IN THE CIRCUIT COURT OF CARROLL COUNTY, MARYLAND WILLIAM HOGE, Plaintiff, v. No, C-16-70789 BRETT KIMBERLIN, et al., Defendants MOTION TO SANCTION PLAINTIFF FOR HARASSING DEFENSE WITNESS Now come Defendants Brett and Tetyana Kimberlin and move this Court to sanction Plaintiff for his direct harassment of Judge Michael Mason for being listed as a witness by Defendants. In the attached letter, Plaintiff Hoge told Judge Mason to take judicial action against Defendants for listing him as a witness. This is an outrageous intrusion into Defendants’ right to call witnesses on their behalf. Plaintiff has no right to ask Judge Mason to take some unspecified action against Defendants for exercising their rights under Maryland Law and the Constitution. Judge Mason will testify that he found Plaintiff to be an uncredible witness on the stand, and that Plaintiff engaged in the same tortious conduct as did Aaron Walker. He will testify that he told Walker to never file any more legal actions in Montgomery County without counsel because his filings were frivolous and malicious. He will testify that a jury in his Court found in favor of Defendants based on the same fact set and legal theory presented by Plaintiff in the instant case. Plaintiff with his unethical letter to Judge Mason is attempting to place the judge ina conflict of interest by asking him to take some type of judicial action against Defendants which would undermine his status as a witness for Defendants.This Court should sanction Plaintiff for this unprecedented attack on Defendants’ rights. Because this misconduct by Plaintiff is so extreme and egregious, Defendants ask this Court to dismiss this case outright. Respectfully subyijtted, Brett Kimberlin| Certificate of Service I certify that I mailed a copy of this answer to vexatious litigant and Plaintiff William Hoge this Wt day of January, 2017. fk Bethesda, MD 20817 justicejtmp@comcast.net (301) 320 5921Hogwash! ieemaeaaeeaee rom Snail Maio 20 Ridge Pi ose West Westrinste, Maryland 21187 Email to himsetf@wijhoge.com (410) 596-2854 23 December, 2016 Hon. Michael Mason Cireuit Court for Montgomery County 50 Maryland Avenue Rockville, Maryland 20850 Dear Judge Mason: Iam sending this letter to inform you that Brett Kimberlin might be contemplating an attempt to call you as a witness in a lawsuit. Tam suing Mr, Kimberlin in the Cireuit Court for Carroll County alleging malicious prosecution and defamation. Hoge v. Kimberlin, et al., Case No. 06- C-16-070789. In an answer to an interrogatory seeking the identity of Kimberlin’s non-expert witnesses, he appears to have identified you as a potential witness. See attachment. Lknow better than to think this suggests any kind of cooperation between you and Mr. Kimberlin. I simply inform you so that you may determine for yourself what steps, if any, you need to take to address this. Very truly yours, ce: Brett Kimberlin encl.CIRCUIT COURT OF CARROLL COUNTY WILLIAM HOGE Piaintiff, ve No, 06C16070789 BRETT KIMBERLIN and ‘TETYANA KIMBERLIN, Defendants. DEFENDANTS’ ANSWERS TO INTERROGATORIES Defendants object to Plaintiffs interrogatories of Brett Kimberlin on the grounds of (1) marital privilege, (2) the discovery is for an improper purpose, (3) it is over burdensome, harassing, irrelevant, annoying and oppressive, and (4) it violates state and federal privacy laws and confidential court approved settlement agreements. 1. Brett, Tetyana and [INI Kimberlin, Aaron Walker, William Hoge, Bill Schmalfeldt, Audrey Creighton, Michael Mason, Kathy Knight. They will all testify that William Hoge stalked, harassed and engaged in a continuous course of insidious, perverted, and depraved conduct towards the Kimberlins. 2 Menai 3. Music videos. . None. no . Irrelevant. 2 ». None. 7. Overbroad. Irrelevant. There are only two complaints mentioned in the complaint.8. Irrelevant. No idea what the interrogatory is asking. 9. Irrelevant. No idea what the interrogatory is asking. 10. Irrelevant, confidential, and overbroad. 11. BLANK 12. BLANK 13. Confidential. Irrelevant. Attorney Client Privilege SIGNED THIS 7 DAY OF December, 2016