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EXECUTIVE SUMMARY & URGENCY We are engaging a high-caliber, out-of-state Administrative Law expert to consult on a complex, high-stakes legal matter in Minnesota involving the DHS's enforcement actions against a Medicaid provider (1-0 Granny's Helpful Hands, LLC) and its executive team. This is not a standard compliance review. We are fighting a systemic abuse of process and potential unlawful discrimination (Race/Disparate Treatment), as evidenced by an official referral from the OLA to the MDHR. The primary goal is to use administrative law and due process failures to collapse a politically motivated criminal prosecution (RICO/Aggravated Theft). Due to the alleged bias and hostile political climate in MN, an external, unbiased perspective is non-negotiable. II. THE CORE CONFLICT: DUE PROCESS DENIAL AND MALICE The foundation of our strategy rests on proving the State engaged in malicious prosecution stemming from a deliberate administrative failure: Administrative Failure: The DHS imposed a severe sanction (payment withhold) on Granny's but illegally denied the Executive Director, Robin Stepney, the statutory right to appeal by never issuing a mandatory Notice of Disqualification (NOD) or a Contested Case Hearing (CCH) schedule. Racial Disparity (The "Two-Tier System"): We are leveraging the public, documented contrast between the State's actions: Black-Owned Entity (Granny's): Charged with RICO for complex regulatory issues and debt service. White-Owned Entity (NUWAY Alliance): Resolved $18.5 Million in intentional fraud (kickbacks) via a non-criminal civil settlement. Judicial Precedent: We are using successful legal motions from peer cases (Mohamud/Yusuf) to argue that the charged conduct is, at most, a regulatory violation, not a criminal enterprise, making the prosecution legally untenable. III. SCOPE OF WORK & CONSULTATION DELIVERABLES The consultant will work remotely with our lead advocate and operational executive to ensure all strategic and legal filings are robust and airtight. STRATEGY VALIDATION & RISK ANALYSIS (Immediate Priority): Thoroughly review the complex factual record: DHS internal emails (showing foreknowledge and acceptance of the operational manager, "Chavez," which destroys the State's concealment theory), the POLA Submission, and financial documentation (proving the $145k was used for debt service). Validate the legal strategy for the upcoming challenges in three separate domains: Criminal Defense, Judicial Mandamus, and Civil Rights (MDHR). DUE PROCESS REMEDY EXECUTION: Consult on the drafting and legal framework for the Written Demand for a Contested Case Hearing (CCH). Consult on the drafting of the Petition for a Writ of Mandamus (and Declaratory Relief) to compel the DHS Commissioner to grant the CCH that was illegally denied. This requires mastery of the Minnesota Administrative Procedure Act and recent statutory changes (Minn. Stat. § 15.013). BIAS AND DISPARATE ENFORCEMENT ANALYSIS: Structure the legal arguments proving the RICO prosecution is tainted by unlawful discrimination, leveraging the official OLA referral to the MDHR. IV. REQUIRED EXPERTISE & TOP 5 STRATEGIC SKILLS Category: Regulatory Law (Primary), Business Law (Secondary) Required Qualification: Must be an actively licensed attorney outside the State of Minnesota (Strict requirement). Familiarity with Rule 5.5 regarding temporary legal practice. Top 5 Strategic Skills: Administrative Appeals & Writs of Mandamus: Proven track record challenging agency actions and compelling administrative hearings in state court. Regulatory Compliance (Healthcare/DHS): Deep knowledge of state licensing laws, Medicaid/Medicare regulations, and civil/criminal disqualification procedures. Complex Litigation Strategy: Ability to integrate evidence from criminal, civil, and administrative domains to build a unified defense against prosecutorial overreach. Due Process & Civil Rights Law: Expertise in Fourteenth Amendment claims regarding state deprivation of property/liberty interests and analyzing government actions for disparate impact. Evidence Synthesis & Fact-Pattern Analysis: Ability to quickly dissect conflicting government narratives (e.g., DHS claims vs. OIG actions) and validate factual claims against legal theories. V. COMPENSATION AND LOGISTICS Rate: Competitive Hourly Rate (Based on expertise, commensurate with high-level legal consulting in the $100–$300+ range). Project Structure: Initial compensation will be hourly for strategy and document review (estimated 10-20 hours). Fixed-price contracts may be negotiated for specific, clearly defined drafting deliverables (e.g., the final Mandamus Petition). We are seeking a seasoned expert who understands that this is not just a regulatory compliance review, but a legal fight against institutional bias and abuse of process. Your role is vital to ensuring fairness in a corrupted system.