Lawsuit: In Session MegaMinerM v. Blazora Corporation [2025] FCR 27

Writ of Summons

@Nexalin is required to appear before the Federal Court in the case of MegaMinerM v. Blazora Corporation [2025] FCR 27

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.

Answer to Complaint

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

MegaMinerM
Plaintiff

v.

Blazora Corporation
Defendant

I. ANSWER TO COMPLAINT
1. AFFIRM that “on 23 September 2024, Nexalin founded Easy Corporation and thereafter listed a bond with a face value of $1,000,000 on The Exchange, a stock exchange hosting several business ventures and entities based in Redmont. This bond was listed under the CUSIP number “EZC24-6M”.”
2. AFFIRM that “on 27 September 2024, MegaMinerM purchased 2,604 shares of this bond through a market buy order. The bonds have a face value of $100 each, totalling $260,400. The bonds held a monthly interest rate of 7.0% and were said to have a maturity date of 1 January 2025. The official issuing date was 1 October 2024.”
3. AFFIRM that “on 5 November 2024, fellow bondholder lcn privately dm’d Nexalin to ask for interest to be paid. Nexalin responded simply with, “Yeah.”” NEITHER AFFIRM NOR DENY that Interest was not paid.
4. AS FOR “after all of October and November passed without payment, on 15 December 2024 fellow bondholder lcn publicly asked in The Exchange general chat: “@nexalin interest plz #ezc24-6m,” to which Nexalin quickly replied “Will go out today.” Interest was not paid.” AFFIRM that the message was sent, however NEITHER AFFIRM NOR DENY whether interest was paid in October, November, and/or after the message.
5. AFFIRM that "later that day, an announcement from Exchange CEO Stoppers said that Easy Corporation “Has been taking aggressive steps to prepare for launch,” and they “Plan[ned] to launch by summer 2025.”” however NEITHER AFFIRM NOR DENY that this was done at the behest of Nexalin and/or Blazora Corporation.
6. AFFIRM that “on 16 December 2024, an announcement from Exchange CEO Stoppers reached out to officially begin a bondholder’s vote as to the matter of extending the bond’s interest payments by six months.” however NEITHER AFFIRM NOR DENY that this was done at the behest of Nexalin and/or Blazora Corporation.
7. AFFIRM that “on 22 December 2024, Nexalin filed a Corporation Registration for Blazora Corporation. The documents of this incorporation do not list Easy Corporation in any capacity, nor is there any office announcement on the Easy Corporation (now Blazora Corporation) discord server or the Easy Corporation bond (now Blazora Corporation bond).”
8. AFFIRM that “on 30 December 2024, an announcement from Exchange CEO Stoppers said that the previous vote to extend the duration of the bond had passed, and it would be extended for six months. At this time, Stoppers also announced that “[The] bond and the issuing company (Easy Corporation) have both been named to Blazora.”” however NEITHER AFFIRM NOR DENY that this was done at the behest of Nexalin and/or Blazora Corporation. NEITHER CONFIRM NOR DENY “Nowhere in the publicly shown terms for the bond was this shown to be a potential option. Approximately ten minutes later, the first (of nine) interest payments were paid out.”
9. AFFIRM that “on 31 December 2024, a conference room within Dragon Law Firm was created to ask the Defendant’s agent, Nexalin, to resolve the breach of contract in lcn v. Blazora Corporation, [2025] FCR 18 up to that point.” however NOTE that while this was the perceived reason from the Plaintiff’s perspective, we NEITHER AFFIRM NOR DENY that there was Breach of Contract.
10. AFFIRM that “on 2 January 2025, an attorney for [lcn] made an official demand for relief, stating lcn’s willingness to resolve the matter amicably if: (1) Immediate payment of all overdue interest was met, (2) A formal explanation of the delays and assurance of compliance going forward was provided, and (3) Reimbursement of lcn’s legal fees. Nexalin did not respond. Later that day, Exchange CEO Stoppers announced that Blazora Corporation had officially paid its second of nine interest payments.” however NOTE that while this was the perceived necessary damages from the Plaintiff’s perspective, we NEITHER AFFIRM NOR DENY that there was any overdue interest.
11. AFFIRM that “on 6 January 2025, the attorney representing [lcn] pinged Nexalin. Nexalin responded with “We are all caught up on bond payments.” The attorney responded “No, you are still missing the bond payment for the first of January.” Nexalin did not respond” however NEITHER AFFIRM NOR DENY that Nexalin “instead left the discord.”
12. AFFIRM that “later that day, Exchange CEO Stoppers posted that the reason for the failure to pay the third owed month was that the bond’s terms gave them the right to disallow interest to be charged on October, with the first month where interest would be accrued being November. The above terms were provided in the form of a screenshot to a restricted channel, and dated to 23 September 2024, when the bonds were first listed. These newly revealed terms also said that interest will be paid at the end of each month, and that the bond term was to last from 1 October 2024 to 31 March 2025, a period of six months. This is contradictory to the listing information, which said the bond would mature on 1 January 2025. The Exchange claimed they would “[Take] full responsibility for any inconvenience caused by our failure to adequately communicate these terms.””
13. AFFIRM that “On 13 February 2025, fellow bondholder lcn filed suit against Blazora Corporation alleging $274,983.89 in damages.”
14. DENY that “On 25 February 2025, Judge Dartanboy of the Federal Court of Redmont issued summary judgment in favor of the Plaintiff, agreeing that there were no material facts at issue.” NOTING that the associated Motion and Decision was improperly labeled, and what actually occurred was a Default Judgement (when a party does not appear), as opposed to a Summary Judgement (when both parties agree on the facts). AFFIRM that “All damages were upheld, except one portion of the compensatory damages and part of the legal fees. The Judge in that case awarded $233,752.48 in damages, not diminishing any punitive damages.” Also NOTE that the Judge spoke publicly on the matter later, explaining that some of the punitive damages were because “the Defense [didn’t] show up” [see Exhibit D-001].
15. AFFIRM that “Two days later, on 27 February 2025, Exchange CEO Stoppers announced Defendant had “called” the bond, and had promised that “all interest due to-date along with the bond’s principal” would be paid.”
16. AFFIRM that “On March 8 2025, Plaintiff asked in the Public Exchange General Chat "when will bondholders be paid out?" Later that day, he pinged Defendant's agent. The Agent never responded.” however NOTE that this money is sitting in The Exchange, and it is no fault of the Defendant that the balance has not been distributed by The Exchange.
17. NEITHER AFFIRM NOR DENY that “As of 17 March 2025, no additional interest past the second payment two and a half months prior nor the principal has been paid.”
18. DENY that “The bond was promised to mature on 1 July 2025. This is four extra months of interest, bringing the total interest payments had the contract been fulfilled to $163,505.” as the Defendant still reserved the right to call the bond [see Exhibit P-006].

