Lawsuit: Adjourned Moyfr v. Crown, Case 4 (Ch. 2025)

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In the Chancery of the Kingdom of Alexandria
COMPLAINT ANSWER RE: Moyer v. Crown

Prior to the presentation of this answer, the Crown would like to express its appreciation for the ongoing flexibility displayed by the Plaintiff and the Court in these proceedings.
Contestation of Facts:

I - "The existing constitution of the Kingdom of Alexandria lacks a clear definition and criteria for granting citizenship."

The Defense does not contest the first fact.

II - "The existing constitution of the Kingdom of Alexandria does not give Parliament the authority to grant citizenship."

The Defense denies the second fact.

Section 3 of Part I of the Constitution empowers the Parliament with "the authority to create, amend, and repeal laws." Barring any explicit provision for the extension of citizenship to players, it is entirely within the constitutional purview of the Crown to legislate on questions of citizenship. Naturally, such legislation must itself be constitutionally sound, but the idea that the current Constitution prohibits the Parliament from acting at all with respect to citizenship is a spurious one.

III - Provisions in the current immigration law violate the constitution directly. For example:

The constitution states," The following rights and freedoms are guaranteed, subject only to such reasonable limits prescribed by law that are justified in a free and democratic society."
  1. The right to participate in and run for office
  2. The right to vote in elections and referendums provided the player meets the activity requirements set by law.
  3. The right to secret ballot in elections and referendums
  4. The right to appeal a charge made against them
  5. No citizen can be made to produce self-incriminating evidence in a court of law, parliamentary hearing, subpoena, or impeachment trial
  6. Freedom of political communication, press, and media
  7. The right to a speedy and fair trial presided over by an impartial Judicial Officer and to be informed of the nature of the charges brought against them
  8. The right to peacefully assemble
  9. Freedom of association
  10. Every citizen is equal before and under the law
  11. Every citizen has the right to life, liberty, and security of the person and the right not to be deprived thereof
  12. Every citizen has the right to be secure against unreasonable search and seizure
  13. Every citizen has the right to be informed of the reason for a subpoena, detention, charge, or arrest made against them
The Immigration and Citizenship Act states:
Section (5) - Residents
(2) Residents have all rights and abilities of a citizen, but may not receive security clearances or run for public office.

This provision goes against the guaranteed freedoms and rights provided by the constitution, as it specifically does not mention that you need to be a citizen to run for office, whereas it specifies in later provisions that citizens are given specific rights. This illustrates two things: One, that the founders specifically included citizenship on some provisions but not others, giving the legislature no right to prevent rights from being given to non-citizens. Two, the law makes unreasonable limits which are not justified and go against our free society.

The Defense affirms the following aspects of the third fact:

1) The Plaintiff's citations of the Constitution and The Immigration and Citizenship Act.​
2) The Plaintiff's observation that the current Constitution does not require citizenship for political participation.​

The Defense denies the following aspects of the third fact:

1) The Plaintiff's claim that the absence of a requirement means political participation cannot be reserved for citizens.​
While it is true that the current Constitution does not require citizenship for political participation, it also reserves certain rights for citizens, notably including equality before the law. This, by itself, might superficially be construed as a glaring error in our Kingdom's constitutional framework, but it is in moments like these that it is appropriate to return to an originalist approach.​
Was the intent of the founders to wholly bar non-citizens from legal equality?​
No, non-citizens are clearly entitled to broad legal equality under the Constitution's self-description of the Kingdom as "a free and democratic society."​
If legal equality is guaranteed to non-citizens, what does it mean for citizens to be privileged before the law?​
Obviously, the founders did not intend to create a caste system. By framing certain rights first, including the possibility for absolute and universal political participation, they sought to establish the framework for the "free and democratic society" mentioned immediately beforehand. They then followed these with certain rights reserved constitutionally for citizens to permit a mechanism for the modification of non-citizen rights, entrusting customary and common law to guide the way on "reasonable limits prescribed by law."​
Constitutionally speaking, is The Immigration and Citizenship Act a reasonable limit?​
It is the opinion of the Defense that the ability to bar non-citizens from political participation on legislative discretion is a reasonable limit. Citizenship and political participation are key to sovereignty. If a government cannot regulate who is a citizen and whether non-citizens can vote, our entire democratic system would be weakened at a critical phase in its development. We are nearing our first election which will set the course for the future development of the nation's core institutions; ensuring those who have a say in government are committed to our future is a perfectly reasonable measure in a nascent democratic society. Moreover, it is common practice among other developed, liberal democracies.​
2) The Plaintiff's assertion that the distinction in citizen rights bars Parliament from modifying non-citizen rights.​
This is illogical on its face. If the founders intended for non-citizens to have the same rights as citizens at all times, they would have simply never made the distinction in the first place. In fact, the distinction is more probative of the Parliament's ability to modify than not, as it seems to be more of a structural appeal to the basic extension of certain rights to non-citizens during an early phase in the nation's life: a critical time when flexibility in citizenship definitions is required.​
3) The Plaintiff's assertion that "the law makes unreasonable limits which are not justified and go against our free society."​

Here, the Plaintiff does not further illustrate how the law makes unreasonable limits beyond the above discussion of citizenship and political participation. They also do not elaborate on how these undescribed limits "go against our free society."​
IV. The Immigration and Citizenship act places an undue burden on immigrants and residents of the Kingdom of Alexandria.

As it stands currently, the Immigration and Citizenship Act places two tests in the way of immigrants who arrive from foreign lands. The first being the Residency Exam and the second being the Citizenship Exam. These tests are akin to that of a poll tax or literacy test, are we such a low society to not realize that placing these barriers could serve to deter or push would-be citizens away?

May I further point out that the Residency Exam must be passed with a 100% score and the Citizenship Exam with an 80% score. What would happen to a poor soul who maybe mistypes or selects an answer question and is all of a sudden barred from becoming a citizen or resident? This is not only unfair but excessive punishment to immigrants or residents who wish to become citizens.

