Lawsuit: Pending Commonwealth of Redmont v. Town of Oakridge [2026] FCR 13

[Novakerbal]

Case Filing

IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
CIVIL ACTION


Commonwealth of Redmont
Plaintiff

v.

Town of Oakridge
Defendant

COMPLAINT
The Plaintiff complains against the Defendant as follows:

WRITTEN STATEMENT FROM THE PLAINTIFF

On November 17th, 2025, Talion77, in their capacity as Oakridge Head of Residence, opened a ticket with the DCT in order to action the eviction of the plot or-brewery. During this ticket, Yeet_Boy, acting in their capacity as the Mayor of Oakridge, discouraged the creation of the ticket, and claimed that they had other means of actioning the eviction. On November 19th, 2025 player Bardiya_King was the owner of or-brewery, whereas on November 22nd, 2025 or-brewery was owned by Yeet_Boy. The DCT was not responsible for this eviction. The Commonwealth actioned a warrant on the transfer history, and staff ticket history, and discovered that Yeet_Boy directly petitioned staff using their position to transfer ownership of the property to them, bypassing the lawful DCT eviction process. This action violated both the Constitution of Oakridge as well as Executive Order 21/25 - Towns' Rights, as the Mayor of Oakridge bypassed the Department of Construction and Transportation in lobbying staff to process the illegitimate eviction.

I. PARTIES
1. Town of Oakridge (Defendant)
2. Commonwealth of Redmont (Plaintiff)
3. Yeet_Boy (Mayor)


II. FACTS
1. On November 17th, 2025, Talion77(in their capacity as Oakridge Head of Residence) created a DCT ticket to request the eviction of or-brewery (P-001).
2. During the aforementioned ticket, Yeet_Boy (in their capacity as Mayor) discouraged the creation of similar tickets, and claimed to have their own methods of transferring plots that bypassed the DCT (P-002)(P-003).
3. Search warrants actioned by the Commonwealth revealed that staff had transferred the plot from the previous owner(Bardiya_King) to Yeet_Boy upon the request of the latter. (P-004), (P-005), (P-006), (P-007), (P-008).
4. ElysiaCrynn asked Yeet_Boy to verify the legality of the transfer they were requesting, which Yeet_Boy subsequently claimed to be legitimate (P-008).
5. At the time of the actions undertaken by Yeet_Boy, Oakridge derived all jurisdiction from Executive Order 21/25 - Towns' Rights.
6. §4 of Executive Order 21/25 - Towns' Rights states: "Evictions and transfers of property within Town limits (Facilitated by Town government, actioned by the DCT);".
7. The Preamble of the Oakridge Town Constitution lists eviction jurisdiction in the Town as "Department of Construction and Transportation to action evictions".
8. Article II, § (e)(4) of the Oakridge Town Constitution states that the Office of Residence is responsible for "Management of evicted plot auctions within Oakridge".


III. CLAIMS FOR RELIEF
1. Yeet_Boy, acting in their official capacity as Mayor of Oakridge violated both the Oakridge Town Constitution and Executive Order 21/25 - Towns' Rights, by directly petitioning staff to transfer the plot to him, rather than utilizing lawful and established DCT mechanisms. Firstly, the conduct unequivocally violated Executive Order 21/25 as it clearly states that the DCT is responsible for actioning the eviction of town plots, and no other entities. The Oakridge Town Constitution corroborates this as it also establishes the DCT as having jurisdiction over actioning evictions. It is abundantly clear that the alleged actions were a violation of the law. The Mayor of Oakridge took an action that violates both federal Executive Order and local Statute, the illegality of such an action is clear.

• 1.A- Executive Order 21/25 - Towns' Rights has since been repealed, however the amendment of the Constitution under The Town Rights Expansion Act maintains the jurisdiction of actioning evictions solely under the Federal Government, and the DCT. Part V 32(3) of the Constitution grants towns explicit jurisdiction over "land use, zoning, building standards, and property administration;". This clause is equivalent with a prior clause present in Executive Order 21/25 - Towns' Rights which states: "Land use, zoning, plot pricing, building regulations, and building standards;". Notably however, Executive Order 21/25 - Towns' Rights explicitly carved out the handling of evictions under a separate section, specifically clarifying that evictions will be facilitated by the Town government and actioned by the DCT. As no such Constitutional clause exists that explicitly delegates the facilitation or actioning of any evictions to any Town jurisdiction, it remains within the jurisdiction of the DCT. Therefore a permanent injunction is necessary to prevent any future violations of the DCT's jurisdiction over actioning evictions, as they are the sole entity granted such jurisdiction.

