Part Seven of the Wilson v. Reliable Street Inc., et al series.
Dangerous Precedent
District Court Sides With Ames, Iowa Businesses’ Argument That They Cannot Be Held Liable for Statements to Civil-Rights Investigators—even if Knowingly False, Malicious, and Causing Serious Harm

By Sondra Wilson | Updated September 26, 2026

How an Unresolved Question of Iowa Law Ended a Civil-Rights Case Before Discovery or a Jury Trial

By the beginning of 2026, Wilson v. Reliable Street Inc., et al. was moving toward something that had never yet occurred in the case: discovery and a jury trial.

The district court had approved a discovery plan. Initial disclosures had been ordered. Electronic evidence was expressly contemplated. A four-day jury trial was scheduled for August.

One libel claim had survived the sweeping October 4, 2024 dismissal of my other claims. It concerned statements defendants submitted to the Iowa Civil Rights Commission during the investigation of the discrimination complaint I had filed against Reliable Street and Lockwood Café.

Then the legal question changed.

In April 2026, defendants moved for summary judgment and argued that the surviving claim should never reach a jury because their submissions to the ICRC were protected by absolute litigation privilege.

Their argument was not merely that the statements were true or that I could not prove malice. They made those arguments in the alternative.

Their primary argument was much broader.

In their Statement of Material Facts and Memorandum in Support of Summary Judgment (D0090), defendants explained what absolute privilege would mean:

“The dispositive feature of the absolute privilege is that it bars recovery even if the plaintiff can prove the statements were false, made with actual malice, and caused serious harm.”

They continued:

“No matter what discovery might reveal about the content of Defendants’ statements or Defendants’ subjective state of mind, those facts cannot defeat an absolute privilege.”

— D0090, § I(d), p. 8.

That argument changed the significance of the case.

I had been seeking discovery into matters including authorship, drafts, native electronic files, metadata, revision history, communications among defendants, and the circumstances under which disputed documents were prepared and submitted. I contended that those materials could bear directly on falsity, knowledge, authorship, sequencing, and malice.

Defendants' response was that, if absolute privilege applied, none of that could change the result.

Their April 27 Reply in Support of Summary Judgment and Resistance to Motion to Compel (D0096) stated the point expressly:

“No discovery, no amendment of the pleading, and no characterization of Defendants’ internal document-preparation process can change the legal character of the Iowa Civil Rights Commission proceeding in which those statements were made.”

The dispute had therefore become larger than whether particular accusations against me were true.

It became a question about what accountability is legally available when allegedly false or malicious statements enter the investigative stage of Iowa's civil-rights process.

The District Court Adopted the Absolute-Privilege Rule

On July 15, 2026, Judge Angela Doyle granted defendants' motion for summary judgment.

Her Order Granting Summary Judgment (D0111) first acknowledged an important point:

“No Iowa appellate court has directly addressed whether statements made in direct response to an ICRC investigation, as opposed to statements made in formal ICRC contested case hearings, are absolutely privileged.”

The court nevertheless concluded that the investigative process was sufficiently quasi-judicial:

“The Court concludes that the ICRC conducts proceedings are quasi-judicial in nature, and that statements made in direct response to an ICRC investigation are absolutely privileged under Iowa law.”

The court then applied that rule to the surviving claim:

“The Court finds the statements at issue in Count II are absolutely privileged as a matter of law because they were part of a quasi-judicial proceeding and the absolute litigation privilege applies.”

And the court explained that the privilege turned:

“not on the content or truth of those statements.”

The surviving claim was dismissed with prejudice before the disputed discovery was completed and before a jury heard the facts.

That is the ruling at the center of Dangerous Precedent.

But the Privilege Fight Was Only One of Two Things Happening

At the same time defendants were attempting to eliminate the surviving libel claim, I was trying to rebuild the broader case.

On January 6, I filed a proposed 115-page Second Amended Petition supported by nearly 300 pages of exhibits. It attempted to correct pleading and evidentiary problems that had affected the 2024 case, distinguish the roles of the individual defendants and business entities, incorporate later-occurring conduct, add Love Club LLC, and plead additional claims—including a constitutional equality claim under the Iowa Constitution.

That filing generated a separate fight over amendment.

After defendants objected to several citations in one exhibit, I withdrew the challenged authorities. Judge Doyle later denied the January motion for leave without prejudice and gave me directions for how a renewed proposed amendment should be structured.

I followed those directions and filed a substantially revised petition.

So two legal tracks were now running beside each other:

Could I obtain leave to put the broader reconstructed case before the court?

And:

Could the one claim already headed toward discovery and trial be eliminated under absolute privilege?

On July 15, Judge Doyle answered both questions in separate orders entered the same day.

She denied leave to file the Revised Second Amended Petition.

Then she granted summary judgment on the sole surviving claim.

The broader case never became operative, and the remaining claim never reached a jury.

Why This Matters Beyond My Case

The appellate significance is straightforward.

The district court itself recognized that Iowa's appellate courts had not directly decided whether statements submitted in response to an ICRC investigation, as distinguished from a formal contested-case hearing, receive absolute privilege.

That distinction matters because absolute privilege is different from qualified privilege.

Qualified privilege can protect good-faith participation while still permitting liability in circumstances such as actual malice. Absolute privilege can foreclose the defamation claim regardless of falsity or malice if the privilege applies.

My position is that Iowa law does not require such sweeping immunity at the preliminary investigative stage of the civil-rights process—and that separate conduct involved in allegedly creating, altering, coordinating, or misleadingly presenting evidence should not automatically disappear into a privilege attached to the eventual act of submission.

Whether Iowa's appellate courts agree remains to be decided.

The statewide question is therefore not whether every factual allegation I have made will ultimately be proved.

It is more fundamental:

When someone submits allegedly false or malicious factual accusations during the investigative stage of an Iowa civil-rights complaint, does Iowa law provide absolute immunity from defamation liability simply because those accusations entered a government civil-rights process?

And there is a second question intertwined with it:

Can discovery into the creation, authorship, alteration, coordination, and provenance of disputed evidence be cut off because the final submission itself is later classified as absolutely privileged?

Those questions can affect far more than this lawsuit.

Iowa's civil-rights process exists for people who report discrimination. Its integrity depends both upon protecting people who participate in that process and upon preserving confidence that the process will not become a shield for knowingly false or malicious factual accusations.

This installment reconstructs how my case reached that question—from an active discovery-and-jury-trial track, through two attempts to amend the petition, a dispute over electronic evidence, defendants' summary-judgment motion, two same-day dispositive rulings, and my final district-court challenge to absolute privilege.

The record begins with a case that was being prepared for trial.

Table of Contents

I. The Case Moved to an Active Discovery-and-Trial Track

II. January 6: I Filed a 115-Page "Second Amended Petition" with Evidentiary Exhibits, Seeking to Rebuild the Case on a Complete Record

III. Defendants Challenged Exhibit G—and Asked the Court to Deny the Amendment

IV. Discovery Had Been Agreed and Ordered—Then Defendants Withheld the Evidence I Sought and Argued It Could Not Matter

V. I Followed Judge Doyle’s Instructions and Filed a "Revised Second Amended Petition"

VI. July 15 — Two Same-Day Orders Closed Both Paths

VII. My Final District-Court Fight: Reconsideration and a 53-Page Challenge to Absolute Privilege

IX. From Litigation Burden to Ballot-Access Harm: Part Eight: Election Interference

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August 1, 2025-January 2, 2026:
I. The Case Moved to an Active Discovery-and-Trial Track

 

 

By the second half of 2025, Wilson v. Reliable Street Inc., et al. had an unusual posture.

Judge Currie's October 4, 2024 ruling had dismissed most of my claims, but the written-defamation claim remained alive. The case had then passed through the settlement and reconsideration disputes documented in [Plausible Deniability]. I had not abandoned the lawsuit, and I still intended to file a substantially reorganized pleading supported by the documentary record.

What happened next matters because it establishes the procedural baseline immediately before the events examined in this installment.

The case was moving toward discovery and a jury trial.

August 1, 2025:
A Rule 1.944 Notice Put the Remaining Case Back on the Clock

On August 1, 2025, the clerk issued the Rule 1.944 Dismissal Notice (D0068).

The notice listed a dismissal date of January 1, 2026 and stated:

“Pursuant to the provisions of Rule of Civil Procedure 1.944, this case shall be tried or shall be subject to dismissal on the above date unless an order is entered as provided by said rule.”

— D0068, p. 1.

It also expressly warned:

“Post December 31 trial or trial-setting conference dates will not serve to avoid dismissal.”

— D0068, p. 1.

For lay readers, Rule 1.944 is essentially a docket-management rule designed to prevent civil cases from remaining inactive indefinitely. The notice did not decide whether my surviving claim had merit. It meant that unless the case was tried or the court entered an appropriate continuation order, it would be automatically dismissed.

That procedural deadline forced the unresolved case back toward active management.

October 13:
The Court Ordered the Case Assigned for Trial

On October 13, the court entered [D0070 — Order to Schedule Trial].

The entire operative direction was straightforward:

“The District Court Administrator shall schedule a trial setting conference to assign this case for trial.”

— D0070, p. 1.

Later that same day, the court issued the [Notice of Trial Setting Conference — D0071], setting the conference for October 28.

The notice stated:

“A firm trial date shall be established in accordance with the Supreme Court's time standards as provided by Chapter 23, Iowa Court Rules.”

— D0071, p. 1, ¶2.

It further required the parties to prepare for the next stage of litigation:

“Prior to the trial-setting conference, the parties must file a Trial Scheduling and Discovery Plan, Iowa Court Rule 23.5-Form 2.”

— D0071, p. 1.

Those two October 13 filings are important because they show the court was not merely keeping the surviving claim nominally alive.

The court was directing that the case be assigned for trial and that the parties prepare a discovery plan.

December 3:
Judge Doyle Ordered the Parties to Begin Planning Discovery

The next major step came on December 3.

In [Judge Doyle's Order Re Discovery Plan — D0072], the court noted that the required discovery conference had not yet occurred and that no Trial Scheduling and Discovery Plan had been filed.

Judge Doyle quoted Iowa Rule of Civil Procedure 1.507, which required the parties to:

“consider the nature and basis of their claims and defenses and the possibilities for promptly settling or resolving the case; make or arrange for the disclosures required by rule 1.500(1); discuss any issues about preserving discoverable information; and develop a proposed discovery plan.”

— D0072, p. 1.

For readers unfamiliar with civil litigation, discovery is the pretrial process through which the parties obtain information and evidence from one another. It can include documents, electronic communications, interrogatories, requests for admission, depositions, and other material needed to test what the parties are alleging.

Judge Doyle's order specifically required the discovery plan to address:

“Subjects on which discovery may be needed, when discovery should be completed, and whether discovery should be conducted in phases or be limited to or focused on particular issues.”

It also required discussion of:

“Issues about disclosure, discovery, or preservation of electronically stored information, including the form or forms in which the information should be produced.”

— D0072, p. 2.

That language was particularly important in this case because electronic communications and disputed electronic records had become central to the evidentiary issues I was attempting to develop.

Judge Doyle ordered the parties to hold the conference no later than December 24 and to file the resulting plan within seven days afterward.

By December 3, therefore, the case was no longer simply sitting on the docket with one claim technically remaining.

The court had ordered the parties to begin planning how evidence would actually be exchanged.

The Discovery Conference Began While I Was Finishing the Amended Pleading

Defense counsel contacted me the next day.

Paul Esker wrote:

“Please let me know if or when you want to have a phone call to do a discovery conference about this case.”

He added:

“The deadline in the Order below is December 24. Otherwise, I will assume you do not intend to continue to prosecute this matter.”

— December 4, 2025 email later attached to the discovery-plan materials.

I responded that same evening and told him:

“My semester ends on the 15th, and—as you can imagine—things are very hectic in school now toward the end of the semester.”

And:

“My second amended petition is nearly finished, but I won't get to filing it until after finals, at which time I will file asap."

— December 4, 2025 email.

That contemporaneous exchange matters because it establishes the posture before January 6.

I was participating in the discovery process, and I had already informed defense counsel that the Second Amended Petition was nearly finished and would be filed after finals.

Electronic Evidence Became Part of the Agreed Discovery Framework

The resulting [Trial Scheduling and Discovery Plan — D0073] expressly identified the case as a jury case and stated that the amount in controversy exceeded $10,000.

