Kimberlin V NBC Res Hoge W M2D (OCR) (Redacted)

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MARYLAND

GREENBELT DIVISION
BRETT KIMBERLIN,
Plaintiff,
v.
NATIONAL BLOGGERS CLUB, etal.,
Defendants
No. PWG 133059
PLAINTIFF'S RESPONSE TO DEFENDANTS HOGE AND WALKER'S MOTIONS TO
DISMISS
Now comes Plaintiff and responds in opposition to Defendants Hoge and Walker's
Motions to Dismiss. The Court must deny a Motion to Dismiss under Rule 12(b)(6)
of the Federal Rules of Civil Procedure unless it II appears beyond doubt that Plaintiff
can prove no set of facts in support of his claim which would entitle him to
relief." Conley v. Gibson, 355 U.S. 41, (1957). liThe question is whether in the light
most favorable to the Plaintiff, and with every doubt resolved in his behalf, the
Complaint states any valid claim for relief." SA Wright & Miller, Federal Practice and
Procedure: Civil 2d 1357, at 336. The Court, when deciding a motion to dismiss,
must consider well-pled allegations in a complaint as true and must construe those
allegations in favor of the plaintiff. Scheuerv. Rhodes, 416 U.S. 232, 236
(1974);jenkinsv. McKeithen, 395 U.S. 411, 421-22 (1969). The Court must further
disregard the contrary allegations of the opposing party. A.S. Abell Co. v. Chen 412
F.2d 712, 715 (4th Cir.1969); Lujan v. National Wildlife Federation, 497 U.S. 871
(1990) ("a complaint should not be dismissed for insufficiency unless it appears to a
certainty that plaintiffis entitled to no relief under any state offacts which could be
proved in support ofthe claim. ") (emphasis added).
1
Maryland's Three-Year Statute of Limitations Applies to Plaintiffs False Light
Invasion of Privacy Claim
1. Defendants argue that Plaintiffs claim of False Light Invasion of Privacy is
barred by Maryland's one year statute oflimitations, and they cite Smith v.
Esquire, 494 F. Supp. 967 (D. Md. 1980), in support of their argument. This is
without merit.
2. In 1988, Maryland's highest Court rejected the reasoning of Smith in Allen v.
Bethlehem Steel Corp., 314 Md. 458 (1988):
We disagree with Smith. What the district court judge said in Smith may be
true, but the Maryland statute of limitations is vividly clear. An action for
libel and slander shall be filed within one year of the date it accrues. Courts
Art. 5-105. Other tort actions shall be filed within three years of the date
they accrue. Courts Art. 5-101. Nowhere in 5-101 does it provide an
exception for "false light" cases. Even though we recognize the district court
judge's view as to how the statute of limitations will be avoided, that
"loophole" must be plugged by the Legislature.
Clearly, Maryland general three-year statute oflimitations applies to the
False Light Invasion of Privacy Claim.
Defendants Have Portrayed Plaintiff In False Light
3. As set forth in the Complaint, Defendants have repeatedly imputed and
stated that Plaintiff is a swatter or involved with swatting. The Defendants
are members of Defendant National Bloggers Club, which continues to state
on its website that Plaintiff is a swatter. Exhibit A. These published
statements are false and portray Plaintiffin false light. Aplaintiff may prove a
claim of false light invasion of privacy by showing: (1) that the defendant
gave publicity to a matter that places the plaintiff before the public in a false
light; (2) that a reasonable person would find that the false light in which the
2
other person was placed highly offensive to a reasonable person; and (3) that
the defendant had knowledge of or acted with reckless disregard as to the
falsity of the publicized matter and the false light in which the defendant
placed the plaintiff. Bagwell v. Pennisula Regional Medical Center, 665 A,2d
297 (1995).
4. Clearly, Plaintiff has properly alleged a false light invasion of privacy claim.
Plaintiffs Defamation Claimis Not Barred By Maryland's One-Year
Statute of Limitations
5. Defendants argue that Maryland's one-year statute of limitations bars
Plaintiffs defamation claim because "all alleged statements by Mr. Hoge were
made more than one year before filing of the instant suit." Hoge at 11. See
also Walker at 41. These arguments are without merit for a multitude of
reasons.
6. On June 8, 2012, Defendant Hoge wrote a letter and published it on his blog
stating that Plaintiff was a swatter who should be investigated and put in
prison. Complaint at 28. Defendant Walker on his personal blog and on his
personal Twitter account has repeatedly stated and imputed that Plaintiff
swatted him. Complaint 16 et seq.
7. These publications were part of a campaign that continues to this day to
falsely accuse Plaintiff of crimes in order to harm him and raise money for
the Defendants. This campaign constitutes discrete acts by and a conspiracy
among the Defendants, and the overt acts of this conspiracy accusing Plaintiff
of swattings did not stop on June 8, 2012. In fact, Defendant Ali Akbar, on
behalf of Defendant National Bloggers Club of which Defendants Hoge and
3
Walker are members, stated on his blog on October 14, 2013, that Plaintiff
was responsible for the swattings. Exhibit A. Defendant Akbar uses that blog
to raise funds for Defendants Hoge and Walker and other bloggers to pay for
legal costs in this case involving Plaintiff. Exhibit A. Defendants Hoge and
Walker, in turn, ask readers on their blogs and on Twitter accounts to donate
to the National Bloggers Club. Therefore, Defendants Hoge and Walker, as
members of the National Bloggers Club, which continues to raise money
based on false assertions of Plaintiffs involvement in swatting, defamed
Plaintiff as a swatter as late as October 14, 2013, well within the one-year
statute of limitations.
8. Since Plaintiff has alleged a conspiracy in this case, the statute of limitations
does not begin until the last overt act of the conspiracy. ShessJer v. Keck, 271
P.2d 588, 292 (2d Dist. CA 1954) ("where the complaint alleges that all the
allegedly libelous acts were committed pursuant to a conspiracy formed by
the defendants, the statute of limitations does not commence to run against
any of the libelous acts until commission of the last over act done in
furtherance of the conspiracy.") The conspiracyalleged by Plaintiff is a
continuing one that has not yet ceased.
9. Moreover, the statute of limitations does not apply because the Defendants
were responsible for causing threats to Plaintiff of death and harm if he went
to court or contacted the authorities. See Complaint at 12. Defendant Hoge
took these threats even further by twice filing false criminal charges against
Plaintiff in February and March 2013, which were nolle prossed, and then
4
filing a false Peace Order against Plaintiff in March 2013, which was denied
and which he then appealed in May 2013, and that was also denied. Exhibit
B. Defendant Walker attempted to file criminal charges against Plaintiff in
Howard County on or about March 13, 2013 and when that was rejected, he
filed a Peace Order on the same day, which was also rejected. Exhibit C. These
false charges were intended to instill fear in Plaintiff and did intimidate
Plaintiff not to seek redress. Defendant Walker also filed two malicious civil
suits against Plaintiff in 2012, which were intended to stop him from seeking
redress. In fact, in Walkerv. Kimberlin et aI, 12-CV-01852-JFM, filed in this
Court, Defendant Walker asked the Court to prohibit filing any suits or
pleadings in court unless first getting permission from a court appointed
administrative law judge.
10. Defendants Hoge and Walker continue to intimidate Plaintiff every day of the
week and raise money based on their exploitation of their false narratives. In
fact, they filed motions in this case to require Plaintiff to file all pleadings
under oath so they could file more harassing criminal charges against
Plaintiff based on their delusional conclusions of perjury. This Court properly
denied those motions on December 30, 2013. They write at least one daily
post on their blogs about Plaintiff and send hundreds if not thousands of
tweets a month about Plaintiff filled with all sorts of intimidating language,
graphics, and threats of imprisonment and doom. All of these are
accompanied by a donate button to help them raise money to target Plaintiff.
See e.g., Exhibits Dand E. Many of these posts accuse Plaintiff of crimes and
5
discuss every nuance of every pleading filed by Plaintiff with commentary
that Plaintiff will be jailed or sanctioned by this judge or that judge. Id. The
purpose for these threats and intimidation tactics is to chill Plaintiffs right to
redress.
11. It is well established that the statute oflimitations can be tolled where the
defendant engages in conduct that threatens or intimidates a party against
seeking redress. In such a case, the defendant is estopped from relying on
the statute of limitations until after the intimidating or threatening behavior
ceases. Cf. Murphy v. Merzbacher, 346 Md. 525, 532, 697 A.2d 861 (1997).
12. Clearly Plaintiff has brought this defamation claim within one year of
Defendant Hoge and Walker's defamation and intimidation tactics, and
therefore there is no statute of limitations bar to Plaintiffs defamation claim.
Plaintiffs Has Established All The Elements Of Defamation
13. Adefamatory statement is one which tends to expose a person to public
scorn, hatred, contempt or ridicule, thereby discouraging others in the
community from having a good opinion of, or from associating or dealing
with, that person.
"To recover for defamation under Maryland law, a plaintiff must establish
that: (1) the defendant made a defamatory statement regarding the plaintiff
to a third person; (2) the statement was false; (3) the defendant was legally
at fault in making the statement; and (4) the plaintiff suffered harm thereby."
Holt v.Camus, 128 F. Supp. 2d 812, 815 (D. Md. 1999).
