Lawsuit: Pending Vanguard & Co v. Commonwealth of Redmont [2025] FCR 49

[Dartanboy]

Motion

IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
MOTION FOR EMERGENCY INJUNCTION

The Department of Commerce has illegally seized Vanguard's assets, alleging illiquidity and an inability to pay back depositors. They immediately began attempting to forcibly liquidate assets and attempted to seize control of the entirety of Vanguard National Bank and Discover Bank.

These actions, if allowed to continue, will cause irreversible harm to the Plaintiff, in the form of forced liquidation of assets and an inability to operate the aforementioned banking institutions.

Thus, we ask that for the duration of this case:

• All seized assets remain frozen
• All seized businesses remain intact and non-dissolved
• The seized businesses be permitted to continue day-to-day business operations

Case Filing

IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
CIVIL ACTION

Vanguard & Co.
Plaintiff

v.

Commonwealth of Redmont
Defendant

COMPLAINT
The Plaintiff complains against the Defendant as follows:

Vanguard & Co - a popular and law-abiding finance and banking company - was performing business as usual when the Department of Commerce suddenly seized their two banking institutions, Vanguard National Bank and Discover Bank. These seizures, along with announcements and actions around it, have violated the rights of the Plaintiff, defamed the Plaintiff, and caused immense harm to the Plaintiff.

The egregious and outrageous actions made by the Commonwealth must be met with the swift action of justice.

I. PARTIES
1. Vanguard & Co
2. Commonwealth of Redmont

II. FACTS
1. On May 15, 2025, at 10:39pm Central Time, the Department of Commerce announced a so-called Bank Holiday to prevent all banking activity for 36 hours [see Exhibit P-001].
2. On May 16, 2025, at 1:37am Central Time, the Department of Commerce lifted the so-called Bank Holiday and seized Vanguard National Bank and Discover Bank [see Exhibit P-002]. In the announcement of this, they made bold, false claims about Vanguard, including that the banks had “grave liquidity concerns” and “misrepresentation of financial statements” [see Exhibit P-002].
3. The Department of Commerce did not serve Vanguard a warrant nor did they properly initiate bankruptcy proceedings, and refused to mention it whenever confronted about it [see Exhibit P-003].
4. The Department of Commerce did not provide any evidence of insolvency until many hours later after arguing with Vanguard's lawyers, and even then, it was grossly insufficient and unconfirmed evidence provided by a 3rd party [see Exhibit P-004].
5. The Constitution gives every “citizen … the right to a … fair trial, presided over by an impartial Judicial Officer, and to be informed of the nature and cause of the accusation, and to be confronted with the evidence against them …” [see Constitution, Part IV, Section 9].
6. The Constitution gives every citizen the right to “life, liberty, and security of a person and not to be deprived thereof except in accordance with the principles of fundamental justice” [see Constitution, Part IV, Section 14].
7. The Constitution gives every citizen “the right to be secure against unreasonable search or seizure” [see Constitution, Part IV, Section 15].
8. The No More Defamation Act defines defamation as “Defamation is a false statement and/or communication that injures a third party's reputation. The tort of defamation includes both libel and slander” libel as “A method of defamation expressed by documents, signs, published media, or any communication embodied in physical form that is injurious to a person's reputation, exposes a person to public hatred, contempt or ridicule, or injures a person in his/her business, profession or organization” [see Act of Congress - No More Defamation Act]
9. Public reaction to the announcement shows significant harm to Vanguard’s reputation [see Exhibit P-005].
10. The Government seized Vanguard’s in-game cash and assets on The Exchange [see Exhibit P-006, Exhibit P-007, Exhibit P-008, Exhibit P-009].

III. CLAIMS FOR RELIEF
1. Violation of the Right to a Fair Trial & Be Confronted With Evidence – By skipping any and all court proceedings and immediately seizing two banks without evidence to support their claims, Vanguard and its shareholders were denied the right to a Fair Trial and to be Confronted with the Evidence Against Them.
2. Violation of the Right to Life, Liberty, and Security – By seizing the life’s work of Nexalin and a significant amount of the shareholders’ interests, the security of these people was violated.
3. Violation of the Right to be Secure Against Unreasonable Seizure – By seizing the banks and millions of dollars worth of their assets without a warrant or court order, the Department of Commerce performed an Unreasonable Seizure.
4. Defamation (Libel) – The false statement declaring Vanguard’s illiquidity and misrepresentation of financial statements, and the illegal seizure of Vanguard’s banks, caused immense harm to Vanguard’s reputation.
5. Consequential Damages (Humiliation) – Vanguard has been disgraced, belittled, and made to look foolish by the Government creating a public spectacle of its seizure of Vanguard’s banks, and making bold, false claims that seriously negatively affected the bank’s reputation and operations.
6. Consequential Damages (Loss of Enjoyment) – Vanguard’s shareholders and Director have lost the ability to run the Vanguard banks, the very core of their gameplay for years.
7. Punitive Damages (Rights Violation 1) – Violating the Right to a Fair Trial is outrageous and warrants punitive damages.
8. Punitive Damages (Rights Violation 2) – Violating the Right to Life, Liberty, and Security is outrageous and warrants punitive damages.
9. Punitive Damages (Rights Violation 3) – Violating the Right to be Secure Against Unreasonable Seizure is outrageous and warrants punitive damages.
10. Punitive Damages (Defamation) – Defamation from Media Outlets is somewhat expected, albeit illegal, but from the Government, it is outrageous and warrants punitive damages.
11. Compensatory Damages (Seized Assets) – The seized assets are no longer able to accrue value through investment, creating compensatory damages.

