What Happened After the Lawsuit Was Filed:
Procedural Bombardment

10 Days to Resist Five Same-Day Motions.
A Judge Required to Recuse—Who Ruled Anyway.
Transferred to Story County on Misrepresented Iowa Code.
A Complex Record Buried in the Docket.

By Sondra Wilson | Updated September 14, 2026

New to this case? This article is Part Four of an eight-part series. For the current appellate status, why the case matters statewide, and a roadmap to the complete series, begin with the Wilson v. Reliable Street Inc., et al. landing page.

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Notice and Disclaimer

 

This article is being actively reconstructed as I prepare the appellate record.

This series draws from nearly five years of communications, administrative records, court filings, exhibits, and firsthand experience. I am making a good-faith effort to reconstruct the record accurately and to distinguish documented facts, firsthand testimony, allegations, legal arguments, and conclusions I draw from the evidence.

Because I personally participated in these events, I am not writing as a disinterested third-party observer. Where firsthand knowledge matters, I describe what I personally experienced, observed, and understand to be true. Where questions remain unresolved—particularly questions involving another person's knowledge, intent, private communications, authorship, or coordination—I identify them as unresolved where appropriate.

As this reconstruction continues, citations, links, wording, and factual details may be clarified or corrected to conform more precisely to the underlying record.

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Before You Read This Article

Procedural Bombardment is Part Four of the Wilson v. Reliable Street Inc., et al. series.

This installment begins at the courthouse. But the procedural history cannot be understood in isolation from what happened before the lawsuit was filed.

Parts One through Three establish the factual and administrative record that brought me there:

• Record Retaliation reconstructs the relationships, agreements, communications, and events leading to my March 31, 2022 exclusion—and the sharp contrast between that contemporaneous record and the accusations later made about me.
• Iowa's Civil-Rights Trap documents what happened when I tried to challenge those accusations through Iowa's civil-rights process, obtain the underlying evidence, find counsel, and determine where the alleged misconduct could be investigated.
• Political Sabotage examines what I discovered when I finally obtained the complete ICRC file: direct statements, reinforcing allegations, disputed documentary presentations, and evidence that I contend materially changed the legal and reputational stakes of the case.

Readers who have not followed those installments should begin with the series landing page.

By the time this article begins, the underlying conflict was already substantial. I had received the complete ICRC file only shortly before the litigation deadline, was proceeding without counsel, and attempting to bring multiple legal claims arising from a complex record that was scattered and could only be proven via re-assembling the written communications between myself and the seven defendants.

This article shows what happened at the outset of the case, after the suit was filed.

The Polk County Record Became "Buried" Inside a 144-page PDF That is Now Unpacked in This Article

The filings described in this phase were originally entered separately in Polk County case number LACL157381. When the case was transferred to Story County, however, the entire Polk County record was transmitted as a single 144-page certified binder and filed under one Story County docket entry: D0001.

As a result, the individual filings, orders, and procedural disputes from this phase no longer appear as separate entries in the current docket. Instead, they are embedded—sometimes with overlapping or repeated material—inside one large document that must be searched page by page. In practical terms, this buried the complexity of what occurred in Polk County. It also obscured several rulings and unresolved burdens that I believe were unjustly imposed upon me. Those issues did not disappear after the transfer; instead, the full history remained much more difficult to reconstruct. 

The complete transferred record—in effect, the entire official record that is unpacked in this article—was compressed into a 144-page "D0001" PDF that was then transferred to Story County.

What transpired during this part of the case was extremely consequential for multiple reasons, that will become evident as you read through the series. 

 

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Table of Contents

I. Dec. 5, 2023-Feb. 22, 2024: Filed Petition and Served Defendants and Filed Related Case, Wilson v. State  and Kim Reynolds for Iowa

II. Feb. 29, 2024: Defendants Filed Five Motions Within a Five Minute Period, Leaving Only 10 Days to Respond to Their Barrage of Filings

III. March 15, 2024: I Filed Four Motions and Four Resistances to Counter The Barrage

5. Rule 51:2.11 Required Judge Gronewald to Disqualify Herself if Her Impartiality Might Reasonably Be Questioned—She Denied Recusal and Ruled Anyway
The motion to recuse, Rule 51:2.11, the request to decide recusal first, and the same-day ruling.

4. I Asked for Limited Time While Studying Abroad—Then My Emergency Filings Were Used Against Me
How the continuance request, professors’ extensions, and defendants’ “ably file documents from London” argument created a self-reinforcing pressure cycle.

6. Polk County Was Treated as the “Wrong County” Despite § 616.18
The defense venue representation, your resistance, the statute, the transfer order, and why Story County being another proper venue does not establish Polk County was improper.

7. The Transfer Ruling Was Then Used to Seek Money From Me
The motion to enlarge, $478 attorney fees, $41 costs, transfer fee, and the court’s ultimate ruling assigning the filing fee to you.

8. Defendants Changed Position on Service After Obtaining Transfer
The sequence: challenge service, obtain transfer, accept service, join the other motions.

9. The Entire Polk County Record Was Buried in D0001
How a sequence of separate filings became one 144-page transferred docket entry.

10. Why This Phase Matters to My Abuse-of-Process Claim

 

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Dec. 5, 2023-Feb. 22, 2024:

I. Filed Petition and Served the Defendants;
and Filed Related Case, Wilson v. State and Kim Reynolds for Iowa,
Then Left for DMACC's London Abroad Program

 

On December 5, 2023, I filed a two-page petition in Polk County District Court against Reliable Street Inc., Lockwood Café, Lyndsay Nissen, Sharon Stewart, Willa Colville, Denise Martinez, and Charlie Esker.

The petition alleged discrimination, fraud, defamation, promissory estoppel, and unjust enrichment.

Its brevity cannot be understood apart from the timing documented in Iowa's Civil-Rights Trap.

I did not receive the complete ICRC file until October 11, 2023. By then, the right-to-sue process left me only fifty-five days to review a newly disclosed multi-party evidentiary record, determine what legal claims it supported, identify the roles of numerous people whose private communications I could not yet access, and file suit before the deadline expired—all without an attorney. Iowa's Civil-Rights Trap documents how that compressed window arose.

That distinction matters because the December 5 petition was not the product of years of leisurely litigation preparation. It was the first pleading I could assemble before the deadline expired after finally obtaining the evidence that substantially changed my understanding of the case.

The petition now appears on pages 143–144 of D0001 because, after the case was transferred to Story County, the separate Polk County filings from this phase were transmitted together as a 144-page certified record and filed under a single Story County docket entry. As explained below, that consolidation made the earlier procedural history considerably harder to reconstruct from the current docket.

After filing Wilson v. Reliable Street Inc. et al, on Dec. 5, on February 8, 2024 I filed a directly-related case, Wilson v. State and Kim Reynolds for Iowa.

On February 9, 2024, two important things happened: I left for London and served the Defendants.

I Arrived in London

 

 I left for London through DMACC's London Abroad program.

My research included collaboration with a Mesopotamian artifacts curator at the British Museum, and a professor at the University of Oxford who also assisted me in the same project. The project itself was central to my academic pursuit, and was largely funded through the Benjamin A. Gilman International Scholarship Program and DMACC Foundation.

As a direct result of the procedural bombardment performed by Defendants during my semester, which they were given notice of through my filings, contractual obligations between myself, Gilman, DMACC Honors, and the DMACC Foundation were interfered with. That is in part why multiple counts of tortious interferences with contractual relations were later pleaded in my 2026 Second Amended and Revised Second Amended Petitions. Part Seven in this series, Dangerous Precedent, provides documentation regarding the denial of my motions for leave to amend, which resulted in the facts alleged in those pleadings to no receive due process. 

As you will see below, notifying the defendants that I was studying abroad, and requesting a continuance until after the semester was over, was not met with consideration, but instead with increased litigation pressure through a second barrage of filings which escalated the situation, increased burden, and interfered with my academic obligations and contractual relations.  

Latest update on this issue: l filed a Notice of Appeal on September 9, and am currently seeking to my dismissed claims remanded, and the interlocutory orders denying leave to amend my petition for these petitions, reversed. In lay terms, my academic obligations became unmet as a direct result of defendants' conduct during this part of the proceedings. Conduct described in this article helps support the abuse-of-process claims that were also alleged in my 2026 petitions. 

Story County Sheriff's Deputy Served Process at the Defendants' Shared Business Address

Going into detail about how process is served is not something I would normally do in this article, however the manner in which service occurred on February 9, 2024 would become important twenty days later, when five defendants moved to have the case dismissed for various reasons, including what they alleged was improper service. We will get into that later in the article. 

First, however, it is important to establish what actually happened.

When I requested service of process, I did not know the private residential addresses of the individual defendants. I was representing myself, and at that point I did not yet understand all of Iowa's technical rules governing the different methods of personal and substitute service. So, I did my best.

