Lawsuit: Adjourned Ref. Rights Collective v Crown, Case 11 (Ch. 2025)

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IN THE HONOURABLE CHANCERY OF THE KINGDOM OF ALEXANDRIA
CIVIL ACTION
NOTICE OF SUBSTITUTION OF COUNSEL

Your honours,

I have been assigned to take over for Kai in this case.

Respectfully submitted,

Joseph Ibney0
Solicitor General
Kingdom of Alexandria
 
IN THE HONOURABLE CHANCERY OF THE KINGDOM OF ALEXANDRIA
CIVIL ACTION
Case No. 11

DISCOVERY SUBMISSION: EVIDENCE P-009

The honourable Chancery has not yet closed Discovery and neither party has yet to file their opening statements. Because of this, the Plaintiff, PhillinDeBlanc, would like to submit the following to this high and honourable Chancery as evidence:

We submit this evidence to the Chancery as we believe it is essential in illustrating Parliament's efforts to undermine the Stimulus referendum by expediting the legislative process and demanding royal assent for both A.P. 01-020 and A.P. 01-021 despite protest from his Majesty, King Wackjap.

Respectfully submitted on behalf of the Plaintiffs,
PhillinDeBlanc
Date: August 28, 2025
 

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PhillinDeBlanc said:
IN THE HONOURABLE CHANCERY OF THE KINGDOM OF ALEXANDRIA
CIVIL ACTION
Case No. 11

DISCOVERY SUBMISSION: EVIDENCE P-009

The honourable Chancery has not yet closed Discovery and neither party has yet to file their opening statements. Because of this, the Plaintiff, PhillinDeBlanc, would like to submit the following to this high and honourable Chancery as evidence:

We submit this evidence to the Chancery as we believe it is essential in illustrating Parliament's efforts to undermine the Stimulus referendum by expediting the legislative process and demanding royal assent for both A.P. 01-020 and A.P. 01-021 despite protest from his Majesty, King Wackjap.

Respectfully submitted on behalf of the Plaintiffs,
PhillinDeBlanc
Date: August 28, 2025
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The Respondent objects to this entry into discovery, as Discovery ended July 16th. See Electronic Court Filing ("ECF") No. 15.

No just cause mandates the entry of this exhibit. As stated previously as well. This case is a defense on the law, not a defense on the facts. Nothing factual is in dispute, and plaintiff simply seeks to encumber the Court.
 
IN THE HONOURABLE CHANCERY OF THE KINGDOM OF ALEXANDRIA
CIVIL ACTION
ENTREATY OF WRIT OF SUMMARY JUDGMENT
Your honours,

Respondent seeks summary judgment on the facts in this case. Under the General Court Rules and Procedures, a writ of summary judgment may be entertained only when there is no genuine dispute of material fact.

In this case, the plaintiff and the respondent agree that the MOTF did not distribute the funds to all of the plaintiffs in this class action lawsuit. The only matter in dispute is whether they were required to.

Under the law established at the time, the Stimulus act required disbursement of the checks "upon approval of the Ministry of Trade and Finance." A.P. 19 | Stimulus Act, Sec. 3(1). This act passed May 6, 2025 when King Emeritus WackJap assented. See A.P. 19 | Stimulus Act. The Interim government had until May 25, 2025 to implement the act through the Ministry of Trade and Finance, but failed to take any action to do so. See Government Announcements for May 25, 2025.

When the new government formed, the new Minister of Trade and Finance took no steps to implement the act, as the act was poorly written and did not require him to do so. The policy itself additionally went against the policy objectives of the ruling party at the time, the Sovereign Kingdom Party, and intentional lack of implementation was a key policy decision of the group.

Parliament later repealed the stimulus act in an effort to rescind the former decision of the previous parliament. After its repeal, the plaintiffs have no claim to the money promised within the act. The plaintiff points to a referendum which sought to force the Minister of Trade and finance to disburse the funds, but this referendum passed after Parliament removed the power of referendums almost entirely.

