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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 those expected 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

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