SUPREME COURT OF KRAMERIA

Luna Moulton Complainant,

v.

Republic of Krameria Defendant.

BILL OF COMPLAINT

1. Jurisdiction

   This Court has jurisdiction pursuant to the Constitution of the 18th Republic of Krameria, Title V, Article 37, as well as Article 4, Section 5 of the Constitution of Hersey's 17th Republic of Krameria.

2. Statement of Facts

   On or about December 6, 2025, the President of Hersey's 17th Republic of Krameria issued Executive Orders 1326 and 1327. These orders unilaterally annexed the countries of Forza and Îles du Sud and restructured their governments. The Congress of Hersey's 17th Republic of Krameria did not enact ordinary legislation regarding these territories. As a result of these actions, the Complainant has suffered injury in that the constitutional order governing territorial administration has been violated, undermining the rule of law and the proper separation of powers guaranteed by the Constitution.

3. Cause(s) of Action

   The Defendant’s conduct violated Article 2, Section 4, of the Constitution of Hersey's 17th Republic of Krameria, which provides that regulations of territories shall be provided for by that Republic's Congress. The Defendant's conduct additionally, and continuously, violates Title II, Article 9, of the Constitution of the 18th Republic of Krameria, which provides for the same. Such actions are unlawful and give rise to this complaint.

4. Prayer for Relief

   Complainant respectfully requests that this Court grant the relief sought, including:

• A declaration that EOs 1326 and 1327 are unconstitutional and void ab initio;
• An injunction prohibiting the continued enforcement and implementation of said Executive Orders;
• An order restoring the lawful governance structures of Forza and Îles du Sud as they existed prior to the issuance of the Orders;
• Such other and further relief as this Court deems just and proper.

Respectfully submitted,

Luna Claire Moulton April 6, 2026