06-01-21
Kathryn Davis Messerich, Chief Judge
C/O: Brian Jones, District Court Administrator
1620 S. Frontage Road, Suite 200
Hastings, MN 55033 Mailed: Certified Mail
RE: Public Defenders Shea And Baker Conspiring With Prosecutors To Sabotage Case No. 19HA-CR-19-2768.
Chief Judge Davis Messerich: My public defenders Kevin Shea and Scott Baker are conspiring with the Dakota County Attorney’s office to sabotage my case - Case No. 19HA-CR-19-2768 State of Minnesota vs. Jessica Danielle Hartger. This complaint will lay out how Shea and Baker are sabotaging my case. A case that should have been dismissed two (2) years ago. The father of my child, Cody Myers, has a history of harassing me with false police reports. I have reason to suspect that Myers has a well-thought out plan to deprive me of my parental rights through these false police reports.
Case No. 19HA-CR-19-2768 is just another example of Cody’s wild, outrageous and unsubstantiated assertions that are being used to harass me and to deprive me of my parental rights. By the conclusion of this correspondence, you will find in part, my reasons to believe that my former Public Defender Kevin Shea, my current Public Defender Scott Baker, former County Attorney James Backstrom, prosecuting Attorney Cory Monnens and current Acting County Attorney Kathryn M. Keena are conspiring, into either forcing me to plead guilty to crimes I did not commit, and or forcing me to be found guilty at jury trial, by withholding exculpatory evidence that proves my innocence.
Unfortunately, after my recently submitted, competent report to The Public Defender’s board, regarding Mr. Kevin Shea & Scott Baker’s misconduct, Mr. Scott Baker has now retaliated against me, and is requesting a Competency Hearing under Rule 20.01, in which to only prolong this trial and to continue to further harass me, humiliate me, and to deprive me of my minor child. To start with a simple example, in July 2019, Mr. Myers contacted Plymouth Police Department to report an alleged assault during a child custody transfer. During this interaction it was noted that Mr. Myers was the aggressor in the situation, against the claim(s) of Mr. Myers being the victim.
“I spoke with Officer Dane who was able to view the video surveillance of the initial interaction in front of the store. Officer Dane told me he could see the door being opened by Hartger but it did not appear to hit Myers. You can see Hartger use her arm to push Myers away from the door, by nothing appeared to be assaultive in nature.” Supplemental Report ICR: 19029509. Title: Main #113 Peterson. Summary Argument between parent of child during child custody exchange. Plymouth Police Department Incident Report. ICR#: 19029509. Reported: 06-28-2109 0855. Officer Assigned: Peterson, Ryan Badge No. 113. Primary: Yes. Involvement: Mentioned. Name: Hartger, Jessica Danielle. Involvement: Complainant. Name: Myers, Cody Austin.
This was almost exactly a month before the second falsified assault claim brought
forth by Mr. Myers, on August 13, 2019 1 . On this date, I, Jessica Danielle Hartger, was contacted by Officer Joshua Flynn (#4897), of Lakeville Police Department, in regards to an alleged assault that occurred previously that day. At the time of this communication, I was geographically located in Plymouth, MN, roughly 40 minutes north of Lakeville, MN. When Officer Joshua Flynn (#4897) questioned my whereabouts, I discussed in detail my true and correct location, and that I was in the process of moving out of my apartment in Plymouth, with the help of a friend, Madison Elkins, at that time. the false accuser Myers contacted Lakeville P.D., and filed a false police that I, the defendant,
1. broke into his secured apartment building in Lakeville, MN, in broad
daylight, and,
2. I was accompanied by an unknown female, and,
3. I attempted to force my way into his apartment after biting him on the
arm,
4. I can be verbally heard in the 9-1-1 call to place me at the scene
I advised the Officer he could simply “ping my phone’s location through my
carrier if necessary.” The Officer advised he would do so. The audio from this day was also requested by Lakeville P.D. Detective Troy Hokanson, in writing, for the 9-1-1 dispatch call and any audio related to such. (See Tape Request Form 8.13.2019, Incident #19003381). The following day, August 14, 2019, I was arrested in Lakeville, MN, for a 5th degree assault. On this date, my then spouse properly filled out the necessary forms to obtain the data related to these allegations, Including police report(s) photos, the 9-1-1 dispatch call recording and transcription, etc. As of this date, May 31, 2021, I have demanded the above mentioned discovery from my former Public Defender, Kevin Shea, directly from Lakeville P.D., directly from Dakota County, as well as from my current
_____________________________
1SUPPLEMENTAL REPORT 4897 Case #:LA19003381 Incident #: LA19003381.002.002 [insert reports AUG 13/14]
