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VERIFIED COMPLAINT FILED JUNE 10, 2026

Sexual Assault. Wage Theft.
DHS Fraud. Retaliation.

A DHS-funded sober home in St. Paul, Minnesota, became a place of exploitation. This is the official case file.

11
Months Unpaid Labor
$5,444+
DHS Fraud Collected
8+
Predicate Crimes
30+
Years Prison Exposure

⚖️ Verified Complaint

Ramsey County District Court, Second Judicial District — Pattern of Criminal Activity (Minn. Stat. § 609.903 et seq.)
Case Information:
Plaintiff: Adam Richard Cole, pro se
Defendants: Blank Slate Homes LLC, Elizabeth L. Glenna, Sara Leonhardt (a/k/a Sara Prigge), Demarcus Jones
Relief Sought: Treble damages ($5M–$8.5M), constructive trust over real property, prejudgment asset freeze, criminal referral, non-dischargeability in bankruptcy.
AllegationKey EvidenceStatutory Basis
Sexual assault (attempted rape) by resident Demarcus Jones on April 17, 2026. Plaintiff screamed for help for 5-10 minutes; staff did nothing.Police Report T26003877, MAARC #1000275294Minn. Stat. § 609.342
Mandated reporter failure – Sara Leonhardt (former probation officer) dismissed assault as "sleep-walking" and never reported.Exhibit D (Text messages)Minn. Stat. § 626.557
Wage theft / modern peonage – Plaintiff worked as Assistant and Full House Manager for 11 months. Received $0 cash wages. Defendants collected DHS Supplemental Services ($494.91/month) for Plaintiff's labor.Exhibit A ("free rent" text), Exhibit B (Employee Checklist)Minn. Stat. § 177.24, 18 U.S.C. § 1589
DHS provider fraud – False certifications of compliance with wage laws.DHS OIG File No. 1434453900022Minn. Stat. § 256.98
Retaliation & whistleblower retaliation – After reporting the sexual assault, Plaintiff's schedule was changed, threats were made, and he was forced into homelessness.Exhibit C (Beth Glenna's threat), Exhibit E (21 photos)Minn. Stat. § 181.932

🔪 Criminal Predicate Acts

The conduct alleged constitutes a pattern of criminal activity under Minnesota law.
CrimeStatuteMax SentenceDefendant(s)
Criminal Sexual Conduct (Attempted Rape)Minn. Stat. § 609.34230 years / $40,000Demarcus Jones
Aiding a Felon (Harboring)Minn. Stat. § 609.4955 years / $10,000Glenna, Leonhardt
Witness Tampering / CoercionMinn. Stat. § 609.275 years / $10,000Glenna, Leonhardt
Failure to Report Vulnerable Adult MaltreatmentMinn. Stat. § 626.557365 days / $3,000Glenna, Leonhardt, Kropp
Theft by False Representation (Wage Theft)Minn. Stat. § 609.525 years / $10,000Glenna, Leonhardt
Wrongfully Obtaining Public Assistance (DHS Fraud)Minn. Stat. § 256.985 years / $10,000Blank Slate, Glenna, Leonhardt
Financial Exploitation of a Vulnerable AdultMinn. Stat. § 609.23355 years / $10,000Glenna, Leonhardt

📁 Exhibits & Evidence

Every document referenced in the Verified Complaint. Click to download PDF.

Exhibit A — Sara's Text

"Free rent and share it part time with another guy?" Establishes unpaid labor arrangement.

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Exhibit B — Employee Checklist

Shows hire date 12/15/25 (actual start 11/1/25). Proof of House Manager role.

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Exhibit C — Beth's Threat

"We have many others willing to step up." Direct evidence of retaliation.

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Exhibit D — Dismissive Response

Sara focused on Demarcus's medical needs, not the sexual assault.

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Exhibit E — 21 Photos

Clean room after departure on May 23, 2026. Disproves abandonment.

View 21 Photos

Exhibit F — Second Assault Cover-Up

Text showing Demarcus punched another resident — pattern of concealment.

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Exhibit G — Mail Interference

Mail held by owners against explicit instructions. Continuing harassment.

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Exhibits O & P — Property Records

Ramsey County tax records for 653 Van Buren Ave and 789 Maryland Ave E.

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Download All Exhibits (ZIP, 45MB)

📅 Chronology of Events

From first day of residency to verified complaint. Click each entry for details.

📋 Agency Filings

Plaintiff has filed complaints with the following agencies. All confirmation numbers are documented.
AgencyReference / Case NumberStatus
St. Paul Police DepartmentTracking No. T26003877Under review by Sex Crimes Unit
Minnesota Adult Abuse Reporting Center (MAARC)Web Report No. 1000275294Referred to Ramsey County APS
DHS Office of Inspector GeneralFile No. 1434453900022Investigation in progress
MN Department of Health (OHFC)Formal Complaint (June 7, 2026)Acknowledged
MN Department of Labor & IndustryWage Theft Complaint (June 7, 2026)Under review
MN Department of Human RightsDisability Discrimination ComplaintIntake pending
MN Attorney General's OfficeConsumer Fraud ComplaintUnder review

⚡ Legal Fund: $150,000

Plaintiff is proceeding pro se while homeless. This fund will retain licensed counsel, cover litigation costs, and provide survival stability so Adam can keep his union job and stay in the fight.

0%

$0 raised of $150,000

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Where the Money Goes

  • Attorney fees — State RICO litigation (Pattern of Criminal Activity), trial, and potential federal RICO appeal$60,000
  • Expert witnesses (forensic accountant, psychologist, DHS compliance)$25,000
  • Discovery & litigation costs (depositions, subpoenas, e-discovery)$15,000
  • Survival & stability — rent, food, gas, hotel rooms, car maintenance (Plaintiff is homeless and at risk of losing his union job)$25,000
  • Appeal reserve (state and federal)$15,000
  • Filing fees, transcripts, court costs$5,000
  • Contingency reserve (trial exhibits, additional expert testimony, victim advocacy)$5,000
  • TOTAL$150,000

Plaintiff reserves all rights to assert federal RICO claims (18 U.S.C. § 1964(c)) in a separate federal action. No claim preclusion. No waiver. Survival funds are essential to keep Plaintiff housed and employed while litigation proceeds — this is not charity, it is stabilization during active legal warfare.