Lawsuit: Pending Gribble19 v. The Exchange Inc [2025] FCR 102

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Case Filing


IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
CIVIL ACTION


Gribble19
Plaintiff

v.

The Exchange Inc
Defendant

COMPLAINT
The Plaintiff complains against the Defendant as follows:

Gribble19 entered into an implied contract with The Exchange Inc upon acquiring blocks of the TEX001 bond, which was issued by The Exchange Inc. The Exchange Inc has failed to pay the face value of this bond upon the bond maturing, and still has not done so months later. Furthermore, there are still two interest payments which have never been made. The Exchange Inc has breached the implied contract by failing to make the interest payments and failing to pay back the face value of this bond upon the maturity date. As Gribble19 owns 5,214 blocks of the TEX001 bond, this totals to a sum of $1,105,368 of damages caused to Gribble19 by this breach of contract. The Exchange Inc should be held liable for the damages caused by their breach of contract, and should be made to compensate Gribble19 for these damages.
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I. PARTIES
1. Gribble19 (Plaintiff)
2. The Exchange (Defendant)

II. FACTS
1. On April 24 2025 The Exchange Inc listed a bond on their discord server, with as issuer The Exchange Inc and with CUSIP "TEX-001". This bond is also known as "tex001" or "TEX001". (P-001)
2. On June 5 2025, it was announced in the "tex001" channel of The Exchange Inc discord server that "Interest payments 1/3 have been paid out." (P-001)
3. No further announcements regarding the bond have been made after the announcement specified in fact 2 in the "tex001" channel of The Exchange Inc discord server. (P-001)
4. Each block of the bond has a face value of $200. The bond had a monthly interest rate of 3.0% and a maturity date of July 24 2025. (P-001)
5. At the date of this filing Gribble19 owns 5,214 blocks of this bond. (P-002)
6. At the date of this filing, more than 3 months after the maturity date of the bond, the face value of the blocks has not been paid out to Gribble19.
7. At the date of this filing, more than 5 months after the second interest payment should have been made, this interest payment has not been paid out to Gribble19.
8. At the date of this filing, more than 4 months after the third interest payment should have been made, this interest payment has not been paid out to Gribble19.

III. CLAIMS FOR RELIEF
1. Gribble19 and Defendant entered in to an implied contract upon the purchase of the bonds. According to the Contracts Act § 4, the five elements necessary to enter in to a contract are: (a) Offer, (b) Acceptance, (c) Consideration, (d) Intent, and (e) Capacity. Contracts do not need to be written out expressly, but can be implied. According to § 6 of the Contracts Act, a contract that meets those requirements is valid and enforceable. According to the verdict in lcn v. Blazora Corporation [2025] FCR 18: "There is no doubt that, in the court’s opinion, an offering of any stock, bond, fund, or similar in a Stock Exchange constitutes a contract once accepted". According to § 7 of the Contracts Act, a breach of contract may result in remedies of damages, specific performance, or other equitable relief.

IV. PRAYER FOR RELIEF
The Plaintiff seeks the following from the Defendant:
1. $1,042,800 in Compensatory Damages as a result of the Breach of Contract, covering the face value of $200 for 5,214 blocks of TEX001.
2. $31,284 in Compensatory Damages as a result of the Breach of Contract, covering June's interest payment at 3% of $200 for 5,214 blocks.
3. $31,284 in Compensatory Damages as a result of the Breach of Contract, covering July's interest payment at 3% of $200 for 5,214 blocks.

V. EVIDENCE
P-001TEX.png
P-002TEX.png


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 fifth day of October 2025

 
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Writ of Summons

@asexualdinosaur, is required to appear before the federal Court in the case of Gribble19 v. The Exchange Inc [2025] FCR 102

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.

 
@gribble19 Unless I am mistaken, is it not the Commonwealth who currently holds possession of the Exchange?
 

Brief


IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
On who holds possession of The Exchange Inc.

Upon request by the Court the Plaintiff will hereby give their view on who currently appears to hold possession of The Exchange Inc. Note that this brief is based on the knowledge and information accessible to the Plaintiff at the time of writing this brief. Plaintiff would like to note that prior to filing this lawsuit, the Plaintiff has attempted to request information from the Government regarding who holds possession of The Exchange Inc in the Government's view or to the Government's knowledge. This however was seemingly met not with clear answers, but rather with confusion, unawareness, and at times even contradiction.

On factual matters

On the 27th of June 2025, Avaneesh2008, at the time the Secretary of the Department of Commerce (DOC), announced through the official government channel (#government-announcements) that the Department of Commerce was commandeering the Exchange. (See here)

On the 7th of July 2025, Avaneesh2008, at the time the Secretary of the Department of Commerce (DOC), released through the same channel a report. Within this announcement, he stated: "After a few days of work, the Department of Commerce has created a report on the failure of The Exchange and Voyager and the events leading up to their seizure." (See here)

The Exchange Inc has an in-game db, named theexchange. The owner of this db is the minecraft account GovCommerce, which is the official account of the Department of Commerce.

On Plaintiff's view

The Government has clearly announced that it commandeered The Exchange. Whether this means the Government transfers possession of The Exchange from the previous owners, to the Commonwealth, is up to interpretation of the law and the definition we use for the term 'holding possession of'.

The Taxation Act §8.(3).(c) states that "In extraordinary situations, the Department of Commerce has the power to commandeer and take temporary control of a financial institution." From this it is clear that commandeering is a temporary measure, during which the Department of Commerce takes control of a certain entity. To the Plaintiff, it appears that by having control of an entity, one would also have control over its legal decision-making and thus its representation in lawsuits and other legal matters. As it has never been announced, to Plaintiffs knowledge, that The Exchange is no longer being commandeered by the Department of Commerce, and further based on the fact that the Department of Commerce still owns the in-game db for The Exchange, it would appear to the Plaintiff that at minimum the Department of Commerce is still currently commandeering The Exchange. By the previous line of reasoning, the Department of Commerce, or the Commonwealth, would thus be the correct legal representative of The Exchange in this lawsuit.

