IN THE DISTRICT COURT OF COWLEY-WINFIELD, KANSAS
PROTECTION FROM STALKING
SHARLA MCIVER, Plaintiff
v Case No. CLW-2023-DM-273
ERIN K. COSTELLO, Defendant
Pursuant to K.S.A. Chapter 23
AMENDED AFFIDAVIT IN SUPPORT OF PLAINTIFF’S MOTION
FOR CONTEMPT FINDING
STATE OF KANSAS
COWLEY COUNTY
I, Sharla J. McIver, of lawful age, being first duly sworn, state:
1. I am the Plaintiff in this action.
2. The Defendant continues to blatantly violate the order despite it being entered as a final
extended (lifetime) order and the Defendant being served with the same.
3. The final extended order requires the Defendant permanently delete all posts and videos
targeting me, speaking of me or to me or in reference to me or these proceedings. The
Defendant states that she does not agree with the order and the judge did not explain how
she is violating the order so she will continue to do so.
4. The Defendant continues to make posts and videos with false accusations against
me, targeting me, and discussing my family and private matters in these proceedings that
continue to the present date.
5. The Defendant continues to instigate others to continue discussing me and these cases,
stating that if others continue to talk about it, she then has the right to continue and the
order does not matter. She has stated she will not remove anything or adhere to any of the
terms of the extended order. She has made statements mocking Judge Walker and the
court, and stated that the court “can’t touch her in New York”
6. The Defendant’s most recent video on 5-7-2026, the description reads “Addressing
someone who refuses to leave me alone in real life. No matter what I’ve done they
keep coming back to disrupt my life and my serenity. I will not keep this harassment
silent any longer. I don’t feel safe being in private conversations with this person. Is
this what parasocial relationship looks like? The following hashtags are used:
Lawfare, Harassment, Harassment allegation, Coercive control, Threat, Corrupt
system, Witness, Cyberharassment, WOACB, Katie Joy, Without a Crystal Ball.
7. In her most recent video, in violation of the order, the Defendant makes statements that
she was addressing me publicly on video in violation of the order rather than replying to
the email I sent trying one last time to come to some kind of agreement with her and
after YouTube told me I needed to attempt to resolve it with her before they would
take action on the removal order from the Court. The Defendant goes on to read and
display this email, a direct communication to her in the capacity of acting as my own
lawyer, which she has done numerous times since the order was granted as well as since
it was extended to her lifetime. The Defendant again threatens to “expose me” be reading
emails with my stepdaughters who have not been part of my life for more than 20 years,
that have nothing to do with Ms. Costello, after Ms. Costello denied to Judge Lanning
and to Judge Walker she had been in communication with any of my family members
after the initial petition was filed.
8. In the same video, the Defendant stated “See, you’re ready to what? Um begin
criminal charges in New York first? How? How so? Because the only way that’s going to
happen is if I’m picked up in New York and extradited to Kansas. And the judge already
told you that’s not going to happen. He even told you that the order isn’t worth the paper
it’s written on unless I’m in Kansas.” She continued, “In other words what? Someone
from Cowley County possibly called New York and therefore you could say they’ve been
in contact and that yeah, they have to enforce it because it’s accepted in all 50 states. But
enforcing it doesn’t mean arresting me.
9. In the comment section of the video the Defendant makes statement such as: “The clerk
is rude as fuck and just tells me to talk to an attorney. I even filed a motion titled
Respondents Motion for Finding of Abuse of Process and for Order Restricting Improper
and Harassing communications. I filed that on November 25, 2025. I had to contact the
court for verification they even received it then heard nothing about it until the end of
March 2026. And that was only because I bought the transcripts for a hearing I missed on
March 13. I was served just days before the hearing and the paperwork mentioned
nothing of my motion being heard nor the motion I filed on December 15, 2025 for
sanctions, abuse of process and misuse of court authority. The paperwork made no
mention of these motions, only her motion and judge hadn’t even read my motions by
March 13th according to the transcripts yet planned on hearing argument.”
10. Addressing me specifically, the Defendant made statements including “You won’t leave
me alone and you keep dragging me through court over this bullshit…..You expect me to
stay silent on it all. No. No. You’re trying to take away my free speech. You’re trying to
tell me I can’t share an opinion about you that’s negative.” The order is already in place,
and is very clear that Ms. Costello was directed to cease all commentary about me
or related to me, on any social media platform, including YouTube, since at least March
2024 when the temporary order was amended with this specific language. The Defendant
has refused to respect or comply with the order for nearly three years.
11. In the comment section of her most recent video, in violation of the order include outright
threats to witnesses in my case, requests for false reports to the FBI and Homeland
Security against witnesses in my cases, and comments from the Defendant’s and Renelle
Smith’s mutual follower stating: “It seems like the time has come to bring this vexatious
Litigant to the media. Expose the harassment and the legal abuse you’ve endured.” and
“Said person has been doing this for years. Why can’t the court see this. It’s wrong how
they let said person use the courts this way.”
