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CASE 0:17-cv-00796-ADM-HB Document 1 Filed 03/17/17 Page 1 of 16
UNrrep SrerBs DIsrrucr CouRr

DTsrruCr OF MINNESOTA
Annelise C. Rice
l-1 1ut l.
VS.
Plaintift(s),
caseNo, l1Lv11t AOM/H6^
1to t" *rign"a Uy Cf".t otoltt i"t
Court)
Brent Roger Rice, individually.
Hennepin County, et al.
Carver County, et al. DEMAND FOR JURY
TRIAL
YES X NO
Defendant(s) .
Brent R. Rice; Carole Cole; Nicole Mercil; Bethany Koch; Sarah Kulesa; Jean Peterson; Judith
Hoy; Susan Olson; Richard Witucki; Jolene Lukanen; Michael Garelick; Cory D. Gilmer,
Michael Borowiak, John Doe I, John Doe II, and John Doe III
COMPLAINT
PARTIES
L List your name, address and telephone number. Do the same for any additional plaintiffs.
a. Plaintiff
Name A,nnre \i s e TZice

Street Address
'Ltjt f rc. vno^l A'Ye, S
County, City H{'^,^CP\'\ , vV\rnzr46\eo \rs

State & Zip Code l{'rv.^<-toio, @ SStlot
Telephone Number
qS.Z--331t-91\C
MAR |7 201i
4-
U.S, DISTFICT COURT MPIS
2. List all defendants. You should state the full name ofthe defendan! even ifthat defendant is
a government agency, an organization, a corpomtion, or an individual Include the address
where each defendant may be served. Make sure tbat the defendan(s) listed below are
identical to those contained in rhe above caDtiorl
a. Defendant No. 1
Nu^" flr3nt ?l(.+

srceteddress {@f I fiPahroOd l'fl
connry, ciry ]tCnnCDi n, Gf CcltiOf
state&zbcode rttirtnc3otr 55 3"1

b. Defenclant No. 2
Name lalolc Colr ' clo iarrvtar cow,ltV Fcrn! d*rlr+ thtisill
SteetAddress (rOO e, qfu 9+.
county, city C*VOI, Chllb*
state&zipcode rUlinncrotr 5S"lA
c. DefendantNo.3
nu-" Nicob Aarail qA crrr.rrc.rritl F.nttt canrt Dlvicicrr

StreetAd<tress @O0 E .lir. 3t
county, city CntfvCU, tfta,3 fr,a,
State&ZipCode l|ifnf Ofa 553Ic

NOTE: IF TIIERE ARE ADDITIONAL PL{NTIFFS OR DEFENDANTS' PLEASE
PROVIDE TIIEIR NAMES AND ADDRESSES ONA SEPARATE SIIPET OF PAPER
Check here if additional sheets of paper are attached;E
Please label the attached sheets ofpaper to correspond to the appropriate numbered
paragraph above (e.g. Additional Ilefendants 2.d.' 2.e.' etc.)
2.d. Defendant No. 4
Name Bethany Koch c/o Carver County Family Court Division
Street Address 600 East 4th St.
County, City Carver, Chaska
State & Zip Code Minnesota 55318
Defendant No. 5
Name Sarah Kulesa c/o Carver County Family Court Division
Defendant No. 6
Name Jean Peterson c/o Hennepin County Family Court Division
Street Address 110 South 4th St.
County, City Hennepin, Minneapolis
Defendant No. 7
Name Judith Hoy c/o Hennepin County Family Court Division
Defendant No. I
Name Susan Olson c/o Hennepin County Family Court Division
Defendant No. 9
Name Richard Witucki c/o Hennepin County Family Court Division
J. Defendant No. 10
Name Michael Garelick c/o Hermepin County Family Court Division
Defendant No. I 1
Name Jolene Lukanen c/o Hennepin County Family Court Division
Defendant No. 12
Name Cory D. Gilmer
Street Address 700 Lumber Exchange Building
10 South 5th St.