COUNT I: VIOLATION OF CONSTITUTIONAL RIGHT TO VOTE
Plaintiff's claim that their right to vote was restricted by the "the Crown" (importantly not parliament) repealing the enabling legislation that granted them their claim in the first place. The Crown repealed no such legislation. Parliament did. Parliament and the Crown are two separate entities under the Constitution, and while plaintiff seeks recourse against the Crown for their perceived lack of ability to vote, the Crown undertook no such action as described within their cause of action. Parliament, through its authority to pass and revert legislation, removed the binding authority of the Civil Engagement Act because it was being used to require parliament to pass legislation contrary to its mandate.

Referendums for political questions are entirely creatures of statute. The requirement that Parliament comply with a credendum is a requirement Parliament established for themselves, and a requirement that Parliament may take away from itself at any time. The Plaintiff may not bring forth a claim against the Crown, then allege that the Crown took the actions of Parliament. Their attempt to navigate away from this constitutional issue is at the heart of what is wrong with this case. As such, as a matter of law, there is no genuine dispute of material fact for this count, and the Court should give summary judgment in favor of the Crown.

COUNT II: RETROSPECTIVE NULLIFICATION OF A LEGAL PROCESS
The Plaintiff sued the Crown, not Parliament. They can not now bring a charge against parliament when they stated the Crown. Even assuming they are one in the same, which they are not, "retrospective legislative abuse" is not a valid claim. Parliament may pass and repeal whatever legislation they wish. The enforcement of that legislation may be unconstitutional by the executive, which grants this honourable Court the ability to render its enforcement void, but nothing may be unconstitutional based on the repeal of a law. Plaintiff has no standing to sue if no action was committed against them.

The referendums are creates of statute, and may be repealed at any time. Nothing special attaches once a referendum begins, and there is no reasonable expectation that parliament will retain its promise to enforce them against itself once a referendum begins. The referendum still had legal authority once it passed, and required parliament to issue a statement regarding its passage. Parliament complied with this requirement, and plaintiff brought suit.

Plaintiff cites to no section of the constitution, our laws, or the common law for this claim. It is made entirely up out of whole cloth, and this court should give summary judgment in favor of the Crown as a result.

COUNT III: FAILURE TO COMPLY WITH LAWFULLY ENACTED LEGISLATION AND REFERENDUM RESULTS
The Plaintiff asserts there was a statutory obligation to provide a £1200 stimulus check to those who requested them. While this is true, it was "on approval of the Minister of Trade and Finance." This requirement destroys any claim the plaintiff may have. Under the plaintiffs theory, when exactly was the Minister suppose to approve the stimulus checks? Immediately once the law passed, thus disbursing no funds? When a certain number of individuals requested them not specified by the act? Any required disbursement point under the act is entirely arbitrary, and thus the determination falls upon the Minister of Trade and Finance. If the decision is entirely the decision of the Minister of Trade and Finance, it is entirely their decision to make at any time they see fit, so long as it does not violate the law.

If there was some certain execution time, why was it not specified? Why did the interim parliament, who had 20 days to enforce the legislation, not enforce it? Did it become binding as soon as it became the new parliaments duty? What point did it become a requirement for the Minister to approve, and why did it require his approval in the first place? Under the plaintiffs logic, he had to approve them the moment the legislation passed, meaning the disbursement of the one-time stimulus checks would be disbursed to no one, as no one signed up to qualify. Any other arbitrary time frame has no basis, and the only reasonable conclusion requires the Minister of Trade and Finance to approve them at his discretion. If he never approves them, there is nothing to disburse.

Furthermore, because the referendum passed after referendums became non-binding, it constitutes a non-binding resolution. Referendums are creates of statute, and Parliaments decision to make them non-binding can not be questioned. As such, this court should give summary judgment in favor of the Crown.
 
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IN THE CHANCERY OF
THE KINGDOM OF ALEXANDRIA
NOTICE OF RECUSAL AND
EX PARTE
​
This notice to the parties of this suit serves as proper and full notice of Chancellor Pepecuu's recusal in discussion and ruling in this case, as she is a Plaintiff involved.

