Lion News

Wednesday, August 11, 2021

Jeremy Boles Asks Kevin J. Kajer, Chief Administrator & State of Minnesota Board Of Public Defense Board Members Le, Darris & Haugen: Why Is Public Defender John Dillon Sabotaging Case Nos. 72-CR-20-85, 72-CR-20-81, 72-CR-20-83 And 72-CR-20-172 State Of Minnesota Vs Jeremy James Boles? FYI Boles' Messerich Complaint Filed As 08/10/2021 Correspondence To Judge Index # 46?

from: jer bls iisokrutoo@gmail.com
to: harris@macalester.edu,
Kevin.Kajer@pubdef.state.mn.us,
lionnews00@gmail.com,
mollyhaugen@yahoo.com,
eli.darris@darrisgroup.com,
dan@danlelaw.com
date: Aug 11, 2021, 2:32 PM
subject: Subject: Why Is Public Defender John Dillon Sabotaging Case Nos. 72-CR-20-85, 72-CR-20-81, 72-CR-20-83 And 72-CR-20-172 State of Minnesota Vs Jeremy James Boles?
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Kevin J. Kajer, Chief Administrator 612-279-3509 & State of Minnesota Board of Public Defense Board members:

Why is my Public Defender John Dillon trying to actively sabotage my criminal cases? Why doesn't Dillon want to get a witness statement from one of my main witnesses Curt Cermak? Dillon has repeatedly stabbed me in the back by not getting my evidence for me. An example would be the recorded statement of Myron Cermak. What has Dillon been doing for 1.5 years? Why didn't Dillon get an investigator assigned to my case 1.5 years ago to get witness statements from Curt Cermak, Myron Cermak, Erica Stufflebeam, and Matthew Romine. In the case of Matthew Romine, Dillon just now finds out right before my repeatedly delayed trial that he can't find Matthew Romine. Why wasn't an investigator looking for Matthew Romine 1.5 years ago? Plus, Dillon admitted that he doesn't have a single policy and procedure from either the City of Henderson Police Department or the Sibley County Sheriff's office. I have reason to suspect that is just another one of Dillion's many blatant lies. I have reason to suspect Dillon knows or should know that Sibley County Attorney David E. Schauer and Assistant County Attorney Donald Lannoye are illegally withholding squad audio/video camera video and/or body camera video and/or jail surveillance/Booking video/jail interview video from me. I believe that Dillon's willful refusal to file a motion for sanction is evidence of Dillion's conspiracy with Sibley County Attorney David E. Schauer and Assistant County Attorney Donald Lannoye. I also believe that Dillon did not subpoena a single member or either City of Henderson Police Department or the Sibley County Sheriff's office to testify at the 05-07-21 Contested Omnibus because he knew or should have known that they would testify to the existence of illegally withheld video by both the city and the county.

I want you to immediately provide me with the names, direct phone numbers and email address for the Chief Public Defender, Dillion's managing attorney and supervising attorney. I also want the updated mailing address for the board members and your current State of Minnesota Board of Public Defense General Office policies. I also want Dillon to email me his eFile copy of 08/10/2021 Correspondence Index # 46 of my complaint to First Judicial District Chief Judicial officer Messerich that I sent to Judicial Officer Amber Donley as correspondence in State of Minnesota vs Jeremy James Boles. Since Dillon has taken advantage of my brain injuries I want him to read pages one (1) through three (3) into the court record on 08/12/2021. If Dillon willfully refuses to do, then I am fully prepared to do so myself. Finally, want Dillon to have my cases dismissed for the reasons that I listed above.

Jeremy Boles

State of Minnesota vs Jeremy James Boles
03/23/2020 E-filed Comp-Order for Detention Index # 1
05/07/2021 Contested Omnibus (1:00 PM) (Judicial Officer Donley, Amber) Result: Held On the Record
08/09/2021 Certify Unserved Process Index # 45
08/10/2021 Correspondence Index # 46
08/12/2021 Settlement Conference (1:00 PM) (Judicial Officer Donley, Amber)
08/24/2021 Jury Trial (8:30 AM) (Judicial Officer Donley, Amber)
04/27/2021 Reset by Court to 05/25/2021
05/25/2021 Reset by Court to 06/29/2021
06/29/2021 Reset by Court to 08/24/2021

https://www.macalester.edu/americanstudies/facultystaff/duchessharris/ Duchess Harris Professor of American Studies Focuses on 20th-century African American political history and civil rights Taoyateduta Hall 109 651-696-6478 harris@macalester.edu
https://darris-consulting-group.ueniweb.com/#contact_us +1 612 385 5664 Darris Consulting Group eli.darris@darrisgroup.com
https://www.danlelawoffice.com/ 7101 York Avenue S., Suite 340, Edina, MN 55435 612.465.8583 dan@danlelaw.com

https://twitter.com/MinneapolisLon1/status/1316948891150045188 Minneapolis LonelyHeart @MinneapolisLon1 How are "ineffective assistance of counsel" complaints & "public defender misconduct complaints" effectively investigated or held accountable when #MinnesotaBoardofPublicDefense @MNBDPubDefense @WilliamWard William.Ward@mnpd.us refuses to address them when filed with his office? Image STMNPD and 9 others 10:47 PM · Oct 15, 2020 from Minneapolis, MN·Twitter for Android 2 Retweets 1 Quote Tweet 2 Likes
https://twitter.com/LonnieKevnClark/status/1237084679385370624 Lonnie Kevin Clark 🗣 Performing arts @LonnieKevnClark On March 2nd 2020 I drafted a letter to alleged @MNBDPubDefense Minnesota Board of Public Defense Member "Helen Meyer" at 1100 2nd Avenue NE in @CityMinneapolis #Minnesota 55413 Clearly #HelenMeyer is not currently at this address or is no longer a @MNBDPubDefense Board Member Image Image Lt. Governor Peggy Flanagan and 7 others 1:35 PM · Mar 9, 2020 from U.S. Post Office·Twitter for Android 1 Retweet

https://twitter.com/MinneapolisLon1/status/1317142015944032258 Minneapolis LonelyHeart @MinneapolisLon1 Outgoing @HennCoDefender @MaryMoriarty could you please identify who is accountable for complaints of misconduct against @MNBDPubDefense @WilliamWard when "Bill" Ward refuses to investigate nor address "ineffective assistance of counsel" complaints & public defender misconduct? Quote Tweet Minneapolis LonelyHeart @MinneapolisLon1 · Oct 15, 2020 How are "ineffective assistance of counsel" complaints & "public defender misconduct complaints" effectively investigated or held accountable when #MinnesotaBoardofPublicDefense @MNBDPubDefense @WilliamWard William.Ward@mnpd.us refuses to address them when filed with his office? Image 11:35 AM · Oct 16, 2020 from Minneapolis, MN·Twitter for Android 3 Retweets 3 Likes

Boles Files Complaint Against Backstabbing Public Pretender Dillon With First Judicial District Chief Judicial Officer Messerich? Boy This Sounds Just Like Complaint Hartger Filed Against Her Backstabbing Public Pretenders Shea And Baker In Rigged Case No. 19HA-CR-19-2768, Doesn't It? It Rigged Case Nos. 72-CR-20-85, 72-CR-20-81, 72-CR-20-83 And 72-CR-20-172, Isn't It? It Is, Isn't It?
http://lionnews00.blogspot.com/2021/07/boles-files-complaint-against.html

Hartger Demands An Administrative Investigation And A Referral To LEO In Complaint Filed With First Judicial District Chief Judicial Officer Kathryn Davis Messerich? It's Still Rigged Case No. 19HA-CR-19-2768 State Of Minnesota Vs Jessica Danielle Hartger, Isn't it? Will Hartger File A Criminal Complaint Next? We'll Have To Wait And See, Won't We?
http://lionnews00.blogspot.com/2021/06/hartger-demands-administrative.html

More to come ...

Do You Remember That False Police Report (No True Threats, Right?) That Corrupt Dakota Co. Judicial Officer Ann Offerman Filed Against Jessica Hartger? AV20000915 Is Still Magically & Mysteriously An Open Case, Isn't It?