IV. PRAYER FOR RELIEF
The Plaintiff seeks the following from the Defendant:
1. All seized businesses and assets be returned to the Plaintiff.
2. $1,000,000 for the immense reputational harm, likely to result in millions of deposits being withdrawn in a bank run.
3. $1,000,000 in Punitive Damages for violating the Right to a Fair Trial.
4. $1,000,000 in Punitive Damages for violating the Right to Life, Liberty, and Security.
5. $1,000,000 in Punitive Damages for violating the Right Against Unreasonable Seizure.
6. $50,000 in Humiliation Damages for creating a public spectacle of its seizure of Vanguard’s banks, and making bold, false claims that seriously negatively affected the bank’s reputation and operations (for some reason, $50k is the legal cap on this).
7. $50,000 for Loss of Enjoyment in Redmont for removing Vanguard’s shareholders’ and director’s way of life (again, for some reason $50k is the legal cap on this).
8. $1,000,000 in Punitive Damages for violating the No More Defamation Act and creating a public spectacle through its defamation of Vanguard.
9. $7,607,051.27 in Compensatory Damages (the value of the seized assets).
10. A public apology, detailing the illegal actions taken by the Government, clearing Vanguard of alleged wrongdoing, and explaining what steps the Department of Commerce will take to ensure they won’t seize businesses on made-up information in the future.
10. $3,812,115 (30% case value, rounded down to nearest dollar) in Legal Fees, payable to the in-game business JusticeCompass.

In Total:
1. All seized businesses and assets returned to the Plaintiff
2. $12,707,051.27 payable to Vanguard & Co.
3. A detailed public apology
4. $3,812,115 payable to Justice Compass, Ltd.

EVIDENCE

Spoiler: ”Exhibit P-001”

Spoiler: ”Exhibit P-002”

Spoiler: ”Exhibit P-003”

Spoiler: ”Exhibit P-004”

Spoiler: ”Exhibit P-005”

Spoiler: ”Exhibit P-006”

Spoiler: ”Exhibit P-007”

Spoiler: ”Exhibit P-008”

Spoiler: ”Exhibit P-009”

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 17th day of May 2025

 

[Dartanboy]

Consent to Represent:

(Justice Compass is representing Vanguard. This includes Dartanboy, Ibney0, Ethamn, and Ameslap)

 

[ko531]

A Modified Emergency Injunction will be Granted

1. All seized assets of Vangard Co. remain frozen
2. All seized businesses remain intact and non-dissolved
3. All day to day business operations will be halted.

In essense, Vangaurd Co. will be completely frozen for the duration of this case in which both the government or Vangaurd itself cannot interact with any of the seized assests.

 

[ko531]

Writ of Summons

@juniperfig is required to appear before the Federal Court in the case of Vangaurd Co. v. Commonwealth of Redmont [2025] FCR 49

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.

 

[Kaiserin_]

The Commonwealth is present, your honour.

 

[ko531]

The Commonwealth is present, your honour.

You have 72 hours to provide your Answer to Complaint

 

[asexualdinosaur]

Answer to Complaint

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

Vanguard & Co.
Plaintiff

v.

Commonwealth of Redmont
Defendant

I. ANSWER TO COMPLAINT
1. AFFIRM DoC announced a Bank Holiday, DENY it prevented all banking activity.
2. AFFIRM DoC seized Vanguard National Bank and Discover Bank, AFFIRM DoC made claims of “grave liquidity concerns” and “misrepresentation of financial statements”, but DENY their falsehood.
3. AFFIRM Vanguard was not served a warrant or bankruptcy proceedings, but DENY refusing to discuss the topic.
4. AFFIRM evidence was provided later, DENY its insufficiency, NEITHER CONFIRM NOR DENY source of evidence
5. AFFIRM that this right is afforded to citizens
6. AFFIRM that this right is afforded to citizens
7. AFFIRM that this right is afforded to citizens.
8. AFFIRM content of the No More Defamation Act.
9. AFFIRM the public reacted to the DoC announcement, but DENY it caused significant harm to Vanguard reputation.
10. AFFIRM the DoC seized Vanguard National Bank’s & Discover Bank’s in-game cash assets, as well as Vanguard’s assets on The Exchange.


II. DEFENCES
1. Taxation Act gives broad power to the DOC to Commandeer, Seize, and Sell.
2. Judicial Standards Act Section 17- ‘The court may issue warrants - court orders that allow actions that would otherwise be unlawful’, It’s clear that a warrant was not required here because the action being taken was indeed lawful.
3. The executive does NOT require a warrant for tasks that are in line with their lawful duties and responsibilities.
4. Vanguard & Co is not a citizen and as such is not afforded rights that are granted to citizens - Constitution Part IV - Sections 9, 14, & 15
5. The Department of Commerce acted legally and within their authority to announce and make public circumstances that affect the population and more narrowly- depositors, about changes being enacted.
6. The statements made by the DOC were facts as they understand the situation.
7. It was not necessary to file bankruptcy proceedings in this instance, as the powers used here were outlined in the Taxation Act Section 8.1 for the purpose of protecting depositors of deposit-taking institutions.


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

DATED: This 19th day of May 2025

 

[asexualdinosaur]

EVIDENCE

Spoiler: ”Exhibit P-003”

Spoiler: ”Exhibit P-004”

Spoiler: ”Exhibit P-005”

Objection

IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
OBJECTION - IMPROPER EVIDENCE

P-005 was improperly filed. It includes multiple statements from multiple sources and lacks the surrounding context for many of those statements. Should the plaintiff wish to include these statements, they should be broken up and submitted individually to allow them to be addressed individually.

