Lawsuit: Pending jsrkiwi v Department of Homeland Security [2025] DCR 93

[jsrkiwi]

Case Filing

IN THE DISTRICT COURT OF THE COMMONWEALTH OF REDMONT

CIVIL ACTION

jsrkiwi
Plaintiff

v.

Department of Homeland Security
Defendant

COMPLAINT
The Plaintiff complains against the Defendant as follows:

WRITTEN STATEMENT FROM THE PLAINTIFF

The Department of Homeland Security issued multiple trespass fines against the Plaintiff without evidence of lawful prior instructions. The decision is unlawful, procedurally unfair, unsupported by evidence, and has resulted in an unjust fine and an improper criminal record entry. The Plaintiff seeks to have the decision overturned and the record cleared.

Beyond the findings against the Plaintiff personally, this case addresses a recurring defect in DHS enforcement. Multiple citizens have been charged with trespass on the basis of the same “ban-list book” method used by the citizen complainant, Vernicia. Each of those cases suffers from identical procedural failures: no proof of service of non-trespass instructions, no confirmation that the accused ever received any instructions, and no evidence establishing when the alleged notice was created. These errors are systemic, not isolated, and I therefore seek relief that corrects my own charges and any other trespass findings that relied solely on this same unlawful evidentiary practice.

I. PARTIES
1. jsrkiwi: Plaintiff, a citizen subject to DHS enforcement actions.
2. Department of Homeland Security: Defendant, the government body responsible for determining guilt for summary criminal offences, arresting and imprisoning criminals, issuing fines and record entry challenged in this action.
3. Plaintiff also challenges a broader DHS pattern of issuing trespass charges based on the same defective “ban-list book” method. Additional affected individuals will be added to the witness list as discovery proceeds.
4. Vernicia: Witness, citizen complainant in all relevant trespass cases and creator of the “ban-list books” forming the basis of the charges challenged in this action.
5. Goldendude15: Witness, the Police Officer who handled the complaint by Vernicia, created the criminal record, and fined the Plaintiff.
6. Roryyy_: Witness, Secretary of the Department of Homeland Security.

II. FACTS
1. On 13th November 2025, the Department of Homeland Security (DHS) created a criminal record for the Plaintiff, listing five trespass offences at locations c108 and c995.
2. On 13th November 2025 at 10:37 UTC, the Plaintiff was fined $2,900 for ‘Trespass x5 (First, Second, and Subsequent charges)’; and a wanted point was created for 35 minutes imprisonment.
3. The supporting evidence for the criminal record was five screenshots provided by Vernicia through ticket dhs-25341. These screenshots show:
(i) Sales records showing the sale of coal blocks by the Plaintiff to Vernicia at ‘14h24m ago’;
(ii) The third page of the book outside of one of the entrances to c995. The page is titled ‘ban list’, and the name of the Plaintiff is listed on the third line from the bottom;
(iii) Sales records showing the sale of 27 iron blocks at ‘1d11h23m ago; 300 coal blocks by the Plaintiff to Vernicia at ‘1d12h38m ago’; and the sale of 960 coal by the Plaintiff to Vernicia at ‘1d12h40m ago’.
(iv) Sales records showing the sale of 65 redstone blocks by the Plaintiff to MZCD at ‘11-11-2025 17:13:50’; the sale of 64 redstone by the Plaintiff to MZCD at ‘11-11-2025 17:13:39’; the sale of 66 lapis blocks by the Plaintiff to MZCD at ‘11-11-2025 17:13:30’; and the sale of 116 lapis lazuli by the Plaintiff to MZCD at ‘11-11-2025 17:13:07’.
(v) Sales records showing the sale of 3 iron blocks to MZCD at ‘11-11-2025 16:47:02’.
4. Only one screenshot includes a timestamp: 13 November 2025 at 05:12 (CET). Two others show indirect metadata; two show none.
5. No evidence is held by the DHS that the book outside c995 was updated to include the Plaintiff’s name prior to the Plaintiff transacting on the plots.
6. No instructions or notice banning the Plaintiff from a property has ever been served upon the Plaintiff by Vernicia. The Plaintiff had no reason to believe that he was banned from entering plots c108 or c995.
7. Plaintiff accessed both properties c108 and c995 exclusively by warp (‘/home vernicia’ and ‘/home mzcd’) and did not walk through the entrance, meaning the book shown in the second screenshot was never visible to him.
8. The property owner (Vernicia) has personally observed Plaintiff warping into c995 before and therefore knew Plaintiff would not see any book.
9. The books outside c108 and c995 do not specify what the ban relates to.
10. Plaintiff has knowledge from his work as a Police Trainee of the existence several other individuals who were charged with trespass at properties owned or controlled by the same private citizen, Vernicia.
11. In each of these cases, the method of ‘instruction’ was identical: reliance on a book placed at the property entrance, with no proof of service and no confirmation that the accused ever saw it.
12. In each of these cases, the ‘proof’ used by the DHS to support the conviction of Trespass is identical: a screenshot of the book showing the accused’s name, and a screenshot showing sales records. In each case, there is no evidence that any instruction was properly served by Vernicia to any of the accused individuals, or that the book was updated prior to the sales taking place.
13. The similarity of fact patterns across multiple cases indicates that DHS applied an unofficial, and unlawful low standard specifically when handling trespass complaints originating from Vernicia.
14. At 14:37 UTC on 13th November 2025, The Plaintiff attempted to dispute the charges through a government ticket (dhs-25445). As of 72 hours later, the DHS had not responded to the ticket and the decision remained uncorrected. At 15:47 UTC on 16th November 2025, with the ticket having become the oldest charge-dispute ticket on the DHS tickets list, the Plaintiff closed the ticket, and now files this action.

