Lawsuit: In Session Multiman155 v. Federal Reserve Bank [2026] DCR 29

Well given that we're 48 hours from the notification and there still is no response, I will move the case to opening statements. Given the complexity of the case, I will give 120 hours for closing statements but I will not mandate a particular writing style.
 
Your Honor, the DOJ requests a brief recess in order to properly transfer this case to another employee. We sincerely apologize for the inconvenience, and we'd be happy to provide a proper explanation if needed.
 
Mask3D_WOLF said:
Your Honor, the DOJ requests a brief recess in order to properly transfer this case to another employee. We sincerely apologize for the inconvenience, and we'd be happy to provide a proper explanation if needed.
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Your Honor,

Plaintiff opposes this request. This case has dragged on repeatedly and has now lasted for over 4 months since the initial filing. Much of the recent delay can be attributed to lack of action by Defendant.

Plaintiff instead requests that we continue to move ahead with closing statements and that the recess not be given.
 
Mask3D_WOLF said:
Your Honor, the DOJ requests a brief recess in order to properly transfer this case to another employee. We sincerely apologize for the inconvenience, and we'd be happy to provide a proper explanation if needed.
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Well, you have the remaining time during the Plaintiff's closing statement + the 120 hours you'll get for the Defendant's closing statement, and whatever extension that your side may request to transfer this case. So I don't see any reason to provide a recess.
 
Matthew100x said:
Well given that we're 48 hours from the notification and there still is no response, I will move the case to opening statements. Given the complexity of the case, I will give 120 hours for closing statements but I will not mandate a particular writing style.
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Your Honor,

Plaintiff requests an 18-hour extension to permit me the full day tomorrow to finalize my closing statement.
 

Closing Statement


IN THE DISTRICT COURT OF THE COMMONWEALTH OF REDMONT
CLOSING STATEMENT

Multiman155
Plaintiff

v.

Federal Reserve Bank,
Defendant
​

Your Honor:

This case begins with a simple public duty. The Federal Reserve Bank received a valid Freedom of Information request. The law required a response within seven days. The FRB gave none. It did not approve the request, deny it as unreasonable, nor provide any other response authorized by the Classified Materials Act. It remained silent. That proves Failure to Respond to Freedom of Information and Failure to Perform Statutory Duty.

The trial record also proves that the eventual response was materially incomplete. The FRB adopted a narrow interpretation of the request and excluded communications about the announcement, its draft and template, staff authorization, Board approval, vendor proposals, and the mandatory implementation of Compliant. Those records bear directly on what the supposed “decision to transition to Compliant” was, whether the Board made it, and what FRB officials understood it to require.

This case now proceeds against the Federal Reserve Bank alone. The Court dismissed DonTrillions and expressly ordered that proceedings continue against the FRB. See Post No. 38. Below, Plaintiff lays out the factual and legal basis for claims against the FRB that were raised in the amended complaint. On those claims, the Court should enter judgment for Plaintiff.

I. The controlling facts are admitted and independently proven​

The FRB’s Answer affirmed the announcement, the public petition, the material facts of ticket #96, the legal duty to respond, the absence of a response within seven days, and the absence of a response before suit. It also affirmed that Plaintiff operates the bLAWg as a news organization. See Post No. 12.

The Defense later affirmed the four amended facts it had not answered. Those facts include that ElysiaCrynn and FloorIsTired discussed deletion of Compliant material and, most importantly, that after receipt of ticket #96 and before responding, the FRB or its agents deleted messages potentially responsive to the request. See the amended facts and exhibits in Post No. 44 and the Defense’s affirmation in Post No. 189. The Court preserved the procedural issue for possible appeal in Post No. 190, but the present trial record contains that affirmation.

The independent evidence establishes the same core timeline. On February 25, 2026, the FRB publicly announced that financial institutions would be required to transition to Compliant. That day, Plaintiff filed ticket #96 and requested “all communications regarding the decision to transition to Compliant,” including FRB communications with Redmont Group, communications on the FRB server, and other records in the FRB’s possession. Exhibit P-022 contains the ticket.

No response came within seven days. Exhibit P-022 shows approval on March 7, ten days after submission. It also shows a later request for another thirty days and that the FRB eventually marked the request complete on March 29.

jJoshuaTheGreat, also known as coshjlose, confirmed the essential facts. He held the positions of Lieutenant Governor and Head of Accounting, had access to ticket #96, became aware of it on or about February 25, referred it to the Board and Governor, and identified no response during the first seven days. He testified that the Governor approved it on March 7. See Post No. 131. Kaiserin_ likewise testified that, to her knowledge, the DOJ had no involvement before the deadline and prepared no response before it expired. See Post No. 135.