What I did know from firsthand experience was the place through which I knew these defendants: 4625 Reliable Street in Ames, the shared location of Reliable Street Inc. and Lockwood Café.

Reliable Street and Lockwood operated in adjoining, interconnected spaces within the same building. Lyndsay Nissen was president of Reliable Street. Sharon Stewart was both Lockwood Café's owner and operator and vice president of Reliable Street. Willa Colville worked at Lockwood. Charlie Esker had repeatedly exhibited artwork through Reliable Street's gallery. The relationships and activities connecting these people to the premises are documented more fully in Part One: Record Retaliation.

I therefore gave the Story County Sheriff's Office the business address through which I knew the defendants and reasonably understood they could be located or contacted.

On Friday, February 9, 2024, Story County Sheriff's Deputy Jason Grubbs went to 4625 Reliable Street. The Sheriff's records show that the papers had been received for service the preceding day, February 8, and that Deputy Grubbs made service at 9:30 a.m.

For Reliable Street Inc., Grubbs' return states:

“I hereby certify that the described ORIGINAL NOTICE, PETITION was served to RELIABLE STREET INC.

Type of service: SUBSTITUTE by delivering a copy to: LYNDSAY NISSEN a person at least 18 years of age described as PRESIDENT.

Address of service: 4625 RELIABLE STREET AMES, IA 50014

Date and time of service: 2/9/2024 9:30 AM”

Return of Service; D0001, p. 134.

For Nissen individually, Grubbs recorded personal service:

“I hereby certify that the described ORIGINAL NOTICE/PETITION was served to LYNDSAY NISSEN.

Type of service: PERSONAL by delivering a copy to: LYNDSAY NISSEN

Address of service: 4625 RELIABLE STREET AMES, IA 50014

Date and time of service: 2/9/2024 9:30 AM”

Return of Service; D0001, p. 136.

The remaining returns—for Lockwood Café, Sharon Stewart, Willa Colville, Denise Martinez, and Charlie Esker—likewise recorded delivery through Nissen at 4625 Reliable Street and classified the deliveries as “SUBSTITUTE” service.

The original notices and corresponding returns now appear together on pages 134–142 of D0001.  The completed returns were filed with the Polk County Clerk on February 22, 2024.

Why I Used 4625 Reliable Street

This was not an address I selected arbitrarily.

Reliable Street and Lockwood Café publicly operated from the same location. Their leadership, employees, activities, and physical spaces substantially overlapped. Reliable Street's own submission to the Iowa Civil Rights Commission identified:

“Lyndsay Nissen, President of Reliable Street INC. Sharon Stewart Vice President of Reliable Street INC.”

Quoted in Plaintiff's later March 15 filing; filing p. 6; D0001, p. 61.

The defendants themselves would later describe Stewart as the “owner and operator of Lockwood Café” and Colville as a Lockwood employee. Their February 29 filing likewise acknowledged that Lockwood Café operated “in the same building as Reliable Street.”

My understanding of Charlie Esker's connection was also based on firsthand experience. Although defendants later characterized Esker as a “former customer” of Lockwood Café, I had seen Esker's artwork exhibited through Reliable Street on multiple occasions. I later placed that fact before the court:

“in fact Esker has, on multiple occasions, had art exhibits wherein several pieces of their art were displayed as a primary exhibit within Reliable Street Inc.'s art gallery.”

Plaintiff's March 15 filing; filing p. 6; D0001, p. 61.

Esker had also supplied a statement during the earlier Iowa Civil Rights Commission proceeding arising from my complaint against Reliable Street and Lockwood Café. To me, that previous process further demonstrated that communication with Esker could occur through the businesses even though I did not possess Esker's private home address.

So the event itself was straightforward: I supplied the Sheriff's Office with the business location through which I knew the defendants; Deputy Grubbs went there at 9:30 a.m. on a Friday; he encountered Reliable Street's president; and he delivered the original notices and petitions at that address.

Whether those deliveries satisfied every technical requirement of Iowa's service rules was a different question—one I had not yet had reason or time to research in detail.

Twenty days later, defendants made that technical question one of five procedural issues I suddenly had to answer at the same time.

 

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Feb. 29, 2024:

II.  Defendants Filed Five Different Motions on the Same Day,
Leaving Me Only 10 Days to Respond to an Initial  Barrage of Filings

 

In a span of five minutes, defendants placed five separate procedural motions before the court in two coordinated filings. Iowa Rule of Civil Procedure 1.431(4) provided ten days after service to file written resistances:

“Unless otherwise ordered by the court or provided by rule or statute, each party opposing the motion shall file within ten days after a copy of the motion has been served a written resistance to the motion.”

Each of the following motions, as well as other serious issues which demanded response, is unpacked in greater detail below. It was this initial and subsequent barrages of filings from which this article, "Procedural Bombardment", derives its name. My responses, and how Judge Gronewald ruled on these filings, are also detailed below. 

First, at 4:04 pm on February 29, Attorney Paul Esker of Bradley & Riley PC filed a twenty-two-page document on behalf of defendants Lyndsay Nissen and Reliable Street Inc. containing four separate motions:

1. Motion to Change Venue — D0001, pp. 112–115
Asked the court to transfer the case from Polk County to Story County and to treat Polk County as the “wrong county,” with transfer-related costs assessed against me. The motion asserted that the location of the Iowa Civil Rights Commission had “no bearing” on venue and that “[n]o exception contained in Iowa Code § 616 is applicable.” 

2. Motion to Dismiss for failure ot state a claim— D0001, approximately pp. 116–130
Asked the court to dismiss my petition in its entirety for failure to state legally sufficient claims. Defendants argued, among other things, that the petition did not clearly identify which claims applied to each defendant, or plead enough facts supporting discrimination, fraud, promissory estoppel, and defamation. Much of the information they demanded could only have been known to me through discovery, because many of the specific facts necessary to identify each defendant’s precise role remained concealed within what I had already alleged to be fraudulent conduct. For additional context regarding why certain facts were known or not known, see the first three articles within this series.  

3. Alternative Motion to Recast — D0001, p. 130
If the court did not dismiss the case, defendants alternatively asked the court to require me to rewrite the petition into a more formal structure with numbered paragraphs and separate statements. Their request appears at filing p. 19, D0001 p. 130. 

4. Alternative Motion for a More Specific Statement — D0001, pp. 131–132
If the petition was not dismissed, defendants alternatively asked the court to require substantially more factual detail so they could respond to the pleading. They specifically demanded more detail about which causes of action applied to which defendants, the terms regarding the garden and prairie agreements described in Section II of Record Retaliation, and Nissen’s alleged conduct. From my perspective, defendants were demanding that I specify details about events and agreements in which they themselves had participated, while other information concerning individual knowledge, communications, and roles remained unavailable to me before discovery. Those requests appear at filing pp. 20–21, corresponding to D0001 pp. 131–132.

Five minutes later, Mr. Esker (the attorney—not to be confused with Defendant Charlie Esker) filed a second document on behalf of defendants Lockwood Café, Sharon Stewart, Willa Colville, Denise Martinez, and Charlie Esker:

1. Motion to Quash Insufficient Service — D0001, pp. 107–111
Asked the court to rule that these five defendants had not been properly served and to quash service against them. They argued that service through Lyndsay Nissen at 4625 Reliable Street was legally insufficient.

2. Alternative Joinder to Motions Filed by  Nissen and Reliable Street Inc — D0001, p. 107
This was not a sixth independent request for relief. It stated that if the service challenge failed, those five defendants would join Nissen and Reliable Street’s motions to change venue, dismiss, recast, and require a more specific statement. The filing said: “If service upon them is deemed to be sufficient,” they joined all four motions.

 

Defendants Led with Iowa's Unrealistic Standard for Self-Represented Litigants:
We Must Perform With “Equal Competence” as Trained Professionals

 

 

They Began By Stating Pro Se Litigants Must Be Given "Some Leeway"

 

In their February 29 motion to dismiss, defendants began their filings by pointing out that I was representing myself without an attorney. They cited Knight v. Knight, 525 N.W.2d 841, 843 (Iowa 1994), and Munz v. State, 382 N.W.2d 693, 697 (Iowa Ct. App. 1985), for the principle that pro se pleadings receive some flexibility:

“When a pleading is filed pro se, ‘some leeway must be accorded from precision in draftsmanship.’”

Filing p. 7, ¶ 33; D0001, p. 117.

The quotation was accurate—but the context mattered.

In Knight, the Iowa Supreme Court held that a pro se petition gave sufficient fair notice even though one incident later discussed at the hearing had not been specifically pleaded. The Court emphasized that the incident was similar to those already alleged, that the opposing party could “scarcely have been surprised,” and that such proceedings were routinely initiated through pro se petitions. The Court therefore applied the “leeway” principle in deciding that the claim could proceed.

Munz went further. The Iowa Court of Appeals did not merely acknowledge liberal construction—it used that principle to preserve a claim. The court stated:

“Because the applicant proceeding pro se is entitled to a liberal construction of his pleadings, we will examine Munz’s claim in terms of ineffective assistance of counsel...”

