Lawsuit: Pending CastoloGR v. Raz0Baz0 [2025] DCR 83

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IN THE DISTRICT COURT OF THE COMMONWEALTH OF REDMONT
CIVIL ACTION


CastoloGR
Plaintiff

v.

Raz0Baz0
Defendant

The Plaintiff complains against the Defendant as follows:

On October 10, 2025, TheBlockTimes published an article based on an anonymous tip, carefully noting the unverified nature of the information with phrases such as "Based on an anonymous tip" and "Apparently." The article concerned a potential change in political endorsement from Plura72. Shortly after, upon Plura72's denial of the tip's contents, the People's Press, under Chief Editor Raz0Baz0, published an article that went beyond reporting the denial. The People's Press article falsely accused TheBlockTimes of spreading "misinformation" and engaging in "journalist malpractice."

These statements are not matters of opinion but are presented as factual accusations regarding TheBlockTimes' professional conduct. The Defendant, motivated by a clear political conflict of interest, knowingly published these false and damaging statements even after being directly warned by the Plaintiff that such accusations could constitute defamation. Furthermore, the Defendant deliberately manipulated evidence to support their false narrative. This conduct constitutes libel under Redmont law and has caused direct injury to the reputation and professional standing of TheBlockTimes, for which the Plaintiff now seeks relief.

I. PARTIES

CastoloGR - Plaintiff
The Block Times - Plaintiff’s newspaper

Raz0Baz0- Defendant
People's Press/People Press - Defendant’s newspaper


II. FACTS

  1. On October 10, 2025, the Plaintiff published an article titled “Plura Withdrawing Support Of JamesTheSlay And Is Now Endorsing Culls.” The article clearly stated its sourcing was an anonymous tip (Exhibit P-001).
  2. Subsequently, Plura72 made a statement denying the information in the anonymous tip and reaffirming his support for JamesTheSlay (Exhibit P-002).
  3. On October 10, 2025, the Defendant, Raz0Baz0, authored and published an article in the People's Press titled “The Block Times spreading misinformation?” (Exhibit P-002).
  4. The Defendant, Raz0Baz0, serves as the Head of Affairs for the Labor Party of Redmont (LPR), the political party led by Plura72. This establishes a clear conflict of interest, indicating that the Defendant's article was motivated by political bias rather than journalistic integrity.
  5. The Defendant's article made the direct and unsubstantiated accusation that TheBlockTimes was engaged in a "blatant misinformation campaign, or journalist malpractice."
  6. The Defendant published these accusations despite being personally warned by the Plaintiff about the potential for a defamation lawsuit. The Defendant's own article includes a direct quote from the Plaintiff stating, "I'll just say that saying TBT is spreading misinformation without proof... can lead to defamation charges."
  7. Crucially, the Defendant's article featured a screenshot of a "sue me" gif sent by the Plaintiff, but deliberately and maliciously edited the image to omit the Plaintiff's immediately subsequent message stating "jk" (just kidding). This selective editing was clearly intended to create the false and damaging impression that the Plaintiff was being belligerent, when the full context shows the Plaintiff was being humorous (Exhibit P-003).
  8. The Defendant's actions driven by political bias and executed through the manipulation of evidence demonstrate that their article was not a work of good faith journalism, but a malicious attack designed to harm the Plaintiff's reputation.
  9. As a direct result of the Defendant's article, TheBlockTimes has suffered demonstrable reputational harm. The Plaintiff has secured evidence of a community member publicly stating that they lost credibility for the Plaintiff's newspaper specifically because of the Defendant's defamatory article (Exhibit P-004).
III. CLAIMS FOR RELIEF

  • Libel. The No More Defamation Act defines defamation in §4(1)(a) as: “Defamation is a false statement and/or communication that injures a third party's reputation. The tort of defamation includes both libel and slander.” The same act, in §4(2)(a), defines Libel as: “A method of defamation expressed by documents, signs, published media, or any communication embodied in physical form that is injurious to a person's reputation, exposes a person to public hatred, contempt or ridicule, or injures a person in his/her business, profession or organization.”
  • The Defendant published an article, a form of media embodied in physical form.
  • This article contained false statements accusing the Plaintiff's organization of "spreading misinformation" and committing "journalist malpractice."
  • The Defendant acted with actual malice, demonstrated by their clear conflict of interest and their deliberate manipulation of evidence (the cropped screenshot) to create a false narrative and hold the Plaintiff up for public ridicule. This proves a knowing and reckless disregard for the truth, motivated by political bias.
  • These libelous statements have caused injury to TheBlockTimes's reputation, as shown in the evidence, fulfilling all criteria under the Act.
IV. PRAYER FOR RELIEF
The Plaintiff seeks the following from the Defendant:

  1. Public Apology. As authorized by the No More Defamation Act, §5(1)(a), we request the Defendant be ordered to issue a formal and public apology to TheBlockTimes for the false and damaging statements made.
  2. Public Retraction. We request the Defendant be ordered to publish a formal and public retraction of the defamatory statements made in their article, specifically the accusations of "spreading misinformation" and "journalist malpractice."
  3. Defamation Damages. As authorized by the No More Defamation Act, §5(1), we request $10,000 for the significant reputational and professional injury suffered by TheBlockTimes due to the Defendant's libelous publication.
  4. Legal Damages. As authorized by the Legal Damages Act, we request damages of 30% of the total case value to be awarded to the Plaintiff's legal representative.
V. EXHIBITS
Exhibit P-001:
TheBlockTimes Article: “Plura Withdrawing Support Of JamesTheSlay And Is Now Endorsing Culls”.
P-001.png
Exhibit P-002: People's Press Article: “The Block Times spreading misinformation?”
P-002.png
Exhibit P-003: A complete screenshot of the Plaintiff's "sue me" gif immediately followed by the "jk" message, proving the Defendant's exhibit was maliciously edited.
P-003.png

Exhibit P-004: Screenshot of a community member stating a loss of credibility in TheBlockTimes as a direct result of the Defendant's article.
P-004.png

Proof of representation:

1449189841682462.PNG
 
Last edited:

Writ of Summons

@Silly Billy(Raz0Baz0), is required to appear before the district Court in the case of CastoloGR v. Raz0Baz0 [2025] DCR 83

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.

 

Motion

IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
MOTION TO AMEND FILING

The Plaintiff respectfully requests to amend a small error in the initial filing, point two under FACTS should say:

"Subsequently, Plura72 made a statement denying the information in the anonymous tip and reaffirming his support for JamesTheSlay (Exhibit P-002)."

And not:

Subsequently, Plura72 made a statement denying the information in the anonymous tip and reaffirming his support for JamesTheSlay (Exhibit P-001).

 

Motion

IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
MOTION TO AMEND FILING

The Plaintiff respectfully requests to amend a small error in the initial filing, point two under FACTS should say:

"Subsequently, Plura72 made a statement denying the information in the anonymous tip and reaffirming his support for JamesTheSlay (Exhibit P-002)."

And not:

Subsequently, Plura72 made a statement denying the information in the anonymous tip and reaffirming his support for JamesTheSlay (Exhibit P-001).

Granted
 

Answer to Complaint


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

CastoloGR
Plaintiff

v.