II. DEFENSES
1. The Plaintiff agreed to a modified contract by voting “Aye” in P-007. This modified contract extended the bond term, but did not remove the callability of the bond by the Defendant. As such, when the bond was called in February, only the principal amount and the interest for November, December, and January (3 months) were owed. 2 months were already paid out per the Plaintiff’s Facts and Evidence. Thus, only 1 interest payment + the principal should be returned to the Plaintiff.

2. The principal amount is still in The Exchange, and it is not the Defendant’s fault it has not been returned to the Plaintiff. Thus, the Defendant is not liable for these “damages.”

3. The Plaintiff is suing the Defendant for damages when The Exchange miscommunicated the bond terms – not the Defendant. This is admitted by both the Plaintiff and the Exchange in Fact 12 and Evidence P-008.

Evidence

Spoiler: ”Exhibit D-001”

Motion

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

The Plaintiff submits that the ruling above be granted a final reconsideration, on the basis that:

1. The subject matter at-hand has its roots and is formed from the same case and controversy as a similar previous case, lcn v. Blazora Corporation,

2. That case was presided over and ruled on by the Learned and Honorable Judge Dartanboy,

3. The Plaintiff finds deep internal turmoil in the fact that the Judge that ruled on the case arising out of the same case or controversy is now opposing counsel for this case,

4. The opposing counsel has, in Answer to Complaint § 14, stated that "the associated Motion and Decision was improperly labeled, and what actually occurred was a Default Judgement (when a party does not appear), as opposed to a Summary Judgement (when both parties agree on the facts),"

5. The associated motion by the Plaintiff in that case was for a Summary Judgment, and the Learned and Honorable Judge later said the court would be in recess until Summary Judgment was delivered,

