Lawsuit: In Session Vanguard & Co v Naezaratheus [2025] FCR 32

Writ of Summons

@naez is required to appear before the Federal Court in the case of Vanguard & Co v Naezaratheus.

Failure to appear within 72 hours of this summons will result in a default judgement based on the known facts of the case.

Both parties should make themselves aware of the Court Rules and Procedures, including the option of an in-game trial should both parties request one.

Brief

IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
AMICUS BRIEF

Ladies, gentlemen, enbies, and others. Since former Justice Nacho's ruling in StressedGV v. SalsaStar [2022] FCR 52, a precedent has been set that deported players do not have the same rights as citizens of Redmont. A precedent affirmed in Krix v. The Commonwealth of Redmont [2023] FCR 11 by former Justice dygyee that "[Lord_Donuticus] cannot represent someone in court as [Krix] has been deported."

A precedent affirmed again in gsse v. Commonwealth of Redmont [2024] FCR 101 by former Justice Unseatedduke1, who affirmed that "DC staff has been clear that deported players have no rights in Redmont. Therefore, deported players do not have the right to challenge this in court..."

A precedent yet again affirmed in UnityMaster v. lcn [2025] SCR 2, Chief Justice Aladeen22, writing the court's verdict, specifically mentioned the following: "Finally, at the time of filling this case, the plaintiff was indeed deported. Deported players have no rights in our nation and have no rights to dispute this in court."

When this case was filed, and at the time of posting this Amicus Brief, the defendant Naezaratheus is deported. The defendant currently has no rights in this nation, and as several precedents have established, deported players do not have the right to dispute legal challenges in court, nor do they have the right to appoint someone on their behalf.

Going against these previous decisions could set a very dangerous precedent. I humbly request that the court consider these previous verdicts and how best to resolve the case.

Thank you for your time.

Motion

MOTION TO DISMISS

The Defendant respectfully moves this Court to dismiss under Rule 5.5

I. FAILURE TO FOLLOW CONTRACTUAL REMEDIES
Exhibit P-020 (Vanguard Market Access TOS) explicitly provides the procedure for addressing alleged exploitative trades:

"Customers are strictly prohibited from engaging in trades designed to exploit system mechanics, including placing trades outside of real-life market hours to gain an unfair advantage. If any trade is determined to be exploitative, Vanguard Market Access reserves the right to reverse the trade and undo all associated gains or losses. Customers engaging in exploitative trading practices may have their accounts restricted or suspended at Vanguard’s sole discretion."

My client did not commit any of the prohibited acts listed in the Terms of Service (TOS). The TOS explicitly uses the term 'including'—rather than 'including but not limited to'—which means the specified prohibitions are exhaustive, not illustrative.

As such, my client:

1. Did not exploit any system mechanics, and

2. Did not breach the contract in any manner.

Consequently, the Plaintiff’s Claims for Relief lack any legal basis and must be dismissed under Rule 5.5.

II. In addition, the evidence provided by the Plaintiff is nonsensical and proves nothing. It appears this documentation may have been intended for submission to the Department of Commerce (DOC) months ago regarding a tax exemption, rather than for this proceeding.


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

DATED: This 6th day of April, 2025.

Answer to Complaint

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

Vanguard & Co
Plaintiff

v.