Although not clearly announced in a government announcement, the Government has implicated in an announcement that the Department of Commerce not only commandeered, but also seized The Exchange. If The Exchange is in fact currently seized by the Department of Commerce, that would, in the Plaintiffs view, also imply that the Department of Commerce would be the correct legal representative of The Exchange in this lawsuit, as seizure implies taking not only taking control over the decision-making of the entity, but also taking control of the assets of the entity.

If the Department of Commerce would currently be neither commandeering or seizing The Exchange, it would then appear based on their ownership of the in-game db that they would be owning The Exchange. In this scenario it is unequivocally clear that the Commonwealth would be in possession of the entity, and thus the correct legal representative of The Exchange in this lawsuit.

Although it is currently not entirely clear to the Plaintiff whether the Exchange is currently being seized, commandeered, owned, or a combination of those at once by the Department of Commerce, it seems clear that at least either of the three is the case. Since all of the options would imply the Commonwealth to be the correct legal representative of The Exchange for this lawsuit, at least in the Plaintiff's interpretation of the law and the facts at hand, the Plaintiff does not think that the Court was mistaken in summoning the Commonwealth's legal representative to this case.

 
Thank you very much for the detailed brief. This Court is very much satisfied that the correct party has been called.

@asexualdinosaur you have 48 hours to file an Answer to Complaint.
 
AmityBlamity said:
Thank you very much for the detailed brief. This Court is very much satisfied that the correct party has been called.

@asexualdinosaur you have 48 hours to file an Answer to Complaint.
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Your Honor,

The Commonwealth requests a 24-hour extension to provide an answer to complaint.
 
AmityBlamity said:
Granted.
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Your Honor,

I'm asking for a further 12-hour extension. The Deputy Speaker of the House resigned less than 30 minutes ago and I need to attend to that in my capacity as Speaker before I file here. This will allow me the rest of the evening to handle everything that has come on my plate.
 
Franciscus said:
Your Honor,

I'm asking for a further 12-hour extension. The Deputy Speaker of the House resigned less than 30 minutes ago and I need to attend to that in my capacity as Speaker before I file here. This will allow me the rest of the evening to handle everything that has come on my plate.
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Granted.
 
AmityBlamity said:
Granted.
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Motion


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

Your Honor, the Defendant is being entirely unreasonable in their request for am extensions and appears to simply be trying to stall this case. It is important to note that the Defendant in this case is being represented by the Department of Justice. To the best of my knowledge the Department of Justice currently employs 11 people besides myself that are in the prosecutor side of the department, or at least a number close to that amount. This group of 11 people was given 48 hours to file an Answer. The Defendant then requested a 24 hour extension without any reason given. This was accepted, as I find totally reasonable. Something can always come up last minute that causes you to be unable to finish up a filing in time. An extra 50% increase of time without any reasoning given is a lenient, but in my opinion fair way to deal with this issue.

Now however we get to the current request from the Defendant. After 70 hours have passed, 22 hours into the 24 hour extension, the Defendant once again asks an extension, due to one of the 11 people in the prosecution side of the DOJ having to deal with a resignation in the house. This is completely unreasonable for a multitude of reasons.

The amount of work that has to be done to deal with this resignation is the total of 2 commands that have to be ran in-game (namely to fire the one resigned) and one message that has to be sent on discord (to inform the government that elections must be held). This should by no means significantly impede on Defendant's ability to timely file an Answer.

It is the Defendant's responsibility to ensure that they can file a response in time. Considering that they already have been granted an extension, and especially considering that there is an entire group of 11 capable lawyers that can work on this case, it should most certainly have been possible to reach this deadline if there was even the slightest willingness to do so. If one of the DOJ's employees has something come up, surely someone else would be available within the 72 hour time span to work on this answer.

The extension is furthermore being requested 2 hours before the deadline which was already extended by 24 hours. By now certainly the Answer should be close to being completed, and if it is not, this is entirely the fault of the Defendant's counsel themselves. The Court cannot simply keep granting infinite extensions, because it appears that the Defendant is using them not as extensions to finish up something that they did not manage to get done in time, but rather as a carte blanche to delay their work until the last minute, where if even the slightest thing comes up another delay must be requested.

The Plaintiff urges the court to deny this request for an extension and deny the Defendant the possibility of stalling this case any longer.

 
gribble19 said:

Motion


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

Your Honor, the Defendant is being entirely unreasonable in their request for am extensions and appears to simply be trying to stall this case. It is important to note that the Defendant in this case is being represented by the Department of Justice. To the best of my knowledge the Department of Justice currently employs 11 people besides myself that are in the prosecutor side of the department, or at least a number close to that amount. This group of 11 people was given 48 hours to file an Answer. The Defendant then requested a 24 hour extension without any reason given. This was accepted, as I find totally reasonable. Something can always come up last minute that causes you to be unable to finish up a filing in time. An extra 50% increase of time without any reasoning given is a lenient, but in my opinion fair way to deal with this issue.

Now however we get to the current request from the Defendant. After 70 hours have passed, 22 hours into the 24 hour extension, the Defendant once again asks an extension, due to one of the 11 people in the prosecution side of the DOJ having to deal with a resignation in the house. This is completely unreasonable for a multitude of reasons.

The amount of work that has to be done to deal with this resignation is the total of 2 commands that have to be ran in-game (namely to fire the one resigned) and one message that has to be sent on discord (to inform the government that elections must be held). This should by no means significantly impede on Defendant's ability to timely file an Answer.

It is the Defendant's responsibility to ensure that they can file a response in time. Considering that they already have been granted an extension, and especially considering that there is an entire group of 11 capable lawyers that can work on this case, it should most certainly have been possible to reach this deadline if there was even the slightest willingness to do so. If one of the DOJ's employees has something come up, surely someone else would be available within the 72 hour time span to work on this answer.

The extension is furthermore being requested 2 hours before the deadline which was already extended by 24 hours. By now certainly the Answer should be close to being completed, and if it is not, this is entirely the fault of the Defendant's counsel themselves. The Court cannot simply keep granting infinite extensions, because it appears that the Defendant is using them not as extensions to finish up something that they did not manage to get done in time, but rather as a carte blanche to delay their work until the last minute, where if even the slightest thing comes up another delay must be requested.

The Plaintiff urges the court to deny this request for an extension and deny the Defendant the possibility of stalling this case any longer.

