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Scope of Discovery

View Full Amended Complaint (PDF)

I. DIGITAL SYSTEMS, SOFTWARE, AND AUTOMATION

Target: Tyler Technologies / MNCIS / Minnesota Judicial Branch

  • Complete eFiling logs for any record containing:
    • “Kellye Strickland” / “Kellye Anne Strickland” / “Onion Madder”
    • Known Facebook usernames used or referenced
    • “Pojo Kutty,” “Leelee Cocodrie,” “Pojo Rahab,” “Madeline Sally Lee”
  • Access logs and revision metadata for HRO templates including:
    • Explanation for “Revised 2021” footer on 2024 HRO
    • Use of retired or resurrected template forms
    • Evidence of “ghost metadata” or re-filled form fields
  • Automation and internal workflows used to:
    • Auto-advance cases despite failed service
    • Flag or delay filings from pro se litigants
    • Deny docketing with silent rejection or ghosting
  • Audit trail from Minnesota eFS system, including:
    • Every timestamped submission or rejection involving Plaintiff
    • Names of staff who accessed or altered entries

II. COMMUNICATIONS & INTERNAL CORRESPONDENCE

Timeframe: August 1, 2024 – Present
Media: Email, Slack, Teams, chat logs, memos, call notes

  • Any messages referencing the Plaintiff, her filings, or aliases
  • Language mocking, minimizing, or dismissing disability, tone, or name usage
  • Names to flag:
    • “Nikki” / Nicole Rueger
    • Judge Elizabeth Clysdale
    • Donald Harper, Corina Loya
    • Hannah Thurmes, Jill Ramaker
    • Bridges to Safety staff
  • Discussion of social media presence, emotional tone, or “risk perception”

III. DISCRIMINATION & ACCOMMODATION PRACTICES

  • ADA accommodation policies for:
    • Pro se litigants
    • Individuals with PTSD, bipolar disorder, autism
  • Training materials, complaint logs, audits
  • Records of denial based on tone, perceived threat, or identity expression
  • Any use of “special handling” flags related to disability, mental health, or unorthodox names

IV. HRO & PROCEDURAL ABUSE PATTERNS

  • Statistical records of HROs issued without service since 2022
  • Cases where non-service was ignored or overridden
  • Known vacated or reversed HROs due to:
    • Lack of service
    • False information or staff error
  • Evidence of document “resurrection,” template cloning, or silent rescheduling

V. INFORMATION LEAKS & PRIVACY VIOLATIONS

  • Who accessed Plaintiff’s private address info between Aug 12-17, 2024; Feb 4–26, 2025; and Apr 17–23, 2025
  • Logs of:
    • Email, print, export, fax, or external relay
    • Any record that went to Madeline Lee, Sumit Sinha, or unknown third parties
  • Breach notifications or known leak incidents
  • Any cross-referenced discussion, flag, or metadata entry involving:
    • The August 12, 2024 CPS phone call made by Plaintiff to Ramsey County court direct line
    • Internal note of that call being forwarded or transferred to CPS or related agency
    • Personnel who spoke to Plaintiff during or in relation to that call

VI. THIRD PARTY AND INTERAGENCY INVOLVEMENT

  • Bridges to Safety — intake logs, refusal justifications
  • Donnell Marie Lee — testimony logs, mention in internal memos
  • Sumit Sinha — mention or reports filed regarding threats or mailings
  • Facebook / Meta — any mention of Plaintiff’s online presence used in case handling

VII. PLAINTIFF’S OUTGOING COMMUNICATIONS

Every email, web form, or letter sent by Plaintiff from August 12, 2024 onward — including:

  • Judge Sara Grewing
  • Donald Harper
  • Nicole Rueger
  • Corina Loya
  • Rafael Ortega
  • Bridges to Safety
  • Ramsey County Courts (any public-facing form or portal)
  • MDHR
  • Minnesota Attorney General’s Office
  • Maricopa County Sheriff’s Office (AZ)
  • Merrimack County Sheriff’s Office (NH)
  • Tyler Tech / Minnesota eFS admin contact

VIII. METADATA DISCLOSURE REQUEST

  • Timestamp of every message submission
  • Who received it, opened it, or redirected it
  • Whether it was:
    • Ignored
    • Deleted
    • Flagged for tone
    • Marked as spam or harassment
  • Internal notes or comments on how to “handle” Plaintiff

IX. CROSS-SYSTEM CPS CALL HANDLING & RETALIATION METADATA

  • Exact timestamp and metadata surrounding the Plaintiff’s August 12, 2024 phone call to Ramsey County court line regarding child welfare concerns
  • Internal routing of the call to external CPS agencies, including:
    • Logs showing who accepted or rerouted the call
    • Which internal staff member initiated the handoff or submitted Plaintiff’s concerns to child services
    • Any call notes, summaries, or annotations added to the file
  • Any internal communication that linked this August 12, 2024 report to the subsequent CPS case raised by Madeline Lee on April 23, 2025
  • Cross-referenced case IDs, backend reference codes, or routing tags showing procedural overlap between Plaintiff’s call and the April 23 hearing
  • Personnel who discussed or were made aware of the Plaintiff’s initial call in relation to Madeline’s subsequent accusation
  • Any record of Plaintiff’s CPS call being flagged internally as “retaliatory,” “harassing,” “unsubstantiated,” or similar prejudicial classifications without evidentiary review
  • Slack, Teams, call center systems, or memo entries where this call or Plaintiff’s name were referenced in conjunction with April 2025 case generation
  • Any user who accessed, altered, printed, or exported these call logs between Aug 12, 2024 – Apr 23, 2025
  • Names of staff who contributed metadata, opinion, or routing decisions without direct review of the call itself
  • Communications between Ramsey County and third parties (e.g., Bridges to Safety, law enforcement, child protection workers, social media observers) about Plaintiff’s involvement in child welfare discussions

    • In the context of demonstrable retaliation and misrepresentation, Plaintiff demands unredacted access to any instance where her voice, words, or intent were used to justify reverse prosecution, suppression, or institutional discrediting. No derivative case or falsified cross-reference shall escape metadata analysis.

FINAL DEMAND

Plaintiff demands full administrative transparency from all involved agencies and systems, including internal metadata, revision logs, personnel actions, and informal chat records. These materials are critical to exposing systemic suppression of due process and ADA rights.