INTHE
CIRCUIT COURT OF CARROLL COUNTY
WILLIAM HOGE
Plaintiff,
v. No, 06C16070789
BRETT KIMBERLIN
and
TETYANA KIMBERLIN,
Defendants.
DEFENDANT BRETT AND TETYANA KIMBERLINS’
RULE 2-504.2 STATEMENT
Pursuant to Maryland Rule 2-504.2, Brett and Tetyana
Kimberlin state the following.
(2) A brief statement by each defendant of the facts to be relied on as a
defense to a claim; PLAINTIFF IS A SEXUAL PREDATOR, STALKER AND
HARASSER WHO HAS SPENT YEARS HARASSING THE KIMBERLINS AND
THEIR MINOR DAUGHTER. THEY HAD PROBABLE CAUSE TO FILE
CHARGES AGAINST PLAINTIFF. THEY HAVE LITIGATION PRIVILEGE. RES
JUDICATA AND ESTOPPEL PROHIBIT RELITIGATION OF THE CASE.
(6) Stipulations of fact or, if unable to agree, a statement of matters of which any
party requests an admission; THE KIMBERLINS REQUEST AN ADMISSION
THAT PLAINTIFF IS A SEXUAL PREDATOR, STALKER AND HARASSER.(7) The details of the damage claimed or any other relief sought as of the
date of the pretrial conference; THEY REQUEST IMMEDIATE DISMISSAL
OF THE SUIT.
(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
KIMBERLINS DO NOT COMMUNICATE WITH PLAINTIFF BECAUSE HE HAS.
STALKED AND HARASSED THEM FOR YEARS SO THEY WILL NO AGREE
TO ANYTHING WITH HIM. THE KIMBERLINS HAVE SCORES OF
DOCUMENTS THAT THEY WILL BE INTRODUCING INTO EVIDENCE AND
THOSE HAVE BEEN TURNED OVER TO PLAINTIFF.
(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, Audrey Creighton, Judge Mason, Tetyana
Kimberlin, Brett Kimberlin, Kelsie Kimberlin, Bill Schmalfeldt, Tae Kim, Assistant
State's Attorney Ken Grote, Ken Ashford, 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 thoseexpected to be used solely for impeachment) and a transcript of the
pertinent portions of any deposition testimony that was not taken
stenographically; Possibly Judge Audrey Creighton.
(12) Any other matter that the party wishes to raise at the conference.
péctfully submitted
Tetyana Kimbertin
Certificate of Service
I certify that I served a copy of this motion on Plaintiff ¢h{s 27% day of May, 2017.
Bet , MD 20817
(301) 320 5921
justicejtmp@comcast.net