Under Court Rules and Procedures Rule 4.1 all material is intended to enable fairness and allow parties to view information so we may properly formulate legal arguments, this type of ‘image doctoring’ is not conducive to fairness.

Objection

IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
OBJECTION - RELEVANCE

P-003 only includes statements from the Plaintiff’s counsel and does not prove the point they’re intending to argue in their complaint. The screenshot only goes to show that the plaintiff said the word a few times, it doesn’t even make clear that the DOC had even seen these messages or responded in the ticket.

Objection

IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
OBJECTION - RELEVANCE

P-004 is a conversation between “Juniperfig” and the Plaintiff’s counsel- they cite this evidence as ‘The Department of Commerce’, but Juniperfig is not under the employ of the DoC.
It is unclear what this piece of evidence is intended to show.

 

[Kaiserin_]

Motion

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

The defence moves that this case should be dismissed under Rule 5.12, lack of personal jurisdiction, and Rule 5.5, lack of claim, and in support thereof, respectfully alleges:

Rule 5.12 of our Court Rules and Procedures establishes that in order to have personal jurisdiction, a case must have standing. Rule 2.1 establishes that in order to have standing, a plaintiff must show to the Court that “[t]he cause of injury was against the law.” Rule 5.5 establishes that the plaintiff must state a proper claim for relief, akin to a cause of action that creates controversy that merits hearing before the Court. No crime under our Commonwealth’s laws has been alleged by the plaintiff, and no genuine claim has been brought forward within this case.

I. Plaintiff’s main stated claims for relief are allegations of constitutional rights violations. To be clear, rights under our Constitution are provided explicitly to citizens of the Commonwealth, not to any legal entity:

“Any citizen, criminal or otherwise will have the right to a speedy and fair trial… and to be confronted with the evidence against them…”
“Every citizen has the right to life, liberty, and security of the person…”
“Every citizen has the right to be secure against unreasonable search or seizure.”

In Bank and Trust of Redmont v. The Commonwealth of Redmont [2021] SCR 8, the Supreme Court ruled that “a company does not have personhood and therefore does not have a constitutional right to protect themselves from unreasonable search or seizure.” It further established that “organizations such as banks are not considered citizens under the law.” While the Business Structuring Act provides that “[t]he firm is treated as a separate legal entity from its owners and managers,” this does not mean that businesses are somehow persons, much less citizens that are afforded constitutional rights.

As the plaintiff is a business, and therefore is not a citizen, claims of any supposed violation of its constitutional rights are invalid, as it has none.

II. Even surviving that, no claim for relief is generated by the government conducting its duties as directly prescribed by law. The Court is reminded that constitutional rights are “subject only to such reasonable limits prescribed by law.” Each of the plaintiff’s claims for relief revolve around the seizure of Vanguard Private Bank and Discover Bank by the Department of Commerce. The DOC is expressly granted the ability to do this by § 8.(3).(c) of the Taxation Act:

“In extraordinary situations, the Department of Commerce has the power to commandeer and take temporary control of a financial institution. This authority is reserved for exceptional circumstances, such as insolvency, near insolvency, financial crises, or situations where the institution's continued operation poses a systemic risk to the financial system or depositors.”

Further, in the following subpart:

“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.”

This is not a power that calls for bankruptcy proceedings, or a court case. This is simply a regulatory power that the Department of Commerce is granted the ability to pursue. Further, the Department legally cannot provide information to justify the reasoning behind the seizure, because according to § 10.(3) of the Commercial Standards Act, “[t]he Department of Commerce must treat the data of Financial Institutions as commercial-in-confidence.” Congress is currently urgently considering a bill to change this law, but as it stood when the action was taken, financial data could not be publicly shared to justify the seizure of the bank.

If the plaintiff finds any of these laws to be unjust, they should work through their democratically elected representatives to have them amended or repealed. If the plaintiff insists that these powers granted to the Department of Commerce are unconstitutional, or that they are not “justified in a free and democratic society,” they should challenge the laws themselves in court to have them struck.

III. The plaintiff’s claim of defamation cannot be valid, because the only public statements made by the Department of Commerce were those strictly necessary in informing the public of the actions it has taken. Even if those actions were illegal, which they were not, the Department is required by its duty of care to inform the public of regulatory actions it has taken that affect the economy so broadly.

IV. The remainder of the plaintiff’s “claims for relief” are justifications for damages that create no claim on their own without a valid cause for action.

In order to have standing, a case must allege an illegal action. No illegal action has been alleged, because the Department of Commerce’s actions are directly made legal by the Taxation Act, and the plaintiff has no constitutional rights that they could allege to have been broken. No law has been cited that states that the Department cannot do what it has done, and the laws explicitly stating that the Department can do what it has done were omitted from the complaint.

Therefore, the defence respectfully requests that this case be dismissed in its entirety with prejudice. Surviving that, the defence asks that those individual claims for relief which the court may find invalid be struck.

 

[Dartanboy]

Objection​

IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
OBJECTION - IMPROPER EVIDENCE

P-005 was improperly filed. It includes multiple statements from multiple sources and lacks the surrounding context for many of those statements. Should the plaintiff wish to include these statements, they should be broken up and submitted individually to allow them to be addressed individually.

Under Court Rules and Procedures Rule 4.1 all material is intended to enable fairness and allow parties to view information so we may properly formulate legal arguments, this type of ‘image doctoring’ is not conducive to fairness.

The images are not doctored. It is a collage of multiple images.

 

[Dartanboy]

Objection​

IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
OBJECTION - RELEVANCE

P-003 only includes statements from the Plaintiff’s counsel and does not prove the point they’re intending to argue in their complaint. The screenshot only goes to show that the plaintiff said the word a few times, it doesn’t even make clear that the DOC had even seen these messages or responded in the ticket.