14. Defendants Hoge and Walker argue that Plaintiff is defamation proof because
(1) he was convicted of a crime that occurred in 1979 and (2) is a public
figure. These arguments are without merit.
6
15. The Defendants, through their various frivolous lawsuits, Peace Orders and
criminal charges against Plaintiff, have been trying to get a judge, any judge,
to rule that Plaintiff is a public figure. On each and every occasion, this
argument has failed. In fact, when Defendant Walker filed a motion for such
a finding in another defamation case brought by Plaintiff, Kimberlin v. Allen,
Montgomery County Circuit Court #339254, which resulted in a favorable
judgment for Plaintiff, Judge Quirk denied the motion on February 2,2012.
Defendant Walker made the same argument in a civil case in Prince William
County Virginia but the judge implicitly rejected it when he excoriated
Walker for filing a frivolous and malicious suit against Plaintiff. The judge
dismissed that case on December 4,2012. See Exhibit F. Now Defendants
Hoge and Walker are making the same argument that has been repeatedly
rejected by other courts.
Docket Date:
Docket
Description:
Docket Type:
Ruling Judge:
Reference
Docket(s):
Docket Text:
02/09/2012 Docket Number: 140
ORDER, FOR APPROPRIATE RELIEF
Ruling Filed By: Court Status: Denied
QUIRK, JOSEPH M
Motion: 119
ORDER OF COURT (QUIRK, J.) THAT DEFENDANT'S MOTION TO DECLARE BRETT
KIMBERLIN AS A PUBLIC FIGURE RATHER THAT PRIVATE CITIZEN (D.E. #119) IS
DENIED, ENTERED. (COPIES MAILED)
16. Plaintiff is the Director of a Maryland based non-profit that works with
famous bands and artists to inspire youth to get involved with civic
participation. In that capacity, Plaintiff has an impeccable reputation. Yet
Defendants Hoge and Walker and the other Defendants spend thousands of
7
hours each year, with tens of thousands ofblog posts, tweets, and frivolous
court filings trying to destroy Plaintiffs livelihood with false allegations of
crimes, such as swattings.
17. Defendants Hoge and Walker and the other Defendants have acted with
extreme malice in their defamatory conduct. They have created a cottage
industry with their false narratives against Plaintiff, lining their pockets with
tens of thousands in donations, increasing their web ranking on Internet
search engines, and inciting their readers to hate Plaintiff, to attack him, to
stalk him, and to harass him, his family and anyone, including judges,
prosecutors and reporters, who supports him or rejects their false narratives.
In fact, Defendants Hoge and Walker were the creators of a campaign against
the Howard County Prosecutors which resulted in weeks of threats and
harassment to that office simply because they would not prosecute Plaintiff
and others for the false crimes concocted by Hoge and some of the other
Defendants. Exhibit G. Clearly, Defendants Hoge and Walker and the other
Defendants acted with reckless disregard for the truth in falsely stating and
publishing that Plaintiff was a swatter or was involved with swattings. New
York Times Co. v. Sullivan, 376 US 254 (1964).
Plaintiff Has Properly Alleged Violation of RICO and Conspiracy to
Violate RICO
18. Defendants Hoge and Walker argue that Plaintiff has not alleged two
predicate acts or the existence of a RICO Enterprise. These arguments are
without merit.
8
19. The National Bloggers Club ("NBC), an organization of which Defendants
Hoge and Walker are members, has publicly stated that it is a 501(c)(3) non-
profit which accepts tax-deductible donations. Exhibit H. This is false
because it has neither applied for nor been granted 501(c) (3) status by the
Internal Revenue Service. Exhibit 1.
20. NBC has raised more than $10,000 in donations as a result of its fraudulent
representations. That money has been sent to NBC by mail and by
wire/Internet across state lines. As such, NBC engaged in wire fraud and
mail fraud under 18 USC 1341 and 1343. NBC received scores ifnot
hundreds of donations in this way, and each donation constitutes a separate
predicate act under RICO. Wang Laboratories v. Burt} 612 F.Supp. 441
(D.Md.1984) (each act is a separate offense under RICO even if there is but
one scheme involved).
21. On information and belief, NBC deposited the funds it received from its
fraudulent fundraising scheme into a federally insured bank(s), and
laundered them for the purposes of its members in violation of 18 USC 1957.
Again, each financial transaction constitutes a predicate act under RICO.
22. The Defendants, including Defendants Hoge and Walker, knew that NBC was
fraudulently raising funds when media reports in May 2012 identified NBC
President and Defendant Ali Akbar as a convicted felon from the State of
Texas. Those media reports disclosed that NBC had never applied for or
received SOl(c)(3) status from the IRS. ExhibitJ. Some of those media
9
reports demanded that NBC and Defendant Akbar disclose the IRS approval,
but that disclosure never occurred because there was no IRS approval. Id.
23. Once Defendant Akbar was exposed as a felon and huckster, the Defendants
continued to raise funds through another Defendant, DB Capitol Strategies,
which falsely published on its website that Plaintiffwas involved with
swatting conservative bloggers. See Response to DBCS' Motion to Dismiss.
Dan Backer and DBCS had been connected to Defendant Akbar for several years,
and had been paying Defendant Akbar's Vice & Victory Agency for political
messaging, website development, and other things, dating back two years. See
FEC Expenditures at Exhibit K. This fact alone implies guilty knowledge by
the Defendants that raising funds through NBC while falsely portraying it as a
501(c) (3) was illegal and constituted fraud.
24. As demonstrated in great detail in Plaintiffs Response to Defendant DB
Capitol Strategies' Motion to Dismiss, it, through its attorney Dan Backer,
then filed a malicious and frivolous lawsuit in this Court against Plaintiff and
two non-profits with which he is involved requesting that this Court prohibit
Plaintiff from filing any pleadings in Montgomery County Courts without first
getting permission from a federal administrative judge. Walker v. Kimberlin,
JFM 12-1852 (Nov. 28,2012). Judge Motz dismissed that case out of hand
but not before Defendant DB Capitol Strategies (1) tried to get Plaintiff fired
from his non-profit job in return for dismissing the non-profits from the suit,
and, when that did not work, and (2) issued a document hold to a foundation
that funded those non-profits falsely asserting that Plaintiff and the non-
10
profits were engaged in criminal activity. These actions by Defendant DB
Capitol Strategies constituted attempted extortion under 18 USC 1951. In
essence, Defendant DB Capitol on behalf of Defendant Walker said: "fire
Plaintiff or we will destroy the funding base of the non-profits." And when
Plaintiff was not fired, they followed through with their threat by sending a
document hold letter laced with false allegations of criminal activity by
Plaintiff and the non-profits to the non-profit's largest institutional funder.
And that funder in turn ceased funding the non-profit. This not only
demonstrates extortion, but it also meets the injury to property or business
requirement of 18 USC 1964.
25. This conduct by Defendant DB Capitol Strategies, on behalf of Defendant
Walker, also violates 18 USC 1513(e) because it was meant to retaliate
against Plaintiff for providing information to state and federal law
enforcement about the conduct of the Defendants. Indeed, both Defendants
Walker and Frey complained bitterly that Plaintiff was "fucking" with them,
Exhibit T, when all Plaintiff ever did was provide information to law
enforcement officials and the Courts about their conduct. Section 1513(e)
provides as follows:
(e) Whoever knowingly, with the intent to retaliate, takes any action harmful
to any person} including inteiference with the lawful employment or livelihood
ofany person, for providing to a law enforcement officer any truthful
information relating to the commission or possible commission of any
Federal offense, shall be fined under this title or imprisoned not more than
10 years, or both. (emphasis added).
11
26. Defendants Hoge and Walker assert that the obstruction of justice claims
cannot be predicate acts because there was no "official proceeding" pending
involving Plaintiff. However, there were official proceedings as well as
federal involvement. First, the swattings occurred across state lines, which
therefore brought them under the jurisdiction of federal law enforcement.
Second, the FBI was investigating the swattings and in fact came
unannounced to Plaintiffs home to interview him about the swattings. Third,
87 Congress Members and at least one US Senator wrote letters to the
Attorney General requesting a federal criminal investigation. Exhibit L. And
fourth, Congress Members raised the issue of swatting on the floor of the
House on at least one occasion. Therefore, the Defendants' actions are also
prohibited by 18 USC 1512(b), which includes engaging "in misleading
conduct toward another person, with intent to influence, delay, or prevent
the testimony of any person in an official proceeding, which includes ita
proceeding before Congress." They also violated section 1512(d) by
harassing Plaintiff for years so he would not seek redress in federal courts or
talk to federal law enforcement officials.
27. The Defendants falsely told the FBI, Senators and Congress Members that
Plaintiff was involved with the swattings and then intimidated Plaintiff by
engaging in conduct that resulted in him being repeatedly threatened not to
appear in court or talk to law enforcement officials. They sued, harassed,
stalked, threatened him with prison, with job loss and caused death threats
against him for seeking redress. Defendant Walker assaulted him in the
12
Montgomery County Circuit Courthouse so severely that he had to go to the
Emergency Room at Suburban Hospital, where he was treated and given
medicine for contusion to the eye, pain and dizziness. And when Plaintiff
contacted the police about the assault, Defendant Walker created the false
narratives and conceived the National Bloggers Campaign against Plaintiff in
retaliation for seeking redress and the administration of justice. All of this
constitutes obstruction of justice and retaliation under the "Omnibus Clause"
of 18 USC 1503, which states:
Whoever ... corruptly or by threats orforce, or by any threatening letter or
communication, influences, obstructs, or impedes, or endeavors to influence,
obstruct, or impede, the due administration ofjustice, shall be fined not more
than $5,000 or imprisoned not more than five years, or both." (emphasis
added).
