IN THE CIRCUIT COURT OF CARROLL COUNTY, MARYLAND WILLIAM HOGE, Plaintiff, ve No. C-16-70789 BRETT KIMBERLIN, et al., Defendants DEFENDANT BRETT AND TETYANA KIMBERLIN’S REPLY TO PLAINTIFF'S OPPOSITION TO THEIR MOTION FOR SANCTIONS Now come Defendants Brett and Tetyana Kimberlin and reply to Plaintifs Opposition to their Motion For Sanctions. 1. Plaintiff wants to hide behind the First Amendment to justify his harassment of Defendants, other Parties, and witnesses. It does not work that way. As the Supreme Court just held last week in Goodyear Tire & Rubber Co. v. Haeger et al, (April 18,2017); Federal courts possess certain “inherent powers,” not conferred by rule or statute, “to manage their own affairs so as to achieve the orderly and expeditious disposition of cases.” Link v. Wabash R. Co,, 370 U.S. 626, 630— 631 (1962). That authority includes “the ability to fashion an appropriate sanction for conduct which abuses the judicial process.” Chambers v, NASCO, Inc, 501 U. S. 32, 44-45 (1991). This Court, like federal courts, has the authority and obligation to manage the affairs in its court and stop abuses of the judicial system. 2. Plaintiff admits that he publishes blog posts every day filled with vicious attacks on the Parties. He admits that he has targeted Defendant Schmalfeldt, and in his Opposition falsely blames Schmalfeldt for slashing his own tires. He admits that he publishes all the pleadings in this case online, which results in this case being tried in the court of his readers’ opinions where it will gin up those readers. Headmits that he has dehumanized and demonized Defendant Schmalfeldt and the other parties in this case, and continues to do so in his Opposition. He admits that he improperly contacted Judge Mason and told him to “lawyer up” because Defendants listed the judge as a witness in this case. He admits that the intimidation of witnesses can result in criminal charges in Maryland and the Federal courts. He admits that he has misused discovery by sharing Defendant Schmalfeldt’s address so one of his minions could post his address online with a photo of his home and the next day slash his tires. 3. Defendants are so sick and tired of Plaintiff's sanctimonious statements and harassing behavior. He isa classic stalker, like the kind caught hiding behind the bushes at the residence of a Hollywood actress only to tell the police that the actress is secretly in love with him and has been corresponding with him to set up the secret rendezvous. He is dangerous because he really believes he is the archangel staying the evil defendants, and that everything he and his minions do is justified by his religious convictions. 4. Why is this Court allowing this monstrosity to continue? The Court must control its courtroom. Plaintiff can either try his case in the court of blog-post opinion or he can try it in this Court. This Court cannot allow Plaintiff to use discovery to harass the parties, and to learn information that he then uses to incite violence and intimidation against the Parties and witnesses. This Court cannot pretend that this is not happening or that Plaintiff has a First Amendment right to do what he is doing. This Court has the power and obligation to bring the hammer down on Plaintiff once and for all.5. This Court can no longer pretend that this case is not being directed and managed by attorney Aaron Walker, who is writing the motions for Plaintiff in order to collaterally attack the judgment against Walker in October. Plaintiff and Walker want to cause Defendants as much harassment and intimidation as possible, and this Court's inaction is enabling and allowing that misconduct and abuse. 6. Defendant Schmalfeldt has filed the motion Plaintiff mocks in his Opposition. Noyseq ne: 1242/0 Fie vace: 04/27/2017 envered vave:04/27/20870ecision: Defendantrarty H2.:4 ‘Motion for Plaintiff to Show Cause as to why he should not be held in contempt Of court for inciting violence, harassment and occasioning the vandalism of Defendant's property That motion is supported with a vast amount of evidence of harassment, intimidation, criminal conduct and stalking by Hoge and those he intentionally incites, directs and manages. ‘Wherefore, Defendants ask this Court to sanction Plaintiff in the harshest way possible, including terminating this litigation. Brett Kimberlin Justicejtmp@comcast.net (301) 320 $921 Certificate of Service I served a copy of this motion on Plaintiff this 28% day of April, 2017 by US Mail. Brett Kimbey