View Full Amended Complaint (PDF)
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MINNESOTA
Case No. 0:25-cv-02056-DWF-DJF
Kellye Strickland,
Plaintiff,
v.
Nicole Rueger, et al.,
Defendants.
Plaintiff Kellye Strickland, proceeding pro se and as a permanently disabled autistic person, respectfully moves this Court for an extension of time to complete service of process under Federal Rule of Civil Procedure 4(m).
Plaintiff filed the original complaint in this matter in good faith and has been working diligently to prepare a complete, well-organized amended complaint with exhibits. What began as a 16-page complaint has expanded to over 70 pages, supported by more than 60 exhibits, all now formatted to meet federal procedural standards.
Plaintiff is proceeding without counsel, while navigating multiple disability-related challenges, including severe PTSD, and ongoing retaliation from the defendants named in this matter. The May 23, 2025, state-level hearing triggered a significant PTSD episode, delaying Plaintiff’s ability to work. However, recovery was followed by continued and sustained progress.
On July 9, 2025, Plaintiff received an unexpected and overwhelming production from Ramsey County court personnel. This “Rueger Dump” consisted of 56 unredacted documents totaling 284 pages, most of which were not responsive to the original records request. Plaintiff is still reviewing and cataloging these materials, which include discrepancies relevant to the claims of due process violations, ADA retaliation, and the improper dissemination of altered judicial documents.
Plaintiff is simultaneously litigating related matters on the state level in Ramsey County and preparing motions in that jurisdiction, while also maintaining detailed documentation for an active inquiry with the U.S. Department of Justice, Civil Rights Division (Case No. [25-OCR-1567]). The DOJ is currently reviewing many of the same incidents and documents involved in this case.
In addition, Plaintiff has reviewed recent judicial rulings from the District of Minnesota and adjusted the list of named defendants accordingly. Specifically, Plaintiff removed the Ramsey County Sheriff’s Office (RCSO) and substituted Ramsey County itself, in recognition of controlling precedent and to avoid unnecessary procedural defects.
Given the scale of evidence, cross-jurisdictional litigation, and the necessity of building an accurate and complete record, Plaintiff respectfully requests a 30-day extension to complete service. This request is not made for the purposes of delay, but rather to ensure fairness, compliance with the Federal Rules of Civil Procedure, and the integrity of this matter moving forward. Plaintiff notes that she is seeking the same due process protections and notice rights that she was repeatedly denied.
No defendant has yet been served. Granting this extension will not prejudice any party and will serve the interests of judicial economy and fairness. A short extension will allow Plaintiff to complete service of a final, fully-supported amended complaint and will reduce the risk of piecemeal filings or procedural inefficiency.
WHEREFORE, Plaintiff respectfully requests that the Court grant an additional thirty (30) days from the current Rule 4(m) deadline to complete service on all named defendants in this matter.
Dated: July 17, 2025
Respectfully submitted,
Kellye Strickland
6445 S Maple Ave, Apt 2006
Tempe, AZ 85283
kellye.sundar@gmail.com
(603) 892-8666
Plaintiff, Pro Se