The Defense affirms the following aspects of the fourth fact:

1) The imposition of the Residency and Citizenship Exams by The Immigration and Citizenship Act.​

The Defense denies the following aspects of the fourth fact:

1) The Residency and Citizenship exams are equivalent to a poll tax or literacy test.​
This is a fundamentally misleading characterization by the Plaintiff. Neither exam is required to have a fee under the Act and, therefore, cannot be construed as poll taxes. The literacy test claim is similarly spurious. For instance, the Residency Exam consists of only two Yes/No questions asking if the given player is interested in becoming a citizen and for their acknowledgement to obey the law. This requires less literacy than it takes to even visit the Kingdom in the first place and cannot reasonably be viewed as a literacy test or "undue burden." There are also no limitations on the number of times exams may be taken, so the worry over mistyping is likewise unfounded.​
2) The Plaintiff's claim that the Residency and Citizenship Exams would deter potential citizens.​
As elaborated previously, the Residency Exam is trivially difficult. However, this should not be taken to mean that it is meaningless. Upon joining, new players will immediately have something to do: become a resident. This process rewards them with a title, motivating an engaged public. The Citizenship Exam is then a new goal for them to work towards as they establish themselves, explore, and otherwise integrate themselves into the Kingdom. Regardless of which argument one believes, both are also hypotheticals and cannot be used as the factual basis for a constitutional decision of such magnitude weighed against the real implications for sovereignty outlined earlier.​
V. The law bars "tourists" of Alexandria from voting in elections, becoming employed, opening bank accounts, opening a business, owning property, and receiving grants in the Kingdom of Alexandria.

This fundamentally goes against the "life, liberty, and security" clause of the Constitution as, not only does the clause gives no mention of "citizen", but there is no way a tourist could survive, thrive, or defend themselves without being able to access these fundamental services that are only given to citizens.

Furthermore, as a current player of StateCraft, I cannot do any of these things and have to rely on the timing and decision of someone else to determine whether I get these supposed "guaranteed rights" or not.

The Defense denies the fifth fact, as it is predicated on a clear misreading of the Constitution. The actual clause reads, "Every citizen has the right to life, liberty, and security of the person and the right not to be deprived thereof." Therefore, it is a reserved right. Additionally, the point itself is irrelevant, as citizenship itself does not materially impact one's ability to "survive, thrive, or defend themselves." If this were not the case, everyone in the Kingdom today, which has yet to implement the citizenship system, would be struggling to survive.

VI. Those who do not agree with the political or governmental structure of the Kingdom of Alexandria are put at a disadvantage and can ultimately be discriminated against in any citizenship process.

When on the server, after saying my views of my distaste with the kingdom and recent legislation, I was threatened with having my life taken and also not being able to get citizenship as I was a "traitor".

The Defense denies the sixth fact. Any potential injuries here are not the responsibility of the Crown and are immaterial to the Constitutional question at hand here.

VII. This lawsuit is being made after RealImza v. Crown, Case 1 (Ch. 2025), in which the Immigrant and Citizenship Act was going through Parliament, the court stated that," The Chancery does not see the need to grant an answer to this question at this time." Further stating that." A proposal within Parliament has been brought that clarifies this question soundly fails the test of having a reasonable and effective means to challenge the law."

Further grounds to hold off a firm decision was due to the reasoning that," Put simply, this issue is one that has not directly harmed the Petitioner."

As a member of the minority who now falls under the new law's jurisdiction and who is also not legally a citizen, further as someone who has been directly affected by this new law, I believe I have firm grounds to challenge the law in court.

The Defense denies the seventh fact. It is impossible for someone to be affected by a law that has yet to actually be implemented in practice.

Statement of Defense:

With respect to the revised Claims for Relief, the Defense views the first Claim as having no factual or legal basis by cross-application of the Crown's contestation of the third Fact.

The Defense views the second Claim as having no factual basis by cross-application of the Crown's contestation of the seventh Fact, regarding the impossibility of being deprived of one's rights prior to the enforcement of a given law.

The Defense views the third Claim as having no factual basis due to the preponderance of all the facts denied in the contestation. In particular, it is impossible to be treated differently (and thereby injured) by a law that has yet to start affecting the lives of anyone.

The Defense thanks the Plaintiff and this Court for their time once again and leaves the determination of adequate relief to the Court.
 
As to the first, the Claimant shall amend their original complaint before the deadline for the Crown's Answer. Given that the Claimant has already said what their claims were, this should not be a problem for the Crown in the construction of their Answer due some 15 hours from now.

As to the second, it does not. If it did, the Court would have mentioned it when specifically outlining the Crown's deadline.

My apologies your honor, I perceived that comment as my claims that I wrote in objection to the defense was already taken into consideration as amended claims.

On top of IRL responsibilities coming up since it is finals week at my university, I ask the court's forgiveness in being late to the reply. I amend my original claims to the following:

Claims:
I.
The Immigration and Citizenship Act, by abruptly and arbitrarily denying me, the plaintiff, an opportunity to obtain citizenship, unlawfully deprives my rights guaranteed by the Constitution, including equality under the law, participation in governance, and due process protections.

II. I, the plaintiff, assert that the Immigration and Citizenship Act, by its structure and timing, unfairly deprives me of the opportunity to obtain citizenship, and places an undue burden on Tourists and Residents to obtain citizenship, thereby denying my fundamental constitutional rights.

III. The Constitution of Alexandria, while silent on explicit citizenship criteria, enshrines core principles including equality under the law, participation in governance, and due process protections. By imposing new, restrictive standards that have directly impacted me, a player who joined after the law was signed into effect, the Act violates these constitutional guarantees. Specifically, if I would have joined a mere week sooner, I would have qualified for citizenship under the fact that all previous residents were automatically grandfathered in. In this notion, I am being treated completely differently and unfairly under the law compared to a "citizen" who was grandfathered in, and does not have to go through any of the troubles the Immigration and Citizenship Act outline.

Just to be extra sure, because I know that the defense loves to use the General Court Rules and Procedures card, I have ensured that these claims are within the outlined provisions and give me cause to sue in this court.

With this in mind, I request that the court rule on these following reliefs:
I. That the Immigration and Citizenship Act is unconstitutional and violates the my rights under the Constitution, specifically the right to equality, political participation, and due process.

II. That the Court issue an injunction preventing the enforcement of the Act as applied to individuals who were residents of Alexandria before the Act’s enactment, until a more equitable and constitutionally sound process is established.

III. That I be granted citizenship or provided an alternative means to gain citizenship under conditions that do not violate constitutional rights.
 
My apologies your honor, I perceived that comment as my claims that I wrote in objection to the defense was already taken into consideration as amended claims.