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Your honor,

I request permission to respond here.
 

Answer to Complaint


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


Gribble19
Plaintiff

v.

The Exchange, Inc.
Defendant

I. ANSWER TO COMPLAINT​

  1. AFFIRMS that on April 24 2025 The Exchange Inc listed a bond on their discord server, with as issuer The Exchange Inc and with CUSIP "TEX-001", and that this this bond is also known as "tex001" or "TEX001".
  2. AFFIRMS that On June 5 2025, it was announced in the "tex001" channel of The Exchange Inc discord server that "Interest payments 1/3 have been paid out."
  3. NEITHER AFFIRMS NOR DENIES that no further announcements regarding the bond have been made after this in the "tex001" channel of The Exchange Inc discord server, NOTING that additional communications in that channel were made prior to the announcement referenced in fact 2 (see: Exhibit P-001).
  4. AFFIRMS that Each block of the bond has a face value of $200, that the bond had a monthly interest rate of 3.0%, that the bond offering had a maturity date of July 24 2025.
  5. AFFIRMS that at the date of this filing Gribble19 owns 5,214 blocks of this bond.
  6. NEITHER AFFIRMS NOR DENIES that “at the date of this filing, more than 3 months after the maturity date of the bond, the face value of the blocks has not been paid out to Gribble19”.
  7. NEITHER AFFIRMS NOR DENIES that “at the date of this filing, more than 5 months after the second interest payment should have been made, this interest payment has not been paid out to Gribble19”.
  8. NEITHER AFFIRMS NOR DENIES that “at the date of this filing, more than 4 months after the third interest payment should have been made, this interest payment has not been paid out to Gribble19”.

II. DEFENCES​

A. No Proof of Ownership at Relevant Times:​

The Plaintiff has not proven that she was the holder of the TEX001 bond at the times the obligations in question came due. The only evidence of ownership provided (Exhibit P-002 in the Complaint) shows that the Plaintiff held 5,214 bond blocks as of the filing of this lawsuit – months after the missed interest payments and the bond’s maturity. Indeed, the Plaintiff does not even assert, as a factual allegation, the date that the Plaintiff came into possession of these bonds.

There is no evidence that the Plaintiff owned these bonds during the months of June or July 2025 when the interest payments were due, nor on July 24, 2025 when the principal payment became due. In contract law, a party can only claim damages for breach of contract if they were a party to the contract and entitled to performance at the time of the breach. Here, any implied contract formed by the bond issuance would have been between The Exchange, Inc. and those investors who originally purchased or held the bond during its term.

As the Federal Court noted in lcn v. Blazora Corporation [2025] FCR 18, an offering of stock or bonds on The Exchange creates a contract once it is accepted by a buyer. In that case, the plaintiff (lcn) had in fact purchased 931 shares of the bond during the original offering period, making lcn the rightful bondholder when interest payments were due. On top of that, the judge’s opinion emphasizes the importance of establishing exactly what is owed; while the Plaintiff sought payments of interest in two instances, the judge commented “I only see one missing payment, not two”, and granted a modified prayer for relief on compensatory damages (awarding $8,263.03 in compensatory damages rather than the $16,526.06 of compensatory damages sought by the Plaintiff in the Complaint).

By contrast, in the present case, the Plaintiff has not shown such direct privity or timely acceptance of the bond contract. If the Plaintiff acquired the TEX001 bonds only after interest payments were missed (for example, by buying the bonds from a previous holder after default), then those interest obligations were never owed to her in the first place. If they were owed to anyone, arguments below about insolvency notwithstanding, they would have been owed to the bondholder of record at the time.

The Complaint’s own description speaks to the present tense in its factual allegations regarding ownership of the bond. The statement from the Plaintiff that proceeds this alleges in present tense that “Gribble19 owns 5,214 blocks of the TEX001 bond”, while the fifth factual allegation (“[a]t the date of this filing Gribble19 owns 5,214 blocks of this bond”) likewise comments in the present tense. That Gribble19 “owns 5,214 blocks” now, months later, provides no clarification regarding any acquisition may have occurred post-default. The law does not generally permit a claimant to retroactively step into a contract claim without an assignment of rights. Therefore, due to this lack of demonstrated standing as an injured party at the relevant times, the Plaintiff’s breach of contract claim is fatally deficient.

The Defendant respectfully asserts that the Plaintiff’s factual allegations, taken at face value, lack standing to recover for payments that were allegedly missed before she became a bondholder, and this lawsuit should be dismissed or judgment entered for Defendant on that basis alone unless the Plaintiff makes factual allegations in their complaint regarding the date at which the Plaintiff obtained ownership of these bonds.

B. Force Majeure:​

In the event that the Court finds a contract, the Court must consider whether a Force Majeure event occurred. Under Section 16(o) of the Contracts Act, Force Majeure “is a legal term that describes unforeseeable circumstances or events beyond the control of contractual parties, making it impossible for them to fulfil their obligations”.

The defense posits that the invocation of Taxation Act 8(3)(c) (“in extraordinary situations, the Department of Commerce has the power to commandeer and take temporary control of a financial institution”) with respect The Exchange was beyond the control of The Exchange, Inc., and made it impossible for The Exchange to fulfil any contractual obligations in its own right. When a business is commandeered, it must give up its control to the Department of Commerce. This includes its ability to make interest payments and transfer funds. The subsequent seizure by the Department of Commerce made this permanent.

Under Contracts Act Section 15(2-3), “During a force majeure event, the affected party may temporarily suspend contractual duties to the extent that the situation significantly hinders their ability to fulfill obligations. … Should the force majeure event persist, either party retains the right to terminate the contract without incurring liability.”

This force majeure event has persisted - the funds of The Exchange were seized by the Department of Commerce for purposes of equitable distribution. In that line, the obligations were permitted temporary suspension, and may be terminated without liability being incurred. Damages should not be awarded for a force majeure event, and the Court should grant no relief.

C. Insolvency:​

In the alternative to above arguments, should the Court find that The Exchange, Inc. still exists as a legal entity (see: exhibit D-004 and exhibit D-005), the Defense asks for a declaration of insolvency. This section assumes that The Exchange, Inc., still exists for sake of argument.

