Documents

Every document in this archive, organized by filer. Plaintiff's filings, defense counsel filings, court orders, and cross-case exhibits are each grouped separately. All PDFs are direct downloads from this site; many also have landing pages with additional context.

Cross-case exhibits (marked with a dashed amber edge) come from unrelated Ramsey County matters — they're included as comparative evidence that the documented procedural defects are systemic, not specific to this plaintiff's litigation.

Plaintiff Filings

17 documents

Filings by the plaintiff in Strickland v. Ramsey County (D. Minn.).

Document Date Type Court PDF
Amended Petition

Amended federal complaint naming the full set of defendants and laying out the Monell theory.

re: starr, larmouth, clysdale, rueger, bacon, mason, manderfeld, kletscher, rcso, loya, bgs, meta, lee

Pleading D. Minn.
Declaration of Plaintiff

Sworn declaration filed in support of the Motion for Preliminary Injunction.

Declaration D. Minn.
Motion for Preliminary Injunction

Motion seeking injunctive relief pending resolution of the federal action.

Motion D. Minn.
Memorandum of Law in Support of Preliminary Injunction

Legal argument with authorities for the Preliminary Injunction motion.

Memorandum D. Minn.
Proposed Order

Form of order the court is asked to enter granting injunctive relief.

Proposed Order D. Minn.
Motion for Default Judgment

Motion to enter default against defendants who failed to respond within the deadline.

Motion D. Minn.
Opposition to Mason's Motion to Dismiss

Response to Assistant Attorney General Mason's MTD on behalf of the Minnesota Judicial Branch.

re: mason

Sep 2025 Opposition D. Minn.
Opposition to Bacon's Motion to Dismiss

Response to Ramsey County Attorney Bacon's MTD on behalf of the county.

re: bacon

Sep 2025 Opposition D. Minn.
Opposition to Kletscher's Motion to Dismiss

Response to BGS shareholder Kletscher's MTD on behalf of BGS and Manderfeld.

re: kletscher, bgs, manderfeld

Sep 2025 Opposition D. Minn.
Surreply

Additional brief addressing new arguments raised in defendants' replies.

Sep 2025 Surreply D. Minn.
Notice of Altered Documents

Notice to the court that documents in the record have been altered post-filing.

Notice D. Minn.
Notice of Irregularities

Notice cataloguing procedural irregularities in the state-court record.

Notice D. Minn.
Notice of Obstruction

Notice of obstruction of court access tied to the fee-waiver denial and related conduct.

re: starr, upton

Notice D. Minn.
Notice of Document Laundering

Notice that filings have been moved between dockets / re-presented as if originally filed elsewhere.

Notice D. Minn.
Informal Brief of Appellant (A25-1655)

Eighteen-page pro se informal brief filed in response to the November 19, 2025 Court of Appeals directive, appealing the HRO entered in 62-HR-CV-24-963 and arguing the district court proceeded without personal jurisdiction after repeated failures of service.

re: lee

2025-11-24 Memorandum MN App.
Motion for Reimbursement of Wrongfully Extracted Fees

Federal motion seeking reimbursement of filing, response, and litigation fees Ramsey County compelled despite an existing hardship-based fee-waiver determination and Minn. Stat. § 563.01. Ties the escalation to Starr's November 7, 2025 order denying an extension of the existing waiver.

re: starr, upton

2025-11-14 Motion D. Minn.
Supplemental Motion for Protective Relief

Forty-four-page supplemental motion in Strickland v. Ramsey County seeking protective relief for third-party suppression of litigation-related speech and evidence, filed after the original Motion for Protective Order and requesting expedited consideration on evidence-preservation grounds.

re: lee, meta

Nov 2025 Motion D. Minn.

Defense Counsel Filings

9 documents

Motions, oppositions, and notices of appearance by the attorneys representing the named defendants.

Document Date Type Court PDF
Mason — Notice of Appearance

Assistant Attorney General Mason enters on behalf of the Minnesota Judicial Branch.

re: mason

Aug 2025 NOA D. Minn.
Mason's Motion to Dismiss

AGO's MTD on behalf of the judicial defendants.

re: mason, starr, larmouth, clysdale, rossow, elsmore, ireland

Aug 2025 Motion D. Minn.
Bacon — Notice of Appearance

Ramsey County Attorney Bacon enters on behalf of the county defendants.

re: bacon

Sep 2025 NOA D. Minn.
Bacon's Motion to Dismiss

County's MTD relying on the internal Register of Actions as authoritative.

re: bacon, rueger, upton, rcso

Sep 2025 Motion D. Minn.
Kletscher — Notice of Appearance

BGS shareholder Kletscher enters on behalf of BGS and Manderfeld.

re: kletscher, bgs, manderfeld

Sep 2025 NOA D. Minn.
Kletscher's Motion to Dismiss

BGS shareholder Kletscher's motion to dismiss on behalf of BGS and Manderfeld, filed a day past the response deadline.

re: kletscher, bgs, manderfeld

Sep 2025 Motion D. Minn.
Manderfeld — Notice of Motion and Motion for Contempt

Two-page motion under Minn. Stat. §§ 609.748, subd. 6(h) and 588.01, subd. 3(3), asking the court to hold Strickland in contempt and to enjoin the webpages Lee says harass her. Served November 10, 2025. The separately filed declaration supporting this motion carried uncensored explicit exhibits — see note below.