Public Defender, Scott Baker. As of this date, now former Dakota County attorney James Backstrom, prosecuting Attorney Cory Monnens and acting Dakota County Attorney Kathreen Keena have willfully refused to provide me with this exculpatory data. It is now former Dakota County attorney James Backstrom’s, prosecuting Attorney Cory Monnens’ and acting Dakota County Attorney Kathreen Keena’s known mandatory, nondiscretionary, ministerial duty of the office to provide me with my subject data aka exculpatory evidence within the ten (10) day time period as prescribed by law. It should be noted that neither Public Defender Shea nor Baker have made any attempt to file a motion for sanctions or even a contested omnibus hearing to bring this due process violation to the court’s attention.
“We have held that when the State suppresses or fails to disclose material exculpatory evidence, the good or bad faith of the prosecution is irrelevant: a due process violation occurs whenever such evidence is withheld.” Illinois v. Fisher.2 2. 540 U.S. 544, 547, 124 S.Ct. 1200, 1202 (2004). George R. Dekle, Sr, Prosecution Principles: A Clinical Handbook (Thompson/West:2007), Page 145.
13.04 RIGHTS OF SUBJECTS OF DATA. Subd. 3. Access to data by individual. Upon request to a responsible authority or designee, an individual shall be informed whether the individual is the subject of stored data on individuals, and whether it is classified as public, private or confidential. Upon further request, an individual who is the subject of stored private or public data on individuals shall be shown the data without any charge and, if desired, shall be informed of the content and meaning of that data. After an individual has been shown the private data and informed of its meaning, the data need not be disclosed to that individual for six months thereafter unless a dispute or action pursuant to this section is pending or additional data on the individual has been collected or created. The responsible authority or designee shall provide copies of the private or public data upon request by the individual subject of the data. The responsible authority or designee may require the requesting person to pay the actual costs of making and certifying the copies. The responsible authority or designee shall comply immediately, if possible, with any request made pursuant to this subdivision, or within ten days of the date of the request, excluding Saturdays, Sundays and legal holidays, if immediate compliance is not possible.
Not only do I want all the evidence for my cases but I want a contested omnibus hearing and the cases dismissed as a sanction for illegally withholding my subject data aka exculpatory evidence from me. As of this date, I have not been provided any objective data that supports my current pending charge(s). The objective date that is either non-existent, or is being unlawful withheld from me regarding the above date(s) mentioned, are as follows:
1. evidence that shows I was ever at that location,
there are no witnesses statements, no cell phone location ping data, no
photographs, etc.
2. Investigator report(s) after contacting my witness, following her signed
Statement, and
3. Photographs of the alleged bite mark, of the site of forced entry, etc.,
4. The 9-1-1 provided, and transcribed dispatch call.
A. Charging Guidelines 4. Specific Charging Considerations. d. Statements of
the Suspect: If a suspect has not provided a statement at the time the case is
referred for charging, the prosecutor shall contact the investigative law
enforcement agency prior to making charging decision and request that the
agency make reasonable efforts to obtain a statement from the suspect,
provided the taking of the statement does not violate the constitutional or other
legal rights of the suspect or rules of professional responsibility. Dakota County
Attorney Guidelines For The Charging And Disposition Of Criminal Cases. Page
2. Adopted: January 3, 1995 Revised: October 5, 2009 Revised: May 7, 2014
Revised: March 8, 2019 Guidelines For Charging And Disposition Of Criminal
Cases 3.8.19.pdf
7. Records Retention Client Files Format At the conclusion of representation the
client file shall be stored in a physical file and not on the employee’s hard drive,
third party vendor site (cloud based or physical) or office network. Audio and
video materials may not be stored on an employee’s hard drive or the office
network. Audio and video materials shall be burned to a disk or other suitable
electronic format, labeled with the court file number and stored in the physical
file. State of Minnesota Board of Public Defense General Office Policies –Revised
May 2019
The discovery provided does however show this initial report to be falsified by the false accuser, please see the attached report #19003381, and the specific narrative included. I would also like to note that the 9-1-1 audio recorded and provided as discovery by the false accuser, does not have my voice anywhere in it.