28. The Defendants also engaged in a conspiracy to threaten, assault and
intimidate Plaintiff and therefore their conduct is prohibited by 18 USC
1512(k).
29. All of these obstruction of justice statutes constitute predicate acts under
RICO.
Plaintiff Properly Alleged the Existence ofa RICO Enterprise
30. Plaintiff has alleged in the Complaint that the National Bloggers Club is a
fraudulent Enterprise because it falsely portrays itselfas a 501(c)(3) non-
profit when it is not. It raises money based on that fraudulent representation
and it uses false accusations of criminal activity by Plaintiffto fleece people
out of money to run its fraudulent activities. It engages in wire and mail
fraud, as well as money laundering.
13
31. Most ofthe Defendants are members of, paid by or otherwise involved with
the National Bloggers Club in some fashion. Defendant Ali Akbar is the boss,
Patrick Frey is the consigIiore, DB Capitol Strategies is the legal muscle, and
various other Defendants are the lynch mob, taking orders from Defendants
Akbar and Frey to harass Plaintiff through various means such as physical
assault, stalking, malicious legal filings, and false allegations online.
32. Most of the Defendants have been or are involved with a common scheme to
harm Plaintiff with false narratives of crimes in order to raise funds, increase
their ranking on Internet search engines, and incite their readers to act in
some harmful way against Plaintiff and his employer.
33. The Defendants have conspired with one another in their common purpose
through a course of conduct, which has lasted for more than two years,
involving scores of predicate acts and intent to violate the laws of the United
States and the rights of Plaintiff. The Complaint sets forth in great detail that
the Defendants have both a formal and informal framework, with daily and
sometimes hourly contact through various networks, mainly through the
Internet, for carrying out its objectives. The Defendants function as a
continuing unit to achieve the common purpose of harming Plaintiff in every
and any way possible. This clearly satisfies the RICO Enterprise requirement.
Boyle v. United States, 556 U.S. 938 (2009).
34.18 U.S.c. 1961(1) defines "racketeering activity" to include "any act or
threat involving ... extortion ... [or] any act which is indictable under any of
the following provisions of Title 18, United States Code: ... section 1341
14
(relating to mail fraud), section 1343 (relating to wire fraud) .... " The
Complaint clearly alleges more than two acts in furtherance of the conspiracy
that may be in violation of the mail and wire fraud statutes. Additionally, the
Complaint alleges acts of extortion and money laundering which are "acts"
included in the definition of "racketeering activity." The Complaint alleges
other predicate acts including obstruction acts. These acts were done in
order to injure Plaintiff, his property, his livelihood and his employer.
35. In order for a plaintiff to have standing to bring a RICO claim, he must allege
an "injury in his business or property" by reason of a violation of RICO. 18
U.S.c. 1964(c). In Wang Laboratories v. Burt, 612 F.Supp. 441 (1984),
this Court found that "Wang's allegations of injury to its business reputation
and customer goodwill in addition to its loss of revenues satisfied the injury
requirement of 18 U.S.c. 1964(c)." See Kimmel v. Peterson, 565 F.Supp. 476,
495 (E.D.PA 1983) (Plaintiffs allegations of monetary losses as a result of
defendant's fraud sufficiently allege "injury" under 18 U.S.C.1964(c)).
Hellenic Lines, Ltd. v. O'Hearn, 523 F.Supp. 244, 248 (S.D.N.Y. 1981) (the
corporation was injured for purposes of RICO if, as alleged, it sustained
monetary damages).
36. Defendants Hoge and Walker joined the Enterprise and committed predicate
acts in order to cause maximum harm to Plaintiff, his livelihood, his property,
and his employer. In fact, one their main goals in the Enterprise was to drive
Plaintiff out of business and intimidate him from exercising his First
Amendment right to redress. In Northeast Women's Health Center v.
15
McMonagle, 868 F.2d 1342 (3
rd
Cir. 1989), the Court addressed a similar fact
situation where activists used threats, intimidation, violence and extortion in
an attempt to drive a health clinic out of business.
The "right" on which the Center's case was predicated was the right to
continue to operate its business. The Center's extortion claim was that
Defendants used force, threats of force, fear and violence in their efforts to
force the Center out of business. The court told the jury that, "[s]pecifically,
defendants are charged with attempting and conspiring to extort from the
Center its property interest in continuing to provide abortion services[;]
from its employees, their property interest in continuing their employment
with the Center[;] and from patients, their property interest in entering into a
contractual relationship with the Center."
Rights involving the conduct of business are property rights. As we
pointed out in United States v. Local 560, 780 F.2d 267, 281 (3d Cir. 1985), ...
other circuits which have considered this question are unanimous in
extending the Hobbs Act to protect intangible, as well as tangible,
property. (Citations omitted). It is, of course, no defense to extortion that
Defendants did not succeed in their ultimate goal, although, as McMonagle's
own letter admitted, Defendants' activities did contribute to the Center's loss
of its lease at the Roosevelt Boulevard location.... Attempted extortion and
conspiracy to commit extortion are crimes under the Hobbs Act, see 18 U.S.c.
1951(a), and "any act which is indictable under [the Hobbs Act]" is a
predicate offense under RICO. 18 U.S.C. 1961(1)(B).
37. Plaintiff had a "property interest
l1
in continuing his employment as the
director of a non-profit that he had worked at for the previous eight years.
He had a /lproperty interest" in being able to raise funds for that business to
pay his salary and the other salaries and expenses of the business. Yet,
Defendants Hoge and Walker conspired with the other Defendants, and
attempted and engaged in conduct intended to deprive Plaintiff of those
property interests. They have stated many times that they want to destroy
the non-profits by stopping their funding and urged others to demand the
same. See e.g., Exhibit Mand N.
16
35. Clearly, Plaintiff has alleged injury to his business reputation, his property
and his loss of revenues to satisfy the injury requirement of RICO.
Plaintiff Properly Alleges Conspiracy to Violate the Ku Klux Klan Act of 1871
Under 42 USC 1985
36. To state a claim under 42 U.S.C. 1985, a plaintiff must show that the
Defendants conspired with a state actor who acted under color of law under
42 USC 1983 by violating a victim's Constitutional right. West v. Atkins, 487
U.S. 42, 48 (1988). "The traditional definition of acting under color of state
law requires that the defendant in a 1983 action have exercised power
'possessed by virtue of state lawand made possible only because the
wrongdoer is clothed with the authority of state law.'" Id. at 49, quoting
United States v. Classic, 313 U.S. 299, 326 (1941). Generally, "a public
employee acts under color of state law while acting in his official capacity or
while exercising his responsibilities pursuant to state law." Atkins, 487 U.S. at
50. See also Griffin v. Maryland, 378 U.S. 130,135 (1964) (UIfan individual is
possessed of state authority and purports to act under that authority, his
action is state action. It is irrelevant that he might have taken the same action
had he acted in a purely private capacity or that the particular action which
he took was not authorized by state law"). Defendant Frey acted under color
of state law when he relied on the authority of his State role as a prosecutor
to threaten to and actively criminally investigate Plaintiff. Anexus exists
between the wrongful act (the issuance of the threats and the attempts to
investigate and imprison Plaintifffor swattings) and Defendant Frey's abuse
of his authority as a prosecutor for Los Angeles County.
17
37. Defendant Frey is a Los Angeles District Attorney who has used his position
under color oflaw to harass, retaliate against, intimidate, threaten and
attempt to imprison Plaintiff, and incite others to do the same. He is the
person all the Defendants rely on to give their false narratives credibility. He
is the equivalent of the Alabama Sheriff by day and the Klan leader by night
directing his hooded followers to destroy his perceived enemies, including
Plaintiff. He regularly contacts the Defendants through email, phone, direct
messages and other means of communication to facilitate his tortious
destruction campaigns.
38. When Plaintiff complained to Defendant Frey's supervisors about his
conduct, Defendant Frey retaliated against Plaintiff by concocting the false
swatting narrative. He wrote an email to Defendant Walker telling him that
he had contacted and met with the FBI in Texas and elsewhere, and provided
false information about Plaintiff. Exhibit O. He contacted Barrett Brown, the
head of the hacking group Anonymous and tried to interest him in Plaintiff.
Exhibit P. There was an implicit quid pro quo in that request because Brown
was facing legal problems of his own. Frey counseled Defendant Walker on
how to file and prepare legal filings against Plaintiff to make him appear
odious: "No, You have to start with ten seconds oflabeling him a convicted
bomber and convicted perjurer, and say this is established by major media
stories and by published court decisions. Then say he obtained the
injunction by repeatedly perjuring himself and that you can prove it. ... Ethos
first. Then logos. Then pathos." Exhibit Q. Frey threatened to criminally
18
investigate Nadia Naffe after she gave Plaintiff evidence about Defendant
O'Keefe targeting Plaintiff. Exhibit R.
