Lawsuit: Pending Nimq_ vs Crown

[Nim]

IN THE MAGISTRATES COURT OF THE KINGDOM OF ALEXANDRIA
CIVIL ACTION

Plaintiff: Nimq_
Defendant: Crown

I. Jurisdiction and Venue​

1. This Court has jurisdiction over this matter pursuant to §14 of the Constitution of the Kingdom of Alexandria, which vests judicial power in the courts to interpret and administer the law.
2. Venue is proper in this Court because the incident giving rise to this claim occurred within the jurisdiction of the Magistrates Court, which has authority over civil matters.

II. Facts​

1. On April 12, at approximately 8:10, Plaintiff Nimq_ was traveling on foot along The Unnamed Big Road surrounding the city.
2. Due to the negligent failure of the Defendant, the Crown, to maintain the road or area in a safe condition, a dangerous and unmarked cliff edge was present.
3. The cliff edge, which was approximately 5.5 meters, was not visible to the Plaintiff due to the lack of proper signage, barriers, or warnings.
4. As a direct and proximate result of the Defendant's negligence, Plaintiff fell from the cliff and sustained significant injuries.

III. Negligence of the Defendant​

1. The Crown, through its Ministry of Development, had a duty to maintain public roads and areas in a reasonably safe condition for use by citizens, as required under §22 of the Constitution, which guarantees the right to life, liberty, and security of the person.
2. The Crown breached this duty by failing to:
- Properly inspect and maintain the road or area.
- Provide adequate warnings or barriers to prevent falls from the dangerous cliff edge.
- Remedy the hazardous condition of the cliff edge.
3. The Crown’s negligence was the direct and proximate cause of the Plaintiff’s injuries and damages.

IV. Injuries and Damages​

1. As a direct and proximate result of the Defendant’s negligence, the Plaintiff sustained the following injuries:
- Loss of several hearts of health.
- Significant mental distress and fear resulting from the unexpected fall and potential for further harm.
- Loss of time and resources spent recovering from the fall.
1. As a further direct and proximate result of the Defendant’s negligence, the Plaintiff has incurred the following damages:
- Compensation for lost health and resources due to the Crown’s negligence, valued at £5,000.
- Payment for the mental distress caused by the lack of maintenance of a dangerous cliff.
- Monetary relief for the anxiety associated with traveling on Crown roads and infrastructure.

V. Prayer for Relief​

WHEREFORE, Plaintiff Nimq_ prays for the following relief:

1. Judgment against the Defendant, the Crown, for compensatory damages in an amount to be proven at trial, but believed to be in excess of £5,000.
2. Reimbursement for the loss of health and resources sustained.
3. Compensation for the mental distress and fear caused by the incident.
4. A formal apology from the Crown for the negligence that led to the Plaintiff’s injuries.
5. A directive from the Court ordering the Crown to immediately repair the dangerous cliff edge and implement safety measures (e.g., barriers, signage) to prevent future incidents.
6. Any other and further relief as the Court deems just and equitable.


Respectfully submitted,
Nimq_
April 12

 

[Greenish9]

In the Chancery of the Kingdom of Alexandria
ENTREATY OF DISMISSAL
Lack of Claim

The defense moves that the complaint in this case be dismissed, and in support thereof, respectfully alleges:

1. There is no reasonable connection between the right to "life, liberty, and security of the person" and having the right to infrastructure. While the Plaintiff claims that the state of the road was in violation of his rights, his participation in the use of this service was optional and as such the Plaintiff assumed the risks of its use. The Plaintiff's claim falls in line with a soldier that sues the government for getting shot in the line of duty. Just because something was operated by the government does not mean that the individual assumes no risk in its use.
2. Furthermore, the Plaintiff does not hold the right to "life, liberty, and security of the person." This is because this right is only designated to citizens, a title which does not exist in this Kingdom
3. Therefore, the Plaintiff is viable to have their complaint dismissed because of a lack of evidence for their claim for relief.

As such, we request the Court dismiss this complaint with prejudice​

 

[Nim]

PLAINTIFF'S RESPONSE TO DEFENDANT'S ENTREATY OF DISMISSAL

Plaintiff, Nimq_, hereby responds to the Defendant's Entreaty of Dismissal and respectfully requests that the Court deny the Entreaty and allow the case to proceed on its merits.

