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IN THE DISTRICT COURT OF CARROLL COUNTY, MARYLAND

WILLIAM JOHN JOSEPH HOGE III


Petitioner )
v.
)
)
WILLIAM M. SCHMALFELDT, SR.
Respondent

)
Case # 06-C-14-067023
)
)

RESPONSE IN OPPOSITION TO PETITIONERS MOTION TO


MODIFY AND EXTEND THE PEACE ORDER
Now comes respondent William M. Schmalfeldt, Sr. (Respondent)
with a motion to this honorable court to deny WJJ Hoge IIIs (Petitioner)
motion to modify and extend the Peace Order issued by this court on
August 27, 2015
STATEMENT OF FACTS
1.

CJ 3-1506(a)(1) clearly states A peace order may be

modified or rescinded during the term of the peace order after: (i)
giving notice to the petitioner and the respondent and (ii) a hearing.
(emphasis added)
2.

CJ 3-1505(f) clearly states All relief granted in a final

peace order shall be effective for the period stated in the order, not to
exceed 6 months. (emphasis added).
3.

The order issued by Circuit Court Judge Michael Galloway

on August 27, 2014, clearly states, unless stated otherwise below,


this order is effective until 08/27/2015. (emphasis added) That is
one year, not six months.

4.

As the one year term of Judge Galloways order was not in

keeping with the states law mandating a six month maximum with the
possibility of another six month extension after a hearing and for good
cause, the order was invalid from the moment it was issued.
5.

Had Respondent been in attendance at the hearing,

instead of being misled by Petitioner into believing that there was


going to be no appeal of the District Courts denial of the initial peace
order attempt, Respondent would have noticed the error, asked for it to
be corrected, and there would have been a valid peace order,
assuming one was issued.
6.

Petitioner had ample opportunity to inform the court of this

scriveners error but chose not to do so.


7.

Even if this had been a valid peace order for the first six

months, that six months expired February 27, 2015. It is not April 21,
2015 nearly two months later. The plaintiff cannot go back to the well
a day, a month, two months, six years after an order expires and
demand that it be modified and extended. If this ever was a valid
peace order, it died on February 27, 2015.
8.

Petitioner claims that Respondent continues to violate this

non-extant peace order. This is simply a lie. This court rejected


Petitioners attempt to find Respondent in contempt of court for
violations of this alleged peace order. This Petitioner had the
Respondent charged with a count of violating the peace order and the

Respondent was found Not Guilty in a Carroll County District Court on


April 16, 2015.
9.

Respondent maintains that Petitioners motion is yet

another manifestation of the Petitioners malignant, megalomaniacal


personality disorder. He cannot be wrong. He must never be proven
incorrect. This petitioner was found to have no cause for charges
against respondent in Howard County in 2013. So through his blog
readership, he organized an Everybody Blog About Howard County
Day, distributing the e-mail address and phone number of the States
Attorney in Howard County, disrupting that offices ability to do its job
of enforcing the laws of the state and county, all because someone told
him he was wrong. He created and sold a line of Maryland is for
Stalkers bumper stickers on his website. All because someone told
him he was wrong.
10.

After 367 nolle prosequi charges against respondent,

Petitioner continues to exhort his readership into continued acts of


harassment against Respondent. All because someone told him he was
wrong.
11.

Petitioner went so far as to file a fraudulent copyright

infringement suit against Respondent, details of which have been


forwarded to the FBI for investigation, naming himself as a copyright
claimant which he is not as he does not own all rights to the work,
claiming that the pseudonymous author Paul Krendler lives at his

address, thereby defrauding the US Copyright Office, the US District


Court for the District of Maryland and this respondent with a frivolous,
illegal lawsuit. All because somebody told him he was wrong.
12.

In his misbegotten contempt of court case against

Respondent, Petitioner introduced into evidence a forged letter, an


obvious forgery with a traced signature, a forgery a respondent will
prove should one of our states law enforcement agencies decide to
investigate the claim, baldly stating that it was mailed to him by
Respondent, who had never seen the letter before Petitioner included it
in a motion to this court. All because someone told him he was wrong,
CONCLUSION
13.

This is a closed case.

14.

This case has been closed for two months.

15.

The peace order died at birth as it was improperly drafted

and nobody took the time or effort to point out the error to the court.
16.

Assuming the peace order did not die at birth, it died on

February 27, 2015 at the end of its six month lifespan.


17.

Petitioner cannot apply salve to soothe the searing pain of

being told by a District Court Judge that the peace order was invalid
and even if it was not, there was no mens rea in the Respondents
conduct and therefore he is not guilty, by attempting to breathe life
into a dead peace order.
THEREFORE: Respondent asks this court to:

A.

Immediately deny Hoges motion to modify and extend the

peace order;
B.

Order that Hoge get the permission of the court before

issuing any new charges or filing any new motions against this
respondent.
C.

Order that Hoge undergo a thorough psychiatric evaluation

to determine the reasons for this vexatious, malicious, vindictive, and


bizarre need to punish Respondent; and
D.

Any other relief the Court may find just and proper.

Dated April 21, 2015

Respectfully Submitted

William M, Schmalfeldt, Sr.


Pro Se Respondent
6636 Washington Blvd. #71
Elkridge, MD 21075
410-206-9637
bschmalfeldt@comcast.net

CERTIFICATE OF SERVICE
I certify that on April 21, 2015, I mailed a copy of this filing to
William John Joseph Hoge, 20 Ridge Road, Westminster, MD 21157 via
First Class US Mail.

William M. Schmalfeldt, Sr.

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