from: Lion News lionnews00@gmail.com
to: kbloomquist@bloomquistlaw.com,
mcstar@midconetwork.com,
sellertson@stjamesnews.com
date: May 19, 2021, 1:19 PM
subject: Court File No. 46-Cv-19-1224. Goldmount Veterinary Center, P.A. Vs Watonwan County, Animal Humane Society And An Armed AHS Humane Agent Keith Streff?
mailed-by: gmail.com
Katherine B. Freitag, Esq. (#201558) 612-810-1030 (Attorney for Defendant Animal Humane Society Court File: 46-CV-19-1224):
Can you provide me with the contact information for the individual who authorized your client Animal Humane Agent Keith Streff to wear a firearm into the Wantonwan County Courthouse for Case No. 83-CR-18-513 State of Minnesota vs Michael Charles Johnson? Would you be so kind as to provide me with a copy of that authorization? And has your client Streff sought and obtained permission to wear a firearm at the June 28‐June 30th, 2021 and July 1– July 2, 2021 Jury Trial for Court File: 46-CV-19-1224? How is it possible for part-time Buffalo Lake police Officer Keith Streff to wear a fireearm outside of his jurisdiction? Is it the policy and procedure of the Animal Humane Society that a firearm is part of the uniform of a Humane Agent? Can you provide me with the complete policy and procedure manual for Animal Humane Society Humane (AHS) Agents? Or does your client use the Minnesota Federated Humane Societies policy manual? If so, can you please provide me with a copy? Has or hasn't your client AHS Keith Streff been accused of impersonating a police officer while wearing an Animal Humane Agent uniform?
Can you provide me with a signed authorization pursuant to Minnesota Statute 343.01 Subdivision 1 from Watonwan County that authorized Keith Streff to act as an agent "for the purpose of investigating or otherwise assisting lawfully empowered officials in the prosecution of persons charged with cruelty to animals"? Did the authorization from Watonwan County include a confidentiality agreement for the 13.82 Subd. 7. Criminal investigative data for the confidential criminal investigation of Michael Johnson? Has or hasn't your client Keith Streff been able to obtain the authorization from his 2012 work for the high-profile work for the City of East Bethel yet? Did you or any of AHS' PR team members Kathy Mock or Zack Nugent sign a confidentiality agreement with Watonwan County? Do you or your client use confidential criminal investigative data for promotional use? Has any member of the AHS Humane Agents obtained a signed confidentiality agreement or a signed authorization to act as an agent for any law enforcement agency, county agency or municipality in the history of the AHS? Inquiring minds want to know, don't they?
Terry Dean, Nemmers 320-283-5713
https://www.mnfedhs.org/about-us.html Minnesota Federated Humane Societies MFHS Team Members 1. MFHS Case Report 2. MFHS Compliance Agreement 3. MFHS Transfer of Ownership Agreement to MFHS AGMT 4. MFHS Transfer of New Owner Agreement 5. MFHS Notice of Seizure 6. MFHS Abandoned Property Notification 7. MFHS Evidence Collection Log 8. MFHS Evidence Collection Log/Chain of Custody AGMT 9. MFHS Expense Reimbursement Form 10. MFHS Mileage Reimbursement Form 11. MFHS Background check form 12. MFHS Policy manual 13. MFHS Agent consent form 14. Team Roles & Responsibility Contract 15. MFHS Surrender Agreement 16. MFHS Open Intake Complaint Form
Animal Response Team Chapter 343 grants authority to humane agents and animal control officers (ACOs) to assist in the enforcement of laws relating to cruelty to animals. Agents and ACOs may provide additional personnel to assist. Local animal shelters, national animal welfare organizations, and other qualified resources may assist. MODEL ANIMAL CRUELTY POLICY FOR MINNESOTA LAW ENFORCEMENT January 2021 ModelAnimalCrueltyPolicy_January2021_final2.pdf
https://www.animalfolksmn.org/documents/ModelAnimalCrueltyPolicy_January2021_final2.pdf
https://www.revisor.mn.gov/statutes/cite/343.01 343.01 PURPOSES; POWERS; COUNTY ORGANIZATION. § Subdivision 1.Formation authorized. A state federation of county and district societies for the prevention of cruelty to animals may be created as a corporation under chapter 317A for the purpose provided in section 343.06. The federation may appoint representatives in any county where no active county or district society exists for the purpose of receiving and accounting for funds from any source, and may also appoint agents at large to carry out the work of the federation throughout the state. The federation and all county and district societies may appoint agents for the purpose of investigating or otherwise assisting lawfully empowered officials in the prosecution of persons charged with cruelty to animals. Appointed agents must have training and experience in activities relating to prevention of cruelty to animals or enforcement of laws relating to cruelty to animals. The federation may make bylaws as are necessary to implement its authority under this chapter and under chapter 317A.