Raz0Baz0
Defendant



I. ANSWER TO COMPLAINT​

  1. Defendant AFFIRMS paragraph 1 of the Complaint.
  2. Defendant AFFIRMS paragraph 2 of the Complaint.
  3. Defendant AFFIRMS paragraph 3 of the Complaint.
  4. Defendant AFFIRMS that Defendant serves in the LPR position alleged in paragraph 4, but DENIES this connection “indicated” Defendant’s article was “motivated by political bias.”
  5. Defendant AFFIRMS that their article made the statements alleged in paragraph 5, but DENIES they were "unsubstantiated" or otherwise false.
  6. Defendant neither AFFIRMS NOR DENIES paragraph 6 of the Complaint. Plaintiff’s personal opinion on defamation has no bearing on this case, nor does Defendant capitulate to bare threats at the drop of a hat.
  7. Defendant AFFIRMS that their article included the screenshot sent by plaintiff, as alleged in paragraph 7. Defendant DENIES the screenshot was “maliciously edited” or that it was “deliberately” designed to create a “false and misleading impression.”
  8. Defendant DENIES paragraph 8 of the Complaint.
  9. Defendant DENIES paragraph 9 of the Complaint. Any harm to Plaintiff’s reputation has come from their incorrect reporting.



II. DEFENCES​

A. Defendant’s statements were true.​

Truth is an absolute defence to a defamation claim. Nobody can be held liable for making a true statement. This case turns on whether Defendant's statements are true; namely, whether Plaintiff "spread misinformation" and committed "journalist[ic] malpractice."

Plaintiff admits the first charge in their Complaint. The TBT article said Plura72 was going to Culls over JamesTheSlay. But paragraph 2 of the Complaint says, "Plura72 … reaffirm[ed] his support for JamesTheSlay". Plainly, the TBT article was inaccurate. "Misinformation" is defined as "false or inaccurate information." Defendant cannot see how Plaintiff can sustain a claim in defamation under this heading.

As to the second charge that the TBT committed "journalistic malpractice", Defendant’s statement is also true. Plaintiff chose to publish their article based on information from a single, unverified, anonymous source. The danger of such sources is clear: they might be totally wrong (as in this case!). Therefore, journalistic standards demand the use of ideally-multiple reliable sources. Plaintiff didn’t bother with generally-accepted journalistic standards and therefore, Defendant's claim of malpractice is true or substantially true.

B. Defendant's statements are opinion.​

As to the second claim about journalistic malpractice, Defendant's statements constitute an expression of their opinion. There is no legislation or industry body regulating journalists in Redmont. In lieu of specific written standards, Defendant is entitled to a level of deference about what constitutes "journalistic malpractice".



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 October 2025.

 

Motion


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

Your Honor,—

Defendant moves that the third Prayer for Relief be dismissed, and in support thereof, respectfully alleges:

The Complaint does not sufficiently plead damages. "Defamation damages" are not recognized under the Legal Damages Act. §5(1) of the No More Defamation Act simply provides that damages are available under the LDA; it does not create a new category of "defamation damages". The Complaint does not make out whether the damages claimed are punitive, consequential, compensatory, or otherwise. For this reason, the Court should dismiss the third Prayer for Relief.




Defendant separately moves that Complaint be dismissed insofar as it relates to the statement about "spreading misinformation":

Under Rule 5.5, that part of the Complaint should be dismissed for failure to state a claim. As pleaded, the Complaint implicitly accepts that the TRT "spread misinformation". The Complaint acknowledges that the TRT was wrong to say that Plura72 changed their endorsement. Under the plain meaning of the term "misinformation" ("false or inaccurate information"), the TRT's reporting was misinformation. Defendant's statement was true. Since a statement must be false to be defamatory, Defendant asks the Court to dismiss this part of the Complaint.

 

Motion


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

Your Honor,—

Defendant moves that the third Prayer for Relief be dismissed, and in support thereof, respectfully alleges:

The Complaint does not sufficiently plead damages. "Defamation damages" are not recognized under the Legal Damages Act. §5(1) of the No More Defamation Act simply provides that damages are available under the LDA; it does not create a new category of "defamation damages". The Complaint does not make out whether the damages claimed are punitive, consequential, compensatory, or otherwise. For this reason, the Court should dismiss the third Prayer for Relief.




Defendant separately moves that Complaint be dismissed insofar as it relates to the statement about "spreading misinformation":

Under Rule 5.5, that part of the Complaint should be dismissed for failure to state a claim. As pleaded, the Complaint implicitly accepts that the TRT "spread misinformation". The Complaint acknowledges that the TRT was wrong to say that Plura72 changed their endorsement. Under the plain meaning of the term "misinformation" ("false or inaccurate information"), the TRT's reporting was misinformation. Defendant's statement was true. Since a statement must be false to be defamatory, Defendant asks the Court to dismiss this part of the Complaint.

PLAINTIFF'S RESPONSE IN OPPOSITION TO DEFENDANT'S MOTION TO DISMISS

Your Honor,

The Plaintiff respectfully requests that the Court deny the Defendants Motion to Dismiss in its entirety. The motion, which carelessly misidentifies the Plaintiff TheBlockTimes as "TRT" throughout is based on a factually incorrect understanding of this Commonwealths legal precedent and a deliberate mischaracterisation of the Plaintiffs claim.

I. The Court Has Repeatedly Recognized and Awarded Monetary Damages for Defamation.

The Defendant's primary argument that "Defamation damages" are not recognized is demonstrably false and is directly contradicted by established case law. While the No More Defamation Act §5(1) provides the clear statutory authority for such damages, the courts of this Commonwealth have consistently put this authority into practice.
  • In Lemonade Lottery v. instrumentbee73 [2022] DCR 10, the court awarded a monetary penalty for slander.
  • In Aladeen22 v. Topte [2021] DCR 8, the court explicitly ordered the defendant to pay "$300 to the plaintiff in compensation" for slander intended to "degrade the reputation of the plaintiff."
  • In BananaNova v. Ugoslawia [2022] DCR 41, the court ordered a $1,000 fine based on the defendant having "damaged the reputation of the Plaintiff" through slander.
These precedents clearly establish that monetary damages for reputational harm caused by defamation are a recognized and adjudicated remedy in this jurisdiction. The Defendant's motion is based on a false premise, and this part of their motion must be denied.

II. The Complaint States a Valid Claim for Libel as the Defendant's Statement Was Both False and Malicious.

The Defendant's argument that their statement was "true" is a simplistic and selfserving defense that ignores both logic and legal precedent regarding malice.

First, the Defendant's statement "TheBlockTimes is spreading misinformation" is a false statement. The Plaintiff's article made a truthful statement: that it had received an anonymous tip. The act of truthfully reporting on the existence of a tip, with appropriate journalistic caveats is not "spreading misinformation." The Defendant's accusation is a separate, false statement about the Plaintiff's professional conduct.

Second, and more importantly, this Court and the Federal Court have consistently held that a defendant's intent and malice are critical factors.
  • In Aladeen22 v. Topte [2021] DCR 8, the court's decision rested on the finding that "the defendant clearly intended to insult and degrade the reputation of the plaintiff."
  • Similarly, in MegaMinerM v. Blazora Corporation [2025] FCR 27, the court considered "the character of the defendant's act" and the "outrageous conduct" when awarding punitive damages.
As pleaded in our Complaint, the Defendant here acted with clear malice and outrageous conduct. He operated from a political conflict of interest and deliberately manipulated evidence (the "jk" screenshot) to create a false narrative. This was not a good-faith statement of truth; it was a malicious act intended to degrade the reputation of TheBlockTimes, precisely the kind of conduct the courts have consistently found to be actionable.

