Bill Windsor files a sworn affidavit and 128 exhibits with Amended Sworn Petition for a Stalking Protective Order against Sean Boushie

On August 8, 2013 at 1:00 pm, Bill Windsor filed a sworn affidavit and 128 exhibits with an Amended Sworn Petition for a Stalking Protective Order against Sean Boushie.  This was filed at the Ravalli County Courthouse in Hamilton Montana.

SWORN AFFIDAVIT OF WILLIAM M. WINDSOR

DATED AUGUST 8, 2013

I, William M. Windsor, the undersigned, hereby declare under penalty of perjury:

  1. I am over the age of 21, am competent to testify, and have personal knowledge of the matters stated herein.  I provide this affidavit to be used in this matter and in any other legal proceeding.
  2. Sean Boushie began stalking me regarding Crystal Cox on March 7, 2012.  He initially sent me four emails.  He offered to donate money to the film I am producing if I told him when and where Crystal Cox would be filmed. [True and correct copies of these are attached hereto as Exhibit 1.] [NOTE: Each exhibit is linked below.]
  3. On May 3, 2012, Sean Boushie first threatened me and intimidated me.  He said he was going to come after me.  “I had enough crap from all the wackjobs associated with this lying POS. You can tell her I’m coming for her and I’m going to make sure she is locked away forever. Want to screw with me and the same goes for you!!” [A true and correct copy of this is attached hereto as Exhibit 2.]
  4. When Sean Boushie began posting on my Facebook pages — www.facebook.com/billwindsor1 and www.facebook.com/lawlessamerica, a Glock gun was the gravatar/photo that he used. [A true and correct copy of this is attached hereto as Exhibit 3.]  This was viewed by me as a threat from Sean Boushie that he was going to shoot me.  Admittedly, this is a veiled threat.  But when you follow the series of posts and threats, it is quite clearly a threat.
  5. I issued a cease and desist notice to Sean Boushie on or about May 3, 2012.  I issued many cease and desist notices advising him to stop contacting me.
  6. On May 6, 2012, Sean Boushie stalked me by interrupting and harassing me during my Lawless America Radio Show.  He was asked to leave, and he didn’t. [A true and correct copy of this is attached hereto as Exhibit 4.]
  7. On August 17, 2012, Sean Boushie stalked, initimidated, and libeled me calling me a liar, a nutcase, mentally disturbed, not very intelligent, and of dubious moral character. [A true and correct copy of this is attached hereto as Exhibit 5.]
  8. On September 2, 2012, Sean Boushie posted nasty comments about Crystal Cox on my YouTube page. [A true and correct copy of this is attached hereto as Exhibit 6.]
  9. On September 13, 2012, Sean Boushie threatens to sue my wife (now my ex-wife) falsely claiming she is the owner of Lawless America. [A true and correct copy of this is attached hereto as Exhibit 7.]
  10. On September 13, 2012, Sean Boushie falsely posted online that I am a liar, an ahole, and a POS. [A true and correct copy of this is attached hereto as Exhibit 8.]
  11. On September 13, 2012, Sean Boushie sent an email in which he claims I had harassed him, lied, and made false statements about him.  There is absolutely no truth to that because I have not communicated with Sean Boushie except to send him cease and desist notices.  Thankfully, Sean Boushie acknowledges receiving those in this email. [A true and correct copy of this is attached hereto as Exhibit 9.]
  12. On September 14, 2012, Sean Boushie continues to cyberstalk me – calls me a liar and psycho in online posts.  He harasses Crystal Cox in the same post and shows that he has used crystalcoxisabitch as an email address. [A true and correct copy of this is attached hereto as Exhibit 10.]
  13. On September 14, 2012, Sean Boushie harasses and stalks me with more online posts, lies, and libel. [A true and correct copy of this is attached hereto as Exhibit 11.]
  14. On September 14, 2012, Sean Boushie is likely responsible for me being suspended by Facebook. [A true and correct copy of this is attached hereto as Exhibit 12.]
  15. On November 7, 2012, Sean Boushie took credit for filing copyright/trademark violation reports with YouTube that caused one woman’s Lawless America videos to be removed and a strike issued against the Lawless America YouTube Channel. [A true and correct copy of this is attached hereto as Exhibit 13.]
  16. On December 12, 2012, Sean Boushie attacked Lawless America film subject, Mary Wilson with a published statement on YouTube. [A true and correct copy of this is attached hereto as Exhibit 2.]
  17. On December 21, 2012, Sean Boushie cyberstalks me with a “threat” to show up at Meet Me in DC event.  He calls me a sociopath. [A true and correct copy of this is attached hereto as Exhibit 14.]
  18. On December 25, 2012, Sean Boushie of the University of Montana threatens me by using a photo for himself that is mass murderer Charles Manson. [A true and correct copy of this is attached hereto as Exhibit 15.]
  19. On January 3, 2013, Sean Boushie sent an email threatening to shoot me. [A true and correct copy of this is attached hereto as Exhibit 16.]
  20. On January 3, 2013, I was advised that Sean Boushie posts on my websites using stolen identities. [A true and correct copy of this is attached hereto as Exhibit 17.]
  21. On January 5, 2013, Sean Boushie publishes lies and veiled threats (using his John Smith alias) on Joeyisalittlekid.blogspot.com. [A true and correct copy of this is attached hereto as Exhibit 18.]
  22. On January 5, 2013, Sean Boushie (using his alias John Smith) publishes that I had a psychotic break and threatens me if I come near him. [A true and correct copy of this is attached hereto as Exhibit 19.]
  23. On January 5, 2013, Sean Boushie emails obscenities to me — F Word, etc. [A true and correct copy of this is attached hereto as Exhibit 20.]
  24. On January 6, 2013, Sean Boushie (using his John Smith alias on Joeyisalittlekid.blogspot.com) publishes lies claiming he has had no contact with and has not threatened me. [A true and correct copy of this is attached hereto as Exhibit 21.]
  25. On January 6, 2013, Sean Boushie (using his John Smith alias on Joeyisalittlekid.blogspot.com) implies that he will shoot me if I come to Montana. [A true and correct copy of this is attached hereto as Exhibit 22.]
  26. On January 6, 2013, Sean Boushie (using his John Smith alias and admitting he is one in the same) publishes lies on Joeyisalittlekid.blogspot.com. [A true and correct copy of this is attached hereto as Exhibit 23.]
  27. On January 6, 2013, Sean Boushie cyberstalks me with posts on Joeyisalittlekid.blogspot.com.  Sean Boushie uses his John Smith alias here. [A true and correct copy of this is attached hereto as Exhibit 24.]
