UPDATE: Manderfeld Introduces Collateral Estoppel Theory

Date: August 14, 2025

Event: On August 14, 2025, attorney Kyle T. Manderfeld filed a sudden, unsolicited memorandum introducing a new legal theory- collateral estoppel-which had never appeared in any prior briefing. The memo was accompanied by a letter requesting a continuance on Plaintiff's behalf and without her consent, and an evidence packet containing two conflicting versions of the same court order.

The August 14 Filing Package

Manderfeld submitted three documents late on August 14:

  • A continuance request improperly framed as though Plaintiff was asking for a delay.
  • A collateral estoppel memorandum arguing that Plaintiff was barred from challenging the December 12, 2024 HRO and the May 23, 2025 denial, despite the fact that:
    • the December 12 HRO has two conflicting versions, and
    • the May 23 denial order remains unsigned in every official record.
  • An evidence packet containing:
    • a signed December 12, 2024 HRO, and
    • an unsigned May 23, 2025 denial order.

The filing attempted to establish a frozen factual record using documents whose authenticity and filing history were already in dispute. These same documents later became central to Plaintiff's Notice of Evidence Laundering filed in federal court.

How This Set Up the August 19 Misconduct

Five days later, on August 19, 2025, Judge Nicole Starr relied heavily-and exclusively-on the August 14 estoppel memo to:

  • deny Plaintiff's Motion to Vacate,
  • affirm the HRO without addressing service irregularities, and
  • treat the May 23 order as signed even though no signed version exists in the evidentiary record.

Her Findings of Fact cite the very same two irregular orders:

  • The December 12 HRO (in competing signed/unsigned versions),
  • The May 23 denial purported to be "signed by a judge," despite a complete absence of any signed copy.

This is the first point in the timeline where a judicial officer adopted Defendant's irregular evidence packet as if it were the official record.

Why This Filing Was Irregular

Several defects in the August 14 submission stand out:

  • Improper continuance request: submitted in Plaintiff's name without consent.
  • Collateral estoppel theory appeared out of nowhere: no briefing, no motion, no legal basis, and no procedural posture supporting it.
  • Two conflicting versions of the December 12 HRO provided without explanation.
  • Unsigned May 23 denial order submitted as operative law.
  • Evidence laundering indicators: the same documents later appeared in Starr's Findings of Fact as if they were verified and official.

The August 14 filing marks the beginning of the chain that later implicated Rueger, Starr, and Bacon: a timeline in which irregular orders, altered documents, and internally inconsistent evidence were repeatedly adopted by state actors without verification.

Aftermath

Plaintiff filed an objection the next morning, August 15, submitting her own evidence packet showing:

  • the December 12 order existed only in conflicting versions, and
  • the May 23 denial had never been signed by any judicial officer.

Those contradictions were ignored at the August 19 hearing, where Judge Starr upheld the HRO based solely on the estoppel narrative introduced by Manderfeld on August 14.

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