Backstabbing Public Pretender Scott Baker's Malicious Plot To Have Hartger Declared Incompetent Foiled By Complaint To Chief Judicial Officer Messerich? (Nemmers Was The Brains Behind That Strategy, Wasn't He?) Retaliation For Hartger Reporting Baker's & Shea's Sabotage Of Case No. 19HA-CR-19-2768 19AV-CR-19-11836 State Of Minnesota Vs Jessica Danielle Hartger To State Of Minnesota Board Of Public Defense Board Members Molly Jannetta Duchess Harris And Elizer Darris & Chief Administrator Kevin J. Kajer?

Nemmers' Chapter 13 Data Request Lands Smack Dab In The Middle Of Rigged Case No. 19HA-CR-19-2768 State Of Minnesota Vs Jessica Danielle Hartger As "09/17/2020 Correspondence Index # 115"? Did Corrupt Dakota Co. Judicial Officer Ann Offerman Get Upset About Nemmers Looking Into Her False Police Report Against Hartger?

Hartger Reports Her Backstabbing Public Defender Kevin Shea To State of Minnesota Board of Public Defense Board Members Molly Jannetta Duchess Harris And Elizer Darris For Sabotaging Case No. 19HA-CR-19-2768 19AV-CR-19-11836 State Of Minnesota Vs Jessica Danielle Hartger? Don't Forget That The Dakota County Attorney's Office And Lakeville Police Illegally Withheld Evidence In Both High-Profile Criminal Cases For Sandra Grazzini-Rucki (19HA-CR-15-2669) And Deirdre Elise Evavold (19HA-CR-15-4227), Okay?

Hartger Reports Her Backstabbing Public Defender Kevin Shea To His Boss State Of Minnesota Board Of Public Defense Chief Administrator Kevin J. Kajer For Sabotaging Case No. 19HA-CR-19-2768 19AV-CR-19-11836 State Of Minnesota Vs Jessica Danielle Hartger? Backstabbing Public Pretender Shea Was Dumb Enough To Reply, Wasn't He?

Oooops! Did Nemmers Wreck All The Rigged Cases For The Fugitive Defective Detective Jessica "The Conspiracy Theorist Who Cried Wolf" Hartger? Nemmers Tosses A Monkey Wrench Into These Rigged Case By Asking For Zoom Instructions? Magically & Mysteriously Hartger's Wrong Address Wiped From Register Of Actions For Rigged Case 19HA-CR-19-2768? Doesn't Corrupt Court Want To Issue A Warrant For Hartger In Colorado? Hey Look Did Corrupt Lakeville Chief Of Police Jeff Long Cough Up My Data? Long Really Hates Me, Doesn't He?

Hey How About We Ask Corrupt Dakota Co. Attorney Jimmy "Sovereign Citizen" Backstrom For Some Chapter 13 Data For The Fugitive Defective Detective Jessica "The Conspiracy Theorist Who Cried Wolf" Hartger? Oh And Let's Get An Update From The Corrupt City Of Burnsville On The Magically & Mysteriously Missing Hartger Data, Shall We?

Corrupt City Of Burnsville Continues To Harass Nemmers Over Jessica "The Conspiracy Theorist Who Cried Wolf" Hartger Data? You Remember That Jessica Is the Defective Detective, Don't You? Is The Motive For The Harassment Burnsville Officer/Detective Klingfus' Perjured Statement About "Imminent Harm"? Klingfus Wasn't Concerned About 04-11-20 "Imminent Harm" If The Complaint Wasn't Signed Until 10-17-20, Right? Isn't Cody Myers Using 609.26 Depriving Another Of Custodial Or Parental Rights To Bait Defective Detective Jessica Into A Violation Trap?

The Defective Detective Jessica "The Conspiracy Theorist Who Cried Wolf" Hartger Targets The Wrong Woman For Harassment? Defective Detective Hartger Almost Earns Another Criminal Harassment Complaint? Oh And All Eight (8) Dakota County Warrants Are All Still Active, Aren't They? Nemmers' Intervention Is Still Keeping Defective Detective Hartger Out Of Jail, Isn't It? UPDATE: Defective Detective Jessica Continues With Her Smear Campaign On Nemmers & Her Abused Husband? Did I Forget To Update You On The 11-05-20 Conspiracy Theory Free Zoom Hearing For 19HA-CR-19-2768?

How About We Request The Burnsville Data For The Warrant (19AV-CR-20-8547, Right?) For Jessica "The Conspiracy Theorist Who Cried Wolf" Hartger? Maybe Burnsville Personnel Can Explain How Fugitive Hartger Has Managed To Avoid Arrest For Eight (8) Active Warrants? We All Know The Real Reason Is The Intervention Of Nemmers, Don't We? We Do, Don't We?

How Is It Possible That Jessica "The Conspiracy Theorist Who Cried Wolf" Hartger Has Been Able To Avoid Arrest (Again, Right?) From 10-19-20 Until Today's Date? It's Because Of Nemmers' Intervention (Again, Right?), Isn't it? Let's Ask Hamline University For Some Of Hartger's Fugitve Data, Shall We? Bonus Round: Why Oh Why Does Ken Hartger's Estranged Wife Jessica Want To Sabotage Ken's Case No. 27-CR-20-4801? Did I Forget To Mention That Lakeville Police Have A Well-Documented History Of Stalking Fugitive Jessica Well Outside Their Jurisdiction? Let's Ask For The Zoom Meeting ID Number & Password For The 11-05-20 3:00 PM Remote Hearing For Case No. 19HA-CR-19-2768, Shall We?

Can You Guess Whose Big Stupid Mouth Earned Her Eight (8) Active Warrants For Her Arrest? Did You Guess Jessica "The Conspiracy Theorist Who Cried Wolf" Hartger? Maybe Jessica Shouldn't Have Spent All Her Time Running Smear Campaigns On Nemmers? Maybe Jessica Will Finally Get Help For Her Paranoia? Paranoia Induced By Daily Marijuana Use - Illicit Adderall Drug Use & Crazy Conspiracy Theories, Right? Bonus Round: Would You Like To See The Washington County Computer-Aided Dispatch Report & Incident Report (Redacted & Unredacted) For The Last Round Of Warrants For Jessica "The Conspiracy Theorist Who Cried Wolf" Hartger?

Whatever Happened To Nemmers' Data Request For The False Police Report Filed By Corrupt Dakota Co. Judicial Officer Ann Offerman Vs Jessica Hartger AKA Jessica Cook DOB: 01/15/1992? Will Hartger File A Counter-Criminal Complaint? Why The Continued Harassment Over Public Data For Corrupt Dakota County Judicial Officer Ann Offerman's False Police Report Against Jessica Hartger AKA Jessica Cook?

Hey Should We Debunk The Trumped Up Charges And The Rigged Case Against Jessica Hartger AKA Jessica Cook? It's Rigged Case Case No. 19HA-CR-19-2768, Isn't It? Watch For The Mystery Woman Who Magically & Mysteriously Stays At The Door, Okay? And Make Sure You See That Corrupt Lakeville Police Chief Jeff Long's Officers Make No Attempt To Verify Jessica's Alibi, Okay?

What Happens When The Person Who Claims To Want Help Can't Work The Plan But Can Only Run Her Big Stupid Mouth? The "Know-It-All-Know-Nothing" Gets Another Warrant Issued, Right? Did You Guess Jessica Hartger AKA Jessica Cook For Rigged Case No. 19HA-CR-19-2768?

Ken Hartger's Complaint To Judicial Officer Robben? City Of Eden Prairie’s & Prosecutor’s Willful Refusal To Comply With Mn Statute 13.82 & Dept. of Administration’s Advisory Opinion 18-005 In Regard To Subject Data AKA Criminal Investigative Data AKA Discovery For Case No. 27-CR-20-4801 State of Minnesota vs Kenneth John Hartger? How About We Ask Robben To Put His Crooked Officers Of The Court Under Oath In Regard To The Fraudulent $321.93 Bill? Hey Did You Know That Chief Judicial Officer Toddrick Barnette's Staff Member Charles Rooney Acknowledged Receipt Of Hartgers' Complaint?