Regulations Pursuant to Approved Humane Investigators ii. Qualifications 5. The appointment as an Approved Humane Investigator may be terminated following hearing for: a. Material misstated in the original application; b. Willful disregard or violation of State Statutes or regulations issued pursuant thereto; c. Conviction of any crime, an essential element of which is misstatement fraud or dishonesty or conviction of a felony, is the State Society determines, after investigation, that such person has not been sufficiently rehabilitated to warrant the public trust; d. Pursuing a continued course of misrepresentation or false statements regarding investigations relative to humane care of animals; e. Failure to perform their investigational duties and enforcement of the statutes and/or regulations pursuant to animal care. How To Conduct A Successful Animal Cruelty Investigation Complied By The Minnesota Humane Society This document is made available electronically by the Minnesota Legislative Reference Library as part of an ongoing digital archiving project. http:/www/leg.state.mn.us/lrl/lrl.asp https://www.leg.mn.gov/docs/pre2003/other/811123.pdf
Sean Ellertson, Editor - St. James Plaindealer 507-936-0316 & Al Klein, Publisher/Editor Martin County Star 507-764-6681:
How would you like to do a front page story on how the Wantonwan County Attorney Stephen Lindee 507-375-3373 is illegally withholding Chapter 13 Data that would toss a huge monkey wrench into Case No. 46-CV-19-1224 Goldmount Veterinary Center, P.A. vs Watonwan County, Animal Humane Society? I'm thinking that Lindee has over a million and a half reasons to illegally withhold this damning data, aren't I?
Terry Dean, Nemmers 320-283-5713
Be vigilant and courageous about holding those with power accountable. Give voice to the voiceless. Society of Professional Journalists Code of Ethics https://www.spj.org/ethicscode.asp
https://mncourts.gov/Find-Courts/Fifth-Judicial-District.aspx District Administrative Orders Order # 9 - Prohibiting Firearms in the Courthouse 3. This order does not apply to the following: a. b. c. Licensed peace officers or federally authorized law enforcement agents who are within a courthouse complex in the course of their official duties and have their badge conspicuously displayed. The use of firearms or ammunition as evidence in a hearing before the Court. Persons who have a permit and who also have in their possession the expressed written permission from the Chief of Police or Sheriff who issued the permit to that person to possess a firearm/ammunition within the courthouse complex. ADMINISTRATIVE ORDER #9, 2 nd SERIES State of Minnesota District Court Administrative Order No. 9, 2 nd Series Date of Implementation: March 26, 2008 Fifth Judicial District In Re: Prohibiting the Possession of Firearms or Ammunition within any Courthouse Complex within the Fifth Judicial District Prohibing-of-Firearms-in-the-Courthouse_1.pdf
V. RESPONSIBILITIES OF THE PART-TIME PEACE OFFICER A. The hours of active duty status during the calendar year of a part-time peace officer are limited to no more than 1,040 hours. B. A part-time peace officer shall record all - active duty hours worked either on the Part-time Peace Officer Monthly Hour Log provided by the POST Board, or in an electronic format that includes the same information for each agency by whom the part-time peace officer is appointed. The part-time peace officer shall record the date. time. and total hours of active duty, the name of the agency for which the hours were worked and the name of the designated supervising peace officer assigned for each shift or time entry on the log. C. On the last day of every month the part-time peace officer shall provide the chief law enforcement officer of every agency for whom the part-time peace officer worked a written notice of the total number of hours worked for all agencies. The notice may be provided on the Part-time Peace Officer Monthly Hour Log provided by the POST Board or in an electronic format that includes the same information. D. The part-time peace officer shall keep and maintain copies of active duty reporting forms for five years and shall make the forms available to the POST Board upon request. BUFFALO LAKE POLICE DEPARTMENT Policy and procedure manual
https://www.revisor.mn.gov/statutes/cite/609.4751609.4751 IMPERSONATING A PEACE OFFICER. § Subdivision 1. Misdemeanor. Whoever falsely impersonates a peace officer with intent to mislead another into believing that the impersonator is actually an officer is guilty of a misdemeanor.