I. RESPONSE TO DEFENDANT'S ARGUMENT REGARDING §22 AND INFRASTRUCTURE

1. The Defendant misinterprets the scope and intent of §22 of the Constitution. The right to "life, liberty, and security of the person" is not merely a passive guarantee; it imposes an affirmative duty on the Crown to take reasonable steps to protect its inhabitants from foreseeable harm. This includes maintaining public infrastructure in a reasonably safe condition.
2. The Crown's analogy to a soldier injured in the line of duty is inapt. A soldier knowingly accepts risks inherent in military service. In contrast, an individual walking on a public road does not assume the risk of encountering a hidden, unmarked, and dangerous cliff edge due to the Crown's negligence. The reasonable expectation is that public roads will be maintained to a standard of reasonable safety.
3. The Plaintiff will provide evidence that the lack of maintenance was a clear and direct violation of expected standards, and that the dangerous nature of the cliff edge was both foreseeable and easily preventable through reasonable measures.

II. RESPONSE TO DEFENDANT'S ARGUMENT REGARDING PLAINTIFF'S CITIZENSHIP STATUS

1. The Defendant's assertion that the Plaintiff is not a citizen is a factual matter that must be proven, and the Defendant has provided no evidence to support this claim. The burden of proof lies with the Defendant to demonstrate that the Plaintiff is not entitled to the protections afforded to residents of the Kingdom of Alexandria.
2. Even if the Plaintiff is not formally considered a “citizen” under a narrow definition, the Plaintiff is a resident and inhabitant of the Kingdom of Alexandria, and as such, is entitled to the protection of its laws and the guarantee of basic safety and security. To argue otherwise would create a dangerous precedent, leaving a significant portion of the population without recourse against government negligence.
3. Furthermore, the Kingdom of Alexandria has only recently opened, and residency plots have not yet been offered or sold to the public. As such, it is impossible for the Plaintiff, or any other resident, to currently possess formal "citizenship" or residency beyond their physical presence within the Kingdom. The Defendant's argument is therefore both premature and disingenuous.
4. The Plaintiff intends to present evidence demonstrating their long-term residency, contributions to the Kingdom, and legitimate expectation of protection under its laws.

III. LACK OF EVIDENCE IS A MATTER FOR TRIAL

1. The Defendant's claim of "lack of evidence" is premature. The Plaintiff's initial complaint clearly outlines the Crown's alleged negligence, the resulting injuries, and the damages suffered.
2. The purpose of a trial is to present evidence and allow the Court to determine the merits of the claim. Dismissing the case at this stage, before the Plaintiff has had an opportunity to present their evidence, would be a gross miscarriage of justice.

IV. CONCLUSION

For the foregoing reasons, the Plaintiff respectfully requests that the Court deny the Defendant's Entreaty of Dismissal and allow this case to proceed to trial, where the Plaintiff will present evidence to substantiate their claims and seek appropriate relief.

Respectfully submitted,

Nimq_
April 14

 

[Gribble19]

IN THE MAGISTRATES COURT OF THE KINGDOM OF ALEXANDRIA
ORDER DENYING DEFENDANT'S ENTREATY OF DISMISSAL​

The court has reviewed the Defendant's Entreaty of Dismissal (#2) and the Plaintiff's response to the Entreaty (#3).
Defendant moves that the Complaint in this case be dismissed, alleging that there is a lack of evidence for Plaintiff's claim for relief, and the Plaintiff alleges that this claim of lack of evidence is premature. The court agrees with the Plaintiff in this regard. Discovery has not yet begun, let alone ended, and there will be ample time for the Plaintiff to submit evidence. Defendant has further used their Entreaty to argue against claims made by the Plaintiff in their Complaint, and the Plaintiff has responded to these arguments in their response. These arguments for or against the claims made in the Complaint do not serve to justify dismissal of this case for Lack of Claim. Arguments against the truth of a claim for relief do not constitute arguments for a Lack of Claim, as they do not imply a failure to state a claim for relief.

Accordingly, Defendant's Entreaty of Dismissal is hereby DENIED.

 

[Gribble19]

Defendant now has 48 hours to submit their Answer to Complaint.