Exhibit D-001 shows the in-game balance of the balance for the /db entry for theexchange, which totals $351,407.51 as of the late evening Pacific Daylight Time on 18 October 2025. The Plaintiff in this case is seeking compensatory damages in excess of $1 million. The Exchange, Inc. simply cannot pay this out at this time, especially when the Defendant (under Plaintiff’s theory of injury) would be also liable for payment in full to any other individual in similar circumstance. And such people are not mere hypotheticals (see, for example: Exhibit D-002).

The circumstances surrounding the non-payment of the TEX001 bond are not those of an ordinary contract breach, but rather of a financial collapse and government-mandated intervention. The Department of Commerce indeed commandeered The Exchange, Inc., under the authority granted by the Taxation Act 8(3)(c), (“in extraordinary situations, the Department of Commerce has the power to commandeer and take temporary control of a financial institution”). As we will show through witness testimony and through discovery, The Exchange, Inc. was, at that time, facing a severe liquidity crisis and potential insolvency, triggering government action to protect the financial system.

Once the Department of Commerce assumed control of The Exchange Inc, the company’s management lost autonomy over its finances — including the ability to pay out debts like bond interest or principal. As time went on, a seizure of The Exchange, Inc. occurred pursuant to Taxation Act 8(3)(d). That section also gives extraordinary power to the Commonwealth in order to act to protect the best interest of depositors, stating:

The Department of Commerce may consider commercial remedies such as selling a collapsed bank (or parts of a collapsed bank) to other interested financial institutions/parties. This may only take place when it is in the best interests of the depositors. Additionally, the Department may seize the assets of Directors/Owners of the Financial Institutions (with the least required disturbance to their estate) to recover debts.
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In effect, from the point of seizure onwards, The Exchange’s obligations were subject to an ongoing insolvency and reorganization process under government supervision, rather than the normal course of business. And, under this process, the Department of Commerce has extraordinary powers under the law to create and pursue a plan in order to protect the best interest of those who had deposited funds with The Exchange. Assets are to be seized and distributed along these lines; individual bondholders would not be entitled to relief by suing the corporation once this seizure begins.

D. Equitable Distribution and Public Interest:​

At all times relevant to the bond payment - that is, from April through July 2025 - The Business Structuring Act was the law of the Commonwealth of Redmont. The act which repealed it (the Legal Entity Act) was signed on 10 August 2025 - well after any alleged breaches of contract may have occurred.

This brings into discussion the Common Law understanding of ex post facto, and how it might apply here. Under Federal Court precedent in End v Commonwealth [2025] FCR 31, the court laid out ex post facto in layman’s terms: “[Ex post Facto] is generally a legal idea to apply the law as it was then and not what it is now when looking at all cases… People, companies and the commonwealth can only act as the law is during the moment and not what it will be in the future.” Except when the new law explicitly states its intent to retroactively displace old laws, the law at the time is the proper law for governing disputes.

As such, the law of the Business Structuring Act governs this dispute, even in spite of its subsequent repeal. And under that Law, the Defense seeks the Court to rule that The Exchange, Inc. is insolvent under Section 17(2)(c) of the Business Structuring Act, which occurs when a firm is “unable to pay debts as they come due. A debtor is considered insolvent when their liabilities exceed the fair value of their assets by 25%”. If the Court does so, the defense asks that the Court recognize insolvency when ordering equitable remedies that preserve the rights of all bondholders to equal shares of anything that might be distributed.

That is to say: in the alternative that the Court finds that the Plaintiff’s contract claim is technically valid, and that The Exchange, Inc. is still liable for performance, the Defendant urges the Court to consider the equitable implications of awarding the full amount of damages sought. The Exchange, Inc. is insolvent, and there are likely other creditors and bondholders who have also not been paid (some of which may be shown in Exhibit D-002). Allowing one bondholder to recover 100% of their claim (principal + interest) via a personal lawsuit, while others remain unpaid forever (for lack of firm assets), would offend the principle of equitable treatment among creditors.

This suit is an attempt for the Plaintiff to grab cash on her own, rather than seek equitable remedies across all bondholders. The Plaintiff is aware of a class action lawsuit (see: Exhibit D-007 and D-002) that was being planned prior to this case's filing (see: Exhibit D-008). But the Plaintiff chose not to join it (see: Exhibit D-007). We should not permit a windfall to merely one creditor here; if bankruptcy is permitted, the Court should order that, or alternatively order the execution of the DoC plan attached as Exhibit D-003 in order to enter equitable relief.

III. Evidence​


1760860310074.png

EmmDubz

Lawsuit: Pending Thread 'Vendeka Inc. and Pepecuu v. Department of Commerce [2025] FCR 107'

Case Filing


IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
CIVIL ACTION


Vendeka Inc. & Pepecuu
Plaintiff

v.

Department of Commerce
Defendant

COMPLAINT
The Plaintiff complains against the Defendant as follows:

WRITTEN STATEMENT FROM THE PLAINTIFF

This is a case for breach of contract and the Defendant's failure to adhere to its own crisis management policies. The Defendant, as the legal successor to the commandeered entity "The Exchange Inc.," defaulted on the repayment of the TEX-001 bonds held by the Plaintiffs.

Following the seizure, the Defendant published the "Financial Crisis...
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  • Ded
See attached PDF "D-003.pdf"
See attached PDF "D-004.pdf"
1760861323225.webp
1760861341058.webp

1760861554245.png
1760861768528.png

IV. Witness List​

  1. Kaiserin_
  2. Avaneesh2008
  3. Stoppers
  4. Toadking
  5. Malka
  6. Pepecuu
  7. ElysiaCrynn
  8. TrueDarklander
  9. .MgChamp2339

By making this submission, I agree that I understand the penalties of lying in court and that I am subject to perjury charges should I knowingly make a false statement in court.

DATED: This 19th day of October 2025

 

Attachments

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  • D-003.pdf
    D-003.pdf
    453.1 KB · Views: 32
gribble19 said:

Motion


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

Your Honor, the Defendant is being entirely unreasonable in their request for am extensions and appears to simply be trying to stall this case. It is important to note that the Defendant in this case is being represented by the Department of Justice. To the best of my knowledge the Department of Justice currently employs 11 people besides myself that are in the prosecutor side of the department, or at least a number close to that amount. This group of 11 people was given 48 hours to file an Answer. The Defendant then requested a 24 hour extension without any reason given. This was accepted, as I find totally reasonable. Something can always come up last minute that causes you to be unable to finish up a filing in time. An extra 50% increase of time without any reasoning given is a lenient, but in my opinion fair way to deal with this issue.