CONCLUSION

For the foregoing reasons, the Defendant's motion is legally and factually baseless. The courts have repeatedly awarded damages for defamation, and the Complaint has pleaded a clear and actionable case for libel supported by evidence of malice. We respectfully request that the Court deny the Motion to Dismiss in its entirety and allow this case to proceed.
 
PLAINTIFF'S RESPONSE IN OPPOSITION TO DEFENDANT'S MOTION TO DISMISS

Your Honor,

The Plaintiff respectfully requests that the Court deny the Defendants Motion to Dismiss in its entirety. The motion, which carelessly misidentifies the Plaintiff TheBlockTimes as "TRT" throughout is based on a factually incorrect understanding of this Commonwealths legal precedent and a deliberate mischaracterisation of the Plaintiffs claim.

I. The Court Has Repeatedly Recognized and Awarded Monetary Damages for Defamation.

The Defendant's primary argument that "Defamation damages" are not recognized is demonstrably false and is directly contradicted by established case law. While the No More Defamation Act §5(1) provides the clear statutory authority for such damages, the courts of this Commonwealth have consistently put this authority into practice.
  • In Lemonade Lottery v. instrumentbee73 [2022] DCR 10, the court awarded a monetary penalty for slander.
  • In Aladeen22 v. Topte [2021] DCR 8, the court explicitly ordered the defendant to pay "$300 to the plaintiff in compensation" for slander intended to "degrade the reputation of the plaintiff."
  • In BananaNova v. Ugoslawia [2022] DCR 41, the court ordered a $1,000 fine based on the defendant having "damaged the reputation of the Plaintiff" through slander.
These precedents clearly establish that monetary damages for reputational harm caused by defamation are a recognized and adjudicated remedy in this jurisdiction. The Defendant's motion is based on a false premise, and this part of their motion must be denied.

II. The Complaint States a Valid Claim for Libel as the Defendant's Statement Was Both False and Malicious.

The Defendant's argument that their statement was "true" is a simplistic and selfserving defense that ignores both logic and legal precedent regarding malice.

First, the Defendant's statement "TheBlockTimes is spreading misinformation" is a false statement. The Plaintiff's article made a truthful statement: that it had received an anonymous tip. The act of truthfully reporting on the existence of a tip, with appropriate journalistic caveats is not "spreading misinformation." The Defendant's accusation is a separate, false statement about the Plaintiff's professional conduct.

Second, and more importantly, this Court and the Federal Court have consistently held that a defendant's intent and malice are critical factors.
  • In Aladeen22 v. Topte [2021] DCR 8, the court's decision rested on the finding that "the defendant clearly intended to insult and degrade the reputation of the plaintiff."
  • Similarly, in MegaMinerM v. Blazora Corporation [2025] FCR 27, the court considered "the character of the defendant's act" and the "outrageous conduct" when awarding punitive damages.
As pleaded in our Complaint, the Defendant here acted with clear malice and outrageous conduct. He operated from a political conflict of interest and deliberately manipulated evidence (the "jk" screenshot) to create a false narrative. This was not a good-faith statement of truth; it was a malicious act intended to degrade the reputation of TheBlockTimes, precisely the kind of conduct the courts have consistently found to be actionable.

CONCLUSION

For the foregoing reasons, the Defendant's motion is legally and factually baseless. The courts have repeatedly awarded damages for defamation, and the Complaint has pleaded a clear and actionable case for libel supported by evidence of malice. We respectfully request that the Court deny the Motion to Dismiss in its entirety and allow this case to proceed.

Objection


IN THE DISTRICT COURT OF THE COMMONWEALTH OF REDMONT
OBJECTION — BREACH OF PROCEDURE

Your Honor,—

Plaintiff has not asked for the Court's permission to respond to my Motion.

 

Objection


IN THE DISTRICT COURT OF THE COMMONWEALTH OF REDMONT
OBJECTION — BREACH OF PROCEDURE

Your Honor,—

Plaintiff has not asked for the Court's permission to respond to my Motion.

RESPONSE TO DEFENDANT'S OBJECTION

Your Honor,

The Plaintiff files this response to the Defendant's "Objection — Breach of Procedure." The objection is procedurally baseless, legally unsound, and should be summarily denied.

A fundamental tenet of a fair and adversarial system of justice is the right of a party to be heard. When one party in a lawsuit files a dispositive motion, such as the Defendant's Motion to Dismiss, the opposing party has an automatic right to be heard on that matter. This is not a privilege for which one must ask permission, it is a core component of due process that ensures the Court can make a fully informed and just decision.

The burden rests entirely on the objecting party to demonstrate that a specific procedure was breached. The Defendant has failed to cite any rule, law, or court policy to support their extraordinary claim that a party must seek "permission" to defend its case. The Defendant has failed to meet this burden because no such rule or law exists.
 

Objection


IN THE DISTRICT COURT OF THE COMMONWEALTH OF REDMONT
OBJECTION — BREACH OF PROCEDURE

Your Honor,—

Plaintiff has not asked for the Court's permission to respond to my Motion.

Sustained.
Following precedent set in [2025] DCR 66 Responses to motions are by request.

Motion


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

Your Honor,—

Defendant moves that the third Prayer for Relief be dismissed, and in support thereof, respectfully alleges:

The Complaint does not sufficiently plead damages. "Defamation damages" are not recognized under the Legal Damages Act. §5(1) of the No More Defamation Act simply provides that damages are available under the LDA; it does not create a new category of "defamation damages". The Complaint does not make out whether the damages claimed are punitive, consequential, compensatory, or otherwise. For this reason, the Court should dismiss the third Prayer for Relief.




Defendant separately moves that Complaint be dismissed insofar as it relates to the statement about "spreading misinformation":

Under Rule 5.5, that part of the Complaint should be dismissed for failure to state a claim. As pleaded, the Complaint implicitly accepts that the TRT "spread misinformation". The Complaint acknowledges that the TRT was wrong to say that Plura72 changed their endorsement. Under the plain meaning of the term "misinformation" ("false or inaccurate information"), the TRT's reporting was misinformation. Defendant's statement was true. Since a statement must be false to be defamatory, Defendant asks the Court to dismiss this part of the Complaint.

Denied.

Acording to the No more Defamation Act
5 - Punishments

(1) Damages caused by defamation, if proven in a civil court of law, shall be paid out as determined by the presiding Judicial Officer.
Damages awarded for defamation if proven in a court are a valid prayer for relief.
furthermore in [2022] DCR 41 this court recognized damages.


Discovery shall now begin lasting 5 days. it may be ended early if both parties agree.
 

Motion

IN THE DISTRICT COURT OF THE COMMONWEALTH OF REDMONT
MOTION FOR SANCTIONS

Your Honor,

The Plaintiff respectfully moves this Court to issue sanctions against the Defendant's legal counsel, BrownBerry, for engaging in serious misconduct intended to intimidate the Plaintiff and obstruct the fair administration of justice. As established in precedents such as YeetGlazer v. Commonwealth of Redmont FCR 76, this Court has the clear authority to sanction parties for such bad faith conduct.

Background

On October 19, 2025, during a settlement discussion, Defendant's counsel made a direct and improper threat. As documented in the attached exhibit, counsel stated:

"I'd also note that we intend to request the name of your client's anonymous source in discovery. It's in your client's interest to settle to avoid that."
This statement is a transparent attempt to abuse the Court's discovery process as a weapon to coerce the Plaintiff into abandoning his case.

Legal Argument

This conduct is a severe breach of legal ethics and constitutes sanctionable conduct under the Commonwealths laws.