 

[Greenish9]

ANSWER TO COMPLAINT
In the Magistrates Court of the Kingdom of Alexandria​

1. The Defendant does not contest that the Plaintiff was travelling across a road
2. The Defendant does not contest the Plaintiff's claims of the condition of the road
3. The Defendant does not contest the lack of signage or barriers nor the difficulty in visibility of the cliff the Plaintiff experienced. The Defense does contest and denies the height which the defendant fell, which was in fact 7 blocks instead of 5.5. The Defendant is willing and able to prove this fact in the process of Discovery.
4. The Defendant does not contest that the Plaintiff fell from the cliff nor that the Plaintiff's fall and the subsequent injury was caused by the Defendant not removing or marking the abnormality in the road. However, the Defendant does contest and denies the Plaintiff's characterization of his injuries as "significant." A 7 block fall, which the Plaintiff experienced, only causes 2 hearts of damage. This is certainly not a "significant" injury but rather a minor inconvenience. The Defendant is willing and able to prove this fact in the process of Discovery.
5. The Defendant denies the Plaintiff's claim that the Constitution guarantees the Plaintiff a protection from road hazards. The Plaintiff references part V § 22 clause 11 (hereafter referred to as Clause 11) of the Constitution to prove his claim but the issue with this is twofold. First of all, the loss of two hearts can not reasonably be determined as an infringement of life or liberty. Furthermore, the inadvertent loss of two hearts can not be, within the reasonable limits of the law that are justified in a free and democratic society, a violation of the Constitutional right to security. While the Defendant does affirm the state of a lack of measures put in place to protect the Plaintiff or others from the minor ill he sustained, the Defendant fully contests the notion of simply any minor injury sustained by someone to be a violation of this clause. Second of all, even if this were to be the case, the Plaintiff is not a citizen of the Kingdom of Alexandria and therefore is not provided with the protections listed in Clause 11. The Plaintiff's opinions or expectations on if he should or should not qualify for citizenship is not relevant in the face of the fact that the Plaintiff is not provably a citizen of the Kingdom. Additionally, the Defendant denies any flexibility with this right's application solely to citizens because as part I § 22 clause 7 of the Constitution states, "Parliament ensures laws protect citizens' rights and freedoms." It is very clear that the written intent of the Constitution was to have these rights ensured solely to the citizens of the Kingdom of Alexandria.
6. The Defendant denies the Plaintiff's claim that "the Crown breached [its] duty" because it had no duty to breach.
7. The Defendant does not contest that it was a part in the Plaintiff's (minor) injury.
8. The Defendant denies that the Plaintiff lost "several hearts of health." Several is, as the Oxford Dictionary so eloquently puts it, "more than two but not many." The Defendant also contests the Plaintiff's claim that any significant amount of mental distress or loss of time was caused by his fall.
9. The Defendant denies that the value of the injury incurred by the Plaintiff was worth £5,000. As previously established, the Plaintiff lost two hearts because of his fall. Additionally, it can be seen that the plaintiff was down 7.5 hunger bars at the time of his fall in the evidence he gave the court. While the Plaintiff already began regaining health immediately after the fall with limited hunger bars, which can be seen in the screenshot provided by the Plaintiff, we will be ignoring this to calculate the cost of the lost health (and the futility of including it will soon be evident.) As is common knowledge, the process by which a player regains hearts is by filling up their hunger slots and saturation (which is done by eating food.) Therefore, we can calculate the actual cost of the 2 hearts the Plaintiff lost by finding how much it would cost to purchase the food to replenish those hearts. We'll use two foods for this, just to make sure our calculations find the true range of this cost, Melon Slices and Baked Potatoes. In a series of statements that the Plaintiff made to a Counsel of the Defendant on 15/4/2025, Melon Slices are worth £0.1 per slice and Baked Potatoes are worth £0.5 per potato. The Defendant is willing and able to prove this fact in the process of Discovery. Melon Slices restore 2 hunger bars and 1.2 saturation, meaning the Plaintiff would have had to eat 4 of them to replenish his health, and Baked Potatoes restore 5 hunger bars and 6 saturation, meaning the Plaintiff would have had to eat 2 of them to replace his missing health. This puts the value of the injuries sustained by the Plaintiff between £0.4 and £1. Certainly not £5,000. The Defendant also denies any need to reimburse the Plaintiff for alleged mental distress and anxiety as a feeling of a lack of security is not analogous to an actual lack of security.