On top of IRL responsibilities coming up since it is finals week at my university, I ask the court's forgiveness in being late to the reply. I amend my original claims to the following:

Claims:
I.
The Immigration and Citizenship Act, by abruptly and arbitrarily denying me, the plaintiff, an opportunity to obtain citizenship, unlawfully deprives my rights guaranteed by the Constitution, including equality under the law, participation in governance, and due process protections.

II. I, the plaintiff, assert that the Immigration and Citizenship Act, by its structure and timing, unfairly deprives me of the opportunity to obtain citizenship, and places an undue burden on Tourists and Residents to obtain citizenship, thereby denying my fundamental constitutional rights.

III. The Constitution of Alexandria, while silent on explicit citizenship criteria, enshrines core principles including equality under the law, participation in governance, and due process protections. By imposing new, restrictive standards that have directly impacted me, a player who joined after the law was signed into effect, the Act violates these constitutional guarantees. Specifically, if I would have joined a mere week sooner, I would have qualified for citizenship under the fact that all previous residents were automatically grandfathered in. In this notion, I am being treated completely differently and unfairly under the law compared to a "citizen" who was grandfathered in, and does not have to go through any of the troubles the Immigration and Citizenship Act outline.

Just to be extra sure, because I know that the defense loves to use the General Court Rules and Procedures card, I have ensured that these claims are within the outlined provisions and give me cause to sue in this court.

With this in mind, I request that the court rule on these following reliefs:
I. That the Immigration and Citizenship Act is unconstitutional and violates the my rights under the Constitution, specifically the right to equality, political participation, and due process.

II. That the Court issue an injunction preventing the enforcement of the Act as applied to individuals who were residents of Alexandria before the Act’s enactment, until a more equitable and constitutionally sound process is established.

III. That I be granted citizenship or provided an alternative means to gain citizenship under conditions that do not violate constitutional rights.
The Claimant is reminded, yet again, to pretty please amend their original complaint. There is a button at the bottom of your original post (attached) that will allow you to edit your original complaint in order to satisfy the Court.

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With Chancellor Smallfries's plea noted and pending, the Court now enters Discovery for a period of 72 hours.
 
The Claimant is reminded, yet again, to pretty please amend their original complaint. There is a button at the bottom of your original post (attached) that will allow you to edit your original complaint in order to satisfy the Court.

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Once again my deepest apologies your honor, I was not aware of that feature. It has been done.
 
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In the Chancery of the Kingdom of Alexandria
ENTREATY OF PROMPTING

Given the lack of requests for discovery, the Crown would like to propose that discovery be ended early for the sake of expediency. We pray that the Plaintiff and this Court are amenable to this idea.
 
Would the Claimant consent to an early ending of Discovery?
 
Would the Claimant consent to an early ending of Discovery?
No objections your honor,

I would just like to be mindful that the Crown has submitted a response to my pre-edited claims rather than the edited ones, as it me at fault here since I was preoccupied with IRL endeavors, I would like to give the Crown some time to respond again perhaps? If they feel the argument they made is still sufficient then I still have no objections.

Best Regards,

Moyfr
Plaintiff
 
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In the Chancery of the Kingdom of Alexandria
ENTREATIES OF STRIKING, COMPULSION, AND PROMPTING

The Crown humbly begs that this Court consider the following Entreaties:

In response to an earlier Entreaty of Compulsion, this Court granted the Crown's request to have the original Complaint updated, stipulating that any changes should be made "as ... elaborated in [the Claimant's] response."
Second, the Defense requests a Writ of Compulsion which we grant. The Claimant seems to have consented to the alteration of their original Complaint, and may do so as they have elaborated in their response.

However, the Claimant has more recently stated that they made "edited" changes, distinguishing them from their so-called "pre-edited claims." Beyond merely causing terminological confusion that wastes this Court's precious time by proxy, this legal editorialization directly violates the relevant Writ's terms, which were clear on calling for a simple transcription of the originally outlined claims from "their response."
I would just like to be mindful that the Crown has submitted a response to my pre-edited claims rather than the edited ones

It is also worth noting that the "edited" changes were provided by the Claimant on Wednesday at 8:38 PM, which is roughly 17 hours past the deadline of 3:35 AM. Considering that specific instructions were given to "amend their original complaint before the deadline for the Crown's answer," this shows wanton disregard for the time of this Court and that of the Crown's Office of Litigation.
As to the first, the Claimant shall amend their original complaint before the deadline for the Crown's Answer. Given that the Claimant has already said what their claims were, this should not be a problem for the Crown in the construction of their Answer due some 15 hours from now.

Moreover, the Claimant is also unable to plead ignorance of this requirement, as they acknowledged the relevant publication by this Court:
Screenshot 2025-05-03 at 7.20.45 AM.png

Additionally, it is the opinion of the Crown that the Claimant's request is not permitted under the General Court Rules & Procedures for two reasons. First, these proposed changes would fall under the Amendment Exception, which prohibits amendments that change information that was already submitted. Since it is the opinion of this Court that the "Claimant ... consented to the alteration of their original Complaint," one may take the aforementioned confirmation on behalf of the Claimant as constituting a submission. Second, these "edited" changes were also never formally declared and explained to the Court. The Claimant simply apologizes for missing the deadline, offers an explanation for their tardiness, and finally provides the edited Claims. However, they make no reference to an actual justification for the changes themselves in the relevant filing, invalidating them procedurally.
My apologies your honor, I perceived that comment as my claims that I wrote in objection to the defense was already taken into consideration as amended claims.

On top of IRL responsibilities coming up since it is finals week at my university, I ask the court's forgiveness in being late to the reply. I amend my original claims to the following:

Claims:
I.
The Immigration and Citizenship Act, by abruptly and arbitrarily denying me, the plaintiff, an opportunity to obtain citizenship, unlawfully deprives my rights guaranteed by the Constitution, including equality under the law, participation in governance, and due process protections.

II. I, the plaintiff, assert that the Immigration and Citizenship Act, by its structure and timing, unfairly deprives me of the opportunity to obtain citizenship, and places an undue burden on Tourists and Residents to obtain citizenship, thereby denying my fundamental constitutional rights.

III. The Constitution of Alexandria, while silent on explicit citizenship criteria, enshrines core principles including equality under the law, participation in governance, and due process protections. By imposing new, restrictive standards that have directly impacted me, a player who joined after the law was signed into effect, the Act violates these constitutional guarantees. Specifically, if I would have joined a mere week sooner, I would have qualified for citizenship under the fact that all previous residents were automatically grandfathered in. In this notion, I am being treated completely differently and unfairly under the law compared to a "citizen" who was grandfathered in, and does not have to go through any of the troubles the Immigration and Citizenship Act outline.

