Lawsuit: Pending Brick and Browse Inc. v. MasterCaelen, Third-Party Defendant Pepecuu [2026] FCR 18

[ToadKing]

Case Filing

IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
CIVIL ACTION

Brick and Browse Inc.
Plaintiff

v.

MasterCaelen
Defendant

COMPLAINT
The Plaintiff complains against the Defendants as follows:

MasterCaelen obtained and continues to retain $1,700,000 transferred from Pepecuu following a monetary judgment against her in [2026] FCR 8, without legal justification, causing direct harm to the Plaintiff by rendering the monetary judgment unsatisfiable. The Plaintiff further contends this transfer constituted a fraudulent conveyance under common law principles.

I. PARTIES​

1. Brick and Browse Inc.
2. ToadKing (Chairman of the Board)
3. MasterCaelen

​

II. FACTS​

1. On 3 March 2026 at 04:14 UTC, the Federal Court rendered its verdict in Brick and Browse Inc. v. Pepecuu [2026] FCR 8, awarding a monetary judgment of $460,000 against Pepecuu. (P-001)
2. At 11:15 UTC on 3 March 2026, Pepecuu's in-game balance was $1,741,943.75, more than sufficient to satisfy the judgment in full. (P-002)
3. At 11:06 UTC on 3 March 2026, an appeal of [2026] FCR 8 was filed in the Supreme Court as In re [2026] FCR 8 | [2026] SCR 8, while the monetary judgment remained unsatisfied. (P-003)
4. At 11:22 UTC on 3 March 2026 - merely 16 minutes after the appeal was filed - Pepecuu transferred $1,700,000 to MasterCaelen, reducing her balance to approximately $41,943.75. (P-004)
5. On or around 4 March 2026, the DHS subsequently created a Debt Recovery Ticket to facilitate the collection of the $460,000 monetary judgment. (P-005)
6. Within that ticket, Pepecuu stated: "Based on my current balance, I do not have $460,000." This statement was made after she had transferred $1,700,000 to MasterCaelen. (P-005)
7. MasterCaelen has retained the $1,700,000, or a portion thereof, without legal justification.

​

III. CLAIMS FOR RELIEF​

1. Unjust Enrichment​

The Redmont Civil Code Act (RCCA) codifies Unjust Enrichment as a civil violation under Part X:

1. Unjust Enrichment
Violation Type: Strict Liability
Remedy: Restitution
A person commits a violation if the person:
(a) obtains and retains a benefit at another’s expense; and
(b) there is no legal justification for retaining the benefit
Relevant Law:

This is a Strict Liability violation. Under RCCA Part II, Section 7(4) and Section 9(4):

7. Civil Law Definitions
(4) Strict Liability Violation means a violation where the violator is held liable regardless of intent or negligence, because the prohibited act occurred and caused harm.

9. Violation Types
(4) Strict Liability Violations require the plaintiff to prove only that the prohibited act occurred and caused harm; the defendant’s intent or negligence is not relevant to establishing liability.

The Plaintiff is therefore not required to prove MasterCaelen's intent or knowledge. The Plaintiff need only establish that the prohibited act occurred and caused harm.

There are two straightforward elements to Unjust Enrichment:

Element (a) MasterCaelen obtained and retained a benefit at the Plaintiff's expense.​

MasterCaelen received $1,700,000 directly from Pepecuu. (P-002) This transfer reduced Pepecuu's balance from $1,741,943.75 to approximately $41,943.75 - below the $460,000 owed to the Plaintiff. The benefit obtained by MasterCaelen came directly at the Plaintiff's expense, as it was those funds - and only those funds - that stood between the Plaintiff receiving their judgment and being left uncompensated.

Element (b) There is no legal justification for retaining the benefit.​

No contract, court order, statutory entitlement, or other legal basis has been established for MasterCaelen's receipt of $1,700,000 from Pepecuu. The transfer had no legitimate commercial purpose apparent on its face. It occurred 16 minutes after a Supreme Court appeal was filed seeking to increase the damages owed. There is no legal justification for MasterCaelen to retain funds that directly caused the Plaintiff's judgment to become unsatisfiable.