Defendant No. 13
Name Brenda K. Dehmer c/o Carver County Family Court Division
Defendant No. 14
Name Michael Borowiak c/o Hennepin County Family Court Diviston
John Doe I, John Doe II, and John Doe III
JURISDICTION
Federal courts are courts of limited jurisdiction. Generally, tvvo tlpes of cases can be heard in
federal court: cases involving a federal question and cases involving diversity of citizenship of
the parties. Under 28 U.S.C. $ 1331, a case involving the United States Constitution or federal
laws or treaties is a federal question case. Under 28 U.S.C. $ 1332, a case in which a citizen of
one state sues a citizen of another state and the amount of damages is more than $75,000 is a
diversity of citizenship case.
3. What is the basis for federal court jurisdiction? (check all that apply)
{ Federal Question I Diversity of Citizenship
4. If the basis for jurisdiction is Federal Question, which Federal constitutional, statutory or
treaty right is at issue? List all that apply.
Under 42 U.S.C. 1983 , this is a civil action for deprivation of constitutional rights.
Plaintiff s fourth and fourteenth amendment rights were violated. (42 u.s.c. soc. 1983: Title
42 The public health and welfare, Chapter 21: Civil rights, civil action for deprivation of
rights and l8 U.S.C. Sec.242]' Title 18: Crimes and Criminal Procedures' Part I: Crimes,
Chapter l3 : Sec. 24?: Deprivation of Rights under color of the law)
5. If the basis forjurisdiction is Diversity ofCitizenship, what is the state of citizenship ofeach
oartv? Each Plaintiff must be diverse from each Defendant for diversity j urisdiction.
Plaintiff Name: State of Citizenship:
Defendant No. l: State of Citizenship:
Defendant No. 2: State of Citizenship :
Attach additional sheets of paper as necessary and label this information as paragraph
Iheck here if additional sheets of paper are attached.
6. What is the basis for venue in the District of Miruresota? (check all that apply)
Gi Defendant(s) reside in Minnesota Gl Facts alleged below primarily occurred in

Minnesota
Gl Other: explain
STATEMENT OF THE CLAIM
Describe in the space provided below the basic facts of your claim. The description of facts
should include a specific explanation ofhow, where, and when each of the defendants named in
the caption vioiated the law, and how you were hatmed. Each paragraph must be numbered
sepamtely, beginning with number 7. Please write each single set of citcumstances in a
separately numbered paragraph.
7.1n2004, Plaintiff s parents, caroline Rice and Defendant Brent Rice, divorced. At the time of
the divorce Defendant Brent R. Rice was employed by Piper Jaffray. A trial was conducted by
Referee David Piper, nephew ofthe owner ofPiper Jaffray. In December of2005, an order for
protection was issued against Defendant Brent Rice to protect Plaintiff from domestic violence.
The Defendant Brent Rice plead guilty to several order for Protection violations. In 2005,
Hennepin County Family Court requested a custody and parenting time evaluation. The
defendants listed conspired and directly contributed to tortious interference with Plaintiffs
Mother-Child Relationship. The defendants conspired to deprive Plaintiffs access to the Courts,
and intentionally inflicted emotional distress. Defendants took affirmative steps to place Plaintiff
in the custody ofher abusive father, and to completely impair Plaintiffs ability to find protection
in the legal system. Defendants knew that Plaintiff was being abused and were sulfrciently
willful, wanton, and outrageous to constitute intentional in{liction of emotional distress.
Attach additional sheets of paper as necessary.

