On July 31, 2024, Madeline Sally Lee submitted her first petition for a Harassment Restraining Order (HRO) against Plaintiff. The petition was denied the same day with an order stating that it failed to allege any conduct that would constitute a violation under Minn. Stat. § 609.749 subd. 2, 3, 4, or 5, or under Minn. Stat. §§ 609.342, 609.345, or 609.3451. The denial also confirmed that neither petitioner nor respondent qualified for a fee waiver.
On August 8, 2024, Lee submitted a second HRO petition, repeating the same statement of facts. It was again denied for failure to allege qualifying acts and for insufficient financial documentation; the court noted that submission of a benefits card alone was not adequate proof for a waiver.
On August 9, 2024, Lee submitted a third petition, once again with the identical statement of facts. The court initially denied the petition for the same reasons as before. However, minutes later, a second order was generated, this time stating that the petition was not frivolous and that Lee’s fee waiver was granted.
On August 12, 2024, Plaintiff placed an 11-minute phone call to Ramsey County Court and was transferred to Child Protective Services (CPS) to report serious concerns about Lee’s conduct involving her minor child. The concerns were based on public social media activity suggesting the child was being used in sexually suggestive or manipulative content online. The report was made under Plaintiff’s legal name and phone number.
On August 16, 2024, Lee filed a third amended petition, again repeating the same statements of fact. That same day, the court issued a new order denying her ex parte request, explaining that a hearing had already been scheduled and instructing Lee that she could not file further amendments without express court approval.
On August 17, 2024, Plaintiff received unsolicited, harassing messages from multiple unknown men accusing her of having a “mental breakdown.” One of the senders was later identified as Dino Di Lucido, a former internet acquaintance from Plaintiff’s time as a verified Meta content creator. These messages coincided with the escalation of Lee’s filings and reflect an effort to provoke or discredit Plaintiff through third-party coordination.
Also on August 17, Plaintiff issued a cease and desist letter to Lee. Out of fear for her physical safety and in light of Lee’s known doxxing and stalking behavior, Plaintiff used a non-residential address in the letter to shield her actual location.
On August 29, 2024, Deputy Kaitlyn Burt of the Merrimack County Sheriff’s Office contacted Plaintiff by telephone in connection with an attempted service related to Madeline Lee’s Harassment Restraining Order petition. Deputy Burt informed Plaintiff that Lee had alleged harassment and threats. Plaintiff responded that she had not lived in New Hampshire for over five years and was currently residing in Arizona.
On September 5, 2024, the Ramsey County District Court issued a continuance order stating that further proceedings would be delayed to allow for a new attempt at personal service at the respondent’s updated address. This acknowledgment in the court record affirms that as of that date, no valid legal service had been accomplished and that jurisdiction had not yet been established.
On October 2, 2024, the Maricopa County Sheriff’s Office in Arizona (Deputy Russ Skinner) filed a second affidavit confirming that service was again unsuccessful.
On October 3, 2024, the court issued another continuance, stating that the petitioner needed to file a request for alternate service or publication.
On November 7, 2024, petitioner Madeline Lee submitted an affidavit and request for publication, falsely stating that Plaintiff was intentionally evading service and that the documents had been mailed to Plaintiff’s “last known address.” That same day, the court issued an order permitting service by first-class mail to those same known invalid addresses, despite previously documented failures and returned mail.
On November 8, 2024, the court issued a third continuance, stating that the matter was being continued “to allow the respondent time to be served by first-class mail.” However, both mailings were later returned as undeliverable.
On December 12, 2024, Defendant Referee Elizabeth Clysdale granted a Harassment Restraining Order (HRO) against Plaintiff Kellye Strickland without her knowledge, participation, or valid legal service. The order was issued without a district judge’s signature.