6. A Summary Judgment must be motioned for by a party as a request for the judge to make a decision without trial if there are no disputed facts, seeking a final ruling,

7. A Default Judgment is when a Defendant fails to submit a complaint, and "failure to include the necessary information is grounds for the [plaintiff] to request the presiding judge to grant default judgment." [Emphasis added],

8. The Plaintiff in that case did not request Default Judgment,

9. The Plaintiff in that case did specifically request Summary Judgment, as the Defendant's failure to contest any claims meant as a matter of law the Plaintiff was entitled to Summary Judgment, and

10. Opposing counsel has used their previous station as a Judge to improperly re-interpret their own previous rulings to argue and attempt to benefit in this case, therefore,

Opposing counsel, subconsciously or otherwise, has improperly used their previous rulings as a Judge to re-interpret or ex post facto (ruling after the fact) say their previous decision as a Judge meant something it very clearly does not.

The Plaintiff is extremely worried that, even if this was a mistake done in good faith, it could be done again on a more serious matter, in another case, or by a future bad actor that would seek to allow the spectre of their previous experience on the bench to manipulate the law as they so chose after leaving the bench.

This is further compounded by opposing counsel's point late in § 14 where they state: "Also NOTE that the Judge spoke publicly on the matter later, explaining that some of the punitive damages were because “the Defense [didn’t] show up” [see Exhibit D-001]."

Even if opposing counsel's assertion is correct, in good faith, and entirely truthful, it cannot be denied that allowing this sort of behavior to occur is irreconcilable with the duties of a Judicial Officer.

If I could serve on the bench, make rulings, and then later in private practice "interpret" my own rulings in any way I pleased, it would be quite difficult to say I was wrong, as only I, the judge in that case, truly knew what I was thinking upon the making of the ruling, and saying otherwise is a daunting—not to mention unfalsifiable—proposition.

The Plaintiff requests that the learned and Honorable Judge in this case take a stand against this potential flaw in our justice system. In two separate instances, within the same point, opposing counsel either changed/misrepresented a previous ruling, or improperly interpreted his own ruling to his client's benefit. This could surely be in good faith and an honest mistake—but it makes no sense to allow this kind of behavior.

The Plaintiff humbly requests opposing counsel in this case be dismissed, any benefits conferred upon opposing counsel by the Defense be remitted, and the Defense being granted a reasonable amount of time to search for new counsel.

Brief

IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
AMICUS BRIEF

Your honor,
The Exchange has recently paid out bondholders of the BZ24-6m bond by Blazora on March 27th at 9:06 pm PST. We wish to clarify the timeline on the payment for the courts information regarding this decision.

March 20th, 2025: Nexalin asked the Exchange to pay out $1,070,000 to cover both the face value of the bond and 1 month worth of interest.

March 27th, 2025: Avaneesh2008 actioned out the distribution and paid out the bond + 1 month of interest to bondholders as well as delisting the said bond.

Specifically, Megaminerm has been paid out $278,628.00 in the following breakdown:
$260,400 - Maturity of the Bond
$18,228 - 1 month of interest

We request the court and parties to take this information into consideration when further deliberating this case. We thank the court for their time.

Motion

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

The Defense petitions the court to dismiss this case, and in support thereof, respectfully alleges:

Under Rule 5.5 - Lack of Claim
As the Plaintiff has now been paid, the lawsuit has no claim.

Opening Statement

IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
OPENING STATEMENT

May it please the court,

My name is Smallfries and I represent the Plaintiff, MegaMinerM. The case before the court today is one of immense importance for the finance sector in Redmont, and should not be taken lightly. Intense and honest scrutiny must be applied, and it is with this in mind that the Plaintiff humbly presents itself to the court.

1. MANY OF THE FACTS ARE NOT IN CONTENTION, AND THOSE THAT THE DEFENDANT SEEMS TO BE UNSURE ABOUT ARE EASILY PROVEN

There are three broad areas to touch on regarding the defendant’s answer: The facts in agreement, the facts the defendant seems to be unsure of, and the facts in contention.

2. THE DEFENDANT CONCEDES TO MOST OF THE PLAINTIFF’S FACTUAL FOUNDATION

The defense agrees that the MegaMinerM purchased over a quarter million dollars in shares. They affirm that Nexalin was contacted several times, and that payment was not completed until long after those attempts at contact. They affirm that again Nexalin was contacted through an attempted conference, but he did not attempt to directly address the plaintiff’s concerns in that case.