The basic violation is therefore not a matter of inference. It is admitted, documented, and confirmed by the FRB official who handled the request.

II. The FRB failed to respond to a valid FOI request​


Under the Redmont Civil Code Act, Part XI, Section 2, Failure to Respond to Freedom of Information is a strict-liability violation. It occurs when a person unreasonably delays or fails to respond to a valid FOI request within the time prescribed by law. The authorized relief includes up to 50 Civil Penalty Units and a writ of mandamus.

The Classified Materials Act, Section 8(2), supplies the deadline and the required form of response. Within seven days, the government must indicate either approval and eventual release or denial because the request is unreasonable. Section 8(6) separately requires compliance with every reasonable request to the fullest extent possible, including partial release, redaction, or summary when full disclosure would be unlawful or harmful.

Every element is satisfied. The request identified a specific subject, named likely locations and participants, and sought records held by the FRB. The FRB never denied it as vague, overbroad, outside its jurisdiction, or otherwise unreasonable. Indeed, it eventually approved the request. Yet it gave neither approval nor denial within seven days.

The Defense has pointed to the Governor’s absence, the FRB’s workload, and the size of the request. Those facts may explain the failure. They do not change it. The statute required an approval or denial within seven days. If collection required more time after approval, the FRB could explain that timetable. If it considered the request unreasonably broad, it could deny it on that ground or work with Plaintiff to narrow it. What it could not do was remain silent past the statutory deadline.

Later action did not erase the completed violation. Otherwise, an agency could ignore the deadline, wait for litigation, produce something later, and make the seven-day rule meaningless. "Remedial action taken only under compulsion of judicial process does not constitute the voluntary good faith the Commonwealth claims". Yeetglazer v Commonwealth of Redmont [2025] FCR 67, Order of the Court, Section I, Par. 4.

Plaintiff need not prove corrupt motive, intentional concealment, or any deletion to prevail on this claim. A valid request was filed. A response was legally required. No response was given in time. The Court should find the FRB liable and impose the statutory civil penalty.

III. The FRB failed to perform its statutory duties​


Under RCCA Part XI, Section 7, a person commits Failure to Perform Statutory Duty when it fails to perform a duty required by law and that failure causes harm to the plaintiff, unless circumstances beyond the defendant’s control caused the failure.

The FRB had three related duties. The Classified Materials Act required a response within seven days. It required compliance with a reasonable request to the fullest extent possible. The Federal Reserve Act, Section 4(2)(c), separately requires the FRB to “be transparent about its operations,” limited only by reasonable adverse effects of transparency.

The FRB breached those duties. It gave no timely response. It later marked the request complete without producing substantial records bearing on the subject. No witness identified a classification, confidentiality rule, national-security concern, or other lawful barrier that prevented timely approval, partial production, redaction, or summary.

The failure was negligent. A reasonable government body receiving a statutory request would at least track the deadline and issue the approval or denial that the Act requires. The FRB instead allowed the entire period to expire without action. Workload and internal absence are conditions the FRB had to manage; on this record, they were not external circumstances that made any response impossible.

The failure caused harm. Timely access to public information is the interest the statute protects. Depriving Plaintiff of that access is itself an informational injury. The record also establishes a concrete public use for the information: the Answer admits that Plaintiff operates a news organization, while EATB’s testimony shows that the announcement prompted legislative concern about mandatory daily reporting and the absence of a Board vote. See Post No. 139. The delay denied Plaintiff the ability to examine the FRB’s records while that controversy was active.

The Defense’s suggestion that Plaintiff could have conducted interviews misses the point. A possible substitute for government records does not eliminate the statutory right to obtain the records themselves. The Court should find Failure to Perform Statutory Duty and issue related relief.

IV. The FRB’s eventual response was materially incomplete​


Exhibit P-022 contains ticket #96 and the material placed into the ticket. Exhibit P-023 is the FRB #compliant channel transcript attached to the response. The FRB marked that response complete. The testimony permits a direct comparison between what was produced and what the FRB possessed or could access.

jJoshuaTheGreat explained the FRB’s method. He treated a record as responsive only if it reflected “the Board’s decision to use Compliant.” He excluded material that he classified as implementation or announcement language. He testified that the AI-generated announcement template and communications about creating and transmitting it were absent from P-022 and P-023. He gave the same answer for Floor-01 and Floor-03. He confirmed that EmmDubz-02 and EmmDubz-03 were absent, that only part of EmmDubz-01 appeared in P-022, and that none of those direct messages appeared in P-023. He also testified that he did not request records from EmmDubz before marking ticket #96 complete. See Post No. 167, Q36.