Further, this notice serves as a voluntary disclosure that prior to Chancellor Pepecuu's recusal, she spoke in some amount about this case. No discussion about the contents of the case themselves were made, and Chancellor Pepecuu in no way gave any sort of opinion or discussion that may alter the proceedings of this case. Attached is the entirety of Chancellor Pepecuu's involvement in this case. The "post" in question discusses merely procedural questions, and no ruling or discussion on the merits of this case were prepared.

No ruling as to any motions are made at this time. This notice is made due to ethical obligations and in the interest of preventing improper ex-parte communication and as a voluntary disclosure of potentially improper communication, as well as assuring the public that the impartiality of the Chancery has not been compromised. This error only occurred due to a minor human fault, and I humbly apologize for any appearance of impropriety.
​
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IN THE CHANCERY COURT OF THE KINGDOM OF ALEXANDRIA
WRIT OF PROMPTING

Your Honours,

The Crown requests guidance as to the deposition of this case. No action has been taken in what appears to be over a month and a half.

Respectfully submitted,

Joseph Ibney0
Solicitor General
Ministry of Justice
 
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IN THE CHANCERY OF
THE KINGDOM OF ALEXANDRIA
NOTICE OF PROCEDURAL
POSTURE
​

This case was filed prior to the promulgation of Ch. R. & P. § 1, which allows the Chancery to delegate one member of the bench to serve as presiding officer during the trial's existence. Because of this, the rule was not implemented in this case, and standard bench procedure has reigned—two members of the Chancery are required to move any matter.

There are several matters outstanding at this time, and with one seat on the Chancery vacant and another held by an interested (and now recused) party in this case, there exists only one member of the Chancery who may impartially rule on this case. These rulings include the outstanding matters before us, as well as moving the case itself along. As Ch. R. & P. § 1 has not been formally introduced to this case (and cannot with only one Chancellor able to rule), I alone cannot proceed this case.

Absent a new, uninterested Chancellor being appointed to the court, or being granted statutory authority by Parliament to directly take procedural action in situations such as this, this case, regrettably, will not move. I hope the parties take some comfort in the knowledge that I have not forgotten about nor ignored the proceedings here, and I share their frustration.
 
Smallfries said:
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IN THE CHANCERY OF
THE KINGDOM OF ALEXANDRIA
NOTICE OF PROCEDURAL
POSTURE
​

This case was filed prior to the promulgation of Ch. R. & P. § 1, which allows the Chancery to delegate one member of the bench to serve as presiding officer during the trial's existence. Because of this, the rule was not implemented in this case, and standard bench procedure has reigned—two members of the Chancery are required to move any matter.

There are several matters outstanding at this time, and with one seat on the Chancery vacant and another held by an interested (and now recused) party in this case, there exists only one member of the Chancery who may impartially rule on this case. These rulings include the outstanding matters before us, as well as moving the case itself along. As Ch. R. & P. § 1 has not been formally introduced to this case (and cannot with only one Chancellor able to rule), I alone cannot proceed this case.

Absent a new, uninterested Chancellor being appointed to the court, or being granted statutory authority by Parliament to directly take procedural action in situations such as this, this case, regrettably, will not move. I hope the parties take some comfort in the knowledge that I have not forgotten about nor ignored the proceedings here, and I share their frustration.
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Your honour,

If possible, would the ability to temporarily appoint a magistrate for the determination of a case in such special circumstances be sufficient to resolve this issue? If so, I will take steps to update Parliament on this matter, and have legislation passed to the best of my ability to give your honour that ability.
 
Ibney0 said:
Your honour,

If possible, would the ability to temporarily appoint a magistrate for the determination of a case in such special circumstances be sufficient to resolve this issue? If so, I will take steps to update Parliament on this matter, and have legislation passed to the best of my ability to give your honour that ability.
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The possibility of having the entirety of the Magistrate Court fill in as one collective vote that could break a tie (or in this case, a failure to meet quorum) was discussed at the formation of the courts, but was abandoned due to concerns of constitutionality. Out of all the resolutions elucidated above, this proposed course of action (in either flavor discussed) would be the least desirable and most worrying in terms of permissibility.