They affirm that the hidden terms of the agreement were revealed months after the bond was released and the contract for the bonds were already made. They affirm that a vote was called to allegedly extend the bond date for six months, with no other stated terms. They affirm that a suit was filed. They affirm that the plaintiff in that case won on almost all of the merits, and that the defendant in that case didn’t even show up.

They affirm that two days after Nexalin’s loss in that case, Nexalin unceremoniously called the bond, a day before the end of the month of February. They affirm that on March 8, 2025, the Plaintiff in this case publicly attempted to get Nexalin’s attention to pay the now more than a week-delayed payments.

There are, however, issues at hand. The defense seems unsure whether at several points, the plaintiff in lcn v. Blazora Corporation received their duly owed interest payments. They are unsure if statements made on behalf of Nexalin/Blazora corporation were made at their request. They are unsure if the vote called to increase the length of the payments to mid-summer were done at Blazora’s request.

3. THE DEFENDANT SEEMS UNSURE OF SOME FACTS, BUT THIS IS EASILY OVERCOME BY A BRIEF GLANCE AT THE EVIDENCE

They are unsure if Blazora (then Easy Corporation) requested the Exchange announce their name change, unsure if there was a breach of contract in that case, unsure if there was any overdue interest at the time of filing of that case, unsure if Nexalin, when confronted with his breaching conduct, instead negligently left the discord, and unsure if no additional interest has been paid past the second payment made.

It is the duty of an attorney to be well-informed of the case on hand, and so I feel it is my sacred obligation to help opposing counsel to be sure of things here.

1. When lcn asked for payment on November 5th, interest was not paid. It would not be paid until almost two months later. This is clear as the record states, and because lcn did not receive their payments at this time, neither did the Plaintiff here.

2. Similar to above, interest was not paid in October or November. The record clearly reflects this, and it seems quite creative to suggest otherwise.

3. It is ridiculous to claim that the Exchange made an announcement on the behalf of Easy Corporation/Blazora Corporation without the latter’s consent.

a. It is equally if not more ridiculous to suggest they did so several times without Blazora seeming to care.

b. It is even more ridiculous to think that the Exchange made several of these announcements over just as many months, of such vital concern to Easy/Blazora Corporation, seemingly without Easy/Blazora Corporation’s approval.

c. It is extraordinarily ridiculous to say all of the above with the ruling that opposing counsel made in lcn v. Blazora Corporation, where the learned judge there ruled the defendant in that case was civilly liable for misrepresentation, fraud, false advertising, and misleading advertising, all connected to the statements above.

i. Whether opposing counsel is misinterpreting his own rulings from a previous case for his benefit or simply making up arguments in a desperate attempt to shield the Defendant’s indefensible acts is unclear.

4. The rest of the moments where the defense seems unsure about statements made apply as above. We assure the court that the statements were made, they were surely made on the defendant’s behalf and with their consent, and that they have already been ruled on. As a matter of law, stare decisis must inform the court’s decision on that respect, due to this case originating from the same misconduct in that case.

5. There was a breach of contract. To say otherwise is a clear and wilful misrepresentation of that facts, not to mention previous rulings by opposing counsel in lcn v. Blazora Corporation. The learned judge in that case—now opposing counsel—said that there was “no doubt that an offering of any bond constitutes a contract when accepted . . . certainly the failure [to pay off the bond and its interest] is a Breach of Contract.” Stare decisis applies due to this case originating from the same misconduct in that case.

6. There was surely overdue interest. As noted in both points above, lcn v. Blazora Corporation held that at the time of the bond’s the attempted negotiation between lcn and Nexalin two interest payments were made, and the bondholders only received two. As a matter of law, at least one interest payment was due. At the time of filing of this case, that interest payment had not been made to bondholders as a class.
7. It is abundantly clear in the record that at the time of filing, only two interest payments had been made. The defendant paid for the first two months—October and November—and owed interest for the entirety of December (which opposing counsel agreed with and made Nexalin pay lcn in that case, and which MegaMinerM had not benefited from) and January.

a. The defendant further waited until the day before February to cancel the bond in a clear attempt to pull the wool over the eyes of the public, defendant’s investors, and this honored court. But the court will not be deceived by this duplicitous action; the judge’s holding in lcn v. Blazora Corporation found that “if the bond’s terms require interest to be paid every month, it must certainly be paid out every month.” [Emphasis added] Opposing counsel’s deliberate misinterpretation or convenient amnesia of his own opinion here stands in stark contrast to the facts.

