Part 14 – Zane Seipler’s Argument that His Case Shouldn’t Be Dismissed for Contempt of Court

F. Plaintiff’s counsel committed a simple error in citing to the websites in question.

Blake Horwitz

Blake Horwitz

Plaintiff’s counsel admitted that he erred regarding the names and URLs of the websites when drafting Plaintiff’s response to Defendants’ initial motion for sanctions.

Mr. Sotos acknowledges that Mr. Horwitz could simply have made a mistake in connection with the drafting [FN11].

Despite these errors, the affidavit that Plaintiff and his counsel submitted in response to Defendants’ original (June, 2011) motion for sanctions established that neither Plaintiff nor his counsel posted the materials to the websites at issue or knew who had done so.

Further, the Plaintiff came forward in his September, 2011 deposition and very candidly explained, in very short and clear questions posed by his counsel that he did not post the materials to the internet.

The testimony and documents in this matter establish that there were many websites being addressed in this cause, including a website name, The Real MCSD, and (Dkt No. 266-2, filed August 11, 2011).

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FN11 Q. And you sure wouldn’t want an attorney like me writing stuff up on motions and messing up the website addresses, right?

A. I think it’s better that that doesn’t happen

Q. Can you accept that that was just a mistake on my part?

A. I don’t know whether it was a mistake. That may have been a  mistake. I don’t know.
(Sotos, Tr. 1100)

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Interestingly, Defendants forensic expert erred as well (Sotos, Tr., 1048-1049) with regard to when the various blogs were created and Mr. Sotos also erred, calling the offending Blog realmcsdexposed whereas the correct address is realmcsoexposed [FN12].

The clerical errors were multiple in nature, but they were merely errors.

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FN12 Q. Okay. And so, with regards to the question in the plural that the federal judge asked me about, which websites in the plural, when he says in the plural, what was he talking about?

A. My interpretation of that, as I’ve said, is that he was talking about the Real MCSD Exposed website on which the documents were posted (Emphasis Added).

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Part 15 tomorrow.


Part 14 – Zane Seipler’s Argument that His Case Shouldn’t Be Dismissed for Contempt of Court — 3 Comments

  1. Not quite sure how this could become any less interesting. Are you almost done Cal? Please?

  2. Considering that the sheriff’s office is the highest office in our land and could quite literally be the only thing to keep our country free from tyranny, it would be judicious for the people to keep abreast of whether or not your own sheriff is involved in the seemingly picayune.

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