bk's opp. to mfl

8/13/2019 BK's Opp. to MFL

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BRETT KIMBERLIN,

Plaintiff,

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF MARYLAND

GREENBELT DIVISION

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v. No. PWG 13 3059

NATIONAL BLOGGERSCLUB, etal

Defendants.

PLAINTIFF'S RESPONSE IN OPPOSITION TO DEFENDANT WALKER'S MOTION

TO EXCEED PAGE LIMIT AND TO STRIKE

Now comes Plaintiff Brett Kimberlin and responds in opposition to Defendant

Aaron Walker's Motion to Exceed Page Limit and his Motion to Strike. In support of

this motion, Plaintiff states (1) the request violates Court rules, (2) Defendant

Walker is not licensed to practice law in the State of Maryland, (3) DeFendant

Walker does not represent any oFthe other DeFendants for whom he asks relieF, and

(4) DeFendant Walker has filed the documents For the improper purpose of

introducing prejudicial and false information into the record so he and others can

post it on the Internet and raise more funds from their readers.

The Pleadings Violate The Court's Rules

1. DeFendant Walker admits that his Response violates Local Rule 105.3, which

limits a Reply to 25 pages. Yet he asks to violate that Rule in essence to"

respond to Plaintiffs Responses to other Defendants' Motions to Dismiss.

2. Defendant Walker requests to exceed the Reply page limit by seven pages (32

pages total in the Reply). But in reality, he is asking to exceed the limit by

vastly more pages because he filed a separate Motion to Strike which is

another 25 pages, and which just continues on where his Reply left off. In

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fact, the relief in that Motion to Strike is to reject Plaintiffs Response and

other pleadings not only for himself but also for other Defendants. Clearly,

this Court should deny Defendant's Walker's blatant attempt to circumvent

the rules.

Defendant Walker Is Not Licensed To Practice In Maryland Courts

3. Defendant Walker submits his pleadings at "Aaron Walker Esq. Va Bar#

48882." However, Defendant Walker is not licensed to practice law in

Maryland.

4. Rule 101 (l)(a) states the following:

1. Who May Appear as Counsel; Who MayAppear Without Counsel

a) Generally. Except as otherwise provided in this Rule and in L.R.112.3 and

28 U.S.C.~ 515, only members of the Bar of this Court may appear as

counsel in civil cases. Individuals who are parties in civil cases may only

represent themselves." (emphasis added).

5. Defendant Walker has not requested to appear pro hac vice and has not

sought local counsel to represent him as required by Local Rule 101 (l)(b)(i).

6. Defendant Walker is using his legal status to file his pleadings without

complying with the Local Rules. Clearly, this Court should only allow

Defendant Walker to proceed pro se, unless he seeks permission to file pro

hac vice and finds local counsel to represent him in that capacity.

7. Ifhe files to proceed pro hac vice, he will have to prove that he is a Member

of the Virginia Bar in good standing, which could be difficult in light of his

unemployed and unemployable status after being terminated from his last

legal position two years ago for anonymously publishing a blog dedicated to

insulting the Prophet Mohammed.

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8. Defendant Walker can represent himself pro se, but he cannot do so as an

attorney unlicensed in the State of Maryland.

Defendant Walker Cannot Represent The Other Defendants

9. Throughout Defendant Walker's latest pleadings, he asks for relief for his co-

defendants. In the Motion to Strike on the first and last pages, he asks the

Court to strike Plaintiffs Responses not only to his Motion to Dismiss, but

also to Defendant DBCapitol Strategies and to The Franklin Center, as well as

a Declaration related to 0 B Capitol Strategies. And throughout that pleading,

he objects to statements and exhibits filed in Plaintiffs Responses to other

Defendants.

10. In Defendant Walker's Reply, he repeatedly asks the Court to dismiss the

complaint for "all parties." Reply at 1 and 31.

11. As noted above, Defendant Walker cannot represent others in Maryland

because he is not licensed to practice in Maryland courts. Moreover, many of

the other Defendants are represented by their own lawyers in this case and

have not given Defendant Walker permission to represent them.

Defendant Walkers Pleadings Are Done For An Improper Purpose

12. Defendant Walker has spent the past 30 months stalking, harassing,

defaming, suing and harming Plaintiffin every possible way. His latest

pleadings are more of the same, and show just why Plaintiff brought this

Complaint Defendant Walker is a bully in every sense of the word. He

admittedly suffers multiple psychiatric handicaps and has let his obsessive

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personality latch on to Plaintiff in the same way other compulsive stalkers

dangerously fixate on targets.