The threat appears to be a clear violation of the Criminal Code Act. By weaponizing the Court's own procedures for the purpose of intimidation, the conduct "obstructs or interferes with the administration of justice," constituting Contempt of Court (§2b).

Furthermore, the Obstruction of Justice statute (§3a) prohibits willfully interfering with justice by "threatening... a witness, [or] potential witness." The Plaintiff is, by definition, the primary witness to the facts of his own claim, and the anonymous source is undeniably a potential witness. The threat to expose this source is a direct attempt to impede and intimidate both. The Defendant's counsel's conduct rises to a level that warrants not just civil remedies but a referral for criminal investigation.

Requested Sanctions

In light of this bad faith and misconduct and to protect the integrity of these proceedings, the Plaintiff respectfully requests the Court to impose the following sanctions:

  1. Protective Order: An order from this Court prohibiting the Defendant from requesting the identity of the Plaintiff's anonymous source during any phase of discovery in this case.
  2. Finding of Contempt: A formal finding from this Court that the Defendant's counsel is in Contempt of Court for their attempt to interfere with the administration of justice.
  3. Investigation: An order directing the Department of Justice to investigate the conduct of Defendant's counsel for a potential criminal violation of the Obstruction of Justice statute.
Attached Exhibit

Exhibit P-006
: Screenshot of the settlement discussion wherein the threat was made.
P-006.PNG

 

Motion

IN THE DISTRICT COURT OF THE COMMONWEALTH OF REDMONT
MOTION FOR SANCTIONS

Your Honor,

The Plaintiff respectfully moves this Court to issue sanctions against the Defendant's legal counsel, BrownBerry, for engaging in serious misconduct intended to intimidate the Plaintiff and obstruct the fair administration of justice. As established in precedents such as YeetGlazer v. Commonwealth of Redmont FCR 76, this Court has the clear authority to sanction parties for such bad faith conduct.

Background

On October 19, 2025, during a settlement discussion, Defendant's counsel made a direct and improper threat. As documented in the attached exhibit, counsel stated:


This statement is a transparent attempt to abuse the Court's discovery process as a weapon to coerce the Plaintiff into abandoning his case.

Legal Argument

This conduct is a severe breach of legal ethics and constitutes sanctionable conduct under the Commonwealths laws.

The threat appears to be a clear violation of the Criminal Code Act. By weaponizing the Court's own procedures for the purpose of intimidation, the conduct "obstructs or interferes with the administration of justice," constituting Contempt of Court (§2b).

Furthermore, the Obstruction of Justice statute (§3a) prohibits willfully interfering with justice by "threatening... a witness, [or] potential witness." The Plaintiff is, by definition, the primary witness to the facts of his own claim, and the anonymous source is undeniably a potential witness. The threat to expose this source is a direct attempt to impede and intimidate both. The Defendant's counsel's conduct rises to a level that warrants not just civil remedies but a referral for criminal investigation.

Requested Sanctions

In light of this bad faith and misconduct and to protect the integrity of these proceedings, the Plaintiff respectfully requests the Court to impose the following sanctions:

  1. Protective Order: An order from this Court prohibiting the Defendant from requesting the identity of the Plaintiff's anonymous source during any phase of discovery in this case.
  2. Finding of Contempt: A formal finding from this Court that the Defendant's counsel is in Contempt of Court for their attempt to interfere with the administration of justice.
  3. Investigation: An order directing the Department of Justice to investigate the conduct of Defendant's counsel for a potential criminal violation of the Obstruction of Justice statute.
Attached Exhibit

Exhibit P-006
: Screenshot of the settlement discussion wherein the threat was made.

Your Honor,

The MZLD requests permission to respond.
 
Sustained.
Following precedent set in [2025] DCR 66 Responses to motions are by request.


Denied.

Acording to the No more Defamation Act

Damages awarded for defamation if proven in a court are a valid prayer for relief.
furthermore in [2022] DCR 41 this court recognized damages.


Discovery shall now begin lasting 5 days. it may be ended early if both parties agree.

Motion


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

Your Honor, two points of clarification:

1. I do not understand what damages Plaintiff is claiming. Plaintiff and the Court both referred to cases before the enactment of the Legal Damages Act, which changed the law relating to damages (precisely in order to stop litigants from claiming generalized "defamation damages"). Could the Court please inform Defendant's counsel the type of damages Plaintiff is claiming under the Legal Damages Act? I'm asking this because Plaintiff's counsel has referred to decisions of this Court (including [2025] FCR 27) relating to punitive damages. Is Plaintiff claiming punitive damages (which would mean they have to prove Defendant's conduct was outrageous)? If not, are they claiming consequential or compensatory damages?

2. Has Your Honor ruled on the second part of my Motion to Dismiss? If so, just so I can make better arguments in future, what were the Court's grounds?

 

Motion


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

Your Honor, two points of clarification:

1. I do not understand what damages Plaintiff is claiming. Plaintiff and the Court both referred to cases before the enactment of the Legal Damages Act, which changed the law relating to damages (precisely in order to stop litigants from claiming generalized "defamation damages"). Could the Court please inform Defendant's counsel the type of damages Plaintiff is claiming under the Legal Damages Act? I'm asking this because Plaintiff's counsel has referred to decisions of this Court (including [2025] FCR 27) relating to punitive damages. Is Plaintiff claiming punitive damages (which would mean they have to prove Defendant's conduct was outrageous)? If not, are they claiming consequential or compensatory damages?

2. Has Your Honor ruled on the second part of my Motion to Dismiss? If so, just so I can make better arguments in future, what were the Court's grounds?

Your honor,

The Plaintiff respectfully requests permission to respond to the Motion.
 

Motion


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

Your Honor, two points of clarification:

1. I do not understand what damages Plaintiff is claiming. Plaintiff and the Court both referred to cases before the enactment of the Legal Damages Act, which changed the law relating to damages (precisely in order to stop litigants from claiming generalized "defamation damages"). Could the Court please inform Defendant's counsel the type of damages Plaintiff is claiming under the Legal Damages Act? I'm asking this because Plaintiff's counsel has referred to decisions of this Court (including [2025] FCR 27) relating to punitive damages. Is Plaintiff claiming punitive damages (which would mean they have to prove Defendant's conduct was outrageous)? If not, are they claiming consequential or compensatory damages?

2. Has Your Honor ruled on the second part of my Motion to Dismiss? If so, just so I can make better arguments in future, what were the Court's grounds?

RESPONSE TO DEFENDANT'S MOTION TO RECONSIDER

Your Honor,

The Plaintiff files this response to the Defendant's "Motion to Reconsider." The motion is improper as it seeks to relitigate arguments that have already been decided by this Court. Furthermore it asks the Court to clarify matters that are already plain and evident from the record.

The Nature of the Damages Claim is Clear.

The Defendant claims to be confused over the type of damages being claimed. Let us be clear:

The damages sought are compensatory damages for the direct and documented injury to the Plaintiff's professional reputation caused by the Defendant's libelous publication. We have already submitted evidence of this harm (Exhibit P-005).

The sole authority required to sustain this claim is the No More Defamation Act §5(1), which explicitly empowers the Court to award "Damages caused by defamation." The Court correctly cited this statute in its ruling. The Defendant's confusion regarding the Legal Damages Act or other types of damages is irrelevant the NMDA is the controlling and specific statute for this tort.

