The Community Garden Management Agreement
Grounds for One of The Promissory Estoppel Claims
In the Wilson v. Reliable Street Inc and Lockwood Café
by Sondra Wilson. Written July 20, 2025.

The following part of my testimony is extracted from lines 28-57 within my amended petition filed on June 17, 2024 for Wilson v. Reliable Street Inc. and Lockwood Café, et al. Photographs were taken throughout the duration of my work in order to build my portfolio for use in securing entrepreneurial work in the future. Although I possess decades of experience in working with the Earth, this was the first time I was put into a management position wherein I finally would be able to document and showcase my skills. Keeping receipts and measuring time spent working the garden would allow me to estimate costs in order to provide quotes to future clients. Instead of leaving the property with my credentials built, instead I was barred from the property under false pretenses, and my reputation severely marred, thus harming my reputation and the reputation of Wild Willpower.

28. Over the course of my visits to Lockwood Café, I noticed the garden located on the

property was overgrown with weeds and plants weren’t being sufficiently watered and cared for:

I mentioned to Defendant Sharon Stewart that I was happy to help because I live

close, was available during the day, and love gardening.

29. Sharon and several members of Lockwood Cafe’s staff were aware I founded Wild

Willpower PAC and that I worked alongside US Army Veteran Richard Lonewolf to create an

ethnobotany textbook called More Valuable Than Gold.¹ I also told Sharon that have experience

gardening, and showed her a booklet I’d written about “Homesteading Starter Kits”.² I had given

both Lyndsay and Sharon my business card at different times, shown them my book, and talked

to them about my skill sets, so they knew I had these skills.

30. Also, by the time I ran this offer by Sharon, several Lockwood Cafe employees had

shown interest in my studies with Lonewolf, especially Denise Martinez and Willa Colville.

Willa was passionate about the prairie, and Denise expressed interest and told me that she was

interested in her indigenous ancestry. We discussed this topic in context with my ethnobotanical

and cultural studies alongside Richard Lonewolf and other experts, and how it relates to our

shared curiosity about wild edibles and herbal teas within Iowa’s tallgrass prairie.

First Agreement entered into with Reliable Street Inc and Lockwood Cafe – Exhibit F

31. Days later Sharon approached me, said she had spoken with Lyndsay, and that they

would like to know if I would help manage the garden. Sharon (and later Lyndsay) told me that

the Ames High School gardening club (Students Helping to End Poverty and Hunger “SHEPH”)

created and was managing it, but that not enough upkeep was being done and it needed a lot of

work.

32. Sharon offered me a 50% discount on all purchases at Lockwood Cafe if I accepted

the position, which I was grateful for and accepted. She told me to talk with Lyndsay and

SHEPH’s President, Emily Poag, first.

33. On September 21 I texted Lyndsay about this interaction, and her response was, “That

would be amazing.” (F1). After discussing this agreement and the second agreement in person

with her while volunteering at September-October open mics, on October 27 Lyndsay gave the

okay for me to start working on both interrelated projects (F2).

34. I requested and waited for approval before performing any task I was unsure about

(F3), and sent her updates to make sure she was happy with what was being done. I also checked

in to make sure I wasn’t sending too many texts (F4). She expressed nothing but gratitude and

appreciation in all our communications.

35. In two separate emails, dated January 20 and February 18, 2022, Lyndsay stated that

Emily from SHEPH and I were “taking the lead” and “in charge” of the garden for the year (F5

and F6). This was not news to me, as it was the agreement Sharon, Lyndsay, and I had discussed

and agreed upon.

36. In accordance with Sharon’s offer on behalf of Lockwood Cafe, I was given a 50%

discount on everything I ordered through March 31. Austin Stewart mentioned this in a text on

March 4, 2022, less than a month before the agreements were breached. He also expressed

gratitude for my work (Exhibits F9 and F10).

Second Agreement entered into with Reliable Street Inc – Exhibit G

34. While initially assessing what needed done in the garden, it was apparent that first

and foremost the approximately 7′ high weeds surrounding the garden needed to be pulled (H1).

It was my opinion that installing native tallgrass prairie to surround the garden would be a

beautiful addition to the property, would attract customers, and would fit the community

atmosphere Reliable Street Inc and Lockwood Cafe were seeking to foster. Over time, it would

help keep weeds from encroaching and overtaking the garden again, which is why the Iowa DOT

does this to manage roadsides.³

35. After learning that the City of Ames will reimburse residents who install native

prairie, I asked Sharon, Lyndsay, and members of the Lockwood Cafe staff what they thought

about the idea, and received positive responses. Every community member I spoke with was

excited about the idea. Lyndsay welcomed me to send her a proposal.