12. In the comment section of her most recent video, the Defendant made numerous
posts in violation of the order including but not limited to the following:
“Whether or not I can respond I think is a grey area. The court doesn’t allow for
public discussion on such matters while proceedings are on going and that goes for
all parties involved. But Kansas is an open records state and allows for information
to be obtained by the public for transparency. Nothing is hidden unless sealed and
nothing is sealed without a motion requesting it and a hearing discussing it followed
by a ruling granting it. Even then it’s never an entire case or trial granted under a
gag order, it’s maybe a document or other sensitive piece of info or info on minors or
medical issues. So our entire trial and concluded proceedings can be osbtained
through a records request. The order is written banning me from discussing her and
the proceedings (only me so it’s not a gag order), making reference to her in any way
even using a code name. But Kansas own state law and appellate court recognized
these types of ROs to be a violation of free speech under federal and Kansas state
law. Both judges in this case between she and I have verbally told her that they can’t
restrict my referencing things so long as I’m not directly referencing her or speaking
to her or contacting her, regardless of how the order reads. So I don’t know. It seems
like it’s worded well enough to allow her to argue/file contempt but its not supported
by Kansas State law and in referencing the Kansas state court of appeals decisions
so long as I put up the fuss of presenting an adequate argument against her. That’s
just fucked up. If that’s the case how many people in Kansas have rulings against
them causing punishment of some kind for not participating in these ridiculous
accusations and costly proceedings? And with thee types of filings on the rise
involving social media like ours when does the court become negligent in some way
for allowing and participating in such tomfoolery (I can’t believe I just used that
word but it is the perfect word to describe this shit laughing my ass off).”
13. In the same comment section, one of the Defendant’s associates falsely states that I
created an email account in her name, that it was time for her to file an RO against
me, and states “The judge is retired. Why he is allowed to do anything amazes me. I
would check with the bar association. Actually I think a bar complaint might be in
order.” The YouTube account/channel owner is responsible for comments in both the
live chat and the comment section of their videos and posts.
14. In numerous posts and videos, the Defendant makes statements directly addressing
me with no legitimate purpose other than to harass and intimidate. On May 14, 2026
after YouTube opted to block her channel in the United States rather than terminate and
delete it as required by the order, the Defendant immediately began to advise her
followers to buy an app (VPN) and set it to a country outside the U.S to circumvent the
block and stating she was uploading her content to a new channel in spite of the order.
She also posted links to videos targeting me, in violation of the order, and asked people
to use those links to watch the videos anyway.
15. The Defendant posted, “ Just because some lies become too much and to big and
harmful, anyone can be added to the NCIC database. And though I am not currently
found to be there, if I were to be, it would be laughed at by New York State almost as
hard as everything else up until now. This is New York State.”
16. On May 17, 2026, the Defendant posted “Since a bullshit by default court order
took my free speech and blocked my channel from being seen in the U.S., where
95% of viewers live, my channel revenue analytics show an increase of 24%
compared to before the order. My earning potentials have gone up 24%. How?
#streisanded”
17. The Defendant, on video and in posts, continues to harass a friends and
professional acquaintances who have nothing to do with this and do not know any of
the Defendants by tracking social media posts from 2012-2013 and claiming I have
used their names on social media accounts. One of those friends has been available
to testify regarding the Defendant’s repeated posts to and about her, but no
evidence or witnesses could be shown in the contempt citation hearings due to the
Defendant’s refusal to appear even via Zoom.
18. On May 30, 2026, the Defendant posted “It just dawned on me, my channel is blocked
in the U.S. So I guess I can talk about whomever or whatever on it now. Why else
block it? Now live stream coming up soon. Let’s really look at why I received an RO.
What did I say or do? See how insane this shit has been.”
19. The Defendant has repeatedly tagged me on social media since the Lifetime Order
has been in place, causing my phone to alert me with a notification. This is a key
element of cyberstalking federally and in Kansas, and has been consistently upheld
by courts as a violation of a protective order. Tagging triggers a direct notification to
the protected person, and courts consider it a prohibited form of electronic contact.
Several rulings clarify why and how this applies:
Direct notification is contact even if the content is not threatening. Case precedent
includes People v Maria Gonzalez, a criminal contempt case, where the court ruled
Social media tagging violated an order prohibiting contact “by electronic or any
other means” as it actively alerted the protected party to the post. Appellate rulings
have rejected the defense that social media tagging is protected under free speech if
it acts as a tool to harass or electronically contact a protected party (Michigan Court
of Appeals ARM v KJL, Docket Nos. 357120, 3568858 and 358859, in which the
Court of Appeals ruled that the trial court properly held the defendant in criminal
Contempt for violating a personal protection order because he tagged the Plaintiff in
a social media post and rejected the Defendant’s argument that the PPO issued
against him violated his constitutional right to free speech).
20. On June 3, 2026, the Defendant posted “She feels so harassed that now she’s
unblocked me so I can see her tweets about me. Get the fuck out of here.” I blocked
the Defendant when I created my X account in April 2025 and have never unblocked
her. The post was made at 2:44 p.m. cst.