III. CLAIMS FOR RELIEF
1. Under the Criminal Code, a person commits the offence of Trespass if the person enters or remains in a non-public or restricted area against instructions’; or ‘is a landlord and enters a tenant's region without reasonable prior notice, unless an exemption applies’.
2. The ‘ban-list’ book relied upon by DHS does not constitute a valid instruction under any reasonable interpretation of the Criminal Code, as it provides no description of the conduct prohibited, no proof of service, and no confirmation that the Plaintiff ever received or could have received the alleged notice.
3. Even if the book were capable of constituting a lawful instruction, DHS possesses no evidence that the book was updated to include the Plaintiff’s name prior to his entry into plots c108 and c995, rendering any alleged instruction void for lack of temporal proof.
4. DHS acted arbitrarily and capriciously by issuing criminal findings without any reliable evidence that valid instructions were ever given, and by treating a book placed at an entrance, which the Plaintiff never uses, as if it constituted proper notice, despite there being no proof of service or receipt.
5. DHS relied on ambiguous evidence, as the ‘ban list’ book does not state what the ban relates to, making it legally insufficient to constitute a criminal instruction.
6. DHS therefore violated the administrative due-process principles applicable to agency decisions and exceeded its lawful authority.
7. DHS has engaged in selective enforcement, as demonstrated by multiple individuals being found guilty for Trespass, reliant on identical fact patterns linked to the same citizen complainant, indicating the presence of an unlawful or improperly supervised internal practice.
8. The systemic nature of the problem justifies class-wide administrative relief, as all individuals previously charged using the same defective evidence suffered the same due-process violation.

IV. PRAYER FOR RELIEF
The Plaintiff seeks the following from the Defendant:
1. An order vacating in full the DHS trespass decision against the Plaintiff, and reversing all findings of guilt;
2. An order expunging any related criminal record entry;
3. A refund of $2,900 for the fine imposed against the Plaintiff;
4. A declaration that ‘ban list’ books do not constitute lawful instructions for the purposes of the crime of Trespass, unless properly served to the individual;
6. An order requiring DHS to vacate all prior trespass findings in which the only evidence of ‘instruction’ was a book placed at a property entrance owned or controlled by Vernicia.
7. An order compelling DHS to review and reform its evidentiary and notice standards to prevent recurrence of these unlawful practices.
8. A declaration that DHS’s historical acceptance of these methods constitutes procedural unfairness affecting multiple citizens.
9. Legal fees of $2,000.