The parties also reached an agreement about electronically stored information.

Attachment A stated:

“Any ESI will be produced in pdf format.”

But it preserved an important exception:

“Nothing in this provision waives any party's right to request production in native format or with metadata where relevance, authenticity, or completeness is at issue and supported by good cause.”

— D0073, Attachment A, ¶1.

The attachment also provided:

“All document productions will be Bates-stamped by the producing party.”

and:

“The parties consent to service by email on all documents required to be served in this matter, including discovery requests and responses.”

— D0073, Attachment A, ¶¶2–3.

These provisions become important later in Dangerous Precedent.

Before defendants moved for summary judgment under absolute privilege, the discovery framework expressly contemplated electronically stored information and preserved the ability to request native files or metadata where authenticity or completeness was at issue.

That is a significant contrast with the later argument that discovery could not matter.

The Disagreement Was About Timing — not Whether Discovery Should Occur

The principal disagreement concerned the date for initial disclosures.

The filed plan stated:

“The parties were unable to reach agreement regarding the timing of initial disclosures.”

— D0073, Attachment A, ¶4.

Defendants requested February 1, 2026.

I requested May 30.

But I was not refusing discovery. Attachment A expressly explained that I was finalizing the forthcoming pleading:

“Plaintiff is in the process of finalizing and filing a Second Amended Petition, together with a Motion for Leave to Amend and a Rule 1.944 Notice. Plaintiff anticipates filing these materials promptly.”

— D0073, Attachment A, ¶4(A).

I argued that beginning disclosures before the operative pleading was settled risked unnecessary duplication:

“Commencing initial disclosures while amended pleadings and anticipated responsive motions are pending would require disclosures to be prepared without knowing which claims and defenses will ultimately govern the case, increasing the likelihood of duplicative or premature disclosures.”

— D0073, Attachment A, ¶4(A).

I also explained the academic timing:

“Plaintiff's fall academic semester concluded last week, and the spring semester begins in January. That is why Plaintiff is using this time, between semesters, to complete her Second Amended Petition, Motion for Leave to Amend, and Rule 1.944 Notice.”

— D0073, Attachment A, ¶4(C).

The filing then stated unequivocally:

“Plaintiff does not object to providing initial disclosures.”

— D0073, Attachment A, Summary.

And I proposed that discovery proceed in stages:

“Plaintiff proposes that discovery proceed in phases, beginning with document production focused on electronic communications, followed by depositions once the record is complete.”

— D0073, Attachment A, ¶5.

That distinction is essential.

The dispute was not whether discovery should happen. I was expressly requesting discovery. The disagreement concerned timing and sequencing—particularly whether documentary discovery should occur first and whether disclosures should begin before the operative pleading was settled.

December 26:
The Court Set a Four-Day Jury Trial and Approved the Discovery Plan

On December 26, the court entered Order Setting Trial and Approving Discovery Plan (D0074).

The order recorded:

“Trial Type: Jury”

and:

“Expected Length of Trial: 4 day(s)”

— D0074, p. 1.

It then ordered:

“TRIAL: Trial of this case is set for 08/04/26 at 09:00 AM.”

— D0074, p. 1.

The court also expressly approved the discovery framework:

“Trial Scheduling and Discovery Plan has been filed in this matter in compliance with IRCP1.507(2). The Trial Scheduling and Discovery Plan has been completed. No additional hearings are required.”

And:

“The Trial Scheduling and Discovery plan is incorporated into this order.”

— D0074, p. 1.

So by December 26, the surviving case had a very concrete procedural posture:

a four-day jury trial set for August 4, 2026; an approved discovery framework; and an agreement expressly preserving the possibility of native-file and metadata discovery where authenticity or completeness became important.

Only the initial-disclosure date remained unresolved.

December 29:
Defendants Asked to Begin Disclosures Earlier

On December 29, defendants filed [Defendants' Motion to Set Initial Disclosures Deadline at February 1, 2026 — D0075].

Their motion accurately summarized the scheduling dispute:

“Defendants seek an initial disclosures deadline of February 1, 2026. Plaintiff seeks May 30, 2026.”

— D0075, p. 1, ¶3.

But the motion also repeated the characterization of the prior litigation discussed in Plausible Deniability:

“Since that time, Plaintiff's prosecution of this case has been minimal-to-nonexistent.”

— D0075, p. 2, ¶7.

After again invoking authority holding self-represented litigants to ordinary procedural requirements, defendants concluded:

“In any event, a May initial disclosures deadline for an August trial is not tenable.”

— D0075, p. 2, ¶9.

The important point is that defendants were not asking the court to eliminate discovery.

They were asking the court to make discovery begin earlier.

December 30:
I Asked the Court to Keep the Case on the Active Docket

The next day, I filed [Plaintiff's Motion to Continue Case on Rule 1.944 Dismissal Docket — D0076].

I pointed directly to the trial and discovery posture:

“On December 26, 2025, the Court entered an Order Setting Trial and Approving Discovery Plan, setting trial in this matter for August 4, 2026.”

— D0076, p. 1, ¶3.

I also pointed out:

“The docket reflects ongoing litigation activity.”

— D0076, p. 1, ¶5.

And I stated the posture as plainly as I could:

“This matter is therefore not dormant, has not been abandoned, and is proceeding toward a scheduled jury trial.”

— D0076, pp. 1–2, ¶6.

That statement was made before the January amendment dispute began.

At the close of 2025, I was not asking the court to avoid discovery or trial.

I was asking the court to preserve the case because it was actively proceeding toward both.

January 2:
The Court Formally Kept the Case Alive

On January 2, the court granted that request in [Order Granting Plaintiff's Motion to Continue Under Rule 1.944 — D0077].

The order first recognized the existing trial setting:

“Trial is scheduled for four days commencing on August 4, 2026.”

— D0077, p. 1.

Then the court ordered:

“Plaintiff's Motion to Continue Case on Rule 1.944 Dismissal Docket is granted.”

And, importantly:

“This case is continued, for purposes of Iowa Rule of Civil Procedure 1.944, to January 1, 2027.”

— D0077, p. 1.

The court further stated:

“This case shall not be automatically dismissed on January 1, 2026.”

— D0077, p. 1.

That ruling is worth emphasizing.

The surviving case was not merely escaping a clerical dismissal through inertia.

The court affirmatively continued it for another year while a four-day jury trial was already scheduled.

January 2:
Judge Doyle Set Initial Disclosures for March 1

Eleven minutes after D0077 was filed, Judge Doyle resolved the parties' remaining discovery-scheduling dispute in [Order Re Defendants' Motion to Set Initial Disclosures Deadline — D0078].

The order summarized the competing requests:

“Plaintiff seeks an initial disclosures deadline of May 30, 2026. Defendants seek an initial disclosures deadline of February 1, 2026.”

— D0078, p. 1.

Judge Doyle chose neither date:

“The Court finds the initial disclosures deadline should be March 1, 2026.”

She explained:

“Plaintiff's requested May 30, 2026, initial disclosures deadline is not workable given the August 4, 2026, trial date.”

— D0078, p. 1.

By January 2, 2026, the record showed:

• the case had been expressly continued under Rule 1.944 until January 1, 2027;
• a four-day jury trial was set for August 4;
• the parties had an approved discovery plan;
• electronic evidence was expressly contemplated;
• native-file and metadata requests remained available where authenticity or completeness justified them; and
• initial disclosures were ordered to begin by March 1.

I had also already informed defense counsel—and placed in the filed discovery-plan materials—that I was finishing the Second Amended Petition.

Four days later, on January 6, I filed it.

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January 6-7, 2026:
II. I Filed a 115-Page "Second Amended Petition" with Evidentiary Exhibits,
Seeking to Rebuild the Case on a Complete Record

Source documents for this section: Plaintiff's motion for leave to amend (D0079) and Second Amended Petition (D0080)

By January 2026, I was no longer simply trying to add a few allegations to the June 2024 pleading. I was trying to reconstruct a case that had been partially dismissed on October 4, 2024, without the court considering the documentary exhibits I had repeatedly said supported the allegations—and after the procedural window in which I had intended to challenge portions of that ruling became consumed by the events documented in Part Six: Plausible Deniability.

Judge Currie's October 4 order had expressly stated that the exhibits referenced in my Amended Petition were not before the court and therefore would not be considered. Yet the same order went beyond simply saying that my pleading lacked sufficient facts. It supplied factual explanations of its own for disputed events. The court reasoned that the defendants may have continued responding positively to me even though they were privately less enthusiastic, concluded that they had apparently been “not entirely truthful” with me in order to spare my feelings, characterized me as “merely a volunteer,” and stated that there was “no evidence” I had been treated differently because I am transgender.

I strongly disagreed with those factual characterizations. More importantly, I believed the documentary record contradicted important parts of them.

But the path for responding to that ruling did not unfold normally.

As documented in Plausible Deniability, the parties entered court-supervised settlement proceedings after the October 4 ruling, and the relevant deadlines were stayed. The deadline later restarted on December 23, making January 7 the resulting reconsideration deadline. I sought additional time on January 3, before that deadline expired. Judge Doyle initially treated reconsideration as untimely before later reconstructing the intervening stay orders and recognizing that my January 3 request had in fact been timely.

By then, however, the litigation had moved into the procedural conflict reconstructed in Plausible Deniability. Instead of being able simply to prepare a focused reconsideration of Judge Currie's October 4 factual and legal conclusions, I was responding to overlapping motions, deadline disputes, service issues, fee requests, and increasingly contested descriptions of the litigation history.

The Second Amended Petition itself later described the practical effect: my limited capacity had been diverted away from preparing a motion to reconsider or amended pleading and toward “preserving procedural rights and correcting mischaracterizations of the record.”

That history is important to understanding why the January 2026 filing became so large.

Why I Did Not Simply Re-Plead the One Surviving Libel Claim

A reader might reasonably ask why I did not simply file a short amended petition containing only the libel claim Judge Currie had allowed to survive.

By that point, however, I felt caught in a procedural trap.

I do not mean that I can prove anyone deliberately designed the procedure to produce that result. I mean that, from my position as a self-represented litigant, every available path appeared to carry a serious risk of surrendering something important.

Judge Currie's October 4 ruling had dismissed most of my claims with prejudice before discovery. At the same time, after declining to consider the evidentiary record I had expected to present, the order supplied factual explanations for disputed conduct. Among other things, the court reasoned that defendants may have appeared more enthusiastic toward me than they actually felt, said they had apparently been “not entirely truthful” in an effort to spare my feelings, characterized me as “merely a volunteer,” and stated that there was “no evidence” defendants treated me differently because I am transgender. Those were factual characterizations I strongly disputed and believed the documentary record could challenge.

Ordinarily, I would have wanted a clear opportunity to challenge those portions of the ruling through reconsideration and, if necessary, appeal. But the practical period in which I expected to prepare that challenge became entangled in the settlement stays, restarted deadlines, reassignment, extension disputes, service issues, and other motion practice documented in Plausible Deniability. By January 2026, the case had moved forward while those disputes had consumed much of the time and attention I had expected to devote to responding to the October 4 ruling. 

That created a question I did not know how safely to answer:

If I filed a new pleading containing only the surviving libel count, would I be treated as having voluntarily narrowed my own case to that single claim?

I was concerned that a newly operative petition containing only Count II might later be portrayed as my own decision to abandon other matters I still intended to challenge—including whether the prior dismissals had rested upon improper factual inferences, whether later-occurring conduct supported new claims, and whether claims arising after the October 2024 ruling could still be pleaded.

That concern was especially acute because I was already contemplating appellate review. I did not want an appellate court eventually presented with a record in which the most recent pleading appeared, through my own drafting choice, to accept the narrowing I was trying to contest.

So I did not understand amendment as an invitation merely to copy the one surviving count onto a new document.

I understood it as my remaining opportunity to state as clearly as I could what claims I believed were still legally available, what later conduct had occurred, what factual distinctions the October 4 ruling had missed, and what documentary record supported those allegations.

That is also why the January pleading distinguished between the prior claims and what I characterized as “surviving and newly matured claims.” In my later reply, I expressly denied that I was simply attempting to relitigate claims already dismissed:

“Defendants contend that Plaintiff seeks to relitigate claims dismissed with prejudice. She does not. Plaintiff seeks leave to amend in order to present surviving and newly matured claims on a complete factual and documentary record…”

— Plaintiff's Reply in Support of Motion for Leave to Amend, D0085, p. 1.