Third example, in regards to falsified police reports and or missing discovery, I would like to bring your attention to the next concerning event herein. On the date of September 25, 2019 2 Mr. Myers falsified yet another police report, claiming Hartger violated the HRO, via 3rd party contact, as ordered by the court. Around 3:00 pm that day, my former spouse was
_______________
2 Primary Narrative By Bradley Eisel, 09/25/19 18:44 Case SL19005772
[insert LVPD report]
followed by two undercover detectives of the Lakeville Police Department. They followed him in their undercover vehicles, from my son's elementary school in Lakeville, MN, Located in Dakota County, to his place of employment in St. Louis Park, MN, Hennepin County. According to the police report(s), Detective Kellie Coughlin, and her partner P. Fitzhenry intentionally followed my former spouse, outside of their jurisdiction, with a minor child in the vehicle, not only stalking me and further harassing me, but to unlawfully detain me, in front of my minor child. Detective Kellie Coughlin dropped her knee down onto the back of my head/neck, and I was handcuffed and placed into the male detective’s squad car. This is when St. Louis Park PD began to arrive. Within St. Louis Park PD’s police report, Officer Bradley Eisel, (Case SL19005772) states that I was placed in their squad car. However, when I demanded the squad car footage and audio from St Louis Park PD, SLPD failed to provide it, because it doesn't exist. I never made it into their custody or squad car(s). Since both Lakeville PD Detective Kellie Coughlin and P. Fitzhenry were outside their jurisdiction Coughlin and Fitzhenry could only make
a citizen’s arrest. A citizen’s arrest required Coughlin and Fitzhenry to turn me over to the SLPD. There is no objective evidence that I was ever placed in the custody of SLPD. This is one of many times Detective Kellie Coughlin has proveably exited her jurisdiction to stalk, harass, intimidate, and threaten myself and my family.
609.43 Misconduct of Public Officer or Employee. A public officer or employee
who does any of the following, for which no other sentence is specifically
provided by law, may be sentenced to imprisonment for not more than one year
or to payment of a fine of not more than $3,000, or both: (1) intentionally fails
or refuses to perform a known mandatory, nondiscretionary, ministerial duty
of the office or employment within the time or in the manner required by law;
or
Officers conducting all criminal investigations will, whenever possible, record oral victim and witness statements in lieu of written statements. Statement evidence obtained during an initial investigation can be very powerful evidence in determining the course of an investigation; ultimately impacting charging decisions and convictions. Policy 325 Preliminary Investigation/Required Reports Duluth Police Department Duluth PD Policy Manual.
To continue, a 4th example of yet another falsified police report which led to an
unlawful arrest, this occurring on the date of February 20, 2020, initiated by Dakota County Judge Ann Marie Offerman. Offerman made the wild, outrageous and unsubstantiated defamatory statements that my emails were a threat to Offermann. However, Offermann provided no clear, precise and unquestionable evidence that my emails were a “True threat” to anyone. On this date, I contacted the Dakota County court in regards to the misconduct occurring in my subsequent Civil/Family litigations within the same Judicial District, that was a direct result of the two criminal case files noted
above. Within this police report from Judge Offerman to Apple Valley & Lakeville police departments, it is noted that:
1. Hartger makes/made no direct threats of harm,
2. Hargters communication is not of a criminal nature
3. Lakeville P.D. installed security cameras on Judge Offermans home.
Law Enforcement smashed my passenger car window, and ripped me from the
vehicle, wherein I was once again thrown to the ground, searched, cuffed, and placed into an unknown squad car. I was transported to the basement of the Mall of America by Eden Prairie Police Department, where I was accompanied by an unknown, unmarked, blacked out SUV. Shortly after our arrival, I was transferred to Apple Valley Police Department’s A. MACK, who transported me to South St. Paul, MN, parked his squad car, made a phone call questioning what statute to input on the warrant, typed something out on his incar laptop, then proceeded to transport me to Dakota County Jail. The two squad car footages have yet to be released into evidence, and or to the defense. After I was detained, my former spouse was as well, and charged with obstruction. My former Public Defender and my current Public Defender are both aware of my provided witness and alibi Madison Elkins, whom of which has provided a sworn and signed statement to this court regarding the false allegations brought against me that have led us here today. Neither Kevin Shea or Scott Baker have contacted my witness for an official statement nor had their investigators contact Madison to verify her statement. Furthermore, it should be noted that my Public Defenders Shea and
Baker have willfully refused to add Madison to my Defense’s witness list.. Concerningly, between the dates of April 12, 2020 and May 5, 2020, Lakeville Police Department and their detectives contacted my witness, presumably to intimidate her into not testifying to the truth, on my behalf. This communication between the Lakeville Police Department and my witness Madison Elkins has also not been released into discovery, and or given to the defense. 3
“Officers conducting all criminal investigations will, whenever possible, record
oral victim and witness statements in lieu of written statements. Statement
evidence obtained during an initial investigation can be very powerful evidence
in determining the course of an investigation; ultimately impacting charging
decisions and convictions.” Policy 325 Preliminary Investigation/Required
Reports Duluth Police Department Duluth PD Policy Manual.
________________
3 09-04-20 Affidavit Of Witness Madison A. Elkins. 09/11/2020 Affidavit-Other Index # 105 Case No. 19HA-CR-19-2768 State of Minnesota vs Jessica Danielle Hartger.
Sandra Grazzini-Rucki stated in her high-profile A16-1997 appeal that her high-profile co-defendant Deirdrie Evavold received twelve times the amount of evidence in her criminal case as did Sandra Grazzini-Rucki.
A. Co-Defendant Deirdre Evavold received 12 times the evidence as Appellant.
Signed July 10, 2017 by Sandra Grazzini-Rucki. Page 10. Appellants’ Reply
Brief, Addendum. Case Number: A16-1997 Short Title: State of Minnesota,
Respondent, vs. Sandra Grazzini-Rucki, Appellant.
Deirdrie Evavold has repeatedly publicly stated in court paperwork that exculpatory evidence was illegally withheld from her in her high profile criminal case.
Illegally Withheld Evidence: - Lakeville Officer Kelli Coughlin’s preliminary
audio -recorded statements from Gianna & Samantha Rucki - Preliminary
audio statement of David Rucki Tammy Love, Rick Hakanson, Loralie Musolf,
Kelli Coughlin, Jim Dronen, and Matthew Palmer — Deputy US Marshal,
(Corresponding audio and Video with a report.) Steams County Evidence
(Surveillance of Residence by David Rucki) (Private, criminal investigative data
for Christina Fox) - Blueray disc containing MN Bureau of Criminal
Apprehension reports - Child Protective Services Documents November 2015,
and Foster Parent letters. Page 5 of 8. 02/12/2019 Answer and Counterclaim.
Case Number: 19HA-CV-18-905. Case Title: State Farm Fire and Casualty
Company vs David V. Rucki, Samantha Rucki, Gianna Rucki, Sandra Sue
Grazzini-Rucki, Deirdre Elise Evavold et. al.