We are happy to provide additional evidence. Lack of additional evidence doesn't make this irrelevant.

 

[Dartanboy]

Objection​

IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
OBJECTION - RELEVANCE

P-004 is a conversation between “Juniperfig” and the Plaintiff’s counsel- they cite this evidence as ‘The Department of Commerce’, but Juniperfig is not under the employ of the DoC.
It is unclear what this piece of evidence is intended to show.

Juniperfig is the Attorney General, and represents the Commonwealth, including the DoC, in all legal matters.

Is the DoJ actually arguing that the Attorney General was not acting on her official capacity in Vanguard's conversations in a DoC ticket?

 

[Dartanboy]

Motion

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

The defence moves that this case should be dismissed under Rule 5.12, lack of personal jurisdiction, and Rule 5.5, lack of claim, and in support thereof, respectfully alleges:

Rule 5.12 of our Court Rules and Procedures establishes that in order to have personal jurisdiction, a case must have standing. Rule 2.1 establishes that in order to have standing, a plaintiff must show to the Court that “[t]he cause of injury was against the law.” Rule 5.5 establishes that the plaintiff must state a proper claim for relief, akin to a cause of action that creates controversy that merits hearing before the Court. No crime under our Commonwealth’s laws has been alleged by the plaintiff, and no genuine claim has been brought forward within this case.

I. Plaintiff’s main stated claims for relief are allegations of constitutional rights violations. To be clear, rights under our Constitution are provided explicitly to citizens of the Commonwealth, not to any legal entity:

“Any citizen, criminal or otherwise will have the right to a speedy and fair trial… and to be confronted with the evidence against them…”
“Every citizen has the right to life, liberty, and security of the person…”
“Every citizen has the right to be secure against unreasonable search or seizure.”

In Bank and Trust of Redmont v. The Commonwealth of Redmont [2021] SCR 8, the Supreme Court ruled that “a company does not have personhood and therefore does not have a constitutional right to protect themselves from unreasonable search or seizure.” It further established that “organizations such as banks are not considered citizens under the law.” While the Business Structuring Act provides that “[t]he firm is treated as a separate legal entity from its owners and managers,” this does not mean that businesses are somehow persons, much less citizens that are afforded constitutional rights.

As the plaintiff is a business, and therefore is not a citizen, claims of any supposed violation of its constitutional rights are invalid, as it has none.

II. Even surviving that, no claim for relief is generated by the government conducting its duties as directly prescribed by law. The Court is reminded that constitutional rights are “subject only to such reasonable limits prescribed by law.” Each of the plaintiff’s claims for relief revolve around the seizure of Vanguard Private Bank and Discover Bank by the Department of Commerce. The DOC is expressly granted the ability to do this by § 8.(3).(c) of the Taxation Act:

“In extraordinary situations, the Department of Commerce has the power to commandeer and take temporary control of a financial institution. This authority is reserved for exceptional circumstances, such as insolvency, near insolvency, financial crises, or situations where the institution's continued operation poses a systemic risk to the financial system or depositors.”

Further, in the following subpart:

“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.”

This is not a power that calls for bankruptcy proceedings, or a court case. This is simply a regulatory power that the Department of Commerce is granted the ability to pursue. Further, the Department legally cannot provide information to justify the reasoning behind the seizure, because according to § 10.(3) of the Commercial Standards Act, “[t]he Department of Commerce must treat the data of Financial Institutions as commercial-in-confidence.” Congress is currently urgently considering a bill to change this law, but as it stood when the action was taken, financial data could not be publicly shared to justify the seizure of the bank.

If the plaintiff finds any of these laws to be unjust, they should work through their democratically elected representatives to have them amended or repealed. If the plaintiff insists that these powers granted to the Department of Commerce are unconstitutional, or that they are not “justified in a free and democratic society,” they should challenge the laws themselves in court to have them struck.

III. The plaintiff’s claim of defamation cannot be valid, because the only public statements made by the Department of Commerce were those strictly necessary in informing the public of the actions it has taken. Even if those actions were illegal, which they were not, the Department is required by its duty of care to inform the public of regulatory actions it has taken that affect the economy so broadly.

IV. The remainder of the plaintiff’s “claims for relief” are justifications for damages that create no claim on their own without a valid cause for action.

In order to have standing, a case must allege an illegal action. No illegal action has been alleged, because the Department of Commerce’s actions are directly made legal by the Taxation Act, and the plaintiff has no constitutional rights that they could allege to have been broken. No law has been cited that states that the Department cannot do what it has done, and the laws explicitly stating that the Department can do what it has done were omitted from the complaint.

Therefore, the defence respectfully requests that this case be dismissed in its entirety with prejudice. Surviving that, the defence asks that those individual claims for relief which the court may find invalid be struck.

May we respond to the Motion to Dismiss, your Honor?

 

[ko531]

May we respond to the Motion to Dismiss, your Honor?

You have 24 hours to respond to the motion to dismiss

 

[ko531]

Objection

IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
OBJECTION - IMPROPER EVIDENCE

P-005 was improperly filed. It includes multiple statements from multiple sources and lacks the surrounding context for many of those statements. Should the plaintiff wish to include these statements, they should be broken up and submitted individually to allow them to be addressed individually.

Under Court Rules and Procedures Rule 4.1 all material is intended to enable fairness and allow parties to view information so we may properly formulate legal arguments, this type of ‘image doctoring’ is not conducive to fairness.

Objection

IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
OBJECTION - RELEVANCE

P-003 only includes statements from the Plaintiff’s counsel and does not prove the point they’re intending to argue in their complaint. The screenshot only goes to show that the plaintiff said the word a few times, it doesn’t even make clear that the DOC had even seen these messages or responded in the ticket.