I later made the same distinction in legal terms: I argued that I was not using amendment as a disguised motion to reconsider the October 4 ruling, but to clarify legally surviving theories and plead causes of action arising from later conduct.

Whether I drew those procedural boundaries correctly is ultimately a legal question. But it explains my drafting decision.

From where I stood in January 2026, filing only the libel claim felt less like simplification and more like a risk that I would narrow the case myself—and later be told that the narrowing was my own choice.

That was a risk I was unwilling to take.

I was Trying to Avoid the Same Pleading Problem Twice

During the 2024 dismissal proceedings, I had been trying to understand what exactly Iowa pleading law required a self-represented litigant to put inside a petition.

In their July 5, 2024, Motion to Dismiss my previous ("Amended") petition (D0022), Defendants cited Krise v. Cota:

“While a motion to dismiss admits the truth of all well-pleaded, issuable and relevant facts, it does not admit mere conclusions of fact or law not supported by allegations of ultimate facts.”

That language mattered to me because I understood its practical message to be: do not merely state your conclusion—plead the factual foundation from which the conclusion can be drawn.

At the same time, defendants were arguing that evidence outside the pleading could not rescue an insufficient pleading. Their August 3 filing stated:

“Motions to dismiss are generally decided on the face of the pleadings.”

And Judge Currie's August 9 order similarly explained that a court accepts well-pleaded factual allegations as true but not legal conclusions, while ordinarily not considering material outside the pleading.

For a lawyer familiar with notice pleading, the distinction among an ultimate fact, an evidentiary fact, and a legal conclusion may be routine.

For me, representing myself while simultaneously being told that I was expected to comply with the same procedural rules as an attorney, it was not routine. Judge Currie's July 19 order specifically reminded me that I was expected to familiarize myself with the Rules of Civil Procedure and Evidence rather than rely upon internet research.

I took those instructions seriously.

So instead of writing:

“The defendants discriminated against me,”

I tried to plead who complained, what I was told, what I was not told, what punishment followed, what the surrounding relationships had looked like, how other people were treated, and what facts caused me to believe gender identity affected the unequal treatment.

Instead of writing:

“The defendants submitted misleading evidence,”

I tried to identify the original communications, the versions later supplied to the ICRC, chronology, attribution, omissions, and what discovery would still be necessary to determine authorship and responsibility.

And instead of simply alleging:

“I had agreements to perform this work,”

I tried to identify the communications creating the arrangements, who approved the work, what responsibilities were delegated, what labor was performed, what defendants later said about it, and which documents supported each assertion.

My January Motion for Leave effectively described that drafting strategy itself: the proposed amendment was intended to attach the previously unavailable documentary record, “plead[] ultimate facts rather than anticipated proof,” distinguish claims that remained legally available, and reorganize the allegations around the administrative and judicial conduct that had occurred since the original case began.

That is a major reason the pleading became 115 pages.

I was trying to make it difficult for another court to say simultaneously that I had pleaded only conclusions and that the evidence supporting those conclusions could not be considered.

I Also Tried to Cure the Rucker Problem

Judge Currie's October 4 ruling created another lesson.

The exhibits referenced in my 2024 petition had not been formally attached in a manner the court could consider. The court therefore stated that it did not have access to them. That problem became inseparable from how I approached the next pleading.

The January Motion for Leave expressly said that the purpose of the amendment was to correct that defect by attaching and incorporating the administrative record and contemporaneous communications.

The resulting Second Amended Petition did not merely say that supporting evidence existed. It contained an exhibit index connecting particular documentary groups to particular allegations and claims. Exhibits A through F organized the ICRC record, the open-mic and flier communications, garden and prairie arrangements, Colville-related records, Martinez-related records, and Esker's statement and surrounding communications. Exhibit G reconstructed the procedural history itself.

That level of integration made the filing much larger. But it was deliberate: I did not want the case dismissed a second time because an important factual proposition depended upon a document the court could not see.

Why I Am not Reprinting Exhibits A-F here

Readers of this series do not need to go through those exhibits twice.

The underlying factual exhibits were later reorganized and sharpened, and the important evidence from Exhibits A through F is now examined directly in Political Sabotage. That article is the evidentiary hub for the underlying communications, ICRC submissions, chronology, and alleged documentary irregularities.

For example, Exhibit D specifically juxtaposed the stalking-and-harassment allegations with the contemporaneous Colville communications, including the communications in which she described us as friends and continued interacting positively with me. Exhibit E similarly placed the Martinez-related racism and anti-LGBT+ allegations beside the contextual communications I contended contradicted or materially undermined that narrative.

I therefore will not reproduce Exhibits A through F again in this installment. Readers who want to examine that evidence can do so in Political Sabotage.

Exhibit G is different.

It is not primarily an exhibit about what happened before the lawsuit. It reconstructs what happened during the litigation—including the venue dispute, overlapping motions, pleading conflicts, judicial rulings, and the procedural history that became the basis for my newly alleged abuse-of-process claim. Exhibit G was organized as a 99-page timeline and pattern record spanning December 2023 through April 2025.

Because Political Sabotage does not reproduce that litigation exhibit, I include and discuss Exhibit G below.

The New Petition Also Tried to Correct the Record Left by October 4

The January filing was therefore not simply “long because I attached a lot of exhibits.”

It was also my first completed attempt to state the case again after the October 4 ruling.

I wanted the next court examining the case to understand that I disputed Judge Currie's factual characterization of the relationships, the work arrangements, the reasons for my exclusion, and the significance of the ICRC record.

That was particularly important because Judge Currie's order had dismissed nearly everything except one written-defamation claim while simultaneously making factual statements favorable to defendants despite the court having declined to consider the documentary exhibits I said contradicted those explanations.

The January filing therefore attempted to put the factual building blocks into the pleading itself rather than assume a later evidentiary hearing would correct the record.

That approach was not subtle. The petition ultimately ran 115 pages, and the entire January submission exceeded 400 pages when the seven exhibit groups were included. The purpose, however, was not to enlarge the dispute for its own sake. It was to put the underlying communications, administrative record, procedural history, defendant-specific allegations, and legal claims into one record that could actually be tested. The January Motion for Leave expressly told the court that the amendment did not expand the factual universe but instead “consolidates, organizes, and attaches the materials already central to the dispute so that the claims may be evaluated on their merits.”

Some Claims Were New Because the Case Itself Had Changed

Another reason the January petition could not simply reproduce the June 2024 pleading was that time had passed and additional conduct had occurred.

My Motion for Leave distinguished the earlier dismissed claims from claims based upon later conduct, the institutionalization of allegations across administrative and judicial records, retaliation and abuse of process after protected activity, and continuing or prospective harms that had not been adjudicated in the October 2024 dismissal.

The resulting petition organized ten counts: two promissory-estoppel counts, defamation, constitutional equality, unjust enrichment, ICRA retaliation, fraudulent representations to a government agency, abuse of process, civil conspiracy, and tortious interference with contractual and prospective relations.

I do not need to re-explain every count here. Several are developed elsewhere in this series.

What matters for this installment is that the January petition attempted to distinguish between the original controversy, the administrative record that followed it, and later conduct and injuries that had developed during the litigation itself.

That distinction later became central when defendants argued that I was simply attempting to revive claims already dismissed with prejudice. My position was that the new pleading included surviving claims, clarified theories, later-occurring conduct, and newly matured injuries that could not simply be treated as though they had all been adjudicated in October 2024.

Love Club LLC and the Parties' Roles Were Pleaded More Precisely

The January petition also corrected something that had remained poorly developed in the earlier pleadings: who was alleged to be responsible for what, and in what capacity.

Love Club LLC was added as a defendant. The petition identified it as the owner of the property, noted that it had been a respondent in my original ICRC complaint, and alleged that the businesses occupying the property were its tenants. It also alleged that Love Club benefited from physical improvements made through my work.

The individual defendants' roles were also pleaded more expressly. Stewart, Colville, and Martinez were identified as being sued personally for alleged conduct attributed to them, while the petition separately alleged derivative entity or employer responsibility where challenged acts were performed within the scope of employment.

That defendant-specific pleading was another response to the recurring criticism that I had not adequately separated who allegedly did what.

I Preserved the Venue Issue Rather Than Pretending It Had Disappeared

The January petition also addressed the Polk County venue dispute.

It did not ask Judge Doyle to transfer the case back to Polk County. It expressly acknowledged Story County as a proper venue. But it preserved my position that the original Polk filing had been made in good faith because part of the legal injury I alleged arose through submissions to the Iowa Civil Rights Commission in Des Moines.

The later abuse-of-process allegations went further and alleged that defendants had represented Polk County as an improper venue while failing to address the statutory basis I had pleaded under Iowa Code § 616.18.

That does not require this installment to repeat Procedural Bombardment. But it helps explain why the litigation history itself became part of the 2026 pleading rather than mere background.

One New Claim Looked Back to Iowa's Constitutional Origins

One addition is important enough to flag separately.

The January petition pleaded discrimination through the Equality Clause of the Iowa Constitution, relying on Clark v. Board of School Directors, an 1868 Iowa Supreme Court decision.

The petition argued that Clark recognized constitutional protection against arbitrary exclusion even where the particular characteristic was not expressly enumerated by statute. It quoted Clark's statement that access could not be denied because of “nationality, religion, color, clothing or the like,” and argued that Iowa's equality guarantee could operate as a constitutional backstop against arbitrary and unequal treatment.

I then alleged that after months of authorized participation, I was excluded after complaints from cisgender women without being told the specific conduct alleged or given an opportunity to respond, and that the resulting treatment reflected impermissible assumptions concerning me as a transgender woman. The claim sought declaratory and equitable relief rather than damages under the constitutional count.

I think the full constitutional history belongs on the landing page, because that is where readers can see the larger statewide significance of the appeal.

But it deserves this short treatment here because of the contrast that eventually emerged:

I was asking the court to consider an Iowa constitutional theory that would potentially strengthen protections against arbitrary unequal treatment. Defendants were soon asking the same court to recognize broad absolute protection for statements made during the preliminary civil-rights process.

The constitutional claim never received the factual development or jury consideration I was seeking.

The absolute-privilege argument ultimately did receive a dispositive ruling.

That juxtaposition belongs in Dangerous Precedent.

Based On My Experiences Thus Far, I Explicitly Demanded a Jury to Decide the Facts

The January petition also ended with an explicit jury demand:

“Plaintiff hereby demands trial by jury on all issues so triable as a matter of right pursuant to Article I, Section 9 of the Iowa Constitution and Iowa Rule of Civil Procedure 1.903.”

That demand mattered to me by this stage of the litigation.

After the 2024 proceedings, I no longer wanted disputed questions about what people said, what they privately believed, why they acted, whether the documents were accurate, whether discrimination occurred, or whether particular conduct was malicious resolved through assumptions made from an incomplete record.

I wanted discovery. And I wanted a jury to examine the facts.

That is the posture in which the case entered 2026.

The January Filing Was a First Reconstruction — not the Final One

There is one final reason not to reproduce all seven January exhibits in this article.

This January version was not the final version Judge Doyle would later evaluate.

As the next section explains, defendants opposed the filing, challenged several citations in Exhibit G, and asked the court to deny amendment. I reviewed those citations, withdrew the ones I could not verify, and Judge Doyle ultimately gave me specific directions for what a renewed proposed petition would have to look like.

I then rebuilt the pleading again.

The Revised Second Amended Petition therefore becomes the more important version for examining the actual claims and sharpened exhibits later in this installment. The January filing matters because it explains how I got there—and why the revised petition did not arise from nowhere.

---

 

January 20-February 11, 2026:
III. Defendants Challenged Exhibit G —
and Asked the Court to Deny the Amendment

 

The January 6 filing did not simply create a dispute over whether I had pleaded too much.

It also created a separate problem.

One of the seven exhibit groups attached to my proposed Second Amended Petition was Exhibit G, a lengthy attempt to reconstruct the procedural history of the litigation and explain how I believed that history supported later-arising claims, including abuse of process.

On January 20, defendants responded by asking the court to deny leave to amend.

January 20:
Defendants Said the Amendment Should Be Denied — and Raised Citation Errors in Exhibit G

In their Defendants' Resistance to Motion to Amend and Request for Status Conference (D0082), defendants emphasized the size of the filing immediately:

“On January 6 and 7, Plaintiff filed over 412 pages of documents, including a 115-page proposed Amended Petition.”