  28. On January 8, 2013, Sean Boushie continues to stalk me by sending a Facebook Friend Request as Mass Murderer Charles Manson. [A true and correct copy of this is attached hereto as Exhibit 25.]
  29. On January 13, 2013, Crystal Cox has provided a sworn affidavit about a death threat from Sean Boushie. [A true and correct copy of this is attached hereto as Exhibit 26.]
  30. On January 15, 2013, Sean Boushie uses my YouTube page to post more libel and threats to Crystal Cox. [A true and correct copy of this is attached hereto as Exhibit 27.]
  31. On January 17, 2013, Sean Boushie has used his YouTube page to threaten those he stalks with guns and explosives.  One of the YouTube videos that Sean Boushie has liked is titled “The Wrong and Right Way to Shoot Someone.” [A true and correct copy of this is attached hereto as Exhibit 28.]
  32. On January 17, 2013, Sean Boushie ignores Cease and Desist Notices from me and begins threatening my family.  Both an email and a letter were sent. [A true and correct copy of this is attached hereto as Exhibit 29.]
  33. On January 17, 2013, Sean Boushie cyberstalks and taunts me by posting on my YouTube Page. [A true and correct copy of this is attached hereto as Exhibit 30.]
  34. On January 19, 2013, Sean Boushie slanders me with online post that I am a dickless koward, mentally ill, and a pedophile.  Oh, and he also says “bite me, asshole,” and the email address used is gofuckyourself@yahoo.com. [A true and correct copy of this is attached hereto as Exhibit 31.]
  35. On January 23, 2013, I filed a Criminal Complaint in Marietta Georgia against Sean Boushie of Stevensville Montana. [A true and correct copy of this is attached hereto as Exhibit 32.]
  36. On January 25, 2013, Sean Boushie Facebook Page appears using Mass Murderer Charles Manson’s Photo as Sean Boushie. [A true and correct copy of this is attached hereto as Exhibit 33.]
  37. On February 1, 2013, Report says Sean Boushie posted online that he is a paid cyberstalker and terrorist. [A true and correct copy of this is attached hereto as Exhibit 34.]
  38. On February 10, 2013, Sean Boushie tells me to tell Crystal Cox to go fuck herself.  Crystal Cox is a woman who says Sean Boushie threatened to kill her. [A true and correct copy of this is attached hereto as Exhibit 35.]
  39. On February 10, 2013, Sean Boushie sent an email threatening me, my wife (now ex-wife), and son…and he tells me to go fuck myself.  Sean Boushie seems to have a real interest in people fucking themselves. [A true and correct copy of this is attached hereto as Exhibit 36.]
  40. On February 10, 2013, Sean Boushie threatens me in email and says:  ”back to fucking yourself asshole.”  [A true and correct copy of this is attached hereto as Exhibit 37.]
  41. On February 10, 2013, “Suck my balls” says University of Montana teacher, Sean Boushie, in email to me. [A true and correct copy of this is attached hereto as Exhibit 38.]
  42. On February 10, 2013, I filed yet another complaint with Gmail over Sean Boushie harassment. This was also sent to Sean Boushie, and it is titled Cease and Desist.  This email is evidence that Sean Boushie was asked to stop harassing and intimidating me. [A true and correct copy of this is attached hereto as Exhibit 39.]
  43. On February 10, 2013, Sean Boushie emails me to tell me to shove it, lard ass, grow a pair dumbbass, go the fuck away, asshole, and more. [A true and correct copy of this is attached hereto as Exhibit 40.]
  44. On February 10, 2013, Sean Boushie emails me calling me a worthless piece of shit, an ass hole, a pie loving fat ass, a scum sucking megalomaniac who is a perpetual liar and a sociopath….and more.  He terrorizes my wife (now ex-wife) with threats of arrest.  And, as usual, he tells me to go fuck myself. [A true and correct copy of this is attached hereto as Exhibit 41.]
  45. On February 10, 2013, Sean Boushie sent yet another email to me.  He says shove it, go fuck yourself, suck my balls, bye asshole, and other obscenities. [A true and correct copy of this is attached hereto as Exhibit 42.]
  46. On February 11, 2013, a Facebook Page is set up in name of Sean Boushie to cyberstalk me. [A true and correct copy of this is attached hereto as Exhibit 43.]
  47. On February 11, 2013, Sean Boushie emails me to say he isn’t going away and doesn’t recognize law enforcement or the courts. [A true and correct copy of this is attached hereto as Exhibit 44.]
  48. On February 11, 2013, Crystalcox Victimsgroup Facebook page is set up to stalk and harass me – Sean Boushie uses this alias. [A true and correct copy of this is attached hereto as Exhibit 45.]
  49. On February 11, 2013, I filed yet another complaint with Gmail and University of Montana against Sean Boushie. Sean Boushie was copied on this email. [A true and correct copy of this is attached hereto as Exhibit 46.]
  50. On February 12, 2013, Sean Boushie sent another email to me.  He can’t spell, and he loves telling people to go fuck themselves. [A true and correct copy of this is attached hereto as Exhibit 47.]
  51. On February 14, 2013, Sean Boushie emails that I am a douchebag, a fucking liar, schitzo, a lesbian, and an asshole. [A true and correct copy of this is attached hereto as Exhibit 48.]
  52. On February 14, 2013, Sean Boushie threatens my wife (now ex-wife) with Prison. [A true and correct copy of this is attached hereto as Exhibit 49.]
  53. On February 14, 2013, I reported Sean Boushie to Yahoo and sent another Cease and Desist. [A true and correct copy of this is attached hereto as Exhibit 50.]
  54. On February 14, 2013, Sean Boushie published online a host of obscenities and threats against my wife (now ex-wife) and me. [A true and correct copy of this is attached hereto as Exhibit 51.]
  55. On February 14, 2013, Sean Boushie emails me to call me a douchebag and other obscenities. [A true and correct copy of this is attached hereto as Exhibit 52.]
  56. On February 14, 2013, I filed complaint against Sean Boushie with Gmail and Missoula Montana officials. Sean Boushie was copied on this cease and desist. [A true and correct copy of this is attached hereto as Exhibit 53.]
  57. On February 15, 2013, Sean Boushie says he plans to shove a warrant up my ass. [A true and correct copy of this is attached hereto as Exhibit 54.]
  58. On February 16, 2013, Sean Boushie harasses and cyberstalks me calling me a coward and a psycho. [A true and correct copy of this is attached hereto as Exhibit 55.]
  59. On February 16, 2013, Sean Boushie continues to impersonate people and steal their identity — me this time. [A true and correct copy of this is attached hereto as Exhibit 56.]
  60. On February 25, 2013, I filed Criminal Complaints against 37 Cyberstalkers, including Sean Boushie. [A true and correct copy of this is attached hereto as Exhibit 57.]
