1112312028 341 F STATE OF MINNESOTA IN DISTRICT COURT. COUNTY OF LAKE OF THE WOODS: NINTH JUDICIAL DISTRICT Type: Civil Other/Miscellaneous North Star Electric Cooperative, Inc., Plaintiff, Civil No. v. Ryan Jaenicke, Tina Fehlhaber, Northland | COMPLAINT AND JURY DEMAND Tire Inc., TiMar LLC, FJ Properties, LLC, Icebox LLC, Ryan Jaenicke as Trustee of the Ryan L. Jaenicke Trust, and John Doe Persons and Entities, Defendants. - [i] COMES NOW THE PLAINTIFF, North Star Electric Cooperative, Inc. (“North Star”), for its cause of action and claim for relief against Defendants Ryan Jaenicke, individually (“Jaenicke”), Tina Feblhaber, individually (“Fehlhaber”), Northland Tire Inc. (“Northland”), ‘TiMar LLC (“TiMar”), FJ Properties, LLC (“FJ”), Ryan Jaenicke as Trustee of the Ryan L. Jacnicke Trust (“Jaenicke Trust”) and John Doe Persons and Entities (“John Doe”) state and allege as follows: PARTIES [92] North Star is 2 Minnesota cooperative corporation, with its principal place of business address of 441 State Highway 172 Northwest, Baudette, Minnesota 56623. [93] Jaenicke, upon information and belief, is a resident of Roseau, Minnesota. ({4] _ Feblhaber, upon information and belief, is a resident of Badger, Minnesota. [15] On information and belief Jaenicke and Fehlhaber are (or were) romantically involved and business partners.{16] Northland, is a Minnesota corporation with a principal place of business address of 117 34 Street Northwest, Roseau, Minnesota 56751. Upon information and belief, Jaenicke is the sole shareholder and officer of Northland, [47] TiMar is a Minnesota limited liability company with a principal place of business address of 505 North Main Street, Badger, Minnesota 56756. Upon information and belief, Fehlhaber is ‘an owner and member of TiMar. Upon information and belief, Jaenicke is also affiliated with TiMar. TiMar owns, among other things, the real property located at 29687 685" Ave., Roosevelt, MN 56673 (“Roosevelt Property”). [18] FJ is a North Dakota limited liability company with a principal place of business address of 39947 River Oaks Drive, Roseau, Minnesota 56751. Upon information and belief, Jaenicke is an owner and member of FJ. Upon information and belief FJ owns, among other things, the real property located at 404 Main St. and 640 5 Ave., St. Thomas, ND 58276. [99] Icebox is a Minnesota limited liability company with a principal place of business address of 39947 River Oaks Drive, Roseau, Minnesota 56571 and a mailing. address of 36647 County Road 13, Salol, MN 56756. Upon information and belief, Jaenicke and Fehlhaber are the registered agents, owners, and members of Ieebox. Upon information and belief, Icebox owns, among other things, the real property located at 415 2" St. NE, Roseau, MN 56751; 811 2™ St. SE, Roseau, MN 56751; 216 Main Ave. N., Roseau, MN 56751; and 701 6" St. NE, Roseau, MN 56751 [910] Jaenicke Trust is upon information and belief a revocable trust with its principal place of business at 39947 River Oaks Drive, Roseau, Minnesota 56571. Upon information and belief, Jacnicke is the trustee of Jacnicke Trust. Upon information and belief, Jaenicke Trust owns, among other things the real property located at 39947 River Oaks Drive, Roscau, Minnesota 56751‘Sate of inn 1112172023 3:41 F [G11] John Doe is one or more unknown persons or entities who are named as Defendants herein under Minnesota Rule of Civil Procedure 9.08 and who are believed to be residents of, have their principal places of business in, or have property or assets in, Lake of the Woods County and Roseau County, Minnesota and other places in the United States and abroad. INTRODUCTION [12] Jaenicke operates a YouTube channel known as “Degenerate Passive Income”. [913] Degenerate Passive Income states it is: is a channel dedicated to discussing passive income in the form of Real Estate, Rental Properties, Crypto Currency buying, selling, mining, and degenerate plays in the Decentralized Finance space. If you are interested in tapping into the power of Passive Income, make sure to subscribe so you can follow my journey through some of the ups and downs