Naezaratheus
Defendant

I. ANSWER TO COMPLAINT

1. The Defendant AFFIRMS paragraph 1 of the complaint regarding the
Plaintiff and Defendant.
2. The Defendant DENIES the general allegations of fraud and theft as
described in the introductory paragraphs of the complaint. The
Defendant asserts that all trading activities were conducted within
the parameters of the Vanguard Market Access (VMA) system, and that
there was no intention to defraud Vanguard & Co. The Defendant
admits to taking advantage of in-game mechanics and strategies to
maximize profits.
3. Regarding Fact 1, the Defendant AFFIRMS that he created a bank
account and deposited $5,000.
4. Regarding Fact 2, the Defendant AFFIRMS that he transferred $5,000 to
Vanguard Market Access (VMA).
5. Regarding Fact 3, the Defendant AFFIRMS that he transferred $10 from
VMA to his bank account.
6. Regarding Fact 4, the Defendant AFFIRMS that he transferred $10 from
his bank account to Voyager.
7. Regarding Fact 5, the Defendant DENIES that the transfer of $21,000
from VMA to his bank account was fraudulent. The Defendant asserts
that this was a result of legitimate trading activity, however
unorthodox.
8. Regarding Fact 6, the Defendant AFFIRMS that he sent $21,000 to
absinf and then at 6:07AM received $1,000 and immediately
transferred that $1,000 to MB
9. Regarding Fact 7, the Defendant DENIES that the transfer of $335,000
from VMA to his bank account was fraudulent. The Defendant asserts
that this was a result of legitimate trading activity, however
unorthodox.
10. Regarding Fact 8, the Defendant AFFIRMS that he transferred $150,000
to Volt and $150,000 to Voyager.
11. Regarding Fact 9, the Defendant AFFIRMS that he transferred $5,000 to
VMA and $30,000 to Volt
12. Regarding Fact 10, the Defendant DENIES that the transfer of
$3.261 million from VMA to his bank account was fraudulent. The
Defendant asserts that this was a result of legitimate trading
activity, however unorthodox.
13. Regarding Fact 11, the Defendant AFFIRMS that he transferred $1
million to Voyager and $2 million to MegaMinerM’s Legacy Account.
14. Regarding Fact 12, the Defendant AFFIRMS that he transferred $260,000
to twilight2660
15. Regarding Fact 13, the Defendant AFFIRMS that he received $1 million
from MegaMinerM’s Legacy Account and transferred it to Voyager.
16. Regarding Fact 14, the Defendant DENIES that the transfer of
$572,800 from VMA to his bank account was fraudulent. The Defendant
asserts that this was a result of legitimate trading activity,
however unorthodox.
17. Regarding Fact 15, the Defendant AFFIRMS that he transferred $500,000
to Gribble and $73,800 to MegaMinerM’s Legacy Account.
18. Regarding Fact 16, the Defendant DENIES that the transfer of $500,000
from VMA to his bank account was fraudulent. The Defendant asserts
that this was a result of legitimate trading activity, however
unorthodox.
19. Regarding Fact 17, the Defendant AFFIRMS that he transferred $500k to
Gribble
20. Regarding Fact 18, the Defendant DENIES that the transfer of $500,000
from VMA to his bank account was fraudulent. The Defendant asserts
that this was a result of legitimate trading activity, however
unorthodox.
21. Regarding Fact 19, the Defendant AFFIRMS that he transferred $500k to
Voyager
22. Regarding Fact 20, the Defendant DENIES that the transfer of
$1.9 million from VMA to his bank account was fraudulent. The
Defendant asserts that this was a result of legitimate trading
activity, however unorthodox.
23. Regarding Fact 21, the Defendant AFFIRMS that he sent $1.9 million to
Voyager.
24. Regarding Fact 22, the Defendant DENIES that the transfer of
$200,000 from VMA to his bank account was fraudulent. The Defendant
asserts that this was a result of legitimate trading activity,
however unorthodox.
25. Regarding Fact 23, the Defendant DENIES that the transfer of
$1.3 million from VMA to his bank account was fraudulent. The
Defendant asserts that this was a result of legitimate trading
activity, however unorthodox, and AFFIRMS that $500,000 was sent
back to VMA
26. Regarding Fact 24, the Defendant AFFIRMS that he transferred $110,001
from VMA to his bank account, and $50,000 back to VMA
27. Regarding Fact 25, the Defendant AFFIRMS that he transferred $22,999
from VMA to his bank account
28. Regarding Fact 26, the Defendant AFFIRMS that he transferred $9,000 to
VMA and then $14,812 from VMA to his bank account
29. Regarding Fact 27, the Defendant AFFIRMS that he transferred
$1.088812 million to Voyager
30. Regarding Fact 28, the Defendant AFFIRMS that he transferred $14,002
from VMA to his bank account, and $7,000 back to VMA
31. Regarding Fact 29, the Defendant DENIES that the transfer of
$517,000 from VMA to his bank account was fraudulent. The Defendant
asserts that this was a result of legitimate trading activity,
however unorthodox.
32. Regarding Fact 30, the Defendant AFFIRMS that he transferred $250,000
to KingBOB99878’s Personal Account
33. Regarding Fact 31, the Defendant DENIES that the transfer of $250,000
from VMA to his bank account was fraudulent. The Defendant asserts
that this was a result of legitimate trading activity, however
unorthodox.
34. Regarding Fact 32, the Defendant DENIES that the transfer of $27,900
from VMA to his bank account was fraudulent. The Defendant asserts
that this was a result of legitimate trading activity, however
unorthodox.
35. Regarding Fact 33, the Defendant DENIES that the transfer of
$49,995 from VMA to his bank account was fraudulent. The Defendant
asserts that this was a result of legitimate trading activity,
however unorthodox.
36. Regarding Fact 34, the Defendant DENIES that the transfer of
$48,995 from VMA to his bank account was fraudulent. The Defendant
asserts that this was a result of legitimate trading activity,
however unorthodox.
37. Regarding Fact 35, the Defendant AFFIRMS that he has $650,894 in his
bank account.
38. Regarding Fact 36, the Defendant acknowledges the trading logs but
DENIES that these trades were inherently fraudulent. The Defendant
maintains that he was exploiting in-game market mechanics, but that
this does not constitute fraud.
39. Regarding Fact 37, the Defendant acknowledges Vanguard Market
Access’ Terms of Service and does not dispute the clarity of "Fair
Trading and Exploit Prevention" as defined, however asserts that the
trades conducted were not explicitly in violation of these terms.