  61. On February 27, 2013, Sean Boushie publishes that I am a sociopath and a liar, neither of which is true. [A true and correct copy of this is attached hereto as Exhibit 58.]
  62. On February 28, 2013, Sean Boushie cyberstalks me with Facebook Messages. [A true and correct copy of this is attached hereto as Exhibit 59.]
  63. On March 6, 2013, I requested corrections and retractions to defamation, libel, and slander by Sean Boushie. [A true and correct copy of this is attached hereto as Exhibit 60.]
  64. On March 6, 2013, Sean Boushie cyberstalks me by requesting that he be added as my “Friend” on Facebook. [A true and correct copy of this is attached hereto as Exhibit 61.]
  65. On March 6, 2013, I published Cease and Desist Notice for Sean Boushie and others. [A true and correct copy of this is attached hereto as Exhibit 62.]
  66. On March 6, 2013, Sean Boushie responds to Cease and Desist Notices from me by publishing that I should stick them up my ass. [A true and correct copy of this is attached hereto as Exhibit 63.]
  67. On March 8, 2013, Sean Boushie continues cyberstalking me. [A true and correct copy of this is attached hereto as Exhibit 64.]
  68. On March 9, 2013, Sean Boushie threatens to run over me with a Mack truck. [A true and correct copy of this is attached hereto as Exhibit 65.]
  69. On March 9, 2013, Cyberstalker Sean Boushie posts on my site using the fictional CrystalCox VictimsGroup as his identity. [A true and correct copy of this is attached hereto as Exhibit 66.]
  70. On March 11, 2013, Sean Boushie has used a Big Knife as his image on Facebook. I view this as another death threat. [A true and correct copy of this is attached hereto as Exhibit 67.]
  71. On March 11, 2013, Sean Boushie stalks and harasses Mary Deneen by falsely claiming there is a warrant for her for trying to kill her children.  Mary doesn’t know Sean Boushie; she is simply one of the people who I filmed for my movie that Sean Boushie chose to cyber-stalk and threaten. [A true and correct copy of this is attached hereto as Exhibit 68.]
  72. On March 12, 2013, I filed Criminal Warrant Application against Sean Boushie. [A true and correct copy of this is attached hereto as Exhibit 69.]
  73. On March 12, 2013, Sean Boushie published false claim that I created a Facebook page for my deceased father. [A true and correct copy of this is attached hereto as Exhibit 70.]
  74. On March 18, 2013, Sean Boushie using alias John Smith cyberstalks me with a Facebook Friend Request. [A true and correct copy of this is attached hereto as Exhibit 71.]
  75. On March 18, 2013, Sean Boushie published that I should suck his balls. [A true and correct copy of this is attached hereto as Exhibit 72.]
  76. On March 21, 2013, Sean Boushie published that I am a fraud, a con artist, and a liar — all false. [A true and correct copy of this is attached hereto as Exhibit 73.]
  77. On March 21, 2013, Sean Boushie published that my wife (now ex-wife) and I are going to jail. [A true and correct copy of this is attached hereto as Exhibit 74.]
  78. On March 21, 2013, Sean Boushie publishes that I am psychotic, and he announces that he will be Allie Overstreet’s bodyguard when I am in Missouri. [A true and correct copy of this is attached hereto as Exhibit 75.]
  79. On March 26, 2013, Sean Boushie is believed to be involved in setting up fake Facebook page for my deceased father. [A true and correct copy of this is attached hereto as Exhibit 76.]
  80. On March 28, 2013, Sean Boushie posts that I need to go fuck myself, and more. [A true and correct copy of this is attached hereto as Exhibit 77.]
  81. On April 1, 2013, I received an email from KillBill@yahoo.com — from Sean Boushie’s IP Address. [A true and correct copy of this is attached hereto as Exhibit 78.]
  82. On April 1, 2013, Sean Boushie published an obscene message using a fake identity – Billyisanasshole. [A true and correct copy of this is attached hereto as Exhibit 79.]
  83. On April 2, 2013, Sean Boushie of the University of Montana sends emails to me from gofuckyourself@yahoo.com. [A true and correct copy of this is attached hereto as Exhibit 80.]
  84. On April 5, 2013, Sean Boushie emailed me to say he has a warrant waiting for me in Missoula. [A true and correct copy of this is attached hereto as Exhibit 81.]
  85. On April 7, 2013, Facebook posts in the name of Sean Boushie libel me and threaten me with murder. [A true and correct copy of this is attached hereto as Exhibit 82.]
  86. On April 9, 2013, identity theft of “Crystal Cox” used for stalking and harassment on my Facebook Page. [A true and correct copy of this is attached hereto as Exhibit 83.]
  87. On April 10, 2013, Sean Boushie falsely said I had herpes and was cheating on my wife. [A true and correct copy of this is attached hereto as Exhibit 84.]
  88. On April 18, 2013, a photo of my father from his death bed is published claiming he is having phone sex with his deceased wife. I believe Sean Boushie was involved in publishing this. [A true and correct copy of this is attached hereto as Exhibit 85.]
  89. On April 28, 2013, I announced that I had lost almost everything – Sean Boushie terrorized my family. [A true and correct copy of this is attached hereto as Exhibit 86.]
  90. On May 9, 2013, Sean Boushie continued to cyberstalk me with more Facebook “Friend” requests. [A true and correct copy of this is attached hereto as Exhibit 87.]
  91. On May 12, 2013, Sean Boushie posted on the Lawless America Mississippi Facebook page that he predicts it is just a matter of time before I am murdered. [A true and correct copy of this is attached hereto as Exhibit 88.]
  92. On May 12, 2013, Sean Boushie offered a reward for my murder.  [A true and correct copy of this is attached hereto as Exhibit 89.]
  93. On May 13, 2013, a Facebook page was set up in the name of John Brown to cyber-stalk me.  John Brown is a Sean Boushie alias. [A true and correct copy of this is attached hereto as Exhibit 90.]
  94. On May 13, 2013, the Sean Boushie Facebook account added knife as the image and claimed my home address as his location. [A true and correct copy of this is attached hereto as Exhibit 91.]
  95. On May 13, 2013, Sean Boushie published that I will not survive my current movie filming trip. [A true and correct copy of this is attached hereto as Exhibit 92.]
  96. On May 13, 2013, online posts libel and threaten me using the name Sean Boushie and the knife photo that he has used in prior posts. [A true and correct copy of this is attached hereto as Exhibit 93.]
  97. On May 21, 2013, Sean Boushie continued to cyberstalk me with even more Facebook “Friend” requests.  He regularly makes these requests as harassment. [A true and correct copy of this is attached hereto as Exhibit 94.]
