which defines a conflict of interest in the legal context as the situation where the same legal counsel represents both the defense and the plaintiff simultaneously in the same case. Mr. Love was part of the council when this case was filed, making him part of the legal team representing the RBA.

Click to expand...

That bill was literally just signed. Ex post facto

Alexander P. Love said:

Your honor, I was just hired by the plaintiff. Seems there was some difficulty with Sumo being raised to the bench so he had to seek new counsel. I ask the court be reasonable. I request a 24 hour extension so that we may have a fair trial.

Click to expand...

Apologies for not getting to this sooner, you of course have an additional 24 hours.

Redmont Bar Association said:

OBJECTION
Breach of Procedure
​

Your Honor. Mr. Love is speaking out of turn. The RBA is in the process of preparing our opening statements. As you mentioned earlier, the plaintiff should have been present throughout this trial. The plaintiff themselves are a licensed attorney and should have requested an extension sooner.

Your Honor, we also request that you disallow Mr. Love from representing this client. Mr. Love was a member of the RBA council during the filing of this case and had access to privileged channels where the council discussed strategy. This presents a clear conflict of interest under the Futurist Legal Framework Bill, which defines a conflict of interest in the legal context as the situation where the same legal counsel represents both the defense and the plaintiff simultaneously in the same case. Mr. Love was part of the council when this case was filed, making him part of the legal team representing the RBA.

Click to expand...

This Objection is rejected as given the bill was signed not long before AlexanderLove's statement to the Court it can be deduced using common sense that AlexanderLove was working on this case before showing in the Court Room itself. Yes the bill did state immediate action upon passage however ex post facto overrides this in a situation like this. Both sides are equal under the law and given the very Chair that wrote the bill is also the head of the RBA, I will be allowing AlexanderLove to remain on this case.

Your Honor, although the law in question was enacted after the initiation of this case, it should not be the sole factor considered in determining Mr. Love's eligibility to serve as legal counsel for the plaintiff. Attached are comments made by Mr. Love in the channel utilized by the RBA to deliberate on this case, providing additional context for your consideration.

Your Honor, should you require further evidence regarding the conversations within this chat, we are fully prepared to present Mr. Love's contributions to this case, which include assisting in the review of the Motion to Dismiss and engaging in discussions concerning its details. Allowing him to persist in representing the plaintiff is akin to a scenario where an individual from the DLA prosecutes a case and then abruptly resigns from the DLA to represent the opposing side midway through proceedings. Such a situation would undoubtedly raise concerns about impartiality and conflicts of interest.

Given this affects the Plaintiff, they shall have 24 hours to respond to the Motion to Reconsider.

Redmont Bar Association said:

MOTION TO RECONSIDER
​

Your Honor, although the law in question was enacted after the initiation of this case, it should not be the sole factor considered in determining Mr. Love's eligibility to serve as legal counsel for the plaintiff. Attached are comments made by Mr. Love in the channel utilized by the RBA to deliberate on this case, providing additional context for your consideration.

Spoiler: Exhibit A

View attachment 43065

Spoiler: Exhibit B

View attachment 43066

Your Honor, should you require further evidence regarding the conversations within this chat, we are fully prepared to present Mr. Love's contributions to this case, which include assisting in the review of the Motion to Dismiss and engaging in discussions concerning its details. Allowing him to persist in representing the plaintiff is akin to a scenario where an individual from the DLA prosecutes a case and then abruptly resigns from the DLA to represent the opposing side midway through proceedings. Such a situation would undoubtedly raise concerns about impartiality and conflicts of interest.

Click to expand...

Objection your honor, both pieces of evidence are hearsay and it is after discovery, where evidence may not be filed.

I will post an argumentative response today.

Redmont Bar Association said:

MOTION TO RECONSIDER
​

Your Honor, although the law in question was enacted after the initiation of this case, it should not be the sole factor considered in determining Mr. Love's eligibility to serve as legal counsel for the plaintiff. Attached are comments made by Mr. Love in the channel utilized by the RBA to deliberate on this case, providing additional context for your consideration.

Spoiler: Exhibit A

View attachment 43065

Spoiler: Exhibit B

View attachment 43066

Your Honor, should you require further evidence regarding the conversations within this chat, we are fully prepared to present Mr. Love's contributions to this case, which include assisting in the review of the Motion to Dismiss and engaging in discussions concerning its details. Allowing him to persist in representing the plaintiff is akin to a scenario where an individual from the DLA prosecutes a case and then abruptly resigns from the DLA to represent the opposing side midway through proceedings. Such a situation would undoubtedly raise concerns about impartiality and conflicts of interest.

Click to expand...

Actually this is easy. Lawyers do not have the duty to be impartial! In fact we are very partial. There is no conflict of interest because my only interest is representing my client. It is not the duty of the defendant to look out for the plaintiff’s representation. If the plaintiff was weary of my involvement with the RBA, he wouldn’t have hired me yet he chose to on his own accord.

Redmont Bar Association said:

MOTION TO RECONSIDER
​

Your Honor, although the law in question was enacted after the initiation of this case, it should not be the sole factor considered in determining Mr. Love's eligibility to serve as legal counsel for the plaintiff. Attached are comments made by Mr. Love in the channel utilized by the RBA to deliberate on this case, providing additional context for your consideration.