Finally, The Defendant reminds the Plaintiff and the Honorable Magistrate that any constitutional matters must be brought before the Chancery. If the Plaintiff continues only having his Constitutional rights as reason for entitlement to reimbursement, the Defendant supplicates the Honorable Magistrate to recuse themselves so this case may be heard by the Chancery.​

 

[Nim]

ENTREATY OF POINT OF ORDER

Plaintiff, Nimq_, hereby brings forth this Entreaty of Point of Order regarding the Defendant's request for recusal included in their Answer to Complaint.

ARGUMENT

1. IMPROPER FILING OF AN ENTREATY: The Defendant's request for recusal, while potentially a valid request in itself, was improperly filed within their Answer to Complaint. By including this motion within the answer, it attempts to obfuscate the rules of the court.
2. VIOLATION OF WRIT PROCEDURES: According to established court rules, "Writs are granted only upon request by a party. Requests must be titled 'Entreaty of [Subject]'." The Defendant did not file a separate "Entreaty of Recusal" as required by the rules.
3. FAILURE TO ALLOW PLAINTIFF TO ADEQUATELY RESPOND: Because the recusal request was embedded within the Answer to Complaint, it circumvents the established procedure that Plaintiff be given a dedicated amount of time to fully respond to an entreaty by defense. Filing in this way undercuts a major feature of the court rules.
4. PREJUDICE TO THE PLAINTIFF: This procedural irregularity prejudices the Plaintiff, as it deprives them of the right to a response with enough time. This can greatly impact the outcome of the situation if a hasty call is made. This filing is intentionally trying to impact how I can make a case.
5. MISREPRESENTATION OF COURT FUNCTION: The Constitution must be referenced as part of a point as to why the harm was done. The fact that the argument has to do with a constitutional right does not mean it has to be moved to another court.

RELIEF REQUESTED

For the foregoing reasons, the Plaintiff respectfully requests that the Court:

1. Strike the Defendant's request for recusal from their Answer to Complaint due to procedural deficiencies.
2. Direct the Defendant to file a separate "Entreaty of Recusal" if they wish to pursue this request, adhering to the established procedures and timelines.

Respectfully submitted,

Nimq_
April 16

 

[Gribble19]

IN THE MAGISTRATES COURT OF THE KINGDOM OF ALEXANDRIA
ORDER DENYING PLAINTIFF'S ENTREATY
​

The court has reviewed the Plaintiff's Entreaty (#7) and the Defendant's Answer to the Complaint (#6), to which the entreaty refers. The Defendant did not submit a response to the entreaty within the 24 hours allowed to do so per this court's rules and procedures.
The Plaintiff has submitted an entreaty which is not listed in this court's rules and procedures. This is allowed, however, in this situation it would have been more fitting to use one of the listed options, as a Writ of Striking would cover the action that the Plaintiff is requesting of the court. In the future, please ensure to make an entreaty from the list of possible writs if one of them is applicable to what you wish to request. Not doing so may result in a contempt charge.
The court agrees with the Plaintiff that the Defendant did not file an official request to the court to consider recusal, and the court will therefore not be considering the final paragraph of Defendant's Answer as such. The court rules and procedures clearly state that writs are only granted upon request by a party through the form of an Entreaty. For the sake of efficiency, the court will hereby also clarify that the recusal of the presiding magistrate would not result in the case being heard by the Chancery.
As the paragraph written by the Defendant is not an official request and will not be considered as such, the court does not find any procedural deficiencies with it. The court will not strike the paragraph from Defendant's Answer to Complaint, noting the lack of requirements for the format and structure of Answers to Complaints under this court's current rules and procedures. The court will not direct the Defendant to make any filings. Either party is free to file an Entreaty if they wish, as long as such is done in line with the court rules and procedures.

Accordingly, Plaintiff's Entreaty is hereby DENIED.

 

[Gribble19]

We will now enter Discovery for a period of 72 hours. Discovery may be extended or ended early through the methods prescribed by the court rules and procedures.

