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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

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