The court ultimately found sufficient factual issues to reverse the summary dismissal and remand for an evidentiary hearing.

Thus, the cases defendants cited did not merely recite an abstract preference for leniency. In both, the courts actually applied liberal construction in deciding that a self-represented litigant should be permitted to proceed.

But the Next Paragraph Demanded "Equal Competence" as Trained Professionals

Immediately afterward, defendants emphasized the limits of that protection. They cited Pickens v. Zeien, No. LACV089735, 2018 WL 7863488 (Iowa Dist. Ct. May 14, 2018):

“But pro se litigants are not ‘excused from complying with requirements with which represented parties must comply. In short, the challenges to pro se pleading do not entitle Plaintiff to special leniency with regard to standards of pleading.’”

They then cited DeBruin v. State, 779 N.W.2d 494 (Iowa Ct. App. 2010):

“The law does not judge by two standards, one for lawyers and the other for lay persons. Rather, all are expected to act with equal competence. If lay persons choose to proceed pro se, they do so at their own risk.”

Filing p. 7, ¶ 34; D0001, p. 117.

Paragraph 33 recognized liberal construction; paragraph 34 emphasized that pro se litigants remain subject to the same procedural requirements as represented parties and invoked the rule of “equal competence.” Defendants then immediately asserted in paragraph 35 that my petition should be dismissed for failure to state a claim.

These principles are not technically contradictory. Liberal construction concerns how a pleading is read; procedural compliance concerns the requirements a litigant must satisfy. But for someone actually navigating court without counsel, the combination creates an extremely narrow path: some imprecision in wording may be tolerated, while mistakes about the governing legal requirements can still end the case.

 

 

Defendants Carried Their False Narrative Against Me Into Court

 

The February 29 filings did more than challenge service, venue, pleading sufficiency, and the form of my petition. They carried into the judicial record substantially the same false portrayal of me that I had gone to court to challenge.

Readers who began with Record Retaliation and Political Sabotage will be able to see what this section of the defendants' filings really amounted to.

Record Retaliation reconstructs the contemporaneous communications before my March 31, 2022 exclusion: months of friendship, affection, collaboration, approvals, delegated responsibility, and appreciation. Political Sabotage then places the later ICRC submissions beside that contemporaneous record and shows how the same period was transformed into a reinforcing portrayal of me as obsessive, intrusive, harassing, threatening, racist, and unwilling to respect boundaries.

I knew that portrayal was false because I had lived the events. I also possessed the records that could be used to vindicate me.

That is the context in which defendants' first court filings must be read.

"Years of Harassing Conduct"

Reliable Street Inc. and Lyndsay Nissen's February 29 filing opened by characterizing the lawsuit itself as:

“This action is the latest in a string of unsubstantiated claims pursued by Plaintiff.”

Filing p. 1, ¶ 1; D0001, p. 112.

It then described my exclusion this way:

“In early 2022, Reliable Street Inc. and Lockwood Café barred Plaintiff from the premises due to reports of harassing conduct towards customers and employees.”

Filing p. 2, ¶ 4; D0001, p. 113.

And two paragraphs later the accusation expanded:

“Defendants—who include current and former Lockwood Café employees, as well as a customer—have been subject to years of harassing conduct by Plaintiff, both inside and outside of the legal system.”

Filing p. 2, ¶ 7; D0001, p. 113.

Neither of the Defendants' February 29 filings identified what supposed “string” defendants meant. The obvious prior formal dispute was my Iowa Civil Rights Commission complaint against Reliable Street and Lockwood Café. But the ICRC had administratively closed that complaint; it had not conducted a trial or entered a factual judgment establishing that my allegations were false. In fact, the ICRC itself issued to me a letter of right-to-sue. 

The second filing by the five other defendants repeated the same characterization:

“This action is the latest in a string of unsubstantiated claims pursued by Plaintiff.”

Filing p. 1, ¶ 1; D0001, p. 107.

So the narrative had moved from the ICRC record into a second government record: first I was portrayed as obsessive, intrusive, stalking, and harassing; then the lawsuit I filed to challenge that record was itself framed as another episode in an alleged pattern of misconduct.

In addition to the burden created by the multitude of same-day motions filed by the Defendants, I also had to controvert these allegations, line-by-line, so as not to be found later to have tacitly agreed to these false characterizations. 

Defendants Misrepresented Basic Venue Law to Claim I Filed in the "Wrong County"

Demanding Facts Known to Defendants, That Could Not Be Known to Me Without Discovery

The February 29 filings created another conflict that would recur throughout the case.

Defendants did not merely ask me to clarify my two-page petition. They simultaneously asked the court to dismiss every identified claim, alternatively require me to recast the petition, and alternatively require a more specific statement identifying additional facts about particular defendants and transactions.

That mattered because some of the information they demanded concerned facts within defendants’ own knowledge or private communications—such as who knew what, who communicated with whom, who prepared or transmitted particular materials, what role each person played, and, where legally relevant, knowledge, intent, scienter, or malice.

Those were precisely the kinds of facts I expected discovery to uncover.

My Petition Was Filed Under Iowa's Notice-Pleading Rules

When I filed the original petition, I was working from Iowa’s pleading rules.

Rule 1.402(2)(a) provided:

“Each averment of a pleading shall be simple, concise, and direct. No technical forms of pleadings are required.”

And Rule 1.403(1) required:

“a short and plain statement of the claim showing that the pleader is entitled to relief and a demand for judgment for the type of relief sought.”

That was the framework under which I filed a short petition identifying the underlying events, the claims I believed arose from them, the defendants involved, and the injuries for which I sought relief.

The venue dispute was only one part of the filing. Defendants then attacked the petition itself from three directions at once.

Motion to Dismiss for Failure to State a Claim

Defendants first asked the court to dismiss the petition “in its entirety.”

They argued that the petition did not adequately assign claims to particular defendants:

“The Petition does not make clear which Defendants are the subject of each claim.”

Filing p. 7, ¶ 37; D0001, p. 118.

They then analyzed discrimination, fraud, promissory estoppel, and defamation separately and repeatedly concluded that each should be dismissed as to all seven defendants.

For fraud, for example, defendants identified seven elements:

“(1) representation; (2) falsity; (3) materiality; (4) scienter; (5) intent to deceive; (6) reliance; and (7) resulting injury and damage.”

Filing p. 11–12, ¶ 58; D0001, pp. 122–123.

They then asserted:

“The Petition, on its face, fails to allege facts sufficient to establish any of these seven elements.”

¶ 59.

and:

“If the Court concludes that Plaintiff has failed to allege any one of these elements, the claim for fraud should be dismissed…”

¶ 60.

Their conclusion was categorical:

“Taking the foregoing together, any claim for fraud should be dismissed as to all seven named Defendants.”

¶ 61.

That is where the discovery problem becomes apparent.

Several of those elements—particularly scienter and intent to deceive—concern what another person knew or intended. I could allege the conduct I had observed and the documentary conflicts I had discovered, but I could not truthfully claim firsthand knowledge of defendants’ private states of mind or undisclosed communications before discovery.

The same structural problem applied more broadly to questions of coordination, authorship, transmission of documents, and each defendant’s precise role.

Defendants nevertheless sought complete dismissal at the pleading stage.

Their conclusions repeated that request claim by claim:

“Taking the foregoing together, any claim for discrimination should be dismissed as to all seven named Defendants.”

p. 10, ¶ 50; D0001, p. 121.

“Taking the foregoing together, any claim for fraud should be dismissed as to all seven named Defendants.”

p. 12, ¶ 61; D0001, p. 123.

“Taking the foregoing together, any claim for promissory estoppel should be dismissed as to all seven named Defendants.”

p. 14, ¶ 73; D0001, p. 125.

“Taking the foregoing together, any claim for defamation should be dismissed as to all seven named Defendants.”

p. 18, ¶ 89; D0001, p. 129.

The filing then asked the court to:

“enter an Order dismissing the Petition in its entirety.”

D0001, pp. 129–130.

So before any interrogatories, document production, requests for admission, or depositions had occurred, defendants were asking the court to terminate every identified claim.

Alternative Motion to Recast

Defendants next moved, in the alternative, to require a structural rewrite:

“If Plaintiff’s petition is not dismissed in its entirety, Defendants Reliable Street Inc. and Lyndsay Nissen respectfully move for the Pleading to be recast…”

Filing p. 19, ¶ 90; D0001, p. 130.

They argued that the petition did not comply with Rule 1.412 because it lacked numbered paragraphs and did not separate circumstances as formally as they believed the rule required:

“The Petition does not comply with Iowa Rule of Civil Procedure 1.412 at least insofar as it does not contain numbered paragraphs and the paragraphs are not limited as far as practicable to a statement of a single set of circumstances.”

p. 19, ¶ 92; D0001, p. 130.