V. EVIDENCE ATTACHED
P-001. Criminal record of jsrkiwi (obtained from the DHS).
P-002. Government ticket DHS-25445, through which the Plaintiff attempted to appeal his Trespass conviction.
P-003, P-004, P-005, P-006, P-007. The screenshots that are included as evidence in the criminal record (P-001).
P-009, P-010, P-011, P-012, P-013. Screenshots showing the content of the ‘ban list’ book outside c995, at 16:15 UTC on 13th November 2025.
P-014, P-015, P-016, P-017, P-018. Screenshots showing the content of the ‘ban list’ book outside c108, at 16:18 UTC on 13th November 2025.
P-019, P-020. Screenshots showing the placement of book outside c995.
P-021, P-022. Screenshots showing the placement of the ‘ban list’ book outside c108.

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 16th day of November 2025

 

[jsrkiwi]

Motion

IN THE DISTRICT COURT OF THE COMMONWEALTH OF REDMONT

EMERGENCY MOTION FOR INTERIM ORDER BARRING ARREST AND IMPRISONMENT OF THE PLAINTIFF PENDING RESOLUTION OF THIS ACTION

The Plaintiff respectfully moves this Court, on an emergency basis, for an immediate interim order prohibiting the Department for Homeland Security (“DHS”) from arresting and imprisoning the Plaintiff until the final disposition of this civil action.

1. The DHS has issued a criminal record entry and imposed a custodial penalty of 35 minutes’ imprisonment arising from the trespass findings currently under challenge in this proceeding.
2. The validity of those findings is the direct subject of this litigation, and the Plaintiff seeks their full vacatur.
3. Executing any term of imprisonment before the Court has determined the lawfulness of the charges would irreparably prejudice the Plaintiff, as the harm of an imposed custodial sentence cannot be reversed once carried out.
4. The Plaintiff has acted in good faith by filing this action promptly after the DHS failed to address the dispute ticket (DHS-25445), and the matter is now properly before the Court.
5. Interim relief is necessary to preserve the Court’s ability to grant effective final relief and to prevent the Plaintiff from suffering an irreversible penalty in respect of charges that may be found unlawful.
6. The requested order imposes no prejudice on the Defendant, as it merely maintains the status quo until the Court adjudicates the underlying dispute.

RELIEF REQUESTED
The Plaintiff therefore respectfully requests that the Court issue an order:
1. Prohibiting the DHS from arresting or imposing any custodial sentence upon the Plaintiff arising from the trespass findings currently under challenge; and
2. Maintaining this prohibition until final judgment is entered in this case.

 

[Muggy21]

Writ of Summons

@Attorney General , is required to appear before the District Court in the case of jsrkiwi v Department of Homeland Security [2025] DCR 93

In the interest of more efficient Courtroom proceedings, the Court will permit responses to motions without prior Court permission. The deadline for said motions shall be 48 hours.

Furthermore, in obedience with Rule 1.4, parties are advised that engaging in conduct that obstructs or interferes with the administration of this Court or its proceedings may be held in Contempt of Court.

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.

 

[Muggy21]

Motion

IN THE DISTRICT COURT OF THE COMMONWEALTH OF REDMONT

EMERGENCY MOTION FOR INTERIM ORDER BARRING ARREST AND IMPRISONMENT OF THE PLAINTIFF PENDING RESOLUTION OF THIS ACTION

The Plaintiff respectfully moves this Court, on an emergency basis, for an immediate interim order prohibiting the Department for Homeland Security (“DHS”) from arresting and imprisoning the Plaintiff until the final disposition of this civil action.

1. The DHS has issued a criminal record entry and imposed a custodial penalty of 35 minutes’ imprisonment arising from the trespass findings currently under challenge in this proceeding.
2. The validity of those findings is the direct subject of this litigation, and the Plaintiff seeks their full vacatur.
3. Executing any term of imprisonment before the Court has determined the lawfulness of the charges would irreparably prejudice the Plaintiff, as the harm of an imposed custodial sentence cannot be reversed once carried out.
4. The Plaintiff has acted in good faith by filing this action promptly after the DHS failed to address the dispute ticket (DHS-25445), and the matter is now properly before the Court.
5. Interim relief is necessary to preserve the Court’s ability to grant effective final relief and to prevent the Plaintiff from suffering an irreversible penalty in respect of charges that may be found unlawful.
6. The requested order imposes no prejudice on the Defendant, as it merely maintains the status quo until the Court adjudicates the underlying dispute.