https://www.revisor.mn.gov/statutes/cite/343.01 343.01 PURPOSES; POWERS; COUNTY ORGANIZATION. § Subdivision 1.Formation authorized. A state federation of county and district societies for the prevention of cruelty to animals may be created as a corporation under chapter 317A for the purpose provided in section 343.06. The federation may appoint representatives in any county where no active county or district society exists for the purpose of receiving and accounting for funds from any source, and may also appoint agents at large to carry out the work of the federation throughout the state. The federation and all county and district societies may appoint agents for the purpose of investigating or otherwise assisting lawfully empowered officials in the prosecution of persons charged with cruelty to animals. Appointed agents must have training and experience in activities relating to prevention of cruelty to animals or enforcement of laws relating to cruelty to animals. The federation may make bylaws as are necessary to implement its authority under this chapter and under chapter 317A.
https://www.revisor.mn.gov/statutes/cite/13.055 13.055 DISCLOSURE OF BREACH IN SECURITY; NOTIFICATION AND INVESTIGATION REPORT REQUIRED. Subd. 2.Notice to individuals; investigation report. (a) A government entity that collects, creates, receives, maintains, or disseminates private or confidential data on individuals must disclose any breach of the security of the data following discovery or notification of the breach. Written notification must be made to any individual who is the subject of the data and whose private or confidential data was, or is reasonably believed to have been, acquired by an unauthorized person and must inform the individual that a report will be prepared under paragraph (b), how the individual may obtain access to the report, and that the individual may request delivery of the report by mail or e-mail. The disclosure must be made in the most expedient time possible and without unreasonable delay, consistent with (1) the legitimate needs of a law enforcement agency as provided in subdivision 3; or (2) any measures necessary to determine the scope of the breach and restore the reasonable security of the data.
6/22/18 9 am I briefed the AHS PR team and Kathy Mock on the status of this case while in route back to the Johnson farm. Arrangements were made to have AHS (Zack Nugent) PR meet me at the farm site. AHS – 23
7/25/18 10:30 am I briefed Kathy Mock and the PR department on the current status of this case. I will have more information once I’ve had an opportunity to speak with the attomey and Dr. Kittleson regarding the status of these ponies. AHS – 27
6pm I briefed Kathy Mock and the AHS PR team by email regarding the current status of this case. AHS – 35
2:05 pm I called Prosecutor Stephen Lindee. I lefi a message for him to call my cell to discuss the status of the ponies. - He returned my call. Kathy Mock happened to be in my office at the time. We discussed the status of the case. He agreed to have Mr. Lindee send Dr. Kittieson another letter releasing the ponies as criminal evidence in this case. Kathy and I decided to seek legal counsel from attorney Katie Bloomquist at c) 612-810-1030. We set a date for Katie to meet us at AHS on October 2, 2018 at 9 am. AHS – 38
10/2/18 9am Kathy Mock, Paula Flom, Ashley and I met with attorney Katie Bloomquist at AHS. We discussed the status of this case and the conflict we are having with Dr. Kittleson and the boarding bill for the ponies. We agreed on a retainer and AHS sending Katie the entire case file.
10/4/18 4:30 pm Agent Pudas forwarded the case file information (see document folder) to AHS attorney Katie Bloomquist. Not all of the photos were included at this time. - Katie has acknowledge receipt of the case file info sent by Pudas. She will begin to review today.
10/5/18 11:30 am I sent Katie Bloomquist an email to confirm her receipt of the case file info. I included the contact information for Prosecutor Stephen Lindee. I also emailed Stephen Lindee the contact information for Katie Bloomquist. A BC of the email exchange between Stephen and I was forwarded to Kathy Mock for review. AHS – 39
Goldmount Veterinary Center, P.A., Plaintiff, vs. Watonwan County and Animal Humane Society, Defendants, and Watonwan County and Animal Humane Society, Third-Party Plaintiffs, vs. Michael Charles Johnson, Third-Party Defendant. Affidavit of Jennifer A. Gish. Filed in District Court State of Minnesota 12/18/2020 3:54 PM Court File No. 46-CV-19-1224.
Q And you said that you were appointed agent for East Bethel; is that right?
A Yes.
Q That was - - and the official that appointed you was the city planner?
A Or a deputy planner. I don’t know her specific title, but she’s from the planning department is my understanding.
Q Who is that?
A I don't recall.
