Documents

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

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

Plaintiff Filings

14 documents

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

Document Date Type Court PDF
Amended Petition

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

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

— Pleading D. Minn. PDF
Declaration of Plaintiff

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

 — Declaration D. Minn. PDF
Motion for Preliminary Injunction

Motion seeking injunctive relief pending resolution of the federal action.

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

Legal argument with authorities for the Preliminary Injunction motion.

 — Memorandum D. Minn. PDF
Proposed Order

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

 — Proposed Order D. Minn. PDF
Motion for Default Judgment

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

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

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

re: mason

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

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

re: bacon

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

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

re: kletscher, bgs, manderfeld

Sep 2025 Opposition D. Minn. PDF
Surreply

Additional brief addressing new arguments raised in defendants' replies.

 Sep 2025 Surreply D. Minn. PDF
Notice of Altered Documents

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

 — Notice D. Minn. PDF
Notice of Irregularities

Notice cataloguing procedural irregularities in the state-court record.

 — Notice D. Minn. PDF
Notice of Obstruction

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

re: starr, upton

— Notice D. Minn. PDF
Notice of Document Laundering

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

 — Notice D. Minn. PDF

Defense Counsel Filings

6 documents

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

Document Date Type Court PDF
Mason — Notice of Appearance

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

re: mason

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

AGO's MTD on behalf of the judicial defendants.

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

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

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

re: bacon

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

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

re: bacon, rueger, upton, rcso

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

BGS shareholder Kletscher enters on behalf of BGS and Manderfeld.

re: kletscher, bgs, manderfeld

Sep 2025 NOA D. Minn. PDF
Manderfeld — Motion for Contempt

Motion containing uncensored explicit material; accepted onto the docket despite content.

re: manderfeld, lee, starr

2025-11-10 Motion Ramsey Co. PDF

Court Orders

3 documents

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

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

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

re: starr, lee

2025-08-19 Order Ramsey Co. PDF
Order Denying Motion to Intervene

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

 Nov 2025 Order MN App. PDF
Order Denying Stay

Minnesota Court of Appeals order denying stay pending appellate review.

 Nov 2025 Order MN App. PDF

Administrative Determinations

1 documents

Disciplinary and oversight body decisions.

Document Date Type Court PDF
LPRB Determination

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

 — Determination LPRB PDF

Cross-Case Exhibits

3 documents

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

Document Date Type Court PDF
Wright — Public MCRO (62-CR-22-5111)

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

re: bacon

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

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

re: bacon

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

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

 Nov 2025 Pleading D. Minn. PDF