Now however we get to the current request from the Defendant. After 70 hours have passed, 22 hours into the 24 hour extension, the Defendant once again asks an extension, due to one of the 11 people in the prosecution side of the DOJ having to deal with a resignation in the house. This is completely unreasonable for a multitude of reasons.

The amount of work that has to be done to deal with this resignation is the total of 2 commands that have to be ran in-game (namely to fire the one resigned) and one message that has to be sent on discord (to inform the government that elections must be held). This should by no means significantly impede on Defendant's ability to timely file an Answer.

It is the Defendant's responsibility to ensure that they can file a response in time. Considering that they already have been granted an extension, and especially considering that there is an entire group of 11 capable lawyers that can work on this case, it should most certainly have been possible to reach this deadline if there was even the slightest willingness to do so. If one of the DOJ's employees has something come up, surely someone else would be available within the 72 hour time span to work on this answer.

The extension is furthermore being requested 2 hours before the deadline which was already extended by 24 hours. By now certainly the Answer should be close to being completed, and if it is not, this is entirely the fault of the Defendant's counsel themselves. The Court cannot simply keep granting infinite extensions, because it appears that the Defendant is using them not as extensions to finish up something that they did not manage to get done in time, but rather as a carte blanche to delay their work until the last minute, where if even the slightest thing comes up another delay must be requested.

The Plaintiff urges the court to deny this request for an extension and deny the Defendant the possibility of stalling this case any longer.

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AmityBlamity said:
Granted.
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Response


Your Honor,

There are three main points here.


1. Gribble19 either misunderstood or intentionally understated the work caused by the resignation of a deputy speaker under the Standing Orders in effect at the time.
Plaintiff Gribble19 falsely asserted that "The amount of work that has to be done to deal with this resignation is the total of 2 commands that have to be ran in-game (namely to fire the one resigned) and one message that has to be sent on discord (to inform the government that elections must be held)", and uses this as the basis for the Complaint. If this were an ordinary representative, I might agree with her, but she apparently missed the effects of most critical part of the statement -that the Deputy Speaker of the House resigned.

Upon seeing the resignation of the Deputy Speaker, I examined the Standing Orders of the House. Upon re-reading the rules in force at the time (prior to amendments shown in Exhibit D-ZZ1/D-ZZ2), the House Standing Orders did not clearly specify a mechanism to re-elect a Deputy Speaker upon vacancy; I could not find any equivalent to Standing Order 2(1)(c) for the Deputy Speaker. I then looked through the entirety of the Legislative Standards Act, and then the Constitution, and could not find guidance. At that time, I concluded that there was no legal path to re-elect a Deputy Speaker in case of vacancy, which is a problem both for pragmatic reasons in managing the House and also because they are enumerated as a Legislative Officer under Article 39 of the Constitution.

To fix this, I then proceded to write a motion to amend the standing order to allow for re-elections in case of Deputy Speaker vacancy, which was posted at 5:49 P.M. Eastern Daylight Time on 18 October. The deadline, had it been extended, would have been at 6:02 P.M. Eastern Daylight Time. At 6:14 P.M., a majority was reached on the motion.

This is all to say, there was more work than running simple in-game commands here, and my constitutional obligations as Speaker to be "responsible for maintaining order, ensuring the efficient running of the chamber" got in the way here at the last minute. Perhaps Gribble19 may be confidently ignorant of the work this resignation caused, or perhaps she is just pontificating here just as she has in public regarding her motion (see: Exhibit D-ZZ4), but her ignorance or desire to pontificate does not motivate retroactively yanking back an extension.

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2. Retroactively withdrawing an extension after it has been granted is inequitable and would harm a fair trial.

I do not believe I need to elaborate much on this point; when an extension is granted, it is assumed by the party that it won't be yanked retroactively; otherwise, there would not really be an ability to rely on granted extensions when dealing with timing issues. The Plaintiff is asking for an extension to be yanked retroactively, which would cause substantial issues here.

3. Gribble19 misunderstands, or implicitly misrepresents, how case assignment works within the DoJ.
When the DoJ is in operation not all of its prosecutors are assigned to work a case. Gribble19 has repeatedly referred to a group of 11 people in her objection - Lo and behold (as she is verily aware), not every lawyer works on every case. Rather, as noted in D-ZZ5, lawyers are expected to "complete assigned cases" and to "[n]ever file anything for a lawsuit you have not been explicitly assigned". This means that, when an individual who is assigned to a case has something pop up a few hours before the deadline, it is not actually 11 others who could step in, be fully briefed on everything, and take over the work. Having worked in the DoJ - and previously as the attorney general - she should understand how this works.


See attached file "D-ZZ5.pdf for a PDF version


In short, the resignation of the Deputy Speaker took a bunch more work than the Plaintiff portrays, the Plaintiff's ask to nuke an extension after it already has been granted is plainly unreasonable, and the DoJ's case assignment process segregates cases in a way that doesn't transfer nearly as easily as implied in her motion. The Motion to Reconsider should be denied on both factual and equitable grounds.



Motion


IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
MOTION TO STRIKE

Your Honor,

As has been demonstrated above, there was a good bit more work that had to be done to deal with the resignation than a mere running of two commands and the sending of one message. This caused me to do research on how to re-elect a deputy speaker, discover that we didn't actually have a Standing Order or law to handle it, write an amendment to a standing order, and send that amendment to vote. The below is provably false, plainly inflammatory, and should be stricken as such.

gribble19 said:
The amount of work that has to be done to deal with this resignation is the total of 2 commands that have to be ran in-game (namely to fire the one resigned) and one message that has to be sent on discord (to inform the government that elections must be held). This should by no means significantly impede on Defendant's ability to timely file an Answer.
Click to expand...