 

[Nim]

AMENDMENT TO COMPLAINT

Plaintiff, Nimq_, hereby amends the original Complaint as follows:

I. AMENDMENT TO FACTS (SECTION II)

1. Paragraph 3 is amended to read as follows:
"The cliff edge, which was approximately 7 meters, was not visible to the Plaintiff due to the lack of proper signage, barriers, or warnings."

II. AMENDMENT TO PRAYER FOR RELIEF (SECTION V)

1. Paragraph 1 is amended to read as follows:

"Judgment against the Defendant, the Crown, for compensatory and punitive damages in the amount of £1,100." This is comprised of £100 for Damages and £1,000 for Punitive Damages

REASONS FOR AMENDMENT

The Plaintiff is seeking to amend paragraph 3 to more accurately indicate the height of the fall that caused the injury in question, as well as update the amount as it is an amount more likely to succeed.

Respectfully submitted,

Nimq_
April 18

 

[Nim]

ENTREATY TO COMPEL: OFFICIAL ROAD NAME

Plaintiff, Nimq_, hereby requests that the Court compel the Defendant, the Crown, to provide the following information within 24 hours:

1. The official name, if any, of the road described in the Plaintiff's initial complaint as "The Unnamed Big Road surrounding the city of Alexandria," specifically the section of the road where the incident occurred (as described in the Plaintiff's initial complaint).

RELEVANCE

The official name of the road, if one exists, is relevant for the following reasons:

a. It will help to provide greater clarity and precision in identifying the location of the incident.
b. It may assist in locating relevant records and documents related to the road's maintenance and safety.
c. It may be a matter of public record, which the Plaintiff is entitled to access.

Respectfully submitted,

Nimq_
April 18

 

[Nim]

ENTREATY TO COMPEL: MAINTENANCE RECORDS FOR THE UNNAMED BIG ROAD

Plaintiff, Nimq_, hereby requests that the Court compel the Defendant, the Crown, to produce the following documents within 24 hours:

1. All maintenance records relating to the Unnamed Big Road surrounding the city of Alexandria, specifically for the section of the road where the incident occurred (as described in the Plaintiff's initial complaint), for the period between January 1, 2025, and April 18, 2025.

RELEVANCE

These records are relevant to establishing the Crown's negligence in failing to maintain the road in a reasonably safe condition. The records may demonstrate a lack of inspections, repairs, or warnings regarding the dangerous cliff edge, both before and after the incident. Showing a continued lack of action even after the incident will further demonstrate the Crown's disregard for public safety and reinforce the need for the court to order corrective measures.

Respectfully submitted,

Nimq_
April 18

 

[Nim]

ENTREATY TO COMPEL: COMMUNICATIONS REGARDING THE CLIFF EDGE

Plaintiff, Nimq_, hereby requests that the Court compel the Defendant, the Crown, to produce the following documents within 24 hours:

1. All internal communications relating to the existence of the cliff edge on the Unnamed Big Road surrounding the city of Alexandria, specifically for the section of the road where the incident occurred (as described in the Plaintiff's initial complaint), for the period between January 1, 2025, and April 18, 2025.

RELEVANCE

These communications are relevant to establishing the Crown's awareness of the dangerous condition and any discussions regarding potential safety measures or remediation efforts.

Respectfully submitted,

Nimq_
April 18

 

[Greenish9]

SUBMISSION OF DISCOVERY
In the Magistrates Court of the Kingdom of Alexandria

1. The Defendant is not aware of any official name for the Unnamed Big Road surrounding the City of Alexandria.
2. The Defendant does not have in its possession any maintenance records as the server was created 6 days ago.
3. The Defendant does not have in its possession any internal communications on the cliff as the Plaintiff's complaint is what made the Defendant aware of its existence as a result of the server being created six days ago.
18/4/25​

 

[Greenish9]

SUBMISSION OF DISCOVERY
In the Magistrates Court of the Kingdom of Alexandria

The Defendant, in lieu of §9 of its Answer to Complaint, hereby submits the following documents to the Court;

d-001


d-002
​

 

[Greenish9]

ENTREATY TO DISMISS
In the Magistrate's Court of the Kingdom of Alexandria
Original Jurisdiction