Check here if additional sheets of paper are attached: c
Please label the attached sheets ofpaper to as Additional Facts and continue to number the
paragraphs consecutively.
8. Tortious lnterference with Mother-Child Relationship: Defendants vigorously and
continuously tortuously used their positions as Plaintiffs "advocates" to wrongfully interfere
with the relationship between Plaintiff and her mother, resulting in her mother's inability to
protect Plaintiff and in further harm to Plaintiff.
9. Defendants repeatedly conspired with Defendant Brent R. Rice to deprive Plaintiffof her right
to access by the court by intentionally preventing the court from hearing evidence ofDefendant
Brent Rice,s abuse of Annelise and her mother, by engaging in ex parte communications with the
court in violation ofPlaintiffs due process rights, by coercing and financially harassing
Plaintiffs mother into abandoning her legal efforts to protect Annelise t}rough the courts, by
knowingly allowing the introduction of false testimony, by allowing into evidence and/or the
court's consideration the bogus, disreputable, and pro child-abuser "Parental Alienation
Syndrome" theory concocted by the discredited misogynist Richard Gardner, by failing to
disclose to the court the unethical and prejudicial relationship between Defendant Brent Rice and
Defendants, by prohibiting Annelise Rice (or any older siblings) from testifuing on her own
behalfin order to obtain protection from the abuse, by falsifying child protective services reports
on Plaintiffs abuse, and other acts.
10. A Guardian Ad Litem report written by Defendant Jean Peterson recommended the split
custody that the court later adopted on 08/18/05. No testimony was received into the record as to
why the children were separated, and no findings were made that j ustified the separation.
Minnesota case law such as, Fish v. Fish 159 N.W. 271 (Minn' 1960), establishes the preference
that the children, absent compelling circumstances, should be under one roof. This precedent was
clearly ignored. This was much to the detriment of the relationship of the Plaintiff with her
siblings. Hennepin County traumatically separated siblings, granting sole legal and physical
custody of Kristina and Lauren (Plaintiffs sisters) to Caroline and sole physical custody of
Plaintiff Annelise and her brothers, Tommy and Jayson. This report interferes with PlaintifPs
constitutional rights io familial relationships with her siblings and mother.
1 1. Defendant Brent Rice did not voice any concems over the sixteen-year marriage about
Plaintiff s mother's parenting abilities. Plaintiffs mother was the primary caretaker throughout
the entire mariage. Upon separation, Defendant Brent Rice intervened in Plaintiff s mother-
child relationship by making unfounded allegations ofbad mothering and emotional issues. It has
been held that the determination of primary parent is to be made at the time of sepmation Kansas
v. Kangas 406 N .W . 2d 628 (Minn. App. 1987). The court has held that when a determination of
primary caretaker has been made there must be a strong showing ofunfitness to grant custody to
the parent who did not serve as primary caretaker during the marriage Tanghe v. Tanghe 400
N.W.2d 389 (Minn. App. 1987).
12.1n2007 , Hennepin county court order (DC 292 618) finds that "Father committed domestic
violence against Mother." Susan Olson was appointed as Guardian Ad Litem in Hennepin
County Court that same year. In 2008, Defendant Susan Olson, Hennepin County Guardian Ad
Litem, wrote that she had not met with the Plaintiff or any of the Plaintiff s siblings. She wrote a
report stating that the Plaintiff was rebelling against Defendant Brent Rice's care and wanted a
change in custody. Defendant Susan Olson disregarded previous court findings of domestic
violence and the court Order for Protection that was currently protecting Plaintiff from
Defendant Brent Rice. She went to Plaintiffs school and traumatically removed Plaintiff from
school and her mother's care without any prior meeting or authorization. Then Susan Lach,
mother's attomey, called mother to inform her that the may not speak to the Plaintiff, essentially
reversing the OFP without the authority to do so.
13. In 2009, Defendant Sarah Kulesa, ofCarver County Social Services, acknowledged
Defendant Brent Rice's verbal and physical abuse, via letters sent to each party, but takes no
steps to protect Plaintifffrom this abuse. Bethany Koch was retained to represent Plaintiffin the
Juvenile proceedings.
14. In May of 2008, Hennepin County Order (27 -F A-292628) orders Plaintiff Annelise into
therapy with Defendant Judith Hoy who suspends Plaintiff s contact with her mother by phone
and in person, requiring contact be in a therapeutic setting. Defendant Judith Hoy cites parental
alienation as her reason for suspending contact, which is an argument that has been debunked
and is not legal or legitimate.

