IN THE CIRCUIT COURT OF
CARROLL COUNTY, MARYLAND
WILLIAM HOGE,
Plaintiff,
v. No. C-16-70789
BRETT KIMBERLIN, et al.,
Defendants
DEFENDANTS BRETT AND TETYANA’S REPLY RE THEIR MOTION FOR
SANCTIONS
Defendants Brett and Tetyana Kimberlin reply to Plaintiff's opposition to the
Motion for Discovery Sanctions.
1, Plaintiff argues that he should not be sanctioned because he was simply
working as a paralegal for Aaron Walker when he invaded the deposition of Walker,
yet he admits he was at the deposition with his own tape recorder recording the
deposition.
2, Aaron Walker is a big boy and does not need Plaintiff in the room to push a
button ona tape recorder.
3, Judge Mason, when he learned that Plaintiff was attending the second
deposition that day told him to leave because it was improper for him to be there.
4, If Walker had wanted Plaintiff to attend as a paralegal, he was required to
inform the Court and the Defendants but he did not. Instead, Plaintiff simply foisted
himself in on the depositions until the parties called Judge Mason's chambers.
5, Clearly, Plaintiff was attempting to take discovery in violation of this Court's
Order prohibiting discovery.Wherefore, this Court should sanction Plaintiff for his blatant violation of the
discovery order issued by this Court.
Bethesda, MD 20817
(301) 3205921
justicejtmp@comcast.net
Respectfully,
Brett Kitt
Tetyana Kitnberll £ L
omer
CERTIFICATE OF SERVICE
I certify that I sent this motion to Plaintiff this Novembgr 28, 2016.
Brett Cy
‘Bethesda, MD 20817
(301) 320 5921
Justicejtmp@comcast.net