  98. On June 1, 2013, Sean Boushie libeled me by posting online that I am a pedophile. [A true and correct copy of this is attached hereto as Exhibit 95.]
  99. On June 1, 2013, Psychopath – Sean Boushie libeled me by publishing that I am a psychopath. [A true and correct copy of this is attached hereto as Exhibit 96.]
  100. On June 1, 2013, Sean Boushie continued to cyberstalk me. [A true and correct copy of this is attached hereto as Exhibit 97.]
  101. On June 5, 2013, Sean Boushie is believed to have been involved in setting up a fake Facebook page for my deceased mother. It shows what is allegedly her skeleton wearing a wig.  My mother died of breast cancer 35 years ago, and she was one of the sweetest, kindest women who ever lived, and now her memory has been desecrated online. [A true and correct copy of this is attached hereto as Exhibit 98.]
  102. On June 14, 2013, Sean Boushie offered a reward if I am sent to the morgue in Arizona. [A true and correct copy of this is attached hereto as Exhibit 99.]
  103. On June 14, 2013, Sean Boushie declared war on me. [A true and correct copy of this is attached hereto as Exhibit 100.]
  104. On June 14, 2013, Sean Boushie libeled me by publishing that I am a liar and falsify information. [A true and correct copy of this is attached hereto as Exhibit 101.]
  105. On June 19, 2013, Sean Boushie published criminal defamation of me on CraigsList. [A true and correct copy of this is attached hereto as Exhibit 102.]
  106. On June 20, 2013, Sean Boushie continued to stalk and harass me and stole my identity. [A true and correct copy of this is attached hereto as Exhibit 103.]
  107. On June 21, 2013, Sean Boushie posted a Scam Alert on Craigslist in which he libels, defames, slanders, harasses, and stalks me. [A true and correct copy of this is attached hereto as Exhibit 104.]
  108. On June 22, 2013, my Lawless America Facebook Page was removed by Facebook.  I believe this is the work of Sean Boushie.  [A true and correct copy of this is attached hereto as Exhibit 105.]
  109. On June 25, 2013, Sean Boushie is believed to have set up a fake Facebook page in the name of Bill Windsor + e. [A true and correct copy of this is attached hereto as Exhibit 106.]
  110. On June 29, 2013, Sean Boushie emailed me with another death threat.  [A true and correct copy of this is attached hereto as Exhibit 107.]
  111. On June 30, 2013, Sean Boushie emailed me to call me “a little dicked coward.” [A true and correct copy of this is attached hereto as Exhibit 108.]
  112. On June 30, 2013, Sean Boushie continues to cyberstalk me – called me a fatass and says mys ex-wife is having a ball without me. [A true and correct copy of this is attached hereto as Exhibit 109.]
  113. On July 2, 2013, Sean Boushie continued to cyberstalk, harass, and threaten me.  And he does it with a stolen identity — pretending to be me with an e on the end of the Windsor. [A true and correct copy of this is attached hereto as Exhibit 110.]
  114. On July 2, 2013, Sean Boushie wrote to me: Fuck you asshole. [A true and correct copy of this is attached hereto as Exhibit111.]
  115. On July 3, 2013, Sean Boushie continued to stalk and harass me with “fuck you” profanity. [A true and correct copy of this is attached hereto as Exhibit 112.]
  116. On July 3, 2013, Sean Boushie continued to stalk, harass, and threaten me. [A true and correct copy of this is attached hereto as Exhibit 113.]
  117. On July 3, 2013, Sean Boushie continued to stalk, harass, and threaten me, and he continues to send obscene emails. [A true and correct copy of this is attached hereto as Exhibit 114.]
  118. On July 3, 2013, Sean Boushie continued to cyberstalk, harass, and taunt me.  Sean Boushie pretends to be me in his emails now. [A true and correct copy of this is attached hereto as Exhibit 115.]
  119. On July 3, 2013, a United Kingdom (England) publication runs story about Sean Boushie offering a reward for my murder. [A true and correct copy of this is attached hereto as Exhibit 116.]
  120. On July 4, 2013, Sean Boushie continued his cybertsalking, harassment, and threats to me: “fuck you dipshit.” [A true and correct copy of this is attached hereto as Exhibit 117.]
  121. On July 5, 2013, Sean Boushie continued to cyberstalk and harass me with a claim of “felony intimidation.” [A true and correct copy of this is attached hereto as Exhibit 118.]
  122. On July 5, 2013, Sean Boushie stole my identity and sent harassing email to Crystal Cox, another of his cyberstalking victims. [A true and correct copy of this is attached hereto as Exhibit 119.]
  123. On July 5, 2013, Sean Boushie emailed me using two stolen identities.  In this email, Sean Boushie uses the stolen identity of Bill Windsor as the sender, and he shows the message to be from Crystal Cox. [A true and correct copy of this is attached hereto as Exhibit 120.]
  124. On July 7, 2013, Sean Boushie continued to cyber stalk and harass me calling me “Fatass.” “Low life worthless stalking fuck.”  [A true and correct copy of this is attached hereto as Exhibit 121.]
  125. On July 9, 2013, Sean Boushie continued to cyber-stalk me claiming I will go to jail in Missouri. [A true and correct copy of this is attached hereto as Exhibit 122.]
  126. On July 12, 2013, Sean Boushie cyber-stalked me emailing that I am going to prison where I will be fucked in the ass. [A true and correct copy of this is attached hereto as Exhibit 123.]
  127. On July 21, 2013, Sean Boushie continued to cyber-stalk me with harassing private communications. [A true and correct copy of this is attached hereto as Exhibit 124.]
  128. On July 21, 2013, Sean Boushie continued to cyber-stalk and commit crimes against me. [A true and correct copy of this is attached hereto as Exhibit 125.]
  129. On July 22, 2013, Sean Boushie continued to cyber-stalk and harass me.  [A true and correct copy of this is attached hereto as Exhibit 126.]
  130. On August 2, 2013, Sean Boushie continued to cyber-stalk me calling me a lying asshole. [A true and correct copy of this is attached hereto as Exhibit 127.]
  131. On August 4, 2013, Sean Boushie claims he missed and shot the car next to me on the Interstate near Billings Montana on August 4, 2013. [A true and correct copy of this is attached hereto as Exhibit 128.]
  132. I received all of the emails attached hereto as exhibits.  I traced the IP addresses on many to IP addresses known by me and others to be used by Sean Boushie.  I personally printed off the online statements published by Sean Boushie.
  133. These are just SOME of the incidents of stalking.  It has taken me days just to organize this.  Sean Boushie has published things repeatedly on other websites, but there is so much that it might take me a month to pull all of it together.