Objection

IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
OBJECTION - RELEVANCE

P-004 is a conversation between “Juniperfig” and the Plaintiff’s counsel- they cite this evidence as ‘The Department of Commerce’, but Juniperfig is not under the employ of the DoC.
It is unclear what this piece of evidence is intended to show.

Objection #1 Improper Evidence
Sustained, please split up the collage so each component can be address individually throughout this case.

Objection #2 Relevance
Sustained, Please provide both sides of the conversation.

Objection #3 Relevence,
Overruled, Juniperfig was clearly representing the DOC and the commonwealth when communicating in a DOC ticket.

 

[Dartanboy]

In Bank and Trust of Redmont v. The Commonwealth of Redmont [2021] SCR 8, the Supreme Court ruled that “a company does not have personhood and therefore does not have a constitutional right to protect themselves from unreasonable search or seizure.”

Objection

PERJURY

This quote is literally not found in that lawsuit. In fact, the words "person" and "personhood" are nowhere to be seen in it.

Spoiler: Proof

 

[Dartanboy]

Response

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

ON THE FIRST POINT
The Defense's counsel appears to be deliberately misrepresenting both the arguments made by the Plaintiff as well as the precedent they have cited.

The Defense first alleges Lack of Standing, citing that Vanguard & Co is a business, not a citizen. The Plaintiff concurs that businesses are not citizen, however holds that businesses are run by citizens, are owned by citizens, employ citizens, and provide goods and/or services to citizens, and these citizens are all affected by the actions taken against Vanguard & Co in this case and thus, their rights were actually violated.

This is, actually, the stance the court took in [2021] SCR 8, as cited by the Plaintiff, and they simply cut off their quote. Here is a quote from the Plaintiff's Motion:

It further established that “organizations such as banks are not considered citizens under the law.”

You'll notice they even ended this with a period, presumably to make it appear as a complete thought from the court, however, the quote, including additional context, is here:

organizations such as banks are not considered citizens under the law, however, seeing as organizations are run by people, citizens are still indirectly impacted by the regulations. Therefore organizations should be protected under the law

As you can see, organizations are still protected under the rights which protect citizens, where violating them would also violate a citizen's rights.

ON THE SECOND POINT
The Defendant claims:

II. Even surviving that, no claim for relief is generated by the government conducting its duties as directly prescribed by law. The Court is reminded that constitutional rights are “subject only to such reasonable limits prescribed by law.” Each of the plaintiff’s claims for relief revolve around the seizure of Vanguard Private Bank and Discover Bank by the Department of Commerce. The DOC is expressly granted the ability to do this by § 8.(3).(c) of the Taxation Act:

“In extraordinary situations, the Department of Commerce has the power to commandeer and take temporary control of a financial institution. This authority is reserved for exceptional circumstances, such as insolvency, near insolvency, financial crises, or situations where the institution's continued operation poses a systemic risk to the financial system or depositors.”

Further, in the following subpart:

“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.”

This is not a power that calls for bankruptcy proceedings, or a court case. This is simply a regulatory power that the Department of Commerce is granted the ability to pursue. Further, the Department legally cannot provide information to justify the reasoning behind the seizure, because according to § 10.(3) of the Commercial Standards Act, “[t]he Department of Commerce must treat the data of Financial Institutions as commercial-in-confidence.” Congress is currently urgently considering a bill to change this law, but as it stood when the action was taken, financial data could not be publicly shared to justify the seizure of the bank.

If the plaintiff finds any of these laws to be unjust, they should work through their democratically elected representatives to have them amended or repealed. If the plaintiff insists that these powers granted to the Department of Commerce are unconstitutional, or that they are not “justified in a free and democratic society,” they should challenge the laws themselves in court to have them struck.

So first of all, the Defendant is making a defense, not a reason for dismissal. Their argument is that the seizure was legal. Ours is that it was not legal. Dismissing this case simply because the Defendant's interpretation of the law is different than ours would be a miscarriage of justice.

Regardless, even though the Taxation Act gives the Department of Commerce the power to "[commandeer] and take temporary control of a financial institution" with the stipulation that "This authority is reserved for exceptional circumstances, such as insolvency, near insolvency, financial crises, or situations where the institution's continued operation poses a systemic risk to the financial system or depositors," the Plaintiff would like to remind the court that the Commonwealth failed to provide any evidence that this was an "exceptional circumstance" and merely claimed that it was one.

Furthermore, this power is not unlimited, and must be tempered by the rights of the Constitution. Similarly, the Departments of Justice cannot simply look through the voting records or check animal kill logs without a warrant, even though they're tasked with "Investigating ... on behalf of the Federal Government." To suggest that a seizure of two entire businesses, and millions of dollars of assets is reasonable without any warrant or court order is reasonable is, frankly, absurd. Not to mention that on top of that, they didn't seem to even have any evidence except for a single, inaccurate spreadsheet, so even if a warrant wasn't required (which it is), this would certainly have been an unreasonable seizure as there was no evidence that it was a necessary action.

Following into this subpart:

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.

the same concept applies - this power is not without limits, and must be reigned in by the Constitution.

We do not believe the laws themselves are unconstitutional, we believe that the Commonwealth has misinterpreted these laws as giving them unlimited, tyrannical power to seize banks.

ON THE THIRD POINT
The Defendant claims:

The plaintiff’s claim of defamation cannot be valid, because the only public statements made by the Department of Commerce were those strictly necessary in informing the public of the actions it has taken. Even if those actions were illegal, which they were not, the Department is required by its duty of care to inform the public of regulatory actions it has taken that affect the economy so broadly.