Dare To Compare How Many Times Jessica Hartger Has Been Arrested Since Nemmers' Intervention As Opposed To The Incompetent Bungler Michael "The Hack" Volpe's Intervention? Hartger Has Been Arrested Zero Times In Rigged Case No. 19HA-CR-19-2768 By Dakota County's Corrupt LEO Since Nemmers' Intervention, Hasn't She?

Dakota Co. Creates An Intelligence Report On Jessica Hartger For Daring To Send Some Emails To Corrupt Dakota Co. Judicial Officer Offerman? Intelligence Report Admits That Hartger Did Absolutely Nothing Wrong, Doesn't It?

Why Oh Why Are Dakota County Communications Executive Director Tom Folie & Operations Director Cheryl Pritzlaff Trying To Steal $13.65 From Jessica Hartger? What Is The Status On The Transcripts?

Evidence Shows That Corrupt Dakota Co. Judicial Officer Offerman Conspired With Dakota Co. Assist. Co. Attorney Monnens & Apple Valley Det. Becker & Corrupt Dakota Co. Judicial Officer Knutson To File False Police Report & Subsequent Phony Arrest Warrant For Jessica Hartger? Eden Prairie Responsible Authority/City Clerk Kathleen Porta Refuses To Explain/Justify In Signed Document Fraudulent Retaliatory Bill Of $321.93 For Hartger Data? It Looks Like There Is A Huge Cover-Up For Eden Prairie Police Personnel Exacting Street Justice & Payback On Jessica Hartger For Dakota County Judicial Officers David Knutson & Ann Offerman, Right? Kenneth's & Jessica's Informed Consent Submissions Toss Monkey Wrenches Into Cover-Up?

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?

Tuesday, August 3, 2021

Transcripts For Case No 46-CV-19-1224 Goldmount Veterinary Center PA Vs Watonwan Co Animal Humane Society Not On The Register Of Actions But Hidden In Affidavit In Support Of The AHS’s Motion For A New Trial Or In The Alternative Remittitur? You Want To Read The Transcripts For The Testimony Of Pistol Packing AHS Humane Agent Keith Streff, Don't You? Did Anyone Ask Streff On The Witness Stand Why He Wasn't Trying To Impersonate A Peace Officer During The Trial? FYI: Did You Know That Streff Was Forced To Wear "Street Clothes" As A Result Of Nemmers' Complaint?

from: Lion News lionnews00@gmail.com
to: cathy.celander@courts.state.mn.us,
pierce@bevcomm.net
date: Aug 3, 2021, 8:14 AM
subject: Transcripts For Case No 46-CV-19-1224 Goldmount Veterinary Center PA Vs Watonwan Co Animal Humane Society Not On The Register Of Actions But Hidden In Affidavit In Support Of The AHS’s Motion For A New Trial Or In The Alternative Remittitur
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Cathy Celander, Court Administrator 507-238-3290 & Amy Yackley, Court Reporter Phone: 507-238-3283:

Why aren't the individual transcripts for Agent Keith Streff, Watonwan County Attorney Steven Lindee, Dr. Kittleson, Dr. Kathleen Jost, Dr. Martinson found on the Register of Actions for Case No 46-CV-19-1224 Goldmount Veterinary Center PA Vs Watonwan Co Animal Humane Society/ Why are those transcripts only exclusively found hidden in the Declaration Of Katherine B. Freitag In Support Of The Animal Humane Society’s Motion For A New Trial Or In The Alternative Remittitur for Case No. 46-CV-19-1224 Goldmount Veterinary Center, P.A. vs Watonwan County, Animal Humane Society? When are the transcripts going to be logged into the system for Case No 46-CV-19-1224? Or don't you want the public to have access to the original transcripts? Is the plan to make sure those transcripts are not accessible via the Minnesota Court Records Online (MCRO) website?

FYI: Did you know that a similar situation occurred in the high-profile criminal case for Nisswa Mayor Frederick Henry Heidmann? Did you know that was only resolved after the District Court Administrator and the MN Board on Judicial Standards were contacted? Did you guess that I contacted both the District Court Administrator and the MN Board on Judicial Standards?

Terry Dean, Nemmers 320-283-5713

State Of Minnesota County Of Hubbard ) ) ss ) Katherine B. Freitag, being first duly sworn upon oath, deposes and states as follows: 1. I am an attorney licensed to practice law in Minnesota, and I am the attorney of record for Defendant Animal Humane Society in this matter. 2. Attached hereto are true and correct copies of the following documents: Exhibit A. True and correct copies of trial transcript pages for Agent Keith Streff cited in AHS’s Memorandum in Support of Animal Humane Society’s Motion for a New Trial or in the Alternative Remittitu4 Exhibit B. True and correct copies of trial transcript pages for Steven Lindee cited in AHS’s Memorandum in Support of Animal Humane Society’s Motion for a New Trial or in the Alternative Remittitur Exhibit C. True and correct copies of trial transcript pages for Dr. Kittleson cited in AHS’s Memorandum in Support of Animal Humane Society’s Motion for a New Trial or in the Alternative Remittitur Exhibit D. True and correct copies of trial transcript pages for Dr. Kathleen Jost cited in AHS’s Memorandum in Support of Animal Humane Society’s Motion for a New Trial or in the Alternative Remittitur. Declaration Of Katherine B. Freitag In Support Of The Animal Humane Society’s Motion For A New Trial Or In The Alternative Remittitur for Case No. 46-CV-19-1224 Goldmount Veterinary Center, P.A. vs Watonwan County, Animal Humane Society

THE RECORD Testimony of Supervisory Humane Agent Keith Streff – Trial Transcript pp. 119-202, 303-367 Testimony of Watonwan County Attorney Steven Lindee – Trial Transcript pp. 187-206 Testimony of Dr. Kittleson – Trial Transcript pp. 211-273 Testimony of Dr. Kathleen Jost – Trial Transcript pp. 383-391 Testimony of Dr. Martinson – Trial Transcript pp. 392-406. Page 2. Memorandum Of Law In Support Of The Animal Humane Society’s Motion For A New Trial Or In The Alternative For Remittitur for Case No. 46-CV-19-1224 Goldmount Veterinary Center, P.A. vs Watonwan County, Animal Humane Society

Case No. 18-CR-20-2969 State of Minnesota vs Frederick Henry Heidmann
05/04/2021 Memorandum Index # 70
06/01/2021 Transcript Index # 77

Argument I. Procedural Failures The Defendant reincorporates his numerous pending motions with regard to the inadequacy of the complaint. The State failed to rebut or even make mention of the fact the Court ordered a formal complaint within 2 weeks to be served and filed by the State. To date, the State has conceded multiple times that their first bite at the apple was fatally flawed and failed to meet this ordered deadline; “The State, first of all, freely acknowledges that the December 28th, 2020, Complaint did contain procedural defects.” (Transcript P.12) C ASE N O . 18-CR-20-2969 State of Minnesota vs Frederick Henry Heidmann

More to come ...

Let's Ask Martin County Sheriff Markquart If Armed Minnesota Animal Humane Society Humane Agent Keith Streff Will Be Allowed To Impersonate A Peace Officer In His Jurisdiction, Shall We? Hey How About We Ask Watonwan County Sheriff Bergeman Why The Pistol Packing Streff Was Allowed To Impersonate A Peace Officer In His Jurisdiction? Will Streff Get Permission To Influence the Jury With His Pistol In The June 28, 2021 Through July 2, 2021 Trial for Court File 46-CV-19-1224 Goldmount Veterinary Center, P.A. Vs Watonwan County, Animal Humane Society?

Armed Minnesota Animal Humane Society Humane Agent Keith Streff Wearing A Firearm In Case No. 83-CR-18-513 State Of Minnesota Vs Michael Charles Johnson? Will AHS Agent Streff Show Up Armed At June 28‐June 30th, 2021 & July 1– July 2, 2021 Jury Trial for Court File 46-CV-19-1224 Goldmount Veterinary Center, P.A. Vs Watonwan County, Animal Humane Society? Has Streff Ever Been Accused Of Impersonating An Officer? Let's Ask AHS Attorney Freitag, Okay? Should We Tell The St. James Plaindealer & The Martin County Star Editors About Watonwan Co. Attorney Lindee's Illegal Withholding Of Public Data? Lindee Knows That The Chapter 13 Data Will Toss A Monkey Wrench Into 46-CV-19-1224, Doesn't He

Sunday, July 18, 2021

Boles Files Complaint Against Backstabbing Public Pretender Dillon With First Judicial District Chief Judicial Officer Messerich? Boy This Sounds Just Like Complaint Hartger Filed Against Her Backstabbing Public Pretenders Shea And Baker In Rigged Case No. 19HA-CR-19-2768, Doesn't It? It Rigged Case Nos. 72-CR-20-85, 72-CR-20-81, 72-CR-20-83 And 72-CR-20-172, Isn't It? It Is, Isn't It?