39. In an email from Defendant Frey to Defendant Walker on December 22, 2011,
Frey complimented Walker on a pleading and then said, "This kicks ass. They
are going to go apeshit. When you blog it, til send it to Glenn Reynolds and tell
him that I think this is the guy who swatted me...." (emphasis added). Exhibit
S. Mr. Reynolds is a well-known conservative author, professor and blogger.
This email clearly shows that Frey was using Defendant Walker to create a
situation Frey could use to falsely accuse Plaintiff of swatting.
40. In another email exchange with Defendant Walker, Walker tells Frey, "Now
he [Kimberlin] is going to learn not to fuck with me either." To which Frey
replied: "Yeah, but he is 'fucking' with me. Just not in court. He sends
bullshit interrogatories that he has to know will never get answered. But
mostly he is trying to make me miserable, publishing my address, hiring
people to swat me, Google bombing me, defaming me, mocking me and so on.
.... I just want you to understand that Kimberlin is behind all the things that
have happened to me, and that he is truly dangerous and a psychopath."
(emphasis added). Exhibit T. Of course, Plaintiff never hired anyone to swat
Defendant Frey, never posted his address, wasn't behind anything, and never
even published online a single word or tweet about Frey.
41. In other emaiIs to Walker and some of the other Defendants, he states that
his office at the LA County District Attorney is "investigating" Plaintiff and
19
had asked Defendant Walker to keep quiet while the investigation proceeded.
Exhibit U.
42. In another email dated December 19, 2011, he states: "Don't volunteer where
you got this stuff. Just because of the investigation. But for that, I would be
shouting all this from the hilltops, but I still think we can put these guys in
prison, so I have to stay quiet." (emphasis added). Id.
43. In an email dated January 25,2012, Defendant Frey told Defendant Walker
while waiting for a jury in a case he was trying. "I'm having fun. This is what I
do: prove things. I have a jury out so I have a little time tonight [to review the
pleading Walker prepared regarding Plaintiff]. " Exhibit V.
44. In several emails on December 21,2011, Defendant Frey discussed his
planned meetingwith the FBI the following day and setting up a sting
operation with law enforcement to arrest Plaintiff. "I don't suggest lying
unless it's done under supervision of law enforcement as part of a sting....
But it only makes sense as part of a monitored sting." Exhibit W.
45. On January 5, 2012, Defendant Frey asked Defendant Walker to send him a
letter about Plaintiff to share with his supervisors at the LA County
Prosecutors Office and other law enforcement officials. Exhibit X.
46. The above emails clearly demonstrate that Defendant Frey directly
communicated and conspired with several Defendants in this case, falsely
accused Plaintiff of swattings, and wanted to have him arrested by the FBI or
other law enforcement officers based on his accusations and a sting
operation. He discussed criminal investigations with his supervisors at the
20
LA County District Attorney's Office and communicated with Defendant
Walker while waiting for a jury. He falsely stated that Plaintiff hired people
to swat him. These actions are not those of a private citizen but rather a
person acting under color oflaw.
47. Not only did Defendant Frey aetas a prosecutor in his private emails with co-
defendants, but he also repeatedly imputed on his blog that Plaintiff swatted
him. And this false accusation signaled his co-defendants to write articles
and blog posts stating that Plaintiff swatted "Deputy District Attorney"
Patrick Frey. See Complaint at 21-23.
48. On May 23,2012, Plaintiff received a threat on his non-profit website contact
page saying: "LEAVE HIM ALONE. DON'T GO THERE." Plaintiff interpreted
this as a threat to leave Mr. Frey alone and not to contact his supervisors.
When Plaintiff checked the contact logs on for that time and that website, he
discovered that the email came from the "Los Angeles County Sheriffs
Department," at IP Address 146.233.0.202 in Whittier, California. Exhibit Y.
Only a person acting under color of law could convince an employee of the LA
County Sheriffs Office to write a threat like that. The person who wrote it
would have to feel that he would be "protected" by Defendant and Deputy
District Attorney Frey against any blowback.
49. Defendant Frey routinely refers to himself on his blog as "Patterico," a
"prosecutor in Los Angeles County...." http://patterico.com/aboutpatterico.
Readers, commenters and reporters all believe that Frey's well-known online
alter ego "Patterico" is a digital extension ofJohn Patrick Frey, the Los
21
Angeles County Deputy District Attorney. In fact, Defendant Frey identifies
himself as "Patterico" and describes "Patterico" as a prosecutor in Los
Angeles County who prosecutes criminals. In his blog posts, Defendant Frey
has made clear that "Patterico's Pontifications" is the product of a Deputy
District Attorney. Frey has indicated that "Patterico's Pontifications" is linked
to his position as a prosecutor. In a September 9, 2009 blog post entitled
"Patterico Banned at the L.A. Times???," Frey wrote "[a]re they banning all
Deputy District Attorneys? Or just the ones that make them look like fools on
a daily basis?11 Id. Frey's post shows that he perceives any purported ban on
"Patterico
l1
to be related to FreY's position as Deputy District Attorney. Id.
Due to Frey's repeated references to his position as a prosecutor, other
media outlets have viewed "Patterico's Pontifications" as inextricably linked
to his position as a deputy district attorney. Moreover, Frey frequently
invokes his position as a prosecutor to lend substance and weight to his
opinions, including claiming that "we Deputy DA's are suspicious by nature;11
disparaging a commenter's critique on his blog post by stating "[i]n your
world, every prosecution is of an innocent person ... your world has nothing
to do with the world I know, and you are clearly 100% ignorant ofthe nature
of the process you are discussing" asserting that "[b]eing a prosecutor is
about presenting the truth" (Id.); and discussing inside information from the
DA's Office. "Patterico's" invocation of his authority as a prosecutor is subtle
and Frey has intentionally crafted "Patterico" to give the impression that
"Patterico
l1
speaks casual, offhand, and is almost always followed by a
22
"disclaimer:' But when "Patterico" continuously and extensively identifies
himself as a prosecutor, when he uses his public position to exert influence
and lend credibility to his opinions, and when he threatens criminal
prosecution, Frey has transformed "Patterico" into the virtual, online
personification of the Deputy District Attorney John Patrick Frey. Thus, when
"Pattericd' speaks, he speaks with the authority and prestige of the Office of
the District Attorney. By cloaking himself with the power of his government
position, "Patterico" placed readers and Internet observers on notice that his
expressions carried the weight and gravitas of a prosecutorial office of the
state government. Like the off-duty police officer who flashes his badge and
uses a department issued handgun, "Patterico" openly displays his
credentials as a prosecutor. When "Patterico" issued his threat to investigate
and imprison Plaintifffor swattings, the statement was uttered with the force
of authority conferred on Frey by virtue of his position as a prosecutor on a
matter in which Frey was uniquely endowed to act.
In Donnellyv. DeChristoforo, 416 U.S. 637,648 n.23 (1974), the Supreme
Court cited to opinion of ChiefJustice Tauro of the Supreme Judicial Court of
Massachusetts:
"Unlike a newspaper, the prosecutor ostensibly speaks with the authority of
his office. The prosecutor's' personal status and his role as a spokesman for
the government tend(ed) to give to what he ... (said) the ring of authenticity .
. . tend(ing) to impart an implicit stamp of believability.III Hall v. United States,
419 F.2d 582,583-584 (5th Cir.).
Defendant Frey's threats were not made by a private individual in his
personal capacity who happened to also work as a prosecutor during normal
23
business hours. Rather, "Patterico," the blogger and Internet persona, had a
long, active online history and presence as the alter ego of Deputy District
Attorney John Patrick Frey who used that presence to violate Plaintiffs
rights.
50. Defendant Frey exploited the authority given him by virtue of his state office
when he threatened to investigate and imprison Plaintiff for possible
criminal violations. "[A]ction under color of law is always identified by
reference to the relationship between defendant's alleged misconduct and
his state-created duties and powers, rather than the status of the parties."
Anthony, 845 F. Supp. at 1401.See McDade v. West, 223 F.3d 1135, 1140 (9th
Cir. 2000) (a public officer is acting under color of state law ifhe or she "is
acting, purporting, or pretending to act in the performance of his or her
official duties");]ohnson v. Knowles, 113 F.3dll14, 1117 (9th Cir. 1997)
(public official's alleged wrongful conduct not performed under color of state
law if conduct is not related to performance of official duties); Dang Vang v.
Vang Xiong X Toyed, 944 F.2d 476, 480 (9th Cir.1991) (ilFor conduct to relate
to state authority, it must bear some similarity to the nature of the powers
and duties assigned to the defendants," quoting Murphy v. Chicago Transit
Authority, 638 F. Supp. 464, 468 (N.D. III. 1986)). By threatening to conduct
and conducting a criminal investigation into Plaintiff, Defendant Frey spoke
and acted with the authority of his office on a subject that uniquely related to
his exclusive, state-authorized duties: criminal investigation and prosecution
of criminal complaints. His threats of criminal investigation and
24
imprisonment were made in context of extensive efforts to intimidate and
silence Plaintiff.
