Scope of Federal Discovery – Strickland v. Ramsey County, et al.

View PDF

This section outlines Plaintiff's formal scope of discovery across all defendants and agents named in Strickland v. Ramsey County, et al. The following categories reflect Plaintiff's request for unredacted, complete records and metadata essential to proving systemic misconduct, ADA suppression, due process violations, and evidentiary laundering.

I. Digital Systems, Software, & Automation

eFiling / Case Management: Complete audit logs, rejection metadata, and revision trails from MNCIS, Tyler Tech’s eFile & Serve system, and any related case management infrastructure. Discovery includes logs of all submission attempts under Plaintiff’s names or aliases, internal rejection reasons, administrative overrides, and records of any altered access permissions or rejection flags.
Administrative Overrides and Gatekeeping: Documentation of all instances where clerks or court administrators used Tyler Tech’s backend controls to accept, reject, reclassify, or silently suppress filings. Includes any actions that removed user access to the payment portal, bypassed required judicial orders, or otherwise substituted administrative discretion for judicial review.
Automated and Rule-Based Decisions: Discovery into automated flagging systems, scripts, or business logic within Tyler Tech’s eFile system that trigger dismissals, delays, or altered routing of filings from pro se litigants or those with ADA disclosures. Includes administrative override rules and thresholds for manual interventions.
System Audit Trails: All back-end action logs showing who accessed, altered, rejected, or delayed Plaintiff’s filings — with timestamps, user roles, session data, and authorization trails. Includes undo privileges, attempted resubmissions, and post-rejection communications or system flags not visible to the Plaintiff.

II. Communications & Internal Correspondence

All internal communications (email, Slack, Microsoft Teams, call logs, texts, memos, or handwritten notes) from June 1, 2024 onward referencing Plaintiff, her aliases, ADA status, litigation status, or online activity.
Any communications referencing or discussing Plaintiff’s public identity as a content creator — including references to “Onion Madder,” “Onionanne,” “Sundar,” “Madsundar,” or any other names, accounts, or platforms connected to Plaintiff’s creative work, websites, or digital presence — whether these names were obtained from court records, social media, or third parties including Madeline Lee or her associates.
Any messages discussing or referencing Plaintiff’s social media accounts or online legal archive, including reviews, monitoring, printing, or incorporation of those materials into decision-making processes by court staff, referees, or Ramsey County personnel.
All communications involving or between the following individuals or offices: Rueger, Clysdale, Larmouth, Rossow, Elsmore, Upton, Loya, Thurmes, Olmstead, Bridges to Safety personnel, and any District Judges who were assigned to or removed from Plaintiff’s case at any stage.
Any discussion of Madeline Lee or her social media presence, aliases, or communications involving Plaintiff, including any statements made by Madeline or her affiliates that influenced court conduct, filing decisions, or ADA accommodations.
All correspondence reflecting mocking, bias, flagging, or retaliation related to Plaintiff’s disability status, gender presentation, name, or content-creator status — including informal commentary, forwarded posts, screenshots, or reactions within court personnel channels.
All communications evidencing or suggesting any coordination, collaboration, or information-sharing between Ramsey County officials (including referees, court administration, or judicial officers) and private entities or individuals including Barna, Guzy & Steffen LLP, Kyle Manderfeld, Ryan Bacon, or any District Judge who has entered or exited the case. This includes but is not limited to: coordination on litigation strategy, narrative framing, discretionary filings, delays, or off-docket communication.