15. Defendant Cory D. Gilmer, Attomey at Law, represents Defendant Brent Rice on court
proceedings. On 05/08/08 Defendant Cory D. Gilmer personally threatens Plaintiff s mother via
email, stating, "l'm really going to enjoy watching you go down." Defendant Cory D. Gilmer
also represented Defendant Brent Rice although there was a known conflict ofinterest.
16. Defendant Brent Rice supplies misleading information to evaluators that tortuously interferes
with Plaintiff s Mother-Child Relationship and inflicts emotional distress on Plaintiff. Plaintiff is
hospitalized on June 10fr, 2008 for Suicidal Ideation due to the stress Defendant Brent Rice and
other Defendants have placed on her by interfering with the Mother-Child Relationship. Reports
state: "The patient states that she lives with her father but she is scared of him and doesn't feel
safe at home." Defendant Brent Rice, with the assistance of Carole Cole, voluntarily places
plaintiff in foster care on June 1ld', 2008 because of this incident. Carole Cole sees the report,
but helps to keep Plaintiff from contacting her mother.
17. Intentional Infliction of Emotional Distress: During Plaintiffs minority, Defendant Brent R.
Rice continuously, repeatedly, intentionally, and cruelly inflicted severe emotional distress and
medical neglect on Plaintiff Annelise Rice by threatening her, intimidating her, berating her,
manipulating her, and improperly admitting her to multiple foster homes and one locked facility
to squelch her reports ofhis abuse and sever her contact with the outside world. Such conduct
was intentional, outrageous, and designed to inflict severe emotional distress on Plaintiff'
18. Conspiracy to Deprive Plaintiff of Access to the Courts: During the course of the pendency
of child custody and visitation proceedings in the Hennepin and Carver County Court, Defendant
Brent R. Rice conspired with the other Defendants to deprive Plaintiffof her right to access to
and protection of the court by intentionally and maliciously discrediting Plaintiff and her
mother's accurate reports of Defendant Rice's abuse, by preventing Plaintiff from presenting
10
evidence to the court conceming her father s abuse, by maliciously attempting to deny Plaintiff
the benefit ofjuvenile court child protection proceedings and by denying Plaintiffthe benefrt of
counsel who truly would advocate for the child rather than advocating for the interests of
Defendant Rice. Defendants also prevented Plaintiff from testifying on her own behalfbefore the
court.
19. Tortious Interference with Mother-Child Relationship: From approximately 2005-2016,
Defendant Brent R. Rice intentionally, maliciously, and tortuously interfered with Plaintiffs
relationship with her mother by denying her contact with her mother, battering her as punishment
for having contact with her mother, isolating her from her mother, harassing and intimidating her
mother in the course of the custody litigation for the puryose of financially and emotionally
ruining her mother to ensure that her mother could no longer continue to fight to protect Plaintiff,
and blocking access to Plaintiffs and Plaintiffs mother's financial resources to deny them the
means to litigate Plaintiffs protection. All of this conduct by Brent R. Rice, who abused
Plaintiffs mother during the course oftheir marriage, was designed to punish Plaintiffs mother
for leaving him and was motivated by his misogyny and desire to avoid paying child support and
spousal maintenance.
20. Defendant Nicole Mercil interviewed Plaintiff s brothers, Tommy and Jayson, but did not
interview Plaintiff. Defendant Mercil falsified reports on the Plaintiff. Defendant Nicole Mercil
also interfered with Plaintiff s emergency medical root canal by attempting to force Plaintiffto
get the treatment with her abusive father rather than with her mother or foster care personnel
(10/01/08). Defendant Mercil also harassed Plaintiff and Plaintiff s mother.
l1
21. On July 1lth, 2008, Defendant Carole Cole, Carver County Social Worker, determines
Plaintiff s mother, Caroline, had caused "mental injury" of Annelise, and that Child Protective
Services were needed. Carole Cole provided no evidence for these claims'
22. Defendants Brenda Dehmer, Carole Cole, and Nicole Mercil placed Plaintiff Annelise back
in Defendant Brent Rice's care on August 28th, 2008 after Plaintiff had run away from Defendant
Brent Rice's home to be with her grandparents. The Defendants disregarded clear evidence of
abuse and mistreatment by Defendant Brent Rice and placed Plaintiff in a harmful situation'
23. In September of2013, the Minnesota Appellate Court reversed Carver County Court
Decision against Plaintiff s mother. According to the Minnesota Law Joumal, "'The reversal
prejudicial judicial conduct is unusual,' said Hennepin County Judge Kevin Burke. 'The fact that
I have been ajudge almost 30 years and can remember one other case, it doesn't happen very
often,' Burke said."
24. On summary judgment of absolute and qualified immunity to social workers who plaintiff
alleges maliciously used perjured testimony and fabricated evidence to secure Plaintiffs removal
from her mother, and that this abuse of state power violated her Fourth and Fourteenth
Amendment constitutional rishts.
REQUEST FOR RELIEF
State what you want the Court to do for you and the amount of monetary compensation, ifany,
you are seeking.
25. Because of the tortuous conduct set forth above, Plaintiff suffered severe physical pain and
suffering, fear, anxiety, depression, loss ofcivil rights and remedies, severe and permanent
t2
emotional and psychological pain and suffering, despair, loss ofyears with her mother and
siblings and other compensable damages.
26. The tortious conduct ofthe Defendants was reckless, malicious, wanton, outrageous, and in
total disregard for the rights and interests of Plaintiff, and, thetefore, the Defendants are liable to
Plaintiff for punitive damages to deter Defendants and others like the Defendants from engaging
in this same sort of misconduct. The amount ofCounty workers involved helped assure diffirsion
of responsibility in this case, which is why so many defendants have been listed in this lawsuit.
The amount requested must be a sufficient deterrent for counties to stop allowing practices that
diffuse accountability and lead to such egregious misconduct.
27. Plaintiff itemizes damages due her from Defendant Brent R. Rice as follows:
A. Intentional In{liction of Emotional Distress: $5,000,000.
B. Conspiracy to Deny Access to the Courts: S5,000,000.
C. Tortious Interference With Mother-Child Relationship: $5,000,000'
28. Plaintiff itemizes damages due her from Defendant Cory D. Gilmer as follows:
A. Professional Malpractice: $5,000,000.
B. Intentional Infliction of Emotional Distress: $5,000,000.
C. Conspiracy to Deny Access to the Courts: $5,000,000.
D. Tortious Interference With Mother-Child Relationship: $5,000,000.
29. Plaintiff itemizes damages due her from Defendant Bethany Koch as follows:
B. lntentional Infliction of Emotional Distress: $5,000,000.
D. Tortious Interference With Mothsr-Child Relationship: $5,000,000'
t3
30. Plaintiff itemizes damages due her from Defendant Sarah Kulesa as follows:
D. Tortious Interference With Mother-Child Relationship: S5,000,000.
31. Plaintiff itemizes damages due her from Defendant Jean Peterson as follows:
D. Tortious Interference With Mother-Child Relationship : $5,000,000.
32. Plaintiff itemizes damages due her from Defendant Judith Hoy as follows:
D. Tortious Interference With Mother-Child Relationship: $5'000,000.
33. Plaintiff itemizes damages due her from Defendant Richard Witucki as follows:
34. Plaintiff itemizes damages due her from Dsfendant Michael Garelick as follows:

D. Tortious Interference With Mother-Child Relationship: $5,000,000'
35. Plaintiff itemizes damages due her from Defendant Jolene Lukanen as follows:
36. Plaintiff itemizes damages due her from Defendant Nicole Mercil as follows:
37. Plaintiff itemizes damages due her from Defendant Catole Cole as follows:
D. Tortious Interference With Mother-Child Relationship: $5,000,000'
38. Plaintiff itemizes damages due her from Defendant Susan Olson as follows:
15
39. Plaintiff accordingly demands punitive damages: $15,000,000
Date:
3 / t b I t-t
Signarure ofPlaintiff 0
Mailing Address Zg3 g Fee.,uront 6vc g
[Y1ravW,ao\ts 9Sq'Og
Teleohone Number
q5Z _ j jc1_ 84 ri
Note: All plaintifTs named in the caption of the complaint must date and sign the complaint and
provide hisftrer mailing address and telephone number. Attach additional sheets ofpaper as
necessary.
l6
CASE 0:17-cv-00796-ADM-HB Document 1-1 Filed 03/17/17 Page 1 of 1 l?."f|1 fonl1-1g
,S a4 (Rc!. rzl12) CryIL COVER SHEET
ThcJs44clvllcovershee|anddreinformat|onconls|ncdhcreinneltherreplacenor9upDlmenr1heflingandservlceofp|ead|ngsoro!herpapersa5required
pro\ldedbY|ocalrulesofcoun'Thi5form'approvedbyth'|ud(ialconferenceofth.Un|t6dstAtcsinsefemberl974.isrequiredfortheuoltheC|erkoIcourt|.}re
burpose ofmitutfng the civil docket sheet (Sit: rNsrnu:TIoNSoN NE)'r PAGE oFTHIS FoRtd)
I. (a) PLAINTIFFS 1
DEFENDANTS ltt<,ralnp in ary$'Cewver uol,
Socitdl[' E14v{,c4$'El
Ri el Annelire, fr1crz, Broat R.
(b) Counry of Residence of Firsr Listed Plaintiff Comty ofRsidenc ofFirst Listed Defendant
(IN US PL4INTIFF (:ASES ONLY)
@rcEPT lN US PLA]MITT CASN)
NoTE: lN LAND CONDTMNATIoN cAsEs. us.E rHE.logArrtgry OF
THE TRACT OF LAND INryOLVED 1
ti ;' :-r
(c) Attomeys (F/u xana Addr#, d.tTeleph@ Nffiber) Atlafte.ys (IJKtNn) 'iLi
ii,iti , {i i;:l
II. BASIS OF JURISDICTION @/aceo, "x" ihowBsMr) CITIZENSHIP OF PRINCIPAL P X' in onr na lor Pl4innf
(Ft Diwrsit! CBet Oklt)
aI U.S. Covcflmht O 3 Faldd Qu.rtim PTF DEF PTF DEF
(rJ.s. Gouemne$ Not a Pury.) Citiz.n ofThis Std. }{ X, lncorporat d d' Pdncipdl Pl@ d 4 t4
Y2 U.s. Covcrnn {t O 1 Divdity Citid of tuoahq Stat 62 O2 IncorporatcdardP.inciprl Phc! Cl 5 O5