51. Defendant Frey clearly intended to prosecute and imprison Plaintiff even
though he was not successful. Therefore} the "color oflaw" analysis applies
because the wrongful act was completed when "Patterico" began his
investigations and issued his threats to imprison Plaintiff for swattings and
whatever other concoction he had in his mind. For purpose of the 1983
"color of law" analysis, Plaintiff need only show that the wrongful act alleged
is related to the performance ofthe state actor's duties. Anderson v. Warner,
451 F.3d 1063, 1068 (9th Cir. 2006) ("the challenged conduct must be
related in some meaningful way either to the officer's governmental status or
to the performance of his duties"); Anthony, 845 F. Supp. at1400 ("[w]hether
a state employee acts under color oflaw turns on the relationship of the
wrongful actto the performance of the defendant's state duties"). The acts to
investigate and imprison Plaintiff for false criminal violations were intended
to retaliate against and silence Plaintiff. That misconduct, which led to
Plaintiffs constitutional deprivation, was directly related to Defendant Frey's
authority as a Deputy District Attorney to investigate and
prosecute violations oflaw. Because Defendant Frey abused the authority of
his public position when he tried to imprison Plaintiff for a false crime, he
acted under "color oflaw" for purposes of 42 U.S.c. 1983.
It is settled law that the First Amendment prohibits government officials
from subjecting an individual to retaliatory actions, including criminal
25
prosecutions, for speaking out or exercising the right to redress. Cf., Hartman
v. Moore, 547 U.S. 250, 256 (2006). To show a First Amendment violation,
Plaintiff must plead facts that demonstrate that Frey's actions "deterred or
chilled" his speech or right 0 redress and that such deterrence "was a
substantial or motivating factor
1J
in Defendant Frey's conduct. Lacey v.
Maricopa County, 693 F.3d 896, 916 (9th Cir. 2012). Plaintiff need not show
that his speech or redress was '''actually inhibited or suppressed.'''
Id., citing Mendocino Envtl. Ctr. v. Mendocino Cnty., 192 F.3d 1283, 1300
(9thCir.1999). The relevant inquiry is "whether an official's acts would chill
or silence a person of ordinary firmness from future First Amendment
activities." Lacey, 693F.3d at 916-17. Plaintiff must allege facts ultimately
enabling him to "'prove the elements of retaliatory animus as the cause of
injury,' with causation being 'understood to be but-for causation.' Id. at 917,
citing Hartman, 547 U.S. at 260.
52. In the instant case, Defendant Frey, because he is prosecutor, became a
leader of the conspiracy to violate Plaintiffs constitutional rights. The co-
defendants looked to him for leadership and followed his direction, advice,
both private and public, to falsely accuse Plaintiff of swattings in order to
imprison Plaintiff. What greater violation of constitutional rights could occur
to a living person than being imprisoned based on a false criminal charge?
Defendant Frey called and met with the FBI and told them to arrest Plaintiff
for the swattings, and Frey had his supervisors at the LA County District
Attorney's Office criminally investigate Plaintiff in the hope that they would
26
find something on which to imprison him.
53. Clearly Defendants Hoge, Walker and the other Defendants conspired with
Frey to violate Plaintiffs civil rights by publicly and privately pushing the
false narrative concocted by Frey that Plaintiff was involved with swattings.
Frey along with other Defendants are members of the National Bloggers Club,
which made the false swatting meme its first and only campaign. Defendants
Hoge and Walker have made Plaintiffs imprisonment their life's work over
the past two years with thousands of tweets and blog posts smearing
Plaintiff, their letters to Congress Members stating that Plaintiff was the
swatter and should be imprisoned, and their false criminal charges against
Plaintiff. This call for imprisonment was taken from Defendant Frey who
stated in his December 11, 2011 email that he would phone a well-known
reporter and say that Plaintiff was the person who swatted him. He also
stated that he would meet with the FBI and set up a sting operation.
54. Plaintiff has alleged a very powerful case that the Defendants, including Hoge
and Walker, conspired with Defendant Frey under 42 USC 1985 to violate
Plaintiffs civil rights.
Plaintiff Hereby Withdraws Fraud and Negligent Misrepresentation
55. Plaintiff hereby withdraws this Count of the Complaint for all Defendants.
Plaintiff Has Properly Alleged Intentional Infliction of Emotional Distress
36. Defendants Hoge and Walker callously argue that Plaintiff has not made any
allegation to demonstrate infliction of emotional distress. This is without
merit.
27
37. I The Restatement (Second) of Torts, 46 at 71, provides: r(l) One who by
extreme and outrageous conduct intentionally or recklessly causes severe
emotional distress to another is subject to liability for such emotional
distress, and ifbodily harm to the other results from it, for such bodily harm."
In comment (i) to the Restatement it is expressly stated that this rule also
covers a situation where the actor knows that distress is certain, or
substantially certain, to result from his conduct. In order to satisfy the element
of extreme and outrageous conduct, the conduct "must be 'so extreme in degree,
as to go beyond all possible bounds of decency, and to be regarded as atrocious,
and utterly intolerable in a civilized society.''' Batson v. Shiflett, 325 Md. 684, 733
(Md. 1992).
38. Illustrative of the cases which hold that a cause of action will lie for
intentional infliction of emotional distress, unaccompanied by physical
injury, is Womack v. Eldridge, 215 Va. 338 (1974). There, the defendant was
engaged in the business of investigating cases for attorneys. She deceitfully
obtained the plaintiffs photograph for the purpose of permitting a criminal
defense lawyer to show it to the victims in several child molesting cases in an
effort to have them identifY the plaintiff as the perpetrator of the offenses,
even though he was in no way involved in the crimes. While the victims did
not identifY the plaintiff, he was nevertheless questioned by the police, called
repeatedly as a witness and required to explain the circumstances under
which the defendant had obtained his photograph. As a result, plaintiff
suffered shock, mental depression, nervousness and great anxiety as to what
28
people would think of him and he feared that he would be accused of
molesting the boys. The court, in concluding that a cause of action had been
made out, said: "Most of the courts which have been presented with the
question in recent years have held that there may be a recovery against one
who by his extreme and outrageous conduct intentionally or recklessly
causes another severe emotional distress .... "
39. In the instant case, Plaintiff has alleged thatthe Defendants, including Hoge
and Walker, engaged in outrageous and extreme conduct by falsely
publishing the defamatory statements accusing him of crimes and nefarious
conduct, demanding that he be investigated, arrested and imprisoned for
swattings, publishing tens of thousands of tweets and blog posts smearing
Plaintiff and accusing him of crimes, filing three frivolous and malicious
lawsuits against him, sending a defamatory letter to an institutional funder
falsely accusing him of crimes, attempting to extort his employer into firing
him, rallying extremists with false narratives to attack him, filing for
sanctions in the amount of tens of thousands of dollars and imprisonment,
and asking a federal court to deny him access to the courts. This abhorrent
conduct has kept Plaintiff under siege for years, and caused extremists to
come to his home, take pictures of him and his daughter, and make
threatening calls to him, his family and his neighbors. No person in a civilized
society should be made to endure such conduct.
40. Moreover, Defendants conspired with the other Defendants to imprison
Plaintiff based on their false narratives that Plaintiff was involved with
29
swattings. This constitutes extremely outrageous conduct that intentionally
inflicted emotional distress on Plaintiff. There are not many things in this
country worse than being falsely accused of crimes and then having those
false accusations incite a lynch mob to attack relentlessly and daily with tens
of thousands of tweets and posts and articles, and stalkers over a period of
years. This is atrocious and has absolutely no place in a civilized society.
41. Not a day goes by where Plaintiff is not attacked, online or in person, by one
or more of the Defendants. Defendant Walker came to a court hearing in
Montgomery County Circuit Court and, after the proceeding to which he was not
a party, followed Plaintiff out of the courtroom and assaulted him so severely he
ended up in the Emergency Room at Suburban Hospital. This resulted in days
off of work and a fear that Defendants will again assault Plaintiff or his
family. Defendants Walker, Hoge, McCain and Ali have stalked Plaintiff in
public places. Defendants Walker, Hoge and DB Capitol Strategies have filed
numerous false criminal and civil actions against Plaintiff over a two-year
period, all which have been dismissed or denied. Defendants Hoge, Walker
and some of the other Defendants publish daily taunts against Plaintiff and
mock this suit with daily posts on their blogs, and continually assert that they
are going to get Plaintiff imprisoned. They have attacked Plaintiffs employer
and those who donate to that non-profit. The Defendants have tried to get
Plaintiff fired. They have attacked Plaintiffs wife and teenage daughter and
even reporters who have written favorably about Plaintiff. They have even
attacked prosecutors who have refused their frivolous charges, Defendant
30
Walker has even imputed in a recent blog post that Plaintiffs daughter is fair
game for destruction because of "corruption of blood. II Exhibit Z.
42. All of this has been intended to inflict maximum emotional distress on
Plaintiff. Plaintiff has had to install robust security devices and video
cameras at his home and office, and take precautions for his family that no
young child should have to be subjected to, all because the Defendants have
created a lynch mob based on false narratives to terrorize Plaintiff and his
family on a continuous multi-year basis. This clearly demonstrates that the
Defendants, including Hoge and Walker, intentionally inflicted emotional
distress.
Wherefore, for all the above reasons, Plaintiff has demonstrated that he entitled
to relief and therefore that this Court should deny Defendants Hoge and Walker's
Motions to Dismiss.
Respectfully submitted,
Brett Kimberlin
I I
Bethesda, MD 20817
Certificate of Service
I certify that I have served a copy of this motion on Defendants Stranahan,
Patrick Frey, Mandy Nagy, by email, and on Defendants DB Capitol Strategies,
Hoge, The Franklin Center, and Walker by First Class mail this 17
th
day of
January, 2014.