They argued that the filing attempted to “revive and relitigate” claims Judge Currie had dismissed with prejudice and objected to the addition of Love Club LLC as a proposed defendant.

Their resistance then raised a much more serious issue.

Defendants wrote:

“The 412 pages of new filings also contain citations to nonexistent cases and cases that have no relation to the cited proposition—perhaps a product of AI hallucinations.”

— D0082, p. 1, ¶4.

They identified four citation groupings in Exhibit G that they contended were inaccurate. The objections included one citation they reported they could not locate at all and several real cases they argued did not support the propositions for which I had cited them.

The defendants did not treat those errors as minor.

They told the court:

“The Court would be within its authority to dismiss this action in its entirety as a sanction for the latest filings, and/or award attorneys’ fees to Defendants.”

They nevertheless stated that they were “sympathetic to the fact that Plaintiff is proceeding pro se” and asked instead that the court deny amendment and schedule a status conference.

The resistance therefore raised two distinct objections to my January filing.

First, defendants argued that the proposed new claims were legally futile because, in their view, they had already been dismissed with prejudice.

Second, they argued that Exhibit G contained serious citation errors that undermined the filing and potentially justified sanctions.

Those objections placed me squarely inside the procedural problem I had been trying to avoid.

Why not simply file a new petition containing only the surviving libel claim?

From my perspective at the time, doing that carried its own risk. I did not know whether a new operative petition containing only Count II could later be treated as my own decision to accept the October 4 narrowing—particularly if the case eventually reached an appellate court. I still disputed aspects of the October 4 ruling, including factual explanations supplied without discovery, and I believed some claims based on later conduct and newly matured injuries had never been adjudicated at all.

I therefore feared that I was being pushed into a procedural dilemma: if I pleaded only the surviving libel claim, I might narrow the case myself; if I attempted to preserve and distinguish claims I believed remained legally available, defendants could characterize that effort as improperly reviving claims already dismissed with prejudice.

I cannot establish from the written record that anyone deliberately designed the procedure to create that dilemma. But that was how it appeared to me as a self-represented litigant trying to preserve issues for further litigation and eventual appellate review.

Defendants' January 20 resistance presented the second side of that dilemma directly. They characterized the proposed claims broadly as futile because, in their view, they had already been dismissed with prejudice. My response was that I was not simply refiling the same dismissed claims: I was attempting to distinguish surviving claims, later-occurring conduct, and newly matured injuries from matters actually decided in October 2024.

On the first issue, defendants relied upon Iowa cases recognizing that a court may deny amendment when a proposed claim would be legally futile. They characterized all of my proposed new claims as attempts to resurrect matters already disposed of in October 2024.

I disputed defendants’ characterization of the proposed claims as merely futile attempts to revive dismissed claims. I separately reviewed their citation objections and, as explained below, withdrew the authorities I could not verify.

My Response:
The Amendment Was Not an Attempt to Pretend the October 2024 Ruling Never Happened

In my Reply in Support of Motion for Leave to File Second Amended Petition (D0085) and supporting Reply Brief (D0086), I argued that defendants were treating every new or reorganized claim as though it were necessarily identical to a claim Judge Currie had already dismissed.

My reply opened with the distinction I was trying to make:

“Defendants contend that Plaintiff seeks to relitigate claims dismissed with prejudice. She does not. Plaintiff seeks leave to amend in order to present surviving and newly matured claims on a complete factual and documentary record…”

— D0085, p. 1.

I also relied on Iowa Rule of Civil Procedure 1.402(4), which states that leave to amend:

“shall be freely given when justice so requires.”

My argument was that amendment was appropriate where the new pleading did more than merely restate the old one: it reorganized the factual record, attached exhibits the court had not considered in 2024, clarified surviving theories, and alleged conduct and injuries that had continued or developed after the earlier pleading.

That was also how I explained the length of the filing:

“The Second Amended Petition responds directly to that posture by attaching and organizing documentary evidence previously referenced and refining the legal framing of Plaintiff’s claims.”

And:

“The volume of the amended pleading reflects the evidentiary record itself, not an attempt to evade procedural limits.”

— D0085, p. 2.

The procedural distinction mattered.

Defendants argued that I was effectively trying to undo the October 2024 dismissal outside the deadline for a motion to reconsider.

I responded that a motion to reconsider under Rule 1.904 and a motion for leave to amend under Rule 1.402(4) were not the same procedural device.

My Reply Brief stated:

“Defendants’ reliance on Rule 1.904(2)’s fifteen-day deadline conflates a motion to reconsider with a motion to amend.”

And:

“Plaintiff does not seek reconsideration of the Court’s October 4, 2024 ruling. Rather, Plaintiff seeks leave to amend under Rule 1.402(4) to clarify surviving claims and plead causes of action arising from later-occurring conduct.”

— D0086, p. 2.

I further argued that later-occurring conduct and newly matured injuries could not simply be treated as though they had already been adjudicated before they existed.

The brief explained:

“The operative facts underlying the Second Amended Petition are not merely elaborations of previously litigated claims, but materially distinct events that arose after the original pleading and therefore were not capable of adjudication in the prior proceeding.”

— D0086, p. 3.

Whether the court would ultimately agree was still unresolved.

But that was the actual amendment dispute: were these merely dismissed claims being refiled, or did the proposed petition also contain surviving, reformulated, and later-maturing claims that could properly be considered through amendment?

I Also Argued That the Court Should Not Decide the Merits Through the Amendment Motion

My supporting brief made another distinction that becomes important later in this article.

Defendants argued that the court could examine the merits of the proposed claims and deny amendment as futile.

I responded that the amendment proceeding should not become a substitute for deciding disputed facts or disposing of the case on the merits.

The brief stated:

“Defendants seek to convert a motion for leave to amend into a merits determination. That is not the inquiry under Rule 1.402(4).”

And:

“The question before the Court is whether amendment should be permitted so that Plaintiff’s claims may be evaluated on a complete and coherent factual and legal record.”

— D0086, p. 2.

I also argued that the existing August trial date reduced any claim of unfair prejudice from amendment, and that the attached exhibits were a response to the earlier problem that the court had not had them before it when evaluating the 2024 pleading.

That argument ended with the point I was attempting to make throughout the January amendment fight:

“Denying leave would entrench procedural fragmentation and elevate procedural form over substantive adjudication.”

The issue was now set for hearing.

January 27:
Judge Doyle Set a Hearing on the Motion for Leave to Amend

On January 27, Judge Doyle entered an Order Setting Hearing (D0084).

The order stated:

“The Plaintiff has filed a Motion for Leave to File Second Amended Petition. A hearing will now be scheduled.”

The hearing was set for February 9, 2026, at 10:30 a.m., by videoconference.

I do not yet have a transcript I am prepared to quote for what was said during that hearing.

For that reason, I do not want to reconstruct the February 9 argument from memory as though it were an official record.

What is documented is what happened next.

February 11:
I Withdrew the Challenged Citations Rather Than Defend Them

After reviewing defendants' objections, I concluded that the challenged authorities should not remain in the record.

On February 11, I filed Plaintiff's Limited Notice of Withdrawal of Inaccurate Citations in Exhibit G (D0088).

The notice did not attempt to argue that the challenged citations were actually correct.

It expressly withdrew them.

I wrote:

“Plaintiff hereby withdraws and expressly disclaims any reliance on the following citations appearing in Exhibit G…”

The notice then identified the five authorities contained within the four challenged citation groupings.

I further stated:

“Plaintiff does not rely on these authorities in support of any claim, allegation, or legal argument.”

— D0088, ¶3.

I deliberately made the notice narrow.

I did not use it to rewrite Exhibit G, reargue the motion for leave, or request a new substantive ruling.

The notice explained:

“Plaintiff submits this Notice without seeking to amend Exhibit G, without re-arguing any procedural or substantive motion, and without requesting any substantive relief, solely to ensure the accuracy of the record before the Court.”

And:

“No other portion of Exhibit G is affected by this Notice.”

— D0088, ¶¶4–5.

That distinction matters to how I present the error here.

The citations were inaccurate, and I withdrew them. I do not rely on them now.

But the withdrawal did not concede that the factual documents collected in Exhibit G were fabricated, that the remaining authorities were invalid, or that the factual allegations in the proposed Second Amended Petition disappeared with those citations.

It corrected the citation record.

The larger amendment question—whether the January proposed petition could become the operative pleading—remained unresolved.

And while that question was still pending, the case was already moving into the next phase:

discovery.

---

 

IV. Discovery Had Been Agreed to and Ordered — 
Then Defendants Withheld the Evidence I Sought and Argued It Could Not Matter

By March 2026, discovery was no longer theoretical. Three months earlier, defendants and I had filed a discovery plan addressing electronically stored information, and Judge Doyle had incorporated that plan into her December 26 order. The plan expressly preserved the ability to request native files or metadata where relevance, authenticity, or completeness was at issue.

I then made exactly that kind of request.

The resulting dispute became one of the central turning points in this case: defendants first objected that the drafts, metadata, native files, and internal communications were irrelevant to the surviving claim. Days later, they moved for summary judgment under a broader theory that, if accepted, would make what that evidence revealed legally immaterial anyway.

Judge Doyle had already placed the case on an active discovery-and-jury-trial track. Initial disclosures were due, the parties had an approved discovery plan, and trial remained scheduled for August.

That meant I had to conduct discovery while the court had not yet decided whether the June 2024 Amended Petition would remain operative or whether the proposed Second Amended Petition would be allowed.

The uncertainty I had worried about in January was becoming concrete.

March 2:
I Served Focused Discovery About the June 28, 2022 ICRC Submission

On March 2, I served my [First Set of Discovery Requests], focused almost entirely on one disputed piece of evidence: the June 28, 2022 submission defendants had provided to the Iowa Civil Rights Commission.

These were not broad requests for every communication defendants had ever exchanged.

The requests sought the materials necessary to reconstruct how that particular submission was created.

I requested:

“All versions (draft and final) of the June 28, 2022 ICRC submission…”

and:

“The native electronic file(s) corresponding to the June 28, 2022 ICRC submission, including all reasonably accessible metadata reflecting creation date, modification date(s), author(s), revision history, file properties, and transmission data…”

— Plaintiff’s First Set of Discovery Requests, Requests for Production Nos. 1–2.

I also requested communications among defendants concerning:

“the preparation, editing, compilation, formatting, ordering, sequencing, review, approval, or submission of the June 28, 2022 ICRC submission…”

as well as records reflecting its:

“creation, drafting, editing, modification, formatting, ordering, sequencing, or transmission history…”

— Requests for Production Nos. 3–4.

The accompanying interrogatories were similarly specific.

I asked defendants to identify:

• who created, edited, formatted, compiled, revised, or altered the submission;
• who authored the introductory caption placed above the screenshots;
• when and how the document was transmitted to the ICRC;
• whether the chronological order of the messages had been modified, rearranged, excerpted, reformatted, or selectively compiled;
• who reviewed or approved the submission; and
• what devices, platforms, or software had been used to create or transmit it.

I also expressly requested preservation of the relevant electronically stored information, including native files, drafts, metadata, cloud-stored versions, backups, audit logs, and communications concerning the submission.

The purpose was straightforward.

The ICRC file contained the final submitted document. What I did not possess were the electronic records that could objectively show who created it, how it changed during preparation, what sequence of edits occurred, and what communications accompanied those changes.

Those materials were in defendants' possession, not mine.

April 1:
Defendants Objected — While Confirming Who Created and Revised the Document

Defendants' Responses and Objections to Plaintiff's Discovery Requests began by confirming how narrowly my requests were framed:

“All of Plaintiff’s discovery requests in this set are directed exclusively at the June 28, 2022 ICRC submission.”

They nevertheless objected that the requests were unduly burdensome, overly broad, and irrelevant to the sole remaining claim.

For the draft versions, defendants asserted both work-product protection and irrelevance, arguing that drafts could not matter because the surviving claim involved a published statement rather than unpublished drafts.

They similarly objected to producing the native files and metadata:

“The native files are not relevant to any claim in defense in this case…”

— Response to Request for Production No. 2.

And they objected to producing communications among defendants about how the document was prepared, saying those communications and native files were likewise irrelevant.

But defendants also gave substantive answers to several interrogatories.

They stated that the submission had been:

“created, edited, formatted, compiled, and revised by Sharon Stewart and Lyndsay Nissen.”