Just to be extra sure, because I know that the defense loves to use the General Court Rules and Procedures card, I have ensured that these claims are within the outlined provisions and give me cause to sue in this court.

With this in mind, I request that the court rule on these following reliefs:
I. That the Immigration and Citizenship Act is unconstitutional and violates the my rights under the Constitution, specifically the right to equality, political participation, and due process.

II. That the Court issue an injunction preventing the enforcement of the Act as applied to individuals who were residents of Alexandria before the Act’s enactment, until a more equitable and constitutionally sound process is established.

III. That I be granted citizenship or provided an alternative means to gain citizenship under conditions that do not violate constitutional rights.

With these arguments in mind, the Crown bows to this Court and implores that it may grant the following Writs:
  1. A Writ of Striking, removing the Claimant's request for a new Answer from consideration.​
  2. A Writ of Compulsion, forcing the Claimant to update the original Complaint to reflect the first changes to the Claims (what the Crown's Answer replies to and the mutual standard until the Claimant's ex post facto revisions).​
  3. A Writ of Prompting, requesting that this Court advance the case as to expeditiously resolve the questions at hand prior to the upcoming election.​
 
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RESPONSE IN OPPOSITION TO DEFENSE'S ENTREATIES

Your honor, if I may, I find the Defense's all of a sudden new urge to object and strike everything absurd. I would like to dispel the misinformation here as well as beg for the court's leniency in regards to my edits.

Response to Writ of Striking and Writ of Compulsion:

Your honor, the Defense makes the above claims hoping that I am not granted any leniency, even though the Defense has been late to replies on MULTIPLE occasions, as evidence here:
The Crown is held in contempt of court, and is fined £100. For every full hour that elapses from the time of this post, they will be fined an additional £50 for contempt.

So ordered.
I find it interesting that the Defense fails to make multiple 72 hour deadlines, but all of a sudden wants to punish me for a 14 hour deadline that I completed in 17 hours to which I stated that I had unforeseen circumstances IRL which hindered my ability to respond.

Moreover, and perhaps I am at a misunderstanding, but why is the defense wanting to strike edits that I have made to the original claim even though that is specifically what the court has asked me to do? Furthermore, the court mentioned in previous opinions that:
Next, we agree with the Crown that there is no properly stated claim. In a more strict, storied, and robust legal framework, the Claimant would fail here and we would dismiss the case at hand. However, Alexandria is a burgeoning and novel nation, and strict adherence to myopic guidelines would be both catastrophic and potentially fatal to justice. It is evident to the Chancery that while Claimant did not properly state their claims, they do indeed have claims. It is quite obvious, particularly through analysis of the Claimant's prayer for relief, that the Claimant's claim for relief comes from the law depriving them of Citizenship they would otherwise have were the law to be more lenient or to be passed mere days later. This deprivation of Citizenship, and thus some rights, is a clear claim for which they may file suit. Confusingly, the Crown implies Sua Sponte as a necessary remedy in the previous section, where it would rather be applicable and appropriate here.
It is clear that the simple facts and therefore claims of my case are fundamentally the same, I just followed the court's advice of being more clarified and specific with the claims that I have made previously. As mentioned by Chancellor Kaiserin, that "strict adherence to myopic guidelines would be both catastrophic and potentially fatal to justice. It is evident to the Chancery that while the Claimant did not properly state their claims, they do indeed have claims."

The defense thus wishes for a strict adherence to these guidelines which, mentioned previously, would be fatal to justice.

Reminder of the struggles of a new nation:

I believe, as Chancellor Kaiserin has been so graceful in opinions, the court said it best that:
A Message to All

Further, the Claimant is reminded that Claims for Relief are to be those crucial underlying points that show to the nation what damages, wrongs, or injustices befell them, or other necessary showings of current, future, or potential harm that could befall them. These claims should naturally flow into their Prayers for Relief. Here, the facts make it evident that the Claimant's Claim for Relief is that A.P.004 removed their rights through restricting Citizenship, as this directly flows into their Prayer where they ask for the Court to declare them as a Citizen.

Observers should note that while Alexandria is young and formats and legal jurisprudence are untested and unshaped, the Courts will be lenient and attempt to offer a hand to litigators as we have here in a fair, impartial, and neutral manner. However, all observers are expected to keenly study what we say and what we ask for, as over time, the maturation of our Kingdom will lead to a tightening of standards in Court. To that end, the Crown is reminded that an Answer to Complaint is not simply any motion or response at all, but rather a specific legal document that outlines their defences and responses to the initial Complaint of the Claimant. The deadline for that filing was around an hour ago, but in the same spirit of leniency and benevolence as extended to the Claimant, the Court will graciously stave off Contempt charges for twenty-four hours from this post. The Crown is not bound to any specific format, and is encouraged to confer with other legal minds in the community or look to other cases for guidance.

While I admit that, when originally filing my claim, I did not properly understand the concept of Claims and Prayer of Relief, it is clear that this court has noticed and, to an extent, agreed with the claims that I have made and offered the right and leniency to amend those claims. The claims I made do not fundamentally change any part of my argument, but rather clarifies the claims that I originally made.

To go further, when entering my edited claims into the record, there was not once any objection from the court OR the defense about them, even Chancellor Smallfries's only objection was that I did not revise them into my original post via the edit feature.
The Claimant is reminded, yet again, to pretty please amend their original complaint. There is a button at the bottom of your original post (attached) that will allow you to edit your original complaint in order to satisfy the Court.

As for the Writ of Prompting, I find it humorous that all of a sudden NOW the Defense wishes to speed up the process, and not when I had been waiting 72 hours+ for a response each time from them. Interesting, isn't it?

Respectfully Submitted,

Moyfr
Plaintiff
 
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CHANCERY OF ALEXANDRIA
RESPONSE TO WRIT
The Crown asks for the Chancery to order three writs: One of Striking, one of Compulsion, and one of Prompting.

First, the Crown asks for a Writ of Striking to "remov[e] the Claimant's request for a new Answer from consideration." The Claimant, in a response to my sister on the bench, informally suggested that the Crown be given time to re-write their Answer to comply with the updated Complaint the former submitted, notably to change their Claims for relief. The Claimant's response in this matter seems to betray a misunderstanding of the situation. The Crown, as the Court sees it, seeks only to remove the Claimant's request to give the Crown time to amend their Answer.