21. Immediately following the Defendant’s post, the following events occurred which
I have been experiencing from the Defendant and her admitted friends/associates
for nearly three years: At 3:23 and 3:24 pm attempts were made to log in to
my Facebook account; at 3:27 and 3:28 pm attempts were made to log in to my
X account; at 3:28 pm an attempt was made to hack into/access my cellular phone;
At 3:43 pm an attempt was made to hack into/access my computer; at 4:08 and 4:09
pm attempts were made to hack into my PayPal account; at 4:14 pm a Domino’s
Pizza order totaling $65.04 was placed from a New York phone number; at 4:31 pm
a false report was made that I was actively suicidal; around the same time a SWAT
attempt was made through a false report to the Winfield Police Department through
the FBI online report site stating someone was at my house with a gun attempting
to kill my husband and I, and four officers arrived at my home at approximately
4:45 p.m.
The Defendant and her friends/associates have been involved in similar conduct
online that has been documented as early as 2019 and has progressively escalated,
with a number of different online targets.
22. The Defendant continues to request that others contact me for information and evidence
and continues to disseminate evidence I sent her during discovery to others who repost
it, misstating what the evidence shows and causing them to join in on harassing me and
threatening me.
23. The Defendant has a history of harassing others, including through manufactured
drama and obtaining/displaying/reading police reports through FOIA, and contacting
family and professional acquaintances of others for content on her YouTube channel. The
Defendant also has a history of hacking devices and involvement with the Dark Web.
24. I continue to fear for my mental, emotional and physical safety substantially more
than when I filed the initial petitions, because of the actions of the Defendant, despite
the final extended order being in place.
25. I have filed reports in Kansas and New York regarding these violations, however
confusion continues to exist regarding enforceability despite the full faith and credit
application.
26. In May 2026, criminal charges were filed against the Defendant by the Winfield
Police Department to the Cowley County District Attorney and are currently under
review by that office.
_______________________________________
Sharla J. McIver, Plaintiff, pro se
SUBSCRIBED AND SWORN TO BEFORE ME this _______day of ______________,
2026. Appointment Expires:
_______________________________________
________________ Notary Public
IN THE DISTRICT COURT OF COWLEY-WINFIELD, KANSAS
PROTECTION FROM STALKING
SHARLA J. MCIVER, Plaintiff
v Case No. CLW-2023-DM-273
ERIN K. COSTELLO, Defendant
Yorkville, NY 13495
AMENDED MOTION FOR CONTEMPT FINDING
COMES NOW the Plaintiff, Sharla J. McIver, pro se, and moves this Court to issue an
Order to Appear and Show Cause for the Defendant to show why she should not be found in
contempt. In support of said motion, Plaintiff states and alleges as follows:
1. The Plaintiff filed a PFS Petition against the Defendant on August 27, 2023, alleging
multiple incidents of stalking and harassment.
2. On December 3, 2024, the Final Order of Protection From Stalking was granted to
the Plaintiff via Memorandum Decision.
3. On December 11, 2024, the Final Order of Protection From Stalking and on
November 13, 2025 the order was extended to her lifetime, with URLs and posts to be
permanently deleted by the Defendant listed. The Defendant continues to refuse to delete any
videos or posts.
4. After the final order, the Defendant continues to harass and stalk the Plaintiff on
multiple occasions in violation of the court’s orders, as set out in the accompanying
affidavit.
5. The Plaintiff requests an in person trial date at the earliest availability of the Court, as
the Defendant continues making content targeting the Plaintiff in violation of the final order.
6. The Plaintiff seeks a finding in contempt for the Defendant’s refusal to respect or
follow the Court’s orders and for violations of the final order. Plaintiff requests that the Court
issue additional financial sanctions, issue an order requiring the Defendant to permanently
delete her YouTube, X, Rumble and TikTok accounts where the violating content is published
and issue a supplemental order to YouTube directing them to remove and delete the Defendant’s
accounts.
WHEREFORE, Plaintiff moves the Court to issue an Order for the Defendant to Appear
and Show Cause as to why she should not be found in contempt and for all sanctions the court
deems just and proper.
Respectfully submitted,
____________________________________
Sharla J McIver, pro se
IN THE DISTRICT COURT OF COWLEY-WINFIELD, KANSAS
PROTECTION FROM STALKING
SHARLA MCIVER, Plaintiff
v Case No. CLW-2023-DM-273
ERIN K COSTELLO, Defendant
Pursuant to K.S.A. Chapter 23
ORDER TO APPEAR AND SHOW CAUSE
The above matter comes upon Motion of the Plaintiff for an Order for the Defendant to Appear
and Show Cause.
WHEREUPON the Court after reviewing the Plaintiff’s Motion, issues the following as Order
of the Court:
1. The Defendant is hereby ordered to appear IN PERSON on the ______ day of
_______________ at _________ before the Honorable Judge Walker in the Cowley County
District Court.
2. The Defendant is ordered to show cause as to why she should not be found in contempt of the
Court’s prior final orders, entered herein.
IT IS SO ORDERED.
THIS ORDER IS EFFECTIVE AS OF THE DATE AND TIME OF THE FILE STAMP.