2. The DCT suffered injury when its authority was illegally undermined by a local Government official. Additionally, the Executive as a whole suffered injury by having a lawful Executive Order undermined in its authority. The Supreme Court in [2025] FCR 117 - Appeal maintained that “It is indeed true that individuals do not need to prove they have been specifically harmed in some discrete, tangible manner—but they still must prove some injury occurred. It should be noted that the bar for this is extremely low.”. The Commonwealth has the constitutional right and duty to enforce the law as written by the legislature. When its authority is undermined, this is not just a matter of preference or procedure – it is an abridgement of the legal rights of the federal government. By undermining both the authority of the DCT and the execution of a lawfully binding Executive Order, the alleged actions inflicted clear injury to the Commonwealth.

IV. PRAYER FOR RELIEF
The Plaintiff seeks the following from the Defendant:
1. Issue a declaratory judgement that the actions undertaken by the Mayor of Oakridge, Yeet_Boy, were illegal.
2. Issue a permanent injunction preventing all current and future Mayors of Oakridge and other members of the Oakridge Town Council from actioning the eviction of plots within their jurisdiction through methods inconsistent with the Constitution of Redmont or the Oakridge town Constitution.

Evidence List:

Spoiler: P-001

Spoiler: P-002

Spoiler: P-003

Spoiler: P-004

See attached PDF P-004 (2)

Spoiler: P-005

See attached PDF P-005

Spoiler: P-006

Spoiler: P-007

Spoiler: P-008

Spoiler: P-009

Spoiler: P-010

Witness List:
1. Talion77 (Former Oakridge Head of Residence)
2. Staff

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 1st day of March, 2026

 

[ko531]

Writ of Summons

@YeetBoy1872325, is required to appear before the Federal Court in the case of Commonwealth of Redmont. v Town of Oakridge [2026] FCR 13

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.

 

[Franciscus]

Writ of Summons

@YeetBoy1872325, is required to appear before the Federal Court in the case of Commonwealth of Redmont. v Town of Oakridge [2026] FCR 13

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.

Your Honor,

I am present on behalf of the Town of Oakridge.

Spoiler: Evidence of consent to represent

 

[ko531]

Your Honor,

I am present on behalf of the Town of Oakridge.

Spoiler: Evidence of consent to represent

View attachment 76244

You have 48 hours to provide an answer to complaint.

 

[Franciscus]

You have 48 hours to provide an answer to complaint.

Your Honor,

The Defense requests a 36-hour extension.

 

[ko531]

Your Honor,

The Defense requests a 36-hour extension.

Granted

 

[Franciscus]

Answer to Complaint

IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT​

ANSWER TO COMPLAINT​

Commonwealth of Redmont,
Plaintiff

v.

Town of Oakridge,
Defendant
​

---

I. Answer to Complaint​

1. NEITHER AFFIRMS NOR DENIES that "On November 17th, 2025, Talion77 (in their capacity as Oakridge Head of Residence) created a DCT ticket to request the eviction of or-brewery", and DENIES that P-001 establishes that any such ticket was made "to request the eviction of or-brewery".
2. NEITHER AFFIRMS NOR DENIES that "During the aforementioned ticket, Yeet_Boy (in their capacity as Mayor) discouraged the creation of similar tickets", and DENIES that Yeet Boy expressly "claimed to have their own methods of transferring plots that bypassed the DCT" in Exhibit P-002 or Exhibit P-003.
3. AFFIRMS that search warrants actioned by the Commonwealth revealed that staff had transferred to Yeet_Boy, but DENIES that Exhibits P-004, P-005, P-006, P-007, and P-008 establish the prior owner as Bardiya King.
4. DENIES that private Redmont Citizen ElysiaCrynn took such action, NOTING that Staff Action must be attributed to the Staff Team rather than any individual player (see: Rule 1, Respect, "Politicizing staff actions, for the sake of roleplay or otherwise, is strictly prohibited. There must be an undeniable separation between staffing and state and this is heavily policed"; Commonwealth of Redmont v. AsexualDinosaur [2025] FCR 127, ruling that individual staff members may not be made to testify about their staff activities).
5. DENIES as a legal conclusion that, at the time of the actions undertaken by Yeet_Boy, Oakridge derived all jurisdiction from Executive Order 21/25 - Towns' Rights.
6. DENIES that §4 of Executive Order 21/25 - Towns' Rights states: "Evictions and transfers of property within Town limits (Facilitated by Town government, actioned by the DCT)".
7. AFFIRMS that the Oakridge Town Constitution's preamble contains the phrase "the Department of Construction and Transportation to action evictions". DENIES as a legal conclusion that this constitutes the exclusive and entire jurisdiction surrounding eviction in Oakridge. DENIES that the Oakridge Town Constitution thereby creates a federal civil cause of action enforceable by the Commonwealth against the Town.
8. DENIES that "Article II, § (e)(4) of the Oakridge Town Constitution states that the Office of Residence is responsible for 'Management of evicted plot auctions within Oakridge'." Inasmuch as this refers to Article II, § 1(e)(4), AFFIRMS that the clause contains the phrase "Management of evicted plot auctions within Oakridge".
9. General Denial. Except as hereinbefore expressly affirmed or expressly neither affirmed nor denied, each and every other factual allegation and claim for relief is DENIED as if set out herein.