We grant this Writ. The Claimant should have made a request for a Writ of Continuance in this case to properly be heard. While we applaud the Claimant on their chivalry and good sportsmanship, it is not appropriate to throw in unrelated questions or statements when speaking in Court. When a Judicial Officer asks something of you, it is expected you respond appropriately or risk Contempt. However, even if the Claimant had properly made their voice heard such a request would likely have been denied, as the Crown should have seen what the future amendments to the Complaint would be.

The request is struck from the record.

Second, the Crown asks for a "Writ of Compulsion." We assume the Crown meant to file a Writ to Compel. The Crown asks for the Claimant's original Complaint to be updated to "reflect the first changes to the Claims." The Court's charitable interpretation of this request is that the Crown believes, or believed at the time of filing, that the Claimant had not updated their Claims for Relief from their Original Complaint to the claims the Claimant later expanded upon at the Court's request. Additionally, perhaps the Crown believed that the Claimant did do so, but did so incorrectly and in bad faith, providing an altered or incorrect update.

The former is obviously incorrect, as the Claimant had updated their Complaint by Wednesday. Though some twenty hours after the Crown's Answer, as previously noted by the bench the Crown had access to the accepted and updated claims some two days prior, and indeed referenced the updated Claims in their Answer. The only explanation the Court sees for this request from the Crown is the latter option, that Claimant incorrectly copied their updated claims as ordered.

Here, the Crown is correct. The Court sees that the Claimant did not perfectly copy and paste their updated Claims into their edit on their Complaint. However, this mistake is harmless. The Crown, interestingly, raises the red flag in regards to "pre-edited claims." It appears here this is also some miscommunication. The Crown states that the Claimant's updated Claims were provided late Wednesday. While this is technically correct, the same updated Claims were posted early Monday, and the writings of Monday and Wednesday are entirely identical.

As to the posts from Monday/Wednesday and the proper edit of the original Complaint itself, a
fter careful studying of the edit history of this case, the Court has determined that the only inconsistency is that the original updated claims had a header reading "Claims:," while the current header says "Claims for Relief:." This is a minor cosmetic change, that at this time the Court sees no reason to punish. We refuse this Writ.

The Court further extends its mercy to Claimant Moyfr as to their tardiness in properly editing their post. The Court understands that sometimes life events occur that may delay one's response. However, in the interest of mutual respect of time, the Court asks all future participants in the Courts to make a request for a Writ of Continuance for however much reasonable time is needed. The Court once again highly encourages all observers to learn from this case as we all trudge forwards and discover what works best in the pursuit of Justice.

Third, the Crown asks for a Writ of Prompting. As the time for Discovery has elapsed without an expressed desire to extend it, the Court grants this Writ. The Claimant has seventy-two hours from the time of posting to make their Opening Statement.


Finally, the Court wants to make one thing clear:

there was not once any objection from the court
it is clear that this court has noticed and, to an extent, agreed with the claims that I have made

These contentions should not be taken at face value. Claimant is reminded as to the first quote that Chancellor Smallfries' reminder to amend their original complaint was surely an objection from the Court. As to the second, this Court has made no determination as to the truth, validity, or jurisprudential viability of the Claimant's claims; only that we determined they were reasonable enough to stand and face scrutiny in Court. The Court asks the Claimant to please refrain from attempting to bend the Court's words or actions.

So ordered.
 

Opening Statement​

In the Chancery of the Kingdom of Alexandria​

Ms. Chief Justice, Chancellors, and may it please the court,

This case is about the Executive infringing on the rights of immigrants and tourists through misinterpretation of the Constitution. Plain and simple, the facts of this case boil down a simple question: Did the executive violate my constitutional rights, and thus the rights of all immigrants and tourists, by passing the Immigration and Citizenship Act of 2025? Throughout my argument, I aim to prove beyond a reasonable doubt why the answer to this question is yes.

I appear before this honorable Chancery not to question the legitimacy of the Crown, nor to deny the noble intention of crafting a functioning immigration framework—but to uphold the very spirit and letter of our Constitution, the bedrock of our civic and legal life.

The Immigration and Citizenship Act of April 18, 2025, while perhaps well-intended, oversteps the authority granted to Parliament and infringes on rights which our Constitution guarantees to all. Parliament is not without power, but its authority is not limitless. Nowhere in our governing document is Parliament granted the express or implied power to define citizenship, rather our rights under the Constitution are "subject only to such reasonable limits prescribed by law that are justified in a free and democratic society."

Let us be clear: the issue is not with the idea of citizenship itself, but with how this Act redefines the relationship between the individual and the State. In elevating "citizenship" to a gatekeeping mechanism for fundamental rights—such as standing for public office—the ICA conditions liberty upon bureaucratic approval. This is not merely legislative discretion. It is a structural rewriting of who is entitled to participate in the governance of their community. That is not Parliament’s role. It is the Constitution’s. Thus, I would argue that this goes against the "reasonable limits" that are "justified in a free and democratic society".

The requirements for citizenship—the so-called Residency and Citizenship Exams—may appear benign on paper. Yet, their implementation mirrors historic tools of disenfranchisement: literacy tests, poll taxes, and subjective evaluations of political "fitness." They empower officials, without clear standards, to judge who is "worthy" of voice and vote, of candidacy and legitimacy. This raises not just a procedural concern but a foundational one: can rights truly be rights, if they are conditional?

The executive has made claims that these tests would be simple and no way be comparable to a literacy test, and that one of the tests is only two questions long. My issue is not with the Residency test, but rather the Citizenship test, which is given no length requirement in law and thus subject to the government itself. The test could be 10, 15, 30, 50, even 100 questions long, with the only provision that two of the questions must be related to server rules. While I applaud the acting prime minister for his aims to create an informed and active population, I feel that restricting the barrier for citizenship behind a test rather than a playtime requirement places an undue burden on the player.

Moreover, how is this act fair to players like me? Players who joined just days after the passing of this legislation who are all of a sudden on paper barred from the basic privileges of society solely based on when we joined. To go further, the executive admits that there is no implemented way for this law to currently be enacted, while continuing to label me as a Tourist. How is one supposed to gain citizenship in the law's current state? There is no forum thread, no in-game test, no discord link that will guarantee citizenship.