Brett Kimberlin
31
Abou Updates Conm nity Con rib tions
))
National Bloggers Club President
Yesterday, we crossed e firs I is Ii T a kyo
Like. Comment 3 man hs ago
Case Information
Go Back
Court System: DISTRICT COURT FOR CARROLL COUNTY - CIVIL System
Case Number: 1002SP003032013Case Status:APPEAL
Case Type: PEACE ORDEROrder Valid Thru:03/29/2013
Filing Date:03/22/2013
Defendant Name: KIMBERLIN, BRETT
City: BETHESDAState: MDDOS:06/03/1954
Hearing Date:
Hearing Location:
Served Date:
Hearing Type:
Result:
Hearing Date:
Hearing Location:
Hearing Type:
Result:
03/22/2013Hearing Time:9:3 AMRoom:Xl
101 NORTH COURT ST,WESTMINSTER,MD 21157-5111
03/22/2013
TEMPORARY
COURT ORDERS:
SHALL NOT ABUSE
SHALL NOT CONTACT
03/29/2013Hearing Time:l0:30 AMRoom:Xl
101 NORTH COURT ST,WESTMINSTER,MD 21157-5111
FINAL
DENIED: DOES NOT FALL W/IN STATUTE.
Other Events
Date: 04/02/2013
Description: Case Appealed
Circuit Court of Maryland
Go Back
Case Information
Cou rt System:
Case Number:
Title:
Case Type:
Case Status:
Case Disposition:
District Case No:
Circuit Court for Carroll County - Civil System
06C13063590
District Court Appeal- Peace OrderFiling Date:04/03/2013
Closed/Inactive
Decree or OrderDisposition Date: 07/ 02/2013
1002SP003032013
32
t ~
Defendantl Respondent Information
(Each Defendant/Respondent is displayed below)
Party Type: RespondentParty No.: 1
Name: Kimberlin, Brett
Attorney(s) for the Defendant/Respondent
Name: Kim, Esq, Tae H
Appearance Date: 04/03/2013
Removal Date: 07/02/2013
Practice Name: Tae H Kim Attorney At Law LLC
Address: 9520 Berger Road
Suite 212
City: ColumbiaState:MDZip Code:21046
Court Scheduling Information
Event Type: De Novo Appeals HearingNotice Date:04/12/2013
Event Date: 05/17/2013Event Time:09:00 AM
Result: Held/ConcludedResult Date:05/17/2013
This is an electronic case record. FuJI case information cannot be made
available either because of legal restrictions on access to case records found
in Maryland rules 16-1001 through 16-1011, or because of the practical
difficulties inherent in reducing a case record into an electronic format.
DISTRICT COURT OF MARYLAND
Go Back
Case Information
Court System: DISTRICT COURT FOR CARROLL COUNTY - CRIMINAL SYSTEM
Case Number:
Case Type:
District Code:
5S00058203Tracking No: 121002299552
CRIMINAL
10Location Code:02
Document Type: SUMMONSlssued Date:02/18/2013
Case Status: CLOSEDCase Disposition:TRIAL
Defendant Information
33
Race: WHITE, CAUCASIAN, ASIATIC INDIAN, ARAB
Sex: MHeight:000Weight:000DOB:06/03/1954
Address: 8100 BEECH TREE RD
City: BETHESD tate:MDZip Code: 20817 - 0000
OTHER PLEA
NOLLE PROSEQUIDisposition Date:04/17/2013
Fine:$O.OOCourt Costs: $0.0 CF:$O.OO
Fine:$O.OOCourt Costs:$O.OOCICF:$O.OO
Probation End Date: Restitution Amount:$O.OO
Yrs:Mos:Days:
Yrs:Mos:Days:
Disposition:
Amt Suspended:
PBJ EndDate:
Jail Term:
Suspended Term:
Credit Time Served:
Charge and Disposition Information
(Each Charge is listed separately. The disposition is listed below the Charge)
Charge No: 001Description:HARASSi A COURSE OF CONDUCT
Statute: CR.3.803Description:HARASS; A COURSE OF CONDUCT
Amended Date: OIS Code:l 0191MO/PLL:Probable Cause:X
Incident Date From: 10/31/2012 To: 02/15/2013 Victim Age:
Disposition
Plea:
Charge No: 002Description:ELEC MAIL HARASS
Statute: CR.3.805Description:ELEC MAIL HARASS
Amended Date: OIS Code:2 1135MO/PLL:Probable Cause:X
Disposition
Plea:
Disposition:
Amt Suspended:
PBJ EndDate:
Jail Term:
Suspended Term:
Credit Time Served:
OTHER PLEA
Fine:$O.OOCourt Costs:$O.O ICF:$O.OO
Probation End Date:Restitution Amount:$O.OO
Yrs: Mos: Days:
Yrs:Mos:Days:
Related Person Information
(Each Person related to the case other than the Defendant is shown)
Name:HOGE, WILLIAM JOHN JOSEPH
Connection: COMPLAINANT
34
Event History Information
Event Date Comment
SUMI 02/18/2013 SUM ISSUED 130218 AGENCY:ZF 06
SUMS 03/14/2013 SUM SERVED 130305
This is an electronic case record. Full case information cannot be made
DISTRICT COURT OF MARYLAND
Go Back
Case Information
Court System: DISTRICT COURT FOR CARROLL COUNTY - CRIMINAL SYSTEM
Case Number: 150005838 racking No:131001166343
Case Type: CRIMINAL
District Code: 10Locatlon Code:02
Document Type: SUMMONSIssued Date:03/22/2013
Case Status: CLOSE ase Dlspositlon:TRIAL
Defendant Information
Race: WHITE, CAUCASIAN, ASIATIC INDIAN, ARAB
Sex: MHeight:000Weight:000DOB:06/03/1954
Address: L-I ----J1
City: BETHESD tate:MDZlp Code: 20817 - 0000
Charge and Disposition Information
(Each Charge is listed separately. The disposition is listed below the Charge)
Charge No: ooIDescription:HARASS; A COURSE OF CONDUCT
Statute: CR.3.803Descriptlon:HARASS; A COURSE OF CONDUCT
35
OTHER PLEA
Fine: $O.OOCourt Costs: $O.OOCICF: $0.00
Probation End Date:Restitution Amount:$O.OO
Yrs: Mos: Days:
Yrs:Mos:Days:
Disposition:
Amt Suspended:
PBJ EndDate:
Jail Term:
Suspended Term:
Amended Date: OIS Code:l 0191MO/PLL:Probable Cause:X
Disposition
Plea:
Credit Time Served:
Related Person Information
(Each Person related to the case other than the Defendant is shown)
Name:HOGE, WILLIAM JOHN JOSEPH
Connection:COMPLAINANT
Event History Information
Event Date Comment
SUMI 03/22/2013 SUM ISSUED 130322 AGENCY:MSP 9056
SUMS 06/04/2013 SUM SERVED 130517
This is an electronic case record. Full case information cannot be made
36
1116/2014 Case Information
Case Information
Go Back
Court System:DISTRICT COURT FOR MONTGOMERY COUNTY - CIVIL System
Case Number:0601SP003412013 Case Status: CLOSED
Case Type:PEACE ORDER Order Valid Thru: 03/13/2013
Filing Date:03/13/2013
City:BETHESDA State: MD DOB: 06/03/1959
Hearing Date:
Hearing
Location:
Hearing Type:
Result:
03/13/2013 Hearing Time: 3:29 PM Room: X3
191 EAST JEFFERSON ST,ROCKVILLE,MD 20850
TEMPORARY
THIS ORDER IS DENIED BECAUSE: THERE IS NO STATUATORY BASIS FOR RELIEF.
This is an electronic case record. Full case information cannot be made available either because of legal
restrictions on access to case records found in Maryland rules 16-1001 through 16-1011, or because of the
practical difficulties inherent in reducing a case record into an electronic format.
http://casesearch.courts.state.md.us/inquiry/inquiryDetail.jis?caseId=0601SF003412013&loc=23&detaiILoc=DV 1/1
Home aison O'etre
Home) Dead Activist) Team Kimberlin Post of the Day I hogewash
Team Kimberlin Post of
the Day I hogewash
Posted on October 30,2013 by Richard MNixon (Deceased) - Leave a
comment L
Team Kimberlin Post of the
Day
Today's episode is another look at factual errors in the amended
complaint The Dread Pirate Kimberlin filed in his frivolous Kimberlin v.
Walker, et al. lawsuit.
40. Defendants Walker. Hoge. McCain, Akbar and KU promoted the unauthorized
fundralsing tool and profited from th money rid. Defendant Hoge. who
controlled the money raised through his PayPal account. refused Plaintiff
wife's dem nd that aU the money be returned to the donors. instead saying
he would give it to charity.
E?C b
In the context of the previous paragraphs, the fundraising tool
referred to in paragraph 40 is the fund created to provide legal and
other support for Mrs. Kimberlin. The first error is the statement that
Aaron Walker, Stacy McCain, Ali Akbar, Kimberlin Unmasked, and I
Help Bloggers
Search for
dead content
search here ...
Go
Follow Blog
via Email
Enter your email address
to follow this blog and
receive notifications of new
posts by email.
