Edwin Hahn and Republicans of Clay County vs. Republican Party of Minnesota, Clay County BPOU, Calvin Benson, David Hann, Rodney Johnson, Laurie Christianson, and Katie Koppelman
SUMMARY
1. On November 14, 2023, legal claims were filed against RINO Defendants in the County of Clay, District of Minnesota, on the counts of Theft, Conspiracy and Defamation, for alleged violations of Minnesota Statute §604.14; including multiple counts of intentional tort.
2. The legal claims are a response to the Republican Party of Minnesota’s lawsuit against Edwin Hahn and Republicans of Clay County BPOU filed on January 4, 2023.
3. The RINOs lost re-election of their long standing ally and Chair, Fred Wright, during the Republicans of Clay County BPOU election held on February 13, 2021.
4. Calvin Benson, David Hann, Rodney Johnson, Laurie Christianson, Katie Koppelman, and several other RINOs in this complaint refused to accept that their establishment-friendly clique lost, and they knowingly and willfully joined a conspiracy to harm Plaintiffs, Edwin Hahn and Republicans of Clay County, and change the outcome of the election in favor of their preferred co-conspirator, Rodney Johnson.
5. Consistent with the conspiracy’s purpose, the RINOs initially made two unsuccessful attempts to install their co-conspirator, Rodney Johnson, into the Republicans of Clay County BPOU Executive Committee and shift the balance of power to their favor.
6. Both acts attempted to breach the contracts, constitution, bylaws, and operating agreements of both the Republicans of Clay County BPOU and Republican Party of Minnesota.
7. Failing both attempts to achieve their purpose, and malcontent by their thwarted ambition, the RINOs then secretly joined with select executive committee members of the Republican Party of Minnesota, and public employees of U.S. Congressional Representative Michelle Fischbach to accelerate their efforts and engage in an unofficial removal process, attempting to usurp the offices of Edwin Hahn and Republicans of Clay County.
8. The RINO conspiracy then published and disseminated their false removal claims as an official narrative of the Republican Party of Minnesota and Republicans of Clay County BPOU, causing a breach of the membership contracts, constitution, bylaws, and operating agreements of both the Republicans of Clay County BPOU and Republican Party of Minnesota.
9. The RINOs cemented their acts by declaring themselves a new entity named the “Clay County Republican BPOU,” submitting false evidence of legitimacy, false claims of identity, converted Edwin Hahn and Republicans of Clay County BPOU identity, property, electronic data, and interfered with the State of Minnesota, Campaign Finance Board, financial institutions, and the Plaintiffs’ third party vendors.
10. As Edwin Hahn and Republicans of Clay County BPOU continued to legitimately fulfill their purpose, the RINOs continued in a pattern of harm and interference by making phone calls, mailing letters, sending emails, and making media appearances to confuse, mislead, and dissuade victims from participating in Plaintiffs Edwin Hahn and Republicans of Clay County’s legitimate business.
11. Edwin Hahn and Republicans of Clay County’s contracts with vendors, investments in, and voter participation in meetings, conventions, and caucuses, were harmed and Edwin Hahn and Republicans of Clay County suffered property loss, monetary loss, reputational damage, and severe emotional distress from the outrageous acts of the RINOs.
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1. The Uniform Declaratory Judgment Act (Minn. Stat. § 555.01 et seq.) permits any party in interest to have the courts determine any rights, status, and other legal relations, whether or not further relief is or could be claimed.
2. Counterclaim Plaintiffs, on the one hand, and Counterclaim Defendants, on the other, are parties in interest.
3. Counterclaim Plaintiffs dispute the validity and lawfulness of the unofficial executive committee meeting, attended by Benson, Koppelman, Dorsett, Olsgaard, and Hanson in person and by Christianson and Nelson via Zoom on March 8, 2022, including as follows:
a. Whether a quorum was present.
b. Whether there was a motion to go into a closed session.
c. Whether a closed session was permitted.
d. Whether Hahn was properly served.
e. Whether the executive committee was properly served.
f. Whether Hahn was properly removed.
g. Whether Hahn, if removed, was re-installed as Chair based on the 2022 Clay
County Convention.
h. Whether Johnson was properly installed.4. Counterclaim Plaintiffs dispute the validity and lawfulness of all actions taken by Counterclaim Defendants subsequent to the unofficial executive committee meeting, including as follows:
a. Canceling the Clay County Convention.
b. Refusing to acknowledge the 2022 delegates.
c. Converting ROCC’s property to the Clay County BPOU.5. Counterclaim Plaintiffs request that the Court make findings construing the validity and lawfulness of the unofficial executive committee meetings and the rights, status, and legal relations of the parties.
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1. Clay County BPOU stole personal property of ROCC.
2. As a result of the actions of Clay County BPOU, ROCC has incurred actual damages for civil theft.
3. ROCC is entitled to actual damages for civil theft, together with its costs and disbursements incurred herein.
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1. Counterclaim Defendants knew that the statements were false and were intended to defame Hahn.
2. Counterclaim Defendants specifically stated the following:
a. Hahn “has continued to falsely present himself as chairman in attempts to conduct party business.” In reality, the unofficial “executive committee” meeting was not valid or binding, and Clay County BPOU had never been the BPOU for Clay County.
b. Hahn “has even made threats against local and state party officials, including promising to inflict unrestrained retaliation upon their most vulnerable points of pain.” In reality, Hahn has never made threats of bodily harm.
c. Hahn’s “behavior caused the venue scheduled for tomorrow’s Clay County BPOU convention to cancel the event.” In reality, the venue canceled due to not wanting to get involved.
d. Hahn’s “dangerous and misleading behavior has caused” confusion. In reality, Hahn’s behavior was not “dangerous” or “misleading,” and Counterclaim Defendants caused confusion.
3. The false and defamatory statements were communicated to third parties, notably members of ROCC.4. The false and defamatory statements about Hahn imputed criminal conduct to him and constitute defamation per se.
5. As a result of Counterclaim Defendants’ false statements, Hahn has sustained general and special damages, including, but not limited to, loss of reputation, business opportunities, and emotional distress damages, in an amount to be determined at trial, plus prejudgment interest, costs, and disbursements.
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1. Upon information and belief, MN GOP and Clay County BPOU communicated with each other about how to remove Hahn from ROCC.
2. Upon information and belief, MN GOP and Clay County BPOU communicated with each other about how to convert ROCC’s property to Clay County BPOU.
3. Upon information and belief, MN GOP and Clay County BPOU communicated with each other about disseminating statements legitimizing Clay County BPOU.
4. Upon information and belief, MN GOP and Clay County BPOU communicated with each other about disseminating false and defamatory statements of fact about Hahn.
5. Counterclaim Defendants are jointly and severally liable for civil conspiracy.