(ltldi.ote CinpBhip ofPatliet i lten 111) ofBusir.ss In tuolhcr Sttle
ct3 D 3 Fd.ign Narion O 6 c,5
o PERSONAL TNJURY PERSONAL INJURY 62t D g ReLr.d S.iarc O {22 App.al 28 USC 158 O 3?J P.lsc Cl.ihs Act
o 120 Mffi.c O 3l0Airplee O 365 Pgsond Injulr . ofPrcprty 21 USC 881 O ,123 Wilbdr.w.l o 400 slat RspPoniontnnt
J 130 Milld Acr n 3ri Airplnc Prod@i Product Lidbiliiy 590 orhd 2E USC 157 O 410 Altifiulr
o 140 Negod.bl IIJElndl Lrabiltty O 367 Hallll Car./ O 430 Bads |nd Bdkins
o O 320 k$nlt, Ub.l &
Pcconsl Injur/
|l O 330 Fldrd Fnployd3' Product Liability O 4?0 Rlckerd Influcnccd and
rl 152 Rcovery of Dcfa{llcd Lirbility al 368 Asb$tos Pcrsonll Conupt Organuahds
Studcnl Loans O 340 Marin ll 480 Con$mer C.cdii
(Excludes v.icrs) O 345 Mdin Prodoct Liabitity O 490 Cabl./Sai Tv
0 I J3 Recov.ry of Ovlrp.)dal Li.bilily PERSONAL PROPERTY O 850 S.cuiti.tcdd@ditiev
ofvctqe's Bcn fits al 350 Motd Vchiclc o 370 orhq F@d 862 Bl&k Lu8 (923)
o 160 St@khol&B' Suits d 3JS Motor v.lElc O 371 Tnth in Lading 20 Labor/M6.sn6r 863 DIWCDIWW (105(s)) O 890 Orhd Staiurory Acnons
o 864 SSID TitL X.\4 ll 891 ASnolturaj A.tj
o 195 Contrnct Prodd Liability Propdty D$Dagc ?40 Rlilway trbd Acl E65 RSI (4oJG)) al 893 Enviroruncdal MlttG
o .| 385 ProFdy Danrgc 751 Fdily {d Mcdicsl O E95 Frecdom of lDfomition
Prodrci Li.bility
?t{ Cnh* Labo( Liligation
O 791 Employ.6 Rli.m. d 899 Adnintutrdiv. Prc.e<lu@
O 2 l0 llnd CoDd.mdid lrcon Sdrity Acr 8?0 Tsg (LI.S. Phitrtitr AciRview or Appeal of
O 220 Forcclcu d 463 Alien Dcrsinc Agarcy Decator
O 230 Rdr t ce & EjcrrMt lt 4-{2 E$rplo}mcfi O E7l lRfftnd P{ty O tto Cdslituliolality of
O 240 Torts to Lud lt Hoosir,
443 16 USC 7609
D 245 Tort Produd Lithilily A.ommdltim
D 290 All Oitd Rtl Propcriy O 4-15 Amcr. P/Dislbilitiq O 535 Dear.\ Poalty
Olt r:
O 446 Ancr. VDi$bilili.s O 540 Mddamlls & Ol[cr 465 Othcr Innni8rari6
Othc. O 550 Civil Rig[6
O 448 Educ.tid d 5s5 ftim Condilion
Ct 560 Civil Dcbin - !
COURT MPLS
V, ORIGIN /Pr*" - 'x" inoR llts oh!9