That testimony identifies the method of nonproduction. The request did not ask only for a final Board vote. It asked for all communications "regarding the decision to transition to Compliant," which specifically included conversations between Defendant and Redmont Group, conversations on the FRB server regarding the decision to transition, and "other records" regarding the subject matter. See Exhibit P-003. A communication about who authorized the announcement, whether Compliant would be mandatory, whether the Board had acted, or what proposal would be taken to the Board is a communication regarding that decision.

The strongest omissions cannot reasonably be dismissed as technical details.

ElysiaCrynn testified that neither the announcement draft nor the deleted announcement appeared in P-022 or P-023. She identified omitted management-compliance discussions about the initial draft, mandatory use, possible exemptions, eventual automation requirements, implementation, rollback, and the absence of a Board vote or decision. See Post No. 142. She later testified that jJoshua approved the transition notice, worked on its drafting, and discussed Compliant’s mandatory nature and implementation in a way that led FRB staff to believe a Board decision had been made. See Post No. 153. Those communications directly concern the existence and meaning of the asserted decision.

FloorIsTired testified that the template, Floor-01, and Floor-03 were absent from P-022 and P-023, and that his Google Doc draft was absent from P-022. Floor-01 addressed his authority to announce adoption; Floor-03 addressed his discovery that the policy lacked a Board vote or approval. See Post No. 143. He later testified that his Google Doc existed before Exhibit P-001, was related to the template, and reflected jJoshua’s approval of framing the announcement around onboarding and possible reserve-interest consequences. See Post No. 159.

EmmDubz identified further omissions. EmmDubz-02 included the software options, pricing, subscription terms, and jJoshua’s statement that he would bring the proposal to the Board. EmmDubz-03 addressed a twelve-month commitment, an early-termination term, and monthly interest reporting. None appeared in P-022 or P-023. See Post No. 150. Additional direct messages discussed requested features and interest logic. See Post No. 154 and Post No. 155. The Court need not hold that every technical detail was independently responsive. The Board-proposal communications and commercial terms are enough to show that material bearing on the decision was omitted.

The FRB’s reading would allow an agency to disclose a final “yes” while withholding the communications that show what was proposed, who authorized it, whether approval existed, and what the decision meant. That is not compliance to the fullest extent possible. The response was late and materially incomplete. Mandamus remains necessary.

V. Public misconduct claims​

Where a wrong constitutes both a crime under the Criminal Code and a violation under the Civil Code, a Plaintiff may pursue civil damages arising from both the crime and the civil violation, provided that there is no double recovery for the same loss. See RCCA, Part II, Section 4(3).

As such, we allege both Abuse of Power under the Criminal Code and Misfeasance in Public Office under the Civil Code, and seek civil recovery for them. We refer to these as the "Public misconduct claims", as they are closely related so as to not be separately cognizable in this factual record. We seek "the provision more favourable to the plaintiff’s rights to seek a remedy". RCCA, Part II, Section 4(4).

V.I. Factual background related to the public misconduct claims​

The Court has already resolved the central audit-log issue. It found a D-001 entry showing a deletion by coshjlose in the channel where Exhibit P-001 appeared and inferred that the entry showed deletion of that announcement. See Post No. 104. jJoshuaTheGreat/coshjlose then testified without qualification: “I deleted the announcement.” See Post No. 131. EATB confirmed that the announcement had disappeared by the time the Senate motion was prepared. See Post No. 139.

The record must be precise about timing and knowledge. The Defense affirmed the amended fact that, after the FRB received ticket #96 and before it responded, the FRB or its agents deleted potentially responsive messages. jJoshua testified that he personally did not recall knowing about ticket #96 when he deleted the announcement. Those propositions can coexist: the institution had received the request even if the deleting official had not yet read it.

The evidence does not conclusively establish that every draft or template was deleted. Floor retained a private Google Doc, while jJoshua testified that he did not know where the draft was and knew of no preserved copy. Elysia believed a now-deleted channel or thread contained the draft and related discussion. The Court should therefore find what the record proves: the announcement was intentionally deleted; the FRB admitted deletion of potentially responsive messages after receipt of the request; related materials were omitted from the response; and at least some material was no longer available in ordinary FRB records.