II. DEFENSES

1. Legitimate Trading Activity: The Defendant maintains that all
trading activity was conducted through the VMA platform, utilizing
in-game mechanics available to all users. The Defendant denies any
intentional misrepresentation or falsification of records. The
scale of the trades does not inherently make them fraudulent.
2. Clear Definition of Exploit: The Defendant acknowledges that
VMA defines "exploits" clearly within its General Trading Rules as
"trades designed to exploit system mechanics, including placing
trades outside of real-life market hours to gain an unfair
advantage." However, the Defendant asserts that the specific trades
in question did not violate this definition. The Defendant's
actions did not involve trading outside of market hours. The
Defendant's understanding of the system mechanics, combined with
his trading strategies, allowed him to capitalize on in-game
opportunities, which, while profitable, do not inherently
constitute an illegal exploit.
3. No Intent to Defraud: The Defendant asserts that he had no
intention to defraud Vanguard & Co. His actions were driven by a
desire to maximize profits through trading within the VMA platform.

III. RESPONSE TO CLAIMS FOR RELIEF

1. Breach of Contract: The Defendant denies breaching the contract,
arguing that his actions, while taking advantage of in-game
mechanics, were not explicitly prohibited by the Terms of Service,
as the trades were not conducted outside of market hours and the
system mechanics in question were not explicitly defined as
prohibited.
2. Fraud: The Defendant vehemently denies the claim of fraud. The
Defendant asserts that all trades were conducted within the VMA
system, and there was no intention to deceive or misrepresent any
information.

IV. PRAYER FOR RELIEF

The Defendant respectfully requests that the Court:

1. Dismiss the Plaintiff’s claims for compensatory damages. The
Defendant argues that the Plaintiff has not provided sufficient
evidence to prove that the Defendant’s actions constitute fraud or
caused direct financial harm.
2. Deny the Plaintiff’s request for punitive damages. The Defendant
asserts that his actions were not malicious, reckless, or in
outrageous disregard for the law.
3. Deny the Plaintiff’s request for legal fees.

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

DATED: April 7th, 2025

Motion

MOTION TO STRIKE

My apologies, your honor. I responded to a response, which is not permitted.

Opening Statement

IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
OPENING STATEMENT

Introduction
The Defendant, Naezaratheus, is a fraudster who intentionally and maliciously tricked the Plaintiff, Vanguard & Co, into paying him more than $9.3 Million through a series of fraudulent stock trades, and throughout this filing, it will become clear not only through a Balance of Probabilities (as required for civil suits), but even Beyond a Reasonable Doubt that the Defendant’s actions were intentional, illegal Fraud.

On The Agreed Upon Facts
1. The Defendant has, while disagreeing on whether they were fraudulent, affirmed that every transaction listed in Facts 1-34 as well as the stock trades in Fact 36 did in-fact occur.

2. The Defendant has affirmed their bank account’s balance to be $650,894.

3. The Defendant has affirmed the contents of Vanguard Market Access’ Terms of Service, although disagrees on the meaning.

On The Disagreed Upon Facts
1. Although the Defendant affirms that the stock trades listed in Fact 36 did occur, the Defendant also “DENIES that these trades were inherently fraudulent. The Defendant maintains that he was exploiting … market mechanics, but that this does not constitute fraud.”

On Fraud
Fraud is defined by the Commercial Standards Act (Act of Congress - Commercial Standards Act) as “An intentional or reckless misrepresentation or omission of an important fact, especially a material one, to a victim who justifiably relies on that misrepresentation; and the victim party or entity suffered actual, quantifiable injury or damages as a result of the misrepresentation or omission.”

Now, we recall the Defendant affirmed the Stock Trades of Fact 36, including the eighteen sets of trades where he sold more shares than he owned. Through these trades, the Defendant intentionally or recklessly misrepresented the amount of shares of stocks he owned, and sold them to the Plaintiff. As a result, the Plaintiff suffered an actual, quantifiable injury of $9,303,691.

This is not a stretch, your honor – this case is exactly the definition of Fraud, and there is simply no alternative way to view this.

Conclusion
My client, Vanguard & Co, is the victim of a Grand Fraud, costing the Plaintiff more than $9.3 Million through the deplorable actions of Naezaratheus, who misrepresented his stocks and caused immense damage to the Plaintiff.

It is clear that the Defendant committed Fraud on a massive scale, and there is no two ways about it.

Opening Statement

IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
OPENING STATEMENT

Your Honor,

The Plaintiff's case against the Defendant rests upon two critical claims: breach of contract and fraud. However, when we examine their own documentation and the applicable laws of the Commonwealth, it becomes evident that neither claim can be substantiated.