Kathryn Davis Messerich, Chief Judge 07-09-21
C/O: Brian Jones, District Court Administrator
1620 S. Frontage Road, Suite 200
Hastings, MN 55033

Mailed: USPS PS Form 3817 Certificate Of Mailing

RE: Public Defender John G. Dillon Conspiring With Prosecutor To Sabotage Case No. 72-CR-20-85, 72-CR-20-81, 72-CR-20-83 and 72-CR-20-172.

I have reason to suspect that I have clear, precise and unquestionable evidence that my court-appointed public defender John G. Dillon is conspiring with Sibley County Attorney David E. Schauer and Assistant County Attorney Donald Lannoye to sabotage my criminal case, Case No. 72-CR-20-85 State of Minnesota vs Jeremy James Boles. I understand from the public record that Jessica Hartger also filed
a similar complaint with you against (06/22/2021 Correspondence Index # 135 – Case No. 19HA-CR-19-2768 State of Minnesota vs Jessica Danielle Hartger) her public defenders John Shea [Note: The correct name is Kevin Shea] and Scott Baker. Apparently, the horrors that I have been maliciously subjected to are not an isolated incident in the First Judicial District.

In Jessica’s complaint to you she said that her case should have been dismissed two years ago. My criminal cases should have been dismissed over a year ago. My case is basically a contract dispute between myself and Anthony Cermak. The witnesses to this contract between myself and Anthony Cermak are Curt Ernest Cermak DOB: 04-03-82, Erica Stufflebeam DOB: 06-13-80 and a few others. As part of my evidence of a valid contact I have screenshots of Facebook Messenger conversations dated 10-07-19 2019 and 1016-19 between Cermak and myself. I also have a signed letter from Cermak to Xcel Energy dated 08-03-19. In my possession, I also have signed contract dated 08-01-19 between myself, Erica Stufflebeam and Cermak. Finally, I have an email Xcel Energy sent to Erica in
regard to her Xcel Account: 51-0012797210-6. See attached.

In order to counter this clear, precise and unquestionable evidence of a contract between myself and Cermark, Henderson Chief of Police Dmitri Ikonitski obtained sworn statements from Anthony Cermak. 1,2,3,4 In these sworn statements Cermak makes some wild, outrageous and unsubstantiated assertions that the contract is not valid. One of Cermark’s wild, outrageous and unsubstantiated
assertions is that his signature is forged. 5,6,7 Yet, my backstabbing public defender Dillon has willfully refused to get Chief Ikonitski on the witness stand at a contested omnibus hearing in order to ask him why the allegedly “forged” signature was not sent to the Minnesota Bureau of Criminal Apprehension for a forensic analysis. And my backstabbing public defender Dillon has also willfully refused to get Chief Ikonitski on the witness stand at a contested omnibus hearing to ask him why he never submitted an Administrative Subpoena for the Facebook Messenger accounts of Anthony Cermak and myself. It would appear that neither Dillon nor Ikonitski want to obtain any objective evidence that will undermine the credibility of the apparently perjured statements of Cermak.

At no time has Dillon made any attempt to interview the individuals who witnessed the signing of the contract nor subpoena them to a contested omnibus hearing. Not surprisingly, Henderson Chief of Police Dmitri Ikonitski has made no attempt to get an audio/video recorded witness statement from either Curt Cermak nor Erica Stufflebeam. Ikonitski did admit in a recorded statement with myself that he had spoken to Myron Micheal Cermak 8 DOB: 11-23-57. However, that audio recorded statement with Myron is currently being illegally withheld from me. In an attempt to sabotage my case, Dillon willfully refused to file a single motion for sanctions over the illegally withheld evidence in my case.

Page 1 of 15

It is my understanding that it is Sibley County Attorney David E. Schauer’s known mandatory, nondiscretionary, ministerial duty of the office to provide me with my Chapter 13.04 Subject Data aka Discovery with (10) ten days of my demand for the data. It is a matter of the public record that the demand for my Chaptter 13.04 Subject Data was made to Schauer on 07-10-20 (07/10/2020 Demand or Request for Discovery Index # 11). As of today’s date I have still not received the audio recorded statement of Myron Micheal Cermak. In fact, there is a vast amount of electronic data that is currently being illegally withheld from me.

I am aware that in the age of technology 10,11,12 that law enforcement officers in the course of their duties collect and retain body camera video, squad audio/video, personnel digital audio recorders audio files, digital images from digital cameras as evidence. In fact, I asked Dillon if there was any body camera video for my case. He stated that there was none. I have not received any squad/audio video for any of my cases. This is despite the fact that incident reports indicate Sibley County Sheriff’s deputies 13 were on the scene. When asked how it was possible for the Henderson police and Sibley County Sheriff’s office to not be running their squad audio/video in violation of their own policy and procedure manuals Dillon stated that he didn’t have the policy and procure manuals for either the Henderson police department or Sibley County Sheriff’s office. I recorded this conversation and many other conversations with Dillon. I recorded the conversation because I have memory problems after sustaining two (2) traumatic head injuries. I have reason to suspect that Dillon is trying to use my memory disability to his advantage and to my disadvantage.

There was no reason for me to believe Dillon when he said that he didn’t have the policy and procedure manuals 14,15 for local law enforcement. So in order to make some sense out of this crazy situation I decided to submit Chapter 13 Data Requests for the policies and procedures for the Henderson Police department, the Sibley County Sheriff’s office and the Sibley County Attorney’s Office. Instead of being kind courteous and helpful I was harassed by the City of Henderson and Sibley County. In fact, I never received a single policy and procedure manual from either the City of Henderson nor Sibley County. Instead, I was harassed with illegal demands to identify myself. 16,17,18 Also illegal threats were made that I would not have my Chapter 13 Data Requests processed unless I identified myself. No law requires me to identify myself nor requires to give a signature for public data. Plus, it is illegal to deny me public data because I refuse to identify myself. Henderson City Administrator Lon Berberich harassed me his wild, outrageous and unsubstantiated assertions that the provisions from the City of Henderson Charter were in fact that policy and procedure manual for the police. 19 Finally, I was also harassed with wild, outrageous and unsubstantiated assertions that my requests were too vague; that not all the data that I was requested was in electronic format and I was threaten with bills for the imaginary paper data. See attached. According to the law, Henderson City Administrator Lon Berberich’s, Sibley County Attorney David E. Schauer’s, Sibley Co. Sheriff Pat Nienaber’s and Sibley County Administrator John Glisczinski known mandatory, nondiscretionary, ministerial duty of the office or employment is to provide me with my Chapter 13.03 data. Obviously, the only person required to follow the law in Sibley County is Jeremy Boles.

This criminal misconduct helps to explain why a variety of readily available, electronic data is being illegally with from me in my criminal cases. One example would be the illegal withholding of the Global Positioning Systems (GPS) from the squads from the City of Henderson and Sibley County. The GPS data would show that both the City of Henderson and Sibley County knew or should have known that my home had was using electricity when they drove past on their patrols at night. The illegally withheld squad audio/video and/or body camera video would show what was said and done during the

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initial encounters with Henderson Chief of Police Dmitri Ikonitski. I have reason to suspect that Ikonitski has a vendetta against me for some strange reason. I do believe that Ikonitski is not following the facts but is instead manufacturing evidence in order to manufacture a case against me.20 And my backstabbing public defender Dillon is actively participating in the manufactured case by willfully refusing to presenting my evidence that proves that I am innocent. And one with eyes to see and ears to hear and a mind to understand come the logical conclusion that Dillon is misusing public resources to sabotage my criminal cases.