---

II. Defenses​

II.I Lack of Claim​

No cognizable cause of action has been pleaded. The Complaint identifies no Act of Congress and no constitutional clause creating a DOJ-enforceable civil cause of action against the Town for alleged violation of Executive Order 21/25 - Towns' Rights or the Oakridge Town Constitution. Congress holds legislative power and is responsible for creating, amending, and removing laws (Const. 1-2). The Executive administers and enforces law and may issue Executive Orders only as a mechanism for powers already granted by the Constitution (Const. 23-24, 45). The Complaint therefore collapses executive policy, local constitutional structure, and civil liability into a single theory that Redmont law does not recognize.

What's more, the Complaint cites no enacted federal law prohibiting a Mayor from petitioning Staff about property administration. The Constitution itself recognizes Staff and the Server Manager as the bridge between Staff and Government (Const. 37). A disagreement over the route allegedly taken is not the same thing as a violation of law.

II.II Under EO 21/25, local government legislation controlled over departmental policy​

The Federal Court in BoopingBerry v. Town of Oakridge [2024] FCR 88 examined the relationship between federal policy and town statutes as it pertained to evictions. In the verdict, the Court established that "Executive Order 5/24 gave towns rights over town building regulations and that department policy doesn’t take precedence over town legislation (i.e., Oakridge Property Standards Act). Therefore, the applicable law is the Oakridge Property Standards Act" ([2024] FCR 88, Verdict, Section III(4)). The Court, as such, held that towns held control over building regulations and contrary department policy was superceded by local authority. That historical usage shows these orders allocated administrative roles and legal hierarchy between town legislation and department policy. It does not convert an executive order into an Act of Congress or a self-executing civil-liability rule. Plaintiff’s theory would allow the Executive to create civil liability by decree, contrary to the separation of powers embedded in Const. 1-2, 23-24, and 45.

As such, Executive Orders are not freestanding lawmaking instruments, and the legal history of the town-rights orders confirm the point. In the succession from Executive Order 5/24 to Executive Order 15/24 to Executive Order 21/25, the language regarding evictions did not change substantially: towns facilitated building regulations and plot-eviction administration within town limits, while the DCT merely served to action the result; the DCT did not, in any way, have precedence over town legislation.

II.III The Department of Justice lacks lawful authority to file this case​

The Oakridge Town Constitution is not a federal civil code. Const. 32(2) requires each Town to have a constitution establishing its local government. That charter allocates local offices and local procedures. It is not a federal civil enforcement statute. Plaintiff points to no Act of Congress, constitutional clause, or controlling precedent authorizing the Department of Justice to sue a Town merely because a local official allegedly acted inconsistently with that local charter.

II.IV Lack of Standing​

The Complaint is defective under Court Rule 2.1 and would support dismissal under Court Rules 5.5 and 5.12. Rule 2.1 requires the Plaintiff to show an injury, that the cause of injury was against the law, and that a remedy is applicable under relevant law. Here, Plaintiff identifies no enacted law making the alleged conduct actionable in this suit and no relevant law authorizing the sweeping declaratory and injunctive relief requested. There is also no cognizable injury. These defects go to the heart of the case.

II.V Plaintiff's constitutional reading is unpersuasive​

Plaintiff’s current-law theory is, at minimum, insufficient for prospective relief. The Complaint argues that current law leaves actioning evictions solely with the Federal Government and the DCT because Const. 32(3) gives towns “property administration” but does not expressly mention eviction actioning. That inference is unsupported. Const. 32 makes towns autonomous local governments and grants them jurisdiction over property administration (Const. 32(1), 32(3)). At minimum, Plaintiff has not identified any enacted law expressly vesting exclusive civilly-enforceable eviction authority in the DCT or authorizing the injunction sought here.

II.VI Requested relief is overbroad, and seeks to legislate by judge​

The requested injunction is overbroad. Plaintiff asks this Court to regulate "all current and future Mayors of Oakridge and other members of the Oakridge Town Council". That is relief aimed at future hypothetical conduct and untethered to any pleaded statutory remedial scheme. In Commonwealth v. Yeet_Boy [2026] FCR 11, the Court dismissed the prior action after recognizing that the Commonwealth was attempting to "set a strong future precedent" that would interfere with the business of a party not properly before the Court, and it expressly stated that no part of that order would be dispositive of the merits or of the Town’s defenses ([2026] FCR 11, Order of Dismissal, Post No. 18). The same caution applies here: the Commonwealth may not legislate by lawsuit what Congress never enacted by statute.

