IN lHE CIRCUIT COURT FOR MONTGOMERY COUNTY, MARYLAND

BREIT KIMBERL
Plaintiff,
Case o. V 339254
SETH AlLEN Aka
ANO OUS CYBER STALKER,
SOCRATES,
PREPOSTERlCITY
D VE FRO QUEENS2,
Defendant.
PLAINTIFF'S RESPO SE TO JOHN DOE AARON WORTHING'S EMERGENCY
REQUEST TO SEAL PLAINTIFF'S MOTION
ow comes Plaintiff, Brett and responds to John Doe Aaron Worthing's
Emergency Motion to Seal Plaintiff's Motion to Unseal.
1. Mr. Worthing has no legal basis to eal Plaint.ifPs motions in this case. He is not a
co ert Go emment agent and in fact does not e en work for the Go emment
Instead, he is a lawyer from Virginia who hates Muslims to such a degree that be
started a blog asking people to submit derogatory depictions of the Prophet
Mohammed. He has posted hundreds of such depictions on that blog and
repeatedly stated that he wants his blog to offend Muslims and that moderate
Muslims that are hanned or offended are . collateral"' damage from an
religion.
2. Mr. Worthing published a book this month c-al1ed "Archangel which amounts to
a direct assault on Muslims. worldwide. It is an alternative history of September
II, 2001 in which a superhero appears and kills all the Muslims including the
female Muslim "bitches" andjihadist ''\; hores. '
3. Mr. Worthing publishes another blog called Allergic to Bull in \ hich he stated
that he is not afraid of Muslims ho take offense his Muslim bating blog. In fact,
he brags about the death threats and taunts Muslims to make him ~ f a t w a h worth
J
."
Here are two such taunts of his:
Come on bitches. Aaron Worthing, Mana sas Virginia. But if 'ou bring it, be
ready: w-e practice the Second Amendment here.... ' Exhibit A
"if terrorists are going to get mad or kill an one, come at me. I till insult OUT
prophet on a regular basis and will continue to do so until tbis ort of thing stops
getting a violent response. And is blog is mine. So if ou are feeling like
beheading someone. I'm right here. Aaron Worthing of Manassas, Virginia,
bitches.' Exhibit B
4. PIaintiffhas no desire to see Mr. Worthing harmed b anyone and in fact Plaintiff
wrote to all rele ant la\ enforcement authorities in Mr. Worthing s jurisdiction
notifying them that since Mr. Worthing stated in his motion that he was afraid for
his life, they should de elop a plan to protect him. Exhibit C
5. Prior to filing the motion identifying Mr. Worthing, Plaintiff sent Mr. Worthing's
attorney an offer to settle the issues relating to Mr. Worthing s identity and
informed ber that if the offer was not accepted or dealt with in good faith, Plaintiff
would fIle the motion. Exhibit D. Mr. orthing responded to the offer by
publici posting a confidential email Plaintiff had written to his attorney and that
post mocked, insulted and ridiculed Plaintiff Clearly, Mr. Walker cared more
about scoring points on his blog than protecting his identity.
6. Mr. Worthing continues to publish the very motions he asked this Court to seal
relating to Plaintiff (and which the Court did seal) while he complains that
Plaintiffs response should remain sealed Therefore, he has waived an legitimate
argument for insisting on sealing the latest motion.
7. Mr. Worthing is a public figure by choice, publishing contro ersial blogs, making
radio appearances, writing articles and publishing letter he has sent to
go erument agencies. There is a presumption against sealing documents filed by
public figures in civil tort matters.
8. Mr. Worthing has maintained his public persona as Aaron orthing, AJW, and
AW. He made claims that he was in fact Mr. Worthing until people began
blogging that there is not an attome named Aaron Worthing in any legal
databases. Mr. Worthing has also maintained that he is an attome and often gave
legal ad ice to people who had been under the assumption that be ,"\'as in fact an
attorney named Aaron Worthing.
9. Mr. Worthing has already been identified on Twitter by veteranjournaJist and
news magazine editor Ron Bryneart, thereby negating an argument b_ Mr.
Worthing for shielding his identity.
10. Mr. Worthing complains that Plaintiffs original motion identifying him contained
personal information such as his high school his LSAT problems, his colleges,
and his employer. Hov ever, Mr. Worthing himself has blogged about all of these
things on his own blog. See Exhibits E-G.
11. Plaintiff i WIder DO obligation public or pri ate to keep Mr. Worthing's name a
secret. There is no gag order on Plaintiff nor would there be an legal basis for
such a gag order. There is no tatute that prohibits Plaintiff from disclosing to
anyone public or priyate what he knows about Mr. Worthing s identi . Thus
nothing as improper about including in the motion his true name or where he
Ii ed or oded or where he went to high school or college.
12. Mr. Worthing' eiled threat that an. disclosure by Plaintiff of his identity would
violate Virginia's terrorism statute is without merit Mr. Worthing, by choice,
published his uslim hating blog and urged Muslim' bnches ' to come get him, to
behead bim and to make him fatwab orthy. He said that he would respond with
"Second Amendment" rights, meaning that he ould use lethal force against an.
Muslim's Nbo targeted him. Clearly, it is Mr. Worthing ho appeal5 to be
inciting terrorism by antagonizing Muslims taunting them and urging them to
corne get him so he can kill them.
13. Mr. Worthing has a current acti e criminal case against him in the Montgomery
COUll Distri t Court from his second-degree assault against Plaintiff as he exited
the Court on January 9, 20] 2. He is also the respondent in a Peace Order action
that resulted from that assault. This information is also publically a ailable on the
Court docket in Mr. Worthing's real name. IfMr. Worthing was afraid of his
identity being then he should not ha e ph sieal} assaulted Plaintiff.
14. Mr. Worthing is asking this Court to shield him from being identified as the
publisher of a Muslim hate blog when he inserted himself in the present case by
conspiring a known stalker and aided and abetted him after that stalker
threatened to mw'der Plaintiff.
15. Mr. Worthing has stated that Plaintiff wants to use his Court filing as a basis for
identifying Mr. orthing in various venues. This is without merit becau e
Plaintiff does not need an ColD't filings to disclose Mr. Worthing's identity.
Moreo er althou b Plaintiff has known of Mr. Worthin 's true identity for a
month, Plaintiff has not published It in any enue outside oftbe legal process.
WHEREFORE, for all the above reasons, the Court should den Mr. orthing's
Emergenc Motion and issue an order unsealing the documents.
Respectfully submitted
Brett Kimberlin
Certificate of Sen; ice
I certify that I mailed a copy of this motion to Seth Allen and Aaron orthing b
first class mail this 27
lh
day of January 201-.
Brett Kimberlin