This motion did not challenge whether the underlying events were true. It challenged the form and organization of a two-page pro se pleading that had been drafted under rules expressly stating that averments should be simple, concise, and direct and that no technical pleading form was required.

It was another separate procedural issue I now had to research and answer.

Alternative Motion for a More Specific Statement

Defendants then made a third alternative request:

“If Plaintiff’s petition is not dismissed in its entirety, Defendants Reliable Street Inc. and Lyndsay Nissen respectfully move for a more specific statement.”

Filing p. 20, ¶ 93; D0001, p. 131.

Their own motion quoted the limited purpose of that procedure:

“A party may move for more specific statement of any matter not pleaded with specific definiteness to enable the party to plead to it, and for no other purpose.”

¶ 94.

They also quoted Iowa’s fair-notice standard:

“A petition complies with the ‘fair notice’ requirement if it informs the defendant of the incident giving rise to the claim and of the claim’s general nature.”

¶ 95.

Yet they demanded considerably more detail, including:

“The petition does not state which causes of action are applicable to particular defendants.”

¶ 97.

They demanded additional information concerning the Reliable Street agreement, including:

“(1) when it was made, (2) whether it was oral or written, (3) the terms of the alleged agreement, or (4) the nature of the alleged breach.”

¶ 98.

And they demanded I specify precise and extensive conduct described in Record Retaliation and Political Sabotage:

“The petition does not make any allegations of any conduct on the part of Defendant Nissen, except for one mention of an alleged act undertaken by her, on behalf of Defendant Reliable Street.”

¶ 99.

In other words, they demanded I specify, line-by-line, an extensive case against numerous defendants, with specificity against each one, even for conduct there is no way I could have known (e.g. who created Exhibit D-3?), or the case should be dismissed.

Some of those matters could plainly be clarified through amendment.

But others pointed directly toward the problem I had already encountered in the ICRC record: I could describe what happened to me, what documents I possessed, and what defendants themselves had said or done in my presence—but I could not truthfully identify every private communication, precise division of responsibility, undisclosed act of coordination, or individual state of mind without discovery.

Defendants, by contrast, possessed their own communications and knew their own roles.

That is what made the combined sequence so consequential.

They first argued that claims should be dismissed because I had not alleged enough facts to establish every required element. Then, if dismissal was denied, they demanded greater specificity about which defendant did what. And much of the missing information concerned matters that could only be reliably developed through the discovery mechanisms that had not yet begun.

The procedural dilemma was already visible: disclose facts I could not yet truthfully know, or face demands that the claims be dismissed before I could obtain them.

And that still was not the end of the February 29 filings.

 

 

Challenging Service Despite Undeniable Actual Notice

Five minutes after the first February 29 filing, the remaining defendants—Lockwood Café, Sharon Stewart, Willa Colville, Denise Martinez, and Charlie Esker—filed a Pre-Answer Motion to Quash Insufficient Service of Process. Their attorney entered what the filing described as a “limited appearance” for the purpose of challenging service.

The motion did not claim that these defendants were unaware of the lawsuit.

Instead, it argued that the manner in which the Story County Sheriff had delivered the original notices and petitions was technically insufficient.

For Stewart, Colville, Martinez, and Charlie Esker, defendants argued that substitute service through Lyndsay Nissen at 4625 Reliable Street was invalid because that business address was not their “dwelling house or usual place of abode.” They therefore asked the court to quash service under Rules 1.305 and 1.302(5).

For Lockwood Café, defendants argued that service through Nissen was insufficient because:

“Lyndsay Nissen is not an officer or agent of Lockwood Café.”

Filing ¶ 15; D0001, p. 109.

They therefore asked that Lockwood’s service also be quashed.

But There Was No Question They Had Actual Notice

Whatever the technical service issue, the filing itself established that all five defendants already knew about the lawsuit and were coordinating their response to it.

They had retained the same attorney representing Reliable Street Inc. and Lyndsay Nissen. Their motion was filed only five minutes after the first twenty-two-page defense filing. And in the opening paragraph, they announced that if the service challenge failed, they were prepared to join every other motion filed that afternoon:

“If service upon them is deemed to be sufficient, Defendants Lockwood Café, Sharon Stewart, Willa Colville, Denise Martinez, and Charlie Esker join the following Motions filed by Defendants Reliable Street Inc. and Lyndsay Nissen: (I) Motion To Change Venue; (II) Motion To Dismiss; (III) Alternative Motion To Recast; (IV) Alternative Motion For A More Specific Statement.”

D0001, p. 107.

The filing concluded with essentially the same conditional joinder.

So the issue was not whether these defendants had been blindsided or lacked notice of the case. They had notice, counsel, and a coordinated litigation strategy.

Their objection was that the sheriff’s delivery did not satisfy the technical requirements for formally bringing them before the court.

Actual Notice Did Not End the Technical Service Dispute

That distinction mattered because I had relied on the Story County Sheriff to carry out service at the shared business address through which I knew these defendants. I did not possess their private residential addresses.

Iowa Rule 1.302(5) also made the issue consequential: if service was not completed within ninety days after filing, the court could dismiss the action without prejudice as to an unserved defendant unless good cause justified additional time or another method of service.

So even though these defendants plainly had actual notice, counsel, and a coordinated litigation strategy, I still had to determine whether the Sheriff’s delivery satisfied Iowa’s technical service rules—and, if not, how to cure it before the deadline expired.

A Procedural Barrage With Multiple Paths to Defeat the Case Before Discovery

Although defendants placed most of their requests into coordinated filings, each arose under a different rule, required a different response, and created a different potential consequence.

Taken together, the February 29 filings sought to:

— quash service on five defendants;

— declare Polk County the “wrong county” and transfer the action at my expense;

— dismiss every identified claim;

— if dismissal failed, require me to recast the petition;

— if that failed, require substantially greater factual specificity;

— and place into the judicial record the same accusations of harassment and misconduct that I had gone to court in part to challenge.

The result was not one procedural dispute. It was a procedural choke point.

Leaving any one of these matters unanswered carried a different risk. Service could be quashed. Venue could be transferred. Claims could be dismissed. The petition could be ordered rewritten. Greater factual detail could be compelled before discovery. And the defendants’ accusations against me could remain in the court record without any contemporaneous denial or correction from me.

That last point mattered separately from the motions themselves.

I understood that court records develop through assertion and response. Iowa’s pleading rules expressly require denials of factual allegations when a responsive pleading is called for, and provide circumstances in which an undenied pleaded fact may be treated as admitted. The February 29 motions were not themselves pleadings to which Rule 1.405(3) automatically applied, but I was not willing to allow serious accusations about my conduct to sit unanswered in the judicial record and later be portrayed as uncontested.

So I was defending two things at once: the survival of the lawsuit and the accuracy of the record.

Defendants had answered my two-page pro se petition with twenty-seven pages of coordinated filings submitted within five minutes. They attacked service, venue, pleading sufficiency, pleading form, and factual specificity simultaneously, while repeating substantive accusations about me and seeking dismissal before discovery could uncover private communications and facts primarily within defendants’ knowledge.

I was not free to choose one issue and ignore the rest.

I had to answer every front.

That is what produced the March 15 filing.

 

---

III. How the Defendants' February 29 Filings
Support My Abuse-of-Process Claim

There is an important distinction between using legal process to litigate a legitimate procedural issue and using multiple forms of process primarily to accomplish something those procedures were not designed to accomplish.

One traditional definition describes abuse of process as:

“The improper and tortious use of a legitimately issued court process to obtain a result that is either unlawful or beyond the process’s scope.” ¹

The Restatement states the principle similarly:

“One who uses a legal process, whether criminal or civil, against another primarily to accomplish a purpose for which it is not designed is subject to liability to the other for harm caused by the abuse of process.” ²

That distinction is important here.

Viewed individually, defendants could describe each February 29 request as an ordinary procedural motion. Viewed together, however, the filings operated very differently.

They sought to:

— quash service despite actual notice;

— characterize a legally permissible county as the “wrong county” and shift resulting costs and attorney fees onto me;

— dismiss valid claims before discovery could uncover information in defendants’ possession;

— require me to articulate private communications, individual roles, knowledge, intent, and other facts I could not truthfully know without discovery, which which they themselves knew and withheld;

— force structural rewriting of the petition with the inclusion of aforementioned withheld facts if dismissal failed;

and simultaneously carry into the judicial record accusations that defendants knew were false.

And all of it arrived at once, against a self-represented litigant, under a ten-day resistance deadline.

The practical objective apparent from that combination was not merely to obtain clarification of a pleading. It:

— created multiple independent opportunities to prevent the case from reaching discovery,

— increase the cost and pressure of continuing it,

— force me to expend limited time defending procedural fronts rather than developing the evidence, and

— continue in the judicial proceeding the same reputational conduct that formed part of the lawsuit itself. This , in and of itself, carried the force of threat of a countersuit, through planting false information into their filings that were capable of helping to carry forth a malicious prosecution and fraudulent and retaliatory countersuit. 