FURTHER SAITH AFFIANT NOT.

I declare under penalty of perjury that the foregoing is true and correct.

Executed this 8th day of August 2013.

__________________________________

William M. Windsor

This was notarized.

Sean-Boushie-Exhibit-128 Sean-Boushie-Exhibit-127 Sean-Boushie-Exhibit-126 Sean-Boushie-Exhibit-125 Sean-Boushie-Exhibit-124 Sean-Boushie-Exhibit-123 Sean-Boushie-Exhibit-122 Sean-Boushie-Exhibit-121 Sean-Boushie-Exhibit-120 Sean-Boushie-Exhibit-119 Sean-Boushie-Exhibit-118 Sean-Boushie-Exhibit-117 Sean-Boushie-Exhibit-116 Sean-Boushie-Exhibit-115 Sean-Boushie-Exhibit-114 Sean-Boushie-Exhibit-113 Sean-Boushie-Exhibit-112 Sean-Boushie-Exhibit-111 Sean-Boushie-Exhibit-110 Sean-Boushie-Exhibit-109 Sean-Boushie-Exhibit-108 Sean-Boushie-Exhibit-107 Sean-Boushie-Exhibit-106 Sean-Boushie-Exhibit-105 Sean-Boushie-Exhibit-104 Sean-Boushie-Exhibit-103 Sean-Boushie-Exhibit-102 Sean-Boushie-Exhibit-101 Sean-Boushie-Exhibit-100 Sean-Boushie-Exhibit-099 Sean-Boushie-Exhibit-098 Sean-Boushie-Exhibit-097 Sean-Boushie-Exhibit-096 Sean-Boushie-Exhibit-095 Sean-Boushie-Exhibit-094 Sean-Boushie-Exhibit-093 Sean-Boushie-Exhibit-092 Sean-Boushie-Exhibit-091 Sean-Boushie-Exhibit-090 Sean-Boushie-Exhibit-089 Sean-Boushie-Exhibit-088 Sean-Boushie-Exhibit-087 Sean-Boushie-Exhibit-086 Sean-Boushie-Exhibit-085 Sean-Boushie-Exhibit-084 Sean-Boushie-Exhibit-083 Sean-Boushie-Exhibit-082 Sean-Boushie-Exhibit-081 Sean-Boushie-Exhibit-080 Sean-Boushie-Exhibit-079 Sean-Boushie-Exhibit-077 Sean-Boushie-Exhibit-076 Sean-Boushie-Exhibit-075 Sean-Boushie-Exhibit-074 Sean-Boushie-Exhibit-073 Sean-Boushie-Exhibit-072 Sean-Boushie-Exhibit-071 Sean-Boushie-Exhibit-070 Sean-Boushie-Exhibit-069 Sean-Boushie-Exhibit-068 Sean-Boushie-Exhibit-067 Sean-Boushie-Exhibit-066 Sean-Boushie-Exhibit-065 Sean-Boushie-Exhibit-064 Sean-Boushie-Exhibit-063 Sean-Boushie-Exhibit-062 Sean-Boushie-Exhibit-061 Sean-Boushie-Exhibit-060 Sean-Boushie-Exhibit-059 Sean-Boushie-Exhibit-058 Sean-Boushie-Exhibit-057 Sean-Boushie-Exhibit-056 Sean-Boushie-Exhibit-055 Sean-Boushie-Exhibit-054 Sean-Boushie-Exhibit-053 Sean-Boushie-Exhibit-052 Sean-Boushie-Exhibit-051 Sean-Boushie-Exhibit-050 Sean-Boushie-Exhibit-049 Sean-Boushie-Exhibit-048 Sean-Boushie-Exhibit-047 Sean-Boushie-Exhibit-046 Sean-Boushie-Exhibit-045 Sean-Boushie-Exhibit-044 Sean-Boushie-Exhibit-043 Sean-Boushie-Exhibit-042 Sean-Boushie-Exhibit-041 Sean-Boushie-Exhibit-040 Sean-Boushie-Exhibit-039 Sean-Boushie-Exhibit-038 Sean-Boushie-Exhibit-037 Sean-Boushie-Exhibit-036 Sean-Boushie-Exhibit-035 Sean-Boushie-Exhibit-034 Sean-Boushie-Exhibit-033 Sean-Boushie-Exhibit-032 Sean-Boushie-Exhibit-031 Sean-Boushie-Exhibit-030 Sean-Boushie-Exhibit-029 Sean-Boushie-Exhibit-028 Sean-Boushie-Exhibit-027 Sean-Boushie-Exhibit-026 Sean-Boushie-Exhibit-025 Sean-Boushie-Exhibit-024 Sean-Boushie-Exhibit-023 Sean-Boushie-Exhibit-022 Sean-Boushie-Exhibit-021 Sean-Boushie-Exhibit-020 Sean-Boushie-Exhibit-019 Sean-Boushie-Exhibit-018 Sean-Boushie-Exhibit-017 Sean-Boushie-Exhibit-016 Sean-Boushie-Exhibit-015 Sean-Boushie-Exhibit-014 Sean-Boushie-Exhibit-013 Sean-Boushie-Exhibit-012 Sean-Boushie-Exhibit-011 Sean-Boushie-Exhibit-010 Sean-Boushie-Exhibit-009 Sean-Boushie-Exhibit-008 Sean-Boushie-Exhibit-007 Sean-Boushie-Exhibit-006 Sean-Boushie-Exhibit-005 Sean-Boushie-Exhibit-004 Sean-Boushie-Exhibit-003 Sean-Boushie-Exhibit-002 Sean-Boushie-Exhibit-001

Sean Boushie and Wynette Boushie have been served by Sheriff to give depositions and produce documents on August 15, 2013

Sean Boushie and Wynette Boushie have been served by Sheriff to give depositions and produce documents on August 15, 2013.

During the evening of August 6, 2013, a Deputy Sheriff from Ravalli County Montana served Sean Boushie and Wynette Boushie. They are to appear for depositions on August 15, 2013, and they are to produce documents.

REQUEST FOR PRODUCTION OF DOCUMENTS TO SEAN BOUSHIE

INSTRUCTIONS  AND DEFINITIONS

 Each document request herein seeks all information available to Sean Boushie, his attorneys or agents, his wife, and any other person acting on his behalf.

  1. If the original of a document is within your possession, custody or control, produce it; if not, produce such a copy of it as is in your possession, custody or control.  Any copy of a document on which any notation, addition, alteration or change has been made is to be treated as constituting an additional original document.
  2. The term “document” is intended to have the broadest meaning permitted by law and specifically includes documents in written and electronic form, including but not limited to electronic mail, online messages, and online postings.
  3. For the purpose of responding, the term “you” and derivations of that pronoun shall refer to Sean Boushie.
  4. For the purpose of responding, the term “Windsor” refers to William M. Windsor.
  5. For the purpose of responding, the term “Lawless America” refers to www.LawlessAmerica.com, www.LawlessAmerica.org, www.facebook.com/lawlessamerica, www.facebook.com/lawlessamerica2, www.youtube.com/lawlessamerica and the project of Windsor that these web pages cover.
  6. For the purpose of responding, the term “Overstreet” refers to Defendant Allie Loraine Yager Overstreet in Missouri Case # 13LF-CV00461.
  7. For the purpose of responding, the term “Mrs. Boushie” refers to Wynette Boushie, the wife of Sean Boushie.
  8. Documents should be organized in folders or stacks with the document request number on the top.

DOCUMENT  REQUESTS

All documents relating or referring to, or evidencing, reflecting, or constituting communication to, from, or about Windsor.

All documents relating or referring to, or evidencing, reflecting, or constituting communication to, from, or about Overstreet.

All documents relating or referring to, or evidencing, reflecting, or constituting communication to, from, or about Crystal Cox.

All documents relating or referring to, or evidencing, reflecting, or constituting communication to, from, or about Mary Wilson or Mary Deneen.

