STATE OF MINNESOTA DISTRICT COURT

COUNTY OF DAKOTA FIRST JUDICIAL DISTRICT

Case Type: Harassment
_____________________________________________________________________

David Rucki, Samantha Rucki and Court File No.: 19AV-CV-17-1950

and o/b/o Minor Children Judicial Officer: Phillip Kanning

Petitioners
PETITIONERS’ NOTICE OF
EMERGENCY MOTION AND
EMERGENCY MOTION FOR
RELIEF AND MOTION TO HOLD
vs. RESPONDENT IN CONSTRUCTIVE
CIVIL CONTEMPT
Deirdre Elise Evavold,

Respondent
_____________________________________________________________________

TO: Deirdre Elise Evavold, Respondent above named, 2015 30th Street Ct South,
St.Cloud, Minnesota 56301:

PLEASE TAKE NOTICE, that Petitioners’ moves the Court, for an emergency

hearing, before the Honorable Phillip Kanning, Judge of District Court, as soon as counsel

may be heard for an Order as follows:

1. Ordering Respondent to immediately remove the entire post titled “Beaten

Before Born: Sandra Grazzini-Rucki Assaulted While Pregnant – Rucki

Wanted to Kill Baby Because ‘Wasn’t Perfect.’”, dated December 18, 2017,

from the Red Herring Alert Blog and /or any subsequent revisions to the post

along with any reposts and/or posts to Facebook and Twitter, which is a

direct violation of Minnesota Statue § 609.748, Sub.1a;

2. Ordering Respondent to immediately remove the entire post titled “Chief

Deputy Dakota County Attorney Phillip Procopowicz Gives It Another Go.”,

 dated December 23, 2017, from the Red Herring Alert Blog and /or any

subsequent revisions to the post along with any reposts and/or posts to

Facebook and Twitter, which is a direct violation of Minnesota Statue §

609.748, Sub.1a;

3. Ordering Respondent to immediately remove the entire post titled “But She

Looks So Sweet.”, dated December 27, 2017, from the Red Herring Alert

Blog and /or any subsequent revisions to the post along with any reposts

and/or posts to Facebook and Twitter, which is a direct violation of Minnesota

Statue § 609.748, Sub.1a;

4. Ordering Respondent to immediately remove the entire post titled “Protect A

Child-Go To Jail.”, dated December 28, 2017, from the Red Herring Alert

Blog and /or any subsequent revisions to the post along with any reposts

and/or posts to Facebook and Twitter, which is a direct violation of Minnesota

Statue § 609.748, Sub.1a;

5. Ordering Respondent to immediately remove the entire post titled “20/20

Denial of Substantiating Documents in the Grazzini-Rucki Case.”, dated

December 31, 2017, from the Red Herring Alert Blog and /or any subsequent

revisions to the post along with any reposts and/or posts to Facebook and

Twitter, which is a direct violation of Minnesota Statue § 609.748, Sub.1a;

6. Ordering Respondent to immediately remove the entire post titled “Fallout

from 20/20’s Fake Broadcast ‘Footprints in the Snow’.”, dated January 1,

2018, from the Red Herring Alert Blog and /or any subsequent revisions to

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 the post along with any reposts and/or posts to Facebook and Twitter, which

is a direct violation of Minnesota Statue § 609.748, Sub.1a;

7. Ordering Respondent to immediately remove the entire post titled “Judge

Halbrooks: Sandra Grazzini-Rucki Too Poor For Court Costs But Can Pay

Child Support.”, dated January 2, 2018, from the Red Herring Alert Blog and

/or any subsequent revisions to the post along with any reposts and/or posts

to Facebook and Twitter, which is a direct violation of Minnesota Statue §

609.748, Sub.1a;

8. Ordering Respondent to immediately remove the entire post titled “Police

Report, HRO: David Rucki is Dangerous, Not Safe Around Children.”, dated

January 3, 2018, from the Red Herring Alert Blog and /or any subsequent

revisions to the post along with any reposts and/or posts to Facebook and

Twitter, which is a direct violation of Minnesota Statue § 609.748, Sub.1a;

9. Ordering Respondent to immediately remove the entire post titled “More

Unedited 20/20 Footage.”, dated January 4, 2018, from the Red Herring Alert

Blog and /or any subsequent revisions to the post along with any reposts

and/or posts to Facebook and Twitter, which is a direct violation of Minnesota

Statue § 609.748, Sub.1a;

10. Ordering Respondent to immediately remove the entire post titled “From the

Archives. Long custody battle produces guilty verdict.”, dated January 14,

2018, from the Red Herring Alert Blog and /or any subsequent revisions to

the post along with any reposts and/or posts to Facebook and Twitter, which

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 is a direct violation of Minnesota Statue § 609.748, Sub.1a;