If Parliament saw this issue as one that needed immediate attention, the most obvious solutions would be to appoint a disinterested third Chancellor, codify the ability for the High Chancellor to promulgate new Rules and Procedures (or apply them to ongoing cases) in exceptional cases, or amend/introduce a statute to include the outstanding rule at issue to apply to all cases post-hoc.
 
Your honour,

After speaking with the government, it appears they don't intend to appoint a new chancellor any time soon. As such, the Crown believes the recourse in this case is to dismiss this claim, to which the Crown would waive any statute of limit concerns, and allow the plaintiff to refile in the future when there are sufficient justices to hear the case.

Your honour may wish to leave this case sitting until such time there is a new chancellor, however, under the Statute of Limitations Act, Sec. 8, if no progress takes place on a case within 7 days, the case shall be dismissed. We need to keep the case moving, or it must be dismissed.

The Government stated they would be alright with giving the Chancery the power to raise a magistrate temporarily to the Chancery to hear cases similar to this going forward, but your honour indicated they were not comfortable with that, so we are at an impasse. We don't wish to take away the plaintiff's right to bring forth this lawsuit, and we believe the above remedy is the only reasonable method of handling this case.

Respectfully Submitted,

Joseph Ibney0
Solicitor General
Ministry of Justice
 
Your honour,

I have resigned and left the server. Please instruct the government to find a new counsel for this case.

Best of luck,

Joseph Ibney0
 
IN THE CHANCERY OF THE KINGDOM OF ALEXANDRIA
ENTREATY FOR CONTINUANCE

Your Honor, given that there is an election on at the moment, it is uncertain who will be leading the Ministry of Justice. Accordingly, the Crown requests continuance in this case until a new government is formed and the incoming Minister of Justice can assign someone to this case.
 
Capt11543 said:
IN THE CHANCERY OF THE KINGDOM OF ALEXANDRIA
ENTREATY FOR CONTINUANCE

Your Honor, given that there is an election on at the moment, it is uncertain who will be leading the Ministry of Justice. Accordingly, the Crown requests continuance in this case until a new government is formed and the incoming Minister of Justice can assign someone to this case.
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This case has no presiding officer, and none can be assigned as only one seat is filled in the Chancery. No answer can be given to this request. If Parliament appoints a second uninterested Chancellor, or gives me authority to either rule on my own or promulgate new rules as I see fit, this case may begin moving again.
 
Discovery is now over.

Given the extended time that has elapsed since any movement from this proceeding, in a 2-0 vote the Chancery has decided to deny all outstanding motions. Parties are free to re-file any motion without penalty or scorn.

Discovery submission P-009 is invalid, as it was filed some time after discover was meant to close. While true that discover was not formally concluded, it is nonetheless also true that a specific time was given. The lack of official ruling does not change any procedural stature.

At this time, the Plaintiff (@PhillinDeBlanc) shall have seventy-two hours to file their opening statement.
 
Smallfries said:
Discovery is now over.

Given the extended time that has elapsed since any movement from this proceeding, in a 2-0 vote the Chancery has decided to deny all outstanding motions. Parties are free to re-file any motion without penalty or scorn.

Discovery submission P-009 is invalid, as it was filed some time after discover was meant to close. While true that discover was not formally concluded, it is nonetheless also true that a specific time was given. The lack of official ruling does not change any procedural stature.

At this time, the Plaintiff (@PhillinDeBlanc) shall have seventy-two hours to file their opening statement.
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Your Honour,

Could I have a 48 hour extension. I have some IRL stuff that requires my attention and am unable to submit an opening statement by the deadline.

Respectfully submitted,
PhillinDeBlanc
 
IN THE HONOURABLE CHANCERY
OF THE KINGDOM OF ALEXANDRIA
CIVIL ACTION

Case No. 11

Referendum Rights Collective ​

v.​

The Crown​

OPENING STATEMENT – ON BEHALF OF THE PLAINTIFFS​


Your Honours,

This case is about the sanctity of the ballot box and the rule of law. It concerns the Crown’s failure to honour both a duly enacted Act of Parliament, a binding referendum, and its obstruction of a statutory duty owed to the citizenry.