Furthermore, while the Crown dismisses this Act as unimplemented and thus harmless, we cannot ignore the chilling effect already observed. Prospective participants in public life are being told—informally, and perhaps unlawfully—that their loyalty is suspect, that they may be denied full recognition for their views. The court has seen in this very thread a citizen of Alexandria labeling the idea of citizenship as "unholy" for tourists and immigrants, which had to be stricken from the record. The Constitution must not merely protect us from realized injury, but from systems that invite it.

This Court does not sit as a legislature, nor as a partisan referee. But it does serve as the guardian of our constitutional order. In asking this Court to strike down the ICA, I do not seek to obstruct governance—I seek to preserve its legitimacy. Rights once made contingent are rights that can be quietly revoked. The Constitution offers no room for such contingencies.

For these reasons, I respectfully ask the Chancery to declare the ICA unconstitutional and to affirm that in this Kingdom, rights are not privileges—and participation in democracy is not a reward to be earned, but a trust to be honored.

Thank you.
 
1746500942920.png
In the Chancery of the Kingdom of Alexandria
ENTREATIES OF DISMISSAL AND CONTINUANCE

The Crown humbly implores this Court to consider the following Entreaties:
Entreaty of Dismissal: Lack of Claim

Given that opening statements have already begun, the Crown begs that this Entreaty be considered under its merits with respect to the Claimant's Lack of Claim.

In the past day, an amendment to the Constitution was passed into law by a public referendum with supermajority support. One of the revisions made by this amendment states the following:

"Every citizen has the right to participate in and run for office."

This change clearly reserves political participation as a right to the citizens of the Kingdom of Alexandria, exclusively. In doing so, the new Constitution no longer contradicts Section (5) (2) of The Immigration and Citizenship Act:

Section (5) - Residents
(2) Residents have all rights and abilities of a citizen, but may not receive security clearances or run for public office.

Without this claim to a damage, which would have required further litigation under the more opaque framing of the original Constitution, the Claimant is no longer able to substantiate the possibility that their rights might have been deprived in an unspecified future where The Immigration and Citizenship Act was in effect.

Turning to Claim I,

I. The Immigration and Citizenship Act, by abruptly and arbitrarily denying me, the plaintiff, an opportunity to obtain citizenship, unlawfully deprives my rights guaranteed by the Constitution, including equality under the law, participation in governance, and due process protections.

it is clear that The Immigration and Citizenship Act no longer deprives the Claimant of their right to "[participate] in governance," as it now no longer exists under the new Constitution. Another change contained in the amendment now also guarantees that

"Every player is equal before and under the law."
This invalidates the Claimant's allegation that they could be deprived of equality under the law, as they are now guaranteed such a right. The same applies to the notion that the due process rights of non-citizens can be violated, as the new Constitution further guarantees the following:
"Every player has the right to life, liberty, and security of the person and the right not to be deprived thereof."

"Every player has the right to be secure against unreasonable search and seizure."


"Every player has the right to be informed of the reason for a subpoena, detention, charge, or arrest made against them."

"Every player has the right to a speedy and fair trial presided over by an impartial Judicial Officer and to be informed of the nature of the charges brought against them."

"No player can be made to produce self-incriminating evidence in a court of law, parliamentary hearing, subpoena, or impeachment trial."

"Every player has the right to appeal a charge made against them."

In fact, the new Constitution guarantees due process in equal measure to citizens and non-citizens under this revised framework. To that end, the only rights actually reserved to citizens today are related to political participation, meaning the non-citizen has now become substantially more enfranchised.

Turning to Claim II,

II. I, the plaintiff, assert that the Immigration and Citizenship Act, by its structure and timing, unfairly deprives me of the opportunity to obtain citizenship, and places an undue burden on Tourists and Residents to obtain citizenship, thereby denying my fundamental constitutional rights.

it is clear that the constitutional changes outlined above for Claim I also apply here. Since citizens are only reserved political participation rights, the only constitutional right that the Claimant is being deprived of here is one that the new Constitution explicitly reserves for citizens, negating the violation implicit in such a deprivation.

Finally turning to Claim III,

III. The Constitution of Alexandria, while silent on explicit citizenship criteria, enshrines core principles including equality under the law, participation in governance, and due process protections. By imposing new, restrictive standards that have directly impacted me, a player who joined after the law was signed into effect, the Act violates these constitutional guarantees. Specifically, if I would have joined a mere week sooner, I would have qualified for citizenship under the fact that all previous residents were automatically grandfathered in. In this notion, I am being treated completely differently and unfairly under the law compared to a "citizen" who was grandfathered in, and does not have to go through any of the troubles the Immigration and Citizenship Act outline.

it is clear, once again, that the aforementioned constitutional changes are also relevant here. There is no damage associated with this Claim under the new Constitution, as the Claimant is now guaranteed all cited rights except "participation in governance," which is now reserved for citizens.

For these reasons, the Crown meekly entreats this Court to grant it a Writ of Dismissal without prejudice. This would permit all parties involved to study and reflect on the implications of the new Constitution. Whenever the Claimant is ready to present a new argument against The Immigration and Citizenship Act, they would be welcome to do so with an updated Petition, allowing for smoother litigation under this Kingdom's new Constitution.

Entreaty of Continuance

To account for the time consumed by deliberation over these entreaties, the Crown also begs the Court to extend a Writ of Continuance for no more than 48 hours.
 
Your honor, if I may respond to these motions:

Opposition to the Entreaty for Dismissal:

The court specifically asked for an opening statement from the defense, and they come back with more attempts to dismiss this case. The Crown’s request for dismissal lacks substantive merit. The arguments presented do not address the core constitutional concerns raised in the Complaint, namely the alleged overreach of parliamentary authority and the infringement upon rights guaranteed by the Constitution of Alexandria. Dismissal at this juncture would preclude a thorough examination of these critical issues.

Not to mention, the crown all but admits that the law did previously infringe on my rights:
it is clear that The Immigration and Citizenship Act no longer deprives the Claimant of their right to "[participate] in governance," as it now no longer exists under the new Constitution.
but now there is no issue due to a change in the constitution. The fact that it did breach my rights previously is grounds for a claim, and cannot simply be dismissed because now the law is different after the fact, as the Crown mentioned here:
it is clear, once again, that the aforementioned constitutional changes are also relevant here. There is no damage associated with this Claim under the new Constitution, as the Claimant is now guaranteed all cited rights except "participation in governance," which is now reserved for citizens.

