UPDATE: Apparent Coordination Among Ramsey County Actors
Date: August 21, 2025
Event: Between August 14 and September 2, 2025, a sequence of filings by Kyle T. Manderfeld, Judge Nicole Starr, and Brett Bacon created the appearance of a coordinated effort to reframe the record and launder unsigned or contradictory documents into "settled facts" across multiple dockets.
August 14: The Initiating Packet
On August 14, 2025, Defendant Manderfeld filed a flurry of submissions:
- A letter requesting a continuance, written as though Plaintiff had consented;
- A new memorandum introducing a collateral estoppel theory never before raised;
- An evidence packet containing:
- a signed version of the December 12, 2024 HRO, and
- the May 23, 2025 denial order-but unsigned.
This packet introduced, for the first time, the contradictory pairing of a December 12 order that had never appeared on the docket as signed, and a May 23 order that appeared only in unsigned form.
August 15: Plaintiff Objects and Corrects the Record
On August 15, Plaintiff filed an objection to the continuance request and submitted her own evidence showing:
- The December 12 HRO in its unsigned form (matching the ROA at the time);
- The May 23 denial order in its unsigned form.
Plaintiff noted that the docket did not contain the signed version of the December 12 order that Manderfeld had submitted, nor any signed version of the May 23 denial.
August 19: Starr Relies on Manderfeld's Packet
On August 19, Judge Nicole Starr held a hearing on the matter. During the hearing, she adopted Manderfeld's framing and later issued a Finding of Fact that:
- quoted extensively from his August 14 memorandum;
- treated the December 12 HRO as authenticated and judge-signed; and
- treated the May 23 denial order as judge-signed-even though no such version existed in the evidence record or the ROA.
This marked the first time Ramsey County formally adopted the altered/inconsistent versions of the orders as "fact."
August 29: Bacon Enters the Orbit
On August 29, county counsel Brett Bacon sent a meet-and-confer email regarding an anticipated motion to dismiss but refused to provide a Notice of Appearance. The county's role remained undocumented while Plaintiff was expected to respond to counsel she could not formally verify as counsel of record.
September 2: Bacon Files MTD Using Laundered Documents
On September 2, Bacon filed a Motion to Dismiss containing:
- Manderfeld's Notice of Appearance-which had not previously appeared on the HRO docket;
- Starr's August 19 Finding of Fact-which incorporated the altered orders;
- the Register of Actions-which was significantly out of date and failed to reflect the evidence Plaintiff had already filed correcting the record.
The MTD relied entirely on the distorted evidence sequence introduced by Rueger's incomplete ROA, Manderfeld's August 14 packet, and Starr's adoption of the same on August 19.
Federal Filing: Notice of Evidence Laundering
Following these events, Plaintiff filed a Notice of Evidence Laundering in the federal case, documenting the sequential pattern:
Rueger - Manderfeld - Starr - Bacon
Each actor relied on the distorted record introduced by the prior, resulting in a self-reinforcing loop of fact-creation detached from the docketed evidence.