Regarding the breach of contract claim, there are several fatal flaws:

1. Vanguard's own Terms establishes an unambiguous method for contract formation. On page two, it explicitly states:

"By signing the agreement, you're agreeing to the Agreements and acknowledging receipt of the disclosures contained in the Booklet..."

It further reinforces this requirement by stating:

"For any like-titled accounts you open in the future, you'll need to sign an Additional Account Acknowledgement where you will confirm that the most current version of the Booklet applies..."

The Defendant never signed any such agreement. No signature was ever solicited, provided, or received. Yet Vanguard now attempts to enforce terms that, according to their own Terms, required signature for acceptance.

2. Vanguard creates a direct contradiction in their acceptance methods. While their Terms requires signature, their login page states:

"By logging in, you agree to our Terms of Service."

This contradiction fails to meet the "clear and unequivocal" communication standard required by Section 4(a) of the Contracts Act.

Even if the Defendant accepts the login page's method of acceptance, their Terms of Service were not reasonably accessible at that point. Users were told they were agreeing to terms they could not readily access or review from the website itself. This undermines the "positive and unambiguous" acceptance requirement of Section 4(b) of the Contracts Act.

3. Turning to the specific trading rules that Vanguard claims were violated, their "Fair Trading and Exploit Prevention" clause states:

"Customers are strictly prohibited from engaging in trades designed to exploit system mechanics, including placing trades outside of real-life market hours to gain an unfair advantage."

While the Defendant acknowledges taking advantage of market mechanics through unorthodox trading strategies, these activities occurred within normal market hours. The prohibition specifically identifies trading "outside of real-life market hours" as the example of prohibited exploitation. The Defendant's activities, though utilizing system mechanics advantageously, do not fall within this specified prohibition.

4. The same section outlines Vanguard's remedy for allegedly exploitative trades: "If any trade is determined to be exploitative, Vanguard Market Access reserves the right to reverse the trade and undo all associated gains or losses." Despite having this contractual remedy available, Vanguard evidently did not identify these trades as exploitative or exercise their right to reverse them at the time they occurred. Instead, they waited until after the funds had been largely transferred before taking any action.

5. Regarding the fraud claim, the Commercial Standards Act Section 6 explicitly defines fraud as: "An intentional or reckless misrepresentation or omission of an important fact, especially a material one, to a victim who justifiably relies on that misrepresentation; and the victim party or entity suffered actual, quantifiable injury or damages as a result of the misrepresentation or omission."

This definition requires four distinct elements, and the plaintiff must prove all four to establish fraud:

1. An intentional or reckless misrepresentation - The Defendant made no false statements whatsoever. When executing trades through Vanguard's platform, he simply used the interface buttons and functions provided to all users, employing unorthodox yet legitimate trading strategies. The system itself processed and approved each transaction. If Vanguard's system permitted these trading activities, this represents a system design issue that the Defendant strategically utilized, not a misrepresentation by the Defendant.
   
   
2. Of an important fact - Even if we were to accept, for argument's sake, that there was some implicit representation about share ownership in each trade, Vanguard's own database contained the definitive record of the Defendant's holdings. Vanguard had perfect information about exactly how many shares the Defendant owned at any given moment. They cannot claim to have been misled about facts that existed in their own records.
   
   
3. Justifiable reliance by the victim - This element is perhaps most clearly absent. Vanguard cannot claim to have justifiably relied on any implied representation when they maintained the authoritative database of all user holdings. As the system operator, they had both the means and responsibility to verify share ownership before executing trades. It is a fundamental principle of fraud law that a party cannot justifiably rely on representations about facts they themselves are in a superior position to verify.
   
   
4. Actual damages resulting from that misrepresentation - While Vanguard may have suffered financial consequences, these resulted from their own system design failures rather than from any misrepresentation by the Defendant. Their system should have had safeguards to prevent transactions that exceeded a user's holdings - a standard feature in properly designed trading platforms.

Motion

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

Justification for Motion

The Defendant respectfully moves this Court to strike all instances of the word "fraud" (or variations thereof) as used by the Plaintiff, Dartanboy, in the case of Vanguard & Co v Naezaratheus. The justification for this motion is as follows:

1. Presumption of Innocence: The Defendant, Naezaratheus, is presumed innocent of any criminal wrongdoing until proven guilty in a court of law.

2. Prejudicial Language: The repeated use of the term "fraud" by the Plaintiff is prejudicial and could unduly influence the Court's judgment before all evidence has been presented and a determination of facts has been made.

3. Lack of Criminal Conviction: There is no indication that the Defendant has been criminally convicted of fraud. Therefore, the use of this term is an unsubstantiated allegation rather than an established fact.

4. Scandalous Language: The use of the term "fraud," without a criminal conviction, could be considered scandalous and impertinent, as it unfairly tarnishes the Defendant's reputation.