11. Ordering Respondent to immediately remove the entire post titled “David

Rucki Commits Apparent Mortgage Fraud”, dated January 21, 2018, from the

Red Herring Alert Blog and /or any subsequent revisions to the post along

with any reposts and/or posts to Facebook and Twitter, which is a direct

violation of Minnesota Statue § 609.748, Sub.1a;

12. Ordering Respondent to immediately remove the entire post titled “Unedited

Footage from ABC 20/20 – Reveals How Far ABC Will Go to Suppress

Abuse in Grazzini-Rucki Case.”, dated January 23, 2018, from the Red

Herring Alert Blog and /or any subsequent revisions to the post along with

any reposts and/or posts to Facebook and Twitter, which is a direct violation

of Minnesota Statue § 609.748, Sub.1a;

13. Ordering Respondent to immediately remove the entire post titled “A Child’s

Desperate Cry for Help: 2013 Audio of S.R. Begging for Protection from

Abusive Father, Dakota County Family Court.”, dated January 25, 2018, from

the Red Herring Alert Blog and /or any subsequent revisions to the post

along with any reposts and/or posts to Facebook and Twitter, which is a

direct violation of Minnesota Statue § 609.748, Sub.1a;

14. Ordering Respondent to immediately remove the entire post titled “Defying

Death: Sandra Grazzini-Rucki Comes Out of Hiding to Plead for Lives of Her

Children, Demand Justice.”, dated January 30, 2018, from the Red Herring

Alert Blog and /or any subsequent revisions to the post along with any

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 reposts and/or posts to Facebook and Twitter, which is a direct violation of

Minnesota Statue § 609.748, Sub.1a;

15. Ordering Respondent to immediately remove the entire post titled “Power

Corrupts: Post on Carver County Corruption Blog Warns About Judicial

Abuse of Authority.”, dated February 2, 2018, from the Red Herring Alert

Blog and /or any subsequent revisions to the post along with any reposts

and/or posts to Facebook and Twitter, which is a direct violation of Minnesota

Statue § 609.748, Sub.1a;

16. Ordering Respondent to immediately remove the entire post titled “Journalist

Michael Volpe Confronts Propaganda in Matt McNeil Show, Exposes Crimes

Committed in Grazzini-Rucki Case.”, dated February 8, 2018, from the Red

Herring Alert Blog and /or any subsequent revisions to the post along with

any reposts and/or posts to Facebook and Twitter, which is a direct violation

of Minnesota Statue § 609.748, Sub.1a;

17. Ordering Respondent to immediately remove the entire post titled “Trying

Too Hard.”, dated February 9, 2018, from the Red Herring Alert Blog and /or

any subsequent revisions to the post along with any reposts and/or posts to

Facebook and Twitter, which is a direct violation of Minnesota Statue §

609.748, Sub.1a;

18. Ordering Respondent to immediately remove the entire post titled “Letter to

Matt McNeil Show Criticizes Victim Shaming Message, Points to Abuse in

Grazzini-Rucki Case.”, dated February 11, 2018, from the Red Herring Alert

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 Blog and /or any subsequent revisions to the post along with any reposts

and/or posts to Facebook and Twitter, which is a direct violation of Minnesota

Statue § 609.748, Sub.1a;

19. Finding Respondent in constructive civil contempt of this Court’s, January 4,

2018 Order by failing to remove the article dated December 12, 2017 in its

entirety.

20. Waiving the time limits set forth in Minnesota Rule of Civil Procedure Rule

303.03 for serving of motion;

21. For such other and further relief as is just and equitable.

Said motion will be made to the Court based upon the Declaration of Lisa M. Elliott;

arguments of counsel, and all pleadings, records and files herein.

Dated: February 12, 2018 ELLIOTT LAW OFFICES, P.A.

By:_/s/ Lisa M. Elliott__________

Lisa M. Elliott, #201923
Attorneys for Petitioners
2409 West 66th Street
Minneapolis, MN 55423
612-466-7191
lisa@elliottlaw.net

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 ACKNOWLEGEMENT

The undersigned hereby acknowledges that costs, disbursements, and

reasonable attorney and witness fees may be awarded pursuant to Minn. Stat. §549.21,
Subd. 2, to the party or parties against whom the allegations in this pleading are
asserted.

Date: February 12, 2018

ELLIOTT LAW OFFICES, P.A.

By: _/s/ Lisa M. Elliott________

Lisa M. Elliott, #201923