Illegally Withheld Evidence: - Lakeville Officer Kelli Coughlin’s preliminary
audio - recorded statements from Gianna & Samantha Rucki - Preliminary
audio statement of David Rucki Tammy Love, Rick Hakanson, Loralie Musolf,
Kelli Coughlin, Jim Dronen, and Matthew Palmer — Deputy US Marshal,
(Corresponding audio and Video with a report.) Steams County Evidence
(Surveillance of Residence by David Rucki) (Private, criminal investigative data
for Christina Fox) - Blueray disc containing MN Bureau of Criminal
Apprehension reports - Child Protective Services Documents November 2015,
and Foster Parent letters. Page 13 of 22. Appellant’s Brief A17-0200. State of
Minnesota, Respondent, vs. Deirdre Elise Evavold, Appellant
I have a great fear that Public Defenders Kevin Shea and Scott Baker were conspiring with and continue to conspire with the Backstrom, Keena and Dakota County Attorney's Office to either force me to plead guilty without ever receiving all my Chapter 13.04 Subject data aka exculpatory evidence or have me found guilty at trial without ever receiving all my Chapter 13.04 Subject data aka exculpatory evidence. I am demanding
an administrative investigation and that you contact outside law enforcement to
investigate this matter.
What this means is that he searched the vehicles at that residence when he knew
he did not have prior judicial authorization and mislead everyone by
representing that he got Judge Quam's authority to search the vehicles. Maybe
Detective Serafin will have another explanation for what happened, and I'll
leave it up to you to decide what happened in this case. I do not think Detective
Serafin has appeared in my courtroom before, and I have nothing against him
personally, but it's important that things like this do not happen in the future.
The parties knew I was prepared to suppress the evidence (drugs) found in the
car and the case eventually settled. March 29, 2018 Letter from Hennepin Co.
District Judge Fred Karasov to Eden Prairie Police Chief DeMann. RE: State v.
Timothy Holmes (27-CR-17-23450) & Detective Travis Serafin
609.43 Misconduct of Public Officer or Employee. A public officer or employee
who does any of the following, for which no other sentence is specifically
provided by law, may be sentenced to imprisonment for not more than one year
or to payment of a fine of not more than $3,000, or both: (3) under pretense or
color of official authority intentionally and unlawfully injures another in the
other's person, property, or rights; or
In conclusion, the above mentioned reasons are just a few of many as to why I
find it to be obvious that I will not have a fair trial or recieve true justice in Dakota County. After 2 years of dealing with these false criminal charges that led to consistent harassment, humiliation, and trauma- inflicted by the Law Enforcement and Judicial Officials noted above, any reasonable person would believe that the never ending misconduct shown herein will continue.
_________________________________________
Jessica Hartger
203 W. 8th Street
Walsenburg. CO 81089
CC:
Libor Jany, Star Tribune Media Company LLC 650 3rd Ave. South, Suite 1300,
Minneapolis, MN 55488
Kevin Kajer, 331 2nd Ave. S. Minneapolis MN 55401
Anna Restovich, 117 E Center St. Rochester MN 55904
from: Harlene Quinzel royalwhiterabbithunter@gmail.com
to: Lion News lionnews00@gmail.com
date: Jun 2, 2021, 2:35 PM
subject: Fwd: REJECTED EFILING Case 19HA-CR-19-2768, State of Minnesota vs Jessica Danielle Hartger
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---------- Forwarded message ---------
From: efilingmail@tylerhost.net
Date: Wed, Jun 2, 2021, 7:43 AM
Subject: REJECTED EFILING Case 19HA-CR-19-2768, State of Minnesota vs Jessica Danielle Hartger
To: royalwhiterabbithunter@gmail.com
This message was automatically generated. Do not reply to this e-mail.
Your submission in case 19HA-CR-19-2768, State of Minnesota vs Jessica Danielle Hartger has been rejected.
Reason(s) for Rejection: Reject per Court Order filed 10/2/2020 in court file 19HA-CR-19-2768. (DLH)
Comment: Reject per Court Order filed 10/2/2020 in court file 19HA-CR-19-2768. (DLH)
Envelope Number: 18204619
Filing Code : Formal Complaint Filed
Filing Description: Complaint & Demand for Sanctions, Investigation, & Dismissal
Date Submitted: 6/1/2021 4:24 PM CST
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from: Harlene Quinzel royalwhiterabbithunter@gmail.com
to: Lion News lionnews00@gmail.com
date: Jun 2, 2021, 12:23 PM
subject: Fwd: complaint file 2021.pdf
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From: Harlene Quinzel royalwhiterabbithunter@gmail.com
Date: Tue, Jun 1, 2021, 2:47 PM
Subject: complaint file 2021.pdf
To: Kathryn.Messerich@courts.state.mn.us, brian.jones@courts.state.mn.us>, anthony.martin@courts.state.mn.us, Clementson, Matthew Matthew.Clementson@courts.state.mn.us
Chief Judge Messerich
C/O: Brian Jones
Please find the attached complaint and demand for investigation. A certified copy has been mailed to you both as well. I will be e-filing a copy for the court record just to ensure this is handled immediately and made apart of the record.