The defense moves that the complaint in this case be dismissed, and in support thereof, respectfully alleges:

Honorable Magistrate, in this case the Plaintiff has posed an interesting question. To what bounds does the life and liberty clause apply and what protections does it ensure? More specifically, the Plaintiff is claiming that they are owed safe roads because of this right. However this is a constitutional one. One that should be heard by the Chancery because as you well know, only the Chancery can rule on constitutional matters. With this motion the Defendant is not making a statement on their opinion on the case, simply that it is better suited in a higher court. That is why the Defendant supplicates the Court to dismiss this case without prejudice.
4/18/25​

 

[Nim]

PLAINTIFF'S RESPONSE TO DEFENDANT'S ENTREATY TO DISMISS

Plaintiff, Nimq_, hereby responds to the Defendant's Entreaty to Dismiss (#16) and respectfully requests that the Court deny the Entreaty.

I. THE NATURE OF THE CLAIM REMAINS A CIVIL ACTION WITHIN THE MAGISTRATES COURT'S JURISDICTION

1. The Defendant's Entreaty incorrectly characterizes the Plaintiff's claim as primarily a "constitutional matter" that must be heard by the Chancery.
2. While the Plaintiff's Complaint references §22 of the Constitution, this is done to establish the duty owed by the Crown to its inhabitants regarding safety and security, which forms the basis of a negligence claim.
3. The core of this lawsuit is a claim of negligence against the Crown for failing to maintain public infrastructure in a safe condition, resulting in the Plaintiff's injury. Negligence actions are standard civil matters explicitly within the jurisdiction of the Magistrates Court ("JURISDICTION—ROUTINE MATTERS").

II. CITING A CONSTITUTIONAL DUTY DOES NOT AUTOMATICALLY TRANSFER JURISDICTION

1. The fact that a constitutional provision may inform or establish a duty of care relevant to a civil claim does not automatically transform the case into a "Constitutional Matter" solely within the Chancery's original jurisdiction.
2. A "Constitutional Matter" as understood by the Court Hierarchy rules typically involves direct challenges to the constitutionality of laws or governmental actions, or public interest cases seeking declarations regarding the Constitution. This case is not a challenge to a law, but rather an application of legal principles (including a duty derived from the Constitution) to the Crown's alleged failure to act reasonably.
3. The Magistrates Court, in its role of interpreting and administering the law as per §14 of the Constitution, is fully capable of considering how constitutional provisions inform duties within the context of a negligence claim.

III. THE COURT HAS ALREADY ADDRESSED THE SUGGESTION OF CHANCERY JURISDICTION

1. The Defendant previously suggested, within their Answer to Complaint (#6), that constitutional matters must be brought before the Chancery.
2. The Court, in its Order Denying Plaintiff's Entreaty (#8), specifically addressed this point, clarifying "that the recusal of the presiding magistrate would not result in the case being heard by the Chancery." While this was in the context of a recusal request, it demonstrates the Court's view that the mere mention of a constitutional right does not mandate a transfer to the Chancery.

IV. DISMISSAL BASED ON ORIGINAL JURISDICTION IS INAPPROPRIATE

1. The "Original Jurisdiction" dismissal rule applies when a case is "incorrectly filed" in a court that lacks the authority to hear the type of matter presented.
2. As established, this is fundamentally a civil negligence case, which is appropriately filed in the Magistrates Court. The inclusion of an argument referencing a constitutional duty does not divest this Court of its jurisdiction over the negligence claim.

V. CONCLUSION

For the foregoing reasons, the Plaintiff respectfully requests that the Court deny the Defendant's Entreaty to Dismiss. The case is properly before the Magistrates Court as a civil action, and the reference to a constitutional duty does not strip this Court of its original jurisdiction over negligence claims.

