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Case: Pending Nim Surname v. Vanguard National Bank (2025) CV 04

Your Honor,


The court set a 48-hour deadline for submitting witness lists, starting from Wednesday at 9:34 PM. The Plaintiff did not submit their request until Friday at 10:28 PM, which is 54 minutes past the deadline.


Given that procedural deadlines are in place to ensure fairness and efficiency, I respectfully request that their witness request be ruled invalid due to late submission.
 
Your Honor,

The timeline of this request is clearly related to concern by the Defendant on the questions provided, not the submission time of the witness list. I had unfortunate real-world concerns that prevented the posting of the witness list, which is why I apologized for what was a brief delay of less than one hour.

Under Eastern Standard Time, the defense had all of Saturday, Sunday, Monday, and Tuesday to raise this complaint, a greater than 96 hour timeframe to raise an objection. The defense was clearly present, because they signaled that they were for the witness summons. This objection is not in line with the spirit of the law, but is instead a clear attempt to avoid having to answer questions that clearly support the Plaintiff's case.

I respectfully request you rule against this objection.
 
The witness is asked to answer the questions posed by the Plaintiff.
 
The witness has 48 hours to answer the questions before they are held in contempt. @Nexalin
 
Motion For Reconsideration

Your Honor,

The witness has had 72 hours from your order to respond to actually respond to the questions, and has failed to do so. The common timeframe for requiring a response in the court is 48 hours, at most. There is no precedent for an individual to be granted 96 hours of time to respond to the court without having requested an extension. I am requesting the witness be held in contempt of court.



Request to Advance Trial

Your Honor, every day that goes by is another day my client is without access to his wrongfully frozen funds. If the Defendant refuses to answer questions as a witness, then to avoid dragging this trial out any further, I would request we move past this witness. I would request, however, that the court notes the failure of the Defendant to answer the questions.



Request to Call Witnesses

Given the failure of the witness to respond, the Plaintiff needs to call additional witnesses to better establish the case, that we would have otherwise been able to use the missing witness for.

As such, I am requesting the court add Oliver Spy, Nanicholls Nanicholls, and Nopuu Catenjoyer to the witness list, and issue a summons. These individuals can testify to the facts and necessity of the damages the Plaintiff is requesting.



Amendment to the Prayer Of Relief

Your Honor, this case was filed nearly a full month ago, and the Defendant’s own delays, including waiting to challenge the witness list and then failing to respond when ordered by the court, have increased the cost of representation for my client.

As such, it is my unfortunate responsibility to amend the prayer for relief one final time, to finalize the costs my client has accumulated and will continue to accumulate the longer this trial takes.

I have provided a fully updated prayer for relief for you here:

1) A ruling that Vanguard National Bank has committed a material breach of their contractual obligations, that orders the immediate unfreezing of the Plaintiff's assets and transfer to his person.
2) Compensatory damages in the amount of $10,000, to cover the harm incurred to the Plaintiff for being unable to access his funds for a week.
3) Special damages in the amount of $25,000, to cover the attorney's fees the Plaintiff would not have incurred without the Defendant's actions.
4) Payment by the Defendant of all court fees, including witness fees, incurred by the Plaintiff.
 
The Court will reject the motion for reconsideration at this time. The witness, Nexalin, must respond to the 48-hour deadline that was specified yesterday. If he fails to do so, he will be held in contempt of court.

In addition, your request to advance the trial has been rejected. Given the large amount of money that the Plaintiff is seeking in this lawsuit, it is important that the full facts of the case are heard. If the Defendant is unable to adequately respond and engage with the Court, they are advised to hire legal counsel as soon as possible.

As for the additional witnesses, please be advised that per the Miscellaneous Changes & Foreign Affairs Omnibus Act, you (or your client) will unfortunately be required to pay any witness summoned a total sum of $250 for their initial summons. If you still wish to summon these three witnesses after the current witnesses answers the questions accordingly, the Court will allow it.
 
Motion for Sanctions

Your Honor, the witness has failed to respond by the court-appointed time. We are requesting he be held in contempt.


