05-CV-20-1045
Filed in District Court
State of Minnesota
6/24/2020 8:44 AM
STATE OF MINNESOTA IN DISTRICT COURT
COUNTY OF BENTON SEVENTH JUDICIAL DISTRICT
Court File No: ______
Rollie’s, LLC d/b/a Rollie’s Rednecks and Judicial Officer: _________
Longnecks, Case Type: 14 (Other Civil)
Plaintiff,
COMPLAINT
v.
UnitedCloud, Natalie Ringsmuth,
and Alexandra Monson,
Defendants.
By and for its Complaint against Defendants UniteCloud, Natalie Ringsmuth, and
Alexandra Monson, Plaintiff Rollie’s, LLC states and alleges as follows:
PARTIES AND VENUE
1. Plaintiff Rollie’s, LLC, doing business as Rollie’s Rednecks and Longnecks
(“Rollie’s”) is a Minnesota limited liability company with a principle place of business
located at 940 35th Ave NE, Sauk Rapids, MN 56379.
2. Defendant UniteCloud is a Minnesota non-profit corporation with a registered
address of 22 Wilson Ave NE #106, St Cloud, MN 56304.
3. Defendant Natalie Ringsmuth is an individual who resides in Stearns County,
Minnesota.
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05-CV-20-1045
Filed in District Court
State of Minnesota
6/24/2020 8:44 AM
4. Defendant Alexandra Monson is an individual who resides in Hennepin County,
Minnesota.
5. Venue is appropriate in the County of Benton as the acts giving rise to the
Complaint occurred therein, and Defendants targeted their activities to the County of
Benton.
GENERAL FACTS
6. Rollie’s operates a restaurant, bar, and entertainment venue in Sauk Rapids,
Minnesota.
7. Rollie’s is well-regarded in the community as a quality restaurant and bar.
8. Rollie’s has a reputation as a top venue for local and national live music
performances.
9. Rollie’s prides itself on being a place that welcomes all customers.
10. Because it is a restaurant, bar, and entertainment venue, Rollie’s reputation is
crucial to its business, as it brings in both customers and entertainment acts.
11. Defendant UniteCloud claims its mission is to provide “education and actionable
steps to resolve tension and restore dignity to all people in Central MN.”
12. Defendant Ringsmuth is the director of Defendant UniteCloud.
13. Despite its stated mission, Defendant UniteCloud has engaged in acts to raise
tension in central Minnesota by harassing persons and entities it perceives to hold
different views on political matters, social events, and government action.
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05-CV-20-1045
Filed in District Court
State of Minnesota
6/24/2020 8:44 AM
14. Defendants UniteCloud and Ringsmuth have, beginning on or around June 1,
2020, taken actions intentionally aimed at defaming, harassing, and interfering with
Rollie’s business.
15. Defendants UniteCloud and Ringsmuth have untruthfully attempted to paint
Rollie’s as racist or homophobic.
16. Defendants UniteCloud and Ringsmuth have repeatedly made numerous
untruthful public statements about Rollie’s claiming to report invented racist acts.
17. For instance, Defendants UniteCloud and Ringsmuth posted on Facebook a
purported “anonymous testimonial” stating “I watched Rollie come up to the bar and
confront the gay couple sitting next to us. I don’t remember his exact words, but he told
them to leave and used the word faggots.”
18. That purported testimonial is false. Such an event never happened.
19. Defendants UniteCloud and Ringsmuth stated after this purported testimonial “In
the years since then, I have heard more and more stories from other people about these
kinds of incidents there.”
20. That statement is also false. There have not been such incidents.
21. Defendants UniteCloud and Ringsmuth posted on Facebook another purported
“anonymous testimonial” stating “We had already received our food and were eating
when the bigot on-stage started in on a particular song. The chorus was: “Homo? Hell
no. You can get the f**k out of my country.”
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05-CV-20-1045
Filed in District Court
State of Minnesota
6/24/2020 8:44 AM
22. This statement is also false. No such performance was ever given.
23. Defendants UniteCloud and Ringsmuth posted on Facebook another purported
“anonymous testimonial” stating “When I was there, the owner of Rollie’s suggested that
I was Native American and I was just in the right place for drugs, drinks, and to ‘make
money the best way we know how.’”