On February 3, 2025, Deputy Corina Loya of the Ramsey County Sheriff’s Office contacted Plaintiff by phone. Loya was calling in response to a report made by Madeline Lee, who alleged that Plaintiff had sent death threats to her mother. The police report referenced a prior report in which Lee had also attempted to report Plaintiff. The police interest was triggered in part by Lee voluntarily showing officers a cease-and-desist notice that Plaintiff had previously sent to her, which officers reportedly found suspicious. During the call, Deputy Loya failed to inform Plaintiff that a Harassment Restraining Order (HRO) had already been granted against her. Instead, Loya vaguely inquired about Plaintiff’s location and requested her residential address under ambiguous pretenses. Believing the inquiry to be administrative and unrelated to any active legal proceeding, Plaintiff provided her real address in good faith.
On February 4, 2025, Plaintiff called Bridges to Safety at the direction of Deputy John Gleason, who informed her that she might be a victim and should consider speaking with a victim advocate. A woman answered the phone and identified herself as “Nikki.” When Plaintiff gave her name, Nikki responded, “I know all about you.” Throughout the call, Nikki was openly hostile and dismissive. When Plaintiff asked why she was being treated with such hostility and requested to speak with someone else, Nikki placed her on hold but never transferred the call. Plaintiff called back a few minutes later, at which point Nikki answered again and asked, in a rude and sarcastic tone, “Do you wanna talk to my manager?” Plaintiff, shaken by the interaction, hung up. After calming herself, she called back a third time to ask for the staff member’s name for her records. Once the name was confirmed, Plaintiff ended the call.
On February 26, 2025, Plaintiff was formally served two weeks later at that address by Deputy David Sheets of the Maricopa County Sheriff’s Office.
On March 3, 2025, Petitioner Madeline Lee sent harassing mail directly to Plaintiff’s husband, Skanda Vishnu Sundar, at their shared residence in Arizona. The envelope was delivered via third party Sumit Sinha and included materials suggesting retaliation and continued surveillance. The delivery confirmed that Plaintiff’s private residential address—previously known only to court officials—had been disclosed to Lee by someone within the Ramsey County system.
On March 4, 2025, similar mail was sent to Sundar’s place of employment, escalating the perceived threat and confirming that personal and professional information had been disseminated without consent.
On March 6, 2025—nine days after formal service of the Harassment Restraining Order—Plaintiff filed a Motion to Rescind. The motion was timely under Minn. Stat. § 609.748, subd. 3(c), which allows a respondent to request a hearing within 20 days of completed service.
Also on March 6, 2025, Plaintiff filed two separate actions in Ramsey County District Court: a small claims complaint against Madeline Lee for defamation and harassment, and a petition for a Harassment Restraining Order (HRO) seeking protection from ongoing misconduct. Both filings were accepted, time-stamped, and accompanied by the mandatory $85 filing fee. However, neither case was docketed, assigned, or scheduled for review. By contrast, Plaintiff’s husband, Skanda Vishnu Sundar, filed a nearly identical HRO petition against Lee on the same day. His petition was promptly docketed, granted ex parte, and scheduled for a hearing—despite the fact that he neither requested nor qualified for a fee waiver, which was nonetheless granted without explanation.
On March 18, 2025, Plaintiff received a deficiency notice from the Ramsey County District Court stating that the filing fee for her petition was $300 and instructing her to either remit payment or submit a waiver request. The notice made no mention of any “frivolous” designation, and instead confirmed that the matter was still pending action by the court. This contradicts any retroactive suggestion that the petition had already been dismissed or procedurally closed.
On April 11, 2025, the court issued two conflicting orders in Plaintiff’s matter. The first order granted Plaintiff’s fee waiver, acknowledging her financial and procedural eligibility. Later that same day, however, the court issued a second order denying Plaintiff’s March 6 Motion to Rescind the HRO. That denial relied on the demonstrably false assertion that Plaintiff had been served by mail on November 7, 2024—despite the fact that formal service was not completed until February 26, 2025 by Deputy David Sheets of the Maricopa County Sheriff’s Office. The court disregarded all sworn affidavits of non-service, all returned mail, and the governing timeline under Minn. Stat. § 609.748, subd. 3.