II.VII The Federal Court may not create a novel civil cause of action​

The Court should not create a new civil cause of action by judicial invention. In INTERLOCUTORY MasterCaelen v. Hon. Magistrate Dr_Eksplosive [2026] FCR 14, the Federal Court rejected a quasi-category that had no basis in statute or precedent. The same rule of restraint applies here, both in principle and under the Redmont Civil Code Act. The Commonwealth asks the Court to convert an executive-management directive into a judicially enforceable civil offense. The Court should refuse.

---

III. Attestation​

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 8th day of March, 2026

 

[ko531]

We will now be moving to discovery. Discovery will last until March 14th at 12:00am CST or until both sides agree to end discovery early.

 

[Franciscus]

Motion

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

Your Honor,

The Defense respectfully moves to dismiss the Complaint under Rule 5.5 (Lack of Claim), Rule 5.12 (Lack of Personal Jurisdiction), and Rule 5.7 (Failure to Include Party). In support of this motion, we respectfully allege as follows:

I. The Complaint fails to state a claim for relief​

Under Rule 5.5 (Lack of Claim), a case may be dismissed when the Plaintiff commits a "failure to state a claim for relief, or against an claim for relief that has insufficient evidence to support the civil or criminal charge".

For several grounds, many of which are independent, Defense alleges that Plaintiff has failed to state a cognizable claim.

I.I Executive Orders are not legislation​

Congress holds federal legislative power and is responsible for creating, removing, and amending laws (Const. 1-2). An Executive Order, by contrast, is only "a lawful directive" and a "mechanism" by which the President exerts "powers expressly granted to the Executive in the Constitution" (Const. 43, emphasis mine). The Supreme Court has likewise stressed that "Departmental policies, while important for internal operations and employment processes within their respective departments, do not carry the force of law unless established by legislation" (zLost v. The Commonwealth of Redmont [2025] SCR 10).

Put plainly: an Executive Order is not, standing alone, a freestanding civil-liability statute; it is not a statute at all, and cannot be considered a form of legislation. The Commonwealth cannot manufacture a novel civil cause of action from executive administration alone.

I.II The Complaint erroneously pleads a legal theory ex post facto based on text in EO 46/25​

The Complaint also misquotes the very order on which it relies. It erroneously says EO 21/25 provides: "Evictions and transfers of property within Town limits (Facilitated by Town government, actioned by the DCT)" (Compl., Factual Allegation No. 6). The actual text of EO 21/25 says: "Plot evictions within Town jurisdiction. (Facilitated by Town government, actioned by the DCT)." The "transfers of property" language appears later in Section 5.2 of EO 46/25, which post-dates the alleged November 2025 conduct (when EO 21/25 was active). The Plaintiff has therefore pleaded a legal theory against language that is not in the order it cites, and whose application to the facts of this case would be ex post facto.

I.III Judicial Precedent and Administrative History cuts against the Commonwealth​

The town-rights line of authority cuts against, not for, the Commonwealth. All of EO 5/24, EO 15/24, and EO 21/25 described Town by-laws as delegated local jurisdiction, gave Town government responsibility over Town constitutions and building regulations, and provided that federal code outside an Act of Congress, an Executive Order, or the Constitution—such as department policy—does not take precedence over Town legislation (See Sections 4 of EO 5/24, EO 15/24, and EO 21/25). In BoopingBerry v. Town of Oakridge [2024] FCR 88, the Court used that framework to hold that the applicable law for evictions was Town legislation, not department policy. That does not turn these executive orders into civil tort statutes, nor any sort of item permitting a civil suit.

I.IV The Oakridge Town Constitution does not provide a federal civil cause of action to the DOJ​

Following the passage of the Town Rights Expansion Act, the Federal Constitution recognizes that Towns are autonomous local governments, each with its own constitution and legislative authority over local matters including property administration, town governance, and internal matters (Const., Section 32(2)-(3)). Oakridge’s Constitution itself reflects a local enforcement structure: the Office of Residence manages evicted plot auctions, the Oakridge Police Department enforces Town law, and the Mayor represents the Town in court or appoints a delegate to do so. (Oak. Const., Article II, Sections 1(e)(4) and 1(g); id., Article III, Section I.)

A town constitution allocates local offices, local duties, and local procedures. It is not transformed into a federal civil code merely because the Department of Justice prefers one reading of it. The Complaint does not identify any Act of Congress, constitutional provision, or controlling precedent that authorises the Commonwealth to sue a Town simply because the Commonwealth says a local official acted inconsistently with that local charter.

I.V It is not legally cognizable to seek a permanent injunction on the basis that (1) a since-repealed EO was allegedly violated and (2) that the constitution was changed thereafter​

The Commonwealth asks for a permanent injunction on the theory that current constitutional law leaves actioning evictions solely to the Federal Government and the DCT because the Town Rights Expansion Act gives towns jurisdiction over "property administration" without expressly mentioning evictions (Compl., Claim for Relief 1(a); id. Prayer For Relief 2). But the current Constitution recognizes towns as autonomous local governments and gives them jurisdiction over "land use, zoning, building standards, and property administration" (Const. 32(3)). The Commonwealth's proposed injunction therefore rests not on clear enacted text, but on an inference layered atop a repealed Executive Order. That is not a sound basis for sweeping permanent relief.