II. The Court's Ruling on the Motion to Dismiss Was Clear.

The Defendant asks whether the Court has ruled on the second part of their Motion to Dismiss. The Court's ruling was clear and dispositive.

A motion to dismiss for failure to state a claim, if granted, results in the termination of the case. By denying the motion and immediately ordering the case to proceed to discovery, the Court has, by necessary implication, denied all parts of the Defendant's motion. The case would not be continuing if the Court believed the Plaintiff's claim was invalid as a matter of law.

The Defendant's request for the Court's "grounds" is an improper attempt to relitigate a motion that has already been decided against them by the court.
 

Motion

IN THE DISTRICT COURT OF THE COMMONWEALTH OF REDMONT
MOTION FOR SANCTIONS

Your Honor,

The Plaintiff respectfully moves this Court to issue sanctions against the Defendant's legal counsel, BrownBerry, for engaging in serious misconduct intended to intimidate the Plaintiff and obstruct the fair administration of justice. As established in precedents such as YeetGlazer v. Commonwealth of Redmont FCR 76, this Court has the clear authority to sanction parties for such bad faith conduct.

Background

On October 19, 2025, during a settlement discussion, Defendant's counsel made a direct and improper threat. As documented in the attached exhibit, counsel stated:


This statement is a transparent attempt to abuse the Court's discovery process as a weapon to coerce the Plaintiff into abandoning his case.

Legal Argument

This conduct is a severe breach of legal ethics and constitutes sanctionable conduct under the Commonwealths laws.

The threat appears to be a clear violation of the Criminal Code Act. By weaponizing the Court's own procedures for the purpose of intimidation, the conduct "obstructs or interferes with the administration of justice," constituting Contempt of Court (§2b).

Furthermore, the Obstruction of Justice statute (§3a) prohibits willfully interfering with justice by "threatening... a witness, [or] potential witness." The Plaintiff is, by definition, the primary witness to the facts of his own claim, and the anonymous source is undeniably a potential witness. The threat to expose this source is a direct attempt to impede and intimidate both. The Defendant's counsel's conduct rises to a level that warrants not just civil remedies but a referral for criminal investigation.

Requested Sanctions

In light of this bad faith and misconduct and to protect the integrity of these proceedings, the Plaintiff respectfully requests the Court to impose the following sanctions:

  1. Protective Order: An order from this Court prohibiting the Defendant from requesting the identity of the Plaintiff's anonymous source during any phase of discovery in this case.
  2. Finding of Contempt: A formal finding from this Court that the Defendant's counsel is in Contempt of Court for their attempt to interfere with the administration of justice.
  3. Investigation: An order directing the Department of Justice to investigate the conduct of Defendant's counsel for a potential criminal violation of the Obstruction of Justice statute.
Attached Exhibit

Exhibit P-006
: Screenshot of the settlement discussion wherein the threat was made.

Defendant's Response to Plaintiff's Motion for Sanctions

Your Honor,—

Let me tell you what is missing from Plaintiff’s motion: they have not discussed whether the name of their source is relevant evidence in this case. Indeed, Plaintiff does not dispute that the evidence is relevant. As I said to Plaintiff’s counsel:

That information [the TBT source] is essential to the case: it goes to the heart of whether the source was reliable. The case turns on whether your client committed "journalistic malpractice" by using an unreliable source.

Plaintiff’s counsel chose not to address this point in Discord or in their Motion for Sanctions. Any competent lawyer would recognise that this is crucial evidence for the reasons already given. This is no reflection on Plaintiff’s counsel: they implicitly agree the evidence is key. I intended to request this information before ever messaging Plaintiff’s counsel. Defendant’s discovery request was always going to happen. It was not a threat.

In this light, Plaintiff’s Motion should fail. All of the messages provided by Plaintiff’s counsel show that I was merely giving my opinion on the result of the litigation if Plaintiff chose not to settle. If the Court grants Plaintiff’s motion, then it must also agree that I was “threatening” Plaintiff by stating that non-settlement would result in Defendant collecting legal fees. That would be silly. It is well within ethical bounds to point out the inevitable result of continued litigation. It makes no difference whether it is a judgment awarding legal fees or a discovery request for crucial evidence which any prudent lawyer would make.

I have displayed high standards of ethics throughout this case. I have not imputed malice onto Plaintiff or onto Plaintiff’s counsel; as they have done to me (see this Motion for Sanctions). I have not called Plaintiff’s counsel’s arguments “simplistic and self-serving" as they have done to me (see post #9). I have not called one of Plaintiff’s requests “an improper attempt to relitigate a motion”; as they have done to me. Let me be clear: I respect professional ethics at least as much as Plaintiff’s counsel. But at the same time, I have a duty to advance my client’s interests to the exclusion of Plaintiff’s interests. I am not here to help Plaintiff. I will continue to advocate for my client.

I have not obstructed justice by threatening a witness or potential witness (under the CCA). Firstly, I have not “threatened to expose [the TBT] source.” None of my comments in the supplied DMs even imply that I intend to do anything with that information other than advance my client’s interests in this litigation. I have no desire to publish information about TBT's sources; that is not what my client hired me to do (nor is it ethical). Further, Plaintiff has an untenable position. Plaintiff says I am obstructing justice by stating that I intend to find out the name of a person. But if they are a witness (which they must be in order for my conduct to be obstruction of justice), then they will be called to the Court and publicly named anyway. My “threat” makes no sense in this context.

I also have not obstructed justice by abusing court processes. As I have already discussed, Defendant intends to make a reasonable and prudent discovery request. That is plainly not obstruction of justice. Defendant needs that evidence in order to make a proper defence.

Plaintiff’s citation to YeetGlazer v. Commonwealth of Redmont [2025] FCR 76 is without merit. Plaintiff chose not to point the Court (or Defendant’s counsel) to the particular post in support of their Motion. I have read the entire record in that case and the only relevant filing is my firm’s Motion for Sanctions against xEndeavour (post #151). The Federal Court granted that Motion on the basis of xEndeavour's ex parte communications with the judicial officer. I have not had any ex parte communications with Your Honor, nor does Plaintiff allege anything of the sort. Plaintiff’s cited case is not relevant to this Motion.

As to the request for a “protective order”, the Court is wholly without jurisdiction to grant such an order. Plaintiff does not refer to any legislation, court rule, or judicial precedent in support. A search on the forums shows this is the only case in Redmont’s history where the term “protective order” has been used. It would also be inappropriate for the Court to preemptively prohibit Defendant from making an interrogatory without considering the merits of that issue.

Plaintiff Motion for Sanctions should be denied for the reasons given above.
 
Defendant's interrogatories for Plaintiff
  1. Who was TBT's anonymous source in the Plura72 article?
  2. Why did Plaintiff believe the source was reliable?
  3. What steps did Plaintiff take to verify the tip (for example, by contacting Plura72) before publishing the Plura72 article?
  4. Especially with respect to anonymous sources, what standards of integrity does Plaintiff believe journalists should uphold?
  5. Fifth interrogatory reserved.
Defendant can not expect Plaintiff to answer #1 until the Court rules on Plaintiff's Motion for Sanctions.
 
Defendant's Response to Plaintiff's Motion for Sanctions

Your Honor,—

Let me tell you what is missing from Plaintiff’s motion: they have not discussed whether the name of their source is relevant evidence in this case. Indeed, Plaintiff does not dispute that the evidence is relevant. As I said to Plaintiff’s counsel:



Plaintiff’s counsel chose not to address this point in Discord or in their Motion for Sanctions. Any competent lawyer would recognise that this is crucial evidence for the reasons already given. This is no reflection on Plaintiff’s counsel: they implicitly agree the evidence is key. I intended to request this information before ever messaging Plaintiff’s counsel. Defendant’s discovery request was always going to happen. It was not a threat.