Once again, this is a defense, not a reason for dismissal.

Secondly, as already established, the seizure itself was unconstitutional, and furthermore it was unfounded, and lacking evidence. The claims made were false and caused immense reputational harm. This is the very definition of defamation.

ON THE FOURTH POINT
The Defense claims:

The remainder of the plaintiff’s “claims for relief” are justifications for damages that create no claim on their own without a valid cause for action.

In order to have standing, a case must allege an illegal action. No illegal action has been alleged, because the Department of Commerce’s actions are directly made legal by the Taxation Act, and the plaintiff has no constitutional rights that they could allege to have been broken. No law has been cited that states that the Department cannot do what it has done, and the laws explicitly stating that the Department can do what it has done were omitted from the complaint.

As established through the previous three points, we do have standing, and the actions taken by the Commonwealth were certainly illegal, and even egregious constitutional violations.

 

[ko531]

Motion

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

The defence moves that this case should be dismissed under Rule 5.12, lack of personal jurisdiction, and Rule 5.5, lack of claim, and in support thereof, respectfully alleges:

Rule 5.12 of our Court Rules and Procedures establishes that in order to have personal jurisdiction, a case must have standing. Rule 2.1 establishes that in order to have standing, a plaintiff must show to the Court that “[t]he cause of injury was against the law.” Rule 5.5 establishes that the plaintiff must state a proper claim for relief, akin to a cause of action that creates controversy that merits hearing before the Court. No crime under our Commonwealth’s laws has been alleged by the plaintiff, and no genuine claim has been brought forward within this case.

I. Plaintiff’s main stated claims for relief are allegations of constitutional rights violations. To be clear, rights under our Constitution are provided explicitly to citizens of the Commonwealth, not to any legal entity:

“Any citizen, criminal or otherwise will have the right to a speedy and fair trial… and to be confronted with the evidence against them…”
“Every citizen has the right to life, liberty, and security of the person…”
“Every citizen has the right to be secure against unreasonable search or seizure.”

In Bank and Trust of Redmont v. The Commonwealth of Redmont [2021] SCR 8, the Supreme Court ruled that “a company does not have personhood and therefore does not have a constitutional right to protect themselves from unreasonable search or seizure.” It further established that “organizations such as banks are not considered citizens under the law.” While the Business Structuring Act provides that “[t]he firm is treated as a separate legal entity from its owners and managers,” this does not mean that businesses are somehow persons, much less citizens that are afforded constitutional rights.

As the plaintiff is a business, and therefore is not a citizen, claims of any supposed violation of its constitutional rights are invalid, as it has none.

II. Even surviving that, no claim for relief is generated by the government conducting its duties as directly prescribed by law. The Court is reminded that constitutional rights are “subject only to such reasonable limits prescribed by law.” Each of the plaintiff’s claims for relief revolve around the seizure of Vanguard Private Bank and Discover Bank by the Department of Commerce. The DOC is expressly granted the ability to do this by § 8.(3).(c) of the Taxation Act:

“In extraordinary situations, the Department of Commerce has the power to commandeer and take temporary control of a financial institution. This authority is reserved for exceptional circumstances, such as insolvency, near insolvency, financial crises, or situations where the institution's continued operation poses a systemic risk to the financial system or depositors.”

Further, in the following subpart:

“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.”

This is not a power that calls for bankruptcy proceedings, or a court case. This is simply a regulatory power that the Department of Commerce is granted the ability to pursue. Further, the Department legally cannot provide information to justify the reasoning behind the seizure, because according to § 10.(3) of the Commercial Standards Act, “[t]he Department of Commerce must treat the data of Financial Institutions as commercial-in-confidence.” Congress is currently urgently considering a bill to change this law, but as it stood when the action was taken, financial data could not be publicly shared to justify the seizure of the bank.

If the plaintiff finds any of these laws to be unjust, they should work through their democratically elected representatives to have them amended or repealed. If the plaintiff insists that these powers granted to the Department of Commerce are unconstitutional, or that they are not “justified in a free and democratic society,” they should challenge the laws themselves in court to have them struck.

III. The plaintiff’s claim of defamation cannot be valid, because the only public statements made by the Department of Commerce were those strictly necessary in informing the public of the actions it has taken. Even if those actions were illegal, which they were not, the Department is required by its duty of care to inform the public of regulatory actions it has taken that affect the economy so broadly.

IV. The remainder of the plaintiff’s “claims for relief” are justifications for damages that create no claim on their own without a valid cause for action.

In order to have standing, a case must allege an illegal action. No illegal action has been alleged, because the Department of Commerce’s actions are directly made legal by the Taxation Act, and the plaintiff has no constitutional rights that they could allege to have been broken. No law has been cited that states that the Department cannot do what it has done, and the laws explicitly stating that the Department can do what it has done were omitted from the complaint.

Therefore, the defence respectfully requests that this case be dismissed in its entirety with prejudice. Surviving that, the defence asks that those individual claims for relief which the court may find invalid be struck.

Motion to dismiss denied

The Supreme Court in the very case you quoted gave protections to organizations as they are ran by citizens and any actions against them affects citizens. As for your other points, they are defenses for the legality of the DOC's actions which is the major fact being contested in this case, whether the DOC acted legally. It is not a valid reason to dismiss a case because one side contests that they acted legally.

 

[Kaiserin_]

Objection

PERJURY

This quote is literally not found in that lawsuit. In fact, the words "person" and "personhood" are nowhere to be seen in it.