The harm is direct and admitted. Pepecuu herself stated in the DHS Ticket that she did not have $460,000 to satisfy the judgment. (P-005) That admission was made only because of the transfer to MasterCaelen. The Plaintiff's $460,000 monetary judgment is presently unsatisfied as a direct result of MasterCaelen retaining this benefit.

2. Fraudulent Conveyance​

In the alternative, and in addition to the Unjust Enrichment claim, the Plaintiff relies on the principle of fraudulent conveyance.

RCCA Part II, Section 3(1)(a) provides:

3. Codification of Civil Law
(1) This Code constitutes a non-exhaustive listing of civil violations within the jurisdiction of Redmont.
(a) Nothing in this Code prevents a plaintiff from seeking remedy for harm not explicitly codified, where common law principles or judicial precedent support such a claim.

RCCA Part II, Section 1(1) further provides:

1. Common Law Principles
(1) This Code shall be interpreted in a manner consistent with the principles of natural justice and common law unless expressly excluded. Judicial reasoning and precedent may inform interpretation and application of this Code where the law is silent or ambiguous.

Fraudulent conveyance is a foundational principle of common law equity: a transfer of assets made with intent to defeat a creditor's ability to collect a judgment is voidable, and a court may rescind such a transfer to restore the assets for enforcement purposes.
The facts establish this plainly:

• A valid unsatisfied judgment of $460,000 existed at the time of transfer. (Fact 1)
• Pepecuu held sufficient funds to satisfy it in full. (Fact 2)
• 16 minutes after filing an appeal, Pepecuu transferred $1,700,000 - nearly her entire balance - to MasterCaelen. (Facts 3, 4)
• Pepecuu then admitted she could not pay the judgment. (Fact 6)
• The sequence of events - judgment, appeal, immediate mass transfer, admitted inability to pay - admits no innocent explanation.

The Plaintiff recognises that fraudulent conveyance has not been previously litigated in Redmont. However, the RCCA expressly invites the Court to look to common law principles where the law is silent, and this principle is considerably foundational to the fair administration of justice that declining to recognise it would produce the absurd result - expressly prohibited by RCCA Part II, Section 2(1) - that a judgment debtor may freely dissipate assets the moment a verdict is rendered, with no legal consequence whatsoever.

Throughout [2026] FCR 8, Pepecuu demonstrated a documented, repeated, and judicially confirmed pattern of precisely this conduct. The Federal Court granted an Emergency Injunction freezing all of Pepecuu's assets on the express basis that "there exists a substantial risk that Defendant will transfer, hide, or dissipate these assets to render herself judgment-proof." Pepecuu then violated that injunction by relocating funds, for which the Federal Court held her in contempt, fined her, and ordered the DHS to seize her assets.

The Court noted pointedly: "there has been nothing from the DHS or the defendant's legal counsel showing any effort by the defendant to retrieve such funds as this court has ordered." Pepecuu ultimately accumulated 53 contempt charges totalling $265,000 in fines before the relocated funds were recovered.

The transfer of $1,700,000 to MasterCaelen is not an isolated act of poor judgment - it is the continuation of a deliberate, proven strategy to place assets beyond the reach of the Court and the Plaintiff. The recognition of fraudulent conveyance as an actionable claim in these proceedings is not the Court venturing into uncharted territory; it is the Court responding to a defendant who has already demonstrated that no lesser remedy will suffice.

​

IV. PRAYER FOR RELIEF​

The Plaintiff respectfully requests that this Court grant the following relief:

1. Restitution of $460,000 from MasterCaelen to Plaintiff under the Unjust Enrichment provision of the RCCA, representing the amount of the unsatisfied monetary judgment in [2026] FCR 8.

2. In the alternative, Rescission of the transfer of $1,700,000 from Pepecuu to MasterCaelen, restoring those funds to Pepecuu's balance to the extent necessary to satisfy the monetary judgment of $460,000.

3. Legal fees as provided under Part III, Section 7 of the RCCA.

4. Such other and further relief as this Court deems just and proper.

EVIDENCE​

Spoiler: P-001

Lawsuit: Adjourned Post in thread 'Brick and Browse Inc. v. Pepecuu [2026] FCR 8'

Mar 2, 2026

Verdict

IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
VERDICT
Brick and Browse Inc. v. Pepecuu [2026] FCR 8

I. PLAINTIFF'S POSITION
The defendant during their time as CEO of Brick and Browse violated both fiduciary and loyalty duties by participating in unauthorized self-dealing stock buybacks all in violation of the company bylaws.