Motion for Reconsideration

Your Honor, you previously denied our request to advance the trial. Given that the witness has now failed to appear within the court’s newly appointed timeframe, we are requesting you reconsider your decision to deny the request to advance the trial.


Calling of the Witnesses

Your Honor, we are prepared to pay the $750 to summon Oliver Spy, Nanicholls Nanicholls, and Nopuu Catenjoyer to the court as witnesses. However, we request formal clarification from the court that these witness fees are included in the payment of court fees requested in our prayer for relief, and so, should we win the case, the Defendant shall be ordered to reimburse the Plaintiff for the cost of the witnesses.
 
Seeing as the witness has been given ample time to respond to the questions, the Court will accept the Plaintiff's motion for sanctions. It has been more than one week since the witness was asked these questions, and they missed the Court's generous deadlines to respond, the Court will be hereby charging the witness, Nexalin, with contempt of court for failure to respond. The Ministry of Justice is hereby ordered to fine Nexalin a total sum of $500 and jail him for 10 minutes accordingly.

The Court cautions to Nexalin, as both representing the Defence and as a witness called in this case, to respond to the Court in a timely manner. Repeated and flagrant ignorance of deadlines may risk the Court being obligated to deliver a default judgement. The Court is relying on the responsiveness of the Defence so that the full extent of facts in this case can be heard. @Nexalin
 
Motion for Sanctions

Your Honor, the witness has failed to respond by the court-appointed time. We are requesting he be held in contempt.

Motion for Reconsideration
Your Honor, you previously denied our request to advance the trial. Given that the witness has now failed to appear within the court’s newly appointed timeframe, we are requesting you reconsider your decision to deny the request to advance the trial.

Calling of the Witnesses
Your Honor, we are prepared to pay the $750 to summon Oliver Spy, Nanicholls Nanicholls, and Nopuu Catenjoyer to the court as witnesses. However, we request formal clarification from the court that these witness fees are included in the payment of court fees requested in our prayer for relief, and so, should we win the case, the Defendant shall be ordered to reimburse the Plaintiff for the cost of the witnesses.

The Court will be rejecting your motion for reconsideration. This case involves a significantly large sum of money and consideration over the terms of service as it relates to the Vanguard National Bank. To advance this trial at such a stage would be a miscarriage of justice. That being said, a motion for an expedited hearing would be in order only if the Defendant also agreed to such, as outlined in the Motions and Objections page.

The Miscellaneous Changes & Foreign Affairs Omnibus Act outlines under §12b that "Court Fees are paid at the end of a lawsuit." It also provides discretion to the Court to determine whether the other party pay the court fees of the plaintiff as part of relief in the case. The Court is open to allowing it in the prayer for relief, but in such a circumstance it is important that excessive witness summons' and other variable-based fees are avoided as to ensure that one party is not causing undue financial burden on the other.

If you wish to call these witnesses, the Court will ask you explain the purpose of their testimony and how it would explain your case.
 
Your Honor,

This court has previously ruled against granting damages requested by Plaintiffs on the basis that the requests were not sufficiently justified. This occurred in:
- Fluffywaafelz v. ko531 (2024) CV 03 https://www.cityrp.org/threads/fluffywaafelz-v-ko531-2024-cv-03.103/, where the court stated that "the Plaintiff did not provide any evidence or case to support... the "mental stress" claim." and "the Plaintiff failed to sufficiently justify why punitive damages should be placed upon the Defendant or to justify a $501 valuation."
- Partially in Nanicholls v Azalea Isles (2025) CV 01 https://www.cityrp.org/threads/nanicholls-v-azalea-isles-2025-cv-01.140/, where although the Plaintiff lost the case, the court specifically addressed failure to prove damages in its verdict, "The Plaintiff has not proven that the Defendant otherwise caused reputational damage to them."
- Azalea Isles v. Galavance (2025) CR 03 https://www.cityrp.org/threads/azalea-isles-v-galavance-2025-cr-03.139/, in which the court later clarified in the courtroom "Aside from legal fees, in requesting these counter-damages, the Defendant asked for it on the basis of reputational harm and "other damages" incurred as a result of "malicious prosecution." Based on the current facts of the case, and as you can see in the ruling, no evidence has been offered and little argumentation has been given as to why this case would have been maliciously prosecuted." found here https://discord.com/channels/1162047422327967766/1231778372615671909/1347325797278421084

