Should Sheriff Keith Nygren Have Known that Retaliatory Action Based on Deputy Scott Milliman’s Deposition Testimony Was Unconstitutional?

That headline pretty much summarizes the final question Federal Judge Frederick Kapala had to decide in whether or not to dismiss former McHenry County Sheriff Deputy Scott Milliman’s wrongful termination suit. The Judge points out it had to determine “whether … Continue reading

Scott Milliman’s Wrongful Termination Case Against Sheriff Keith Nygren Alive and Kicking

Federal District Court Judge Fredrick Kapala refused to dismiss a second case brought by two men fired by McHenry County Sheriff Keith Nygren, this time the one brought by Scott Milliman. Milliman was fired by Nygren for testifying in a … Continue reading

Motion for Sanctions Legal Fees & Costs Set at $260,156 for Zane Seipler

Sheriff Keith Nygren’s motion for legal fees to be paid by Deputy Zane Seipler in his wrongful termination suit total $227,905. There is an addition $32, 252.16 in “costs and expenses” for the contempt of court hearings. Judge Frederick Kapala … Continue reading

Part 15 – Zane Seipler’s Argument that His Case Shouldn’t Be Dismissed for Contempt of Court

G. Plaintiff’s frustrations referenced in his website do not amount to evidence of publication of confidential matters. It is apparent that at times, Zane discussed his frustration at information being kept private. He mentioned his difficulty with the Pavlin situation … Continue reading

Part 15 – Sheriff Keith Nygren’s Argument that Zane Seipler Should Be Held in Contempt of Court for Posting Secret Documents on the Internet

CONCLUSION Defendants take no pleasure in exposing the fraud foisted upon this Court. Yet, evidence of Plaintiff’s and Horwitz’ elaborate scheme of deception, including posting confidential documents, submitting a false affidavit, misdirecting the Court, and fabricating a false affirmative defense, … Continue reading

Part 14 – Sheriff Keith Nygren’s Argument that Zane Seipler Should Be Held in Contempt of Court for Posting Secret Documents on the Internet

V. Only the Remedy of Dismissal Can Adequately Redress Plaintiff’s Misconduct. The foregoing demonstrates clear and convincing proof that Plaintiff intentionally posted confidential documents on the Internet in violation of this Court’s Order, filed a perjurious affidavit denying any relevant … Continue reading

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. 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 … Continue reading

Part 13 – Zane Seipler’s Argument that His Case Shouldn’t Be Dismissed for Contempt of Court

E. Mr. Horwitz properly asserted a privilege in the September 14, 2011 deposition. Defendants contend that Mr. Horwitz did not assert a valid privilege-objection in Mr. Seipler’s deposition, but was merely engaging in misdirection. (Dkt No. 384, pg. 8, allegations … Continue reading

Part 13 – Sheriff Keith Nygren’s Argument that Zane Seipler Should Be Held in Contempt of Court for Posting Secret Documents on the Internet

Why did Plaintiff fail to alert the Court to the evidence until December 2011? Another compelling illustration of the fraud attempted on this Court is the contrived explanations Plaintiff and Horwitz offered for the delay between allegedly learning of Mrs. … Continue reading

Part 12 – Sheriff Keith Nygren’s Argument that Zane Seipler Should Be Held in Contempt of Court for Posting Secret Documents on the Internet

How did Mrs. Seipler create Real MCSO with Plaintiff’s email address? In her January deposition, Mrs. Seipler confirmed an email address was needed to create a blog, but when asked what email address she used to create “the blog that … Continue reading

Part 12 – Zane Seipler’s Argument that His Case Shouldn’t Be Dismissed for Contempt of Court

D. Plaintiff and his counsel hid no information. In the September 14, 2011 deposition of Mr. Seipler, Mr. Horwitz specifically asked Mr. Seipler clear, direct questions as to whether he uploaded the information onto the offending website. Mr. Sotos admits … Continue reading

Part 11 – Zane Seipler’s Argument that His Case Shouldn’t Be Dismissed for Contempt of Court

C. Defendants’ version of events makes little sense. (continued) Moreover, the Google subpoenas were sent to Plaintiff’s counsel on June 15, July 6, and August 1, 2011. (Sotos TR. at 1280, 1278, 1285, 1289-1290.) Plaintiff also knew that Defendants were … Continue reading

Part 11 – Sheriff Keith Nygren’s Argument that Zane Seipler Should Be Held in Contempt of Court for Posting Secret Documents on the Internet

How did Mrs. Seipler hide her document review and blogging from Plaintiff? (continued) Further, the likelihood that Plaintiff would not have learned about her blogging on his own over two and a half months, even if they had not discussed … Continue reading

Part 10 – Sheriff Keith Nygren’s Argument that Zane Seipler Should Be Held in Contempt of Court for Posting Secret Documents on the Internet

How did Mrs. Seipler hide her document review and blogging from Plaintiff? Since Plaintiff’s affidavit denied any knowledge of Real MCSO’s creator, or how that person obtained the documents, the Seiplers had to, and did, testify Plaintiff was blissfully unaware … Continue reading

Part 10 – Zane Seipler’s Argument that His Case Shouldn’t Be Dismissed for Contempt of Court

C. Defendants’ version of events makes little sense. Defendants’ position is riddled with illogic. The Sotos law firm acknowledges that they were monitoring the Plaintiff’s MCSD Exposed website on a daily basis and Plaintiff knew this by means of a … Continue reading

Part 9 – Sheriff Keith Nygren’s Argument that Zane Seipler Should Be Held in Contempt of Court for Posting Secret Documents on the Internet

Why would Mrs. Seipler review, alter, and publicly post the documents? The Seiplers explained that Mrs. Seipler reviewed and posted the documents because she was frustrated with the Sheriff’s harsh treatment of Plaintiff, to expose other deputies’ conduct, and because … Continue reading

Part 8 – Zane Seipler’s Argument that His Case Shouldn’t Be Dismissed for Contempt of CourtPart 7 – Zane Seipler’s Argument that His Case Shouldn’t Be Dismissed for Contempt of Court

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 … Continue reading

Part 8 – Sheriff Keith Nygren’s Argument that Zane Seipler Should Be Held in Contempt of Court for Posting Secret Documents on the Internet

IV. Plaintiff’s Fabrication of a False Affirmative Defense (Nos. 17-19) Allegations 17-19 concern Plaintiff’s fabrication of a false affirmative defense blaming his wife for everything. Once the Google evidence connected Real MCSO to his computer, Plaintiff was caught red-handed, which … Continue reading

Part 7 – Zane Seipler’s Argument that His Case Shouldn’t Be Dismissed for Contempt of Court

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. Defendants claim that either Plaintiff posted the disputed … Continue reading

Part 7 – Sheriff Keith Nygren’s Argument that Zane Seipler Should Be Held in Contempt of Court for Posting Secret Documents on the Internet

III. Clear and Convincing Proof Horwitz Affirmatively Misled the Court on September 7 and 23, 2011 as to the Creation of Real MCSO (Nos. 11-16) [continued] Despite Horwitz’ effort to split hairs as to the quality of his knowledge and … Continue reading