Also on April 11, 2025, Referee Rebecca Rossow denied the Motion to Rescind relying on a conclusory finding that Plaintiff had been “served by mail” on November 7, 2024. The order failed to acknowledge the multiple sworn affidavits of non-service, returned mail notices, and other documentation already in the record. It also failed to identify any valid service event, delivery confirmation, or statutory basis for assuming Plaintiff received the documents.
On April 16, 2025, Plaintiff submitted a formal records request to the Ramsey County District Court seeking comprehensive documentation for multiple active case files, including 62-HR-CV-24-963, 62-HR-CV-25-299, and 62-HR-CV-25-300. The request was specific, timely, and made in good faith. Court staff member Hannah Thurmes initially responded with limited guidance. Within hours, however, Judicial Court Operations Supervisor Nicole Rueger inserted herself into the correspondence and assumed unilateral control of the communication.
On April 17, 2025, Plaintiff filed a Motion to Vacate the Harassment Restraining Order issued against her in December 2024. The court promptly granted a hearing on that motion, scheduled for May 23, 2025. The acceptance of this motion validated the timeliness and substantive merits of Plaintiff’s original March 6 motion and implicitly acknowledged that the prior April 11 denial—based on false assumptions of mail service—had been procedurally defective.
On April 18, 2025, Rueger issued a records denial that exceeded boilerplate language and offered discretionary justifications for restricting access. At the time of this correspondence, Rueger had not been named in any litigation. Her unsolicited rationale and administrative gatekeeping—absent legal necessity or external oversight—demonstrate that the obstructive behavior at issue was not reactive or isolated, but institutional and preexisting.
On April 21, 2025, Plaintiff submitted a formal ADA accommodation request asking that all non-essential court communication be conducted via email rather than telephone. This request was prompted by repeated, distressing interactions with court staff—particularly Nicole Rueger—whose dismissive, mocking, and adversarial behavior had triggered panic responses and communication shutdowns consistent with Plaintiff’s disabilities, including PTSD and Autism. Plaintiff did not request to receive legal filings or court notices by email—only that staff cease placing phone calls and instead use email for administrative or procedural communications to prevent psychological harm and miscommunication.
Also on April 21, 2025, Petitioner Madeline Lee submitted a highly inflammatory filing to the court. In it, she falsely accused Plaintiff’s husband of "harassing" her by obtaining an HRO—a petition that had, in fact, been resolved through mediation at her own request. She further claimed that Plaintiff had contacted approximately 150 people regarding Lee’s personal sexual history—an assertion wholly unsupported by evidence and seemingly calculated to inflame the record and undermine Plaintiff’s credibility.
On April 22, 2025, Judge Kelly Olmstead issued a formal letter stating that no one at her office would communicate with Plaintiff via email. Plaintiff was instructed that any complaint must instead be submitted as a formal pleading—despite Plaintiff’s known disability-related communication limitations and her ongoing ADA accommodation request for email-based interaction. This letter marked a clear institutional refusal to engage in the interactive process required under federal disability law.
On April 23, 2025, the affiliated agency Bridges to Safety issued a letter claiming that they had no knowledge of anyone named “Nikki,” despite Plaintiff’s prior intake interaction with a woman using that name who denied her services and mocked her disability. This contradicts earlier statements made by court staff and appears to be part of a broader institutional attempt to disavow involvement and obscure internal misconduct.
On April 24, 2025, ADA liaison Jill Ramaker denied Plaintiff’s accommodation request. Rather than engage with the request as submitted, Ramaker mischaracterized it as a demand to receive all court filings via email, and rejected it on that basis. No interactive process was initiated. No clarification was sought. No alternative access was proposed. The denial was not rooted in Plaintiff’s actual words or documented needs, but rather in a distorted version constructed by court staff. This constitutes a direct violation of the ADA’s reasonable accommodation requirements and further illustrates the institutional resistance, administrative hostility, and procedural manipulation already established throughout the record.