They identified Sharon Stewart as the person who authored or added the heading:

“Communication where Willa asked for no further communication, followed by Sondra's response.”

— Defendants' Responses to Interrogatories Nos. 1–2.

That answer did not resolve my concern. It made the underlying electronic record more important.

Defendants acknowledged that Stewart and Nissen had “created, edited, formatted, compiled, and revised” the submission. Yet when asked whether the chronological order of the messages had been modified, rearranged, excerpted, reformatted, selectively compiled, or otherwise altered, they answered no—apart from an acknowledged duplicated screenshot.

Those statements are not necessarily mutually exclusive. A document can be edited or formatted without changing the chronological order of its underlying messages. But the response never explained what the acknowledged editing, formatting, compilation, and revision actually consisted of.

To me, that left the central question unresolved: what changed between the source material and the final document submitted to the ICRC?

That was why I had requested the drafts, native file, metadata, revision history, and communications surrounding its preparation. Those materials could provide an objective record of what “created,” “edited,” “formatted,” “compiled,” and “revised” actually meant.

The ambiguity was especially significant because defendants were simultaneously objecting that those very materials were irrelevant. They would identify who created and revised the document, but resisted producing the electronic record that could show how it had been created and revised.

The Procedural Trap I Had Begun to Suspect Was Now Affecting Discovery

There was another problem.

Defendants' objections repeatedly relied upon the premise that only one narrow libel claim remained in the case. But my January 6 motion seeking leave to file the Second Amended Petition had still not been decided.

The procedural dilemma I had worried about in January was therefore no longer abstract. The narrower version of the case was now being used to define what evidence defendants said I could obtain, while my effort to establish a broader operative pleading remained unresolved.

From my perspective, that looked increasingly like the trap I had feared: if I accepted the one-claim posture, I risked narrowing the case myself; if I attempted to preserve other claims and later-occurring conduct, defendants argued that those claims could not be revived; and while the court had not yet decided that dispute, defendants were invoking the narrow posture to resist discovery and seek judgment.

I could not yet prove that anyone had deliberately engineered that sequence. But by April, I had begun to suspect that the procedural narrowing was becoming self-reinforcing.

April 6:
Defendants Asked the Court to End the Surviving Claim
Before the Discovery Dispute Was Resolved

On April 6, before the disputed drafts, metadata, native files, and internal communications had been produced, defendants filed their [Motion for Summary Judgment — D0089] and accompanying [Statement of Material Facts and Memorandum — D0090].

Their motion expressly proceeded from the narrow pleading posture.

They wrote:

“The operative Petition in this case is Plaintiff’s Amended Petition.”

and:

“The sole claim remaining is Count II, which claims libel based on statements Defendants allegedly submitted to the Iowa Civil Rights Commission in 2022.”

— D0089, ¶¶1–3.

But the defendants also acknowledged in a footnote that my January motion for leave to amend remained pending.

They requested that, even if Judge Doyle later allowed the operative pleading to change, summary judgment should still apply to any libel claim arising from ICRC submissions.

The motion presented four potential grounds for ending the surviving claim:

1. absolute litigation privilege;

2. alternatively, qualified or conditional privilege;

3. truth; and

4. lack of damages.

The first argument was the one that fundamentally changed the case.

In their supporting memorandum, defendants argued that the ICRC submissions were absolutely privileged because they had been made as part of a judicial or quasi-judicial proceeding.

They also relied upon Judge Currie's earlier October 4 factual language—including the statement that there was “no evidence” I had been excluded because I am transgender—as support for their alternative qualified-privilege argument.

That mattered because those were some of the very factual conclusions I had been trying to challenge through a more complete pleading and evidentiary record.

April 14:
I Asked the Court to Decide Which Pleading Controlled — and to Require Discovery

On April 14, I filed a combined Resistance to Motion for Summary Judgment, Motion to Compel Discovery, and Motion to Clarify Operative Pleading (D0091).

Attachment A (D0091) Plaintiff's First Set of Discovery Requests

Attachment B (D0091) Defendants' Objections to First Set of Discovery Requests

This was not merely a response to the absolute-privilege argument.

I was also asking Judge Doyle to resolve the procedural uncertainty that had existed since January.

I wrote:

“The absence of a ruling has created uncertainty regarding which claims are operative, the permissible scope of discovery, and the issues properly before the Court.”

— D0091, p. 1, ¶2.

I then identified how that uncertainty was affecting the litigation:

“Defendants have taken the position that only a limited claim remains and have relied on that position to restrict discovery, object to production, and move for summary judgment.”

I argued that defendants could not themselves determine which pleading controlled and asked the court to rule before the scope of the litigation was narrowed further.

A page later, I made the connection even more explicitly:

“Since that filing, Defendants have continued to rely on the absence of a ruling on the Motion for Leave to Amend to assert a limited scope of claims, restrict discovery, and seek summary judgment.”

— D0091, p. 3.

The uncertainty I had feared in January was therefore no longer hypothetical.

The unresolved amendment question had now become the premise of defendants’ discovery objections and summary-judgment posture: they treated the June 2024 petition and its single surviving libel count as controlling while my motion for leave remained undecided.

I Also Argued That the Requested Discovery Mattered
Even Under the Narrowest Possible Version of the Case

Importantly, my motion did not depend entirely upon Judge Doyle accepting the broader January pleading.

I argued that the requested materials were relevant even if the court agreed with defendants that only the written-defamation claim remained.

I wrote:

“Even under the Court’s prior ruling limiting the case to a written defamation claim, the requested discovery remains directly relevant.”

I explained that the drafts, metadata, native files, and communications related directly to:

“their authorship, preparation, and accuracy.”

— D0091, ¶17.

I also pointed out what I viewed as a tension in defendants' own responses: they acknowledged that Stewart and Nissen had “created, edited, formatted, compiled, and revised” the ICRC submission while simultaneously denying that its underlying messages had been modified, rearranged, excerpted, reformatted, selectively compiled, or otherwise altered apart from the acknowledged duplicated screenshot.

For me, that was precisely why the underlying electronic evidence mattered.

A final PDF could show what was submitted.

The native files, metadata, drafts, and communications could potentially show how it was made.

This Set Up the Central Conflict in Dangerous Precedent

The parties were now asking the court to answer fundamentally different questions.

I was asking:

What would the evidence show about who created the disputed material, how it was assembled, when it was changed, and what the defendants knew when they submitted it?

Defendants' absolute-privilege theory posed a different question:

Even if discovery answered all of those questions in my favor, would any of it legally matter?

That became explicit in their next filing.

On April 27, defendants would argue:

“No discovery, no amendment of the pleading, and no characterization of Defendants’ internal document-preparation process can change the legal character of the Iowa Civil Rights Commission proceeding in which those statements were made.”

That was the argument at the heart of Dangerous Precedent.

March 2
I Sent the Defendants the First set of Discovery Requests

Plaintiff's first set of discovery requests
D0091 (attached to resistance to MSJ, same docket numer)

The docket screenshot and later filings support this date, even though it appears attached through the April 14 filing. The article should explain the actual requests, not merely say “discovery.” Relevant categories included authorship, drafts, native files, metadata, revision history, communications, chronology, transmission, and reliance.

Defendants refused to comply with my March 3 discovery requests, so i filed a motion to compel. This prompted their resistance and motion for summary judgment and subsequent filings in favor of the absolute-privilege argument. 

 

 

April 6:
Defendants Filed Motion for Summary Judgment, Arguing "Absolute Privilege" for Submissions Sent to Iowa Civil Rights Commission

Defendants' Motion for Summary Judgement and Facts Supporting
D0089-D0090

This should be one of the article’s turning points:

Before producing the disputed document-creation evidence, defendants asked the court to terminate the remaining claim as a matter of law.

Then quote their core theory from the memorandum and describe what it meant.

April 14:
I Filed a Motion to Compel for Discovery and a Resistance to Motion for Summary Judgmeent; Sought Clarification

D0091

Emphasize that this was not one simple motion. The docket shows:

• omnibus motion to compel and clarify;
• resistance to summary judgment;
• Attachment A: first discovery requests;
• Attachment B: defendants’ objections.

That is a significant drafting and evidentiary event.

 

 

 

How a Case Set for Discovery and Jury Trial Was Terminated Before Either Occurred

 

By the beginning of 2026, Wilson v. Reliable Street Inc., et al. had returned to an active trial track. The court had approved a discovery plan, set initial-disclosure deadlines, and scheduled a four-day jury trial for August 4.

What followed was not ordinary preparation for a single surviving claim. I was required to reorganize a multi-defendant case, file hundreds of pages of pleadings and exhibits, litigate the scope and timing of discovery, respond to demands for sanctions, resist summary judgment, prepare for two hearings, complete a revised pleading after the first was rejected, and research whether Iowa law truly grants absolute immunity to allegedly false or manipulated submissions made during the preliminary phase of a civil-rights investigation.

Those obligations overlapped directly with Iowa’s ballot-access period. They also continued after the statutory deadline, ultimately producing two July 15 orders that denied amendment, granted summary judgment, and dismissed the case before the disputed discovery was produced or a jury heard the facts.

This installment documents how the surviving claim moved toward discovery and trial—and how an expansive absolute-privilege theory instead ended the case before either occurred.

Wilson v. Reliable Street Inc., et al. now presents questions that extend beyond my own case to anyone who may one day rely upon Iowa's civil-rights process.

All but one of the claims I brought—including claims arising from discrimination, fraud, promissory estoppel, unjust enrichment, and defamation—were dismissed with prejudice in 2024 before discovery occurred and while the district court declined to consider the exhibits I had identified in my amended petition (D0020). I also contend that some of the dismissal rulings resolved questions in ways that depended upon facts the parties had not yet developed through discovery—an issue examined later in this page and throughout the series.

One libel claim survived those dismissals. It concerned statements defendants submitted to the ICRC in 2022—the same administrative record reconstructed throughout this series, including the modified document identified as Exhibit D-3 in Part Three of this series, Political Sabotage.

In April 2026, defendants moved for summary judgment and asked the court to classify the ICRC process as a quasi-judicial proceeding protected by absolute litigation privilege.

In their Memorandum in Support of Summary Judgment (D0090), defendants wrote:

“The dispositive feature of the absolute privilege is that it bars recovery even if the plaintiff can prove the statements were false, made with actual malice, and caused serious harm.

No matter what discovery might reveal about the content of Defendants’ statements or Defendants’ subjective state of mind, those facts cannot defeat an absolute privilege.”

Defendants’ Memorandum in Support of Summary Judgment, D0090, § I(d), p. 8.

Their April 27 Reply in Support of Summary Judgment and Resistance to Motion to Compel (D0096) made the point even more explicitly:

“[T]he privilege protects inaccurate and even malicious statements in quasi-judicial proceedings…”

I argued that authenticated contemporaneous records can prove multiple material factual assertions false; defendants' position was that absolute privilege would bar recovery regardless of what discovery might ultimately show about truth, falsity, or state of mind.

They further argued that discovery into authorship, drafting history, metadata, accuracy, selective compilation, or state of mind could not defeat absolute privilege. In the alternative, defendants argued that qualified privilege applied, that their statements were true, and that I could not establish damages.

I argued that authenticated contemporaneous records can prove multiple material factual assertions false and that discovery was necessary to develop evidence concerning authorship, knowledge, falsity, and actual malice.

V. The Court Narrowed The Pleading
While Summary Judgement Remained Pending

 

April 22 — Multiple Orders

Judge Doyle's Order
D0092–D0095

Separate these carefully:

• pretrial conference order;
• May 26 hearing order;
• clarification that the 2024 amended petition remained operative;
• broader order addressing numerous items.

This is where the article should show that amendment, discovery, summary judgment, and trial preparation were all active simultaneously.

Apr. 26, 2026 — Defendants filed a motion for summary judgment, arguing that my libel claim should be dismissed immediately, and that there should be no trial. They argued that their statements to the Iowa Civil Rights Commission were protected by "absolute privilege" because the ICRC is a quasi‑judicial tribunal. , stating, “[Absolute privilege] applies regardless of whether the statement was false… or made with ill will.” They further argue that the ICRC is a quasi‑judicial tribunal, writing in the same filing that “The ICRC satisfies every criterion for a judicial proceeding… [and] is the hallmark of a quasi‑judicial proceeding.” Because of this, they insist that my discovery requests are irrelevant. As they put it: “No discovery… could change the legal character of the Iowa Civil Rights Commission proceeding.” (see motion for summary judgment, D0089).