re: manderfeld, lee, starr

2025-11-10 Motion Ramsey Co.
Letter to Judge Starr re: August 19 Motion Hearing

Barna, Guzy & Steffen letter from Kyle T. Manderfeld to Judge Starr, filed 4:53 PM on August 13, 2025. States that the transcript needed for his response arrived August 12 and that his response was filed August 13, acknowledges this left Strickland under a week to review before the August 19 hearing, and proposes a brief continuance.

re: manderfeld, starr, lee

2025-08-13 Notice Ramsey Co.
Affidavit of Service by U.S. Mail (Motion for Contempt)

Affidavit of Janet R. Anderson attesting that on November 10, 2025 she served the Notice of Motion and Motion for Contempt, and the Declaration of Kyle T. Manderfeld with Attachments, by U.S. Mail in 62-HR-CV-24-963.

re: manderfeld, lee

2025-11-10 Notice Ramsey Co.

Court Orders

5 documents

Orders issued by state-court judges and the Minnesota Court of Appeals.

Document Date Type Court PDF
Starr's Order Denying Motion to Vacate

Order invoking collateral estoppel to deny vacatur of the underlying HRO; the "Finding of Facts" referenced throughout the Starr dossier.

re: starr, lee

2025-08-19 Order Ramsey Co.
Order Denying Fee Waiver Request (June 29, 2026)

Fourth fee-waiver denial in 62-HR-CV-24-963. The only finding checked is Box 1, "The action is frivolous" — the eligibility findings in Box 2 and the insufficient-information finding in Box 3 are both blank, as is the record-open date in Box 4. The Box 5 "Other" paragraph declares the ex parte allegation "a false statement of the facts," rejects the notice-defect and irreparable-harm grounds, and states the underlying HRO is not properly before the court. Digitally signed 13:45:02 and filed the same day.

re: starr

2026-06-29 Order Ramsey Co.
Order Directing Remedy of Briefing Deficiencies (A25-1655)

Court of Appeals order in Lee v. Strickland, A25-1655, signed by Chief Judge Jennifer L. Frisch. Notes that no appellant brief or extension motion was on file, affords a final opportunity to file, permits an informal brief because the appellant is self-represented, and sets a December 1, 2025 deadline on pain of dismissal.

re: lee

2025-11-19 Order MN App.
Order Denying Motion to Intervene

Minnesota Court of Appeals order denying intervention in the underlying state matter.

Nov 2025 Order MN App.
Order Denying Stay

Minnesota Court of Appeals order denying stay pending appellate review.

Nov 2025 Order MN App.

Oversight & Administrative

4 documents

Federal civil-rights oversight correspondence and disciplinary or administrative determinations.

Document Date Type Court PDF
LPRB Determination

Lawyers Professional Responsibility Board disposition on a complaint filed against one of the attorneys in this matter.

Determination LPRB
DOJ Office for Civil Rights — Complaint Acknowledgment (25-OCR-1567)

Letter from the DOJ Office for Civil Rights (Office of Justice Programs) acknowledging Plaintiff's complaint against the Ramsey County District Court, assigning number 25-OCR-1567, and requesting the verification and identity-release forms that precede any jurisdictional review.

2025-07-10 Notice DOJ OCR
OLA — Complaint Received (Ramsey County Fee Handling)

Office of the Legislative Auditor acknowledgment of Plaintiff's complaint about Ramsey County District Court fee handling, with the data-practices identity questions.

2025-09-19 Notice MN OLA
OLA — Complaint Decision (Declined Review)

OLA's decision declining to select the complaint for audit or review — confirming its authority under Minn. Stat. 357.021 but citing limited staff resources, and redirecting Plaintiff to Administrator Michael Upton.

re: upton

2025-10-15 Determination MN OLA

Cross-Case Exhibits

5 documents

Documents from unrelated Ramsey County litigation that exhibit the same dual-record defect — independent corroboration of the Monell pattern.

Document Date Type Court PDF
Register of Actions — Scheffler (62-CV-25-6308)

Register of Actions for Ramsey County case 62-CV-25-6308, cited in the Wright docket analysis as a comparison record for non-sequential index references and regrouped case events.

re: bacon

Nov 2025 Exhibit Ramsey Co.
Wright — Public MCRO (62-CR-22-5111)

Public-facing MCRO Register of Actions for Wright v. St. Paul Police Department — clean, chronological, ascending index.

re: bacon

Exhibit Ramsey Co.
Wright — Internal "Bacon ROA" (62-CR-22-5111)

Internal attorney-facing Register of Actions for the same Wright criminal case — non-sequential index, regrouped entries. Same dual-record defect documented in Strickland's own dockets.

re: bacon

Exhibit Ramsey Co.
Wright v. St. Paul Police — Amended Complaint

Federal amended complaint that placed the dual-ROA evidence into the federal record — independently of Strickland.

Nov 2025 Pleading D. Minn.
Unsigned Default HRO — Perryn Marks v. Franchize McWright (62-HR-CV-26-415)

Two-year default Harassment Restraining Order issued by Referee Jenese Larmouth and processed as final despite a blank "By the Court — Judge of District Court" countersignature line, then mis-mailed to the plaintiff. Exhibited as independent corroboration of the same default-by-routine defect. (Companion law-enforcement information form withheld here — it contains an uninvolved third party's confidential data.)

re: larmouth

2026-05-14 Order Ramsey Co.