 

Attachments

Your Honor, having read the Defendant's response the Plaintiff concurs that there was a misunderstanding with regards to the effort required. As the Defendant has now filed their Answer, the Plaintiff would like to retract their motion to reconsider so that this case can move into Discovery.
 
gribble19 said:
Your Honor, having read the Defendant's response the Plaintiff concurs that there was a misunderstanding with regards to the effort required. As the Defendant has now filed their Answer, the Plaintiff would like to retract their motion to reconsider so that this case can move into Discovery.
Click to expand...
The motion is retracted at the Plaintiff's request.

We shall now enter Discovery, which shall last 5 days or shorter if both parties agree to conclude it sooner.
 
Pursuant to Rule 4.7, the Plaintiff requests the Defendant to produce the following materials relevant to the case:

1. A document outlining the exact dates, if such has happened, on which The Exchange Inc has been commandeered, seized, and/or owned by the Department of Commerce, as well as the dates on which the Department of Commerce stopped commandeering, seizing, and/or owning The Exchange Inc, if applicable.
 
The Plaintiff hereby respectfully requests to amend their Complaint as follows (where struck through text is to be removed and bolded text is to be added) to clarify something that could be interpreted in multiple ways:

II. FACTS
3. No further announcements regarding the bond have been made after this the announcement specified in fact 2 in the "tex001" channel of The Exchange Inc discord server. (P-001)
 
Pursuant to Rule 4.7, the Plaintiff requests the Defendant to produce the following materials relevant to the case:

1. A document outlining for all payments made to the Plaintiff by the Defendant with the purpose of paying out either the face value for, or the interest on, any blocks of TEX-001:
- The date on which these payments were made
- The amount that was paid
- Through which method this payment was made
 
gribble19 said:
The Plaintiff hereby respectfully requests to amend their Complaint as follows (where struck through text is to be removed and bolded text is to be added) to clarify something that could be interpreted in multiple ways:

II. FACTS
3. No further announcements regarding the bond have been made after this the announcement specified in fact 2 in the "tex001" channel of The Exchange Inc discord server. (P-001)
Click to expand...
Granted.
 

Motion


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

Your Honor,

The Exchange, Inc. seeks to compel the Department of Commerce to provide any documents (including balance sheets, analyses, or electronic communications) regarding the financial status of The Exchange, Inc. on or prior to 7 July 2025 and after the issuance of the tex-001 bonds. The Exchange, Inc., believes that this will help to establish insolvency under the law at the time, which is relevant to our defense.

 
Your Honor,

The Defense submits the following into evidence:
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Motion



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

Your Honor,

The Exchange, Inc. seeks to compel the Department of Commerce to provide any documents regarding or copies account deposit balances in The Exchange, Inc. on or prior to 7 July 2025.

The Exchange, Inc., believes that this will further help to establish insolvency under the law at the time, which is relevant to our defense, and will also better demonstrate for this Court how equitable distribution might occur in case of insolvency.

 
gribble19 said:
Pursuant to Rule 4.7, the Plaintiff requests the Defendant to produce the following materials relevant to the case:

1. A document outlining the exact dates, if such has happened, on which The Exchange Inc has been commandeered, seized, and/or owned by the Department of Commerce, as well as the dates on which the Department of Commerce stopped commandeering, seizing, and/or owning The Exchange Inc, if applicable.
Click to expand...

Response


Your Honor,

In Line with Rule 4.7, The Exchange, Inc. submits an oppositional statement as follows:

The Exchange, Inc., to the best of my knowledge and ability, is not in possession of any such single document at this time. Discovery can be used to require production of existing documents, but cannot compel the creation of new documents.

Should the Plaintiff seek this information, perhaps the Plaintiff should seek to compel the Department of Commerce to produce related documentation. But The Exchange, Inc. (the defendant here) per se is likely the wrong target for this request.

 
Franciscus said:

Response


Your Honor,

In Line with Rule 4.7, The Exchange, Inc. submits an oppositional statement as follows:

The Exchange, Inc., to the best of my knowledge and ability, is not in possession of any such single document at this time. Discovery can be used to require production of existing documents, but cannot compel the creation of new documents.

Should the Plaintiff seek this information, perhaps the Plaintiff should seek to compel the Department of Commerce to produce related documentation. But The Exchange, Inc. (the defendant here) per se is likely the wrong target for this request.

Click to expand...

Objection

IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
OBJECTIONS - PERJURY, PERJURY

1. PERJURY 1
Your Honor, Defendant has stated in this response that: "Discovery can be used to require production of existing documents, but cannot compel the creation of new documents."

This is something the Defendant seems to have simply made up. The Court Rules and Procedures state under Rule 4.7, which was linked directly in Defendant's filing:
"Prior to the end of Discovery, a party may move to request documents, messages, or screenshots from the opposing party. The material must be relevant to the case and will need to be signed off by the presiding judge if opposed by the opposing party. If granted by the presiding judge, the material must be given by the opposing party to the best of their ability under sanction of contempt of court and perjury."
The only requirements that are put on the documents are that they may be requested from "the opposing party" and that the material must be "relevant to the case". There are no requirements on when or where these documents must have been created.

Furthermore there is Supreme Court precedent of similar requests having been made for documents that were yet to be created by a party under the exact same court rule, which was granted by the Supreme Court. As Supreme Court precedent is binding in the Federal Court, this shows that Defendant's hallucinated rule is in fact non-existent. An example of this can be found in the motion of compel made in #18 in AnimeInc & KattoC324 v. The Commonwealth of Redmont [2025] SCR 5, which was granted by the Supreme Court.

Plaintiff respectfully requests the Court to strike this part of Defendant's response, and to compel the Defendant to produce the requested documents to the best of their abilities, as it is extremely relevant to the case.

2. PERJURY 2
Your Honor, Defendant has stated in this response that: "Should the Plaintiff seek this information, perhaps the Plaintiff should seek to compel the Department of Commerce to produce related documentation. But The Exchange, Inc. (the defendant here) per se is likely the wrong target for this request."

This is not only wrong, but also incredibly silly. The reason that opposing counsel is counsel of this case, is because the Exchange is being commandeered by the Department of Commerce. This makes the Department of Commerce the legal representatives of The Exchange, and the de facto executive officers of The Exchange. This is akin to claiming that in a court case against a business the information should be externally requested from the CEO, instead of from the business. This is exceptionally silly considering the information requested is directly related to the business and its management.