III. ADA & Discrimination Practices

All ADA-related policy manuals, internal training materials, enforcement memos, and procedural guidelines concerning accommodations for pro se, neurodivergent, or disabled litigants — including how such materials were disseminated and applied from June 2024 onward.
All records involving or referencing ADA Liaison Ramaker, including communications with Plaintiff, internal staff, referees, or third-party agencies regarding Plaintiff’s accommodation requests, denials, or complaints.
All communications and records related to the Minnesota Department of Human Rights (MDHR) inquiry regarding Plaintiff’s disability accommodations — including responses, internal assessments, meeting notes, and discussions about whether and how to respond to the inquiry, as well as any analysis of litigation exposure or reputational risk.
Any internal correspondence or documentation reflecting retaliation, adverse treatment, or suppression of Plaintiff’s rights based on her disability, neurodivergence, or perceived emotional tone — including claims that Plaintiff’s communication style justified denial of accommodations or court access.
All records of participation in, response to, or coordination with any oversight body, watchdog group, or internal compliance inquiry involving Plaintiff’s disability, ADA accommodations, or civil rights concerns. This includes communication about how to handle or deflect those oversight efforts, and any explicit or implicit plans to coordinate response narratives or deny wrongdoing.
All communications referencing Plaintiff’s ADA status, accommodation history, or perceived disability that suggest bias, suspicion, or coordinated discrediting — especially among referees, clerks, administrators, and attorneys from Ramsey County or Barna, Guzy & Steffen LLP.

IV. HRO & Procedural Abuse Patterns

Statistical data and case records on Harassment Restraining Orders (HROs) issued without valid or perfected service from 2022 to present — including resulting defaults, dismissals, vacated orders, or admissions of procedural error.
Evidence of document manipulation across HRO cases, including forged or unsigned orders, use of deprecated or retired templates, backdated filings, altered metadata blocks, and resurrection of previously voided or withdrawn orders.
All internal records, policies, and audit logs related to silent rescheduling of hearings, ex parte communications, retroactive judicial assignments, and clerical issuance of orders without formal judicial review.
All communications and records relating to how Barna, Guzy & Steffen LLP (BGS) — a municipal law firm typically representing government entities — came to represent a private petitioner in the HRO proceedings against Plaintiff. Includes discovery into the contractual relationship between BGS and Ramsey County, any known conflicts of interest, and prior or parallel representation of county clients.
Personnel and employment records showing the career trajectory of Kyle Manderfeld, including his time at the Ramsey County Attorney’s Office (RCAO), the timing and nature of his move to BGS, and any overlap, coordination, or continuing communication between BGS and RCAO during or after his transition.
All communications or case records involving attorneys Bradley Kletscher and Joel LeVahn regarding Plaintiff, Madeline Lee, or the HRO case, including the internal assignment of roles, filing decisions, and strategy coordination between BGS personnel and Ramsey County court administration, referees, or judicial officers.

V. Information Leaks & Privacy Violations

All access logs, internal memos, and correspondence showing when, how, and by whom Plaintiff’s residential address or other protected contact information was accessed, recorded, or disclosed without consent — including but not limited to the following timeframes: August 12–17, 2024; February 4–26, 2025; and April 17–23, 2025.
All communications between the Ramsey County Sheriff’s Office, Bridges to Safety, Madeline Lee, Nishi Sinha, and any court personnel or affiliated agencies regarding Plaintiff’s identity, location, phone number, or home address — especially where such information was acquired under false pretenses, falsely claimed in police reports, or obtained via Plaintiff’s ADA disclosures or court contact.
All drafts, submissions, and metadata associated with the police report filed by Madeline Lee and/or processed by the Ramsey County Sheriff’s Office that falsely claimed a lack of identifying information about Plaintiff while simultaneously referencing known data acquired from internal systems or court documents.
All records showing how Plaintiff’s home address — provided to the court confidentially on August 12, 2024 — was internally processed, logged, or passed between departments, and how that data was subsequently omitted from formal notice or hearing documentation despite being used to send physical mail to Plaintiff’s residence.
All evidence of informal channels through which Plaintiff’s identity was known or referenced — including phone call logs, social media surveillance, intake conversations, or any digital footprint tracing back to Plaintiff prior to or during the above periods — that contradict claims that the court or sheriff’s office “did not know” who Plaintiff was.
All correspondence or file activity showing when Plaintiff’s private address was disclosed or leaked to Madeline Lee, including direct or indirect disclosures via third-party programs, court files, or coordinated off-docket messaging. Discovery should include metadata, staff messages, mailing logs, and Bridges to Safety communication trails.