Q You said that, there would be a record of that on file: is that right?
A Yes.
MR, RICHMAN: Your Honor, I would ask that that be provided by the prosecutor, Ms. Nodes.
THE COURT: That's the rule of discovery in a criminal case that, she turns over everything she has.
So, go ahead. Next question. Page 50. State Of Minnesota, Plaintiff VS. Lowell George Friday, Defendant Case No. 02-CR-12-197 Contested Omnibus Hearing July 6, 2012 Transcript. Honorable Sean C. Gibbs, Presiding.
A Again, I'm not sure. I'd have to working with the City of East Bethel that it was assumed that I was their agent and worked in that capacity, and at one point I asked them to officially documentation and send it.
Q But that was sometime after August 29th?
A It could be. I'd have to look at it. Page 51. State Of Minnesota, Plaintiff VS. Lowell George Friday, Defendant Case No. 02-CR-12-197 Contested Omnibus Hearing July 6, 2012 Transcript. Honorable Sean C. Gibbs, Presiding.
Q Upon receipt then of these formal complaints, did you take any course of action?
A Yes.
Q What did you do?
A I subsequently followed up by contacting the Anoka County Sheriff's Department and discussing their case file history and we made arrangements to meet at the farm to take a look at the horses and discuss the situation with Mr. Friday.
Q Why did you invite the Anoka County Sheriff's Office to come with you?
A That is an SOP that our department, typically follows, on top of prior history and knowledge of what’s going on with this particular farm.
Q Okay. First, a couple things with that statement. First, SOP?
A Standard Operating Procedure.
Q Thank you. Second, tell me a little about the history of the property and indicate what caused you to
want to call out to the sheriff's office?
A Well due to the background, history and prior knowledge of what's going on in a number of horses and some of the complications associated with the complaint, my awareness of the background, history of those that are filing those complaints all tell me that local 1aw enforcement, of jurisdiction should be involved with the foIlow-up procedure.
Q Okay. Are they there for safety purposes?
A For writing purposes. Documentation, witness safety obviously, and they are the agency of loca1 jurisdiction, so it's a matter of professional courtesy. Page 15-16. State Of Minnesota, Plaintiff VS. Lowell George Friday, Defendant Case No. 02-CR-12-197 Contested Omnibus Hearing July 6, 2012 Transcript. Honorable Sean C. Gibbs, Presiding.
Q So given that you didn't have a search warrant what authorized you to even step on that property?
A we discussed the situation with Mr. Friday. Mr. Friday and I have a rather cordial relationship and
I explained to him exactly what the policy, procedure was that we were following, and the purpose for our visit, and that we wanted to establish the facts and circumstances regarding the health and welfare of his horses and he voluntarily allowed us to do that. Page 19. State Of Minnesota, Plaintiff VS. Lowell George Friday, Defendant Case No. 02-CR-12-197 Contested Omnibus Hearing July 6, 2012 Transcript. Honorable Sean C. Gibbs, Presiding.
Q I want to also draw your attention to your personal notes and ask you to focus on the center of this page dated November 14, 2011, approximately 1 p.m., take a moment to familiarize yourself with this and refresh your recollection.
MR. RICHMAN: Your Honor, I object. There hasn't been any indication that there is an absence of recollection.
THE COURT: That's true. Ask him a question first.
MS. NODES: Sure.
(By Ms. Nodes) Do you recall having communications with Gina Benson on November 14, 2011?
A Yes.
THE COURT: Well, take the document back because he is looking at it and testifying from the document. So the procedural objection was he can't do that, which is true. so if you can ask him the question and if he can't remember it, then he can refresh his memory. Go ahead, question. Page 60. State Of Minnesota, Plaintiff VS. Lowell George Friday, Defendant Case No. 02-CR-12-197 Contested Omnibus Hearing October 2, 2012 Honorable Sean C. Gibbs, Presiding.
5 Attachments: Chapter13020121_940am.pdf, Chapter13020221_159pm.pdf, Chapter13020221_217pm.pdf, Evidence Of Harassment Over Watonwan Sheriff Lexipol Policy And Procedure And County Attorney Policy And Procedure Manuals And Pleadings For Case No 46-CV-19-1224.pdf, Why Oh Why Am I Being Harassed Over Readily Available Free Electronic Public Data That Proves That Watonwan County Is Negligent In Both Case No. 46-CV-19-1224 And Case No. 83-CR-18-513_040721_1158.pdf
More to come ...
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