IN THE CIRCUIT COURT FOR CARROLL COUNTY MARYLAND

WILLIAM JOHN JOSEPH HOGE, III
Plaintiff
v.
BRETT KIMBERLIN, et al.,
Defendants

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Case No. 06-C-16-070789

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DEFENDANT’S REPLY TO PLAINTIFF’S MOTION TO COMPEL DISCOVERY
COMES NOW Defendant William M. Schmalfeldt, Sr. to REPLY to plaintiffs motion to
compel discovery.
SUING PEOPLE IS NOT DEFENDANT SCHMALFELDT’S HOBBY. SO HE HAS NO
IDEA WHAT PLAINTIFF IS REFERRING TO REGARDING “PROTECTIVE
ORDERS” AS RELATED TO INTERROGATORIES.
The reason this Defendant and others have time and time again asked Caroll County
Courts to declare the plaintiff a vexatious litigant is because filing lawsuits seems to be his
hobby. This defendant has no idea what the plaintiff is referring to when he writes “defendant
Schmalfeldt has failed to answer interrogatories with no protective order sought.” Mr. Hoge is
not an attorney. He calls himself a paralegal because his friend, Virginia unemployed attorney
Aaron Worthing, asks for his help from time to time and provides free legal assistance to the
plaintiff in return for those services. Defendant Schmalfeldt is a retired writer editor with
Parkinson’s disease, who has other interests that do not include interfering in the lives of others
by filing frivolous lawsuits.

THE TWO INTERROGATORIES DEFENDANT ANSWERED AS BEING
IRRELEVANT TO HOGE’S CASE ARE, IN FACT, IRRELEVANT TO HOGE’S
“CASE”.
In Interrogatory No. 7 the plaintiff asks this defendant to identify the name of the
person(s) who paid attorney Tae Kim’s fee for defending him against the plaintiffs first attack on
defendant’s freedom, the plaintiff’s peace order from early 2013. This was clearly before the
time period plaintiff describes as the time of the alleged conspiracy. The answer to that question
has no bearing on plaintiff’s case. Plaintiff admits he asked the question to ascertain the
identities of John Does 3 and 4. If plaintiff wishes to ascertain those identities, he can use other
avenues that do not violate attorney-client privilege. Mr. Kim ceased being my attorney in mid
2013. Again this is well before the. Plaintiff alleges the conspiracy against him took place.
In Interrogatory No. 8, Plaintiff asks this defendant to identify any person who exercised
either editorial or managerial control over the defendant during his first tenure as editor of
Breitbart Unmasked. Again if Mr. Hoge wishes to ascertain the identities of other defendants in
this case, there are other means he can employ. As this defendant was never actually employed
by Breitbart Unmasked, and worked as a freelance editor, the question is irrelevant and has no
bearing on the plaintiff’s case.
DEFENDANT SCHMALFELDT GROWS WEARY OF MR. HOGE’S NEVER-ENDING
PERSECUTION IN ORDER TO FIND SCHMALFELDT GUILTY OF SOMETHING.
The defendant asks this court to take judicial notice that he moved from Maryland to
Wisconsin after the death of his wife in the summer of 2015 in large part to make himself a less
available target to the vexatious litigation whims of this plaintiff. Defendant learned just
yesterday that Mr. Hoge’s wife, Connie, died of metastatic breast cancer. The loss of his own
wife still fresh in Defendant’s mind, he would urge the Plaintiff to give up this “Captain Ahablike” quest to smear this defendant and others with the taint of wrongdoing. Where this

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Defendant’ss wife died from complications of kidney failure, a very merciful death as far as
deaths go, the plaintiff’s wife must have been in severe pain due to the nature of the cancer that
had metastasized from her breast, on information and belief, to her spinal column. Looking back
at his own situation, this Defendant wishes he had spent more time with his wife when he could
have, instead of being forced to defend himself from baseless allegation and after baseless
allegation made against him by this Plaintiff. While it is too late for Mr. Hoge to spend time with
his wife, it is not too late for him to realize that he is not going to achieve his ultimate goal of
convicting this Defendant of a crime or finding him liable for breach of contract, such contract
which never existed, or for conspiracy to defame via an imaginary conspiracy,
This Defendant avers that he will obey any lawful order of the Court. However, he also
avers that he is finished playing “tit for tat” with this vexatious, vindictive, disturbed individual
who should, instead of pursuing his endless streak of litigation, attend to his family in their grief
following his wife’s death. This defendant has no idea whether or not the Plaintiff loved his wife,
but certainly he has family members who did. He needs, for his own mental well-being, to
consider the damage done to the family, the unnecessary expenditures, the leaving of his dying
wife’s bedside so he could work his judicial nonsense costing the Carroll County taxpayers God
knows how much.
As stated, this Defendant will obey any order of the Court. But he chooses to no longer
be a willing participant in Mr. Hoge’s descent into madness as manifested by his overwhelming
desire to cause harm to his perceived enemies over imaginary wrongs.
CONCLUSION
WHEREFORE, Defendant Schmalfeldt asks the Court to deny the Plaintiff’s motion to
compel him to answer the irrelevant interrogatories. Once again, this Defendant informally asks

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the Court to assess the Plaintiff’s mental and emotional status and then decide whether Mr. Hoge
has any chance at prevailing on the merits of his case.

DATE: November 26, 2016

Respectfully Submitted,

William M. Schmalfeldt, Sr.
3209 S. Lake Dr. Apt. 108
Saint Francis, WI 53235
(414) 249-4379
bschmalfeldt@twc.com
CERTIFICATE OF SERVICE
I certify that on the 26th day of November, 2016, I served copies of the foregoing on the
following persons:
WJJ Hoge III via e-mail as agreed
Brett and Tetyana Kimberlin via e-mail as agreed.

William M. Schmalfeldt, Sr.

AFFADAVIT
I, William M. Schmalfeldt, Sr., solemnly affirm under the penalty of perjury that the
contents of the foregoing filing are true top the best of my knowledge, information and belief.

DATE: November 26, 2016

William M. Schmalfeldt, Sr.

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