B. The Plaintiff did not upload the documents onto the web or pressure his wife to do so. Mrs. Seipler uploaded the documents out of anger, fear and concern for her family. (continued)

Mrs. Seipler felt like “we didn’t have a chance” and “we were battling something.”

She was “very pissed… [and] afraid.” (Id. at 1447.)

Rosa believed that the truth about the MCSO was not going to come out. (Id. at 1447, 1456).

Mrs. Seipler put the information up on the web because she had become “paranoid,” fearing that something was going to happen to Zane, her, or her children.

Deputy Milliman’s brother, Kurt, was murdered only six months after the Deputy was deposed, and Rosa believed that Kurt Milliman’s death was payback to stop Deputy Scott Milliman from speaking out. (Id. at 1457, 1467, 1557).

At the time, Mrs. Seipler had three children under the age of six. (Id. at 1334-1335.)

In addition, at that time and for several months prior Mrs. Seipler had been barricading the doors to her house (Id. at 1491-1492).

Guns were strategically placed in the house to defend the family and the shades were drawn so that the children could not be seen from the outside. (Id.)

Rosa was also afraid that the Sotos law firm, with its unlimited resources, was going to “come after her” and she would lose her job. (Id. at 1501.)

Rosa believed that publishing the information on the internet might make her family safer. (Id. at 1467-1468).

Mrs. Seipler was aware that the Milliman deposition transcript had gotten to the Northwest Herald and to an associate of Sheriff Nygren, Jose Rivera, who, as she understood it, was involved in shady dealings with the department. (Id. at 1459-1460).

Moreover, in January, 2010, after the domestic violence report was made public, Mrs. Seipler spoke to a sergeant of the Woodstock Police Department, who initiated an internal investigation to find out how the materials became public.

The sergeant told her that only the Sotos law had received the documents, in response to a subpoena; other requests by various newspapers were denied. (Id. at 1511-1515).

Ultimately, Rosa received a letter from the Woodstock Chief of Police confirming these details. (Id.)

Mrs. Seipler removed the confidential designation from the documents when she scanned them into the computer.

After all, the domestic violence report had been distributed with the confidential designation and therefore Rosa understood this to be the proper procedure.

She believed that the documents that she uploaded to the blogs were not confidential, since Judge Mahoney ruled that the domestic report and the Milliman deposition transcript were not confidential. (Id. at 1504-1509).

When Mrs. Seipler created the first blog, there was no need to log in or create a website; the computer was turned on and so she went in straight to Google.

When creating the second blog, the computer was turned off, so she turned it on and had to log in. (Id. at 1465-1467).

This presented no problem. Zane and Rosa shared the same password on the computer.

They agreed, after Zane’s had a relationship with another woman, that there would be no secrets between them.

For this reason, Zane could not create a password that would limit Rosa’s access to the computer. (Id. at 1485).

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Part 8 tomorrow.