It happens. It is quite possible that it has not been initiated by ATC at all, so they would not have been aware. Especially noise complaints are usually either flagged by the noise monitoring system after the fact, or private citizens. Those take quite a bit of time to wander through the system until they can reach the correct person.
As usual, laws are only published in the national language, in this case german. There are no official translations i could find, the closest thing i could find was a mention in the
AIP. One thing to note here, as words in german are often combined words and get rather lengthy, they will be abbreviated especially in regards to laws, even in official texts which makes them barely readable, even for german nationals without legal training. The Luftverkehrsgesetz is usually shortened to
LuftVG (Air Traffic Act), and the Luftverkehrsordnung to
LuftVO (Air Traffic Ordinance).