II. DEFENDANT'S POSITION
The defendant cannot be held liable for such breaches in company bylaws as they were never trained in the process of handling information or assets. Brick and Browse also had a duty to mitigate by not allowing such...

• ko531

• 

Spoiler: P-002

Spoiler: P-003

Appeal: Pending Thread 'In re [2026] FCR 8 | [2026] SCR 8'

Mar 3, 2026

Username: ToadKing__

I am representing a client

Who is your Client?: Brick and Browse Inc.

What Case are you Appealing?: [2026] FCR 8

Link to the Original Case: Lawsuit: Adjourned - Brick and Browse Inc. v. Pepecuu [2026] FCR 8

Basis for Appeal: See Below

Supporting Evidence:

• ToadKing
• Replies: 3
• Forum: Appeals

Spoiler: P-004

Spoiler: P-005

WITNESSES​

1. MasterCaelen
2. Pepecuu

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 7th day of March 2026

 

[ToadKing]

Motion

IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
MOTION FOR EMERGENCY INJUNCTION

Your Honour,

The Plaintiff respectfully requests that this Court issue an emergency injunction freezing $460,000 of MasterCaelen's assets pending resolution of this matter. MasterCaelen received $1,700,000 from Pepecuu in circumstances forming the basis of this action. Without a freeze, there is a substantial and demonstrated risk that these funds will be further dissipated before judgment, rendering this case moot before it begins.

The Plaintiff notes that the judgment debtor, Pepecuu, has a confirmed pattern of asset dissipation during proceedings, and the Plaintiff believes this pattern may extend to the assets now held by MasterCaelen.

 

[Muggy21]

Motion

IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
MOTION FOR EMERGENCY INJUNCTION

Your Honour,

The Plaintiff respectfully requests that this Court issue an emergency injunction freezing $460,000 of MasterCaelen's assets pending resolution of this matter. MasterCaelen received $1,700,000 from Pepecuu in circumstances forming the basis of this action. Without a freeze, there is a substantial and demonstrated risk that these funds will be further dissipated before judgment, rendering this case moot before it begins.

The Plaintiff notes that the judgment debtor, Pepecuu, has a confirmed pattern of asset dissipation during proceedings, and the Plaintiff believes this pattern may extend to the assets now held by MasterCaelen.

Granted.

DHS is ordered to seize and safeguard $460,000 from MasterCaelen. These funds shall be held in bond pending adjudication of this proceeding. DHS is ordered to take all necessary actions as permitted under law to effectuate this order.

 

[Muggy21]

Writ of Summons

@Caelen is required to appear before the Federal Court in the case of Brick and Browse Inc. v. MasterCaelen [2026] FCR 18

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.

 

[ToadKing]

Same shit, different day...

Your Honour, @Muggy21

The Plaintiff urgently brings to the Court's attention evidence that MasterCaelen has violated the Emergency Injunction granted in these proceedings by dissipating assets held in their sole proprietorship, RKB, in an apparent attempt to render themselves judgment-proof in direct contravention of this Court's order.

On 7 March 2026, at 16:12 UTC, Plaintiff ran /db info RKB and recorded a balance of $1,685,954 - a sum consistent with the $1,700,000 received from Pepecuu.

On 8 March 2026 at 05:30 UTC, Plaintiff ran the same command and recorded a balance of $85,954 - a reduction of $1,600,000 in under 14 hours.

RKB is not a registered company with the DOC and maintains no active company docket. It is therefore a sole proprietorship under Part VI, Section 1 of the Legal Entity Act:

Part VI, Section 1(3) provides:

(3) All assets and liabilities of the sole proprietorship shall be regarded as assets and liabilities of the owner of the sole proprietorship.

Meaning RKB's balance constitutes MasterCaelen's personal assets, and the withdrawal of $1,600,000 from RKB is a withdrawal of MasterCaelen's personal assets subject to this Court's Emergency Injunction.