VI. Third Party / Interagency Involvement

All records, communications, case notes, referrals, and interagency messages referencing Plaintiff — or any of her known aliases (e.g., Onion Madder, Kellye Strickland, Onionanne, Kellye Sundar) — held or transmitted by the following entities:

Bridges to Safety (including intake notes, inter-staff messages, and partner agency coordination)
Donnell Marie Lee (any court filings, advocacy communications, or backchannel contacts)
Sumit Sinha (including any professional records or communications concerning Plaintiff)
Facebook / Meta (including abuse report escalations, account flagging, legal requests, and platform-level inquiries involving Plaintiff or Madeline Lee)
Ramsey County Sheriff's Office and Ramsey County Attorney’s Office (beyond direct filings, including informal interagency memos, data-sharing, or flagging)
Minnesota Department of Human Rights (inquiries, responses, and internal strategy related to Plaintiff's ADA claims)
Office of Lawyers Professional Responsibility (OLPR) and Minnesota Board on Judicial Standards (BSJ), including references to Plaintiff’s filings, outreach, or standing)
District Court Administration (including coordination with any other agency named above)
Barna, Guzy & Steffen LLP (BGS) and any of its subcontractors or parallel counsel operating under county contract or related conflict)

All evidence of indirect coordination, knowledge-sharing, or reactive policy shifts across or between these agencies following Plaintiff’s protected speech, legal filings, social media activity, or ADA accommodation requests — including any efforts to monitor, discredit, delay, or reroute Plaintiff’s filings, cases, or public presence.
All additional third-party involvement that may be revealed during discovery, regardless of whether those individuals or entities were named in initial pleadings — including sealed referrals, informal advisory calls, and off-record consultations affecting Plaintiff’s cases, ADA access, or legal standing.

VII. Plaintiff’s Outgoing Communications

All emails, web forms, certified or first-class letters, faxes, voicemails, in-person drop-offs, or other communications submitted by Plaintiff to any Ramsey County court personnel, referee, clerk, administrative department, or affiliated agency — including but not limited to communications sent to court administration, judicial officers, ADA liaison staff, law enforcement, legal departments, or interagency programs — from January 1, 2024 to present.
All internal metadata and routing logs associated with the above communications, including timestamps, recipients, attachment access records, forwarding actions, deletion events, suppression flags, internal notes, or classification decisions (e.g., “do not respond,” “flagged,” “forwarded to legal”).
All records showing whether, when, and how each communication was opened, acknowledged, rerouted, ignored, or suppressed — including staff Slack messages, Teams discussions, or sidebar email threads about how to handle Plaintiff’s inquiries, requests, notices, or filings.
This demand includes **every instance** of Plaintiff contacting any named or unnamed party involved in this case, regardless of medium or response status. Plaintiff retains a full, timestamped archive of her outgoing correspondence — including screenshots, delivery confirmations, audio recordings, certified mail receipts, and bounceback headers — and will use these records to identify and challenge any omission, falsification, or misrepresentation in response to this request.

VIII. Metadata Disclosure

Full metadata, audit logs, version histories, and revision trails for all documents, notices, orders, filings, or internal correspondence relating to Plaintiff — including but not limited to timestamps, authorship history, digital signatures, routing chains, access logs, print records, flagging events, and file-type conversion data.
This demand specifically includes all documents identified by Plaintiff as altered, unsigned, or retroactively assigned — as well as any materials discovered during the course of litigation or responsive production that contain hidden metadata, overwritten layers, anomalous save patterns, or unexplained formatting inconsistencies.
Discovery must include embedded file metadata (e.g., EXIF, XMP, DOCX XML layers), system-level tracking data (e.g., Tyler Tech logs, MNCIS document lifecycle records), and any separate log systems used to track document handling or override access.
Plaintiff reserves the right to subject all disclosed materials to forensic examination using digital analysis tools or manual audit methods. All documents produced in response to any request may be scrutinized for alterations, inconsistencies, or metadata anomalies — regardless of whether they were flagged by Defendants or offered voluntarily.