36. Because we had exchanged numbers and she expressed that she wanted to help, on

October 20 I asked Willa if she wanted to help me with prairie restoration research and review

the prairie installation proposal before I sent it to Lyndsay. Willa’s response was, “I would love to

help! I am very passionate about the prairie…” After sharing Exhibit G1 – proposal to install

tallgrass prairie with Willa, she responded, “It looks great :)” (G2 – Willa approves prairie

proposal).

37. After sharing the proposal with Lyndsay on October 21 (G3 – sent proposal to

Lyndsay), on October 27 Lyndsay gave me the okay to go ahead and get started (G4 – Lyndsay

gives the okay). She emailed me old blueprints created by SHEPH the previous year so that

Willa and I could record measurements. The old blueprints are the images she mentions in G4.

38. On October 27 I informed Willa that I got a “yes” from Lyndsay on the prairie, at

which point she offered to help me take measurements of the area, which we did (G5 – yes on

prairie, Willa to help measure). Willa and my measurements are found in the Oct – Dec 2022

timeline file in the Exhibit F and G folder.

October 2021 – March 31, 2022:
Examples of volunteer work I performed in accordance with the agreements – Exhibit H

39. Exhibit G1 – proposal to install native tallgrass prairie includes City of Ames fire

safety regulations. This section was put together following phone calls I made to the Ames Fire

Department for guidance. I was told by Ames FD and the multiple prairie restoration specialists

that creating a mulch pathway and then wetting it before control burns was an effective means

for conducting control burns. Mulch pathways also would beautify the garden, keep weeds at

bay, and provide walkways for gardeners and visitors. This information was shared and approved

by everyone interested in the garden and prairie.

40. Reliable Street Inc and Lockwood Cafe did not have a way for volunteers to transport

mulch to the property, so I coordinated, helped haul, and installed approximately six truckloads

of mulch to the property over the course of my volunteerism. Defendant Willa Colville, her

father, and her boyfriend helped deliver the first load, and donated several of the 4 x 4s to help

create the frames the mulch was poured into. H5 – hauling mulch to Reliable Street Inc.

41. I created a Google Doc to record our progress, and to document the work of other

volunteers, including Willa Colville, Luke Gran from Pruneterra, Nate Kemperman from

Mustard Seed Farms, and Travis Lala. The document records from October 20 through

December 8. I emailed the Doc to Lyndsay on October 22 so she could remain apprised of what

was going on and offer input and direction as needed. The final entry describes a meeting

between SHEPH members, Defendants Willa Colville and Denise Martinez, who also wanted to

volunteer, and myself. During the meeting we decided to develop an online job board where

tasks could be posted and volunteers could indicate when they performed a task. It was agreed

that any tasks others did not have time to do, I would perform. This ensured everything that

needed done would get accomplished, and everyone’s contributions could be seen. It also would

allow future SHEPH members to know what type of maintenance was needed. I stopped

updating the timeline as we switched to the job board I created on www.Freedcamp.com. The

Google Doc was downloaded into a PDF: H1 – Oct – Dec 2021 timeline.

42. On January 14, 2022 Emily Poag emailed SHEPH’s rough draft blueprints and current

plans and requested input from everyone involved. I provided Emily with suggestions, answered

questions, and created an editable version of the blueprints she sent to the group so that when

changes were decided on we could quickly update the blueprints. Emily expressed appreciation

for my help. Many of these interactions are found in H2 – coordinating with SHEPH, and more

can be provided.

43. Because Freedcamp didn’t offer some of the features we needed, and so everyone

could discuss and coordinate plans together (instead of having to relay conversations and info

from text messages between parties), on January 31 I created a Discord server and invited

everyone to join and participate.⁴

44. Prior to the Discord server, Emily told me that SHEPH lacked a repository of

gardening research which could be passed to future students, so they were essentially researching

from scratch each year. I worked for weeks creating step-by-step instructions including planting

dates for each plant the students wanted to grow. Blueprints, articles, progress reports, grant

applications we could apply for to potentially help with funding, and receipts were posted into

the server.

• Although the mulch pathway served the needs of both the garden and prairie, receipts for the wood frames, for example, were important in order to receive reimbursement later via the grant they offer for installing prairie. Again the application for this grant was posted into Exhbit G1 (proposal to install prairie). The grant required us to record costs, then apply for reimbursement after the prairie was installed.

I have since removed Defendants from the server, however all messages are still visible.

45. Willa Colville volunteered multiple times to help in the garden, found at least one

grant we could apply for, and engaged with the server and text messages. Denise Martinez came

to one meeting, expressed on multiple occasions that she didn’t have time to help in the garden,

and participated in the Discord server.