The Emergency Injunction was filed and served as part of this action. Within hours, $1,600,000 disappeared from the sole proprietorship into which the $1,700,000 from Pepecuu had been deposited. MasterCaelen has followed precisely the playbook of their counterpart - the Plaintiff warned this Court in the Emergency Injunction motion that "the Plaintiff believes this pattern may extend to the assets now held by MasterCaelen." The Plaintiff respectfully submits, based on this clear evidence, that MasterCaelen is now engaged in identical behaviour.

The Plaintiff, therefore, requests that this Court:

1. Find MasterCaelen in contempt of court for violating the Emergency Injunction by withdrawing $1,600,000 from RKB following the granting of the injunction;
2. Order MasterCaelen to immediately retrieve and restore the $1,600,000 withdrawn from RKB to their personal or business balance;
3. Direct the Department of Commerce to investigate and report all asset movements made by MasterCaelen and RKB since the granting of the Emergency Injunction; and
4. Impose such sanctions as this Court deems necessary to compel compliance, consistent with the approach taken in [2026] FCR 8.

 

[Muggy21]

Same shit, different day...

Your Honour, @Muggy21

The Plaintiff urgently brings to the Court's attention evidence that MasterCaelen has violated the Emergency Injunction granted in these proceedings by dissipating assets held in their sole proprietorship, RKB, in an apparent attempt to render themselves judgment-proof in direct contravention of this Court's order.

On 7 March 2026, at 16:12 UTC, Plaintiff ran /db info RKB and recorded a balance of $1,685,954 - a sum consistent with the $1,700,000 received from Pepecuu.
View attachment 76510

On 8 March 2026 at 05:30 UTC, Plaintiff ran the same command and recorded a balance of $85,954 - a reduction of $1,600,000 in under 14 hours.
View attachment 76511

RKB is not a registered company with the DOC and maintains no active company docket. It is therefore a sole proprietorship under Part VI, Section 1 of the Legal Entity Act:

Part VI, Section 1(3) provides:

Meaning RKB's balance constitutes MasterCaelen's personal assets, and the withdrawal of $1,600,000 from RKB is a withdrawal of MasterCaelen's personal assets subject to this Court's Emergency Injunction.

The Emergency Injunction was filed and served as part of this action. Within hours, $1,600,000 disappeared from the sole proprietorship into which the $1,700,000 from Pepecuu had been deposited. MasterCaelen has followed precisely the playbook of their counterpart - the Plaintiff warned this Court in the Emergency Injunction motion that "the Plaintiff believes this pattern may extend to the assets now held by MasterCaelen." The Plaintiff respectfully submits, based on this clear evidence, that MasterCaelen is now engaged in identical behaviour.

The Plaintiff, therefore, requests that this Court:

1. Find MasterCaelen in contempt of court for violating the Emergency Injunction by withdrawing $1,600,000 from RKB following the granting of the injunction;
2. Order MasterCaelen to immediately retrieve and restore the $1,600,000 withdrawn from RKB to their personal or business balance;
3. Direct the Department of Commerce to investigate and report all asset movements made by MasterCaelen and RKB since the granting of the Emergency Injunction; and
4. Impose such sanctions as this Court deems necessary to compel compliance, consistent with the approach taken in [2026] FCR 8.

Granted in full.

@Caelen Your transfer violated this Court's order. You have until March 9th 2026 at 9pm EST to post a bond of $460,000 with DCGovernment and to show such proof in this thread. You or your lawyer may do this.


In the event you don't comply, you shall be found in Contempt for every 1 hour window for non-compliance. You'll be fined $5000 and imprisoned for 10 minutes per occurrence. The Court may take other more permanent actions to ensure compliance with its orders.

 

[Muggy21]

Granted in full.

@Caelen Your transfer violated this Court's order. You have until March 9th 2026 at 9pm EST to post a bond of $460,000 with DCGovernment and to show such proof in this thread. You or your lawyer may do this.


In the event you don't comply, you shall be found in Contempt for every 1 hour window for non-compliance. You'll be fined $5000 and imprisoned for 10 minutes per occurrence. The Court may take other more permanent actions to ensure compliance with its orders.

This has been completed, the EI is now being complied with.

 

[Johnes]

Present, Your Honour.

 

[Muggy21]

Present, Your Honour.

Thanks, 48 Hours to Respond.

 

[Johnes]

Thanks, 48 Hours to Respond.

Your Honour, I humly request a 24 hour extension. I had to finish an assignment and had not enough time to complete the answer. Much appreciated.

