October 20, 2022
VIA EMAIL & US MAIL VIA EMAIL & US MAIL
Jon W. Lubke Campaign Central Lakes College
34013 North Oak Drive President Charlier and staff
Jenkins, MN 56472 501 West College Drive
[email protected] Brainerd, MN 56401
[email protected] VIA EMAIL & US MAIL
Chelsey Perkins
Matt Erickson
Brainerd Dispatch
506 James Street
Brainerd, MN 56401
[email protected] [email protected] Re: In the Matter of Robin M. Sylvester v. Jon W. Lubke Campaign, Central
Lakes College, President Charlier and staff, and Brainerd Dispatch,
Chelsey Perkins, Matt Erickson
OAH 8-0325-38753
Dear Jon W. Lubke Campaign, President Charlier, Chelsey Perkins, and Matt Erickson:
The enclosed Fair Campaign Practices complaint (Complaint) was filed with the
Office of Administrative Hearings on October 19, 2022. The Complaint alleges violations
of Minn. Stat. §§ 10A.01, 211B.02, 211B.06, and 211B.15 (2022) in connection with
Mr. Lubke’s campaign for the Crow Wing County Commissioner, District 2 seat in the
general election to be held on November 8, 2022.
The complaint has been assigned for review to Administrative Law Judge Eric L.
Lipman. Within three (3) business days, the Administrative Law Judge will make a
preliminary determination of whether the complaint constitutes a prima facie violation of
Minn. Stat. §§ 211A.01-.14, 211B.01-.37 (2022). “Prima facie” means that the facts
alleged, if later proven as true, are sufficient to show a statutory violation.
If the Administrative Law Judge determines that a prima facie violation has not
been shown, the complaint will be dismissed. If a prima facie violation is demonstrated,
the matter will be set for a hearing and you will be provided an opportunity to submit a
response. You do not need to submit a response at this point.
October 20, 2022
Page 2
The complaint was filed within 90 days before the general election and includes a
request for an expedited probable cause hearing. If the Administrative Law Judge
determines that the complaint establishes a prima facie case, the law requires that the
probable cause hearing must be conducted within three (3) business days of the judge’s
assignment to this matter, or up to seven (7) days, for good cause shown. We will notify
you of the date of the probable cause hearing if one is required.
The complaint process is described in Minn. Stat. §§ 211B.32-.37, which can be
found on the Office of Administrative Hearings’ website at http://mn.gov/oah/.
Questions regarding the complaint process may be directed to one of our staff
attorneys at 651-361-7837 or [email protected].
Very truly yours,
JENNY STARR
Chief Administrative Law Judge
JS:mbg
Enclosure
cc: Robin Sylvester
