William John Joseph Hoge,

Plaintiff,
v.
Brett Kimberlin, et al.,
Defendants.

IN THE

CIRCUIT COURT FOR CARROLL COUNTY

MARYLAND
Case No. 06-C-16-070789

PLAINTIFFS MOTION TO COMPEL DISCOVERY FROM DEFENDANT SCHMALFELDT

COMES NOW William John Joseph Hoge and moves the Court compel answers
to discovery interrogatories propounded to Defendant Schmalfeldt pursuant to
Maryland Rule 2-432. In support of his motion Mr. Hoge states as follows:
DEFENDANT SCHMALFELDT HAS FAILED TO ANSWER INTERROGATORIES WITH NO
PROTECTIVE ORDER SOUGHT, LET ALONE IN PLACE
On 17 October, 2016, Mr. Hoge propounded a series of interrogatories to
Schmalfeldt. His responses were due on 16 November, 2016. The following day,
Schmalfeldt published via one of his Twitter accounts his intention not to comply in
a timely manner. Following an exchange of emails later on the 17th, Schmalfeldt
agreed to serve his responses on Mr. Hoge.
Mr. Hoge has not been served a copy of a motion for a protective order from
Schmalfeldt, and he cannot find any record of such a motion being filed in the
instant lawsuit or of the Court granting such a motion. However, Schmalfeldt has
failed to answer two interrogatories because he objects to their relevance. The
Court should order Schmalfeldt to comply with the discovery request and fully
answer Mr. Hoges interrogatories.

SCHMALFELDT FAILED TO ANSWER THE FOLLOWING INTERROGATORIES

The two interrogatories which Schmalfeldt failed to answer are intended to
develop evidence related to the allegations in Mr. Hoges Complaint. Also, one of
the interrogatories seeks information related to the identity of Defendants John
Does 3 and 4 and information to allow service of process on Defendants Almighty
Media and Breitbart Unmasked.
This is the first interrogatory Schmalfeldt failed to answer:
7. Identify who (See Intructions (b) and (c)), paid the fees for Tae
Kim to defend you as a respondent to a peace order in 2013.
Answer No. 7
Interrogatory objected to as irrelevant.
This interrogatory seeks to develop information leading to evidence of the
conspiracy alleged in Mr. Hoges Complaint. Thus, this interrogatory is permissible
under Rule 2-402, and Schmalfeldt should be compelled to answer.
This is the second interrogatory Schmalfeldt failed to answer:
8. Identify any person who (See Instructions (b) and (c)) has
exercised either editorial or managerial control over you in
connection with your work as an editor or writer for the website
Breitbart Unmasked, describing the nature of any such persons
supervisory role.
Answer No. 8
Interrogatory objected to as irrelevant.
This interrogatory seeks to develop information leading to evidence of the
conspiracy alleged in Mr. Hoges Complaint and information related to the identity
and whereabouts of other Defendants. None of the information sought is privileged.

Thus, this interrogatory is permissible under Rule 2-402, and Schmalfeldt should be
compelled to answer.
CONCLUSION
WHEREFORE, Mr. Hoge asks the Court to compel Defendant Schmalfeldt to
answer Interrogatories 7 and 8 propounded to him on 17 October, 2016, and to
grant such other relief as the Court may find just and proper.
Date: 18 November, 2016

Respectfully submitted,

William John Joseph Hoge, pro se

20 Ridge Road
Westminster, Maryland 21157
(410) 596-2854
himself@wjjhoge.com

CERTIFICATE OF SERVICE
I certify that on the 18th day of November, 2016, I served copies of the
foregoing on the following persons:
William M. Schmalfeldt by First Class U. S. Mail to 3209 S. Lake Drive, Apt. 108,
St. Francis, Wisconsin 53235
Brett Kimberlin by First Class U. S. Mail to 8100 Beech Tree Road, Bethesda,
Maryland 20817
Tetyana Kimberlin by First Class U. S. Mail to 8100 Beech Tree Road, Bethesda,
Maryland 20817

William John Joseph Hoge

AFFIDAVIT
I, William John Joseph Hoge, solemnly affirm under the penalties of perjury
that the contents of the foregoing paper are true to the best of my knowledge,
information, and belief.
Date: 18 November, 2016
William John Joseph Hoge