IX. CPS Call Handling & Retaliation Metadata

Full records of Plaintiff’s August 12, 2024 call to Child Protective Services (CPS), including intake transcripts, phone logs, staff assignments, internal transfers, call summaries, and routing notes. This includes identification of all staff, clerks, or social workers who spoke to or received information from Plaintiff during that call, and how that information was processed, logged, or archived.
All metadata associated with the August 12 CPS report, including timestamped handling logs, internal annotations, priority codes, system routing, risk assessments, and dismissal rationale. Includes any audit trails reflecting access or edits to Plaintiff’s report after initial submission.
All internal communications or agency notes connecting Plaintiff’s August 12 report to subsequent retaliatory action, including disclosure to opposing parties, linkage to HRO proceedings, or narrative construction in court filings by the petitioner or affiliated counsel.
All records regarding false claims made by HRO petitioner Madeline Lee stating that Plaintiff initiated CPS reports in June or July 2024. This includes intake logs, phone records, investigatory notes, agency findings, and metadata showing the actual source, date, and nature of any CPS contact made during that time period — and whether those contacts were ever initiated by Plaintiff or falsely attributed to her.
Plaintiff authorizes and demands disclosure of all technical metadata, digital access logs, and internal case management history to determine how her call and personal data were handled, flagged, or weaponized. All records must include sufficient identifiers to reconstruct a full chain of custody from Plaintiff’s first contact through any administrative or judicial use.

X. Payment, Fees, and Financial Records

Full financial ledger of all filing fees, money orders, ePayments, and payment portal activity associated with Plaintiff from January 1, 2024 to present — including timestamps, payment types, fee categories, handling staff, internal routing, and confirmation logs. This includes fees for conciliation, district court motions, ADA-related filings, appeals, transcript requests, and eFile rejections that were later reprocessed or quietly resolved.
Scanned copies and intake metadata for every physical money order submitted by Plaintiff, including postal tracking numbers, internal scanning logs, mailroom check-in records, and cashier processing documentation. Each must be tied to the responsible intake personnel and chain-of-custody from receipt to deposit or misplacement.
All internal communications — including clerk emails, Slack or Teams messages, payment portal support tickets, and administrative memos — concerning missing, redirected, held, or contested payments from Plaintiff. This includes all instances where Plaintiff’s payments were accepted without docketing, returned with delay, misplaced internally, or used to justify a denial of service.
All eFiling portal activity logs associated with Plaintiff’s account, including unexplained lockouts, error flags, ghost rejections, or suspension from payment privileges. Include helpdesk records, override authorizations, and any administrative review of Plaintiff’s ability to pay or file under standard procedures.
All records related to refunds or reversals — whether approved, denied, or pending — including refund requests initiated by Plaintiff or internally discussed due to procedural failure. Identify who authorized each decision, the legal basis cited, and any irregularity that may have triggered internal review or off-the-record intervention.
All interdepartmental communications referencing Plaintiff’s fees or money orders as burdensome, inconvenient, or needing to be “worked around,” especially any references to handling Plaintiff differently than other filers due to volume, tone, or disability status.
All records of funds, discretionary budgets, external legal resources, or emergency allocations used to resolve or bury administrative failures connected to Plaintiff’s filings — including but not limited to payments made to outside counsel, consultants, records vendors, or internal crisis teams for reputation or litigation risk management. Identify the amounts spent, the accounts drawn from, and the individuals who authorized the expenditures.
All financial records showing direct or indirect payments made by Ramsey County, court administration, BGS, or any associated actor to remedy, suppress, delay, or cover up harm resulting from the mismanagement of Plaintiff’s filings, fees, or rights. Plaintiff intends to establish a full financial footprint of procedural misconduct and identify both the cost and beneficiaries of concealment efforts.