I've encountered along the way, and learn from my mistakes to save you time and money. If Passive Income is your dream, let's make some money!!! ‘See https://www-youtube.com/@ryanjaenicke/about. [14] Jaenicke has openly posted about having had two cryptocurrency mining operations, one of which he has said was twenty minutes from him and the other was an hour anda half away. See https://www.youtube.com/watch?v=8)Lulofgo_két=481s,"Shale of Minnose swi2sie023 3a [{15] As set forth above, FJ Properties, which is owned in whole or part by Jaenicke, owns real estate in St. Thomas, North Dakota, which is approximately an hour and a half away from where Jaenicke resides, and as set forth above, TiMar owns the Roosevelt Property, which is located approximately twenty minutes from where Jaenicke resides. [416] Through Degenerate Passive Income and elsewhere, Jaenicke has emphasized the importance of abundant and cheap electricity for successful cryptocurrency mining operations and clearly connects his cryptocurrency operations with making passive income, and investing the same into various assets, including real estate and digital assets such as more eryptocurrency and NFTs. [17] Jaenicke also emphasizes a strategy to his viewers to “Be greedy, when other people are fearful, that is how you make money.” bttps://www.youtube.com/watch?'v-9NOmaY5Az80. {918} As illustrated on the Degenerate Passive Income YouTube channel and detailed herein, the Defendants have engaged in a greed fueled conspiracy to steal electricity from North Star for the purpose of powering their cryptocurrency mining operations, and to then hide the profits of their ill-gotten gains in various entities and assets. [119] Through this Complaint, North Star seeks to protect its members, recover the damages Defendants have caused, and disgorge from the Defendants all ill-gotten gains, so as to ensure that Defendants and other persons and entities do not engage in such actions in the future, [920] While it may be too much to ask, perhaps Defendants will follow Jaenicke’s advice of October 24, 2023, wherein he told those following him to: “Be a man” and to “own up to your mistakes.” https:/Avww youtube.com/watch?v=qiERe_2V-L8.1 TIONS, ({21] North Star is a not-for-profit member-owned electric power distribution cooperative, organized under Minnesota Statutes Chapter 308A, with a primary purpose to provide electric power to its member-owners within rural north central Minnesota, North Star's service territory includes Lake of the Woods, Koochiching, Roseau, and St. Louis counties. 922] To purchase and receive electric power from North Star, an entity and/or individual is required to submit a membership application and become 2 member of North Star. [123] From on or about August 25, 2005, until November 2, 2018, the then owners (“Prior Owners") of the Roosevelt Property were members of North Star and received electric power at the Roosevelt Property. [24] The Roosevelt Property was serviced by # high voltage distribution line (the “Line”) owned by North Star that serviced the area in which the Roosevelt Property is located. [925] On November 1, 2018, the Prior Owners of the Roosevelt Property informed North Star that they would be disconnecting from its electrical services as “[tJhey are having the place condemned and they have no intention of reconnecting the property anytime soon.” The disconnect request was documented by North Star as part of its usual policies and procedures. In accordance with the request from the Prior Owners, North Star disconnected its services to the Roosevelt Property on November 2, 2018. As part of the disconnection on November 2, 2018, North Star removed the meter from the Roosevelt Property and, for safety and security purposes, locked the meter box which houses the open meter socket. [926] On or about January 19, 2022, TiMar purchased the Roosevelt Property from the Prior Owners. At no point thereafter, however, did TiMar request to become a member of North Star nor did it request that North Star reconnect electrical services to the Roosevelt Property. “Stato of Minnese 12172023 3:41 F