13. Defendant Walker acts as though Plaintiff must wear a Scarlett Letter on his

forehead for life and must be attacked mercilessly until he is imprisoned,

ostracized or killed. That Scarlett Letter is dated 1979 and before in the form

of a conviction and prison sentence. Defendant Walker believes it is his call

in life to protect the world from Plaintiff and to do so at all cost According to

Defendant Walker, Plaintiff has no right to live his life without harassment

and fear from reprisals. Defendant Walker has spent the past two plus years

depriving Plaintiff of humanity with his constant sick and twisted false

narratives. His perverted justifications for this daily bullying of Plaintiff are

similar to those used by others to bully vulnerable students at school for

making mistakes, to torture a gay man in Wyoming and leave him tied to a

fence post to die, to hang blacks in the South, and to burn witches in New

England. Defendant Walker believes in whipping up the mob with false

narratives in the hope that the mob will constantly pillory Plaintiff, turn

vigilante and destroy Plaintiff. Therefore, he increasingly escalates with

more and more vile allegations and then publishes articles with comments

about his guns and how he will use them to protect himself and others from

Plaintiff.

14. Defendant Walker has used his latest pleadings to make more defamatory

allegations against Plaintiff in order to whip up his readers to engage in

vigilante action against Plaintiff. He filed these pleadings so he could publish

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yet more articles on his blog accusing Plaintiff of more imagined crimes. See

Exhibit A,entitled, "Convicted Document-Forger Brett Kimberlin's Fraud On

The Court," dated February 6, 2014. And of course, Defendant Walker asks

his readers to "get out the popcorn" and to send him money so he can rid the

world of Plaintiff once and for all. ld.

15. Every legal pleading that Defendant Walker has filed against Plaintiff over

the past 26 months has been denied, dismissed, nolle prossed, or ignored by

a dozen judges, prosecutors and other law enforcement officials. Defendant

Walker in virtually every filing has bullied Plaintiff for 3S year-old crimes.

He has filed literally thousands of pages of pleadings and exhibits in his sick

attempt to persuade one person in an official capacity to accept his warped

view of reality. And he has failed in every instance. Plaintiffthoughtthat

Defendant Walker would get the message 16 months ago when Judge Motz

and Judge Potter excoriated him for filing malicious pleadings against

Plaintiff. As Judge Potter said: "The Court finds that the complaint is not well

grounded in fact, it's not warranted by existing law, and it's imposed for an

improper purpose ...."

Wherefore, for all the above reasons, Plaintiff moves this Court to deny Defendant

Walker's Motion to Exceed Page Limit, along with his underlying Reply and Motion

to Strike.

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Respect

Brett Kim

8100 Beech ree RdBethesda, MD20817

(301) 320 5921justicejtmp@comcastnet

Certificate of Service

I certify that I mailed a copy of this motion to Defendants Walker, McCain

and Hoge and to Attorney James Skyles, and emailed a copy to Defendant

Stranahan, Michael Smith, Mark Bailen, Ron Coleman this 11th day of

February, 2014.

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211012014

II

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Allergic to Bull: Convicted DocUI1lent.rorger Brett Kimberlin's Fraud on the Court

.' ,

THE BREIT KIMBERLIN SAGA:

Follow this linkto my BLOCKBUSTERSTORYof how Brett Kimberlin, a convicted terrorist and

peljurer, attempted to frame me for a crime, and then got me arrested for blogging when I exposedthat misconduct to the world. That sounds like an incredible claim, but I provide primary documents

and video evidence proving that he did this. And if you are moved by this story to provide a little help

to myself and other victims of Mr. Kimberlin's intimidation, such as Robert Stacy McCain,you can

donate at the PaypaJ buttons on the right. And I thank everyone who has done so, and will do so.

THURSDAY, FEBRUARY 6,2014

Convicted Document-Forger Brett Kimberlin's Fraudon the Court

Thisis the latest post in what I half-jokingly callThe Kimberlin Saga@. If you are

new to the story, that's okay! Not everyone reads my blog. Theshort version is that

Kimberlin has been harassing mefor over a year, his worst conduct being when he

attempted toframe me for a crime. I recognize that this might sound like an

incredible claim, but I provide video and documentary evidence of that fact; in

other words, you don't have to believe my word. You only have to believeyour eyes.

So,ifyou are new to the story, go to this page and you71 be able to catch up on what

has been happening.

Well, dear reader, in the last post I said that I wasn't going to blog until I got a little

more under my belt in terms of the RICO case, and so we have some catching up to

do. This will be the first in a series where I present to you various filings that have

occurred in this case, in this case by Michelle Malkin and the non-party Twitchy.

And 1 can almost hear you, dear reader. "Wait a minute," you might say, "I thought

T\\itchy was being sued, too? Since when are they a 'non-party.'" Well, I will let the

http://allergic2bu1l.blogspolcoml2014102/comicted-document.forger- bre lthtml 1

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2/1012014 Allergic to Bull:Com"icted Document-lbrgcr BrettKimberlin's rnud on the Court

able Mr. Smith explain it to you, below the fold in his

memorandum in support of their motion to dismiss:

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bk's opp. to mfl

Documents