Respectfully submitted,

Nimq_
April 18, 2025

 

[Greenish9]

View attachment 49
ENTREATY TO DISMISS
In the Magistrate's Court of the Kingdom of Alexandria
Original Jurisdiction

The defense moves that the complaint in this case be dismissed, and in support thereof, respectfully alleges:

Honorable Magistrate, in this case the Plaintiff has posed an interesting question. To what bounds does the life and liberty clause apply and what protections does it ensure? More specifically, the Plaintiff is claiming that they are owed safe roads because of this right. However this is a constitutional one. One that should be heard by the Chancery because as you well know, only the Chancery can rule on constitutional matters. With this motion the Defendant is not making a statement on their opinion on the case, simply that it is better suited in a higher court. That is why the Defendant supplicates the Court to dismiss this case without prejudice.
4/18/25​

AMENDMENT TO ENTREATY
In the Magistrate's Court of the Kingdom of Alexandria

The Defendant hereby motions to refile its Entreaty to Dismiss as an Entreaty of Removal because it more thoroughly fits the nature of its request. The Defendant did not originally file it as an Entreaty of Removal because that was not an option at the time of its filing.
4/20/25​

 

[Nim]

ENTREATY FOR CLARIFICATION
OF COURT RULES REGARDING ENTREATY AMENDMENTS

To the Honorable Magistrate,

Plaintiff, Nimq_, hereby submits this Entreaty for Clarification of Court Rules regarding the amendment of Entreaties. This Entreaty arises from the Defendant's recent actions in this case, specifically their attempt to amend their "Entreaty to Dismiss" into an "Entreaty of Removal" (filing #18) after the Plaintiff had already filed a response, the response deadline had expired, and the Magistrate had not yet ruled on the original Entreaty.

ARGUMENT

1. ABSENCE OF EXPLICIT RULE:

The "General Court Rules and Procedures" and the "Magistrates' Court Rules and Procedures" are silent on the matter of amending Entreaties. While the rules address amending Complaints and Answers, there is no corresponding provision for Entreaties. This silence creates ambiguity and potential for abuse.

2. POTENTIAL FOR PREJUDICE:

Allowing the amendment of Entreaties after a response has been filed, the response deadline has expired, and without a ruling from the Magistrate prejudices the responding party. It forces them to address a moving target, undermines the purpose of the response deadline and the judicial review process, and disrupts the orderly process of the court.

3. EQUITABLE CONSIDERATIONS:

Given the lack of explicit rules, the Court must consider equitable principles. Allowing amendments to Entreaties without clear guidelines or limitations, and without requiring a ruling on the original motion first, could lead to tactical maneuvering and unfair advantage, contrary to the Guiding Principles of the Judiciary.

4. MAGISTRATE'S DUTY TO RULE:

The Magistrate has a duty to rule on motions presented to the Court in a timely manner. Allowing a party to circumvent this process by amending their motion before a ruling is made effectively nullifies the Magistrate's role in reviewing and deciding on the original motion. In addition, the Chansellor would respond to an amended motion, and the motion should never have been amended in the first place

RELIEF REQUESTED

For the foregoing reasons, the Plaintiff respectfully requests that the Court:

1. Issue a ruling clarifying whether Entreaties can be amended, and if so, under what circumstances and subject to what limitations. Specifically, the ruling should address the permissibility of amending an Entreaty after a response has been filed, the response deadline has passed, and before the Magistrate has ruled on the original Entreaty.

2. Direct the Defendant to adhere to the Court's clarification regarding Entreaty amendments in this case.

3. Respectfully request that the Court direct the Magistrate to rule on the original "Entreaty to Dismiss" before considering any amended version.

Respectfully submitted,

Nimq_
April 20, 2025

 

[Nim]

ENTREATY OF PROMPTING

Plaintiff, Nimq_, hereby submits this Entreaty of Prompting to respectfully request that the Court issue a ruling on the Plaintiff's "Entreaty for Clarification of Court Rules Regarding Entreaty Amendments" (filed April 20, 2025).

ARGUMENT

1. PENDING RULING: The Plaintiff's "Entreaty for Clarification of Court Rules Regarding Entreaty Amendments" has been pending before the Court since April 20, 2025.

2. DELAY IN DECISION: The Court has not yet issued a ruling on the request for clarification, and it has been 4 days.

3. MATERIAL IMPACT: It will greatly assist with further problems that happen in this court

RELIEF REQUESTED

For the foregoing reasons, the Plaintiff respectfully requests that the Court promptly issue a ruling on the Plaintiff's "Entreaty for Clarification of Court Rules Regarding Entreaty Amendments" so that this matter can proceed in a timely and orderly fashion.

Respectfully submitted,

Nimq_
April 24, 2025