All documents relating or referring to, or evidencing, reflecting, or constituting communication to, from, or about Michael Spreadbury.

All documents relating or referring to, or evidencing, reflecting, or constituting communication to, from, or about Lea Anne Scott.

All documents relating or referring to, or evidencing, reflecting, or constituting communication to, from, or about Shawn Rutherford.

All documents relating or referring to, or evidencing, reflecting, or constituting communication to, from, or about Stephanie DeYoung.

All documents relating or referring to, or evidencing, reflecting, or constituting communication to, from, or about Paul Stramer.

All documents relating or referring to, or evidencing, reflecting, or constituting communication to, from, or about Royce Engstrom.

All documents relating or referring to, or evidencing, reflecting, or constituting communication to, from, or about the police, sheriff’s department, University of Montana Public Safety or Campus Security Department, any law enforcement agency, district attorney, or prosecuting attorney.

All documents relating or referring to, or evidencing, reflecting, or constituting communication to, from, the University of Montana or any other entity or person about you or your wife allegedly stalking, harassing, defaming, libeling, slandering, cyberstalking, or threatening anyone.

All documents relating or referring to, or evidencing, reflecting, or constituting communication to, from, or about any charges against you or your wife by any law enforcement agency, any arrests, and any convictions for violating the law.

All documents relating or referring to, or evidencing, reflecting, or constituting information about Windsor or Lawless America provided to you or your wife by anyone or obtained by you from any source.

All documents relating or referring to, or evidencing, reflecting, or constituting emails or online messages sent by you or your husband or received by you or your wife at home, at work, on a mobile device, or in any other manner in 2012 or 2013.

All documents relating or referring to, or evidencing, reflecting, or constituting accounts that you or your wife have ever set up with Facebook, Yahoo, Google, Lawless America, any email provider, or any website on which you have ever posted a comment.

All documents relating or referring to, or evidencing, reflecting, or constituting your drivers’ license.

All documents relating or referring to, or evidencing, reflecting, or constituting your passport.

All documents relating or referring to, or evidencing, reflecting, or constituting licenses or permits for guns or weapons of any type.

All documents relating or referring to, or evidencing, reflecting, or constituting information about Mrs. Boushie’s participation in email, online messaging, and online posting.

All documents relating or referring to, or evidencing, reflecting, or constituting information about your employment with the University of Montana, including but not limited to performance appraisals, contracts, personnel file information, compensation information.

All documents relating or referring to, or evidencing, reflecting, constituting, or showing telephone calls by you or your wife in 2012 and 2013.

All documents relating or referring to, or evidencing, reflecting, constituting, or showing all communications between you or your wife and anyone regarding Windsor or Lawless America.

All documents relating or referring to, or evidencing, reflecting, constituting, or showing all communications between you or your wife and all persons known to you or your wife who have knowledge of the facts and circumstances alleged in Overstreet’s Complaint for Protective Order in Missouri Case # 13LF-CV00289.

All documents relating or referring to, or evidencing, reflecting, constituting, or showing all communications that support Overstreet’s claim that she was entitled to relief against Windsor as alleged in her Complaint for Protective Order in Missouri Case # 13LF-CV00289.

All documents relating or referring to, or evidencing, reflecting, constituting, or showing all communications between you or your wife and each person with knowledge of you and Windsor or Lawless America.

All documents relating or referring to, or evidencing, reflecting, constituting, or showing all communications with Windsor, including but not limited to, any and all telephone discussions with Windsor, notes or recordings of oral discussions with Windsor, emails, letters, faxes, or messages sent to or received.

All documents relating or referring to, or evidencing, reflecting, constituting, or showing all communications between you or your wife and anyone to the effect that Windsor or Lawless America are dishonest, operate a “scam,” are fraudulent, or are corrupt.

All documents relating or referring to, or evidencing, reflecting, constituting, or showing all communications between you or your wife and Joeyisalittlekid.blogspot.com or anyone who posts on the Joeyisalittlekid.blogspot.com website.

All documents relating or referring to, or evidencing, reflecting, constituting, or showing communications, or any other form of publication or information between you or your wife and anyone regarding the American Mothers Political Party.

All documents relating or referring to, or evidencing, reflecting, constituting, or showing communications, information, messages, postings, articles, recordings, or any other form of publication or information to indicate that statements made by Windsor in the VERIFIED COMPLAINT in Missouri case # 13LF-CV00461 were false.

All documents relating to, referring to, or evidencing, reflecting, or constituting messages, postings, articles, recordings, or any other form of publication, information, or communication about all the time you or your wife have spent in the state of Missouri, Kansas, or Texas from January 1, 2012 to the present.

All documents relating to, referring to, or evidencing, reflecting, or constituting messages, postings, articles, recordings, or any other form of publication, information, or communication about a Facebook page pretending to be Windsor’s deceased father.

All documents relating to, referring to, or evidencing, reflecting, or constituting messages, postings, articles, recordings, or any other form of publication, information, or communication about a Facebook page pretending to be Windsor’s deceased mother.

All documents relating to, referring to, or evidencing, reflecting, or constituting messages, postings, articles, recordings, or any other form of publication, information, or communication about a Facebook page pretending to be Bill Windsor.

All documents relating to, referring to, or evidencing, reflecting, or constituting messages, postings, articles, recordings, or any other form of publication, information, or communication about a Facebook page pretending to be Barbara or Babs Windsor.

All documents relating to, referring to, or evidencing, reflecting, or constituting messages, postings, articles, recordings, or any other form of publication, information, or communication about Windsor as the victim of stalking, harassment, defamation, libel, slander, and threats.

All documents relating to, referring to, or evidencing, reflecting, or constituting messages, postings, articles, recordings, or any other form of publication, information, or communication regarding threats that you or your wife have made to Windsor or Lawless America.

All documents relating to, referring to, or evidencing, reflecting, or constituting messages, postings, articles, recordings, or any other form of publication, information, or communication regarding threats that you or your wife have made to anyone.

All documents relating to, referring to, or evidencing, reflecting, or constituting messages, postings, articles, or any other form of publication, information, or communication made online in 2012 and 2013.

All documents relating to, referring to, or evidencing, reflecting, or constituting messages, postings, articles, recordings, or any other form of publication, information, or communication between anyone and you or your wife in which you use an alias, such as John Smith, John Brown, William Windsore, or any other name than your own.

All documents relating to, referring to, or evidencing, reflecting, or constituting messages, postings, articles, recordings, or any other form of publication, information, or communication between you or your wife and Claudine Dombrowski, Lorraine Tipton, Shannon Miller aka Elizabeth Hope Hernandez aka Shannon Hernandez, or anyone associates in any manner with the American Mothers Political Party.

All documents relating to, referring to, or evidencing, reflecting, or constituting messages, postings, articles, recordings, or any other form of publication, information, or communication that Windsor posted the death notice posting about Noah Williamson or that Windsor has ever posted knowingly false information.

