CIRCUIT COURT OF CARROLL COUNTY WILLIAM HOGE Plaintiff, ve No. 0616070789 BRETT KIMBERLIN, et al Defendants. DEFENDANT WILIAM M SCHMALFELDT’S RULE 2-504.2 STATEMENT Pursuant to Maryland Rule 2-504.2, William M. Schmalfeldt, Sr. states the following. (2) A brief statement by each defendant of the facts to be relied on as a defense to a claim; PLAINTIFF HAS A FOUR-YEAR HISTORY OF USING THE CARROLL COUNTY AND HOWARD COUNTY COURTS TO HARASS THIS DEFENDANT. HE HAS CAUSED TO BE FILED 367 CRIMINAL COMPLAINTS AGAINST SCHMALFELDT IN THAT TIME, ALL OF WHICH BUT ONE WERE NOLLE PROSS'D. THE ONE THAT WAS PROSECUTED BY THE CARROLL COUNTY STATE'S ATTORNEY RESULTED IN AN ACQUITTAL. THIS PLAINTIFF HAS RELIED ON TRICKERY AND LYING TO HAVE HIS WAY WITH THIS DEFENDANT, ONCE PROMISING WITH A HANDSHAKE THAT HE WOULD NOT PURSUE A PEACE ORDER DENIAL APPEAL, THEN WITHOUT INFORMING SCHMALFELDT WHO DID NOT ATTEND THE HEARING BASED ON HOGE’S WORD, HE APPEARED IN COURT AND WON ANUNCONTESTED PEACE ORDER. THIS PLAINTIFF HAS LIED TO THIS AND OTHER COURTS ON MULTIPLE OCCASIONS. HE IS, IN DEFENDANT'S OPINION, A VEXATIOUS LITIGANT WHO NEEDS TO BE REINED IN BY THIS COURT BEFORE HE CAN INFLICT FURTHER DAMAGE. (6) Stipulations of fact or, if unable to agree, a statement of matters of which any party requests an admission; SCHMALFELDT REQUESTS AN ADMISSION THAT PLAINTIFF IS A VEXATIOUS LITIGANT WHO HAS NO GOOD REASON FOR FILING THE INSTANT SUIT. SCHMALFELDT REQUESTS AN ADMISSION FROM HOGE THAT SCHMALFELDT IS NONE OF THE ENTITIES, OTHER THAN WILLIAM M. SCHMALFELDT, THAT HOGE CLAIMS IN HIS MOTION FOR SUMMARY JUDGMENT. (2) The details of the damage claimed or any other relief sought as of the date of the pretrial conference; SCHMALFELDT REQUESTS IMMEDIATE. DISMISSAL OF THE SUIT, SCHMALFELDT REQUESTS PLAIHTIFF BE DESIGHATED A VEXATIOUS LITIGANT, (8) A listing of the documents and records to be offered in evidence by each party at the trial, other than those expected to be used solely for impeachment, indicating which documents the parties agree may be offered in evidence without the usual authentication and separately identifying those that the party may offer only if the need arises; THE DEFENDANT WILL RELY ON HOGE'S OWN WORDS TO PROVE THE VEXATIOUS NATURE OF HIS ACTIONS, THESE ARE DOCUMENTS THAT ARE ALREADY IN HOGE’S POSSESSION.(9) A listing by each party of the name, address, and telephone number of each non-expert whom the party expects to call as a witness at trial (other than those expected to be used solely for impeachment) separately identifying those whom the party may call only if the need arises; Witnesses will be Aaron Walker, William Hoge, Patrick G. Grady, Sarah Palmer, Eric P, Johnson,, Brett Kimberlin, Tae Kim, Assistant State's Attorney Ken Grote, Mary du Bravo, and Carroll County Circuit Judge Stansfield. (10) A listing by each party of those witnesses whose testimony is expected to be presented by means of a deposition (other than those expected to be used solely for impeachment) and a transcript of the pertinent portions of any deposition testimony that was not taken stenographically: None (12) Any other matter that the party wishes to raise at the conference. Respectfully submitted, tA William M. SchmalfeldtCertificate of Service I certify that I served a copy of this motion on Plaintiff this 27% day of May, 2017. William M. Schmalfeldt Aff ‘Myrtle Beach, NC 29579 Broadwaybill947@outlook.com