That is why I contend the February 29 filings are evidence supporting my the abuse-of-process claim documented in Part Seven of this series, Dangerous Precedent.

The significance lies in the purpose and function of the sequence as a whole.

— A process designed to resolve venue was used to label a permissible county “wrong” and seek fees against me.

— Procedures designed to test pleading sufficiency were used to demand information that defendants themselves possessed while discovery had not yet occurred.

— A service objection was pursued despite unquestionable actual notice and coordinated representation.

— And the defendants’ substantive accusations were inserted into the same filings, requiring me to defend my reputation while simultaneously defending against the multi-pronged procedural attacks that did not work directly toward resolving the underlying merits of the case, but instead asserted, on multiple occasions, to have the case dismissed, with costs wrongly assessed to me, despite knowing defendants had in fact performed the wrongs alleged.

On its face, the pattern appeared calculated primarily to increase pressure, multiply the avenues through which the action could be defeated before discovery, and prevent the underlying evidence from ever being examined.

That was not an interpretation I developed years later.

As the next section shows, I said substantially the same thing contemporaneously in my March 15 response: that the motions appeared designed to prevent discovery, bury me in legal research during the short response period, and stop evidence and testimony from being presented. 

Defendants' filings did not appear designed to resolve the wrongs alleged on their merits. Documentation throughout Record Retaliation and Political Sabotage show that some or all of the defendants knew exactly which wrongs my petition referred to. 

My March 15 filing sought to address these issues and counter the multiple filings so that the court would not accept the version of the story Defendants were now putting forth. 

 

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March 15, 2024:

IV. I Filed a Motion for Judge Gronewald to Recuse,
Followed by Four Motions and Four Resistances to Counter Defendants' Barrage

 

Direct link to filing from Polk County record: Motion to (1) Recuse, (2) Continue, (3) Estop, and (4) Amend, and Resistances to (1) Quashing Service, (2) Changing Venue, (3) Recasting, and (4) Dismissal. 
This filing is located on pages 56-72 in D0001.

_____________________________

My March 15 response was seventeen pages long because the February 29 filings did not present me with one motion, one legal question, or even one kind of threat.

Every front had to be answered and controverted.

However, there was an immediate issue that needed to be resolved first: Judge Gronewald's recusal.

My Motion for Judge Gronewald to Recuse, 
and the Information She Did Not Disclose

For reasons that will be described momentarily, I did not trust that Judge Gronewald was impartial in this case.

Therefore, within my March 15 filing, began by expressly moved for Judge Gronewald to recuse so that a different judge could decide on the defendants' motions. I wrote:  

“prior to any other motions made by myself or Defendants are decided on by the Court, I respectfully request that you recuse yourself from this action.”

Filing p. 9; D0001, p. 64.

And on the opening page of the same filing, before turning to the other disputes, I wrote:

“After that motion is resolved and a new judge is assigned to this case…”

Filing p. 1; D0001, p. 56.

I continued:

“I question Judge Samantha Gronewald’s impartiality with regard to this action.”

Filing p. 9, ¶ 22; D0001, p. 64.

Then quoted Iowa Code of Judicial Conduct Rule 51:2.11:

“A judge shall disqualify himself or herself in any proceeding in which the judge’s impartiality might reasonably be questioned.”

Filing p. 9, ¶ 23; D0001, p. 64.

The comments section under that same rule further explain:

"[1] Under this rule, a judge is disqualified whenever the judge’s impartiality might reasonably be
questioned, regardless of whether any of the specific provisions of paragraphs (A)(1) through (6)
apply. The term “recusal” is used interchangeably with the term “disqualification.”

[2] A judge’s obligation not to hear or decide matters in which disqualification is required applies
regardless of whether a motion to disqualify is filed.

[5] A judge should disclose on the record information that the judge believes the parties or their
lawyers might reasonably consider relevant to a possible motion for disqualification, even if the
judge believes there is no basis for disqualification."

Judge Gronewald Donated to "Kim Reynolds for Iowa", Then Was Appointed by Reynolds;
Now She Was Assigned As Judge to This Case and My Related Suit Against "Kim Reynolds for Iowa"

My March 15 filing put the part of Judge Gronewald's relationship squarely before the court:

“Governor Reynolds has performed multiple acts of defamation and rights violations [against] transgender Iowans.”

Filing p. 8, ¶ 19; D0001, p. 63.

I then identified the related lawsuit that was currently in front of the same court, which for some reason Judge Gronewald was also assigned to:

“On 2-8-2024 I filed a Petition to commence a civil action for case # LACL157953 against Defendants Governor Kim Reynolds and Kim Reynolds for Iowa.

Governor Kim Reynolds appointed Her Honorable Judge Samantha Gronewald in December 2017.”

Filing p. 9, ¶¶ 20-21; D0001, p. 64.

Judge Gronewald knew that the case I was referring to Wilson v. State and Kim Reynolds for Iowa (Polk County No. LACL157953), named Kim Reynolds' political fundraising committee "Kim Reynolds for Iowa" as a defendant due to acts of defamation (libel per quod) against transgender Iowans, and the related unjust enrichment of her campaign that was built on on working to turn the public against transgender Iowans in general. My separate suit also contained allegations of fraudulent misrepresentation and reckless endangerment by the Iowa Civil Rights commission due to how they handled my complaint against the defendants in this case: see Part Two of this series, Iowa's Civil-Rights Trap, for context. 

against transgender Iowans. How could I trust a judge appointed by a named tortfeasor to be impartial in this case? 

What I did not know at the time—but which Judge Gronewald certainly knew at the time—is that she and her husband had personally donated to "Kim Reynolds for Iowa" less than two months before Reynolds appointed her as Judge on December 2, 2017: 

I'm not going to get into all of the conduct alleged in Wilson v. State and Kim, that is covered in a separate article but my petition in that case also 

So my motion to recuse was not simply:

“A governor once appointed this judge.”

It was:

Kim Reynolds, who has repeatedly shown animus toward transgender women, and whose own tortious actions personally caused me harm on multiple occasions, is a named tortfeasor in one of two lawsuits I filed around the same time. Judge Gronewald does not have the appearance of impartiality to me because she was appointed by Mr. Reynolds. I am personally experiencing ongoing mental anguish, emotional pain and sufferent, and ongoing legal injuries as a direct result of tortious actions performed by Ms. Reynolds. I do not trust that Judge Gronewald is impartial in this matter. 

My four resistances and four motions were designed to counter defendants' multi-pronged attack, while seeking a continuance until after my semester at DMACC was over.

 

 

My Motion to Continue Requested an Extension to Respond to Defendants' Filings
After My Semester Was Finished

I also asked for a continuance because I was enrolled in DMACC’s London study-abroad program and would not return to Iowa until approximately May 2. My opening request explained that I was:

“currently studying abroad this semester with Des Moines Area Community College”

and asked that the case be continued:

“preferably no sooner than May 15, 2024”

Filing p. 1; D0001, p. 56.

The request was tied to concrete tasks. I needed time to amend the petition, research the defendants’ motions, arrange any corrected service, and continue my college coursework. I was not asking for the case to remain dormant indefinitely; I proposed a specific period extending only slightly beyond my return.

My filing explained that the Iowa Civil Rights Commission had left me with an unusually compressed period in which to begin the lawsuit. For context, this is described in Part Two of this series, Iowa's Civil Rights Trap. I wrote:

“The Iowa Civil Rights Commission did not provide me with a sufficient amount of time to review evidence submitted to them … before having to file this lawsuit.”

Filing p. 10, ¶ 27; D0001, p. 65.

I further explained:

“I was rushed, and as a result was not provided a sufficient amount of time to fully review the Iowa Rules of Civil Procedure.”

Filing p. 10, ¶ 27; D0001, p. 65.

That statement is important. I did not insist that every procedural choice I made was beyond correction. I explained the circumstances, acted in good faith, and asked the court for time to cure any deficiency rather than allow a technical dispute to destroy the action.

Procedural Authority:

Iowa Rule of Civil Procedure 1.911(1): “A continuance may be allowed for any cause not growing out of the fault or negligence of the movant, which satisfies the court that substantial justice will be more nearly obtained.”

Filing p. 11, ¶ 34; D0001, p. 66.

My request fit that standard. It identified a specific and limited period, explained that I was overseas for an academic program, and described the concrete work that needed to be completed. I asked for time to amend, cure any service defect, research the defendants’ numerous motions, and continue the coursework and Honors project I needed to work on in accordance with various contracts and scholarships.

I Resisted the Motion to Quash,
but Offered to Serve by Newspaper for Defendants Whose Addresses Were Unknown

 

The defendants’ own motion acknowledged that Reliable Street and Lockwood Café operated in the same building. I attached screenshots showing that both publicly listed 4625 Reliable Street as their address and wrote:

“Reliable Street Inc. and Lockwood Cafe appear to have been appropriately served at their addresses by Story County Sheriff’s Deputy Jason Grubbs on 2–9–2024.”