V.II. Abuse of Power​

Under the Criminal Code Act, Part II, Section 1, a person commits Abuse of Power when that person exercises a power, function, or duty vested through public office or government-agency employment in contravention of law and either knows the exercise is unlawful or acts with reckless disregard for its lawfulness. As previously noted, RCCA Part II, Section 4 expressly permits civil damages arising from Criminal Code conduct and permits that theory to be pursued alongside an RCCA violation without double recovery.

First, jJoshua exercised official power. He was the FRB Lieutenant Governor and Head of Accounting. The message was authored by FloorIsTired, not jJoshua. Deleting another official’s message required administrative permissions that ordinary server users did not possess. jJoshua therefore deleted the announcement through power attached to his FRB position, not through any private capacity.

Second, that power was exercised in contravention of law. The FRA required the FRB to be transparent about its operations. The CMA required the FRB to comply with the pending request to the fullest extent possible. The Defense affirmed that potentially responsive messages were deleted after the FRB received ticket #96 and before it responded. The Court has identified the central deletion, and jJoshua has admitted performing it. The most reasonable reading of the combined record is that the deletion of the announcement formed at least part of the admitted course of deletion. The FRB then omitted the announcement and surrounding materials from the response.

Third, the evidence supports reckless disregard. jJoshua had access to ticket #96 and became aware of it on or about February 25, the same day as the request and deletion. He deliberately removed the public record at the center of the controversy. He testified that he focused on delaying the rollout and reducing confusion and did not consider other effects of deletion. See Post No. 131, Q20-21. An official with access to the FRB’s legal-request system cannot avoid recklessness by failing to check whether a request exists before deleting the central record concerning the same subject.

jJoshua’s stated reasons do not establish either statutory defense. A desire to reduce confusion may explain why he acted, but it does not show a good-faith assessment that deletion was lawful. Nor did he testify that he sought and reasonably relied on legal advice before deleting the announcement. The FRB could have left the original in place and posted a correction, issued a superseding notice, or preserved a copy while formally rescinding it. It instead removed the official post and later withheld the surrounding record.

The act was performed by an FRB official through FRB authority. The Court has already dismissed former co-Defendant DonTrillions on immunity grounds while directing that proceedings continue against the FRB. See Post No. 38. The FRB cannot receive the benefit of official immunity for its agents and then disclaim institutional responsibility for their official acts.

On the balance of probabilities, the FRB, through its agent, caused Plaintiff harm arising from Abuse of Power. The Court should enter judgment on that claim.

V.III. Misfeasance in Public Office​

RCCA Part XI, Section 3 requires Plaintiff to establish that a public official intentionally misused official power, that the misuse harmed Plaintiff, and that the official knew or ought to have known the conduct was unlawful.

jJoshua was a public official. He served as the FRB Lieutenant Governor and exercised authority within a public legal entity created by statute. His deletion of Floor’s announcement was intentional; he did not describe an accident, technical failure, or mistaken click. His use of administrative FRB permissions to remove an official announcement satisfies the exercise-of-power requirement.

That exercise was a misuse. The announcement purported to communicate a major FRB decision affecting every financial institution. When jJoshua concluded that its wording was poor and its rollout premature, the lawful and transparent course was to correct or supersede it while preserving the record. Deleting it frustrated the FRA transparency mandate and the FRB’s ability to comply fully with a pending FOI request. The later decision to exclude the announcement, draft, template, and authorization discussions compounded that misuse.

The misuse caused harm. Plaintiff sought the FRB’s records, including the communications around the decision, not merely words copied by a member of the public. The deletion prevented this announcement from being included in Plaintiff's lawfully sought FOI returns, which deprived Plaintiff of Plaintiff's statutory right.

Finally, jJoshua at least ought to have known the conduct was unlawful. He was a senior FRB official with access to ticket #96 and awareness of it on or about the date of deletion. Even accepting his testimony that he had not personally read the ticket at the exact moment, a senior official ought to know that deleting the principal record of a disputed public action risks defeating both the FRB’s transparency mandate and any pending request for records about that action. The "ought to have known" standard under RCCA Part XI, Section 3(c) exists precisely because an official cannot manufacture innocence by declining to consider the legality or foreseeable consequences of an intentional exercise of public power.

Every element is satisfied on the balance of probabilities. The Court should find that the FRB, through its official, caused Plaintiff harm arising from Misfeasance in Public Office.