The Plaintiff hopes the above is a helpful reminder of the facts as they stand, and serves to clear up any deliberate or otherwise unnecessary confusion introduced by the defense, and welcomes further questions from the bench.

4. THE DEFENSE DISCLAIMS SOME FACTS, BUT THESE ARE EASILY OVERTURNED BY A LOOK AT THE RECORD AND A BASIC ANALYSIS OF THE LAW, JUSTICE, AND COMMON SENSE

There are two facts in contention here:

1. That lcn v. Blazora Corporation was decided via a Summary Judgment, and

2. That defendant had a right to call the bond as he did on the 27th of February.

These are both easily resolvable. First, it as a matter of fact the judge (opposing counsel) in that case did grant Summary Judgment. After the defendant in that case said they were present, they failed to disagree with any of the facts brought up by the plaintiff. The plaintiff then moved for summary judgment alone, stating that:

“The lack of an answer means there are no denials of any of the Plaintiff’s allegations or facts. The lack of denial means there are no facts in dispute. As there are no facts in dispute, as a matter of law the Court should direct the verdict for the Plaintiff.”

lcn v. Blazora Corporation. The judge then granted that request, saying “This court is now in recess until Summary Judgment is delivered.” The defendant in that case had six whole days to say anything or attempt to appeal, but did not. After the verdict was delivered for the plaintiff, the defendant never attempted to appeal the case.

Opposing counsel attempts to muddy the waters by bringing up definitions, but two can play at that game. Default judgment is: when “[a party fails] to include the necessary information[, which] is grounds for plaintiffs to request the presiding judge to grant default judgment.” This does not say that a judge may grant default judgment on their own. It also does not say that a judge must grant default judgment, whether a plaintiff moves for it or not. Simply that a plaintiff may request it.

In contrast, Summary Judgment is when a plaintiff requests a judge to make a decision before trial when no facts are in dispute. The plaintiff alleged facts, the defendant did not dispute them. The plaintiff pointed this out and the judge agreed, so much so that he wrote an entire opinion going through each alleged offense and agreeing with all of them.

In this case, opposing counsel said that the Summary Judgment rightfully granted in that case should have instead been a default judgment, because the party in question did not appear, vs. a Summary Judgment where the parties both agree on the facts.

It is plain as day that the plaintiff in that case was seeking a Summary Judgment. The judge in that case echoed that desire, and then granted it. To attempt to say that instead it was a default judgment is clearly wrong, because the judge in that case—opposing counsel here—went through and granted each of the claims as fact due to the defense not denying them. If this case were to be default judgment, the judge would not have wasted time writing up his opinion, nor would he have wasted time asking the plaintiff there for explanation over one of his alleged offenses, nor would the judge have denied one small portion of the alleged damages. As a matter of law, the judge in that case granted Summary Judgment, and there it shall stay.

As to the second point, the defendant did indeed create a new contract. This contract exists because the original contract did not have a provision whereby a modification of the contract could be made. Even if it did, not every bondholder agreed to the alleged modification (two bondholders voted against). They could not be held bound to a modification they never agreed to.

Instead, a new contract was created because as a class the bondholders continued to hold the bonds when the proposal was put into place, indicating silence by acceptance. This new contract did not have any of the terms included in the first contract, nor did it modify the first contract except for the fact that the bond would continue until mid-summer.

With these contentions swatted down, there are no more disputes in the facts, and we can move on to the defense’s attempt to defend against the Plaintiff’s allegations.

5. THE DEFENSE’S NEW ARGUMENTS ARE SEE-THROUGH AND WILL NOT SURVIVE SCRUTINY

The defense has three arguments:

1. The vote created a modified contract, and when that contract was called (as they alleged it still could be) it only owed its holders the principal amount and the amount of interest for November, December, and January.

2. That amount was still in the exchange, and it was not the Defendant’s fault in any way that it was not in the Plaintiff’s hands.