24. This statement is also false. The owner of Rollie’s never made such statements.
25. Defendants UniteCloud and Ringsmuth posted on Facebook another purported
“anonymous testimonial” stating “I saw a black baby doll behind the bar, HANGING BY
ITS NECK.”
26. This statement is also false. Rollie’s has never had any baby doll hanging by its
neck on its premises.
27. These false statements were intentionally invented and posted with the purpose
of defaming Rollie’s.
28. Defendants UniteCloud and Ringsmuth have made other false statements.
29. Defendants UniteCloud and Ringsmuth know, or should know, that the
purported anonymous testimonials are false or contrived.
30. Despite knowing that the anonymous testimonials are false and contrived,
Defendants UniteCloud and Ringsmuth posted those statements.
31. Defendants UniteCloud and Ringsmuth are intentionally attempting to create
controversy by trying to blame Rollie’s for invented racist activities.
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05-CV-20-1045
Filed in District Court
State of Minnesota
6/24/2020 8:44 AM
32. Defendants UniteCloud and Ringsmuth are intentionally doing this to generate
unfounded outrage aimed at Rollie’s to cause Rollie’s to lose customers and entertainers.
33. On information and belief, Defendants UniteCloud and Ringsmuth are doing this
because they perceive Rollie’s and its owners to have different views than Defendants on
political matters, social events, and government actions.
34. In addition to making false statements, Defendants have taken actions to directly
interfere with Rollie’s business.
35. Defendant Monson created and administrates a Facebook group called “Crashing
Rollies.”
36. The Facebook group states “this is a group where we can discuss the possibility of
crashing Rollie’s in sauk rapids [sic] with BLM and other allies! We need about 50 (or
more brave souls . . . .”
37. The “Crashing Rollie’s” group states its purpose is to “take the most space” at
Rollie’s while “buying the least.”
38. The “Crashing Rollie’s” group is trying to keep actual customers from Rollie’s.
39. Members of “Crashing Rollie’s,” including Monson, have discussed bringing
firearms into Rollie’s.
40. The “Crashing Rollie’s” group is also planning to take potentially violent actions
to disrupt Rollie’s business.
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05-CV-20-1045
Filed in District Court
State of Minnesota
6/24/2020 8:44 AM
41. Many members of Defendant UniteCloud and the “Crashing Rollie’s” group have
expressed the intent to harm the employees of Rollie’s and destroy Rollie’s property.
42. All Defendants are coordinating together to interfere with Rollie’s business.
43. Defendants have encouraged people to use social media to harass Rollie’s.
44. Defendants encouraged members of Defendant UniteCloud and the Crash Rollie’s
group to write false and defamatory reviews on restaurant review websites, including
Google Reviews and Yelp.
45. Defendants encouraged members of Defendant UniteCloud and the Crash Rollie’s
Group to use a website called TownSquare to send harassing statements to Rollie’s.
46. For instance, one person sent Rollie’s a TownSquare message stating “I hope your
disgusting restaurant goes out of business and you die penniless and miserable. Fucking
Ghoul.”
47. Another TownSquare message stated “You f’n racist pig.”
48. Defendants encouraged these messages to be sent, and on information and belief
helped write some of the messages.
49. Defendants are again repeating untrue statements and false allegations to
encourage people to harass Rollie’s online.
50. Defendants stated goal is to drive Rollie’s out of business by ruining its reputation
and standing in the community.
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05-CV-20-1045
Filed in District Court
State of Minnesota
6/24/2020 8:44 AM
51. Defendants have organized a campaign to have radio station KNSI in St. Cloud,
Minnesota, stop airing a program which features the owner of Rollie’s.
52. This campaign is based on false statements and untrue allegations.
53. Rollie’s caused a cease and desist demand to be served on Defendants UniteCloud
and Ringsmuth, demanding Defendants cease their unlawful activities and remove the
untrue social media postings.