RELIEF REQUESTED
The Plaintiff therefore respectfully requests that the Court issue an order:
1. Prohibiting the DHS from arresting or imposing any custodial sentence upon the Plaintiff arising from the trespass findings currently under challenge; and
2. Maintaining this prohibition until final judgment is entered in this case.

Court Order

IN THE DISTRICT COURT OF THE COMMONWEALTH OF REDMONT
TEMPORARY INJUNCTION - WRIT OF MANDAMUS


Until such a time an Order is given from this Court, the Department of Homeland Security is enjoined from arresting p:jsrkiwi on the Offense of Trespass entered on 13th November, 2025; If there be a discrepancy between the time in the Complaint and the local time of any DHS official, the record entered by Goldendude15 shall not be made effective. This Order does not bar DHS from enforcing any other law nor offense undertaken by Plaintiff.

This order applies to all Law Enforcement Officers of the Department of Homeland Security. If Plaintiff is arrested after 17:14 EST on November 16th, 2025, the Court will use its contempt powers.

So ordered,
Magistrate Mug.

 

[Franciscus]

Writ of Summons

@Attorney General , is required to appear before the District Court in the case of jsrkiwi v Department of Homeland Security [2025] DCR 93

In the interest of more efficient Courtroom proceedings, the Court will permit responses to motions without prior Court permission. The deadline for said motions shall be 48 hours.

Furthermore, in obedience with Rule 1.4, parties are advised that engaging in conduct that obstructs or interferes with the administration of this Court or its proceedings may be held in Contempt of Court.

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 Commonwealth.

 

[Muggy21]

Your Honor,

I am present on behalf of the Commonwealth.

Thanks. The CW shall have 48 hours to offer an Answer.

 

[Franciscus]

Court Order

IN THE DISTRICT COURT OF THE COMMONWEALTH OF REDMONT
TEMPORARY INJUNCTION - WRIT OF MANDAMUS


Until such a time an Order is given from this Court, the Department of Homeland Security is enjoined from arresting p:jsrkiwi on the Offense of Trespass entered on 13th November, 2025; If there be a discrepancy between the time in the Complaint and the local time of any DHS official, the record entered by Goldendude15 shall not be made effective. This Order does not bar DHS from enforcing any other law nor offense undertaken by Plaintiff.

This order applies to all Law Enforcement Officers of the Department of Homeland Security. If Plaintiff is arrested after 17:14 EST on November 16th, 2025, the Court will use its contempt powers.

So ordered,
Magistrate Mug.

Motion

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

Your Honor,

The order is a bit tricky to enforce; I can ping everyone in the DHS to see if they got the message, but I worry that someone may miss a ping or just have a lapse of mind.

To prevent a lapse of mind or otherwise, the Commonweallth would ask that the DHS directed to do as follows:

1. Archive the existing crime record, removing the wanted star.
2. At the conclusion of the case, the DHS may create a new crime record for the trespass unless the Court orders otherwise.

This would remove the wanted star for the duration of the case, which would make it so that the individual does not appear wanted to DHS officers. At the end of the case, the DHS would be permitted to create the wanted point anew, thereby allowing us to enforce the imprisonment at an appropriate time absent an order from Your Honor.

 

[Muggy21]

Motion

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

Your Honor,

The order is a bit tricky to enforce; I can ping everyone in the DHS to see if they got the message, but I worry that someone may miss a ping or just have a lapse of mind.

To prevent a lapse of mind or otherwise, the Commonweallth would ask that the DHS directed to do as follows:

1. Archive the existing crime record, removing the wanted star.
2. At the conclusion of the case, the DHS may create a new crime record for the trespass unless the Court orders otherwise.

This would remove the wanted star for the duration of the case, which would make it so that the individual does not appear wanted to DHS officers. At the end of the case, the DHS would be permitted to create the wanted point anew, thereby allowing us to enforce the imprisonment at an appropriate time absent an order from Your Honor.

That's fine, I'll amend my order to DHS to the above.

 

[Franciscus]

That's fine, I'll amend my order to DHS to the above.

Your Honor:

The order has been executed.

 

[Franciscus]

Motion

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

Your Honor,

The Commonwealth seeks to dismiss the eighth alleged claim for relief on the basis of Rule 5.5 (Lack of Claim) and Rule 5.12 (Lack of Personal Jurisdiction).