Filing p. 5; D0001, p. 60.

I also showed that the defendants’ description of the organizations’ leadership was incomplete. Although their motion described Sharon Stewart only as the owner and operator of Lockwood Café, Reliable Street’s own response to the ICRC identified:

“Lyndsay Nissen, President of Reliable Street INC. Sharon Stewart Vice President of Reliable Street INC.”

Filing p. 6; D0001, p. 61.

This evidence showed that Reliable Street, Lockwood Café, Nissen, and Stewart were more interconnected than the motion to quash suggested.

At the same time, I acknowledged that I lacked the individual defendants’ residential addresses and might need to complete service differently. I offered to serve them by publication or at addresses they voluntarily provided. My goal was not to evade the rules; it was to correct any arguable defect and move the case forward.

 

• I requested a limited continuance: I needed enough time to research and answer the barrage while completing my DMACC London study-abroad obligations.
• I directly rebutted the carried-forward accusations: I would not allow statements alleging “years of harassing conduct” and a “string of unsubstantiated claims” to sit unanswered in the judicial record.
• I resisted the “wrong county” argument: I explained the Polk County connection and opposed transfer based on defendants' representation that no Chapter 616 exception applied.
• I resisted dismissal before discovery: defendants were demanding dismissal of claims before I could obtain evidence necessary to determine facts held by other parties.
• I sought amendment rather than dismissal or forced recasting: I offered to correct format and provide additional facts that I could truthfully plead.
• I resisted demands for information I could not yet know: private communications, authorship, individual roles, knowledge, intent, scienter, and coordination required discovery rather than speculation.
• I resisted the service challenge and offered to cure any defect: five defendants had actual notice and coordinated counsel, and I proposed practical means of completing service if the Sheriff's delivery was technically insufficient.

I Resisted the Change of Venue,
Pointing Out Subject-Matter Jurisdiction Made Polk County a Proper Venue

The defendants argued that all relevant conduct occurred in Story County. I responded that the action concerned:

“the fraudulent document that was filed with the Iowa Civil Rights Commission by Sharon Stewart on behalf of Lockwood Cafe”;

Filing p. 3; D0001, p. 58.

and:

“various libelous statements made against me… within documentation submitted to the Iowa Civil Rights Commission by Sharon Stewart, Lyndsay Nissen, and Charlie Esker.”

Filing p. 3; D0001, p. 58.

I later explained more directly:

“acts of libel and the fraudulent document were submitted within Polk County to the Iowa Civil Rights Commission. The majority and more severe injurious acts against me, with regard to this action, occurred in Polk County.”

Filing p. 8, ¶ 15; D0001, p. 63.

Venue Argument Placed Before the Court:

The allegedly false statements and altered document were submitted into the ICRC proceeding in Polk County, while the proposed transferee county raised documented prejudice concerns.

Thus, my venue argument was not based merely on the physical location of an agency office. I alleged that actionable statements and materials had been transmitted into the ICRC proceeding in Polk County, where they entered a government record and caused additional injury.

I also raised serious concerns about being transferred into Story County because of prior experiences involving Story County officials and courts—matters I was simultaneously litigating in Wilson v. State of Iowa and Kim Reynolds for Iowa.

5. Motion to Amend Petition and Resistance to Recasting

Proposing a Practical Alternative to Dismissal or a Forced Rewrite

At the beginning of my filing, I proposed a practical solution. Instead of dismissing the action or forcing a separate recasting process, I proposed an amended petition that would:

conform its formatting to Iowa Rule of Civil Procedure 1.412;

Filing p. 2; D0001, p. 57.

include more specific statements in response to defendants’ motion; and  

p. 2; D0001, p. 57.

state certain claims more explicitly, except where the requested details depended upon discovery.

p. 2; D0001, p. 57.

I also asked for enough time to serve the amended petition and notices where necessary. I told the defendants that any of them could avoid service by publication by simply providing:

“an appropriate address for which service of process may be delivered”

Filing p. 2; D0001, p. 57.

In other words, I did not refuse to clarify or correct anything the court found deficient. I proposed amendment, renewed service where necessary, and eventual discovery—the least drastic means of preserving the action while addressing the defendants’ stated concerns.

6. Resistance to the Motion to Dismiss

Warning that Dismissal Would Prevent Discovery and Evidence

My filing directly addressed the practical effect of the dismissal arguments within defendants’ twenty-two-page consolidated motion.

I wrote that the dismissal arguments appeared designed:

“to prevent this civil action from moving forward into the discovery process”;

“to bury me in tedious legal research which cannot reasonably be performed within the brief ten day time limit allowed to respond to a motion”; and

“to further injustices against me already performed by all Defendants via disallowing due process to occur.”

Filing p. 4; D0001, p. 59.

This was my contemporaneous assessment—not a conclusion invented after years of litigation. I recognized at the outset that the procedural attacks could prevent the case from reaching the stage where documents, interrogatories, and testimony would reveal the defendants’ respective roles.

I therefore told the court:

“I object to Defendants’ multiple requests to dismiss this action in its entirety, as they are attempts to deny me due process and disallow evidence and testimony to be presented.”

“It would create a miscarriage of justice to dismiss this case during this early phase of the action.”

Filing pp. 16–17; D0001, pp. 71–72.

 

7. Motion to Estop

Trying to Stop the Same Accusations from Being Repeated in Court

My filing also sought to prevent the defendants from continuing to place into the court record statements I alleged were false. I moved to estop them from reasserting statements made within:

“filings submitted to the Iowa Civil Rights Commission” and “Defendants’ Motions filed on 2–29–2024.”

Filing p. 3; D0001, p. 58.

I specifically disputed their assertion that they had endured “years” of harassment. I wrote:

“I did not know the Defendants for ‘years’, nor did I ever harass any of them.”

Filing p. 7, ¶ 14; D0001, p. 62.

This was not peripheral to the litigation. The defendants’ repetition of those accusations required me to defend my character at the same time I was attempting to research service, venue, pleading rules, amendment, and dismissal.

Why This Filing Mattered

My March 15 filing shows that I did not ignore the defendants’ motions or refuse to correct potential defects. I proposed amendment, renewed service where necessary, a limited continuance, and eventual discovery. I identified the Polk County conduct underlying substantial portions of the action, documented my concerns about transfer to Story County, invoked the judicial disqualification rule, and warned that dismissal would prevent evidence and testimony from being examined.

Most importantly, I identified the danger before the court ruled. I wrote that the procedural demands appeared designed to prevent discovery, bury me in legal research, and deny me a meaningful opportunity to present evidence.

Later that same day, Judge Gronewald denied recusal and granted defendants’ venue motion “for the reasons stated within the motion.” The next entry examines those orders and the point at which the defendants’ procedural strategy became court-assisted.

 

 

 

 

 

 

The defendants' filings had carried into court accusations of stalking, harassment, and other misconduct that I knew had not occurred. Those accusations did not exist in a political vacuum. The broader history of how transgender people in Iowa had been portrayed, criminalized, and politically targeted is documented elsewhere in Dark History, Intersex in Iowa, Record Retaliation, Iowa's Civil-Rights Trap, and Popularizing Discrimination. In 2023, for example, Governor Reynolds signed legislation restricting gender-affirming healthcare for minors and transgender students' restroom access.

That context gave the allegations additional leverage.

Anyone entering the case through defendants' filings could see a pro se transgender plaintiff being described as obsessive, harassing, legally incompetent, improperly served, insufficiently pleaded, and unwilling to stop pursuing supposedly “unsubstantiated claims.” What they could not yet see was the underlying documentary record that sharply contradicted that portrayal.

The defendants and I knew that underlying history. The court had not yet examined it.

That was the danger.

The February 29 filings did not merely require me to argue legal doctrine. They required me to defend the survival of the case and prevent defendants' version of events from becoming the only developed narrative before the evidence could be tested.

There was also simply not enough time to research and answer every individual assertion with the precision defendants were demanding.

Near the end of my March 15 filing, I said so directly. Addressing paragraphs 53 through 89 of defendants' dismissal motion, I wrote:

“Lines 53 through 89 within Defendants’ Motion to Dismiss Plaintiff’s Petition for Failure to State a Claim appear to serve at least three purposes:”

“(i) to prevent this civil action from moving forward into the discovery process, at which point the claims I have asserted will be shown to have merit;”

“(ii) to bury me in tedious legal research which cannot reasonably be performed within the brief ten day time limit allowed to respond to a motion…”

“(iii) to further injustices against me already performed by all Defendants via disallowing due process to occur.”

Plaintiff's March 15 filing, filing p. 16; transferred record D0001, pp. 102–103.

That passage is important because it establishes that “procedural bombardment” is not a label I invented years later while reconstructing the case. I identified the same problem while it was happening.