All documents relating to, referring to, or evidencing, reflecting, or constituting messages, postings, articles, recordings, or any other form of publication, information, or communication regarding any cease and desist notices published by Windsor in an attempt to stop you from making contact and defaming Windsor.

All documents relating to, referring to, or evidencing, reflecting, or constituting messages, postings, articles, recordings, or any other form of publication, information, or communication regarding Windsor’ published request for retractions from you or anyone else.

All documents relating to, referring to, or evidencing, reflecting, or constituting messages, postings, articles, recordings, or any other form of publication, information, or communication regarding any litigation involving you or your wife now or at any time in the last 10 years.

All documents relating to, referring to, or evidencing, reflecting, or constituting messages, postings, articles, recordings, or any other form of publication, information, or communication that relates to police reports made by you or your wife.

All documents relating to, referring to, or evidencing, reflecting, or constituting messages, postings, articles, recordings, or any other form of publication, information, or communication regarding any weapons that you or your wife own, including but not limited to, guns, knives, bows and arrows, explosives.

All documents relating to, referring to, or evidencing, reflecting, or constituting messages, postings, articles, recordings, or any other form of publication, information, receipts, logs, or communication regarding your travel or your wife’s travel from January 1, 2012 to the present.

All documents relating to, referring to, or evidencing, reflecting, or constituting messages, postings, articles, telephone records, Internet records, recordings, or any other form of publication, information, receipts, logs, or communication regarding time that you or your wife have spent in Missouri, Kansas, or Texas from January 1, 2012 to the present.

All documents relating to, referring to, or evidencing, reflecting, or constituting messages, postings, articles, telephone records, Internet records, recordings, or any other form of publication, information, receipts, logs, or communication to indicate that you or your wife are an experienced cyberstalker.

All documents relating to, referring to, or evidencing, reflecting, or constituting messages, postings, articles, telephone records, Internet records, recordings, or any other form of publication, information, receipts, logs, or communication to indicate that you or your wife have conspired with Overstreet.

All documents relating or referring to, or evidencing, reflecting, or constituting communication to, from, or about anyone that you or your wife have ever said, written, or posted something negative.

All documents relating or referring to, or evidencing, reflecting, or constituting communication to, from, or about anything that you or your wife have ever sent to anyone by any means or posted online containing vulgar words, cuss words, four-letter words, or anatomical terms, including but not limited to fuck, shit, dickless, ass, penis, butt.

All documents relating or referring to, or evidencing, reflecting, or constituting web pages of or about Windsor or Lawless America.

 

REQUEST FOR PRODUCTION OF DOCUMENTS TO WYNETTE BOUSHIE

INSTRUCTIONS  AND DEFINITIONS

 Each document request herein seeks all information available to Wynette Boushie, her attorneys or agents, her husband, and any other person acting on his behalf.

  1. If the original of a document is within your possession, custody or control, produce it; if not, produce such a copy of it as is in your possession, custody or control.  Any copy of a document on which any notation, addition, alteration or change has been made is to be treated as constituting an additional original document.
  2. The term “document” is intended to have the broadest meaning permitted by law and specifically includes documents in written and electronic form, including but not limited to electronic mail, online messages, and online postings.
  3. For the purpose of responding, the term “you” and derivations of that pronoun shall refer to Wynette Boushie.
  4. For the purpose of responding, the term “Windsor” refers to William M. Windsor.
  5. For the purpose of responding, the term “Lawless America” refers to www.LawlessAmerica.com, www.LawlessAmerica.org, www.facebook.com/lawlessamerica, www.facebook.com/lawlessamerica2, www.youtube.com/lawlessamerica and the project of Windsor that these web pages cover.
  6. For the purpose of responding, the term “Overstreet” refers to Defendant Allie Loraine Yager Overstreet in Missouri Case # 13LF-CV00461.
  7. For the purpose of responding, the term “Mr. Boushie” refers to Sean Boushie, the husband of Wynette Boushie.
  8. Documents should be organized in folders or stacks with the document request number on the top.

DOCUMENT  REQUESTS

All documents relating or referring to, or evidencing, reflecting, or constituting communication to, from, or about Windsor.

All documents relating or referring to, or evidencing, reflecting, or constituting communication to, from, or about Overstreet.

All documents relating or referring to, or evidencing, reflecting, or constituting communication to, from, or about Crystal Cox.

All documents relating or referring to, or evidencing, reflecting, or constituting communication to, from, or about Mary Wilson or Mary Deneen.

All documents relating or referring to, or evidencing, reflecting, or constituting communication to, from, or about Michael Spreadbury.

All documents relating or referring to, or evidencing, reflecting, or constituting communication to, from, or about Lea Anne Scott.

All documents relating or referring to, or evidencing, reflecting, or constituting communication to, from, or about Shawn Rutherford.