Besides that, the claim that this information should somehow be requested from the Department of Commerce rather than the Exchange is silly on its own, even if opposing counsel would not currently be representing this exact Department of Commerce as the legal representatives of the Exchange. The information that was requested was related to when The Exchange Inc was seized, commandeered, or changed ownership. Surely if the Department of Commerce seized, commandeered or took ownership of The Exchange, The Exchange itself would be notified and made aware of this.

Plaintiff respectfully requests the Court to strike this part of Defendant's response, and to compel the Defendant to produce the requested documents to the best of their abilities, as these are documents that are not only relevant to the case, but make up information that any reasonable person would expect Defendant to be in possession of.

 
gribble19 said:

Objection



PERJURY 2
Your Honor, Defendant has stated in this response that: "Should the Plaintiff seek this information, perhaps the Plaintiff should seek to compel the Department of Commerce to produce related documentation. But The Exchange, Inc. (the defendant here) per se is likely the wrong target for this request."

This is not only wrong, but also incredibly silly. The reason that opposing counsel is counsel of this case, is because the Exchange is being commandeered by the Department of Commerce. This makes the Department of Commerce the legal representatives of The Exchange, and the de facto executive officers of The Exchange. This is akin to claiming that in a court case against a business the information should be externally requested from the CEO, instead of from the business. This is exceptionally silly considering the information requested is directly related to the business and its management.

Besides that, the claim that this information should somehow be requested from the Department of Commerce rather than the Exchange is silly on its own, even if opposing counsel would not currently be representing this exact Department of Commerce as the legal representatives of the Exchange. The information that was requested was related to when The Exchange Inc was seized, commandeered, or changed ownership. Surely if the Department of Commerce seized, commandeered or took ownership of The Exchange, The Exchange itself would be notified and made aware of this.

Plaintiff respectfully requests the Court to strike this part of Defendant's response, and to compel the Defendant to produce the requested documents to the best of their abilities, as these are documents that are not only relevant to the case, but make up information that any reasonable person would expect Defendant to be in possession of.

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Response


Your Honor,

I am utterly confused by the Plaintiff's statements here. The Plaintiff is suing The Exchange, Inc., which is the named party in this case. Under The Business Structuring Act 8(2)(a), "[t]he firm is treated as a separate legal entity from its owners and managers." Section 13 of the Legal Entities Act notes that "[a]ll firms under the business structuring act must convert" to a new form, but also does not extinguish old legal entities; under Section 13(2)(a)(iii) thereof, the law recognizes continuity of "the same legal entity" from the beginning to the end of the conversion process.

In my best reading of the law, The Exchange, Inc., continues to exist as a legal entity. The Plaintiff is not suing the Department of Commerce and is not suing the Commonwealth - neither are named parties here. Likewise, neither of those entities are the Defendant, the entity towards whom the discovery request was pointed.

I respectfully submit that I am, to the best of my ability, being truthful and forthright here. I understand that I am here to represent The Exchange, Inc.; if I am here to represent a different entity, I would appreciate the Court clarifying who is the defendant in this case. But none of this comes anywhere close to perjury (when one "knowingly provides false testimony in a court of law") - I am representing my understanding of this situation in good faith here.

 
gribble19 said:
1. PERJURY 1
Your Honor, Defendant has stated in this response that: "Discovery can be used to require production of existing documents, but cannot compel the creation of new documents."

This is something the Defendant seems to have simply made up. The Court Rules and Procedures state under Rule 4.7, which was linked directly in Defendant's filing:
"Prior to the end of Discovery, a party may move to request documents, messages, or screenshots from the opposing party. The material must be relevant to the case and will need to be signed off by the presiding judge if opposed by the opposing party. If granted by the presiding judge, the material must be given by the opposing party to the best of their ability under sanction of contempt of court and perjury."
The only requirements that are put on the documents are that they may be requested from "the opposing party" and that the material must be "relevant to the case". There are no requirements on when or where these documents must have been created.

Furthermore there is Supreme Court precedent of similar requests having been made for documents that were yet to be created by a party under the exact same court rule, which was granted by the Supreme Court. As Supreme Court precedent is binding in the Federal Court, this shows that Defendant's hallucinated rule is in fact non-existent. An example of this can be found in the motion of compel made in #18 in AnimeInc & KattoC324 v. The Commonwealth of Redmont [2025] SCR 5, which was granted by the Supreme Court.

Plaintiff respectfully requests the Court to strike this part of Defendant's response, and to compel the Defendant to produce the requested documents to the best of their abilities, as it is extremely relevant to the case.
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Response


Your Honor,

When someone reads "Prior to the end of Discovery, a party may move to request documents, messages, or screenshots from the opposing party", this does not typically conjure to mind that a party may move to create de novo items. Indeed the Federal Court, in Privacy Matters v. Nexalin [2025] FCR 36, explicitly noted as such, writing "[t]he plaintiff cannot compel the defendant to create new documentation on information" (emphasis mine) in response to a discovery request. (Instead, the Court found, "[t]his should be something that should be sought through interrogatives".) My statement that ""[d]iscovery can be used to require production of existing documents, but cannot compel the creation of new documents" follows this wording from the Federal Court quite closely, and was made in good faith from my understanding of the Court precedent regarding discovery procedure as laid out in [2025] FCR 36.

The Plaintiff now alleges that my statement that constitutes perjury. Her reason for doing so is that a ruling in a different case when a Plaintiff sought to compel classified information, on implication that the list sought did not exist before it was requested.

Simply put: it is not perjury to closely paraphrase the rulings of the Federal Court regarding the scope of discovery in good faith, and then submit that in an oppositional statement to the Federal Court. This does not come anywhere near a situation where one "knowingly provides false testimony in a court of law" (as perjury is defined in the Criminal Code Act), and I would ask that this objection be overruled.

 
Franciscus said:

Motion



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

Your Honor,

The Exchange, Inc. seeks to compel the Department of Commerce to provide any documents regarding or copies account deposit balances in The Exchange, Inc. on or prior to 7 July 2025.