In this light, Plaintiff’s Motion should fail. All of the messages provided by Plaintiff’s counsel show that I was merely giving my opinion on the result of the litigation if Plaintiff chose not to settle. If the Court grants Plaintiff’s motion, then it must also agree that I was “threatening” Plaintiff by stating that non-settlement would result in Defendant collecting legal fees. That would be silly. It is well within ethical bounds to point out the inevitable result of continued litigation. It makes no difference whether it is a judgment awarding legal fees or a discovery request for crucial evidence which any prudent lawyer would make.

I have displayed high standards of ethics throughout this case. I have not imputed malice onto Plaintiff or onto Plaintiff’s counsel; as they have done to me (see this Motion for Sanctions). I have not called Plaintiff’s counsel’s arguments “simplistic and self-serving" as they have done to me (see post #9). I have not called one of Plaintiff’s requests “an improper attempt to relitigate a motion”; as they have done to me. Let me be clear: I respect professional ethics at least as much as Plaintiff’s counsel. But at the same time, I have a duty to advance my client’s interests to the exclusion of Plaintiff’s interests. I am not here to help Plaintiff. I will continue to advocate for my client.

I have not obstructed justice by threatening a witness or potential witness (under the CCA). Firstly, I have not “threatened to expose [the TBT] source.” None of my comments in the supplied DMs even imply that I intend to do anything with that information other than advance my client’s interests in this litigation. I have no desire to publish information about TBT's sources; that is not what my client hired me to do (nor is it ethical). Further, Plaintiff has an untenable position. Plaintiff says I am obstructing justice by stating that I intend to find out the name of a person. But if they are a witness (which they must be in order for my conduct to be obstruction of justice), then they will be called to the Court and publicly named anyway. My “threat” makes no sense in this context.

I also have not obstructed justice by abusing court processes. As I have already discussed, Defendant intends to make a reasonable and prudent discovery request. That is plainly not obstruction of justice. Defendant needs that evidence in order to make a proper defence.

Plaintiff’s citation to YeetGlazer v. Commonwealth of Redmont [2025] FCR 76 is without merit. Plaintiff chose not to point the Court (or Defendant’s counsel) to the particular post in support of their Motion. I have read the entire record in that case and the only relevant filing is my firm’s Motion for Sanctions against xEndeavour (post #151). The Federal Court granted that Motion on the basis of xEndeavour's ex parte communications with the judicial officer. I have not had any ex parte communications with Your Honor, nor does Plaintiff allege anything of the sort. Plaintiff’s cited case is not relevant to this Motion.

As to the request for a “protective order”, the Court is wholly without jurisdiction to grant such an order. Plaintiff does not refer to any legislation, court rule, or judicial precedent in support. A search on the forums shows this is the only case in Redmont’s history where the term “protective order” has been used. It would also be inappropriate for the Court to preemptively prohibit Defendant from making an interrogatory without considering the merits of that issue.

Plaintiff Motion for Sanctions should be denied for the reasons given above.
Your Honor,

The Plaintiff respectfully requests to file a brief reply to the "Defendant's Response to Plaintiff's Motion for Sanctions."

We recognize that replies to a response are not typically permitted. However, a reply is necessary in this extraordinary circumstance for two reasons:

New Substantive Arguments: The Defendant's response makes new and specific legal arguments that the Plaintiff has not yet had an opportunity to address. This includes their narrow interpretation of the YeetGlazer precedent and their novel claim that the Court lacks jurisdiction to issue a protective order.

Improper Discovery: The Defendant has simultaneously served discovery interrogatories that are directly linked with the misconduct alleged in the motion. It is critical that we be allowed to formally object and connect them to the pending sanctions request.
 

Motion


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

Your Honor, under Rule 4.7, Defendant moves to obtain the following information from Plaintiff:

1. The location (e.g., which Discord channel or DM) where the conversation in P-004 took place.

2. Any communications between shugthedug and Plaintiff relating to The Block Times since 10 October.

3. Any relationship (including, but not limited to, a business, professional, or political relationship) between shugthedug and Plaintiff.

 
Defendant's interrogatories for Plaintiff
  1. Who was TBT's anonymous source in the Plura72 article?
  2. Why did Plaintiff believe the source was reliable?
  3. What steps did Plaintiff take to verify the tip (for example, by contacting Plura72) before publishing the Plura72 article?
  4. Especially with respect to anonymous sources, what standards of integrity does Plaintiff believe journalists should uphold?
  5. Fifth interrogatory reserved.
Defendant can not expect Plaintiff to answer #1 until the Court rules on Plaintiff's Motion for Sanctions.

Objection


IN THE DISTRICT COURT OF THE COMMONWEALTH OF REDMONT
OBJECTION - RELEVANCE;PRIVILEGE;ASSUMES FACT NOT IN EVIDENCE;ARGUMENTATIVE;CALLS FOR A CONCLUSION

Your Honor,

The Plaintiff files this objection to the interrogatories served by the Defendant. The questions are improper as they seek information that is privileged, irrelevant, and argumentative.

The Plaintiff addresses each interrogatory below. Interrogatory #1 has been omitted as it is the subject of the Plaintiff's pending Motion for Sanctions.

Regarding Defendant's Interrogatory #2: "Why did Plaintiff believe the source was reliable?"

Objection: Privilege; Relevance.

Argument:

  • Privilege: This question is a backdoor attempt to identify the anonymous source. Any substantive answer regarding the source's reliability would inevitably require the disclosure of privileged information that could lead to their identification (e.g., "the source held a position of trust," "the source has provided accurate information in the past"). This is a violation of the Freedom of the Press (Constitution §32(10)), which protects a journalist's relationship with their confidential sources.
  • Relevance: The core issue of this case is not the Plaintiff's belief, but the Defendant's malicious conduct. The question is irrelevant.
Regarding Defendant's Interrogatory #3: "What steps did Plaintiff take to verify the tip (for example, by contacting Plura72) before publishing the Plura72 article?"

Objection: Relevance; Assumes facts not in evidence.

Argument:

  • Relevance: This question is irrelevant to the facts of the case. The Plaintiff's article was explicitly published as a report on an unverified anonymous tip, not as a statement of verified fact. The steps one would take to verify a fact are therefore not relevant to an article that makes no claim of verification.
  • Assumes facts not in evidence: The question improperly assumes that the journalistic standard for a verified news story applies to an article that was clearly and intentionally labeled as a report on a tip. The Defendant is attempting to create and apply a standard where none exists to fit their false narrative of "malpractice."
Regarding Defendant's Interrogatory #4: "Especially with respect to anonymous sources, what standards of integrity does Plaintiff believe journalists should uphold?"

Objection: Argumentative; Calls for a conclusion; Relevance.

Argument:
This question is improper and does not seek factual information.
  • It is Argumentative and Calls for a conclusion as it asks the Plaintiff to provide a personal opinion or a professional treatise on journalistic ethics, which is not the purpose of discovery.
  • It is not Relevant, as the Plaintiff's personal beliefs are not facts at issue in this case. The case centers on whether the Defendant's specific, published statements were false and made with malice.

The Defendant's interrogatories are an improper attempt to shift the focus from their own malicious conduct to the Plaintiff's journalistic process. For the reasons stated above, the Plaintiff respectfully requests that the Court sustain these objections and rule that the Plaintiff is not required to answer these interrogatories.