Spoiler: Exhibit A

View attachment 43065

Spoiler: Exhibit B

View attachment 43066

Your Honor, should you require further evidence regarding the conversations within this chat, we are fully prepared to present Mr. Love's contributions to this case, which include assisting in the review of the Motion to Dismiss and engaging in discussions concerning its details. Allowing him to persist in representing the plaintiff is akin to a scenario where an individual from the DLA prosecutes a case and then abruptly resigns from the DLA to represent the opposing side midway through proceedings. Such a situation would undoubtedly raise concerns about impartiality and conflicts of interest.

Click to expand...

This Motion to Reconsider is rejected and I will provide more clarity:

The bill that was linked states that the RBA may investigate and should they wish prosecute for Conflict of Interest for a fine and, or, jail time. Nowhere in that section does it state that the Presiding Officer has the ability to remove someone's council nor should one have it.

- Act of Congress - Super Modern Legal Board Act
Section 11

The idea of Conflict of Interest surrounds on the fact that there needs to be proof that such is occurring, that is achieved however the hard part of this is, as with the point above, lack of power to remove someone from their position of representing someone. If you wish to remove one's ability to represent other's that power is already awarded to the RBA to vote on disbarring the individual and then the Courts granting or rejecting the charge.

When it comes to the knowing strategy and writing the Motion to Dismiss, if those are arguments one is making to remove someone from the Plaintiff then that shows how little the Defense believed in the arguments presented by the Defense.

The very bill that was also linked by the Defense also is regarding the RBA itself thus while I applaud that the RBA understands it's own charter, these are not actual Court Procedure and are simply remedies, procedures, and daily actions that the RBA can utilize day to day.

Tl;dr, the Motion to Reconsider is Rejected due to the bill that was linked is the RBA Charter.

May it please the Court,

Your honor, the law is simple. The Super Modern Legal Board Act (governing law of these facts) explicitly states who hires who. The ethics chairman hires committee members, and the RBA Chairman has zero say in this. The RBA chairman claimed a power to veto which he did not possess. Even though the Chairman has assumed de facto control of the organization, the legal board is a democracy and there is due process to follow. Where the law enumerates something, the law must be followed to the letter. It is clear by the language of the law that the author intended for the committee chairmen to independently administer their own committees, especially ethics which, for practical reasons, needs to be distanced from the Council anyways to do its job with fairness and impartiality. In the RBA Charter Article 3 Section 3 it states “The Ethics Committee shall be composed of... members appointed by the Ethics Chairperson.” Remember this, and note that it does NOT say the RBA Chairperson.

In this process, the Chairman made false and defamatory remarks, making my client out to be petty and vindictive, that caused the plaintiff to no longer hold any influence in the RBA or in the legal field. His lack of clients is a good economic indicator of the damage caused to his reputation as a result of these remarks. The remarks and gross breach of due process constitutes an outrageous action subject to the punitive damages requested. I ask that all prayers for relief are granted. Thank you.

RelaxedGV said:

Due to the Plaintiff missing their Opening Statement I will be holding them in Contempt. Simply put this is the case that they started and thus should be in attendance throughout this case.

The Defense has 72 hours to file their Opening Statement.

Click to expand...

The Defense is going to also have an additional 24 hours given how this case has already been running.
The 24 hours shall start from this message.

OPENING STATEMENT


Your Honor, Members of the Court,

The defendant has contended that the RBA Chair lacks the authority to "veto" or obstruct the Ethics Chair's appointment of committee members. Allow me to direct your attention to the Super Modern Legal Board Act, which meticulously delineates the responsibilities of the RBA Chairperson. According to this act, the Chairperson is tasked with overseeing all programs and committees within the RBA. While the term "veto" was utilized during the announcement to the committee, it was merely an exercise of the Chair's oversight authority, as mandated by the SMLBA. Nowhere within the Super Modern Legal Board Act is the authority to appoint committee members granted to the Ethics Chair. Let me be unequivocal: the SMLBA does not confer upon the Ethics Chair the power to appoint committee members. The RBA charter also gives the RBA Chair the authority to oversee all programs and committees within the RBA, including the power to appoint RBA Officers and Committee Chairpersons who supervise RBA programs. In this context, the Chair assumed the responsibility of overseeing the Ethics Committee and exercised their authority to "appoint" officers, thereby preventing the defendant from joining the Ethics Committee. It is crucial to recognize that the Chair's actions were undertaken in the best interests of the committee, as mandated by their role as overseer of all programs.

Regarding the defamatory remarks alleged by the plaintiff, it is imperative to consult the Defamation Act, which stipulates that in cases of suing for defamation, the plaintiff must demonstrate both harm and intent to harm reputation. There was no intent to harm the plaintiff's reputation; indeed, when the Chair was promptly corrected upon making the statement, they immediately rectified their error. I submit that the actions of the RBA Chair were conducted within the bounds of their authority and in accordance with the mandates of the SMLBA and the RBA charter. There was no malicious intent behind the alleged defamatory remarks, as evidenced by the Chair's swift correction of their statement.

Thank you.

Thank you, given neither side provided witnesses during Discovery, we will be moving straight into Closing Statements.

The Plaintiff has 72 hours to post their Closing Statement.