54. Despite receiving the cease and desist demand, Defendants have persisted in their
unlawful activities.
55. Despite receiving the cease and desist demand, Defendants have left the untrue
social media postings online.
56. Defendants acts are unjustified, unlawful, and based on untruths.
57. Defendant Ringsmuth has been personally involved in these harassing and
defamatory activities, going beyond her duties as director of Defendant UniteMinnesota
and acting in her personal capacity.
58. Defendant’s actions have caused Rollie’s actual damages in the form of a loss of
reputation, loss of customers, and loss of business.
COUNT I: DEFAMATION
(Defendants UniteCloud and Ringsmuth)
59. Rollie’s restates and realleges all preceding paragraphs.
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05-CV-20-1045
Filed in District Court
State of Minnesota
6/24/2020 8:44 AM
60. Defendants UniteCloud and Ringsmuth made false statements about Rollie’s on
social media.
61. Defendants UniteCloud and Ringsmuth made false statements about Rollie’s
verbally.
62. These false statements were communicated to other persons, including but not
limited to Defendants UniteCloud and Ringsmuth’s “friends” and “followers” on social
media.
63. Defendants UniteCloud and Ringsmuth’s false statements tend to harm Rollie’s
reputation and lower the community’s esteem of Rollie’s.
64. Defendants UniteCloud and Ringsmuth have defamed Rollie’s, and caused
Rollie’s to suffer damages in an amount to be proven at trial, but in excess of $50,000.
COUNT II: TORTIOUS INTERFERENCE WITH BUSINESS RELATIONS
(All Defendants)
65. Rollie’s restates and realleges all preceding paragraphs.
66. Rollie’s has a reasonable expectation of business from customers.
67. Rollie’s has a reasonable expectation that it will be able to book performers of
sufficient appeal and reputation to bring in additional customers.
68. Defendants are aware that Rollie’s has customers and books performers.
69. Defendants intentionally, wrongfully, and without justification have interfered
with Rollie’s reasonable expectations.
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05-CV-20-1045
Filed in District Court
State of Minnesota
6/24/2020 8:44 AM
70. Had Defendants not taken their wrongful and unjustified acts, Rollie’s would have
realized the fruits of its business expectations.
71. Defendants have tortuously interfered with Rollie’s business expectations.
72. Rollie’s has suffered damages in an amount to be proven at trial, but in excess of
$50,000.
WHEREFORE, Plaintiff Rollie’s, LLC requests that the Court issue an Order as follows:
1. Finding that Defendants UniteCloud and Ringsmuth defamed Rollie’s;
2. Finding that Defendants tortuously interfered with Rollie’s business
relations;
3. Awarding Judgment in favor of Rollie’s and against Defendants on all
counts;
4. Awarding Rollie’s damages against Defendants, jointly and severally, in an
amount to be proven at trial, but in excess of $50,000.00;
5. Issuing an injunctive order prohibiting Defendants from further defaming
Rollie’s or interfering with Rollie’s business relations;
6. Awarding Rollie’s its costs and damages; and
7. All other relief that this Court deems just and equitable.
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05-CV-20-1045
Filed in District Court
State of Minnesota
6/24/2020 8:44 AM
Dated: June 23, 2020 CHESTNUT CAMBRONNE PA
By: _/s/ Jeffrey C. O’Brien___________
Jeffrey C. O’Brien (#304852)
Emeric J. Dwyer (#389471)
100 Washington Avenue South,
Suite 1700
Minneapolis, MN 55401
Telephone: (612) 339-7300
jobrien@chestnutcambronne.com
edwyer@chestnutcambronne.com
ATTORNEYS FOR PLAINTIFF
ACKNOWLEDGMENT REGARDING SANCTIONS
Pursuant to Minn. Stat. § 549.211, subd. 1, the undersigned acknowledges that
non-monetary sanctions and monetary sanctions, such as costs, disbursements, and
reasonable attorney and witness fees, may be imposed under Minn. Stat. § 549.211,
subd. 3.
Dated: June 23, 2020 /s/ Jeffrey C. O’Brien
Jeffrey C. O’Brien
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