Motion for Summary Judgment they filed in April (D0089. 4/6/26) . The reasoning they gave is that they contend that their statements to the Iowa Civil Rights Commission were protected by "absolute privilege" even if knowingly false, stating, “[Absolute privilege] applies regardless of whether the statement was false… or made with ill will.” They further argue that the ICRC is a quasi‑judicial tribunal, writing in the same filing that “The ICRC satisfies every criterion for a judicial proceeding… [and] is the hallmark of a quasi‑judicial proceeding.” Because of this, they insist that my discovery requests are irrelevant. As they put it: “No discovery… could change the legal character of the Iowa Civil Rights Commission proceeding.”

April 27 — Reply and Resistance to Compel

D0096

Explain that defendants argued no discovery could alter the legal character of the ICRC proceeding. That became the reason you needed the major privilege memorandum.

VI. Filed "Revised Second Amended Petition"

May 2-6 — Continuance Requested and Denied

D0097, D0099

This matters for burden because the court denied a request to shift the May 26 hearing even though the ballot deadline was June 2.

May 26 — Hearing

D0098

The hearing occurred seven days before the statutory ballot deadline and after I had already redirected campaign time toward hearing preparation and emergency ballot-access litigation.

June 15 — Revised Second Amended Petition

D0100–D0103

This is another major burden marker:

• revised petition;
• revised Exhibit A–G;
• summary of major amendments;
• response to April 22 instructions;
• substantial restructuring after the January filing.

 

 

June 15 — Defendants' Resistance

D0104

Placeholder for the new arguments and requested disposition.

June 22 — Reply and Reply Brief

D0105–D0106

Document the cited authorities, drafting length, and why both were required.

June 24-25 — Second Discovery and Scheduled Filings

D0107–D0108

The screenshot shows:

• omnibus motion;
• second discovery requests;
• email correspondence;
• cited authority;
• clerical corrections.

This is strong evidence that the case remained actively burdensome after the ballot deadline and while the Pate reconsideration process was unfolding.

June 24, 2026 — (see second set of discovery requests, D0107)

 

1.) Denied my motion for leave to amend (D0110) — In Iowa civil cases, a Motion for Leave to Amend is a request asking the judge for permission to change a pleading, such as a complaint, petition, or answer. Under Iowa law, "leave to amend... shall be freely given when justice so requires"

Exhibit A — Correspondence and Filings Before the Iowa Civil Rights Commission (ICRC)

Exhibit B — Open Mic and Flier Agreements and Related Communications

Exhibit C — Garden and Prairie Agreements and Related Communications

Exhibit D — Allegations of Stalking and Harassment: Statements v. Contemporaneous Communications

Exhibit E — Allegations Concerning Defendant Martinez and Contextual Communications

Exhibit F — Statement by Defendant Esker and Contradictory Prior Communications

Exhibit G — Litigation Conduct and Continuing Damages (2023-2026)

2.) Granted Defendants' motion for summary judgment (D0111) — 

Although I was in the nearly finished drafting a memorandum which cited several cases I believe will prevent this case from setting a devastating and wholly unjust precedent, 

VI. District Court Sides With "Dangerous Argument"

 

On June 15 I filed a Revised Second Amended Petition and Renewed Motion for Leave to Amend, which was substantially more focused, less sprawling, and conformed to Judge Doyle's April 22 instructions. 

On July 15, Judge Doyle denied my motion for leave to amend and granted Defendants' motion for summary judgment (D0111). Please note that I filed tooth-and-nail against the motion for summary judgment because I knew how dangerous and consequential this would be for so many Iowans, if granted. Those filings are included in the article. 

Also note that, in her order denying my motion for leave to amend, Judge Doyle recounted several parts of the proceedings, but did not account for the abuse of process claims alleged in the January 6 and June 15 petitions. I believe that severely prejudiced my right to due process, and that the facts must be put before a jury and a fair trial.

 

 

Judge Doyle Adopted the Absolute-Privilege Rule
Despite Acknowledging That No Iowa Appellate Court Had Directly Decided the Question

On July 15, 2026, Judge Angela Doyle granted defendants' motion for summary judgment.

The order (D0111) acknowledged:

“No Iowa appellate court has directly addressed whether statements made in direct response to an ICRC investigation, as opposed to statements made in formal ICRC contested case hearings, are absolutely privileged.”

The court nevertheless concluded:

“The Court concludes that the ICRC conducts proceedings are quasi-judicial in nature, and that statements made in direct response to an ICRC investigation are absolutely privileged under Iowa law.”

It then applied that conclusion to my surviving claim:

“The Court finds the statements at issue in Count II are absolutely privileged as a matter of law because they were part of a quasi-judicial proceeding and the absolute litigation privilege applies.”

Most importantly, Judge Doyle explained that absolute privilege turns:

“not on the content or truth of those statements.”

The court therefore granted summary judgment and dismissed the remaining case with prejudice.

 

VI. Two July 15 Orders Ended the Case Before Discovery or Trial

 

 

On April 22 Judge Doyle clarified that my Second Amended Petition was not operative. She ruled that my motion for leave to amend (the filing that asks permission to allow an amended petition to become operative) was denied without prejudice, and provided explicit directions for how it must be filed in order to be considered by the court. 

July 15 — Two Dispositive Orders

D0110–D0111

Treat these as one procedural turning point:

One order prevented the revised claims and reorganized record from becoming operative. The second then treated the narrowed 2024 pleading as containing only the surviving libel claim, applied absolute privilege, and dismissed the case.

That relationship is already stated clearly in the consolidated motion.

July 16 — Defendants' Resistance to Various Filings

D0109

This may belong before the July 15 rulings chronologically only if the timestamp/order sequence is verified. The screenshot shows July 16, so describe it afterward unless the document itself clarifies what it addressed.

7 — Consolidated Reconsideration Record

July 30–31 — Consolidated Reconsideration Record

D0112–D0113

This deserves a dedicated section, not a closing footnote.

The docket shows that D0112 included:

• the consolidated Rule 1.904 motion;
• the supplemental privilege memorandum;
• the main Iowa’s Broken Judiciary article;
• Iowa’s Civil Rights Trap;
• Procedural Bombardment.

D0113 added Plausible Deniability because of file-size limits.

The July 30 filing was not a short request to “try again.” It required me to review two interdependent final orders, complete a fifty-three-page memorandum addressing a major common-law immunity doctrine, reconstruct the amendment and discovery history, explain why the two rulings had to be reconsidered together, and organize multiple public-facing record summaries as exhibits. The consolidated motion itself was fourteen pages; the incorporated memorandum exceeded fifty pages.

On July 30, I filed a consolidated motion to reconsider both July 15 orders (D0012), which included an attached Memorandum (D0012) that was incorporated into my filing. The Memorandum was extensive, but incomplete, due to time constraints. I was going to file it the same day I received notice that the motion for summary judgment was filed, however Judge Doyle 

By this time, this case had already collided with the petition-gathering period needed for meet the June 2 deadline to get on the ballot for Iowa Governor. Nine deadlines in this case, including two hearing, had already interfered with my schedule so severely that I filed a separate suit at equity, Wilson v. Pate, to request a deadline extension. That case is covered in the next and final article in this series (for now), Election Interference.

 

However, I requested the trial to be set to a later date (D0107, 6/24/26) because:

1. Defendants have refused to comply with discovery requests. Evidence that is essential toward proving my allegations is being withheld by the defendants. I filed a Motion to Compel Discovery (D0091, 4/14/26). In other words, I am requesting the court to order the defendants to comply with my pretrial discovery requests. This is discussed in detail below. 

2. On June 15, I filed a Motion for Leave to Amend and Revised Second Amended Petition (D0102, D0100). A motion for leave to amend is a formal request that the court allows you to amend your petition due to some improvement or clarification that makes it a more accurate, well-pled filing. If the court grants my motion, the Revised Second Amended Petition will become the operative pleading. Currently, the Amended Petition (D0020, 10/4/24) is the operative pleading, however, as noted by Judge Currie when she dismissed all of my claims except for defamation (10/4/24, D0036),

Sondra referenced several exhibits [that] are apparently saved in a Google Doc folder. The Court does not have access to the exhibits and does not consider them in addressing the motion to dismiss. See Rucker v. Taylor, 828 N.W.2d 595, 598 (Iowa 2013) (“[D]istrict courts generally do not consider facts outside the pleadings in evaluating a motion to dismiss.”).

I believe that several of my claims would not have been dismissed, had the court been able to view these exhibits. Also, after the ruling a legal professional indicated that my Amended Petition was not well-pleaded, and that if it were formatted as a more standard pleading, several of my claims would have likely moved forward. That is why I requested the court to allow the Revised Second Amended Pleading to become the operative pleadings (current petition recognized by the court as active). Right now they consider my previous petition "operative".  Pursuant to Iowa Rule of Civil Procedure 1.402, courts grant these motions "freely... when justice so requires." I argue that justice requires the court to grant leave to amend.

My Motion for Leave to Amend, Revised Second Amended Petition, and Exhibits A-G are presented here, and then the defendants' arguments against allowing this case to move to trial are presented below. 

Defendants' Arguments

Defendants filed a Resistance (D0104, 6/15/26), urging the court to deny my Motion for Leave to Amend, and arguing that:

1. My Amended Petition that was largely dismissed (except for one of my libel claims) ought to remain the operative pleadings,

Discovery was still unresolved

The unfairness did not stop there.

In the Reliable/Lockwood case, defendants sought summary judgment while discovery remained unresolved. I served written discovery on March 2, 2026. Defendants objected and, according to my motion, produced no responsive documents. I filed a motion to compel on April 14. A hearing was held on May 26, but no ruling had issued when I moved to continue trial and extend discovery.

The discovery I sought was not random.

It went to the heart of the case: authorship, preparation, transmission, chronology, reliance, republication, truth or falsity, damages, and the scope of any asserted privilege.

In other words, I was being forced to defend against summary judgment while still seeking the very discovery needed to test who prepared the submissions, how they were edited or transmitted, what chronology was presented, who relied on what, and whether the allegations were true or false.

The Reliable/Lockwood case remains active. Trial is currently scheduled for August 4, 2026, but the case is not in a stable trial posture. Defendants have moved for summary judgment. I have moved to compel discovery. My renewed request to file the Revised Second Amended Petition remains part of the procedural dispute. I have also asked the court to continue trial, extend discovery, defer summary judgment until discovery is completed, and hold a status conference or enter a revised scheduling order.

That matters because this is not merely old litigation I chose to keep alive. It is an active case involving unresolved discovery, disputed pleadings, summary-judgment pressure, and a pending trial date — all of which overlapped with the same period when Iowa required me to gather signatures for ballot access.

That is the legal environment I was navigating while also trying to qualify for the ballot.

 

These are not abstract legal theories. They arise from lived consequences: lost civil‑rights protections, lost medical care, false public‑record damage, years of litigation, and the loss of ballot access.

The defendants are asking the court to prevent my revised claims from moving forward and to dismiss the one remaining defamation claim without a trial.

In their Defendants’ Resistance to Plaintiff’s Renewed Motion to Amend (D0104, June 15, 2026), they ask the court to deny my renewed request to amend the petition. They also ask the court to grant their pending motion for summary judgment, enter judgment in their favor on the remaining defamation claim, and dismiss the case entirely.

Their central argument appears in their Defendants’ Statement of Material Facts and Memorandum of Authorities in Support of Summary Judgment (D0090, April 6, 2026). They contend that statements submitted to the Iowa Civil Rights Commission are protected by absolute privilege because the Commission’s process qualifies as a judicial or quasi-judicial proceeding.

Absolute privilege is a legal protection that can prevent a person from recovering damages for statements made during certain official proceedings, even when those statements are alleged to be false or malicious. The defendants state:

“The absolute privilege is distinct from the qualified or conditional privilege: it applies regardless of whether the statement was false, regardless of whether it was made with ill will, and regardless of whether it caused serious harm.”

— Defendants’ Statement of Material Facts and Memorandum of Authorities in Support of Summary Judgment (D0090, April 6, 2026), p. 5.

The defendants argue that the Iowa Civil Rights Commission functions like a court for purposes of this doctrine. They write:

“The ICRC satisfies every criterion for a judicial proceeding.”

They further state that the Commission’s investigative and adjudicative structure is “the hallmark of a quasi-judicial proceeding.”