III. CLAIMS FOR RELIEF

...

8. The systemic nature of the problem justifies class-wide administrative relief, as all individuals previously charged using the same defective evidence suffered the same due-process violation.

IV. PRAYER FOR RELIEF
The Plaintiff seeks the following from the Defendant:

...

6. An order requiring DHS to vacate all prior trespass findings in which the only evidence of ‘instruction’ was a book placed at a property entrance owned or controlled by Vernicia.

1. So-called "class-wide administrative relief" involving unnamed parties fails to state a claim for relief under the law.​

In the eighth alleged claim for relief, which is quoted above, the Plaintiff is seeking "class-wide administrative relief", praying that the which the DHS be ordered to vacate "all prior trespass findings" of unnamed parties that were created from a particular evidentiary pattern.

There is not statute that permits this, nor may the Courts grant it. The Federal Court has been fairly unequivocal about this.

1a. The Courts cannot grant class-wide administrative relief without an enabling statute present.​

Can Courts grant class-wide administrative relief without enabling legislation? The Federal Court has been clear: No.

As the Federal Court has noted in Privacy Matters v. Nexalin [2025] FCR 36: "Establishing a procedure robust enough to handle a class of people in a lawsuit would be substantial to a point of encroaching upon the powers of the legislative. See Constitution § 2(1)."

In other words: if we are going to have lawsuits that grant class-wide relief that affects people other than named parties, the legislature would need to act. It would be unconstitutional for the Court to create, as a matter of common law or otherwise, some sort of class action procedure to grant relief to anyone other than the named plaintiffs.

As the Federal Court has appeallate jurisdiction over the District Court, and also has original jurisdiction over questions of constitutionality (see: Article 18 of the Constitution), this precedent on constitutionality binds the District Court.

1b. No applicable statutory authority exists for class-wide administrative relief.​

Does statutory authority exist in this context for class-wide administrative relief? The answer is clear: No.

As the Federal Court noted in Privacy Matters v. Nexalin [2025] FCR 36 "[t]here is no statutory authorization for establishing 'classes' of people in a case". While multiple Plaintiffs may join themselves together to file against a defendant as if they were one single entity, there is no means to certify a broad class present in the law - no class action procedure exists in statute that would apply here."

The Plaintiff has not asserted a statute which permits them to seek class-wide administrative relief, and the Commonwealth cannot find one. There is one Plaintiff here, not many; the only claims for relief that the Plaintiff may seek are redress for actions which have harmed the Plaintiff (see, for example . Absent a contrary showing, the Court should find that no claim for relief here arises from statutory text.

2. The Plaintiff lacks personal jurisdiction to seek class-wide administrative relief.​

Standing, in Redmont, is a three point test defined under Court Rule 2.1. As summarized by the Supreme Court in ToadKing v. Commonwealth of Redmont [2025] SCR 19:

Standing consists of three elements. First, the individual must have suffered an injury caused by a clearly identifiable second party or affected by an application of law. Second, the cause of the injury must be unlawful. Third, the injury must be capable of being remedied by a favorable decision under the relevant law.

The Plaintiff fails to meet the first element of standing as it pertains to the eighth prayer for relief. Simply put: the Plaintiff does not suffer injury when unnamed third parties are charged with trespass, and is not affected by an application of the law when unnamed third parties are charged with trespass. The Plaintiff therefore lacks standing for such a broad prayer for relief as it pertains to unnamed third parties, warranting dismissal of the claim under Rule 5.12.

3. Conclusion: The District Court should dismiss the eighth claim for relief and its associated prayers.​

Under Rule 5.5, "failure to state a claim for relief" may warrant dismissal. As noted above, a statutory authorization would be required for class-wide administrative relief to be granted, but no such authority exists in statute. The eighth claim for relief lacks legal basis under the law, and should be dismissed on this basis.

Separately, under Rule 5.12, dismissal is warranted when "the plaintiff fails to have sufficient standing in order to pursue the case". As established above, the Plaintiff fails the first prong of the standing test under Rule 2.1 as it pertains to claims for relief on behalf of unnamed third parties; this independently warrants dismissal of the claim.

Therefore, the defense humbly prays that this Court strike the eighth claim for relief, as well as any prayers for relief which rest wholly thereupon.