3. The Plaintiff is suing because the Exchange is the ones that actually posted, not the Defendant.

These are easily dismissed.

Point one is addressed directly in the latter half of section four. A new contract was created, and it did not have the term that the bond could be called early. Further, it is a factual inaccuracy—and another eyebrow-raising misrepresentation—that the only months owed were for the months of November, December, and January. The case preceding this one held that as of the bond’s maturity date, January 1, two interest payments had been made and one was owed. Those months would be October, November, and December. The opposing counsel knows this for a fact, but chose to misrepresent their previous ruling anyways.

Further, the Defendant “called” one day before the month of February concluded. This was a clear attempt to suck as much time as the Defendant could from innocent investors, and should not be rewarded. The moment a month ticks over, interest for that full month must be owed to prevent fraud. Finally, the Plaintiff’s principal was not returned until March 27, 2025. Until that time, the Defendant was able to not pay out any investors and keep the money. If the court does not hold that the Defendant owes the plaintiff interest for the full month of February and for at least 27 days of the month of March, then the court will be punishing future investors who may innocently invest in a project, only for a bad-faith debtor to call their investment and drag their feet, holding the amount in principal interest-free. This cannot stand.

Point two is similarly tossed aside, ironically thanks to the Defendant’s own help. An amicus brief filed by Avaneesh2008 on behalf of The Exchange notes that on March 20th, 2025, “Nexalin asked The Exchange to pay [to cover] both the face value of the bond and one month [sic] worth of interest.” Opposing counsel seems to agree with this fact, as he did not object to anything stated, and decided to try to say that the Plaintiff in this case has no more standing.

In helpfully giving the timeline for when Nexalin truly tried to pay back the money, opposing counsel has made a critical error. The eagle-eyed court watcher will notice that the date Nexalin asked The Exchange to pay back his investors—almost a month after officially calling the bond—coincided with the same day that opposing counsel declared its representation for Nexalin.

The timeline must be remembered here; Nexalin lost his case against lcn on February 25. Nexalin called the bond on February 27. MegaMinerM asked for his money on March 8. This lawsuit was filed on March 17. Nexalin retained the judge of the previous case as counsel on March 20. Nexalin asked The Exchange, for the first time, to pay investors back on March 20.

This is not a coincidence. It is also not ethical, and it is not moral. It is clear as the magnifying glass in my profile picture that the Defendant in this case, pleading that it was instead the victim of The Exchange’s failure to get the money out to the people, was lying. The Defendant did not even try until the threat of a lawsuit hung over his head. For this reason, point two must be discarded, as if the Defendant had attempted to return the money to the Plaintiff the day (or even the week) of the bond being called, it would have returned in a timely manner. In addition, if the Defendant wants to blame The Exchange, they must sue The Exchange and prove they caused the damages, instead of waving around vague accusations of blame. It is not the Plaintiff’s fault that the negligence of the Defendant may have been augmented by that of a third party—that is what third party cross-claims are for.

Point three is the weakest of all the points. The language of many of the punitive claims says “authorizing.” It is unreasonable to think The Exchange was posting various informational releases without the Defendant’s authorization, and opposing counsel recognized and agreed with this fact when he ruled against the Defendant in the previous case.

Further, again, if Defendant truly believed his assertion correct he would sue The Exchange during this case in order to reclaim partial or whole damages the Defendant is ruled liable here for. In not doing so, Defendant plainly admits his desire to see this case tossed out and hoping that The Exchange is likewise shielded, so that the Defendant’s wrongdoings and The Exchange's alleged (by the Defendant’s) wrongdoings will go unpunished.

The court cannot allow this to pass, and must not diminish liability for the Defendant. If the Defendant truly believes that The Exchange should be held liable for the damages wrought in this case, they should put their money where their mouth is. It is not up to the Plaintiff to combat wrongs on the behalf of the Defendant.

6. THE MOTION TO DISMISS HAS NO BACKING, THE CLAIM HAS NOT BEEN EVEN PARTIALLY DISTURBED

As explained above, the motion to dismiss is toothless. Even if it could be fathomed that the claim on the principal value of the bond and one interest payment should be disclaimed (more on that later), the case still relies upon a wealth of punitive damages from the horrendous conduct of the Defendant, the interest payment for the entire month of January, the interest payment for the entire month of February, and the interest for the money held up until the 27th of March.