— Defendants’ Statement of Material Facts and Memorandum of Authorities in Support of Summary Judgment (D0090, April 6, 2026), p. 6.

Based on that argument, the defendants contend that the truth or falsity of their submissions—and their reasons for making them—would not affect the outcome. They state:

“The dispositive feature of the absolute privilege is that it bars recovery even if the plaintiff can prove the statements were false, made with actual malice, and caused serious harm.”

They therefore ask the court to grant summary judgment before further discovery takes place.

— Defendants’ Statement of Material Facts and Memorandum of Authorities in Support of Summary Judgment (D0090, April 6, 2026), p. 8.

The defendants repeat this position in their Defendants’ Reply in Support of Motion for Summary Judgment and Resistance to Motion to Compel (D0093, April 27, 2026). They argue that discovery into the authorship, drafting history, metadata, accuracy, or selective compilation of the documents would make no legal difference because, in their view, the privilege applies to the submissions automatically if the Commission proceeding was quasi-judicial.

They state:

“No discovery, no amendment of the pleading, and no characterization of Defendants’ internal document-preparation process can change the legal character of the Iowa Civil Rights Commission proceeding in which those statements were made.”

— Defendants’ Reply in Support of Motion for Summary Judgment and Resistance to Motion to Compel (D0093, April 27, 2026), p. 2.

And later:

“It does not turn on whether the submission was accurate or selectively compiled—the privilege protects inaccurate and even malicious statements in quasi-judicial proceedings.”

— Defendants’ Reply in Support of Motion for Summary Judgment and Resistance to Motion to Compel (D0093, April 27, 2026), p. 4.

Defendants’ Statement of Material Facts and Memorandum in Support (D0090),

Page in making. Please check back soon. everything below is being edited. 

To make sense of all this, we need to back the story up, and explain how things got to this point. Why don't the defendants want to share discovery?

This Case Could Destroy Civil Rights Protections in Iowa

summary-judgment argument is that statements submitted during an Iowa Civil Rights Commission investigation are protected by absolute privilege, even when the person making the statements allegedly knew they were false.

They argue that this presents a question of law rather than fact. For that reason, they contend that the court does not need to determine:

1. 1. Who actually wrote or edited the disputed documents.
   2. Whether drafts or earlier versions exist.
   3. Whether the documents were altered.
   4. Whether relevant information was deliberately omitted.
   5. What communications occurred while the documents were being prepared.

The defendants also argue that my discovery requests are irrelevant, burdensome, and harassing. In their Reply in Support of Summary Judgment and Resistance to Motion to Compel (D0094, 4/27/26), they state that no discovery concerning their internal document-preparation process could change whether their statements are legally privileged.

The defendants argue that the court should deny my Renewed Motion for Leave to Amend, and that my my previous Amended Petition (D0020, 6/17/24).

They contend that my Revised Second Amended Petition improperly attempts to revive claims the court dismissed in 2024. They therefore ask the court to:

1. Deny leave to amend.
2. Grant their Motion for Summary Judgment (D0089, 4/6/26).
3. Dismiss the entire case.

My Rebuttal

I contend that the court should not grant summary judgment before I have been allowed to obtain evidence directly relevant to the disputed documents.

My Motion to Compel (D0091, 4/14/26) asks the defendants to produce basic information concerning the preparation of the documents submitted to the Iowa Civil Rights Commission, including:

1. The identity of each person who wrote or edited the documents.
2. Drafts and earlier versions.
3. Native electronic files.
4. Metadata and revision histories.
5. Communications concerning the preparation and submission of the documents.

These requests are not based on speculation. The documents contain disputed statements, disputed chronology, apparent omissions, and information attributed to multiple defendants. The requested evidence may show who created the statements, how they changed, and whether the final submissions accurately reflected the underlying information.

The defendants are asking the court to rule that their statements are absolutely protected while simultaneously refusing to produce evidence showing how those statements were created.

I contend that this would allow a person responding to a civil-rights investigation to submit false or misleading information, prevent the opposing party from examining how it was produced, and then avoid accountability merely because the information was submitted to a government agency.

That is the dangerous precedent at the center of this case.

My Argument

The Four Petitions That Have Been Filed

 

 

Original Petition

Amended Petition

Second Amended Petition

Revised Second Amended Petition

Motion for Leave to Amend, Revised Amended Petition, and Exhibits A-G

(Proposed filings — not yet accepted by the Court)

What These Filings Are In January 2026, I filed a Second Amended Petition along with a Motion for Leave to Amend. The Court denied that request on April 22, 2026, ruling that the filing was too long, contained defects, and did not comply with Iowa’s pleading rules. The Court also clarified that the June 17, 2024 Amended Petition remains the operative pleading, and that all claims except written defamation (Libel II) remain dismissed with prejudice.

On June 25, 2026, I filed a Revised Second Amended Petition together with a Renewed Motion for Leave to Amend (D0102, D0100). This new filing was created specifically to cure the defects the Court identified in April.

What the Revised Petition Does The Revised Second Amended Petition:

• • reorganizes the factual record chronologically,

  • shortens the pleading from 115 pages to ~62,

  • removes unverified citations,

  • consolidates overlapping claims,

  • incorporates Exhibits A–G directly into the factual narrative, and

  • clarifies claims based on conduct occurring after the original petition was filed.

It presents a clearer, evidence‑supported account of the agreements, communications, administrative proceedings, and alleged misrepresentations from 2021–2026.

Why Amendment Is Being Requested The Court dismissed most of my claims in October 2024 because the exhibits referenced in my Amended Petition were not before the Court. The Revised Second Amended Petition corrects that problem by presenting the full factual record in an organized, properly supported format.

Under Iowa R. Civ. P. 1.402(4), courts “freely” grant leave to amend when justice requires. I contend that justice requires allowing the revised petition to become operative so the Court can evaluate the claims on a complete record rather than on the incomplete pleading filed in 2024.

Why These Filings Matter This entry helps readers understand:

• • What was filed: a motion + a reorganized petition.

  • Why it was filed: to correct defects and present the full factual record.

  • What happened: the January version was denied; the June version was filed to comply with the Court’s instructions.

  • What is pending: the Court must decide whether to accept the revised petition or, as Defendants request, deny amendment and instead grant summary judgment.

Operative Petition

Read: Plaintiff’s Reply Brief in Support of Renewed Motion for Leave to File Revised Second Amended Petition
Read: Plaintiff’s Reply in Support of Renewed Motion for Leave to File Revised Second Amended Petition

 

 

If the court accepts the argument Defendants have recently presented to the court, this case will set a dangerous precedent for all protected classes under the Iowa Civil Rights Act. This article presents my understanding  of where the the case currently stands, what led up to this situation, and 

 

case could establish a dangerous precedent for civil-rights complainants in Iowa. The defendants argue that statements and materials submitted to the Iowa Civil Rights Commission are absolutely protected from liability, while also opposing discovery into how the disputed materials were created, edited, arranged, and submitted.

If the court accepts that position, respondents could potentially use false or manipulated materials to shape a civil-rights record, defeat a complaint, and then prevent meaningful scrutiny of what occurred.

The outcome will also profoundly affect my safety, financial stability, reputation, public work, and future. I am representing myself because I have been unable to find or afford counsel. I am urgently seeking an attorney or experienced legal professional who can represent me, provide limited-scope assistance, consult, review filings, or help with discovery and appellate strategy.

Anyone who may be able to assist or provide a qualified referral may contact me at Sondra.Wilson7777@gmail.com.

 

This article explains the live dispute in Wilson v. Reliable Street Inc., et al.  Trial is currently scheduled for August 4, 2026. I have asked the court to continue the trial, extend discovery, and resolve the pending discovery (D0107) dispute because the defendants have not produced materials I requested that bear directly on key facts in the case.

This article presents my firsthand testimony, court filings, documents and communications in my possession which the court has not yet, and may or may not choose to accept, and my sincere understanding of what occurred, and where the case stands now. Some of the materials presented here have been filed with the court. Others were submitted as part of my proposed Revised Second Amended Petition (D0101) and accompanying exhibits, which the court has not yet accepted as the operative pleading. Additional materials I have requested through discovery have not been produced.

It is therefore possible that some of the evidence published in this article will never be formally admitted into evidence or considered by the court. If the court accepts the defendants’ position that the remaining claim should be dismissed as absolutely privileged before discovery is completed, the defendants may never be required to produce the drafts, native files, metadata, revision history, and communications that I believe would confirm key parts of this account.

This article is not written as a neutral report by an outside journalist. It is my firsthand testimony, supported by the documents currently available to me and presented so readers can examine them directly. The defendants dispute many of the facts described here, and the court has not entered a final judgment determining the truth of the parties’ competing accounts.

Several of my claims were previously dismissed. I believe they were wrongly dismissed before the court considered the complete exhibit-supported account, and I intend to seek appellate review if necessary. My renewed request to amend remains pending, so the court may never accept or rule on several of the claims and exhibits discussed in this article.

I cannot predict how the court will rule. I have encountered procedural barriers, highly technical rules, and legal doctrines that, in my experience, have repeatedly prevented the case from reaching the full facts of what happened. A court ruling may ultimately turn on pleading requirements, privilege, procedure, or other legal doctrines rather than a determination that the events described here did or did not occur.

That is one reason I am publishing the supporting materials directly. Regardless of which evidence the court ultimately accepts, readers can examine the available communications, filings, timelines, and exhibits and reach their own conclusions.

I believe many Iowans will agree that ordinary people should not lose access to justice because they cannot afford an attorney, cannot obtain evidence controlled by the opposing party, or fail to navigate rules so complex that the underlying facts are never meaningfully heard.

Dangerous precedent — The defendants  have put forth a dangerous argument which, if the court accepts, would create a dangerous precedent. Thus, this case is bigger than me, and I suspect many other Iowans will want to know about it, and make sure that this case is not lost as a result of my inexperience. I need help, and thus far have been been unable to find (or afford) counsel. If anyone can help, please contact me at Sondra.Wilson7777@gmail.com.

Personal Safety — Defendants have already requested the court to assign their attorney's fees to me.  If the court sides with the defendants' arguments and assigns approximately four years of attorney's fees to me, I would be required to pay tens of thousands of dollars to a group of people who used me for labor that I was not paid for, discriminated against me under false pretenses, and harmed my reputation, then lodged false, severely damaging accusations against me into government records. Although the Iowa Civil Rights Act explicitly prohibits retaliation, it doesn't define what the defendants did as retaliation within the Iowa Code, therefore the court might not interpret it that way. Regardless, if 

The case Wilson v. Reliable Street Inc., et al. asks a dangerous question for civil rights in Iowa:

Can businesses submit false statements, misleading narratives, or altered documents to a civil‑rights investigator — have those materials shape official government records — and then avoid accountability by claiming those submissions are absolutely protected?

That is the issue now before the Iowa District Court for Story County.

Note: This article explains the live court dispute. For the longer article, which tells the backstory on how this case reached this point, read:

How Iowa's Civil Rights Process Harms The People It Was Designed to Protect:
An exposé on the Iowa Office of Civil Rights, Broken Judiciary, and What's Really Going on with the Reliable/Lockwood Case

That procedural history matters because the defendants now argue that the earlier dismissal should permanently narrow the case, even though the court has still never examined the full exhibit-supported record.

My position is straightforward: the dismissed claims should not have been dismissed without the court seeing the evidence. My Revised Second Amended Petition now places that record before the court in organized form, with more than one hundred exhibits showing communications, timelines, agreements, exclusions, agency submissions, and factual context that were not previously examined.

The court has not yet accepted that Revised Second Amended Petition. My Motion for Leave to Amend is still pending. That means the underlying facts and exhibits have not yet been fully examined.

Meanwhile, the defendants are asking the court to keep the case narrowed to the single remaining defamation claim — and then dismiss that claim too.Read: Defendants’ Motion for Summary Judgment
Read: Defendants’ Statement of Facts and Memorandum in Support of Summary Judgment

I have also asked the court to resolve the pending motion for leave to amend before summary judgment, compel discovery, continue trial, and extend discovery so the case is not decided before the disputed documents and communications are produced.

Read: Plaintiff’s Resistance to Summary Judgment and Motion to Compel Discovery

The defendants oppose that discovery. They argue that absolute privilege makes the disputed facts irrelevant. In effect, they are asking the court to decide the case before I receive the drafts, metadata, native files, revision history, and communications that could show how the June 28, 2022 submission was created, edited, arranged, and used.