Join 1,686 other followers
Follow
Allergic to Bull: How Brett Kimberlin Tried to Frame Me for a Crime (A... http://allergic2bull.blogspot.comI20 l2/0S/how-brett-kirnberlin-tried-to...
Followthis link to my BLOCKBUSTERSTORY of how Brett Kimberlin, a convicted terrorist and perjurer, attempted to frame me for a crime,
and then got me arrested for blogging when rexposed that misconduct to the world. That sounds like an incredible claim, but I provide
primary documents and video evidence proving that he did tills. And ifyou 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 PayPal buttons on the right. And I thank everyone
who has done so, and will do so.
POPULARPOSTS
I Search I
Help The Bloggers' Defense Team!
Home
There was an error in this gadget
The Brett Kimberlin Saga (And How
You Can Help!)
Tweellhis
View stats
(NEW) Apoo'ument gadget
IJ Share Ihis QO Eacebook
SEARCHTHIS BLOG
There was an error in this gadget
There was an error in tltis gadget
PAGES
DONATETOTHE NATIONAL
BLOGGERS CLUB ANDDEFEND
FREEDOMTO BLOGI
HELP PRESERVE FREE SPEECHl
DONATETO MY LEGAL DEFENSE
FUNDl
SHAKE IT
Introduction
Well, at exactly 6:54 a.m. I posted my monster post describing howconvicted
ten'orist and peIjurer Brett Kimberlin actually tried to frame me for a crime and it
has gotten a lot of hits so far.
So I am going to backdate a series of posts covering each part separately. I will end
each one with a link to the next part, and I will start each one with a link to the
previ.ous part, but here is a list of the parts with links attached, for your
convenience:
Part 2: The January 9, 2012 Hearing.
Part 3: The January 9 Incident.
But a couple people have complained that the post is too large, and too unwieldy,
that it is causing computers to crash and the like and have suggested breaking down
the post into smaller, more digestible parts. That seems realistic. My computer is
relatively new and moderately ahead of the curve, and it was groaning as I tried to
create the post.
Part 4: What Kimberlin Said about the January 9 Incident.
THURSDAY, MAY17,2012
Part 5: The Effect of Kimberlin's Lies.
Part 6: Trying (And Failing) to Get Justice in Montgomery County,
Maryland.
Part 7: How You Can Helpl
How Brett Kimberlin Tried to Frame Me for a Crime
(And HowYou Can Help!)-Broken Down into Eight
Easy Pieces
So fu'st up, we get: the Introduction.
Part 1: Background.
1 of7 9/2/13 Il:03 AM
PAR T I A L
V I R GIN I A
T RAN S C RIP T
1
IN THE CIRCUIT COURT OF PRINCE WILLIAM COUNTY
x
AARON J. WALKER,
Plaintiff,
-vs-
BRETT KIMBERLIN,
Defendant.
x
Case No. CL12-631-00
Circuit Courtroom 4
Prince William County Courthouse
Manassas, Virginia
Tuesday, December 4, 2012
The above-entitled matter came on to be heard
before the HONORABLE RICHARD B. POTTER, Judge, in and for
the Circuit Court of Prince William County, in the
Courthouse, Manassas, Virginia, beginning at 11:15 o l o ~
a.m.
R E E N & K E R N S
CERTIFIED VERBATIM REPORTERS
4116 LEONARD DRIVE
FAIRFAX, VIRGINIA22030
(703) 591-3136
R E
p
o R T
APPEARANCES:
On Behalf of the Plaintiff:
DAN BACKER, ESQUIRE
On Behalf of the Defendant:
(Pro Se)
2
:3 R E E N & K E R N S
4116 LEONARD DRIVE
(703) 591-3136
R E
p
o R T
1 EXT R ACT o F PRO C E E DIN G S
3
2 *
3 *
4 *
5 (The Court Reporter was previously sworn by
6 the Clerk of the Court.)
7 THE COURT: We're back on the record.
8 The Plaintiff has brought a complaint against
9 the Defendant Kimberlin, and two other Defendants who are
10 not before the Court today personally.
11 Their complaint contains thirty-two counts of
12 which fourteen involve the Defendant Kimberlin. Counts
13 two, four, five, eight, nine, fourteen, fifteen, sixteen,
14 twenty-three, twenty-four, twenty-five, twenty-six,
15 twenty-seven, and thirty-two.
16 The Defendant Kimberlin has filed a motion to
17 dismiss the complaint for failure to state a claim, the
18 lack of jurisdiction, improper venue, and violation of ~
19 First Amendment.
20 Kimberlin's motion to dismiss will be granted
21 That is motions for any additional sanctions will be
22 denied.
23 In light of the Court's ruling on the motion
R E E N & K E R N S
4116 LEONARD DRIVE
(703) 591-3136
R E
p
o R T
4
1 to dismiss, the other pending motions by the Court are
2 moot and therefore dismissed as well.
3 Plaintiff's motion for default judgment
4 against the co-defendants are also denied and the case is
5 dismissed.
6 Upon consideration of the totality of the
7 pleadings including the attached exhibits and the r g u m n ~
8 of the parties and counsel it is clear to this Court that
9 the Plaintiff seeks two million dollars in punitive
10 damages, but makes no claim for compensatory damages so
11 that the Plaintiff (inaudible) is not recognizable under
12 the law.
13 It's also clear from the various pleadings ani
14 exhibits filed in this case that the parties have been
15 involved in extensive disputes that have involved
16 political and religious issues.
17 These various claims including criminal and
18 civil allegations and litigations in state and federal
19 courts all of which appear to have been dismissed. The
20 most recent case filed by the Plaintiff against the
21 Defendant Kimberlin and his two organizations was
22 dismissed by order of the U.S. District Court in the
23 District of Maryland on November 28, 2012, just six days
3 R E E N & K E R N S
CERTIFIEDVERBATIM REPORTERS
4116 LEONARD DRIVE
(703) 591-3136
R E
p
o R T
5
1 ago, in which the Judge stated and I quote, deem it
2 unwise to intervene in the bitter political disputes
3 between the parties."
4 This Court takes the same position. It's
5 clear that this case is simply a continuation of
6 and vindictive litigation between the parties.
7 While the law in Virginia is clear that
8 failing to state a claim is an issue generally addressed
9 by demurrer, and Defendant Kimberlin has not filed a
10 demurrer in this case.
11 It's also true that Virginia law provides tha
12 the signature of an attorney or a party with any pleading
13 before this Court constitutes a certification by him that
14 the pleading is well grounded in fact, warranted by
15 existing law, and is not interposed for any improper
16 purpose such as to harass or to cause unnecessary delay
17 needless increase in the cost of litigation.
18 The Court finds that the complaint is not weI
19 grounded in fact, it's not warranted by existing law, and
20 it's imposed for an improper purpose as part of an
21 political dispute between the parties.
22 While the statute provides for sanctions by
23 the Court, this Court will grant the motion to dismiss by
R E E N & K E R N S
4116 LEONARD DRIVE
(703) 591-3136
R E
p
o R T
6
1 Defendant Kimberlin.
2 The Court denies the motion for any further
3 sanctions.
4 The Court further finds that count two is
5 based upon a claim of defamation. Under Virginia law, the
6 elements on defamation are:
7
8
9
1 )
2 )
3)
Publication,
Of an actual statement and,
Intent.
10 In order to assert a claim of defamation
11 however the Plaintiff must first show that the Defendant
12 published a false factual statement that concerns and
13 harms the Plaintiff.
14 But here by the Plaintiff's own allegations
15 including paragraph fifty-one they indicate that the
16 statements allegedly made by the Defendant were not
17 directed at the Plaintiff.
18 In addition, as the Defendant has stated in
19 his motion to dismiss and here today expressions of
20 opinion are constitutionally protected and they're not
21 actual as defamation.
22 So as a matter of law the Court finds that th
23 statements set forth in the complaint do not contain
R E E N & K E R N S
CERTIFIEDVERBATIM REPORTERS
4116 LEONARD DRIVE
(703) 591-3136
R E
p
o R T
7
1 provable false factual statements but are relative in
2 nature and depend upon the viewpoint of the speaker.
3 Counts four and five are dismissed for lack 0
4 proper jurisdiction and venue.
5 As to count eight, it is based on allegation
6 of intentional infliction of emotional distress. In orde
7 to recover on a claim of intentional infliction of
8 emotional distress the Plaintiff must satisfy four
9 elements of proof:
10 1 ) That the Defendant's conduct was
11 intentional and reckless and,
12 2) The Defendant's conduct was outrageous anc
13 intolerable and,
14 3) There was a causal connection between thE
15 wrongdoers conduct and the resulting emotional distress,
16
17 severe.
4 ) The resulting emotional distress was
18 Even taken in the light most favorable to the
19 Plaintiff, the Court cannot find that the alleged
20 statements of the Defendant Kimberlin were outrageous or
21 could be the basis of any severe emotional distress.
22 As to count fourteen, that count is based on
23 the tort of interference with business expectations and
R E E N & K E R N S
4116 LEONARD DRIVE
(703) $1-3136
R E
p
o R T
8
1 the elements of that tort include:
2 1) A business relationship or expectancy of
3 probability of future economic benefit to Plaintiff as an
4 objective test and,
5 2) Defendant's knowledge of that relationshi
6 or expectancy and,
7 3) Reasonable certainty that absent the
8 Defendant's intentional misconduct Plaintiff would have
9 continued in that relationship and,
10
11 and,
12
4 )
5)
The interference was by improper methods
Damages resulted from that improper
13 interference.
