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 KIMBERLIN'S REPLY TO PLAINTIFF'S OPPOSITION TO MOTION TO STAY DISCOVERY Now come Defendants Brett and Tetyana Kimberlin and reply to Plaintiffs Opposition to their Motion to Stay Discovery. 1. Plaintiff makes assertions about the Walker v. Kimberlin case which he is not qualified to do and in fact he was not even present during the trial except when he testified and during final argument. Judge Mason excluded him from the Courtroom because he was a witness so he cannot advise this Court what happened. 2. Defendants were present when Judge Mason specifically instructed the jurors that they were required under Maryland law to list only the statements in the criminal complaints that were false on the special verdict form. Anything not listed would be considered true as far as probable cause was concerned. 3. Plaintiff wants this Court to believe that the jury was required to make specific findings as to what was true rather than what was false. But that is not what happened. In fact, once the jury returned its verdict finding only a few words out of thousands false, Judge Mason considered the remaining information in the Complaints true, which included all the information about Plaintiff Hoge, anddetermined that that remaining information provided overwhelming probable cause to support the issuance of the criminal charges. 4, Defendants’ Motion to Stay Discovery is tantamount to a Motion for a Protective Order. They should not be harassed with discovery after a jury has found in their favor based on the same factual issues and legal claims. In fact, since Plaintiff is a party in privity, he is barred by res judicata from even continuing this lawsuit against Defendants. Wherefore, Defendants will not be participating in discovery in this case unless specifically ordered to by this Court after a denial of their Motion for Summary Judgment. Respedtfully.submitted, Bethesda, MD 20817 (301) 320 5921. justicejtmp@comcast.net Ai Brett Kitmberlin Teepe i: L t CERTIFICATE OF SERVICE I certify that I sent this motion to Plaintiff this “es 2016. hein Bethesda, MD 208: (301) 3205921 justicejtmp@comcast.net