Given the court has previously denied damages due to lack of justification, I am calling these witnesses to address damages. Witnesses are not required to have directly witnessed an event, or even necessarily have knowledge of its occurrence. They can testify to external facts that support a case. This precedent was set in Azalea Isles v. Krix (2024) CR 01 https://www.cityrp.org/threads/azalea-isles-v-krix-2024-cr-01.30/, where RandomIntruder and Welsh_Mongoose (now Fergie_Foo) were called as witnesses to speak on probabilities.

Oliver Spy is the sitting Minister of Justice and a fellow lawyer. He will be asked to testify on the fees that another lawyer, such as himself, might charge in a civil case, and to testify as to the supply of lawyers in existence. Oliver Spy's testimony will allow me to cement the necessity of our requested special damages through addressing how few lawyers exist and what he might personally charge for a civil case, demonstrating that the special damages for legal fees are not overinflated but are in fact an accurate representation of what my client has or will incurred.

Nanicholls Nanicholls is a business owner and Member of Parliament who is also likely familiar with the restriction supply places on legal options, and how that influences the price. As a business owner and an individual who has leveled up to the maximum in several trades, he is also qualified to testify to how damaging it would be to lose complete access to one's funds, and the damages one might incur in missed opportunities, inability to level up to a level that can create useful or necessary goods, and so on. Nanicholls' testimony will address both the special damages, by addressing the restriction on the number of lawyers, and the compensatory damages, by proving harm and loss suffered by the Plaintiff.

Nopuu Catenjoyer is the Minister of Social Services, and thus would be expected to have a general knowledge of all the trades. Nopuu Catenjoyer would be asked to testify to the cost of leveling up these trades, and the potential difficulty in advancing without having access to funds. This would speak directly to, once again, proven harm, as the Plaintiff has been directly harmed by being unable to advance in any trade, buy any good, or engage in most of the economy to the extent he would be able to had his funds never been frozen.
 
Writ of Summons - Witnesses

Azalea Isles Civil Court (CV)


Case No. CV-25-04

Plaintiff: Nim Surname (Nimq_)
Defendant: Vanguard National Bank
The Court will be calling two out of the three requested witnesses. This is because Nanicholls and Nopuu both have the same expertise as it relates to trade jobs, and Nopuu would likely have more insight to speak to this as Minister of Social Services. This is to avoid duplicate testimony and unnessecary court fees in light of the current laws.

Therefore, the following individuals are required to appear before the court:
  • Oliver Spy (spyrolix)​
  • Nopuu Catenjoyer (Nopuu).​
Please indicate your presence in this thread. Failure to respond within 72 hours may result in contempt of court.

The Plaintiff is asked to provide their questions as soon as possible.

Signed,
Hon. Justice Raymond West

 
Oliver Spy

1) How many active lawyers would you estimate there to be in the Azalea Isles?

2) Of that number, how many would you trust to competently execute legal duties?

3) We have spoken before about the proper amount to charge an individual for various legal services. What would you typically charge in the average civil suit?

4) Given supply constraints when it comes to the number of lawyers, could the going rate or charge for a civil suit be higher than the amount and/or percentage you gave in your answer to question 3?


Nopuu Catenjoyer

1) In your estimation, how much do the specialist trades such as industrialist, mechanic, and gunsmith, cost to level up to max? You may give more than one answer if need be, I recognize the costs can vary.

2) Are the best goods and services an individual can provide usually achieved by leveling up a profession to max? For example, a max industrialist versus a level two or three.

3) Given these answers, wouldn't an individual's progress in these more lucrative trades be dramatically slowed if they were unable to access their funds?

4) If an individual was unable to progress in these trades, would that not harm their ability to participate within the Azalea Isles, given many events are combat-oriented, and such an individual would be unable to offer the higher-tier products and services that bring in better income locked behind progression?
 
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