VI. The principal defenses fail​

Eventual production does not defeat liability. The seven-day violation was complete before the first response, and the later production was incomplete.

The scope defense fails because the FRB read "regarding the decision" as though it meant “the final record of a Board decision.” The actual request was broader. Communications about whether approval existed, who authorized the announcement, what proposal would go to the Board, whether adoption was mandatory, and what staff were told all regard the decision.

Public availability of a screenshot does not cure nonproduction. Plaintiff requested FRB communications and records, not merely the words visible in the final announcement. Authorship, drafting, approval, context, and surrounding discussion are part of the requested record.

The harm defense also fails. The denial of timely statutory access is a real informational injury. The live public controversy, Plaintiff’s uncontested role as a news publisher, and the legislative response establish why timing mattered.

Finally, workload and absence do not establish circumstances beyond the FRB’s control. The FRB remained an operating public legal entity. It had officials, a Board, a ticket system, and the ability to conduct Compliant business. Nothing prevented it from issuing the approval or denial required by law.

VII. Relief​

Plaintiff respectfully requests the relief pleaded in the amended complaint at Post No. 1.

First, Plaintiff requests declarations that ticket #96 was valid; that the FRB committed Failure to Respond to Freedom of Information; that the FRB committed Failure to Perform Statutory Duty; that the later response was materially incomplete; and that the FRB, through its official, caused Plaintiff harm arising from Abuse of Power and Misfeasance in Public Office.

Second, Plaintiff requests the statutory civil penalty of up to 50 Civil Penalty Units for Failure to Respond to Freedom of Information.

Third, Plaintiff requests mandamus requiring the FRB to fully complete the request in ticket #96 by producing all responsive, non-exempt records held by or accessible to the FRB in the locations identified in the complaint. For anything withheld, the FRB should identify the category and specific legal ground. Where full disclosure is unlawful or harmful, it should provide partial release, redaction, or summary to the fullest extent possible.

Fourth, Plaintiff requests the pleaded preservation order preventing deletion, destruction, or alteration of remaining responsive Compliant-transition records.

Fifth, Plaintiff requests $7,500 in nominal damages for Failure to Perform Statutory Duty. The legal injury exists even if the Court finds no measurable economic loss.

Sixth, Plaintiff requests punitive damages in the amount of $25,000 for violations of the Criminal Code Act's prohibition on Abuse of Power and the Redmont Civil Code Act's prohibition of Misfeasance in Public Office. These are sought, in line with RCCA, Part III, Section 3.

Finally, as a pro se litigant, Plaintiff requests legal fees equal to 30% of the case value under RCCA Part III, Sections 7(2)(a) and 7(2)(h).

VIII. Conclusion​

The FRB had seven days to respond. It did not. That violation is admitted and independently proved.

When the FRB finally acted, it marked the request complete while omitting records that bore directly on the supposed decision: who authorized the announcement, whether the Board had acted, what staff understood, what proposal was taken to the Board, and whether the transition was mandatory. The official announcement was deliberately deleted, and the response omitted the surrounding record. Only under motion to compel in this courtroom were many of the relevant records produced for this case.

FOI rights cannot depend on whether an agency is busy, whether an official is absent, or whether litigation has begun. Nor may an agency narrow a request after the fact until only the records it prefers to disclose remain within scope. The law required a timely answer and compliance to the fullest extent possible. The FRB provided neither.

The Court should find for Plaintiff on Failure to Respond to Freedom of Information, Failure to Perform Statutory Duty, Abuse of Power, and Misfeasance in Public Office.

Plaintiff respectfully requests judgment and the full relief set out above.

 
Hi Matthew, hi Multi. I know I have another two days to get this done, but in all likelihood I'm going to need an extension on it while I ensure all our cases are properly assigned and looked after. I'll let y'all know closer to the deadline, but wanted to confirm the DOJ is aware and working on it :)
 
Hello, Attorney General Juniperfig here with a settlement offer.

I will give everyone in this case (lawyers, parties, judges) $2,500 each if you drop this case with prejudice.

If I don't hear back within an hour, I'll assume you want me to write a closing statement, and I will, and you will all actually have to consider it or else I can appeal. This is a threat.
 
Your Honour,

If it pleases the Court, I most respectfully seek leave to make a brief statement for the record. I am mindful that this matter is presently under recess and under the Court’s consideration, and I will of course abide by whatever direction the Court deems appropriate.

I wish only to place before the Court a matter that has weighed heavily upon the Federal Reserve Bank throughout these proceedings.