I.VI No uncodified tort at common law is plausibly alleged​

Even if the Court were to read the Complaint generously as attempting to invoke uncodified common-law harm, it still fails. The Redmont Civil Code Act makes clear that uncodified harms remain actionable only where common-law principles or judicial precedent support the claim and where such uncodified harm does not address the same subject matter as a common law tort (RCCA, Part II, Section 3(1)(a)-(c)). The Complaint identifies no qualifying Common Law Tort. And the Commonwealth cannot rely on other acts as a basis for a tort claim; "Any civil violation purportedly created by another Act of Congress shall be null and void unless incorporated as an amendment" to the RCCA (RCCA, Part II, Section 3(2)).

I.VII Conclusion: Plaintiff has failed to state a claim​

The Commonwealth cites no Act of Congress, no constitutional provision, and no established common-law cause of action that authorizes the Department of Justice to sue a Town for an alleged violation of Executive Order 21/25 or the Oakridge Town Constitution. The Complaint simply assumes that because it dislikes the alleged conduct, a cause of action must exist. Redmont law does not work that way. This case must be dismissed.

II. The Plaintiff lacks standing​

Under Rule 5.12 (Lack of Personal Jurisdiction), a case may be dismissed when a "plaintiff fails to have sufficient standing in order to pursue the case".

To survive dismissal, consistent with Rule 2.1 (Standing Application), Plaintiff must demonstrate the following to this Court:

1. Suffered some injury caused by a clear second party; or is affected by an application of law.
2. The cause of injury was against the law.
3. Remedy is applicable under relevant law that can be granted by a favorable decision.

This case was brought by the Department of Justice acting of its own accord. Keeping this in mind, the Defense respectfully alleges that the Complaint does not plausibly demonstrate any of these three points.

II.I Plaintiff has not plausibly demonstrated that they were injured​

The Complaint does not plead a cognizable injury. It does not allege that the Commonwealth lost money, lost property, suffered a statutory disability, or was deprived of any concrete legal entitlement. Instead, it alleges only that the DCT's role was bypassed and that federal authority was undermined (Compl., Claim for Relief No. 2). That is an abstract institutional disagreement, not a pleaded legal injury.

The Supreme Court's reasoning in 2025] FCR 117 - Appeal squarely defeats that theory. There, the Court held that public interest does not erase standing, that a potentially illegitimate government action does not give all parties unrestricted standing to sue, and that some injury still must be shown, even if the bar is low (2025] FCR 117 - Appeal, Verdict, Section I). The Court rejected an asserted injury based on alleged interference with Congress's institutional ability to legislate, holding that no harm existed where the order had no tangible legal effect and where the supposed restriction would, as a matter of law, simply evaporate (ibid.). The Court further explained that disputes between government institutions require tangible effects or conflicts of law or applications thereof, not mere disagreement (id., Section II).

The same logic applies here with even greater force. If an Executive Order that allegedly burdened Congress itself was insufficient to create standing because no tangible legal effect was shown, then the Commonwealth cannot manufacture standing from the bare assertion that the wrong office handled the final button-pushing on an Oakridge eviction. The Complaint alleges an internal allocation-of-responsibility dispute. It does not plead a concrete injury to the Commonwealth recognized by law.

II.II Plaintiff has not plausibly demonstrated that the alleged cause of injury is against the law​

Second, the Plaintiff has not plausibly pleaded that the asserted cause of injury was against the law. For the reasons above, we respectfully submit that the Complaint identifies no enacted cause of action, misquotes EO 21/25, and tries to transform executive allocation of jurisdiction into civil liability.

Executive Orders are constitutionally confined to implementing "powers expressly granted to the Executive within the Constitution" (Const. 45). Since-repealed Executive Order 21/25, which is now relied upon by the Plaintiff (despite being misquoted), reads as a governance delegation framework for towns and departments that was in effect prior to the Town Rights Expansion Act's amendments to the constitution. This EO is plainly not a civil liability statute.

Likewise, the Oakridge Constitution is a charter establishing internal institutions to the Town of Oakridge, including local enforcement through the Oakridge Police Department and local litigation representation by the Mayor or designee (Const. 32(2); Oak. Const., generally). The Oakridge Constitution does not create a DOJ-enforceable federal civil cause of action against a private citizen for alleged noncompliance with Oakridge’s governmental structure.

For the reasons set out above, the Complaint does not identify an enacted law making the alleged conduct actionable in this suit.