 

[Muggy21]

Your Honour, I humly request a 24 hour extension. I had to finish an assignment and had not enough time to complete the answer. Much appreciated.

Granted

 

[Johnes]

Answer to Complaint

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

Brick and Browse Inc.
Plaintiff

v.

MasterCaelen
Defendant

I. ANSWER TO COMPLAINT
1. AFFIRM
2. AFFIRM
3. AFFIRM
4. AFFIRM
5. AFFIRM
6. AFFIRM
7. NEITHER AFFIRM NOR DENY

II. DEFENCES
1. The Defendant had $460 000 in his balance
The Defendant had $460 000 in his balance during the duration of the Emergency Injunction, (D-001). The evidence shows, that ZxRiptide, the CEO of the RKB (D-002), deposited $600 000 into the Federal Reserve pursuant to § 6(13) of the Federal Reserve Act one day before the EI was in effect. As the Plaintiff mentioned, property of the RKB (a sole proprietorship) are property of the owner, the Defendant.

This shows that the Defendant has maintained $460 000 in liquid assets the entire time the EI was in effect, thus effectively complying with the EI.

Spoiler: D-001

Spoiler: D-002

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 11th day of March 2026.

Pursuant to Part IV, § 4 of the RCCA, we respectfully file a Third-Party Claim against Pepecuu.

Case Filing

IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
CIVIL ACTION – THIRD-PARTY CLAIM

MasterCaelen
Plaintiff

v.

Pepecuu
Third-Party Defendant

COMPLAINT
The Plaintiff complains against the Third-Party Defendant as follows:

On the 3rd of March 2026, the Third-Party Defendant, Pepecuu, transferred $1 700 000 to the Plaintiff, which the Plaintiff did not know of at the time, creating a liability for him for $460 000 due to the monetary verdict issued in [2026] FCR 8. This presents a clear case of fraud, causing damages for the Plaintiff, which has used the funds in good faith.

I. PARTIES
1. MasterCaelen (Plaintiff)
2. Pepecuu (Third-Party Defendant)

II. FACTS
1. On the 3rd of March, the Federal Court in [2026] FCR 8, ordered the Third-Party Defendant to pay $460 000 to the Plaintiff in said case.
2. RKB, Plaintiff's bank, sent $2,000,000 to the Department of Commerce in order to satisfy an emergency injunction granted in [2026] FCR 8 on behalf of the Third-Party Defendant.
3. At 11:22 UTC on the 3rd of March, the Third-Party Defendant sent $1,700,000 to the Plaintiff due to the $2,000,000 sum, which reduced the Third-Party Defendant's ability to satisfy the judgment in [2026] FCR 8. (P-004, TPC-001)
4. Third-Party Defendant sent the sum of $1,700,000 whilst aware of the judgment in [2026] FCR 8.
5. Plaintiff was not made aware of the verdict, or of any liabilities associated with the transfer, nor was he made aware of the transfer by the Third-Party Defendant in any way. (TPC-001)
6. On the 7th of March, ToadKing on behalf of Brick and Browse Inc. filed a case against the Plaintiff, seeking $460,000 from the $1,700,000 given to the Plaintiff.
7. Plaintiff relied on the Third-Party Defendant's lack of notice of the transferred funds, as to mean they're without any liabilities or judgment associated with them and used them in good faith. (TPC-002)
8. Behavior by the Third-Party Defendant is unacceptable of a sitting Magistrate.

III. CLAIMS FOR RELIEF
1. Fraud
The Redmont Civil Code Act's Part II § 4(2) and § 6(3) allow for plaintiffs to pursue civil action for criminal acts. The Criminal Code Act defines the crime of fraud as the following:

A person commits an offence if the person:
(a) knowingly or recklessly misrepresents or omits a material fact to another, causing the other party to rely on that misrepresentation, resulting in actual, quantifiable harm.

Let's examine the definition of fraud under the facts of this case:

1. Third-Party Defendant omitted the verdict in [2026] FCR 8 when returning the $1,700,000 to the Plaintiff; Third-Party Defendant did not inform the Plaintiff that a transfer of funds took place as well,

2. Third-Party Defendant's lack of notice caused the Plaintiff to rely on the information and used the funds transferred in good faith, and

3. the lack of notice resulted in a case being filed against the Plaintiff.