 

Motion


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

Your Honor, under Rule 4.7, Defendant moves to obtain the following information from Plaintiff:

1. The location (e.g., which Discord channel or DM) where the conversation in P-004 took place.

2. Any communications between shugthedug and Plaintiff relating to The Block Times since 10 October.

3. Any relationship (including, but not limited to, a business, professional, or political relationship) between shugthedug and Plaintiff.

[/motion]

Objection


IN THE DISTRICT COURT OF THE COMMONWEALTH OF REDMONT
OBJECTION - BREACH OF PROCEDURE;PRIVILEGE; RELEVANCE

Your Honor,

The Plaintiff files this objection to the Defendant's Motion to Compel.

OBJECTION TO THE MOTION IN ITS ENTIRETY

Objection: Breach of Procedure.

Argument:
The Defendant's motion constitutes a breach of standard court procedure. The proper and good-faith process of discovery is to first serve interrogatories upon the opposing party, allow them time to respond or object, and only then file a motion to compel if the response is deemed insufficient. By combining their initial request with an immediate motion to compel, the Defendant has improperly circumvented this process and pre-empted the Plaintiff's right to respond in the normal course. This is an overly aggressive and procedurally flawed tactic.

OBJECTIONS TO SPECIFIC INTERROGATORIES CONTAINED WITHIN THE MOTION

Without waiving the foregoing objection to the motion in its entirety, the Plaintiff further objects to the substance of the specific interrogatories as follows:

Regarding Defendant's Request for "any communications between shugthedug and Plaintiff..."

Objection: Relevance; Privilege.

Argument:

  • Relevance: The request is not relevant to the case. It is an overly broad "fishing expedition" into private communications of a third-party witness that have no bearing on the core issue: whether the Defendant's article was libelous.
  • Privilege: This request infringes upon the Freedom of the Press (Constitution §32(10)). Compelling a journalist to turn over all communications with a witness would have a chilling effect on the press's ability to function and would violate the witness's right to Security of the Person (Constitution §32(14)) by inviting potential harassment.
Regarding Defendant's Request for "any relationship between shugthedug and Plaintiff..."

Objection: Relevance.

Argument:
The existence of a prior relationship is not relevant. The fact at issue, established by Exhibit P-005, is that the witness's opinion was damaged as a direct result of the Defendant's article. This request is an improper attempt to attack the witness personally rather than confront the evidence. It also infringes on the Plaintiff's Freedom of Association (Constitution §32(12)).

The Plaintiff respectfully requests that the Court sustain the objection for Breach of Procedure and deny the Defendant's Motion to Compel in its entirety.

In the alternative, the Plaintiff requests that the Court sustain the objections of Relevance and Privilege and deny the specific, improper interrogatories contained within the motion.


 

Objection



IN THE DISTRICT COURT OF THE COMMONWEALTH OF REDMONT
OBJECTION — BREACH OF PROCEDURE

Your Honor,

The Plaintiff files this objection against all interrogatories served by the Defendant on the grounds that they are in direct violation of the Court's established rules of discovery.

Court Rule 4.8 (Interrogatories) explicitly limits each party to a maximum of five questions. The rule states:

"The Plaintiff and Defendant may ask up to 5 relevant questions while within discovery to each other..."
The Defendant in this case has served a total of eight (8) interrogatories upon the Plaintiff across two separate filings (a "Motion to Compel" containing three interrogatories, and a separate "Interrogatories for Plaintiff" filing containing five).

This is a clear and undeniable breach of procedure. The Defendant's requests are improper in their entirety as they exceed the number permitted by the Court's own rules.

For this reason, the Plaintiff respectfully requests that the Court sustain this objection and strike all eight of the Defendant's interrogatories.

 

Objection


IN THE DISTRICT COURT OF THE COMMONWEALTH OF REDMONT
OBJECTION - RELEVANCE;PRIVILEGE;ASSUMES FACT NOT IN EVIDENCE;ARGUMENTATIVE;CALLS FOR A CONCLUSION

Your Honor,

The Plaintiff files this objection to the interrogatories served by the Defendant. The questions are improper as they seek information that is privileged, irrelevant, and argumentative.

The Plaintiff addresses each interrogatory below. Interrogatory #1 has been omitted as it is the subject of the Plaintiff's pending Motion for Sanctions.

Regarding Defendant's Interrogatory #2: "Why did Plaintiff believe the source was reliable?"

Objection: Privilege; Relevance.

Argument:

  • Privilege: This question is a backdoor attempt to identify the anonymous source. Any substantive answer regarding the source's reliability would inevitably require the disclosure of privileged information that could lead to their identification (e.g., "the source held a position of trust," "the source has provided accurate information in the past"). This is a violation of the Freedom of the Press (Constitution §32(10)), which protects a journalist's relationship with their confidential sources.
  • Relevance: The core issue of this case is not the Plaintiff's belief, but the Defendant's malicious conduct. The question is irrelevant.
Regarding Defendant's Interrogatory #3: "What steps did Plaintiff take to verify the tip (for example, by contacting Plura72) before publishing the Plura72 article?"

Objection: Relevance; Assumes facts not in evidence.

Argument:

  • Relevance: This question is irrelevant to the facts of the case. The Plaintiff's article was explicitly published as a report on an unverified anonymous tip, not as a statement of verified fact. The steps one would take to verify a fact are therefore not relevant to an article that makes no claim of verification.
  • Assumes facts not in evidence: The question improperly assumes that the journalistic standard for a verified news story applies to an article that was clearly and intentionally labeled as a report on a tip. The Defendant is attempting to create and apply a standard where none exists to fit their false narrative of "malpractice."
Regarding Defendant's Interrogatory #4: "Especially with respect to anonymous sources, what standards of integrity does Plaintiff believe journalists should uphold?"

Objection: Argumentative; Calls for a conclusion; Relevance.

Argument:
This question is improper and does not seek factual information.
  • It is Argumentative and Calls for a conclusion as it asks the Plaintiff to provide a personal opinion or a professional treatise on journalistic ethics, which is not the purpose of discovery.
  • It is not Relevant, as the Plaintiff's personal beliefs are not facts at issue in this case. The case centers on whether the Defendant's specific, published statements were false and made with malice.

The Defendant's interrogatories are an improper attempt to shift the focus from their own malicious conduct to the Plaintiff's journalistic process. For the reasons stated above, the Plaintiff respectfully requests that the Court sustain these objections and rule that the Plaintiff is not required to answer these interrogatories.

Objection


IN THE DISTRICT COURT OF THE COMMONWEALTH OF REDMONT
OBJECTION - BREACH OF PROCEDURE;PRIVILEGE; RELEVANCE

Your Honor,

The Plaintiff files this objection to the Defendant's Motion to Compel.

OBJECTION TO THE MOTION IN ITS ENTIRETY

Objection: Breach of Procedure.

Argument:
The Defendant's motion constitutes a breach of standard court procedure. The proper and good-faith process of discovery is to first serve interrogatories upon the opposing party, allow them time to respond or object, and only then file a motion to compel if the response is deemed insufficient. By combining their initial request with an immediate motion to compel, the Defendant has improperly circumvented this process and pre-empted the Plaintiff's right to respond in the normal course. This is an overly aggressive and procedurally flawed tactic.