In my capacity of Governor of the Federal Reserve Bank, I have repeatedly attempted to contact the Department of Justice, our appointed counsel, to seek advice and direction regarding this case. Despite numerous efforts, since early-to-mid June, I have received no substantive response. To the best of my knowledge, our communications have simply gone unanswered.

Throughout this time, the Federal Reserve Bank remained under the sincere belief that the Department of Justice would continue to fulfil its role as counsel of record by responding to the Court’s orders and making the necessary filings on our behalf. The Bank did not intentionally disregard this Court or its directions. Rather, we continued to wait for guidance and representation that, despite our repeated attempts to obtain it, never came.

Accordingly, I humbly ask that, if the Court considers it appropriate, these circumstances be noted as part of the procedural history of this matter.


Further, should the Court deem it just and proper, I respectfully seek leave to represent the Federal Reserve Bank personally for the limited purpose of submitting a closing statement, so that the Bank may have an opportunity to be heard before judgment is rendered. I fully appreciate that the Court has already entered recess, and I make this request only out of concern that the Bank has not had the benefit of representation through no deliberate fault of its own.

Respectfully submitted,

jJoshuaTheGreat,
On behalf of the Federal Reserve Bank
 
Seeing as this case has not been picked up by another Judicial Officer while I was the Attorney General, I will resume this case. Given that we have a fully heard case and arguments have been submitted, this Court will enter recess and enter a verdict on this matter.
 

Motion


IN THE DISTRICT COURT OF THE COMMONWEALTH OF REDMONT

MOTION TO RECONSIDER

The Federal Reserve Bank moves for the Court to reconsider its order in Post #219 entering recess for the purpose of rendering a verdict, and in support thereof respectfully submits:

1. In Post #219, the Court stated that this matter is a "fully heard case" and that "arguments have been submitted," before entering recess to render a verdict.
2. Respectfully, the procedural record does not reflect that all arguments have been submitted.
3. In Post #213, following the Plaintiff's closing statement, the Court expressly ordered:

The Defendant has 120 hours to make their closing statement.
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4. No closing statement was subsequently submitted on behalf of the Defendant. The Court itself acknowledged this in Post #217:

The Defendant has failed to post a closing statement.
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5. Accordingly, the statement in Post #219 that "arguments have been submitted" appears inconsistent with the Court's own record. The Plaintiff has submitted closing arguments. The Defendant has not.
6. The Defendant respectfully submits that this failure did not result from an intentional waiver by the Federal Reserve Bank.
7. Rather, the docket reflects a breakdown in the Defendant's representation by the Department of Justice during the period immediately preceding the Defendant's closing deadline.
8. In Post #203, then-counsel for the Defendant informed the Court:

I am no longer employed at the DOJ. No one else at the DOJ is receiving notifications for this case.
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9. DOJ thereafter requested a recess in Post #205 "in order to properly transfer this case to another employee."
10. In denying that request, the Court expressly noted in Post #207 that DOJ would have the remaining period during the Plaintiff's closing statement, the Defendant's 120-hour closing period, and any extension it might request to facilitate the transfer of the case.
11. DOJ subsequently informed the Court is Post #208 that AmityBlamity would be taking over the case.
12. On July 15, in Post #214, the Attorney General confirmed that DOJ was aware of the Defendant'sclosing deadline and was working to ensure that its cases were properly assigned and handled.
13. On July 17, in Post #215, the Attorney General further indicated that, absent settlement, DOJ would prepare a closing statement.
14. No closing statement was ultimately filed.

RELEVANT CHANGE IN EXECUTIVE CIRCUMSTANCES

15. The Defendant further respectfully notes the unusual institutional circumstances under which this breakdown occurred.
16. During the pendency of this litigation, the Plaintiff, Multiman155, assumed the office of President of the Commonwealth of Redmont.
17. The Department of Justice is an executive department charged with defending the national legal interest, and its leadership and operation exist within the executive structure of government.
18. Following the Plaintiff's assumption of the Presidency, the Defendant experienced repeated changes in DOJ personnel and responsibility for this case. Counsel ceased communication with the Defendant. Counsel ceased acting, the Court was advised that no other DOJ employee was receiving case notification, DOJ requeted time to transfer the matter, replacement counsel was announced, and the promised defence closing statement was never filed.
19. The Defendant does not ask the Court, on the present record, to make any finding regarding motive, intent, or improper interference by the Plaintiff or any member of the executive government.
20. The Defendant does, however, respectfully submit that the sequence is relevant to determining whether the Federal Reserve Bank intentionally waived its right to be heard. The Bank was represented exclusively through an executive department whose handling of this litigation became unstable during a period in which the opposing party simultaneously held the Presidency.
21. At minimum, these circumstances demonstrate that the failure to complete the Defendant's case cannot fairly be attributed simply to inactivity or abandonment by the Federal Reserve Bank itself.
22. The Court record confirms that the Defendant's counsel expressly reported that no DOJ employee was receiving notifications for the case, after which DOJ sought time to transfer the matter to new counsel. The Plaintiff opposed that request and asked that proceedings move directly toward closing statements.
23. The Defendant respectfully submits that this institutional context makes it particularly important that judgment not be entered without first resolving the Defendant's outstanding request to complete its case.