The Exchange, Inc., believes that this will further help to establish insolvency under the law at the time, which is relevant to our defense, and will also better demonstrate for this Court how equitable distribution might occur in case of insolvency.

Click to expand...
Franciscus said:

Motion



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

Your Honor,

The Exchange, Inc. seeks to compel the Department of Commerce to provide any documents regarding or copies account deposit balances in The Exchange, Inc. on or prior to 7 July 2025.

The Exchange, Inc., believes that this will further help to establish insolvency under the law at the time, which is relevant to our defense, and will also better demonstrate for this Court how equitable distribution might occur in case of insolvency.

Click to expand...

Objection


IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
OBJECTION - BREACH OF PROCEDURE x 2

Your Honor, our Courts guides to Motions defines a Motion to Compel as: "A request for the court to order a party to produce requested documents or information, or to sanction them for failing to comply with discovery requests."

The Defendant has made two motions requesting the Court to compel the Department of Commerce to produce requested documents or information. In the Defendant's own words: "The Plaintiff is not suing the Department of Commerce and is not suing the Commonwealth - neither are named parties here."

As the Department of Commerce is not a party to this case (which is furthermore clear from the fact that they are not listed as a party to this case in the Complaint) both of these motions constitute a breach of procedure.

Plaintiff respectfully requests these motions to be struck. In the case that they are not struck, Plaintiff requests to respond to these motions.

 
gribble19 said:

Objection


IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
OBJECTION - BREACH OF PROCEDURE x 2

Your Honor, our Courts guides to Motions defines a Motion to Compel as: "A request for the court to order a party to produce requested documents or information, or to sanction them for failing to comply with discovery requests."

The Defendant has made two motions requesting the Court to compel the Department of Commerce to produce requested documents or information. In the Defendant's own words: "The Plaintiff is not suing the Department of Commerce and is not suing the Commonwealth - neither are named parties here."

As the Department of Commerce is not a party to this case (which is furthermore clear from the fact that they are not listed as a party to this case in the Complaint) both of these motions constitute a breach of procedure.

Plaintiff respectfully requests these motions to be struck. In the case that they are not struck, Plaintiff requests to respond to these motions.

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Response



Your Honor,

The Federal Court has a history and precedent of granting subpoenas to third parties pursuing to a "Motion to Compel". Recent cases include YeetGlazer v. Commonwealth of Redmont[2025] FCR 76 and in malka v. The Commonwealth of Redmont[2025] FCR 87, where a subpoena was issued to various individuals who might have information relevant to this case. In the latter, the Federal Court approved the Subpoena of materials from third parties after a Motion to Compel, with the Court stating that it would "grant these motions as they are relevant to this case directly" (emphasis in original).

Compelling information from third parties during litigation is not a new phenomenon: in xLayzur & Krix v. Politico [2023] FCR 62, a subpoena was issued to a third party (Milkcrack) and the Federal Court did obtain information using it, even denying a motion to reconsider regarding the validity and scope of the subpoena. And it's not a behavior limited to the Federal Courts; the Supreme Court, in SCR 1 [2025] The Patriotic Coalition of Redmont v. The Commonwealth of Redmont, even ordered a non-party (a former State Secretary) to compel the production of relevant documents with guidance to treat such an order as a "subpoena".

As such, this process to subpoena third parties is well established. Reading all this in concord, the use of "a party" in the motion guide's statment describing a Motion to Compel as "[a] request for the court to order a party to produce requested documents or information, or to sanction them for failing to comply with discovery requests" would appear to include third parties. That the narrower sense of the term "a party" as one would use in the terms "named parties" or "litigation parties" does not apply to the recipient of the subpoena would not be relevant here in light of Court precedent, and barring this subpoena on procedural grounds would be a mistaken reading.

Given that the information is relevant to our defenses here, and the Federal Court has previously granted like motions when "relevant to this case directly", The Exchange, Inc. asks that this objection be overruled and that the subpoena be granted.

 
I would like to briefly reassure all parties that your objections and motions have been noted. A reply is forthcoming, but due to the nature of the case, significant research is required. I shall endeavor to have a continuation of this case shortly. My apologies for the wait.
 
The Plaintiff moves to extend Discovery such that it shall end 5 days after the Court responds to all outstanding matters.
 

Motion


IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
MOTION FOR CLOSED COURT

Your Honor,

The Defense wishes to submit evidence that contains potentially sensitive information regarding individual account owners and their balances. In Bank and Trust of Redmont v. Commonwealth of Redmont [2021] SCR 8, the Supreme Court has stated the longstanding precedent that “The court believes that there needs to be a reasonable expectation to privacy, notably in regards to the customer's finances.”

In order to reasonably protect privacy of The Exchange, Inc.’s depositors and other customers while also permitting the Court to examine evidence relevant to our Defense, the Defendant requests a closed court session to submit evidence related to customer account balances and/or loan balances.

 
Franciscus said:

Motion


IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
MOTION FOR CLOSED COURT

Your Honor,

The Defense wishes to submit evidence that contains potentially sensitive information regarding individual account owners and their balances. In Bank and Trust of Redmont v. Commonwealth of Redmont [2021] SCR 8, the Supreme Court has stated the longstanding precedent that “The court believes that there needs to be a reasonable expectation to privacy, notably in regards to the customer's finances.”

In order to reasonably protect privacy of The Exchange, Inc.’s depositors and other customers while also permitting the Court to examine evidence relevant to our Defense, the Defendant requests a closed court session to submit evidence related to customer account balances and/or loan balances.

Click to expand...
Plaintiff requests a response to this motion.
 
gribble19 said:
Plaintiff requests a response to this motion.
Click to expand...

Objection


IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
OBJECTION - BREACH OF PROCEDURE

Under Rule 6.6 (Response Times), the "standard set of response times" for Objections is 24 hours, for items in the "Answer to Complaint & Plea" stage is 48 hours, and in no circumstance is a standard response time longer than 72 hours. However, here a privilege to respond to this motion was granted over 82 hours ago, and neither has a response has been proffered nor an extension requested.

As such, the Defense asks that this response not be granted and that the motion be rule on, treating the failure to file a response as a forfeiture of the privilege to file, in line with the failure to adhere to standard response time guidance by the Plaintiff here.

 
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