The facts of the matter satisfy the definition of fraud under the CCA, thus allows the Plaintiff to pursue civil action for the damages incurred by the Third-Party Defendant's conduct.

2. Punitive Damages
Third-Party Defendant, at the time of filing this case, is a sitting Magistrate of the District Court. As a judicial officer, the Third-Party Defendant must abide by and follow the Judicial Code of Ethics at all times.

The RCCA's Part II § 1 says:

1. Common Law Principles
(1) This Code shall be interpreted in a manner consistent with the principles of natural justice and common law unless expressly excluded. Judicial reasoning and precedent may inform interpretation and application of this Code where the law is silent or ambiguous.

This allows the Court to apply common law principles to its decisions and to consider precedent as binding. The same applies to the JCE and thus it allows the Courts to consider any rules therein as binding.

The JCE's § 1.3 states the following:

1.3 This Code applies to all judicial activities, whether in official proceedings, public communications, or private conduct that may affect the perception of the Judiciary.

§ 2.3:

2.3 Integrity: Judges must act honestly and uphold the dignity of judicial office at all times.

and § 5.1:

5.1 Judges and judicial officers must conduct themselves, in public and private life, in a manner consistent with the dignity of judicial office.

All of these rules show, that a judicial officer must refrain from being dishonest and must maintain dignity of the office at all times, even outside of Court. Third-Party Defendant's conduct in the scope of this case shows the dishonesty of the Third-Party Defendant and does not uphold the dignity of the judiciary.
Thus we respectfully ask the Court to grant us Punitive Damages for the Third-Party Defendant's conduct, as a sitting Magistrate.

IV. PRAYER FOR RELIEF
1. Any monetary judgment issued against the Defendant in the case of Brick and Browse Inc. v. MasterCaelen [2026] FCR 18 as Compensatory Damages.
2. $100,000 in Punitive Damages in regard to the conduct of the Third-Party Defendant.
3. 30% of the damages awarded as legal fees.

Spoiler: TPC-001

Spoiler: TPC-002

Witnesses:
ToadKing
ElysiaCrynn
Jakkuwu

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 11th day of February 2026.

 

[Muggy21]

Caption modified to Brick and Browse Inc. v. MasterCaelen, Third-Party Defendant Pepecuu [2026] FCR 18 to include the new third-party defendant.

Writ of Summons

@Pepecuu is required to appear before the Federal Court in the case of Brick and Browse Inc. v. MasterCaelen, Third-Party Defendant Pepecuu [2026] FCR 18

THIRD-PARTY DEFENDANT.

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.

 

[ToadKing]

Answer to Complaint

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

Brick and Browse Inc.
Plaintiff

v.

MasterCaelen
Defendant

I. ANSWER TO COMPLAINT
1. AFFIRM
2. AFFIRM
3. AFFIRM
4. AFFIRM
5. AFFIRM
6. AFFIRM
7. NEITHER AFFIRM NOR DENY

II. DEFENCES
1. The Defendant had $460 000 in his balance
The Defendant had $460 000 in his balance during the duration of the Emergency Injunction, (D-001). The evidence shows, that ZxRiptide, the CEO of the RKB (D-002), deposited $600 000 into the Federal Reserve pursuant to § 6(13) of the Federal Reserve Act one day before the EI was in effect. As the Plaintiff mentioned, property of the RKB (a sole proprietorship) are property of the owner, the Defendant.

This shows that the Defendant has maintained $460 000 in liquid assets the entire time the EI was in effect, thus effectively complying with the EI.

Spoiler: D-001

View attachment 76741

Spoiler: D-002

View attachment 76740

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 11th day of March 2026.

Motion

IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
MOTION FOR SUMMARY JUDGMENT

Your Honour,

Plaintiff moves for summary judgment on all claims pursuant to the undisputed material facts established by Defendant's Answer to Complaint. Defendant has affirmed every material fact in this case - Facts 1 through 6 - and has neither affirmed nor denied Fact 7, that MasterCaelen retains the $1,700,000 without legal justification. A failure to deny is not a denial.