II.III Remedy sought is not available under the law​

Third, the requested remedy is not authorized by relevant law. The Complaint asks for a declaratory judgment about a past act and a permanent injunction binding "all current and future Mayors of Oakridge and other members of the Oakridge Town Council." The Plaintiff cites no Act of Congress authorizing that kind of sweeping unnamed-party relief. Redmont courts have rejected similarly unsupported relief against unnamed persons or broad classes because building such remedies without legislation would invade the legislative sphere (Privacy Matters v. Nexalin [2025] FCR 36, Order Granting Motion for Default Judgement, Section II(F), Par. 2; jsrkiwi v Department of Homeland Security [2025] DCR 93, Post No. 14) or may adversely impact constitutional rights of citizens to a fair trial by depriving them of a chance to defend themselves in open court (MasterCaelen v. Hon. Magistrate Dr_Eksplosive [2026] FCR 14).

The Plaintiff has not identified any statute authorizing this sweeping remedy, and the Commonwealth’s own civil code does not supply it: the Redmont Civil Code Act contains no "Executive Order" enforcement cause of action, no "town constitution" enforcement cause of action, and no injunction/declaratory remedial framework on which the Plaintiff can rely. The defense cannot find any such causes of action at Common Law prior to the passage of the Act, nor any statute authorizing civil causes of action against private citizens on the basis of "Executive Order" or violation of a Town Constitution in the laws in place at the time of the incident alleged in the complaint's factual allegations. We posit that this is because no such cause of action exists.

III. The Plaintiff has erroneously failed to include relevant legal entities whom relief will affect​

Separately, each department of Oakridge is a legal entity distinct from the Town itself (see: Legal Entity Act, Part II, Section 1(5)(b)-(c)), Oakridge Council members each head a town department (Oak. Const., Article II, Section I), and that parties themselves must be summoned to defend their rights (MasterCaelen v. Hon. Magistrate Dr_Eksplosive [2026] FCR 14). This case has not summoned any Department of Oakridge, despite the status of each such department as a separate legal entity - "a legal person with separate rights and liabilities, strictly distinct from their directors, managers, members, shareholders, employees and other agents" (Legal Entity Act, Part I, Section II(3)) - and the impact that this would have on them. As held in Commonwealth of Redmont v. Yeet_Boy [2026] FCR 11, when an "endeavour clearly interferes with the business of a party not named before this Court", dismissal is warranted.

IV. Conclusion​

The Complaint asks this Court to do three things Redmont law does not permit: treat an Executive Order as though it were an Act of Congress creating civil liability, convert a Town Constitution into a federal civil cause of action at the Commonwealth’s pleasure, and issue a sweeping injunction against unnamed current and future local officials without statutory authorization. None of that works.

Therefore, your Honor, we respectfully pray that the Court dismiss this case.

 

[Novakerbal]

Motion

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

Your Honor,

The Defense respectfully moves to dismiss the Complaint under Rule 5.5 (Lack of Claim), Rule 5.12 (Lack of Personal Jurisdiction), and Rule 5.7 (Failure to Include Party). In support of this motion, we respectfully allege as follows:

I. The Complaint fails to state a claim for relief​

Under Rule 5.5 (Lack of Claim), a case may be dismissed when the Plaintiff commits a "failure to state a claim for relief, or against an claim for relief that has insufficient evidence to support the civil or criminal charge".

For several grounds, many of which are independent, Defense alleges that Plaintiff has failed to state a cognizable claim.

I.I Executive Orders are not legislation​

Congress holds federal legislative power and is responsible for creating, removing, and amending laws (Const. 1-2). An Executive Order, by contrast, is only "a lawful directive" and a "mechanism" by which the President exerts "powers expressly granted to the Executive in the Constitution" (Const. 43, emphasis mine). The Supreme Court has likewise stressed that "Departmental policies, while important for internal operations and employment processes within their respective departments, do not carry the force of law unless established by legislation" (zLost v. The Commonwealth of Redmont [2025] SCR 10).

Put plainly: an Executive Order is not, standing alone, a freestanding civil-liability statute; it is not a statute at all, and cannot be considered a form of legislation. The Commonwealth cannot manufacture a novel civil cause of action from executive administration alone.

I.II The Complaint erroneously pleads a legal theory ex post facto based on text in EO 46/25​

The Complaint also misquotes the very order on which it relies. It erroneously says EO 21/25 provides: "Evictions and transfers of property within Town limits (Facilitated by Town government, actioned by the DCT)" (Compl., Factual Allegation No. 6). The actual text of EO 21/25 says: "Plot evictions within Town jurisdiction. (Facilitated by Town government, actioned by the DCT)." The "transfers of property" language appears later in Section 5.2 of EO 46/25, which post-dates the alleged November 2025 conduct (when EO 21/25 was active). The Plaintiff has therefore pleaded a legal theory against language that is not in the order it cites, and whose application to the facts of this case would be ex post facto.