All documents relating or referring to, or evidencing, reflecting, or constituting communication to, from, or about Stephanie DeYoung.
All documents relating or referring to, or evidencing, reflecting, or constituting communication to, from, or about Paul Stramer.
All documents relating or referring to, or evidencing, reflecting, or constituting communication to, from, or about Royce Engstrom.
All documents relating or referring to, or evidencing, reflecting, or constituting communication to, from, or about the police, sheriff’s department, University of Montana Public Safety or Campus Security Department, any law enforcement agency, district attorney, or prosecuting attorney.
All documents relating or referring to, or evidencing, reflecting, or constituting communication to, from, the University of Montana or any other entity or person about you or your husband allegedly stalking, harassing, defaming, libeling, slandering, cyberstalking, or threatening anyone.
All documents relating or referring to, or evidencing, reflecting, or constituting communication to, from, or about any charges against you or your husband by any law enforcement agency, any arrests, and any convictions for violating the law.
All documents relating or referring to, or evidencing, reflecting, or constituting information about Windsor or Lawless America provided to you or your husband by anyone or obtained by you from any source.
All documents relating or referring to, or evidencing, reflecting, or constituting emails or online messages sent by you or your husband or received by you or your husband at home, at work, on a mobile device, or in any other manner in 2012 or 2013.
All documents relating or referring to, or evidencing, reflecting, or constituting accounts that you or your husband have ever set up with Facebook, Yahoo, Google, Lawless America, any email provider, or any website on which you have ever posted a comment.
All documents relating or referring to, or evidencing, reflecting, or constituting your drivers’ license.
All documents relating or referring to, or evidencing, reflecting, or constituting your passport.
All documents relating or referring to, or evidencing, reflecting, or constituting licenses or permits for guns or weapons of any type.
All documents relating or referring to, or evidencing, reflecting, or constituting information about Mr. Boushie’s participation in email, online messaging, and online posting.
All documents relating or referring to, or evidencing, reflecting, or constituting information about your husband’s employment with the University of Montana, including but not limited to performance appraisals, contracts, personnel file information, compensation information.
All documents relating or referring to, or evidencing, reflecting, constituting, or showing telephone calls by you or your husband in 2012 and 2013.
All documents relating or referring to, or evidencing, reflecting, constituting, or showing all communications between you or your husband and anyone regarding Windsor or Lawless America.
All documents relating or referring to, or evidencing, reflecting, constituting, or showing all communications between you or your husband and all persons known to you or your husband who have knowledge of the facts and circumstances alleged in Overstreet’s Complaint for Protective Order in Missouri Case # 13LF-CV00289.
All documents relating or referring to, or evidencing, reflecting, constituting, or showing all communications that support Overstreet’s claim that she was entitled to relief against Windsor as alleged in her Complaint for Protective Order in Missouri Case # 13LF-CV00289.
All documents relating or referring to, or evidencing, reflecting, constituting, or showing all communications between you or your husband and each person with knowledge of you and Windsor or Lawless America.
All documents relating or referring to, or evidencing, reflecting, constituting, or showing all communications with Windsor, including but not limited to, any and all telephone discussions with Windsor, notes or recordings of oral discussions with Windsor, emails, letters, faxes, or messages sent to or received.
All documents relating or referring to, or evidencing, reflecting, constituting, or showing all communications between you or your husband and anyone to the effect that Windsor or Lawless America are dishonest, operate a “scam,” are fraudulent, or are corrupt.
All documents relating or referring to, or evidencing, reflecting, constituting, or showing all communications between you or your husband and Joeyisalittlekid.blogspot.com or anyone who posts on the Joeyisalittlekid.blogspot.com website.
All documents relating or referring to, or evidencing, reflecting, constituting, or showing communications, or any other form of publication or information between you or your husband and anyone regarding the American Mothers Political Party.
All documents relating or referring to, or evidencing, reflecting, constituting, or showing communications, information, messages, postings, articles, recordings, or any other form of publication or information to indicate that statements made by Windsor in the VERIFIED COMPLAINT in Missouri case # 13LF-CV00461 were false.
All documents relating to, referring to, or evidencing, reflecting, or constituting messages, postings, articles, recordings, or any other form of publication, information, or communication about all the time you or your husband have spent in the state of Missouri, Kansas, or Texas from January 1, 2012 to the present.
All documents relating to, referring to, or evidencing, reflecting, or constituting messages, postings, articles, recordings, or any other form of publication, information, or communication about a Facebook page pretending to be Windsor’s deceased father.
All documents relating to, referring to, or evidencing, reflecting, or constituting messages, postings, articles, recordings, or any other form of publication, information, or communication about a Facebook page pretending to be Windsor’s deceased mother.
All documents relating to, referring to, or evidencing, reflecting, or constituting messages, postings, articles, recordings, or any other form of publication, information, or communication about a Facebook page pretending to be Bill Windsor.
All documents relating to, referring to, or evidencing, reflecting, or constituting messages, postings, articles, recordings, or any other form of publication, information, or communication about a Facebook page pretending to be Barbara or Babs Windsor.
All documents relating to, referring to, or evidencing, reflecting, or constituting messages, postings, articles, recordings, or any other form of publication, information, or communication about Windsor as the victim of stalking, harassment, defamation, libel, slander, and threats.
All documents relating to, referring to, or evidencing, reflecting, or constituting messages, postings, articles, recordings, or any other form of publication, information, or communication regarding threats that you have made to Windsor or Lawless America.
All documents relating to, referring to, or evidencing, reflecting, or constituting messages, postings, articles, recordings, or any other form of publication, information, or communication regarding threats that you or your husband have made to anyone.
All documents relating to, referring to, or evidencing, reflecting, or constituting messages, postings, articles, or any other form of publication, information, or communication made online in 2012 and 2013.
All documents relating to, referring to, or evidencing, reflecting, or constituting messages, postings, articles, recordings, or any other form of publication, information, or communication between anyone and you or your husband in which you use an alias, such as John Smith, John Brown, William Windsore, or any other name than your own.
All documents relating to, referring to, or evidencing, reflecting, or constituting messages, postings, articles, recordings, or any other form of publication, information, or communication between you or your husband and Claudine Dombrowski, Lorraine Tipton, Shannon Miller aka Elizabeth Hope Hernandez aka Shannon Hernandez, or anyone associates in any manner with the American Mothers Political Party.
All documents relating to, referring to, or evidencing, reflecting, or constituting messages, postings, articles, recordings, or any other form of publication, information, or communication that Windsor posted the death notice posting about Noah Williamson or that Windsor has ever posted knowingly false information.
All documents relating to, referring to, or evidencing, reflecting, or constituting messages, postings, articles, recordings, or any other form of publication, information, or communication regarding any cease and desist notices published by Windsor in an attempt to stop you from making contact and defaming Windsor.
All documents relating to, referring to, or evidencing, reflecting, or constituting messages, postings, articles, recordings, or any other form of publication, information, or communication regarding Windsor’ published request for retractions from you or anyone else.
All documents relating to, referring to, or evidencing, reflecting, or constituting messages, postings, articles, recordings, or any other form of publication, information, or communication regarding any litigation involving you or your husband now or at any time in the last 10 years.
All documents relating to, referring to, or evidencing, reflecting, or constituting messages, postings, articles, recordings, or any other form of publication, information, or communication that relates to police reports made by you or your husband.
All documents relating to, referring to, or evidencing, reflecting, or constituting messages, postings, articles, recordings, or any other form of publication, information, or communication regarding any weapons that you or your husband own, including but not limited to, guns, knives, bows and arrows, explosives.
All documents relating to, referring to, or evidencing, reflecting, or constituting messages, postings, articles, recordings, or any other form of publication, information, receipts, logs, or communication regarding your travel or your husband’s travel from January 1, 2012 to the present.
All documents relating to, referring to, or evidencing, reflecting, or constituting messages, postings, articles, telephone records, Internet records, recordings, or any other form of publication, information, receipts, logs, or communication regarding time that you or your husband have spent in Missouri, Kansas, or Texas from January 1, 2012 to the present.
All documents relating to, referring to, or evidencing, reflecting, or constituting messages, postings, articles, telephone records, Internet records, recordings, or any other form of publication, information, receipts, logs, or communication to indicate that you or your husband are an experienced cyberstalker.
All documents relating to, referring to, or evidencing, reflecting, or constituting messages, postings, articles, telephone records, Internet records, recordings, or any other form of publication, information, receipts, logs, or communication to indicate that you or your husband have conspired with Overstreet.

All documents relating or referring to, or evidencing, reflecting, or constituting communication to, from, or about anyone that you or your husband have ever said, written, or posted something negative.

All documents relating or referring to, or evidencing, reflecting, or constituting communication to, from, or about anything that you or your husband have ever sent to anyone by any means or posted online containing vulgar words, cuss words, four-letter words, or anatomical terms, including but not limited to fuck, shit, dickless, ass, penis, butt.

All documents relating or referring to, or evidencing, reflecting, or constituting web pages of or about Windsor or Lawless America.