IN THE CIRCUIT COURT OF CARROLL COUNTY, MARYLAND WILLIAM HOGE, Plaintiff, ve. No. C-16-70789 BRETT KIMBERLIN, et al., Defendants DEFENDANT BRETT AND TETYANA KIMBERLIN’S RESPONSE IN OPPOSITION ‘TO PLAINTIFF'S MOTION TO STRIKE Now come Defendants Brett and Tetyana Kimberlin and respond in opposition to Plaintiff's Motion to Strike Docket Item 47. The motion is without merit. 1. The Chutzpah of Plaintiff Hoge, with his faux outrage at being called a spade. He is a man who has filed, over three years, close to 400 frivolous, malicious, harassing, scandalous, and vexatious legal actions against Defendants and their associates, every single one which has been dismissed. He has stalked Defendants and their teenage daughter for years, so severely that the daughter was bullied out “Bftwo public schools, He has been told by Montgomery County Judge Audrey Créighton that his stalking amounted to “child abuse” that could land him behind bars. 2. This case will suffer the same fate as all of Hoge’s other lawsuits. There is no sense or reason for acting as though he is deserving of respect or for sanitizing his monstrous behavior. He is a predator pure and simple, and he is abusing the legal system and wasting this Court’s valuable resources to deal with yet another of his delusional and vexatious lawsuits. These are not ad hominem attacks, but stark facts based on Plaintiff's long and sordid history of harassment, stalking and legal abuse.‘And Defendants are not using the narrow Maryland statutory definition of stalking but rather the definition used by victim’s rights organizations and the Federal Violence Against Women Act: “Stalking is a form of mental assault, in which the perpetrator repeatedly, unwantedly, and disruptively breaks into the life-world of the victim, with whom they have no relationship. Moreover, the separated acts that make up the intrusion cannot by themselves cause the mental abuse, but do taken together.” "CyberStalking: Menaced on the Internet”. sociosite.org. 14 May 2013. The Violence Against Women Act defines stalking as: “STALKING—The term ‘stalking’ means engaging in a course of conduct directed at a specific person that would cause a reasonable person to—(A) fear for his or her safety or the safety of others; or (B) suffer substantial emotional distress." 3. Plaintiff knows that he cannot sue Defendants in Carroll County because judges in other cases he has filed have dismissed suits due to the fact that he filed them in Carroll County rather than the county of the defendants he is suing. See Courts and Judicial Procedure 6-201. Nota single one of the defendants in this case is from Carroll County and this cause of action did not arise in Carroll County. Yet Plaintiff has filed this suit in Carroll County as a form of harassment, just as he has done so with his hundreds of other dismissed legal actions. 4, Plaintiff flat out lies to the Court in saying that he does not have Defendants’ address because it is not listed on their pleading. This lie comes from a man who has repeatedly sent the police to Defendants’ address to deliver his vexatious legal actions; who has sent hundreds of legal pleadings to the address; and whose right wing associates have come to and taken pictures of the home and Defendants’ pre-teen daughter. Again, this is just another one of Plaintiff's crying wolf to the Court in order to harass Defendants. In short, Plaintiffis using this case to harass Defendants and to get attention. He is, based on his multi-year history of stalking and obsessive behavior toward Defendants and their teenage daughter, a mentally disturbed sexual predator who will never voluntarily stop his cruel harassment. This Court should not enable his vile and vexatious behavior in any way, but instead should shut him down permanently by declaring him a vexatious litigant. RespectfullyStbmitted peo pret Kibo Certificate of Service I certify that I mailed a copy of this motion on Plaintiff this 24" day of May, 2016. Brett Ki jin