I.III Judicial Precedent and Administrative History cuts against the Commonwealth​

The town-rights line of authority cuts against, not for, the Commonwealth. All of EO 5/24, EO 15/24, and EO 21/25 described Town by-laws as delegated local jurisdiction, gave Town government responsibility over Town constitutions and building regulations, and provided that federal code outside an Act of Congress, an Executive Order, or the Constitution—such as department policy—does not take precedence over Town legislation (See Sections 4 of EO 5/24, EO 15/24, and EO 21/25). In BoopingBerry v. Town of Oakridge [2024] FCR 88, the Court used that framework to hold that the applicable law for evictions was Town legislation, not department policy. That does not turn these executive orders into civil tort statutes, nor any sort of item permitting a civil suit.

I.IV The Oakridge Town Constitution does not provide a federal civil cause of action to the DOJ​

Following the passage of the Town Rights Expansion Act, the Federal Constitution recognizes that Towns are autonomous local governments, each with its own constitution and legislative authority over local matters including property administration, town governance, and internal matters (Const., Section 32(2)-(3)). Oakridge’s Constitution itself reflects a local enforcement structure: the Office of Residence manages evicted plot auctions, the Oakridge Police Department enforces Town law, and the Mayor represents the Town in court or appoints a delegate to do so. (Oak. Const., Article II, Sections 1(e)(4) and 1(g); id., Article III, Section I.)

A town constitution allocates local offices, local duties, and local procedures. It is not transformed into a federal civil code merely because the Department of Justice prefers one reading of it. The Complaint does not identify any Act of Congress, constitutional provision, or controlling precedent that authorises the Commonwealth to sue a Town simply because the Commonwealth says a local official acted inconsistently with that local charter.

I.V It is not legally cognizable to seek a permanent injunction on the basis that (1) a since-repealed EO was allegedly violated and (2) that the constitution was changed thereafter​

The Commonwealth asks for a permanent injunction on the theory that current constitutional law leaves actioning evictions solely to the Federal Government and the DCT because the Town Rights Expansion Act gives towns jurisdiction over "property administration" without expressly mentioning evictions (Compl., Claim for Relief 1(a); id. Prayer For Relief 2). But the current Constitution recognizes towns as autonomous local governments and gives them jurisdiction over "land use, zoning, building standards, and property administration" (Const. 32(3)). The Commonwealth's proposed injunction therefore rests not on clear enacted text, but on an inference layered atop a repealed Executive Order. That is not a sound basis for sweeping permanent relief.

I.VI No uncodified tort at common law is plausibly alleged​

Even if the Court were to read the Complaint generously as attempting to invoke uncodified common-law harm, it still fails. The Redmont Civil Code Act makes clear that uncodified harms remain actionable only where common-law principles or judicial precedent support the claim and where such uncodified harm does not address the same subject matter as a common law tort (RCCA, Part II, Section 3(1)(a)-(c)). The Complaint identifies no qualifying Common Law Tort. And the Commonwealth cannot rely on other acts as a basis for a tort claim; "Any civil violation purportedly created by another Act of Congress shall be null and void unless incorporated as an amendment" to the RCCA (RCCA, Part II, Section 3(2)).

I.VII Conclusion: Plaintiff has failed to state a claim​

The Commonwealth cites no Act of Congress, no constitutional provision, and no established common-law cause of action that authorizes the Department of Justice to sue a Town for an alleged violation of Executive Order 21/25 or the Oakridge Town Constitution. The Complaint simply assumes that because it dislikes the alleged conduct, a cause of action must exist. Redmont law does not work that way. This case must be dismissed.

II. The Plaintiff lacks standing​

Under Rule 5.12 (Lack of Personal Jurisdiction), a case may be dismissed when a "plaintiff fails to have sufficient standing in order to pursue the case".

To survive dismissal, consistent with Rule 2.1 (Standing Application), Plaintiff must demonstrate the following to this Court:



This case was brought by the Department of Justice acting of its own accord. Keeping this in mind, the Defense respectfully alleges that the Complaint does not plausibly demonstrate any of these three points.

II.I Plaintiff has not plausibly demonstrated that they were injured​

The Complaint does not plead a cognizable injury. It does not allege that the Commonwealth lost money, lost property, suffered a statutory disability, or was deprived of any concrete legal entitlement. Instead, it alleges only that the DCT's role was bypassed and that federal authority was undermined (Compl., Claim for Relief No. 2). That is an abstract institutional disagreement, not a pleaded legal injury.

The Supreme Court's reasoning in 2025] FCR 117 - Appeal squarely defeats that theory. There, the Court held that public interest does not erase standing, that a potentially illegitimate government action does not give all parties unrestricted standing to sue, and that some injury still must be shown, even if the bar is low (2025] FCR 117 - Appeal, Verdict, Section I). The Court rejected an asserted injury based on alleged interference with Congress's institutional ability to legislate, holding that no harm existed where the order had no tangible legal effect and where the supposed restriction would, as a matter of law, simply evaporate (ibid.). The Court further explained that disputes between government institutions require tangible effects or conflicts of law or applications thereof, not mere disagreement (id., Section II).