XI. Representation, Conflicts & Payment of BGS / Manderfeld

All records showing how and when Barna, Guzy & Steffen LLP (BGS) — and attorney Kyle Manderfeld specifically — were retained to represent the private petitioner in Plaintiff’s HRO case and/or any Ramsey County entity in related litigation. This includes engagement letters, contract approval memos, emails, and internal routing or assignment notices.
All financial records showing who paid BGS and Manderfeld for their participation in any capacity relating to Plaintiff’s litigation — including private billing, Ramsey County funds, pooled public legal defense resources, insurance reimbursements, or court-authorized funds. Each record must show payor identity, dates of payment, amounts billed, billing codes, and related case files or matter numbers.
All communications between Ramsey County, its agents, or administrators and BGS regarding scope of representation, authorization to appear, litigation strategy, ADA issues, or concerns over public liability. This includes records of informal authorizations, hand-offs, and verbal referrals.
Complete internal conflict-of-interest checks and assignment documentation from BGS and/or Kyle Manderfeld prior to or during his appearance in any case involving Plaintiff. This includes known conflicts from Manderfeld’s prior employment at the Ramsey County Attorney’s Office (RCAO), whether such conflicts were disclosed, waived, or concealed, and the legal basis offered for continuing representation despite Plaintiff’s objections.
All BGS emails, memos, or records referencing Plaintiff’s conflict disclosures — including her federal complaint, written objections, and spoliation notices — and internal responses, legal analyses, or strategic pivots taken in response.
All documents, billing records, or communications showing whether any costs of representation for BGS or Manderfeld have been subsidized, reimbursed, or anticipated for reimbursement by Ramsey County, its insurers, or any third-party aligned with county interests or litigation outcomes. This includes shadow billing, deferred payment arrangements, or indemnity agreements.
All materials evidencing dual representation, conflicting loyalties, improper alignment with county officials during pending litigation, or use of privileged access to RCAO knowledge, personnel, or systems gained during Manderfeld’s public employment to influence private litigation tactics against Plaintiff.

XII. Litigation Strategy, Collusion, and Laundering

All communications, memos, drafts, and internal messaging reflecting coordinated litigation strategy involving any combination of the following actors: Barna, Guzy & Steffen LLP (BGS), Kyle Manderfeld, Ramsey County court personnel, Referees, district judges, the Ramsey County Attorney’s Office (RCAO), Bridges to Safety, and state-affiliated legal bodies — particularly following the filing of Plaintiff’s federal complaint on May 9, 2025.
All records evidencing the laundering of judicial or quasi-judicial orders for tactical use — including unsigned or defectively signed orders that were later recycled, refiled, or relied upon by other parties (BGS, Ramsey County, or otherwise) in a manner that falsely implied legitimacy or finality.
All communications indicating intentional estoppel construction between state and federal forums, including efforts to provoke or exploit contradictory rulings, delay federal discovery, or insulate Ramsey County actions from federal scrutiny via procedural distraction, tactical silence, or premature dismissal narratives.
All materials evidencing coordination between BGS and Ramsey County after the federal complaint was filed — including litigation response strategy, parallel motion timing, indirect narrative seeding, ghostwritten affidavits, or coordinated refusal to acknowledge Plaintiff’s standing, disability disclosures, or ongoing service attempts.
All internal discussions regarding "forum shielding" — including efforts to use conciliation court, referee dockets, or local orders to shape or suppress federal exposure. Includes strategies to confuse jurisdiction, repeat pre-empted claims, or leverage non-federal motions as bad-faith "responses" to Plaintiff’s federal claims.
All off-docket communications, Teams or Slack threads, call notes, or sealed discussions evidencing collusion or foreknowledge across distinct parties in this litigation chain. Plaintiff specifically seeks to expose covert collaboration between actors who later claimed independence or neutrality in official filings.