INCOMPLETE DEFENCE PROCEEDINGS

24. The Defendant also respectfully notes that the evidentiary proceedings were not fully completed as originally contemplated. In Post #179, defence counsel expressly informed the Court that the Plaintiff had examined the FRB Governor but that:

The Defence has yet to examine him.
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25. The Court subsequently asked in Post #191 whether the Defendant was ready to examine the Governor and again, in Post #201, asked whether the proceedings could continue without that examination.
26. That defence examination never occured. Instead, after the subsequent disruption in DOJ representation, the case proceeded to closing statements.
27. Most importantly, the Defendant raised these circumstances with the Court before judgment.
28. In Post #218, I, as Governor of the Federal Reserve Bank, advised the Court that the Defendant had repeatedly attempted to obtain advise and direction from DOJ since early June, that those communications had received no substantive response, and that the Defendant had continued to rely upon DOJ to fulfill its responsibilities as counsel of record.
29. As Governor, I then expressly requested that the Court permit the Defendant an opportunity to be heard before judgment was rendered.
30. Post #219 does not appear to address or dispose of that outstanding request.
31. The Defendant fully appreciates the substantial length of these proceedings and does not seek to restart this case or cause unncessary delay. Rather, the Defendant respectfully seeks the opportunity to complete the portion of the proceedings that was left unfinished following the breakdown in its representation.
32. The requested relief is particularly important given the breadth of relief presently sought by the Plaintiff, including finding of Abuse of Power and Misfeasance in Public Office, punitive damages, nominal damages, statutory penalties, mandamus, and legal fees.
33. Even where certain underlying facts have been affirmed or are otherwise undisputed, the Defendant has not had an opportunity to make submissions regarding the legal consequences of those rfacts, the elements of the Plaintiff's remaining claims, the Defendant's available defences, or the appropriate scope of any remedy.

WHEREFORE, the Defendant respectfully requests that the Court:

1. reconsider Post #219 insofar as it finds that this case has been fully heard and all arguments have been submitted;
2. refrain from entering a verdict until the Defendant has been afforded an opportunity to make its closing submissions;
3. rule upon the Defendant's outstanding request in Post #218;
4. permit the Defendant to complete its previously contemplated examination of the FRB Governor before closing submissions are made; and
5. permit the Defendant a reasonable period prescribed by the Court to submit the Defendant's closing statement.

In the alternative, if the Court declines to reopen witness examination, the Defendant respectfully requests, at minimum, leave to submit its closing statement before judgment is entered.

For the purposes of this Motion, and in light of the Department of Justice's failure to provide effective representation or respond to the Federal Reserve Bank's requests for direction, the undersigned Governor appears on behalf of the Federal Reserve Bank for the limited purpose of preserving the Bank's position and requesting that the Court address its outstanding representation concerns before judgment is entered.

The Defendant respectfully requests that, if the Court determined that the Governor may not make these submissions on behalf of the Bank, the Court treat this filing as notice of the Defendant's objection and afford the DOJ or other properly authorized counsel an opportunity to enter an appearance and adopt or supplement these submissions.

DATED: This 2nd day of October 2026.

Respectfully submitted,

jJoshuaTheGreat
Governor
Federal Reserve Bank

 
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Motion


IN THE DISTRICT COURT OF THE COMMONWEALTH OF REDMONT

MOTION TO RECUSE

The Defendant respectfully moves, pursuant to Part III §1 of the Judicial Standards Act, for the recusal of the presiding Judicial Officer.

The presiding Judicial Officer served as Attorney General of the Commonwealth of Redmont during the period in which the Department of Justice represented the Defendant in this case.