The same logic applies here with even greater force. If an Executive Order that allegedly burdened Congress itself was insufficient to create standing because no tangible legal effect was shown, then the Commonwealth cannot manufacture standing from the bare assertion that the wrong office handled the final button-pushing on an Oakridge eviction. The Complaint alleges an internal allocation-of-responsibility dispute. It does not plead a concrete injury to the Commonwealth recognized by law.

II.II Plaintiff has not plausibly demonstrated that the alleged cause of injury is against the law​

Second, the Plaintiff has not plausibly pleaded that the asserted cause of injury was against the law. For the reasons above, we respectfully submit that the Complaint identifies no enacted cause of action, misquotes EO 21/25, and tries to transform executive allocation of jurisdiction into civil liability.

Executive Orders are constitutionally confined to implementing "powers expressly granted to the Executive within the Constitution" (Const. 45). Since-repealed Executive Order 21/25, which is now relied upon by the Plaintiff (despite being misquoted), reads as a governance delegation framework for towns and departments that was in effect prior to the Town Rights Expansion Act's amendments to the constitution. This EO is plainly not a civil liability statute.

Likewise, the Oakridge Constitution is a charter establishing internal institutions to the Town of Oakridge, including local enforcement through the Oakridge Police Department and local litigation representation by the Mayor or designee (Const. 32(2); Oak. Const., generally). The Oakridge Constitution does not create a DOJ-enforceable federal civil cause of action against a private citizen for alleged noncompliance with Oakridge’s governmental structure.

For the reasons set out above, the Complaint does not identify an enacted law making the alleged conduct actionable in this suit.

II.III Remedy sought is not available under the law​

Third, the requested remedy is not authorized by relevant law. The Complaint asks for a declaratory judgment about a past act and a permanent injunction binding "all current and future Mayors of Oakridge and other members of the Oakridge Town Council." The Plaintiff cites no Act of Congress authorizing that kind of sweeping unnamed-party relief. Redmont courts have rejected similarly unsupported relief against unnamed persons or broad classes because building such remedies without legislation would invade the legislative sphere (Privacy Matters v. Nexalin [2025] FCR 36, Order Granting Motion for Default Judgement, Section II(F), Par. 2; jsrkiwi v Department of Homeland Security [2025] DCR 93, Post No. 14) or may adversely impact constitutional rights of citizens to a fair trial by depriving them of a chance to defend themselves in open court (MasterCaelen v. Hon. Magistrate Dr_Eksplosive [2026] FCR 14).

The Plaintiff has not identified any statute authorizing this sweeping remedy, and the Commonwealth’s own civil code does not supply it: the Redmont Civil Code Act contains no "Executive Order" enforcement cause of action, no "town constitution" enforcement cause of action, and no injunction/declaratory remedial framework on which the Plaintiff can rely. The defense cannot find any such causes of action at Common Law prior to the passage of the Act, nor any statute authorizing civil causes of action against private citizens on the basis of "Executive Order" or violation of a Town Constitution in the laws in place at the time of the incident alleged in the complaint's factual allegations. We posit that this is because no such cause of action exists.

III. The Plaintiff has erroneously failed to include relevant legal entities whom relief will affect​

Separately, each department of Oakridge is a legal entity distinct from the Town itself (see: Legal Entity Act, Part II, Section 1(5)(b)-(c)), Oakridge Council members each head a town department (Oak. Const., Article II, Section I), and that parties themselves must be summoned to defend their rights (MasterCaelen v. Hon. Magistrate Dr_Eksplosive [2026] FCR 14). This case has not summoned any Department of Oakridge, despite the status of each such department as a separate legal entity - "a legal person with separate rights and liabilities, strictly distinct from their directors, managers, members, shareholders, employees and other agents" (Legal Entity Act, Part I, Section II(3)) - and the impact that this would have on them. As held in Commonwealth of Redmont v. Yeet_Boy [2026] FCR 11, when an "endeavour clearly interferes with the business of a party not named before this Court", dismissal is warranted.

IV. Conclusion​

The Complaint asks this Court to do three things Redmont law does not permit: treat an Executive Order as though it were an Act of Congress creating civil liability, convert a Town Constitution into a federal civil cause of action at the Commonwealth’s pleasure, and issue a sweeping injunction against unnamed current and future local officials without statutory authorization. None of that works.

Therefore, your Honor, we respectfully pray that the Court dismiss this case.

Your Honor,

May the Plaintiff be granted 48 Hours(From this point forward) in order to sufficiently parse and respond to this Motion to Dismiss.