I had already recognized that the combined filings were forcing me into extensive emergency legal research while simultaneously threatening to prevent the case from ever reaching the discovery process where the disputed evidence, testimony, private communications, authorship, knowledge, and respective roles of the defendants could be examined.

So I responded broadly because the attack was broad.

 

---

March 15, 2024:

IV. Within Hours After My Filing, Judge Gronewald Denied Recusal
and Granted Defendants' Venue Transfer That Was Predicated on Misrepresented Iowa Code

She Denied Recusal—and Then Immediately Ruled on Venue

Judge Gronewald denied the recusal request.

She then proceeded that same day to decide another contested issue: defendants’ request to transfer the case from Polk County to Story County.

That matters because my motion had specifically asked her not to decide the remaining motions until disqualification had been resolved and another judge assigned.

The legal issue is therefore larger than whether Judge Gronewald was personally conscious of any bias.

The issue is whether, under the circumstances I placed before her, her impartiality could reasonably be questioned within the meaning of Rule 51:2.11—and, if so, whether she had authority to make the venue ruling that immediately followed.

That question becomes still more consequential in the next section.

Because the ruling Judge Gronewald entered after refusing to recuse did not merely move the case to another courthouse.

It transferred the case based on defendants’ representation of Iowa venue law—a representation I contend was materially wrong—and that transfer was then used to seek costs and attorney fees against me.

Feb. 29-April 1, 2024:

II.  Judge Appointed by Defendant in Related Case Denies Recusal

 

 

Judge Gronewald denied recusal and then granted defendants' request to transfer the Reliable Street case from Polk County to Story County the same day.

This part therefore asks readers to examine not merely whether I disagreed with a ruling, but whether the judicial-disqualification rule required the recusal question to be resolved differently before the judge decided a contested issue affecting where the case would proceed.

 

 

 

March 15-April 2, 2024
The Court Granted Transfer Based on Misstated Law, Defendants Used the Ruling to Further the Retaliation I Alleged, and Reconsideration was Rejected

The March 15 filing described above placed eight motions and resistances before the court, including a request that Judge Samantha Gronewald resolve disqualification before ruling on anything else.

What followed was a rapid chain of rulings and filings. Judge Gronewald denied recusal and granted defendants’ venue motion later that same day. Four days afterward, defendants abandoned their service challenge, accepted service, joined the remaining motions, resisted my request for time, and sought to enlarge the transfer order to impose costs and attorney fees against me. When I sought reconsideration, the court preserved the transfer and assigned its filing fee to me.

---

March 15 — Same-Day Orders

A Seventeen-Page Filing Followed Hours Later by a Brief Ruling

Plaintiff’s Omnibus Motions and Resistances — discussed above
Filed March 15, 2024, at 8:23 a.m.; D0001, pp. 88–104.

Judge Gronewald's Order Denying Recusal and Granting Change of Venue
Entered March 15, 2024, at 5:45 p.m.; D0001, pp. 85–87.

Approximately nine hours after I filed a seventeen-page document addressing eight separate procedural disputes, Judge Gronewald entered an order denying my motion to recuse and granting defendants’ motion to transfer the action to Story County.

The order denied recusal in a single sentence:

“The Court finds that recusal is not warranted and the Motion is denied.”

Order p. 1; D0001, p. 85.

The court then granted transfer:

“Defendants’ Motion to Change Venue is granted for the reasons stated within the motion.”

Order p. 1; D0001, p. 85.

That language was consequential. As explained above, defendants’ motion categorically asserted that no Iowa Code chapter 616 exception applied—even though Iowa Code § 616.18 permitted venue where one defendant resided or where the injury or damage was sustained.

The court did not independently identify the controlling venue law, address § 616.18, or explain why defendants’ categorical assertion was correct. It did not merely omit a lengthy venue analysis. It granted transfer expressly “for the reasons stated within” a motion that categorically declared no chapter 616 exception applicable, without addressing § 616.18 or the Polk County facts I had placed before it.

The order also stated that the remaining issues would be decided after transfer:

“All other pending motions shall be resolved by the court in Story County.”

Order p. 1; D0001, p. 85.

Thus, Judge Gronewald denied the request that she recuse before deciding anything else, immediately ruled for defendants on venue, and sent the unresolved disputes—including dismissal, recasting, amendment, specificity, continuance, and estoppel—to another county.

The timing and brevity raise a serious question about how fully my filing was considered. I cannot know what review occurred outside the written record. The record does show that a seventeen-page filing addressing eight issues was followed within hours by an order denying recusal in one sentence and granting transfer solely “for the reasons stated within” defendants’ motion.

March 19 — Strategic Reversal and Escalation

Defendants Accepted Service, Joined the Remaining Motions, Intensified Filing Pressure Caused by Feb. 29 Bombardment, and Sought Transfer Expenses

Defendants’ Acceptance of Service
Filed March 19, 2024, at 3:47 p.m.; D0001, pp. 83–84.

Defendants’ Response to Plaintiff’s Omnibus Motion and Reply in Support of Motion to Dismiss
Filed March 19, 2024, at 8:24 p.m.; D0001, pp. 75–79.

Defendants’ Motion to Enlarge Order Granting Change of Venue
Filed March 19, 2024, at 8:24 p.m.; D0001, pp. 80–82.

Four days after obtaining transfer, the five defendants who had challenged service abandoned that dispute and accepted service.

Their response stated:

“Defendants Lockwood Café, Sharon Stewart, Willa Colville, Denise Martinez, and Charlie Esker have now accepted service, and hereby join the Motions filed by Defendants Reliable Street Inc. and Lyndsay Nissen on February 29.”

Response p. 1, ¶ 2; D0001, p. 77.

The sequence permits a reasonable inference that the transfer ruling changed defendants’ strategic priorities. Before transfer, they sought to quash service. After transfer had been granted, they accepted service and joined the remaining requests to dismiss, recast, and require greater specificity.

They also resisted my motion to continue. Although I had explained that I was studying abroad, had requested a limited period, and needed time to protect my coursework while responding to numerous procedural demands, defendants argued:

“Plaintiff has demonstrated an ability to ably file documents from London.”

and:

“Plaintiff is not entitled to a carte blanche extension of court deadlines because she now finds the lawsuit that she filed to be inconvenient.”

Response p. 2, ¶¶ 14–15; D0001, p. 78.

That argument converted the sacrifices required to meet emergency deadlines into supposed proof that no additional time was needed.

My ability to file from London did not show an absence of hardship. It showed that my professors had allowed extensions, that I was diverting time away from my coursework, and that the Honors discipline project that had been a primary reason for the trip was being displaced by emergency legal research and writing.

The procedural pressure became self-validating: every response I completed by sacrificing my education was used as evidence that I could absorb still more litigation.

Defendants also filed a motion asking the court to enlarge its venue order. They again invoked Iowa Rule of Civil Procedure 1.808(1)—quoting it twice within the motion—and argued that I had filed the action in the “wrong county.” They requested that the court assign to me:

the $40 transfer-processing fee;

$478 in attorney fees; and

$41 charged for ICRC records.

Motion to Enlarge ¶¶ 2, 8–11; D0001, pp. 80–81.

The venue ruling therefore became the foundation for a new attempt to impose financial consequences against me—even though the transfer had been granted based on a motion containing the categorical legal misstatement examined earlier.

I viewed this as a continuation of the retaliation underlying the lawsuit: after I filed a civil-rights action challenging false and damaging statements, defendants sought not only to relocate and dismiss the case, but also to make me pay expenses arising from that relocation.

April 1 - 2 — Reconsideration Rejected

The Court Preserved the Transfer and Assigned Its Filing Fee to Plaintiff

Plaintiff’s Motion to Reconsider Orders on Recusal and Venue; Resistance to Dismissal and Defendants’ Motion to Enlarge
Filed April 1, 2024, at 9:46 a.m.; D0001, pp. 20–31.

The transferred record contains duplicate or near-duplicate versions of this filing. Only the clearest copy needs to be linked.

Order Denying Reconsideration and Ruling on Transfer Expenses
Entered April 2, 2024, at 12:17 p.m.; D0001, pp. 5–7.

I asked the court to reconsider both March 15 rulings. I renewed the argument that Judge Gronewald should not have decided venue after I had placed disqualification before her, challenged the transfer, resisted dismissal, and opposed defendants’ effort to impose costs and attorney fees.

I also documented the educational harm caused by the litigation. I explained that my professors had granted extensions so I could complete the court filings, that I was falling behind, and that I needed to return immediately to my homework and Honors discipline project after filing.

The court denied reconsideration:

“Plaintiff’s 4/1/2024 and 4/2/2024 Motions appear to be nearly identical to each other and seek reconsideration of the Court’s 3/15/2024 Order. Plaintiff’s 4/1/2024 and 4/2/2024 Motions are DENIED.”

Order p. 1; D0001, p. 5.