Spoiler: Proof

View attachment 55185

Apologies for the misquote, your honour, it was the result of some miscommunication within Department of Justice internal chats. What I had thought was a direct quote was, in fact, a paraphrase. That is admittedly an embarrassing mistake, but does not constitute perjury, as it was not intended as a lie.

 

[Dartanboy]

3. All day to day business operations will be halted.

In essense, Vangaurd Co. will be completely frozen for the duration of this case in which both the government or Vangaurd itself cannot interact with any of the seized assests.

Motion

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

Vanguard requests a slight modification to this ruling, which we believe further prevents harm.

Vanguard seeks permission to, of its own power and accord, liquidate some of its assets in preparation for the nearly inevitable bank run that will likely result from the Defendant's actions of defamation.

 

[juniperfig]

Motion

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

Vanguard requests a slight modification to this ruling, which we believe further prevents harm.

Vanguard seeks permission to, of its own power and accord, liquidate some of its assets in preparation for the nearly inevitable bank run that will likely result from the Defendant's actions of defamation.

Your honour, I request a response to this motion.

 

[ko531]

Your honour, I request a response to this motion.

You may, you have 24 hours to do so.

 

[ko531]

Objection

PERJURY

This quote is literally not found in that lawsuit. In fact, the words "person" and "personhood" are nowhere to be seen in it.

Spoiler: Proof

View attachment 55185

Objection granted

The statement will be struck for being factually incorrect but as there seems to be no intent to purposely deceive the court, no one will be charged with perjury.

 

[asexualdinosaur]

You may, you have 24 hours to do so.

Motion

The Commonwealth respectfully opposes Plaintiff's Motion to Reconsider the Emergency Injunction on the following grounds:

1) The Plaintiff lacks standing to request liquidation of assets currently under lawful seizure by the Department of Commerce pursuant to § 8.(3).(c) of the Taxation Act. The Emergency Injunction properly maintains the status quo by preserving the seized assets, pending judicial review.

2) The Plaintiff's request constitutes an improper attempt to circumvent the legislated seizure process. Granting this motion would effectively reverse the seizure prior to adjudication of its merits.

3) It’s important to note that the role of an emergency injunction is to prevent serious, unavoidable harm, as noted in the court orders thread, as well as being held by many judicial officers in the past.
Court Orders Guide
- `The goal of an emergency injunction is to prevent harm.`

Bank of Reveille v. Federal Reserve Bank 2025 [FCR 22]
In this case we see that the Judge makes extra note of the intent and use of an Emergency Injunction and considerations to be made.
`The movant has failed to demonstrate that that remedies sought by the preliminary injunction will prevent irreparable damage which can not later be remedied by a permanent injunction or a court order`

Commonwealth v. Bardiya_King 2023 [SCR 23]
‘When examining the issue of the emergency injunction, I am brought back to its basic premise, “The goal of an emergency injunction is to prevent harm” (see Guide - Court Orders Guide).’

In this particular case, the questions of harm reduction, what it means to prevent harm, and the balance of harm caused all come up.
`As a Justice, when reviewing an emergency injunction, we should do so on a prevention of harm basis of review only. There should be no indication of whether or not a defendant or party on the receiving end of an emergency injunction is actually guilty of the charges put forth.`

The Commonwealth has already affirmed the seizure in our answer - at this point the assets are the Government’s, not the Plaintiff’s. We urge the court to see how this would hurt the interests of depositors if Vanguard were able to liquidate assets under government control, and how it would harm the government’s interest of protecting depositors funds, which was partially the goal of the seizure in the first place.

The freezing of assets enables the court to properly review the situation, and allowing the assets to be liquidated at this time would harm depositors as well as the Commonwealth, and there would potentially be no remedy to liquidations after the fact.

 

[ko531]

Motion

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

Vanguard requests a slight modification to this ruling, which we believe further prevents harm.

Vanguard seeks permission to, of its own power and accord, liquidate some of its assets in preparation for the nearly inevitable bank run that will likely result from the Defendant's actions of defamation.

Motion to Reconsider denied

The Emergency Injunction is in place to protect both sides from furthering the other harm in their process to protect depositors in case they are found to be the winning party. If the Commonwealth is found to be correct in their stance, The assets requested to be liquidated aren't Vangaurds to liquidate. This case must be fully heard before any manipulation of assets can happen.

 

[asexualdinosaur]

Your honor,

Apologies for speaking out of turn, but we'd like to request this case move forward to discovery or to clarify what's currently pending.

Thank you.

 

[ko531]

Sorry for the wait. We will now be entering discovery, discovery will last 5 days starting now

 

[Dartanboy]

INTERROGATORY
The following interrogatory is submitted for the Commonwealth to respond to:
1. What evidence did the Commonwealth have that there was a financial crisis or other major problem that necessitated the seizure of Vanguard's banks?
2. Why didn't the Commonwealth serve Vanguard a warrant for this seizure?
3. Did the Commonwealth attempt to resolve the alleged issue through a course of action other than seizure of Vanguard's banks?

 

[juniperfig]

The Commonwealth would like to call the following witnesses:

xSyncx
Avaneesh2008
DonTrillions
supersuperking

 

[Dartanboy]

Motion

IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
MOTION FOR DEFAULT JUDGEMENT

The Court Rules clearly dictate:

Answers to Interrogatories must be made within 48 hours of being asked.

(Rule 4.8)
and

A Motion to Dismiss may be submitted if a request made within the Discovery Rules (Rule 4 and all subsections) was not complied with.

(Rule 5.13)

The equivalent to a Dismissal on the Plaintiff's side is a Default Judgement. As it has been More than 80 hours since interrogatories were asked, it is clear that the Defendant is not taking this case seriously, and should receive a Default Judgement.