Read: Defendants’ Reply in Support of Summary Judgment and Resistance to Motion to Compel

That is the danger at the center of this case: if respondents can submit false or manipulated materials to a civil-rights agency, shape the government record, defeat the complaint, and then block discovery by claiming absolute privilege, civil-rights complainants are placed in a trap the law was never meant to create.

What the defendants argue

The defendants are not simply arguing that I am wrong. They argue that the court should end the last remaining claim before discovery because the statements they submitted to the Iowa Civil Rights Commission are protected by “absolute litigation privilege.”

In plain language: They claim that the statements and materials they submitted to the Civil Rights Commission — even if false, harmful, misleading, or damaging — cannot support a defamation claim.

They argue the privilege applies to judicial and “quasi‑judicial” proceedings, and that an Iowa Civil Rights Commission investigation qualifies. Under their theory, the privilege applies even if the statements were inaccurate, malicious, or damaging.

They also oppose my Motion to Compel Discovery. They are resisting production of draft versions, native files, metadata, revision history, and communications about preparing the June 28, 2022 submission.

So their position is not only that the case should be dismissed. Their position is that I should not receive the discovery needed to show how the disputed materials were created, edited, arranged, submitted, and used.

Why absolute privilege requires a closer, context-specific look

There is an important reason the defendants’ absolute-privilege argument should not automatically end this case.

In my reply brief, I cited Mills v. Denny, 245 Iowa 584, 588–89, 63 N.W.2d 222, 224–25 (1954), an Iowa Supreme Court case explaining that whether privilege is absolute or qualified depends on the occasion and circumstances involved. In other words, privilege should not be applied mechanically simply because a statement was connected to an official proceeding. The context matters.

That matters here because the defendants are not merely asking for protection for ordinary participation in a civil-rights investigation. They are asking the court to apply absolute privilege even where I allege that respondents created or relied on a false factual record, selectively compiled or altered documents, reversed chronology, omitted contrary communications, and caused the civil-rights agency to rely on a distorted record.

My argument is that this goes beyond protecting candid participation in an administrative process. It would turn a doctrine meant to protect truth-seeking into a shield for alleged corruption of the truth-seeking process itself.

I am not asking the court to punish someone simply for responding to an Iowa Civil Rights Commission complaint. I am asking the court to recognize that absolute privilege should not become categorical immunity for allegedly false, altered, misleading, selectively excerpted, or chronologically distorted submissions that defeat a civil-rights complaint before the complainant ever receives a fair chance to challenge the record.

Civil-rights law is supposed to protect people who report discrimination and retaliation. That protection becomes hollow if respondents can lodge false statements, misleading narratives, or altered documents into government records — and then claim those materials are absolutely immune from accountability.

That creates an implicit threat against every civil-rights complainant:

File a complaint, and the people you complained about may be able to place damaging accusations about you into official records — accusations that shape the investigation, deny you remedies, follow you into future proceedings, harm your reputation, and remain shielded from accountability because they were submitted inside the civil-rights process.

The Iowa Civil Rights Act was not designed to create an immunity zone where respondents can allegedly manipulate the administrative record, cause the complainant to lose civil-rights remedies, and then avoid discovery because the manipulation occurred inside the civil-rights process.

The Revised Second Amended Petition alleges that these materials were incorporated into administrative and judicial records, contributed to the denial of administrative remedies, harmed my reputation, and continue to create future risk because those records remain capable of being cited, relied upon, repeated, or republished.

So the issue is not simply whether I disagree with what the defendants said.

The issue is whether civil-rights respondents can use the government complaint process itself to distort the record, defeat the complaint, and then avoid discovery by invoking absolute privilege.

Why discovery matters

Discovery is the part of a lawsuit where parties must turn over documents, drafts, metadata, communications, and sworn answers. It is how courts determine what actually happened instead of relying only on one side’s description of events.

In this case, discovery matters because the dispute is not only about what the defendants said. It is also about how the documents and statements were prepared, edited, arranged, and submitted.

I filed a Motion to Compel Discovery because the defendants have refused to produce key materials, including:

• draft versions

• native files

• metadata

• revision history

• communications about the June 28 submission

These materials could show who created the documents, how they were edited, whether communications were rearranged, whether screenshots or written materials were altered or selectively excerpted, and whether the final submission accurately reflected the underlying communications.

The defendants argue discovery is irrelevant because, in their view, the only question is whether the Civil Rights Commission process was “quasi‑judicial.” Under their theory, even deliberately false or manipulated submissions would be absolutely privileged.

That is why this case is so dangerous.

If the court accepts that argument before discovery, then the people accused of shaping the government record through false or manipulated materials may never have to produce the drafts, metadata, communications, or revision history that could show what happened.

Why this case matters beyond me

Civil-rights agencies exist to investigate discrimination and retaliation complaints and protect the public from unlawful discrimination. But if respondents can submit false or manipulated materials, have those materials shape official records, and then claim total immunity, the process becomes dangerous for the very people it was created to protect.

This spring — while finishing a full‑time semester and running an independent campaign for Governor of Iowa — I compiled and filed a Revised Second Amended Petition with more than one hundred exhibits. These exhibits show the communications, timelines, agreements, exclusions, agency submissions, and factual context that the court has never fully examined.

I am representing myself because I have not been able to obtain civil‑rights counsel. I am doing my best as a pro se litigant to keep my mouth above water in a case I cannot afford to lose — not only because of the continuing harm to my own reputation, safety, campaign, and future, but because of what this ruling could mean for minorities and civil‑rights complainants across Iowa.

The defendants argue that all claims except one were already dismissed with prejudice, and that the remaining libel claim should now be dismissed on summary judgment.

Summary judgment allows a court to end a claim without trial if there is no genuine factual dispute. But here, the missing facts concern the very documents and communications discovery is supposed to uncover.

The core question

So the question before the court is not only about me.

Will Iowa courts apply privilege in a careful, context-specific way that protects honest participation in civil-rights proceedings while allowing discovery into allegedly false, misleading, or altered submissions — or will respondents be able to shield those submissions from scrutiny by invoking absolute privilege?

If the defendants’ argument is accepted broadly, it could create a dangerous precedent: civil‑rights complainants could be harmed by official records shaped by manipulated materials, while the people who submitted those materials claim they cannot be held liable because the deception occurred inside the civil‑rights process.

This case urgently needs attention from civil‑rights lawyers, defamation lawyers, legal scholars, journalists, and Iowans who care about whether civil‑rights investigations can still be trusted.

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To understand how Iowa’s civil-rights process failed before this lawsuit became necessary, read:

Iowa Is Failing the People Civil Rights Law Was Meant to Protect.

Part Eight:
Election Interference — Wilson v. Pate

That collision became the basis of Wilson v. Pate.

By May 2026, the question was no longer theoretical. The Reliable Street litigation was generating mandatory obligations during the same finite period Iowa law provided for gathering the signatures necessary to reach the gubernatorial ballot.

On May 27—six days before the June 2 deadline and one day after a Reliable Street hearing—I sought additional time to complete Iowa's existing ballot-access requirements.

I was not asking to waive the signature requirement. I was asking for additional time to satisfy it.

The district court ultimately characterized the litigation burden as ordinary, foreseeable, and voluntary.

I adamantly dispute that characterization.

That conclusion treats the filing of the original petition as though it answers the entire causation question. This series is intended to show why I believe it does not.

Record Retaliation asks what happened before the lawsuit.

Iowa's Civil-Rights Trap asks why the administrative process failed to resolve it and why I entered court under severe time pressure.

Political Sabotage asks what I discovered when I finally obtained the underlying evidence and why allowing claims arising from that record to expire was not an option I could safely accept.

Procedural Bombardment, Sudden Reversal, Plausible Deniability, and Dangerous Precedent document what happened after I entered court and why the litigation continued consuming increasing amounts of time.

Whether the resulting exclusion from the ballot should stand is now before the Iowa Supreme Court in Wilson v. Pate.

Click the image below to follow the live case.

References

 Ballantine’s Law Dictionary Legal Assistant Edition
by Jack Ballantine (James Arthur 1871-1949).  Doctored by Jack G. Handler, J.D. © 1994 Delmar by Thomson Learning.  ISBN 0-8273-4874-6.

[1]: Motion for Summary Judgment, Black’s Law Dictionary 1842 (10th ed. 2014) (defining a motion for summary judgment as “[a] request that the court enter judgment without a trial because there is no genuine issue of material fact to be decided by a fact-finder—that is, because the evidence is legally insufficient to support a verdict in the nonmovant’s favor”).

[1]: See Discovery Abuse, Black’s Law Dictionary [page number] (10th ed. 2014) (defining discovery abuse as “[t]he failure to respond adequately to proper discovery requests”).

 

Additional Reliable/Lockwood Case Materials: Current Procedural Posture

The following documents provide additional context for where the Reliable/Lockwood case currently stands. Trial is presently scheduled for August 4, 2026, but multiple issues remain pending, including Defendants’ motion for summary judgment, my motion to compel discovery, my renewed request to file the Revised Second Amended Petition, and my request to continue trial and extend discovery.

I am including these materials because they show why the case remains active, why discovery matters, and why the litigation continued to impose major burdens during the ballot-access period.

Defendants’ Motion for Summary Judgment
Link to PDF: https://wildwillpower.org/wp-content/uploads/2026/06/4-6-26-DEF-Mot-for-Summary-Judgment-2.pdf 
Defendants ask the court to enter summary judgment on the remaining libel claim, arguing that statements submitted to the Iowa Civil Rights Commission are protected by litigation privilege and that the claim should be dismissed as a matter of law.

Defendants’ Statement of Material Facts and Memorandum in Support of Summary Judgment
Link to PDF: https://wildwillpower.org/wp-content/uploads/2026/06/4-6-26-DEF-Facts-in-Support-of-Summary-Judgment.pdf 
This filing sets out Defendants’ factual and legal arguments in support of summary judgment, including their position that the ICRC submissions were privileged, true, conditionally privileged, and not capable of supporting damages.

Plaintiff’s Resistance to Summary Judgment, Motion to Compel Discovery, and Motion to Clarify Operative Pleading
Link to PDF: https://wildwillpower.org/wp-content/uploads/2026/06/4-14-Mot-to-Compel.pdf 
In this filing, I opposed summary judgment, asked the court to compel discovery, and requested clarification of the operative pleading. I argued that Defendants were seeking summary judgment while withholding discovery concerning authorship, alteration, metadata, communications, chronology, transmission, truth or falsity, republication, damages, and privilege.

Defendants’ Reply in Support of Summary Judgment and Resistance to Motion to Compel
Link to PDF: https://wildwillpower.org/wp-content/uploads/2026/06/4-27-26-Reply-in-Support-of-MSJ-and-Resistance-to-Compel.pdf 
Defendants responded that further discovery was unnecessary because, in their view, the privilege issue is a legal question and the alleged publication occurred within the ICRC proceeding. They also resisted my motion to compel and argued that additional discovery would not change the legal character of the ICRC submissions.

Plaintiff’s Reply and Reply Brief in Support of Renewed Motion for Leave to File Revised Second Amended Petition
Link to Reply: https://wildwillpower.org/wp-content/uploads/2026/06/Plaintiffs-Reply-to-Resistance-to-Mot-to-Leave-to-Amend.pdf 
Link to Reply Brief: https://wildwillpower.org/wp-content/uploads/2026/06/Plaintiffs-Reply-Brief-to-Resistance-to-Mot-to-Leave-to-Amend.pdf 
These filings respond to Defendants’ resistance to my renewed request to file the Revised Second Amended Petition. I argued that the revised pleading was shorter, reorganized, exhibit-supported, responsive to the court’s April 22 order, and necessary to place the factual record before the court in a usable form before summary judgment or trial.

Plaintiff’s Motion to Continue Trial, Extend Discovery, Defer Summary Judgment, and Request Status Conference
Link to PDF: https://wildwillpower.org/wp-content/uploads/2026/06/Plaintiffs-Mot-to-Continue-Trial-and-Extend-Discovery.pdf 
This filing asks the court to continue the August 4, 2026 trial date, extend discovery and pretrial deadlines, defer summary judgment until discovery is completed, and hold a status conference or enter a revised scheduling order. I argued that the case is not trial-ready while discovery, summary judgment, the operative pleading, and the motion to compel remain unresolved.