OBJECTIONS TO SPECIFIC INTERROGATORIES CONTAINED WITHIN THE MOTION

Without waiving the foregoing objection to the motion in its entirety, the Plaintiff further objects to the substance of the specific interrogatories as follows:

Regarding Defendant's Request for "any communications between shugthedug and Plaintiff..."

Objection: Relevance; Privilege.

Argument:

  • Relevance: The request is not relevant to the case. It is an overly broad "fishing expedition" into private communications of a third-party witness that have no bearing on the core issue: whether the Defendant's article was libelous.
  • Privilege: This request infringes upon the Freedom of the Press (Constitution §32(10)). Compelling a journalist to turn over all communications with a witness would have a chilling effect on the press's ability to function and would violate the witness's right to Security of the Person (Constitution §32(14)) by inviting potential harassment.
Regarding Defendant's Request for "any relationship between shugthedug and Plaintiff..."

Objection: Relevance.

Argument:
The existence of a prior relationship is not relevant. The fact at issue, established by Exhibit P-005, is that the witness's opinion was damaged as a direct result of the Defendant's article. This request is an improper attempt to attack the witness personally rather than confront the evidence. It also infringes on the Plaintiff's Freedom of Association (Constitution §32(12)).

The Plaintiff respectfully requests that the Court sustain the objection for Breach of Procedure and deny the Defendant's Motion to Compel in its entirety.

In the alternative, the Plaintiff requests that the Court sustain the objections of Relevance and Privilege and deny the specific, improper interrogatories contained within the motion.



Your Honor, permission to respond to both of Plaintiff's objections? I'm happy to wait a bit so you can catch up.

EDIT: Plaintiff filed a third objection while I was writing this: I seek permission to respond to #26 too.
 
Your Honor, permission to respond to both of Plaintiff's objections? I'm happy to wait a bit so you can catch up.

EDIT: Plaintiff filed a third objection while I was writing this: I seek permission to respond to #26 too.
You may, for future context you dont need permission to respond to objections, only to motions.
 
Defendant's Consolidated Response to Plaintiff's Discovery Objections
Your Honor, Defendant opposes all of Plaintiff's discovery objections.

"Why did Plaintiff believe the source was reliable?"
This is a violation of the Freedom of the Press (Constitution §32(10)), which protects a journalist's relationship with their confidential sources.
Plaintiff has not cited legislation or judicial precedent in support. To the best of my knowledge, no Redmont court has ever found such a protection.

We submit that there is no protection of a journalist's sources. Redmont law simply does not recognize it. Your Honor, even if there is a protection, we would submit this is not a proper case to apply it. Defendant did not seek this litigation. It is not fair for Plaintiff to bring a case and then hide behind confidentiality. A protection for journalists is much better applied to journalist-defendants, not journalist-plaintiffs (as in this case).

It may also be useful for the Court to seek further submissions from both Plaintiff and Defendant to further develop this issue, if the Court considers that appropriate.

The core issue of this case is not the Plaintiff's belief, but the Defendant's malicious conduct. The question is irrelevant.
The core issue of this case is not Plaintiff's beliefs or Defendant's "malicious conduct". The core issue is whether Defendant's statements were true—the heart of defamation. This question is clearly relevant because if Plaintiff's source was not reliable, then Defendant can make out that Plaintiff did not adhere to journalistic standards. And thus, Defendant's statement would be true, which would be a defence to the Complaint. That is how the question is relevant.

"What steps did Plaintiff take to verify the tip (for example, by contacting Plura72) before publishing the Plura72 article?"

Both of Plaintiff's objections amount to the same issue: the interrogatory is irrelevant because the Plura72 article was not presented as fact. With respect, Plaintiff is making an argument on the facts that should be reserved for trial. Defendant disputes that the article was merely presented as reporting on a tip: and we must be allowed to make our arguments. We need discovery in order to make our case; Plaintiff's objection is premature. Even then, the interrogatory is still relevant: the accuracy of the anonymous tip is crucial to this case, regardless of whether the Plura72 article is fact or based only on the tip.

"Especially with respect to anonymous sources, what standards of integrity does Plaintiff believe journalists should uphold?"
The case centers on whether the Defendant's specific, published statements were false and made with malice.
Indeed Plaintiff now correctly identifies that the case is about whether Defendant's statements were true. The statements in issue are allegations that Plaintiff committed "journalistic malpractice". Surely we must identify what "journalistic malpractice" means in order to determine whether Defendant's statements were true. That is what the interrogatory addresses.

The Motion to Compel
The proper and good-faith process of discovery is to first serve interrogatories upon the opposing party, allow them time to respond or object, and only then file a motion to compel if the response is deemed insufficient.
Defendant's Motion to Compel is totally separate from the issues raised in the interrogatories. It doesn't matter whether the response to interrogatories is "insufficient": the Motion to Compel is separate. I am not aware of any practice whereby a party cannot file a Motion to Compel before they receive a response to their interrogatories (I might be wrong?). Rule 4.7 makes clear that a Motion to Compel can be filed at any time during discovery.

"any communications between shugthedug and Plaintiff..."
The request is not relevant to the case. It is an overly broad "fishing expedition" into private communications of a third-party witness that have no bearing on the core issue: whether the Defendant's article was libelous.
Shugthedug is not a "third-party witness." They are a witness for Plaintiff. Their evidence was submitted in the Complaint.

Defendant wants to know whether shugthedug may have been influenced to make his comments. Defendant is at least entitled to the full conversation. If shugthedug truly is a random member of the public, then Plaintiff should have an easy time responding—there will be no conversations to produce.

Plaintiff is correct that shugthedug's evidence has "no bearing on the core issue". Instead, it goes to damages and whether Plaintiff was harmed by Defendant's article. That is absolutely a valid area for a discovery request.

This request infringes upon the Freedom of the Press (Constitution §32(10)). Compelling a journalist to turn over all communications with a witness would have a chilling effect on the press's ability to function and would violate the witness's right to Security of the Person (Constitution §32(14)) by inviting potential harassment.
Shugthedug is not a source for The Block Times. There is no journalist privilege (if that even exists). Plaintiff contacted shugthedug not as a journalist, but as a potential litigant seeking evidence of damages.

Again, shugthedug was not a source for The Block Times. There is no "chilling effect" by requiring Plaintiff to produce conversations with them. The issue of security of the person and harassment are a legal nonsense; under Plaintiff's argument, every witness in every case could escape justice by citing "potential harassment".

The existence of a prior relationship is not relevant.
It goes to credibility of the witness in proving damages. If the witness has a prior relationship, then the Court may doubt their reliability as they may have a bias in favour of Plaintiff (or against).

This request is an improper attempt to attack the witness personally rather than confront the evidence.
Defendant cannot "confront the evidence" if it is excluded by Plaintiff's Objection. We absolutely want to confront the evidence.

It also infringes on the Plaintiff's Freedom of Association (Constitution §32(12)).
It does not. This is a standard and prudent discovery request. Plaintiff cites nothing in support, nor do they explain their argument further. A reasonable discovery request has no bearing on Plaintiff's freedom to associate with shugthedug.

The Breach of Procedure Objection
The Defendant in this case has served a total of eight (8) interrogatories upon the Plaintiff across two separate filings (a "Motion to Compel" containing three interrogatories, and a separate "Interrogatories for Plaintiff" filing containing five).
A Motion to Compel is not an interrogatory. It does not count towards the 5-interrogatory limit. Plaintiff should refer to judicial precedent in support.

Your Honor, for the reasons given, the Court should overrule all of Plaintiff's objections.
 
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