Receipts.pdf
2 Attachments: Receipts.pdf, complaint file 2021.pdf
from: Harlene Quinzel royalwhiterabbithunter@gmail.com
to: Lion News lionnews00@gmail.com
date: Jun 2, 2021, 12:23 PM
subject: Fwd: complaint file 2021.pdf
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From: Harlene Quinzel royalwhiterabbithunter@gmail.com
Date: Tue, Jun 1, 2021, 2:47 PM
Subject: complaint file 2021.pdf
To: Kevin.Kajer@pubdef.state.mn.us
Kevin,
Please find the attached complaint. A certified copy as also been mailed out to you as of today.
Sincerely,
Jessica Danielle Hartger
2 Attachments: Receipts.pdf, complaint file 2021.pdf
More to come ...
Related Links:
Update: Eden Prairie Police Greg Weber Lurking & Skulking On Lion News For 3 Minutes 37 Seconds On 06-19-20 With IP Address 156.142.95.179? Weber Gawking At Pic About Eden Prairie Police Personnel Exacting Street Justice & Payback On Jessica Hartger For Dakota County Judicial Officers David Knutson & Ann Offerman? Oh Dakota Co. Deputy Scheffknecht Says Offerman Filed False Police Report Against Jessica Hartger, Didn't He? So Evidence Of EPPD Street Justice & Payback On Hartger, Right? 3 Minutes Long Enough To File Share Damning Data To Nemmers On 06-19-20, Right? Corrupt Chief Weber Attempts "Payback" & "Street Justice" On Nemmers With Retaliatory Fraudulent Bill?
Eden Prairie Police Personnel Exacting Street Justice & Payback On Jessica Hartger For Dakota County Judicial Officers David Knutson & Ann Offerman? Why Oh Why Didn't EPPD Confirm The Warrant Before They Broke Out Hartger's Car Window? To Teach Hartger A Street Justice Lesson, Right?
Incompetent Bungler Michael "The Hack" Volpe's Latest Victim Jessica Danielle Cook AKA Jessica Danielle Hartger Lands In The Dakota County Jail? Did Nemmers' FOIA Requests To Kent Co. Sheriff Michelle LaJoye-Young & Kent Co. Prosecuting Attorney Christopher R. Becker Expedite Extradition?
Incompetent Bungler Michael "The Hack" Volpe Succeeds In Getting His Latest Victim Jessica Danielle Cook AKA Jessica Danielle Hartger Arrested? You Remember "The Hack" Volpe From His Sabotaging Of The High-Profile Sandra Grazzini-Rucki Case, Don't You? Oh And Don't Forget "The Hack" Volpe Helped To Sabotage All Of Dede Evavold's Cases Also, Didn't He? Run Away - Do Not Walk Away - Run Away From Hack Volpe And His Fellow Fanatic Karen Possessky, Okay?
Incompetent Bungler Michael "The Hack" Volpe Succeeds In Getting A Warrant Issued For His Latest Victim Jessica Danielle Cook AKA Jessica Hartger? You Remember "The Hack" Volpe From His Sabotaging Of The High-Profile Sandra Grazzini-Rucki Case, Don't You? Oh And Don't Forget "The Hack" Volpe Helped To Sabotage All Of Dede Evavold's Cases Also, Didn't He? Hack Volpe's Fellow Fanatic Karen Possessky Speaks?
Lion News: Nemmers Exposes Michael “Hack” Volpe’s & Sandra Grazzini-Rucki’s Smear Campaign?