During that period, the Defendant was a client of the DOJ. The presiding Judicial Officer had access to the FRB's channel on the DOJ server in which this litigation, legal strategy, and related legal matters were discussed, and also participated in that channel personally discussing various legal matters with the Defendant.

The Judicial Standards Act requires a Judicial Officer to recuse where an interest would cause a reasonable person to doubt the Judicial Officer's impartiality. The Act expressly identifies prior work as a lawyer for a litigant as a relevant basis for recusal.

Those provisions apply directly here.

The Judicial Officer now presiding over this case previously headed the legal office representing the Defendant, had access to the Defendant's confidential legal discussions, and personally participated in legal discussions with the Defendant in that channel.

A reasonable person could plainly doubt the propriety of that same individual now adjudicating the case and entering judgment.

THIS MOTION IS EXPRESSLY PERMITTED BEFORE JUDGMENT

Part III §1(2) of the Judicial Standards Act expressly provides that:

A litigant may file a motion to recuse a Judicial Officer at any time before Court issues judgment.
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No judgment has been issued; this Motion is timely and expressly authorized by statute.

While ordinary Court procedure may restrict filings once the Court has entered recess, the Court's decision to enter recess cannot extinguish a statutory right. The Judicial Standards Act does not provide that a party may file a motion to recuse only while the Court is actively in session; it provides that such a motion may be filed at any time before judgment.

The Supreme Court has also made clear that court rules and procedural guidance cannot override legislation enacted by Congress.

In [2026] DCR 92 – Appeal | [2026] SCR 15, the Supreme Court rejected reliance on a court guide because it conflicted with the Judicial Standards Act, saying the guide "goes directly against legislative authority duly and properly promulgated by Congress." The Court then stated:

[C]ourt rules apply only in the absence of legislative or constitutional guidance.
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Here, there is direct legislative guidance. Congress has expressly authorized a party to file a motion to recuse at any time before judgment. Accordingly, this Motion cannot properly be dismissed or characterized as an "outburst" merely because the Court has entered recess.

For further clarity, the undersigned is not an unauthorized third party to this litigation.

Section 5(2)(a) of the Federal Reserve Act expressly provides that:

(i) The Governor shall have the executive authority of the FRB.

(ii) The Governor shall be the principal representative of the FRB.
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The Governor there appears in his official capcity as the individual whom statute expressly designates to exercise the FRB's executive authority and serve as its principal representative.

The Federal Reserve Act also expressly addresses the FRB's use of Department of Justice counsel. Section 4(3) provides:

The FRB may require the DOJ to defend it in court cases.
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The choice of the word "may" is significant. The Act authorizes the FRB to require representation from the DOJ but it does not state that the DOJ is the FRB's exclusive representative, nor does it provide that the FRB may act only through DOJ in litigation.

This interpretation is reinforced by Part XVI §63 of the Redmont Corporate Entities Act.

Section 62 expressly identifies the Federal Reserve Bank as a governmental entity separate from the executive departments. Section 63 then distinguishes between those two categories for purposes of legal representation.

For executive departments, the Act provides:

The Department of Justice is the legal representative of the executive departments.
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But for other governmental entities, including the Federal Reserve Bank, it instead provides:

A governmental entity that is not an executive department may seek outside counsel.
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The statutory scheme therefore does not make the DOJ the exclusive means through which the Federal Reserve Bank may protect its interests in litigiation. Instead, the governing legislation provides that: (1) the Governor holds the FRB's executive authority; (2) the Governor is the FRB's principal representative; (3) the FRB may require the DOJ to defend it; but that (4) the FRB, unlike an executive department, merely may request DOJ lawyers; and (5) the FRB is expressly permitted to seek outside counsel or defend itself in Court via its principal representative, the Governor.

Accordingly, the undersigned is not an outside participant making an unauthorized "outburst." He is the Governor and statutory principal representative of the named Defendant, statutorily acting on behalf of the Federal Reserve Bank to exercise a procedural right expressly granted to that litigant by the Judicial Standards Act.


RELIEF REQUESTED
For the foregoing reasons, the Defendant respectfully requests that the presiding Judicial Officer recuse from this proceeding and that no judgment be entered until this Motion has been determined in accordance with the Judicial Standards Act.

If the presiding Judicial Officer declines to voluntarily recuse, Part III §1 of the Judicial Standards Act requires that this Motion be referred to another Judicial Officer of equal or greater level for determination.

jJoshuaTheGreat
Governor
Federal Reserve Bank of Redmont

 
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