I believe that the plan of Dillon, Ikonitski, Schauer, Nienaber, Berberich, Glisczinski, Lannoye and even Judicial Officer Amber Donley is to either force me to plead guilty without ever receiving all my evidence or force me to at trial without ever receiving all my evidence. 20 After the ordeal that I have suffered through so far I have absolutely no faith that I will ever receive a fair trial in a Sibley county court. I demand that you do an administrative investigation & you refer this to law enforcement! 22
_____________________________________________________
Jeremy Boles
302 E. Clinton St.
Arlington MN 55307

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

Footnotes:
1. “My signature is obviously forged.” Voluntary Statement of Anthony James Cermak DOB: 05-31-96. ICR Numbers(s): 20000212 Date: 12-09-20 Place: Henderson Police Department. Witness: Alexander Schmidt #702.
2. “never paid me for rent and never paid any of the bills there” & “I wish to press criminal charges for trespassing on my property” Voluntary Statement of Anthony James Cermak DOB: 05-31-96. ICR Numbers(s): 20000212 Date: 03-19-20 Place: 600 Main St. Henderson, MN. Witness: Chief D. Ikonitski
3. “I did not give Jeremy Boles permission to enter my house.” & “I wish to press criminal charges against Jeremy Boles to breaking in my house.” Voluntary Statement of Anthony James Cermak DOB: 05-31-96. ICR Numbers(s): 20000212 Date: 03-22-20 Place: 600 Main St. Henderson, MN. Witness: Chief D. Ikonitski
4. Cermak said he wishes to press criminal charges against Jeremy Boles for trespassing on his property. Cermak provided a written voluntary statement, which is attached to this report. I then discussed this case with the City of Henderson Attorney, Alison Jones. The City Attorney agreed that with me that based on the information and statement provided by Anthony Cermak, the legal owner of the residence, Jeremy Boles had no legal rights to occupy residence at 208 South 3rd Street, and in fact was in violation on MN Statute 609.605, by trespassing on the premises of another without claim of right and refused to depart on demand of the lawful possessor. 19000130 – MN0720500 Supplemental
Report ICR: 20000212 Title: Last Modified: 03-22-2020 2355 Created By: Dimitri Ikonitski Henderson Police Department.

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5. Jeremy James Boles (02/01/1978) turned in information to Assistant Sibley County Public Defender John Dillon, who then turned the information over to Henderson City Attorney Jones provided several documents to the police department which included a copy of a lease agreement that indicates that it was signed by Anthony James Cermak (05/31/1996) as the property owner, and Boles and Erica Marie Stufflebeam (06/13/1980) as tenants to the property (208 S 3rd St) on 08/01/2019; an email from Excel Energy in regards to setting up an account dated on 09/24/2019; two hand written notes; and what appears to be a Facebook messenger conversation between Cermak and Boles. Attorney Jones asked that we follow up on the authenticity of the lease, if there was ever a termination of the lease, and if any rent was paid. I then contacted Cermak and asked if he would be willing to give another statement on the matter and he advised that he would. Cermak provided a written and recorded statement. See attached written statement. Supplemental Report ICR: 20000371 Title: 702 Report Last Modified: 12-14-2020 2017 Created By: Alex Schmidt Henderson Police Department.
6. I asked Cermak what his interpretation of these documents were, and he advised that this never happened and made a comment that his signature was forged Supplemental Report ICR: 20000371
Title: 702 Report Last Modified: 12-14-2020 2017 Created By: Alex Schmidt Henderson Police Department.
7. This report will be forwarded to the Sibley County Attorney's Office for review and possible charges in accordance to MN statute for aggravated forgery 609.625 subd. 1(1) against Jeremy Boles. Supplemental Report ICR: 20000371 Title: 702 Report Last Modified: 12-14-2020 2017 Created By: Alex Schmidt Henderson Police Department.
8. Well, I talked to grampa (Note: Myron Micheal Cermak DOB: 11-23-1957). 05-20-20 audio recorded statement of Jeremy Boles at Sibley County Jail ICR: 20000371 Dimitri Ikonitski, Police Chief Henderson Police Department. Boles Statement.MP3
9. 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
10. 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.
11. 418.5 Documenting BWC Use LEO's must document BWC use and non-use as follows: • Whenever an LEO makes a recording, the existence of the recording shall be documented in the LEO's report or CAD record/other documentation of the incident. • Whenever an LEO fails to record an incident that should be recorded under this poicy or captures only a part of the activity, the LEO must

Page 4 of 15

document the circumstances and reasons for not recording in the LEO's report or CAD record/other

documentation of the incident. Policy 418 Body Worn Cameras Policy Duluth Police Department Duluth PD Policy Manual https://dps.mn.gov/entity/post/model-policies-learning-objectives/
Documents/Professional-Conduct-of-Peace-Officers-Model-Policy.pdf
12. 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
https://duluthmn.gov/media/10847/release_20201208_t123452_duluth_pd_policy_manual-1.pdf
13. It should be noted that upon my arrival, Officer Schmidt with Henderson Police Department, and Sibley County Sheriff Deputies Daily and Johnson were also on scene. Officer Schmidt spoke to the reporting party, Monica Meyer, who confirmed that the two white males detained by police were in fact the same individuals who she had observed enter the residence at 208 S 3rd Street. 19000130 – MN0720500. Supplemental Report ICR: 20000371 Title: Last Modified: 12-07-2020 2113 Created By: Dimitri Ikonitski Henderson Police Department.
14. a. Exculpatory Evidence: Evidence is exculpatory if it tends to negate the defendant’s responsibility for the charged crime and is material to guilt or punishment. Brady v. Maryland, 373 U.S. 83, 87 (1963). Pine County Attorney’s Office Policies And Procedures Reese Frederickson, County Attorney
Title of Policy: Date Issued/Revised: I. Brady/Giglio Policy September 14, 2020 Pine County Attorney's Office Brady-Giglio Policy.pdf
15. Peace officers shall not knowingly disobey the law or rules of criminal procedure in such areas as interrogation, arrest, detention, searches, seizures, use of informants, and preservation of evidence, except where permitted in the performance of duty under proper authority. ... Peace officers shall not knowingly make false accusations of any criminal, ordinance, traffic or other law violation. This provision shall not prohibit the use of deception during criminal investigations or interrogations as permitted under law. Peace officers shall truthfully, completely, and impartially report, testify and present evidence, including exculpatory evidence, in all matters of an official nature. Professional Conduct Of Peace Officers Model Policy Mn Stat 626.8457 https://dps.mn.gov/entity/post/model-policies-learning-objectives/Documents/Professional-Conduct-of-Peace-Officers-Model-Policy.pdf
16. 13.03 Access To Government Data. Subd. 12. Identification or justification. Unless specifically authorized by statute, government entities may not require persons to identify themselves, state a reason for, or justify a request to gain access to public government data. A person may be asked to provide certain identifying or clarifying information for the sole purpose of facilitating access to the data. https://www.revisor.mn.gov/statutes/cite/13.05
17. Part 2: Set Parameters for Data Requests The Data Practices Act does not require that individuals make data requests in writing; however, DPO recommends that government entities make this their policy. If you decide to require written requests, you must include it in your Data Practices Policy (see Advisory Opinion 01-014). Worksheet for Developing Data Practices Policies & Procedures https://mn.gov/admin/assets/accesspolworksheet2017_tcm36-309302.docx
18. Opinion: Based on the facts and information provided, my opinion on the issue that X raised is as follows: Pursuant to Minnesota Statutes, section 13.05, subdivision 12, when an individual requests access to public data, it is not appropriate for the Minnesota Department of Labor and Industry (DLI) to ask a data requestor to identify him/herself and to justify the request. Signed: David F. Fisher Commissioner Dated: January 16, 2001 Advisory Opinion 01-014 January 16, 2001; Minnesota Department of Labor and Industry January 16, 2001 | Requests for data https://mn.gov/admin/data-practices/opinions/library/#/detail/appId/1/id/267444

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19. 204.03. Duties Of Police: Members of the police department shall enforce the ordinances and laws applicable to the city, bring violators before the county court, and make complaints for offenses coming to their knowledge. Members of the police department shall serve processes on behalf of the city and shall serve notices as may be required by the council or other authorities. Chapter Ii: Operations And Administration Part Iv. Police Department chapter_2.pdf
http://www.henderson-mn.com/uploads/1/1/0/4/11043847/chapter_2.pdf
20. I recognized one white male from the previous contacts as Jeremy James Boles. In March of 2020, Boles was arrested at the same location for Second Degree Burglary, First Degree Criminal Damage to Property, Fifth Degree Possession of Controlled Substance(methamphetamine) along with other
charges. I was also aware of Boles' conditions of release, disseminated on a regular basis via e-mail by the Sibley County Attorney's Office. One of Bole's conditions of release states as following: "Prohibited from 208 South 3rd Street, Henderson, MN 56044. May retrieve personal property with the assistance of law enforcement." Boles did not contact any law enforcement agency in reference to
getting his personal property prior on the day of the incident. 19000130 – MN0720500. Supplemental Report ICR: 20000371 Title: Last Modified: 12-07-2020 2113 Created By: Dimitri Ikonitski Henderson
Police Department.
21. “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 20. 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.
22. 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

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Form 2817 PS Certificate of Mailing

More to come ...