XIII. Policy, Training, and Supervision

All written, unwritten, internal, or unofficial policies, workflows, or standard operating procedures governing service of process, order signature requirements, handling of pro se or ADA-disclosing litigants, and response protocols for federal lawsuits naming Ramsey County personnel or systems.
All internal training materials — including presentations, staff handbooks, onboarding packets, continuing education content, and legal compliance briefings — addressing service timing, order finalization, digital signature protocols, ADA accommodation, and procedural discretion when dealing with high-risk or “difficult” filers.
All supervisory directives, managerial bulletins, internal memos, or oral guidance given to clerks, referees, or judicial staff regarding how to delay, reroute, or neutralize filings from litigants seen as burdensome, threatening, or litigious — including any classification systems, flagging mechanisms, or informal "red list" designations used internally.
All documents describing how Ramsey County personnel are instructed to respond when named in federal litigation — including risk management protocols, press coordination, file review instructions, or any protocol for preserving (or quietly eliminating) vulnerable communications or defective orders once litigation is filed.
Any gaps, omissions, or contradictions in training, policy, or oversight that may have enabled or encouraged ADA retaliation, procedural obstruction, or document manipulation — including failure-to-train, deliberate indifference, or systemic disregard for rights protected under federal law.

XIV. Injury, Damages, and Emotional Distress Records

All records — including internal communications, court memos, staff notes, or interagency correspondence — referencing Plaintiff’s emotional harm, stress responses, disability status, trauma disclosures, or heightened risk of injury related to litigation stress, procedural mistreatment, or ADA denial.
All documentation acknowledging, analyzing, or reacting to Plaintiff’s stated or documented disability, neurodivergence, or trauma history, including risk assessments, crisis alerts, or supervisory notes identifying Plaintiff as vulnerable, high-risk, or emotionally distressed.
All instances where Plaintiff’s emotional or disability disclosures were dismissed, downplayed, mocked, or treated as justification for punitive action, delay, obstruction, or refusal to engage. This includes all internal staff commentary, Slack messages, or informal reactions to Plaintiff’s filings, complaints, or public posts about harm.
Any records reflecting concern, awareness, or institutional acknowledgment that Plaintiff was likely to suffer psychological or reputational injury from the way her filings, ADA requests, or identity were handled — especially where no corrective action followed.
All internal tracking, communications, or supervisory escalation related to emotional distress claims raised by Plaintiff — including references in motion reviews, ADA correspondence, legal strategy meetings, or risk mitigation discussions post-federal filing.
All third-party referrals, hotline alerts, incident reports, or informal wellness checks initiated, denied, or discussed in connection with Plaintiff’s distress — especially where initiated without consent, in bad faith, or as a retaliatory mechanism.

Final Demand for Administrative Transparency

Plaintiff demands unrestricted access to all systems, communications, and internal records directly or indirectly relevant to the claims at issue. This includes, but is not limited to: back-end metadata, draft revision histories, internal routing logs, staff email and messaging platforms (including Slack, Teams, and SMS), payment ledger systems, docketing rejections, signature and service handling notes, ADA accommodation logs, and all interagency coordination trails involving named or unnamed actors.

This demand explicitly encompasses informal chat history, post-submission commentary, sealed or unpublished documents, and any off-docket activity affecting Plaintiff’s filings, rights, or legal standing. Any form of redaction, omission, or destruction will be treated as a potential act of spoliation and subject to sanction.

Given the constitutional magnitude of the claims under federal review — including due process violations, ADA retaliation, evidence tampering, and systemic obstruction — the scope of discovery requested herein is both legally proportional and procedurally mandatory. Ramsey County and all participating actors are formally expected to preserve, produce, and disclose the full digital and administrative record in its entirety.