On May 5, 2025, Plaintiff received a letter from the Second Judicial District suggesting that she could obtain eFiled documents online and redirecting her to previously attempted complaint channels. The response failed to acknowledge Plaintiff’s prior efforts or the barriers she had already documented, including unresolved ADA accommodation issues and repeated misdirection from court staff.
On May 6, 2025, Sara P. Boeshans, Executive Secretary of the Minnesota Board on Judicial Standards, informed Plaintiff that her misconduct complaint against Ramsey County judicial officers had been improperly formatted. No assistance was offered regarding reformatting or procedural correction. The message effectively functioned as a bureaucratic deflection, closing the door without resolving the underlying grievance.
On May 7, 2025, Plaintiff received an official order rejecting her recently submitted Motion Regarding Immediate Danger. The court stated that the motion was not a valid procedural vehicle and that it was “untimely.” No hearing was scheduled, and no effort was made to engage the substantive safety concerns outlined in Plaintiff’s filing.
On May 8, 2025, Petitioner Madeline Lee submitted a retaliatory motion to the court. In it, she referred to Plaintiff’s legal archive as a form of "violent litigation threat" and claimed that Plaintiff posed a danger to her, her family, and 110 employees of Ramsey County. This filing mischaracterized protected legal expression as aggression and appeared to be timed specifically to cast Plaintiff’s anticipated federal lawsuit as menacing or destabilizing—before it was even filed. The motion relied entirely on exaggeration and omitted the context of Plaintiff’s legal filings, disability disclosures, and prior requests for ADA accommodations.
On May 9, 2025, Plaintiff’s federal civil rights complaint was docketed in the United States District Court for the District of Minnesota. The complaint named six Ramsey County officials, including court administrators, judicial referees, and law enforcement personnel. It alleged a sustained pattern of due process violations, administrative obstruction, and ADA-related misconduct.
On May 12, 2025, attorney Kyle Manderfeld filed a Notice of Appearance in the underlying state HRO case. Public records confirm that Manderfeld had been employed by the Ramsey County Attorney’s Office through late 2024—during the period when Plaintiff’s Harassment Restraining Order was initiated, advanced without service, and ultimately granted in her absence. Manderfeld entered the case just three days after Plaintiff filed her federal complaint naming Ramsey County as a defendant, and he did so without disclosing any potential conflict of interest or prior affiliation.
On May 14, 2025, Plaintiff filed a formal complaint with the Minnesota Office of Lawyers Professional Responsibility, citing Manderfeld’s nondisclosure and ongoing participation in a matter where his prior employment posed an ethical concern. That same day, the Minnesota Department of Human Rights issued a denial of Plaintiff’s ADA inaccessibility complaint—despite extensive supporting documentation of communication barriers, denied accommodations, and procedural obstruction at multiple levels of the court system.
On May 23, 2025, a contested hearing on Plaintiff’s Motion to Vacate the Harassment Restraining Order was held in Ramsey County District Court. The presiding judicial officer was Referee Jenese Larmouth. Although Larmouth’s name had appeared on earlier court documents—including those issued during the period of obstructed filings and unresolved ADA requests—Plaintiff did not fully grasp the extent of her involvement until the hearing itself. By that point, Plaintiff had already filed a federal civil rights complaint naming multiple Ramsey County officials, and had contemplated including Larmouth as a defendant due to irregularities associated with her name. However, Plaintiff withheld her from the initial suit pending confirmation of her direct participation.
On July 7, 2025, following more than seven weeks of silence from the court after the May 23, 2025 hearing in Madeline Sally Lee v. Kellye Strickland, during which Plaintiff received no transcript, no record of filings, and no procedural notice, Plaintiff submitted a written records request to the Ramsey County District Court. The request sought a complete and certified copy of all documentation, filings, exhibits, and hearing materials associated with the case. It was addressed to the court’s general administrative email channels and did not reference or address Defendant Nicole Rueger.
On July 9, 2025, Rueger informed Plaintiff that she would be sending 56 documents across five separate emails. No index, manifest, or explanatory note was provided to clarify the contents or confirm whether the production was complete. The first email included only affidavits, with no indication of the production’s structure or scope.