Tuesday, July 13, 2021

Hey Did You Know That Nemmers Is Famous? Maybe You Want To Attend The 08-02-21 Zoom Hearing At 1:00PM For Rigged Case No. 19HA-CV-18-905 To Find Out How Nemmers (Actually Misspelled In Paperwork As "Nemers" Right?) Is Famous? Psst It Has To Do With A Protective Order, Doesn't It? Oh And Michael "The Hack" Volpe's Name Isn't Even Mentioned, Is It? Funny, That The Hack Volpe Never Attended The Zoom Hearings That Nemmers Attended, Isn't It? Maybe Sandra Grazzini-Rucki Will Finally Attend A Hearing?

Filed in District Court
State of Minnesota
7/12/2021
District Court
First Judicial District
Court File Number: 19HA-CV-18-905
Case Type: Civil Other/Misc.
State of Minnesota
Dakota County
Notice of Remote Zoom Hearing
FILE COPY
State Farm Fire and Casualty Company vs David V. Rucki, Samantha Rucki, Gianna Rucki, Sandra Sue Grazzini-Rucki, Deirdre Elise Evavold et. al

You are notified this matter is set for a remote hearing. This hearing will not be in person at the courthouse. Hearing Information August 02, 2021 Hearing 1:00 PM

The hearing will be held via Zoom and appearance shall be by video and audio unless otherwise directed with Judicial Officer Jeroe B. Abrams, Dakota County District Court. The Minnesota Judicial Branch uses strict security controls for all remote technology when conducting remote hearings.

You must: Notify the court if your address, email, or phone number changes.
Be fully prepared for the remote hearing. If you have exhibits you want the court to see, you must give them to the court before the hearing. Visit www.mncourts.gov/Remote-Hearings for more information and options for joining remote hearings, including how to submit exhibits.
Contact the court at 651-438-8100 if you do not have access to the internet, or are unable to connect by video and audio.

To join by internet:
1. Type https://zoomgov.com/join in your browser’s address bar.
2. Enter the Meeting ID and Meeting Passcode (if asked):
Meeting ID: 161 549 6681
Passcode: 046841
3. Update your name by clicking on your profile picture. lf you are representing a party,
add your role to your name, for example, John Smith, Attorney for Defendant.
4. Click the Join Audio icon in the lower left-hand corner of your screen.

MNCIS—PAN-104 STATE Notice of Remote Zoom Hearing 4/21

5. Click Share Video.

To join by telephone (if you are unable to join by internet):
Be sure you know how to mute your phone when you are not speaking and unmute it again to speak.
1. Call Toll-Free: 1-833-568-8864
2. Enter the Meeting ID and Meeting Passcode:
Meeting ID: 161 549 6681
Passcode: 046841
Para obtener ma’s informacién y conocer Ias opciones para participar en audiencias remotas, incluido cémo enviar pruebas, visite www.mncourts.gov/Remote-Hearings.
Booqo www.mncourts.gov/Remote-Hearings oo ka eego faahfaahin iyo siyaabaha aad uga
qeybgeli karto dacwad-dhageysi ah fogaan-arag, iyo sida aad u soo gudbineyso wixii caddeymo
ah.
Dated: July 12, 2021

Maria King
Dakota County Court Administrator
1560 Highway 55
Hastings MN 55033
651-438-8100

cc: Sandra Sue Grazzini-rucki
Deirdre Elise Evavold
Destiny Equine Intervention
Gina Schmit Dahlen
Douglas Dahlen
Destiny Church
Steven Quernemoen
Trish Quernemoen
C Todd Koebele
Dawn L Gagne

STATE OF MINNESOTA
DISTRICT COURT
COUNTY OF DAKOTA
FIRST JUDICIAL DISTRICT
Type of Case: Civil Other/Misc.

Court File No. 19-HA-CV-18-905
Judge Jerome B. Abrams

JOINT NOTICE OF MOTION AND MOTION FOR PROTECTIVE ORDER AND ORDER

State Farm Fire & Casualty Company, Plaintiff,

David V. Rucki; Samantha Rucki; Gianna Rucki; Sandra Sue Grazzini-Rucki; Deirdre Elise Evavold; Destiny Equine Intervention d/b/a White Horse Ranch, a Minnesota Nonprofit Corporation; Gina Schmit Dahlen; Douglas Dahlen; Destiny Church; Steve Quernemoen and Trish Quernemoen, Defendants.

TO: DEFENDANT DEIRDRE ELISE EVAVOLD, pro se.

NOTICE OF MOTION

PLEASE TAKE NOTICE that Plaintiff State Farm Fire & Casualty Company
(“State Farm”) will bring the following motion for hearing before the Honorable
Jerome B. Abrams, Dakota County District Court, on August 2, 2021 at 1:00 p.m. or as soon thereafter as counsel may be heard, via Zoom.

MOTION
Plaintiff State Farm Fire and Casualty Company and Defendants David V. Rucki,
Samantha Rucki, and Gianna Rucki jointly move the Court pursuant to Minnesota
General Rule of Practice 11.04 for leave to file the Partial Settlement Agreement and Meadowbrook Release between State Farm Fire and Casualty Company and
1

Defendants David V. Rucki, Samantha Rucki, and Gianna Rucki under seal, consistent with the terms outlined below.

The above-entitled matter came before the Honorable Jerome B. Abrams, Judge
of District Court, on June 8, 2021 on Plaintiff State Farm Fire and Casualty Company’s Motion to Dismiss. The Court granted the motion and ordered entry of judgment of dismissal on June 21, 2021 consistent with the confidential settlement of any claims David Rucki, Gianna, Rucki, and Samantha Rucki asserted against Deirdre Evavold which are, or arguably are, covered under the Homeowner’s Policy and PLUP issued by State Farm Fire and Casualty Company, consistent with Meadowbrook, Inc. v. Tower Ins. Co., 559 N.W.2d 411, 417 (Minn. 1997).

The Court’s Findings and Order for Dismissal With Prejudice are incorporated herein by reference. Because the settlement agreement is confidential, State Farm Fire and Casualty Company, David Rucki, Samantha Rucki, and Gianna Rucki (“Stipulating Parties”) now stipulate and jointly move that the Court enter a Protective Order that the Partial Settlement Agreement and Meadowbrook Release be filed with the Court under seal, confidentially, and that it remain confidential and not disclosed to the public, parties or counsel in this matter except as set forth in the Court’s Order. David Rucki, Samantha Rucki, and Gianna Rucki further request that they be permitted to file Partial Satisfactions of Judgment under seal, confidentially, and that they remain confidential and not disclosed to the public, parties or counsel in this matter except as set forth in
the Court’s Order.

Settlement agreements are historically private and there is no first amendment
right of access to settlement documents sealed by the court. Minneapolis Star & Trib.
2

Co. v. Schumacher, 392 N.W.2d 197, 204 (Minn. 1986). Public policy favors settlement of disputed claims without litigation; “[t]o allow public access to settlement documents filed with a court may circumvent this policy.” Id. at 205 (citations omitted). The privacy interests of litigants may justify restricting access to settlement documents. Id. at 206.