dt o.ieinat d 2 Removed from O3 Remandd frorn O4 Reinslated or Cl 5 from 3 6 Multidistrict
wtl
tlc
Tt
' ' Proi.eedrns state Court Applldte Court Reopened Litigation
tVt4
VI. CAUSE OF
CHECK IF THIS IS A CI"ASS ACTION DIMANI} S CHECK YES only
COMPLAINT: UNDER RULE 23, F.R.CV.P. JURY DEMAND: d Yes O No
VIII. RELATED CASE(S)

IF ANY ,oot P11 DocKEr NUMBER D e eq
RECEIPT # AMOTJNT AFPLYINC IFP MAO.

'IJDGE
Car@ (re-TV^ aa- Lcs)

"-d,y

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CASE 0:17-cv-00796-ADM-HB Document 1 Filed 03/17/17 Page 1 of 16

UNrrep SrerBs DIsrrucr CouRr

Name A,nnre \i s e TZice

County, City H{'^,^CP\'\ , vV\rnzr46\eo \rs

Nu^" flr3nt ?l(.+

state&zbcode rttirtnc3otr 55 3"1

nu-" Nicob Aarail qA crrr.rrc.rritl F.nttt canrt Dlvicicrr

county, city CntfvCU, tfta,3 fr,a,

State&ZipCode l|ifnf Ofa 553Ic

2.d. Defendant No. 4

Name Bethany Koch c/o Carver County Family Court Division

Street Address 600 East 4th St.

County, City Carver, Chaska

State & Zip Code Minnesota 55318

Name Sarah Kulesa c/o Carver County Family Court Division

Street Address 600 East 4th St.

County, City Carver, Chaska

State & Zip Code Minnesota 55318

Name Jean Peterson c/o Hennepin County Family Court Division

Street Address 110 South 4th St.

County, City Hennepin, Minneapolis

State & Zip Code Minnesota 55401

Name Judith Hoy c/o Hennepin County Family Court Division

Street Address 110 South 4th St.

County, City Hennepin, Minneapolis

State & Zip Code Minnesota 55401

Street Address 110 South 4th St.

County, City Hennepin, Minneapolis

State & Zip Code Minnesota 55401

Name Richard Witucki c/o Hennepin County Family Court Division

Street Address 110 South 4th St.

County, City Hennepin, Minneapolis

State & Zip Code Minnesota 55401

Name Michael Garelick c/o Hermepin County Family Court Division

Street Address 110 South 4th St.

County, City Hennepin, Minneapolis

State & Zip Code Minnesota 55401

Name Jolene Lukanen c/o Hennepin County Family Court Division

Street Address 110 South 4th St.

County, City Hennepin, Minneapolis

State & Zip Code Minnesota 55401

Name Cory D. Gilmer

Street Address 700 Lumber Exchange Building

10 South 5th St.

County, City Hennepin, Minneapolis

State & Zip Code Minnesota 55402

Name Brenda K. Dehmer c/o Carver County Family Court Division

Street Address 600 East 4th St.

County, City Carver, Chaska

State & Zip Code Minnesota 55318

Name Michael Borowiak c/o Hennepin County Family Court Diviston

Street Address 110 South 4th St.

County, City Hennepin, Minneapolis

State & Zip Code Minnesota 55401

John Doe I, John Doe II, and John Doe III

{ Federal Question I Diversity of Citizenship

Chapter l3 : Sec. 24?: Deprivation of Rights under color of the law)

Plaintiff Name: State of Citizenship:

Defendant No. l: State of Citizenship:

Defendant No. 2: State of Citizenship :

Iheck here if additional sheets of paper are attached.

Gi Defendant(s) reside in Minnesota Gl Facts alleged below primarily occurred in

STATEMENT OF THE CLAIM

willful, wanton, and outrageous to constitute intentional in{liction of emotional distress.