Further, it is clear that the punitive damages have finally convinced the Defendant to take his fraudulent behavior seriously. The defendant, as opposing counsel notes in the dicta of his opinion, disappointingly did not even bother to properly defend his first case. He seemed to have taken it as a cost of business and moved on. The Plaintiff here, worried about the justice for future investors, decided to up the amount on the punitive damages, both as a reflection of how much more is at stake (monetary wise, as he has much more money invested than lcn in that case) and how Nexalin continued his depraved actions despite being slapped with a heavy fine.

It is telling that the Defendant has finally retained counsel—the judge of his old case, no less. It is telling that Defendant has tried to undercut the Plaintiff by (eventually) paying back (part of) the money the Defendant unjustly kept. It is telling that the Defendant has attempted to use all of these tricks, but they will all fail.

The Plaintiff humbly asks the court this: do not reward the Defendant’s despicable actions. These duplicitous, anti-social, and untrustworthy acts of fraudulent behavior such as calling a bond one day before he believed new interest would be due to evade it, keeping the principal of that interest for nearly a month interest-free, and then trying to fess up and return the stolen money when threatened with legal action in an attempt to try to lower the fees he will inevitably pay cannot be rewarded.

In considering your damage awards, do not reduce any of the compensatory damages, particularly the $260,400 figure. The Plaintiff urges the court not to remove this figure but instead to credit the mid-case payment after rendering the decision. The Defendant here clearly wants to try to mitigate fees they pay by “fixing” damage done after the fact. A thief cannot return a precious gem he has stolen in the middle of his trial and force the government to lower his prison sentence; so too should the court not reward this “Oops, I got caught!” behavior.

In closing, none of the requested damages should be removed or diminished, as they were true when the case was filed and the Defendant should not be rewarded for only changing their behavior when they were caught. Further, the case should not be dismissed because there are still many claims on the board: by Plaintiff’s math, nearly two million of them. Finally, none of the defenses opposing counsel summons are able to overcome the evidence presented—nor can the Defendant overcome common decency. The Plaintiff requests a speedy and just verdict in this matter.

Thank you for your consideration. I yield the remaining time.

Motion

IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
MOTION FOR SUMMARY JUDGMENT

The Plaintiff moves that the Plaintiff in this case be granted summary judgment, and in support thereof, respectfully alleges:

1. The Defendant has had 80 hours to file an opening statement,

2. The Defendant has failed to file an opening statement,

3. The Plaintiff has conclusively disproven the Defendant's assertions regarding the facts in controversy,

4. There are no facts in controversy,

5. The merits of this case are backed up by common sense and precedent through lcn v. Blazora Corporation,

6. The Plaintiff is entitled to summary judgment as a matter of law, and to be granted all relief listed in the original complaint above.

Opening Statement

IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
OPENING STATEMENT

INTRODUCTION
Your honor, this case is a simple one. The Plaintiff attempted to distort reality and convince you that somehow my client is liable for some nearly non-existent damages. Unfortunately for the Plaintiff, the facts show an entirely different story. In this Opening Statement, I will establish the following:

• Even if my client is liable, the requested damages are grossly disproportionate.
• The much smaller amount of actual damages were not caused by Blazora Corporation.

Closing Statement

IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
CLOSING STATEMENT

Your honor,

The arguments of the defense are quite concerning and border on perjury. It is frightening to see this total collapse in legal standards and professionalism as the defense misrepresents, obfuscates, and in some cases outright lies about the facts in order to attempt to salvage the Defendant’s despicable, greedy, and outrageous behavior. Opposing counsel here attempts to misrepresent what they ruled on in that case, but it cannot be denied that he unequivocally held against Nexalin, and as a matter of law ruled that Nexalin was liable in some part for all of the claims submitted against him; which make up the bulk of the claims here.

The defense’s argument fails because it asks the court to blatantly go against legal precedent not only in a case similar to this one, but arising directly out of the same case or controversy. It also fails due to common sense and basic date-checking, because the Plaintiff has enough fingers on his hand to count how many months the bond ran before even the calling of the bond on the 27th of February. (Spoiler, it is more than three.) Further, the argument fails because it is wholly unreasonable, illogical, and absurd to deny the Plaintiff relief in this matter, caused or influenced wholly by the Defendant’s laziness and greed.