Courts have discretion to permit filing settlement documents under seal and to restrict access to them. See id.

Good cause exists to file the Partial Settlement Agreement and Meadowbrook Release under seal. The litigation involving David V. Rucki, Samantha Rucki, and Gianna Rucki has been the subject of media coverage as well as blog and other internet posts. As this Court found at pages 8-12 in its Findings of Fact, Conclusions of Law, and Order for Judgment in Court File 19-HA-CV-18-4286, Defendant Evavold has a history of using her blog to post about David Rucki. Terry Nemers, who identified himself as a member of the press, attended the hearing on the Motion to Dismiss this action. [Note: Nemmers never saw either Michael "The Hack" Volpe or Sandra "The Perjurer" Grazzini-Rucki at a single Zoom hearing he attended, did he?] David V. Rucki, Samantha Rucki, and Gianna Rucki as well as State Farm Fire and Casualty Company have strong interests in maintaining the terms of the settlement agreement as confidential, and there is a real risk that the terms would not be kept confidential if the agreement is not filed under seal. Ms. Evavold requested State Farm Fire and Casualty Company advise her of the amount of the settlement. Filing the agreement under seal would permit her to view the document, while also requiring it to be kept strictly confidential under the terms of the Court’s Order.

Balancing the interests of all potentially interested parties, this Court should permit David V. Rucki, Samantha Rucki, and Gianna Rucki and State Farm Fire and Casualty Company to file the Partial Settlement Agreement and Meadowbrook Release under seal.
3

State Farm Fire and Casualty Company and Defendants David V. Rucki,
Samantha Rucki, and Gianna Rucki therefore request the Court enter a Protective
Order with the following terms:

1. That the motion of the Stipulating Parties is granted. State Farm Fire and
Casualty Company shall submit to the Court an executed copy of the Partial Settlement Agreement and Meadowbrook Release to remain confidential with the heading, “CONFIDENTIAL – NOT TO BE DISCLOSED TO THE PUBLIC, THE PARTIES, OR OPPOSING COUNSEL WITHOUT COURT ORDER.”

2. Any party or opposing counsel wishing to review the confidential documents, shall arrange to view the confidential documents at the Dakota County
Court House located in Hastings, Minnesota, conditioned on the following:
a. A party or opposing counsel may not make copies of confidential documents subject to this Order.
b. A party or opposing counsel may not have any electronics on his or her person when viewing any confidential documents subject to this Order.
c. A party or opposing counsel may take handwritten notes about the documents.
d. A sheriff’s deputy shall be present at the viewing.
e. The viewing shall be on a Monday or a Friday and at a date and time acceptable to court administration.
f. No third parties shall be allowed with a party or opposing counsel when reviewing the documents.
g. The terms of the document shall remain strictly confidential and shall not be shared or disclosed with any other person or entity, nor shall they be published in any fashion. Disclosure or publication of any details of the settlement, including the amount, shall subject the person violating this Order to penalties for contempt of court.
4

h. David Rucki, Samantha Rucki, and Gianna Rucki acknowledge receipt of the amounts identified in the Confidential Partial Settlement Agreement and Meadowbrook Release and agree that the judgments against Deirdre Evavold are partially satisfied in the amounts identified in the Confidential Partial Settlement Agreement and Meadowbrook Release. They shall file Partial Satisfactions of
Judgment in the underlying matter, confidentially, consistent with the Order Regarding Confidential Documents in effect in Court File 19-HA-CV-18-4286.

3.That Dakota County Court Administration shall file the documents according to the policies allowing for CONFIDENTAL materials accessible only to specific court employees.
5

Dated: July 12, 2021 HKM, P.A.
/s/ Kathleen Curtis
C. Todd Koebele, #1728X
William L. Moran, #177167
Kathleen K. Curtis, #388279
30 East Seventh Street, Suite 3200
St. Paul, MN 55101-4919
Telephone: (651) 227-9411
Fax: (651) 223-5199
tkoebele@hkmlawgroup.com
wmoran@hkmlawgroup.com
kcurtis@hkmlawgroup.com
Attorneys for Plaintiff State Farm Fire and Casualty Company
Dated: July 12, 2021

ELLIOTT LAW OFFICES, P.A.
/s/ Lisa M. Elliott
Lisa M. Elliott, #201923
Dawn L. Gagne, #158550
2409 West 66th Street
Minneapolis, MN 55423
Telephone: (612) 861-3000
lisa@elliottlaw.net
dawn@elliottlaw.net
Attorneys for Defendants David V. Rucki, Samantha Rucki and Gianna Rucki

4811-9739-8513, v. 1
6

Bonus Material - Did you know that the judicial officer just delete email from Michael "The Hack" Volpe?

THE COURT: Now, I also want the record to reflect that I keep getting contacted by an individual who just – I think his first name is Michael. I don't know -- I am constantly -- I'm constantly deleting emails from some fellow. I don't know if you're getting those contacts as well, Miss Elliot. I think he's a person that's left over from that kind of prior unhappy litany of passel of cases involving Miss Grazzini-Rucki, Miss Evavold, and others in their community. And I've had that fellow send me a note. Somebody told me that his position was that this case was canceled for today and obviously, I had never done that. So have you any communications with anyone whether it's Miss Evavold or anyone else about this trial going forward today?

MS. ELLIOT: The only issue or communication I got is I received that same email from -- his name is Mr. Michael Volpe, V-O-L-P-E, and yes, he lives in Chicago and he seems to have taken -- this case has taken on a life of its own in his world. And I think are now on his service list along with 50 other people, and I am included on that. Any time anything happens to anybody in this world, including Deirdre Evavold or Sandra Grazzini-Rucki or any of the other players, he gets wind of it and posts and sent -- he does interviews and then sends that information all out to everybody. My impression is that Miss Evavold is still in close contact with Mr. Volpe and any time something is filed in this case, she immediately forwards it to him. He received within minutes copies or our Plaintiff's exhibit lists, and I know he sent out one of his mass emails about those. And -- but no, I have no knowledge of this hearing being canceled.

THE COURT: Yeah. I'm am only raising that because as far as I know, that the normal process has been followed -- and in a minute, I'm going to have court staff confirm this -- that the normal process has been followed in connection with providing notice of today's events. That is, today's hearing, today's court trial via Zoom to those persons who have previously been served with process and remain parties to this case and that there's no irregularity to any process in place. Miss Klein, is that in fact the case?

THE CLERK: Yep. I'm just verifying. But yes, that appears to be the case.

THE COURT: Notice has been served to Miss Evavold of today's proceeding?

THE CLERK: Yes. It's just shows Grazzini was not able to be, yes.

THE COURT: Okay. So that's fine. All right. So I think -- thank you very much. I'm sorry to put you on the spot with all of that. In any event, so Miss Elliot, I guess my point is that again, in connection with certain cases, it's taken me, you know, a long time in this job to recognize that sometimes more thorough records of procedural matters need to be made in certain cases than in others. And this case
given its history, seems to be one of those. So there you have it. That's why I went through that elaborate kind of process of sort of setting the table as it were over the last ten minutes or so. So why don't you explain to the Court for the benefit of the record, how it is you wish to proceed. The above-entitled matter came duly on for hearing before the Honorable Jerome B. Abrams, one of the judges of the above-named Court, on the 7th day of December, 2020 Court File No. 19HA-CV-18-4286 David Rucki, et al., Plaintiffs, vs. Sandra Grazzini-Rucki, et al., Defendants.

More to come ...

Friday, July 9, 2021

Illegally Withheld Body Camera Video & Squad Audio Videos For Officer Nathaniel Larson Finally Released To Judd Hoff? It's Still Rigged Case No. 21-Cr-20-1255 State Of Minnesota Vs Judd Bradford Hoff, Isn't It? Motive = Videos Shows Damning Evidence That Incriminates Mentally Unstable Pistol Packing Eric Cornett? Hoff's Infantile Understanding Of Law And The World Will Get Him Convicted, Won't It? Oh And Illegally Withheld Video From Rigged Case No. 21-CR-20-1351 Is Finally Released, Also? FYI: Nemmers Dumped Ingrate Hoff After Making Sure Hoff Obtained A Variety Of Missing Evidence, Didn't He? Nemmers Was Tired Of Hoff's Infantile BS, Wasn't He?