46. Sharon suggested I make a sign to help keep the compost in order, which I painted

and sent her a photo of in a November 3 email. She responded, “Perfect!” (H3). She also asked

me how Lockwood Cafe might be able to compost in winter. I inquired with Iowa State

University’s composting specialist, Steve Jonas, who visited the property, assessed the situation,

and helped formulate a plan which simultaneously would have provided a small greenhouse

space for SHEPH to sprout plants. On November 11 and January 9 I emailed Sharon regarding

all this. H3 – responding to Sharon’s ideas.

47. A local customer, Audrey, offered to donate a rain barrel to the garden. I asked

around, found a volunteer (Travis), and coordinated with Travis Lala to haul it to the garden

together. Travis and I hauled/donated two or three loads of mulch as well. Austin Stewart, who

often provided good handyman advice, advised me on which product to purchase for the rain

cache system we were setting up. Exhibit H4.

Other Volunteers Didn’t Have Time to Work in the Garden – Exhibit I

48. Throughout winter, I had performed quite a bit of research to prepare for spring

planting. Emily used my research to create the sprouting and planting schedule she emailed to

the group on February 7.

49. Willa and Denise both informed me they were very busy and did not have time to help

prep the garden, and Emily informed me the students were busy with finals, and would not be

available until April planting. A great deal of work needed done, however, and as originally

discussed with Sharon and Lyndsay when we formed the agreement, and with the rest of the

team at our December 8 and subsequent meetings, I performed and documented my tasks on

Discord.

I requested a meeting about raising funds for garden supplies – Exhibit J

50. Lyndsay, Sharon, and I did not discuss finances for supply needs during our initial

conversations, but as I began working it became apparent more supplies than the students could

afford were needed:

• Old, cracked hoses needed replaced.

• Plastic buckets were rotted through.

• 4 x 4s were needed for the mulch paths.

• There was no hand saw or other basic tools readily available.

• The tool shed needed a door.

51. At the December 8 meeting Emily explained that garden supplies needed to be

applied for well ahead of time. This did not work well in spring when the garden needed

prepared, because there were many immediate purchases needed to get things ready before

planting the prairie seeds, and then the garden plants in April. I was the only person who had

time to work in the garden in March (Exhibit I), so I was the only one really assessing on-the-

ground needs. It therefore became my duty to relay these needs to the team, which I did. No one

had any ideas, but this needed to be discussed. It had been awhile since we’d had a meeting, so I

texted the group and called for one on March 25.

52. The biggest expense were the many the 4 x 4s needed to finish building the mulch

frame. Although Willa and her dad donated most of them back when we hauled the first load of

mulch, several more were needed. I asked everyone involved if anyone had cheap or free leads

on 4 x 4s, but no one had any ideas. We needed to get the frame finished before planting, so I

purchased them. I posted the receipts in the Discord server to keep a record, and planned to get

reimbursed half the costs via the City of Ames’ prairie grant (G1 proposal to install prairie).

Again, the grant requires you to install the prairie, then the City of Ames will reimburse you for

half the costs afterward. I made the purchase not only as a donation, but also because this was the

first time I’d had the opportunity to work on projects like these. I wanted the results to be

beautiful.

53. In March, Emily wrote that SHEPH only had about $100 in their account. I did not

feel right about asking students for supply needs when I read that, which is why I suggested a

meeting to discuss ideas (J7 and J8).

54. I went ahead and made purchases for items we needed “immediately” because it

would be a bit before everyone would have time for a meeting, and things needed to get done

asap. It was not an issue for me to do so. Again, Lyndsay gave me Reliable Street’s mailing

address specifically so I could order products for the garden with my own money (F8). Austin

sent me “exactly which product” I should purchase for the rain cache equipment (H4). Our

agreements authorized me to make these purchases. This may seem menial for me to mention,

but later you will see where Defendants lied to the ICRC via trying to re-frame my purchases as

inappropriate and unauthorized.

55. I texted Lyndsay about the meeting, she responded, “I’m not really sure what to tell

you.” (Exhibit H6).

56. I then brought supply needs up with Austin, and he suggested I talk to Lyndsay. This

confused me, because she had been unresponsive.

57. I asked Sharon about a possible plant sale or donation jar for the students. She

acknowledged I had done a great deal of work, and set up a meeting between the Lyndsay, she,

and I so I could give them to get a tour of what had been done, and show what was still needed. I

was excited about this meeting because I was proud of the quality of the work I had been doing,

and was under the impression everyone was on very good terms with me. I was under the

impression I’d be showing what needed to be purchased, and the purchases would be made by

Reliable Street Inc, or we would discuss ideas on how to help the students raise funds. The

meeting was set up for March 31, 2022 on Transgender Day of Visibility, an annual event since

2009 dedicated to recognizing societal hardships transgender people face, and contributions trans

people offer to society. I saw my work with Reliable Street Inc as a contribution to society, and

thought – because of their showings of support to myself and other local trans people – that this

meeting was going to be a positive one. I had no idea what was about to happen.