The court did not grant every form of financial relief defendants requested. It denied the requested $478 in attorney fees and $41 in costs at that time. But it assigned the transfer filing fee to me:

“Defendants’ Motion is GRANTED to the extent the transfer filing fee shall be assigned to Plaintiff, however, payment of the same shall be waived at this time.”

Order p. 1; D0001, p. 5.

The order further provided:

“Payment of the transfer filing fee shall be due along with the other court costs, if any, assigned at the conclusion of this matter.”

Order p. 1; D0001, p. 5.

And although the court denied defendants’ attorney-fee request at that time, it left the issue open:

“Nothing contained herein shall preclude Defendants from seeking recovery of their attorney fees, if appropriate, at a later date.”

Order p. 1; D0001, p. 5.

The result was that the transfer remained in place, reconsideration was rejected, and I was left responsible for the filing fee generated by moving the action out of a county I maintain was legally proper.

Although the Reliable Street case was then transferred out of Judge Gronewald’s courtroom, the underlying disqualification dispute continued in my related case against the State of Iowa and Kim Reynolds for Iowa.

The Recusal Dispute Continued in the Related Reynolds Case

My objection to Judge Gronewald’s participation did not end with the March 15 ruling or the denial of reconsideration in Wilson v. Reliable Street.

On March 31, 2024, I filed a complaint concerning Judge Gronewald with the Iowa Judicial Qualifications Commission ("IJQC") based on her refusal to recuse in the Reliable Street case, and her same-day venue ruling.

The issue then continued in my separate but related Polk County case, Wilson v. State of Iowa and Kim Reynolds for Iowa, where the State of Iowa and Governor Reynolds’s campaign committee, "KIM REYNOLDS FOR IOWA", were named defendants.

On May 28, I filed a motion asking Judge Gronewald to recuse from the Reynolds case. She denied the motion on June 19. On June 20, I filed a second complaint (scroll down to view second complaint) with the IJQC—this one concerning her refusal to recuse from the Reynolds case. On July 1, I filed a motion asking her to reconsider that denial and set out the history of my recusal requests and complaints in both proceedings.

On July 9, Judge Gronewald entered an order recusing herself from the Reynolds case and directing court administration to assign another judicial officer.

The July 9 order did not explain why she recused. I therefore cannot establish from the written order whether either judicial-conduct complaint or the July 1 reconsideration motion caused that decision. The chronology is nevertheless significant: I moved for recusal in each case, sought reconsideration after each denial, and filed a judicial-conduct complaint concerning each refusal. Judge Gronewald ultimately stepped aside from the Reynolds case.

That later recusal did not undo the venue ruling she had already entered in Wilson v. Reliable Street after denying my original request for disqualification. Nor did it return the case to Polk County, remove the transfer fee assigned to me, or restore the time and educational opportunity consumed by the resulting proceedings.

Defendants Used My Emergency Responses as "Proof" That I Needed No Continuance

At the time, I was studying abroad in London through Des Moines Area Community College and working on an Honors discipline project—the principal academic reason for the trip. I had informed the court that I would return to Iowa in early May and requested a limited continuance so I could complete my coursework and address the litigation upon my return.

Defendants treated my emergency filings as evidence against me. Because I had managed to file documents from London, they argued that I had demonstrated the ability to continue litigating from there. Their response expressly stated that I was not entitled to an extension merely because the lawsuit had become “inconvenient.”

But the filings showed the opposite of what defendants claimed. My professors had granted extensions so I could meet the litigation deadlines. I was falling behind in my coursework, and the project I had traveled overseas to complete was being displaced by legal research and writing.

My later filing documented that harm while it was occurring. The eventual consequence was greater than the record could yet show: I did not complete the Honors project that had been the primary reason for traveling to London.

A once-in-a-lifetime academic opportunity was consumed by responding to procedural motions seeking to relocate or end the case before discovery. I regard that lost educational opportunity as one of the concrete harms caused by the defendants’ litigation strategy.

 

IV. What I Learned in Hindsight About The Defendants' Filings

Iowa Law Did Not Require a Fully Proven Case in the Opening Petition

Iowa is a notice-pleading state. A petition must provide fair notice of the incident giving rise to the claim and the claim’s general nature. It ordinarily does not need to plead every ultimate fact supporting every element.

In Rees v. City of Shenandoah, the Iowa Supreme Court explained:

“Under notice pleading, nearly every case will survive a motion to dismiss.”

“The petition need not allege ultimate facts that support each element of the cause of action.”

“A petition complies with the ‘fair notice’ requirement if it informs the defendant of the incident giving rise to the claim and of the claim’s general nature.”

682 N.W.2d 77, 79 (Iowa 2004).

My two-page petition identified the underlying incident, the defendants, the claims I understood at the time, and the relief requested. Some clarification could properly be supplied through amendment, and I offered to amend.

Other information—including defendants’ private communications, their respective knowledge, and each person’s precise role—could only be developed through discovery.

Defendants nevertheless demanded a defendant-by-defendant account of every claim, detailed agreement terms, and facts concerning conduct and communications that had not yet been disclosed.

Their demands therefore did more than seek clarification. They attempted to impose a level of factual development Iowa notice pleading did not require and forced me, while studying abroad, to research dismissal standards, service, venue, recusal, amendment, pleading form, factual specificity, and discovery under compressed deadlines.

The February 29 obstruction originated with defendants. The rulings beginning March 15 gave that strategy judicial force: the action was transferred based on the reasons stated in a legally misstated motion, the remaining disputes were carried into Story County, and the transfer fee was ultimately assigned to me.

I Did Not Have Time to Fully Research These Cases While Having Only a 10-Day Response Time

None of this deeper case-law analysis was available to me when the motion arrived. I was in London for my academic program, facing what I understood to be a ten-day deadline to answer five separate procedural requests.

Within that period, I had to research dismissal, venue, service, recasting, pleading specificity, and the underlying causes of action while continuing to meet my academic obligations. I did not have the time or research infrastructure to retrieve every cited decision, trace its procedural history, evaluate its weight, and compare defendants’ quotations with what the courts had actually done in those cases.

Only later, while reconstructing the record, was I able to read Knight and Munz for myself.

That experience exposed the practical problem with the doctrine: a self-represented person can be told that ignorance of the law provides no protection while simultaneously being required, on short deadlines, to locate and understand precedent that attorneys spend years learning how to research.

The "Equal Competence" Standard is Antithetical to "Liberty and Justice for All"

I do not argue that self-represented litigants should be free to ignore court orders, prejudice opposing parties, commit fraud, destroy evidence, or disregard procedural requirements.

The problem is the premise that someone who cannot afford an attorney can realistically be expected to perform with the “equal competence” of trained lawyers.

Attorneys acquire that competence through years of education, examinations, professional practice, specialized research systems, and institutional experience. A self-represented citizen acquires none of that merely by filing a lawsuit.

I later counted more than 1,100 rules and over 6,300 sub-rules across Iowa’s core civil, evidence, criminal, and appellate procedural chapters. And knowing the text of those rules is only the beginning: a litigant must also locate controlling precedent, understand how rules interact, recognize deadlines, preserve issues for appeal, distinguish allegations from evidence, and determine when discovery or amendment is available.

Allowing a person to represent herself while declaring she must perform with “equal competence” to trained lawyers does not make the system accessible. It imposes formally equal obligations on people who enter the courthouse with radically unequal access to the knowledge required to satisfy them.

The Defendants' Filing Later Helped Lead to the Justice Accessibility Act

This February 29 filing was one of the experiences that led me to begin developing what eventually became Wild Willpower’s Justice Accessibility Act.

The proposal does not ask courts to apply different substantive laws to represented and unrepresented people. It addresses the structural problem I encountered here: if citizens are legally permitted to represent themselves, they should have a realistic way to understand what the law requires before a curable procedural mistake costs them their rights.

The Act proposes plain-English procedural maps, a searchable archive of controlling law, clearer notices and deadlines, expanded guided forms and assistance, and reasonable opportunities to correct good-faith procedural errors that cause no material prejudice.

The lesson I took from this filing was not that courts should have two sets of laws. It was that equal standards cannot produce meaningful equality when access to the knowledge needed to satisfy those standards is profoundly unequal.

Where Phase One Left the Case

By the time the case reached Story County:

• the venue had changed;
• the transfer filing fee had been assigned to me;
• the complete Polk County record had been compressed into one 144-page docket entry;
• the dismissal, recasting, specificity, amendment, continuance, and estoppel disputes remained unresolved; and
• defendants had accepted service and joined their remaining procedural motions.

The litigation had also caused a consequence the docket could not fully capture. The time intended for my DMACC Honors project had been diverted into emergency filings, and my ability to complete those filings was then used against me as proof that I needed no continuance.

I ultimately did not complete the project that had been the principal reason for traveling to London.

Part Two begins when Judge Currie inherited those unresolved disputes, announced that one hearing would address them, and directed the parties to disclose whether they intended to present evidence.

Next Article:

Part Two:
Sudden Reversal