Furthermore, the action still deprives me of a route towards citizenship as there is no clear way to obtain it as of yet. No system has been put in place to apply for or obtain citizenship legally. I am not sure why the government is so obsessed with making laws it cannot enforce, but yet again it has been done.

Opposition to the Request for Continuance:

The Crown’s request for a continuance appears to be a strategic delay rather than a necessity grounded in unforeseen circumstances or new developments. The Court has already provided ample time for both parties to prepare their cases. Granting a continuance at this stage would undermine the efficient administration of justice and prolong the resolution of constitutional questions that bear significant implications for the Kingdom.

Can the Crown, instead of playing this cat and mouse chase, just admit that it was in the wrong?

Respectfully Submitted,

Moyfr
Plaintiff
 
View attachment 112
In the Chancery of the Kingdom of Alexandria
ENTREATIES OF DISMISSAL AND CONTINUANCE

The Crown humbly implores this Court to consider the following Entreaties:
Entreaty of Dismissal: Lack of Claim

Given that opening statements have already begun, the Crown begs that this Entreaty be considered under its merits with respect to the Claimant's Lack of Claim.

In the past day, an amendment to the Constitution was passed into law by a public referendum with supermajority support. One of the revisions made by this amendment states the following:

"Every citizen has the right to participate in and run for office."

This change clearly reserves political participation as a right to the citizens of the Kingdom of Alexandria, exclusively. In doing so, the new Constitution no longer contradicts Section (5) (2) of The Immigration and Citizenship Act:



Without this claim to a damage, which would have required further litigation under the more opaque framing of the original Constitution, the Claimant is no longer able to substantiate the possibility that their rights might have been deprived in an unspecified future where The Immigration and Citizenship Act was in effect.

Turning to Claim I,



it is clear that The Immigration and Citizenship Act no longer deprives the Claimant of their right to "[participate] in governance," as it now no longer exists under the new Constitution. Another change contained in the amendment now also guarantees that

"Every player is equal before and under the law."
This invalidates the Claimant's allegation that they could be deprived of equality under the law, as they are now guaranteed such a right. The same applies to the notion that the due process rights of non-citizens can be violated, as the new Constitution further guarantees the following:
"Every player has the right to life, liberty, and security of the person and the right not to be deprived thereof."

"Every player has the right to be secure against unreasonable search and seizure."


"Every player has the right to be informed of the reason for a subpoena, detention, charge, or arrest made against them."

"Every player has the right to a speedy and fair trial presided over by an impartial Judicial Officer and to be informed of the nature of the charges brought against them."

"No player can be made to produce self-incriminating evidence in a court of law, parliamentary hearing, subpoena, or impeachment trial."

"Every player has the right to appeal a charge made against them."

In fact, the new Constitution guarantees due process in equal measure to citizens and non-citizens under this revised framework. To that end, the only rights actually reserved to citizens today are related to political participation, meaning the non-citizen has now become substantially more enfranchised.

Turning to Claim II,



it is clear that the constitutional changes outlined above for Claim I also apply here. Since citizens are only reserved political participation rights, the only constitutional right that the Claimant is being deprived of here is one that the new Constitution explicitly reserves for citizens, negating the violation implicit in such a deprivation.

Finally turning to Claim III,



it is clear, once again, that the aforementioned constitutional changes are also relevant here. There is no damage associated with this Claim under the new Constitution, as the Claimant is now guaranteed all cited rights except "participation in governance," which is now reserved for citizens.

For these reasons, the Crown meekly entreats this Court to grant it a Writ of Dismissal without prejudice. This would permit all parties involved to study and reflect on the implications of the new Constitution. Whenever the Claimant is ready to present a new argument against The Immigration and Citizenship Act, they would be welcome to do so with an updated Petition, allowing for smoother litigation under this Kingdom's new Constitution.

Entreaty of Continuance

To account for the time consumed by deliberation over these entreaties, the Crown also begs the Court to extend a Writ of Continuance for no more than 48 hours.
YRKrp9o.png

IN THE CHANCERY OF
THE KINGDOM OF ALEXANDRIA

RESPONSE TO WRIT

The Chancery refuses the Entreaty of Continuance.

While we appreciate what seems to be the Crown's concern for the Court to have enough time to deliberate the Entreaty of Dismissal, we do not believe it necessary. Even if the Court takes longer than the elapsed deadline for the Crown to respond with their opening statement, we will come to a conclusion eventually. The Court does not see fit to allow for the extension of a deadlines for either party due to a potential matter on the table which the Court alone may deliberate on, nor do we see it as proper for a party to perhaps attempt to stave off a filing if they believe they can simply get it dismissed. Parties should always assume they will be required to file the next piece of their work in Court.

If the Crown needs extra time for their filing, they should say so. As it stands, we believe this Entreaty was made solely for our benefit, so we shall gratefully refuse.
 
The Crown is charged with Contempt and is fined £100. They shall be charged again and fined a further £100 for every hour they are late in the submission of their opening statement.
 
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In the Chancery of Alexandria
Entreaty of Dismissal: Lack of Claim


On behalf of the Crown, I apologize for the lack of response and submit that I have taken over this case. I also recognize that the Chancery just ruled on an Entreaty of Dismissal, but with recent amendments to legislation The Crown respectfully submits another with the following reasoning:


The Amended Immigration and Citizenship Act:
Amendments made and signed into law by His Royal Highness has included specific information about when and how residency and citizenship exams may take place.

Furthermore, the ICA now grants citizenship to all players who come to the Kingdom of Alexandria until the exams are implemented, this now means the Claimant is a citizen.

On the Reliefs Being Requested:

With this in mind, I request that the court rule on these following reliefs:
I. That the Immigration and Citizenship Act is unconstitutional and violates the my rights under the Constitution, specifically the right to equality, political participation, and due process.
The ICA has been amended and the Claimant has no rights in violation because they are a citizen.

II. That the Court issue an injunction preventing the enforcement of the Act as applied to individuals who were residents of Alexandria before the Act’s enactment, until a more equitable and constitutionally sound process is established.
The ICA is already in not actively being enforced, as per the amended Act signed into law.

III. That I be granted citizenship or provided an alternative means to gain citizenship under conditions that do not violate constitutional rights.
The Claimant is a citizen as outlined in the ICA.

The Crown would like the record to reflect that just because amendments to legislation caused all of these reliefs to be granted does not mean in anyway that the rights of the Claimant were ever violated.