21-CR-20-1255 Filed in District Court State of Minnesota 7/9/2021 11:33 AM
Chad M. Larson, Douglas County Attorney
Daniel C. Lee, Assistant County Attorney
Timothy S. Hochsprung, Assistant County Attorney
Ezra P. Hartsell, Assistant County Attorney
Rachel E. Pence, Assistant County Attorney
Tara J. Ulmaniec, Assistant County Attorney
Douglas L. Whiting, Investigator
Deb Joachim, Office Manager
Ginny Aanenson, Legal Assistant
JoAnna Meduna, Legal Assistant
Mandy Leesch, Legal Assistant
Amanda Blascyk, Legal Assistant

DOUGLAS COUNTY ATTORNEY
305 8 TH AVENUE WEST
ALEXANDRIA, MN 56308
Phone: (320) 762-3856
Fax: (320) 762-3860

July 9, 2021

Rebecca C. Marsnik & Lucien A. Cravens, Jr.
Seventh District Public Defender's Office - Fergus Falls
309 South Mill Street, Suite #101
P.O. Box 816
Fergus Falls, MN 56537
Re: State v. Judd Bradford Hoff
Court File Number: 21-CR-20-1255

Dear Ms. Marsnik and Mr. Cravens:
Enclosed, please find the following additional disclosure items:

I. State's disclosure regarding Alexandria Police Department ICR Number: 20010388: C. Body-Cam Videos: - 1 body-cam video and 2 squad-cam videos received from Officer Nathaniel Larson.

Best regards,
Tara J. Ulmaniec
Assistant County Attorney
TJU/jm
Enclosures
c: Court Administrator (letter, 7.01, 9.01, and request only)
WARNING DISTRIBUTION PROHIBITED: Pursuant to Rule 9.03, Subd. 4, Minn. Rules Crim. Proc., Rule 10.06, Subd. 4, Minn. Rules Juv. Crt.,
and Chapter 13, Minn. Statutes.
Page 1 of 1

21-CR-20-1351 Filed in District Court State of Minnesota 7/9/2021 9:54 AM
Chad M. Larson, Douglas County Attorney
Daniel C. Lee, Assistant County Attorney
Timothy S. Hochsprung, Assistant County Attorney
Ezra P. Hartsell, Assistant County Attorney
Rachel E. Pence, Assistant County Attorney
Tara J. Ulmaniec, Assistant County Attorney
Douglas L. Whiting, Investigator
Deb Joachim, Office Manager
Ginny Aanenson, Legal Assistant
JoAnna Meduna, Legal Assistant
Mandy Leesch, Legal Assistant
Amanda Blascyk, Legal Assistant

DOUGLAS COUNTY ATTORNEY
305 8 TH AVENUE WEST
ALEXANDRIA, MN 56308
Phone: (320) 762-3856
Fax: (320) 762-3860

July 8, 2021

Rebecca C. Marsnik
Seventh District Public Defender's Office - Fergus Falls
309 South Mill Street, Suite #101
P.O. Box 816
Fergus Falls, MN 56537
Re: State v. Judd Bradford Hoff
Court File Number: 21-CR-20-1351
Douglas County Attorney’s File Number: 20-1406

Dear Ms. Marsnik:
Enclosed and hereby served upon you as additional disclosure in the above-entitled matter, please find:
I. State's disclosure regarding Alexandria Police Department ICR Number: 20011192:
A. Reports & Misc. Docs:
6. APD Supplemental Report drafted by Sergeant Brian Kakach on 1/5/21 (1 page);
7. APD Supplemental Report drafted by Officer Elliott Draz on 7/2/2021 (1 page).
C. Body and Squad-Cam Videos:
- 2 body-cam videos received from Sergeant Brian Kakach;
- 1 body-cam video received from Officer Elliott Draz.

Best regards,
Tara J. Ulmaniec
Assistant County Attorney
Enclosures
c: Court Administrator (letter only)
WARNING DISTRIBUTION PROHIBITED: Pursuant to Rule 9.03, Subd. 4, Minn. Rules Crim. Proc., Rule 10.06, Subd. 4, Minn. Rules Juv. Crt.,
and Chapter 13, Minn. Statutes.
Page 1 of 1

Case No. 21-CR-20-1255 State of Minnesota vs Judd Bradford Hoff
09/30/2020 Discovery Disclosure Index # 18
10/14/2020 Discovery Disclosure Index # 21
07/09/2021 Discovery Disclosure Index # 29
08/12/2021 Pre-trial (9:00 AM) (Judicial Officer Clark, Michelle L.)
08/23/2021 Jury Trial (9:00 AM) (Judicial Officer Clark, Michelle L.) 08/23/2021, 08/24/2021, 08/25/2021, 08/26/2021, 08/27/2021

Case No. 21-CR-20-1351 State of Minnesota vs Judd Bradford Hoff
09/30/2020 Discovery Disclosure Index # 14
07/09/2021 Discovery Disclosure Index # 25
07/09/2021 e-Service Hoff, Judd Bradford Served 07/09/2021
07/09/2021 e-Service Hoff, Judd Bradford Served 07/09/2021
08/12/2021 Pre-trial (9:00 AM) (Judicial Officer Clark, Michelle L.)
08/23/2021 Jury Trial (9:00 AM) (Judicial Officer Clark, Michelle L.)
08/23/2021, 08/24/2021, 08/25/2021, 08/26/2021, 08/27/2021

https://www.revisor.mn.gov/statutes/cite/13.04 13.04 Rights Of Subjects Of Data. Subd. 3. Access to data by individual. Upon request to a responsible authority or designee, 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.

More to come ...

"Customers" - Defendants - Members Of Public - Members Of Media AKA Press Denied Access To Zoom Technology For Rigged Case Nos. 21-CR-20-1351 21-CR-20-1255 21-CR-20-896 State Of Minnesota Vs Judd Bradford Hoff? Why Does Corrupt Judicial Officer Michelle L. Clark Hate Her "Customers" Members Of The Public And The Press?

Why Is Nemmers Of Lion News Being Booted From Rigged Case No. 13-CR-19-987 State Of Minnesota Vs Luke Eugene Koslowski By Corrupt Judicial Officer Catherine Trevino's Court Staff? Corrupt Trevino Hates The Media, Doesn't She? FYI: The Corrupt MN State Court Acknowledged Nemmers As Media Back On April 17, 2014, Didn't They?

What Does West Central MN Drug & Violent Crime Task Force Special Agent Shawn Schmidt Have To Say About The Incident Involving Poor Judd Hoff & The Mentally Unstable Gunslinging Stalker Eric Cornett? Where Oh Where Are The Body Camera Videos For Schmidt & Douglas Co. Deputy Berle? The Truth Is Stranger Than Fiction Section: Did You Know That Poor Judd’s Public Defender (Pretender, Right?) Rebecca Marsnik Brags On Twitter About Not Wearing Underwear To Work? Yeah, It's Still Rigged Case No. 21-CR-20-1255, Isn't It?

Gunslinger Eric Cornett Says: "3 Of The Officers Thanked Me For It"? 3 Officers Thanked The Mentally Unstable Gunslinger Cornett For Pulling A Concealed Pistol In Order To Steal Judd Hoff's Flag? Why Oh Why Is The Body Camera Video For APD Officer Nathaniel Larson #102 Being Illegally Withheld From Poor Judd? Does Larson's Body Camera Video Contain The Damning Officer's Praise Of Gunslinger Cornett's Armed Theft Of Poor Judd's Property? It's Still Rigged Case No. 21-CR-20-1255, Isn't It?

No Sound On APD Sgt Kevin Guenther's Body Camera Video During Voluntary Statement For Gunslinger Eric Cornett? Why Oh Why Wasn't Poor Judd Hoff Given The Body Camera Video From APD Nathaniel Larson #102? (It Supposedly Contains Gunslinger Cornett's Audio/Video Statement, Right?) Why Oh Why Would Douglas Co. Sheriff Troy Wolberson Issue Gunslinger Cornett A Concealed Carry Permit When Gunslinger Cornett Has An Admitted History Of Mental Health Problems? It's Rigged Case No. 21-CR-20-1255, Isn't it?