The Plaintiffs, a class of citizens lawfully assembled as the Referendum Rights Collective, filled out a survey expecting to receive stimulus checks upon approval by the Ministry of Trade and Finance. After waiting to receive stimulus checks for a month, the Plaintiffs signed a petition which in turn triggered a binding referendum governed by A.P. 021 (Civic Engagement Act) (P-002).

The Plaintiffs participated in the lawful referendum under laws in full force, expecting that the rules governing their votes would remain stable, and that the referendum would have a binding effect. That expectation was not only reasonable—it was guaranteed by the Civic Engagement Act and the Constitution of Alexandria, §22(2), which affirms every citizen’s right to vote in elections and referenda, subject to law.

However, over the 72 hours the referendum was being held, the Crown moved as quickly as they could, expediting acts through their chamber to repeal the enabling legislation on which the referendum was based.

Less than an hour before the referendum ended, Parliament repealed both the Stimulus Act and the very statute that made the referendum binding. By doing so, the Crown rendered the Plaintiffs’ votes legally meaningless, retroactively nullified a statutory process in motion, and struck at the heart of democratic legitimacy in Alexandria. The Crown refused to act on its outcome—even though the referendum passed by majority vote.

The facts of this case are not in serious dispute. A.P. 019 (Stimulus Act) was passed and received royal assent on May 6, 2025, offering £1200 to eligible citizens. A.P. 021 (Civic Engagement Act), passed the same day, made referenda legally binding on Parliament and the Crown. The referendum triggered under that law met all legal thresholds and concluded with a clear majority in favour of enforcing the stimulus.
Yet the Crown declined to act—claiming the law had changed. The Crown’s act of repealing and nullifying the Stimulus Act and Civic Engagement Act while the binding referendum that would have required them to pay the stimulus to eligible citizens represents an egregious violation of the citizen’s right to vote and an ex post facto move that is completely illegitimate. If the Stimulus Act and Civic Engagement Act were repealed before the referendum went up to a vote as was before the citizenry, we would not be here before the court today. However, the Crown so heinously violated the constitutional and civil rights of all Alexandrians by effectively declaring, “givsies backsies” and “no fair I don’t like that” in the middle of the vote like toddlers, here we stand before the impartial parental adjudicators that is the court to ask that the court to do what is right and just.

Your Honours, this case brought before you today asks the following:

1. Did the Stimulus Act allow the Crown to not pay, approve, deny or otherwise not interact with stimulus requests?

2. May the Crown impede referenda it does not like by repealing enabling legislation?

3. May the Crown change laws regarding voting and referenda after ballots have already been cast?

The Plaintiffs believe that the answer to these three questions is no and respectfully ask this Honourable Chancery to declare the referendum binding, order the Crown to comply with the results, and to recognize that the right to vote—once exercised—cannot be taken back by legislative sleight of hand without due processes.


Respectfully submitted,
PhillinDeBlanc
On behalf of the Referendum Rights Collective
Dated: November 5, 2025 CET
 
IN THE HONOURABLE CHANCERY
OF THE KINGDOM OF ALEXANDRIA
CIVIL ACTION

Case No. 11

Referendum Rights Collective

v.

The Crown​
Writ of Prompting

Alex. Const. Part V. §22.7 states that: "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." this case now reaches into its 5th month, with little to no progress thus leaving open the possibility of further infringing upon the Plaintiff's constitutional rights.

As such, the Plaintiff would like to ask the following questions:

1.1 Has the Crown appointed a new opposing counsel to represent them in this case?
1.2 If the Crown has appointed a new counsel, whom?

2.1 Is there a timeline for how this case will proceed?
2.2 If there is a timeline, what is it?

3.1 The Plaintiff understands that High Chancellor Smallfries resigned from the Chancery a few weeks ago, and would like to inquire about the status of the presiding officers for this case.


Respectfully submitted,
PhillinDeBlanc
On behalf of the Referendum Rights Collective
Dated: November 21, 2025
 
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