 

[gribble19]

Your Honor, the Defense respectfully requests 24 more hours to answer the Interrogatories asked by the Plaintiff and apologizes for the delay in doing so.

 

[ko531]

Motion

IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
MOTION FOR DEFAULT JUDGEMENT

The Court Rules clearly dictate:

(Rule 4.8)
and

(Rule 5.13)

The equivalent to a Dismissal on the Plaintiff's side is a Default Judgement. As it has been More than 80 hours since interrogatories were asked, it is clear that the Defendant is not taking this case seriously, and should receive a Default Judgement.

Motion for Default Judgement denied.

This large of a case is not going to default judgement because of this little discovery infraction. The Commonwealth's request for an additional 24 hours to respond is granted

 

[Dartanboy]

Motion for Default Judgement denied.

This large of a case is not going to default judgement because of this little discovery infraction. The Commonwealth's request for an additional 24 hours to respond is granted

Motion

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

Your honor, clearly this case is not a big deal to the Commonwealth, or they wouldn't be on day 4 out of 2 to respond to 3 questions.

Furthermore, the Court rules are clear, stating that answers  must be given in time (not should, MUST)

Surely, asking for an extension 32 hours after the deadline is not reasonable.

 

[Dartanboy]

The Commonwealth would like to call the following witnesses:

xSyncx
Avaneesh2008
DonTrillions
supersuperking

Objection

RELEVANCE

supersuperking is neither a DoC employee (based on the DC Discord) nor an employee of Vanguard.

We don't see the witness' relevance.

 

[Kaiserin_]

The defence introduces the following pieces of evidence in relation to Vanguard and Discover's financial situation at the time of seizure, as well as compliance with the DOC:

Spoiler: D-001

Spoiler: D-002

Spoiler: D-003

Spoiler: D-004

Spoiler: D-005

 

[Kaiserin_]

INTERROGATORY
The following interrogatory is submitted for the Commonwealth to respond to:
1. What evidence did the Commonwealth have that there was a financial crisis or other major problem that necessitated the seizure of Vanguard's banks?
2. Why didn't the Commonwealth serve Vanguard a warrant for this seizure?
3. Did the Commonwealth attempt to resolve the alleged issue through a course of action other than seizure of Vanguard's banks?

1. A plethora of evidence was available as to the insolvency of Vanguard's banks. Some has been introduced, and more is pending.
2. It was not necessary, as per the Taxation Act.
3. Yes.

 

[Kaiserin_]

Objection

RELEVANCE

supersuperking is neither a DoC employee (based on the DC Discord) nor an employee of Vanguard.

We don't see the witness' relevance.

Your honour, supersuperking was involved in the merger that was planned between Vanguard and Volt, which was later stopped by the DOJ. Souper can testify as to Vanguard and Discover's situation in the leadup to the seizure, as he very briefly owned them in that time period.

 

[ko531]

Motion

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

Your honor, clearly this case is not a big deal to the Commonwealth, or they wouldn't be on day 4 out of 2 to respond to 3 questions.

Furthermore, the Court rules are clear, stating that answers  must be given in time (not should, MUST)

Surely, asking for an extension 32 hours after the deadline is not reasonable.

Motion to Reconsider denied

The court rules are up to the discretion of the presiding officer. Additionally, the interrogation questions have now been answered. Allowing a case seeking 15 million dollars to go to default judgement because of the slightest violation of discovery rules (which has now been corrected to the best of the defenses abiliity) would be a major miscarry of justice for both sides.

 

[ko531]

Objection

RELEVANCE

supersuperking is neither a DoC employee (based on the DC Discord) nor an employee of Vanguard.

We don't see the witness' relevance.

Objection overruled

supersuperking seems to have valuable testimony to give for this case as he did (even though briefly) owned Vanguard.

 

[Dartanboy]

1. A plethora of evidence was available as to the insolvency of Vanguard's banks. Some has been introduced, and more is pending.
2. It was not necessary, as per the Taxation Act.
3. Yes.

INTERROGATORY
4. What steps did the Commonwealth take to attempt to resolve the alleged issue through a course of action other than seizure of Vanguard's banks?

 

[Dartanboy]

The Defense submits Exhibit P-010:

Spoiler: Exhibit P-010

 

[Dartanboy]

The Defense seeks to submit the balances of all users of Discover Bank and Vanguard National Bank, but recognizes this information is protected by the Privacy Act. We seek Closed Court to submit it.

 

[ko531]

The Defense seeks to submit the balances of all users of Discover Bank and Vanguard National Bank, but recognizes this information is protected by the Privacy Act. We seek Closed Court to submit it.

Close Court session is granted.

 

[Kaiserin_]

We submit the following Department of Commerce report as D-006.

 

[Dartanboy]

The Plaintiff seeks to amend the complaint, adding:

Fact 11. The Commonwealth finally provided evidence (although the Plaintiff finds it incomplete and noncompelling) however they have done so long after the seizure and only after it was contested in court (see D-006).

 

[ko531]

The Plaintiff seeks to amend the complaint, adding:

Fact 11. The Commonwealth finally provided evidence (although the Plaintiff finds it incomplete and noncompelling) however they have done so long after the seizure and only after it was contested in court (see D-006).

granted

 

[asexualdinosaur]

INTERROGATORY
4. What steps did the Commonwealth take to attempt to resolve the alleged issue through a course of action other than seizure of Vanguard's banks?

The commonwealth regularly takes reports from financial institutions to keep track of tax reporting.
In part of these regular reports, the DOC has asked for clarification or clarified reports from Vanguard that had not been provided.
When Vanguard lost tax exemption status- there was an agreement for an audit of Vanguard that was not followed through prior to the seizure.