Consistent with this Court's approach in Volt Bank, Inc. v. Sagamo2008 [2025] FCR 135 and Brick and Browse Inc. v. Pepecuu [2026] FCR 8, where material facts are not in dispute, summary judgment is appropriate. The Defendant has affirmed that a $460,000 judgment existed, that Pepecuu held sufficient funds to satisfy it, that the transfer to MasterCaelen occurred 16 minutes after the appeal was filed, and that Pepecuu subsequently admitted she could not satisfy the judgment. No triable issue of fact remains. The elements of unjust enrichment are established on the affirmed facts alone.

The Plaintiff further notes that Defendant has filed a Third-Party Complaint against Pepecuu pursuant to RCCA Part IV, Section 4(1)(a), alleging that Pepecuu is liable to MasterCaelen for all or part of the Plaintiff's claim against MasterCaelen. That provision expressly permits a defendant to bring such a claim where "the third party is or may be liable to the defendant for all or part of the plaintiff's claim." Under Part IV, Section 4(3), Pepecuu has now become a party to these proceedings with all associated rights and obligations, and under Part IV, Section 7(2), that third-party claim shall be determined within the same proceeding unless this Court orders otherwise.

The Plaintiff takes no position on the merits of MasterCaelen's claim against Pepecuu. However, the filing of that Third-Party Complaint is itself a concession that MasterCaelen does not dispute that the $460,000 must ultimately be accounted for - only that Pepecuu should bear it. That dispute is properly one for MasterCaelen v. Pepecuu to resolve within this proceeding, and the Plaintiff respectfully submits that this Court should enter judgment in favour of the Plaintiff first, with the third-party claim between MasterCaelen and Pepecuu proceeding accordingly thereafter.

 

[Johnes]

Motion

IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
MOTION FOR SUMMARY JUDGMENT

Your Honour,

Plaintiff moves for summary judgment on all claims pursuant to the undisputed material facts established by Defendant's Answer to Complaint. Defendant has affirmed every material fact in this case - Facts 1 through 6 - and has neither affirmed nor denied Fact 7, that MasterCaelen retains the $1,700,000 without legal justification. A failure to deny is not a denial.

Consistent with this Court's approach in Volt Bank, Inc. v. Sagamo2008 [2025] FCR 135 and Brick and Browse Inc. v. Pepecuu [2026] FCR 8, where material facts are not in dispute, summary judgment is appropriate. The Defendant has affirmed that a $460,000 judgment existed, that Pepecuu held sufficient funds to satisfy it, that the transfer to MasterCaelen occurred 16 minutes after the appeal was filed, and that Pepecuu subsequently admitted she could not satisfy the judgment. No triable issue of fact remains. The elements of unjust enrichment are established on the affirmed facts alone.

The Plaintiff further notes that Defendant has filed a Third-Party Complaint against Pepecuu pursuant to RCCA Part IV, Section 4(1)(a), alleging that Pepecuu is liable to MasterCaelen for all or part of the Plaintiff's claim against MasterCaelen. That provision expressly permits a defendant to bring such a claim where "the third party is or may be liable to the defendant for all or part of the plaintiff's claim." Under Part IV, Section 4(3), Pepecuu has now become a party to these proceedings with all associated rights and obligations, and under Part IV, Section 7(2), that third-party claim shall be determined within the same proceeding unless this Court orders otherwise.

The Plaintiff takes no position on the merits of MasterCaelen's claim against Pepecuu. However, the filing of that Third-Party Complaint is itself a concession that MasterCaelen does not dispute that the $460,000 must ultimately be accounted for - only that Pepecuu should bear it. That dispute is properly one for MasterCaelen v. Pepecuu to resolve within this proceeding, and the Plaintiff respectfully submits that this Court should enter judgment in favour of the Plaintiff first, with the third-party claim between MasterCaelen and Pepecuu proceeding accordingly thereafter.

Defendant does not dispute this motion.

 

[Johnes]

Your Honour, the parties in the Third-Party Complaint are currently negotiating a settlement. We respectfully request a continuance on the Third-Party Complaint.

 

[Muggy21]

Your Honour, the parties in the Third-Party Complaint are currently negotiating a settlement. We respectfully request a continuance on the Third-Party Complaint.

Give a status update by 3/14/26 @ 9pm EST.

I'm going to hold from finalizing the summary motion, I don't want a situation where my EI permits the money to move against parties interest.