As all of the Claimant's terms for relief have now been fulfilled, we ask that this case be dismissed.
 
AD_4nXfsvhQ-1leEDgxMFFuGtkvXDqOXsxa2HUzwiui8ufIOuM5zpDV3rvtk5ONDVEjbUKrhjTRN9mts-DVGjBpX4dP6gkJSjQ41kVzVdnAD-vCjSuyQD5mJLqjEVRF5HuOsF2C3koAk

In the Chancery of Alexandria
Opening Statement​


On the First Claim for Relief:
The Immigration and Citizenship Act does not abruptly and arbitrarily deny the Claimant the opportunity to obtain citizen. Rather the opposite is true. Our Constitution separates the rights and privileges of citizens and non-citizens, and gives Parliament the power to create "law that are justified in a free and democratic society" (P.5, S.22). Without the ICA, there is no mechanism to become a citizen. Furthermore, the ICA explicitly outlines the process so it is not abrupt or arbitrary in the least. Additionally, the Claimant no longer has a valid claim in this matter, as the ICA has been amended to read "Any player who joins/joined before the relevant exams are set up shall be granted automatic citizenship" (S.10, P.1).

On the Second Claim for Relief:
The ICA does not deprive the claimant of citizenship due to its timing and structure. The Kingdom must have laws. It is not the fault of the Crown that the Claimant chose to step into the Kingdom when they did. Let us look at this another way for example, say the following were to occur: An act outlawing murder is signed into law on May 1. On May 2, a player is welcomed to Alexandria and murders the first player they see. By the logic of the Claimant, because of the timing of the law "deprived" the player to murder as they see fit had they joined a day earlier, then they should be allowed to now. The logic that the Claimant is trying to claim makes no sense and should be ruled against.

On the Third Claim for Relief:
Again, the Constitution gives Parliament the power to create laws that are justified in a free and democratic society. To do this, the ICA was created to not only ensure there is a process for citizenship, but that it is obtainable. Again, timing of when a law is passed and when a player joins should have no merit.

In Response to the Claimant's Statement:
The ICA does not overstep the reasonable limits test as outlined by the Constitution. The Constitution is clear the Parliament creates laws for the nation, and the Constitution clearly separates citizens from non-citizens and their rights. This law is to give clarity to how to achieve those rights. Without the ICA, there would be no way to obtain citizenship.

The Claimant makes the statement that the Citizenship test could be an undue burden on the player due to the not having a specified amount of questions. This has been amended and you can see that the exam will have an unlimited amount of time to complete 10 questions.

The Claimant tries to paint a picture of "Bad things are happening in Alexandria because of this law." But has provided no evidence to support such a claim. They hint at threatening language and that non-citizens have their loyalty tested, but has provided not a scrap of evidence showing this.

In Conclusion
The ICA is a constitutional law. The Claimant has not provided any actual proof that there has been damages due to its implementation or lack thereof.
 
[]
1746500942920.png

In the Chancery of the Kingdom of Alexandria
ENTREATIES OF DISMISSAL AND CONTINUANCE

The Crown humbly implores this Court to consider the following Entreaties:
[/]Entreaty of Dismissal: Lack of Claim

Given that opening statements have already begun, the Crown begs that this Entreaty be considered under its merits with respect to the Claimant's Lack of Claim.

In the past day, an amendment to the Constitution was passed into law by a public referendum with supermajority support. One of the revisions made by this amendment states the following:

[]"Every citizen has the right to participate in and run for office."[/]
This change clearly reserves political participation as a right to the citizens of the Kingdom of Alexandria, exclusively. In doing so, the new Constitution no longer contradicts Section (5) (2) of The Immigration and Citizenship Act:


Without this claim to a damage, which would have required further litigation under the more opaque framing of the original Constitution, the Claimant is no longer able to substantiate the possibility that their rights might have been deprived in an unspecified future where The Immigration and Citizenship Act was in effect.

Turning to Claim I,


it is clear that The Immigration and Citizenship Act no longer deprives the Claimant of their right to "[participate] in governance," as it now no longer exists under the new Constitution. Another change contained in the amendment now also guarantees that

[] "Every player is equal before and under the law."
[/]This invalidates the Claimant's allegation that they could be deprived of equality under the law, as they are now guaranteed such a right. The same applies to the notion that the due process rights of non-citizens can be violated, as the new Constitution further guarantees the following:
[]"Every player has the right to life, liberty, and security of the person and the right not to be deprived thereof."

"Every player has the right to be secure against unreasonable search and seizure."


"Every player has the right to be informed of the reason for a subpoena, detention, charge, or arrest made against them."

"Every player has the right to a speedy and fair trial presided over by an impartial Judicial Officer and to be informed of the nature of the charges brought against them."

"No player can be made to produce self-incriminating evidence in a court of law, parliamentary hearing, subpoena, or impeachment trial."

"Every player has the right to appeal a charge made against them."
[/]
In fact, the new Constitution guarantees due process in equal measure to citizens and non-citizens under this revised framework. To that end, the only rights actually reserved to citizens today are related to political participation, meaning the non-citizen has now become substantially more enfranchised.

Turning to Claim II,


it is clear that the constitutional changes outlined above for Claim I also apply here. Since citizens are only reserved political participation rights, the only constitutional right that the Claimant is being deprived of here is one that the new Constitution explicitly reserves for citizens, negating the violation implicit in such a deprivation.

Finally turning to Claim III,


it is clear, once again, that the aforementioned constitutional changes are also relevant here. There is no damage associated with this Claim under the new Constitution, as the Claimant is now guaranteed all cited rights except "participation in governance," which is now reserved for citizens.

For these reasons, the Crown meekly entreats this Court to grant it a Writ of Dismissal without prejudice. This would permit all parties involved to study and reflect on the implications of the new Constitution. Whenever the Claimant is ready to present a new argument against The Immigration and Citizenship Act, they would be welcome to do so with an updated Petition, allowing for smoother litigation under this Kingdom's new Constitution.
Given that the Crown has submitted another Entreaty for Dismissal, we will be refusing this previously undecided entreaty while we begin deliberating the Crown's novel arguments.

As there are no witnesses or testimonies called upon by either party, we will proceed to closing statements. The Claimant has seventy-two hours to produce their closing statement, unless we grant a Writ of Dismissal first.

The Crown is given a total of three contempt charges, and is fined £300 as outlined previously.
 
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