14 The complaint fails to state all of the
15 elements. It fails to state sufficient facts that were
16 any way improper methods by the Defendant.
17 Counts fifteen and sixteen are dismissed for
18 lack of jurisdiction and venue.
19 Count twenty-three is based on the Virginia
20 business conspiracy. And the elements of that are:
21
22
23
1)
2)
3)
An allegation of two or more persons,
An agreement and,
To willfully and maliciously interfere
4116 LEONARD DRIVE
(703) 591-3136
R E
p
o R T
9
1 with another in his trade, reputation, business, or
2 profession by any means and,
3 4) Malice, that is an intentional purpose anc
4 without justification.
5 The given complaint fails to state sufficient
6 facts to support the elements of the tort and fails to
7 state those specific facts with reckless and
8 particularity.
9 Count twenty-four is based on the tort of
10 Virginia Common Law of Conspiracy and the elements of the
11 tort include:
12
13
1) Two or more persons combined to,
2) Accomplish by some concerted action for
14 some criminal or unlawful purpose, or an unlawful purpose
15 by unlawful and criminal means.
16 If a Plaintiff fails to allege the tort with
17 reckless and particularity.
18 Counts twenty-five, twenty-six, and twenty-
19 seven are dismissed for lack of jurisdiction and venue ~
20 for the reasons set forth herein.
21 Count thirty-two is based upon Plaintiff's
22 request for an injunction, but an injunction requires one
23 irreparable harm and two, a lack of adequate remedy of
4116 LEONARD DRIVE
FAIRFAX, V1RGINIA22030
(703) 591-3136
R E
p
o R T
10
1 law.
2 In view of the fact no compensatory damages
3 are sought, there can be no showing of irreparable harm
4 the allegations set forth in the complaint or any showing
5 that the Plaintiff would not have an adequate remedy of
6 law or a claim of merit.
7 Therefore, the Defendant's motion to dismiss
8 counts two, four, five, eight, nine, fourteen, fifteen,
9 sixteen, twenty-three, twenty-four, twenty-five, twenty-
10 six, and twenty-seven, and thirty-two is granted.
11 The motion is granted and those counts are al
12 dismissed with prejudice. The Court shall note the
13 exceptions of the Plaintiff and the Defendant to the
14 ruling of the Court.
15 The other motions are therefore rendered moot
16 and are also dismissed. At the same time the Court will
17 dismiss the motion for default judgment against the co-
18 defendants upon the same grounds as set forth by the
19 Court.
20 I will ask counsel to prepare an order which
21 simply reflects the ruling of the Court which is that the
22 Defendant's motion to dismiss is granted and the case is
23 dismissed.
4116 LEONARD DRIVE
(703) 591-3136
R E
p
o R T
1
2
3
4
Thank you, gentlemen.
*
*
*
11
5 END o F EXT RAe T
6
* * * * *
7 (Whereupon, at approximately 11:57 o'clock
8 a.m., the hearing in the above-entitled matter was
9 concl uded. )
10
11
12
13
14
15
16
17
18
19
20
21
22
23
R E E N & K E R N S
4116 LEONARD DRIVE
FAIRFAX VIRGINIA22030
(703) 591-3136
R E
p
o R T
12
* * * * *
CERTIFICATE OF REPORTER
I, SUZANNE GONZALES, a Verbatim Reporter, do
hereby certify that I took the stenographic notes of the
foregoing proceedings which I thereafter reduced to
typewriting; that the foregoing is a true record of said
proceedings; that I am neither counsel for, related to,
nor employed by any of the parties to the action in which
these proceedings were held; and, further, that I am not
relative or employee of any attorney or counsel employed
by the parties hereto, nor financially or otherwise
interested in the outcome of the action.
SUZANNE GONZALES
Verbatim Reporter
4116 LEONARD DRIVE
(703) 591-3136
R E
p
o R T
hogewash
Everyone 810g About the Howard County
State's Attorney's Office Day
Posted on
11 o Rate This
It's been two weeks since I requested answers to these questions:
1. Is it the position of the State's Attorney that operation of a blog allows one unlimited license to contact
another person without regard to Maryland Criminal Statutes 3-803 and/or 3-805?
2. Does Mr. Broccilino believe that a public person such as himself may not seek to demand that someone
cease contacting him as provided by Maryland Criminal Statutes 3-803 and/or 3-8051
3. Is it the policy of State's Attorney that non-residents of Maryland must or should avoid entering the state
if they are being stalked by a Maryland resident?
I have not yet received a response from either State's Attorney Dario J. Broccolino or a member of his
staff.
I was prompted to ask these questions because of his office's handling of harassment complaints filed by
families from Texas and Virginia that were not prosecuted. Of course, it is possible that a complaint can be
filed without sufficient supporting evidence. However, it appears that all of the evidence necessary to
establish that harassment occurred and who did it was well documented. The State's Attorney's Office's
response was
Stay offthe Internet ifyou don't want to be harassed.
The Virginia family has also be stalked by a convicted violent felon for the past year. After the wife was
stalked by that individual in a Howard County courthouse parking lot, she was told
Ifyou're so concernedfor your safety, stay out ofMaryland.
f=tcG
IVIUI C"VVc;l tJllll LJI c;VVC;1 J 1I Ie; F""'\vv10LQI It \JlQLO 0 nllUI I Ivy VVI IV 1101 IUIe;U lJVLJ I vQvv..:J, I lau I IV II Ilvl vOL II I I IC;OIIl
from the complainants. He told them up front that his decision not to prosecute had been made.
Over the past couple of weeks, I've encouraged others to contact the Howard County State's Attorney's
Office to see what they could find out about these questions and suggested that today should be a date to
report their findings. I look forward to their reports.
UPDATE-One theme that seems to be emerging in the early posts for Everyone Blog About the Howard
County States' Attorney's Qfffce Day is that most blogger's requests for information have been ignored. In
fact, the only response published as of 6:30 am ET was this one, received by the anonymous blogger who
uses the nom de cyOOr of R. M. Nixon (Deceased):
The ONLYresponse I have received, as a private citizen is an email requesting mu real identity, driver's
license information, social security nwnber as a requirement for a respons Follow ld residents
only.
Folio V "hoge\Jvasll"
Why would driver's license and social security infc
an answer about how laws are interpreted? Why
Maryland's law might affect him or his travel plam
Hmmmm.
UPDATE 2-Here is a list of participating bloggers
ot ( (;r r (w
t\.l v( ur 11111 lX
Enter your email address
( Sign me up )
Attorney to give
Jt how
Share this: Twitter 27 Facebook Powered by WordPress.com
Like this:
Related
*Like
14 bloggers like this.
Everyone Blog About the How...
" .. I, r
#BlogHoCoSAO Coming Mon... #BlogHoCoSAO On 8 April
V')'
This entry was posted in Blogging, Crime, First Amendment, Government and tagged Dario J.
Broccolino, Equal Protection of the Laws, Harassment, Howard County State's Attorney by
wjjhoge. Bookmark the permalink [http://hogewash.com/2013/04/08/everyone-blog-about-the-
howard-county-states-attorneys-office-dayl] .
17 THOUGHTS ON "EVERYONE BLOG ABOUT THE HOWARD COUNTY STATE'S AnORNEY'S OFFICE DAY"
monitor2112
A
rlHflnn to blO{lners
paid anything do so,
tjlCl(lQerS Club
truly care
see
opinion,
\NVifW f'1P!!!nnalhinnnPfsr.!llh nrn
r-rL' M
1116/2014
Piryx
Share This Page
National Bloggers Qub Breitbart Scholarship :: Remembering Breitbart - Piryx
Like 0
TweetO
National Bloggers Club Breitbart Scholarship
$0.00
Raised: $0.00 Goal: $5,000.00
Andrew Breitbart's relentless pursuit of the truth has forever shaped America, and for the better. A voice for
the voiceless, his life's work was a bold proclamation of the power of an informed citizenry that holds
government accountable to those it serves. His tireless efforts empowered patriotic people to engage in
public policy and critically analyze the world around us.
Although he is no longer with us, Andrew's legacy lives in every individual who seeks what is just and
what is right. In his honor, friends and admirers intend to establish a scholarship fund to sponsor
enterprising investigative journalists and bloggers who, like Andrew, understand the,immeasurable affect
citizen journalism has in public discourse and policy-making.
As arrangements are made for this scholarship, we invite you to pledge a contribution-- any amount helps--
for our cause. We will be in touch soon with details on making a donation in his honor. Thank you in
advance for your generosity and your continued support for the values championed by our beloved friend,
Andrew Breitbart.
ACT NOW. If you donate $55 or more, you will be sent a commentative Remember Breitbart shirt.
https:llsecure.piryx.com/donate/c97AfwVcfRemembering-BreitbartJ 115
1/16/2014 National Bloggers Oub Breilbart Scholarship:: Remembering Breitbart - Piryx
lk One person likes this. Be the first of your friends.
Payment Information
E-Check
-, Visa
I =I Mastercard
'-I Amex
~ Discover
Routing Number
I
Account Number
r-::-
I .: l ~ S lQi? 12S&.E,QS?"
I I
I ROUTING NUMBER (9 DIGITS} I ( ACCOUNT NUMBER )
Billing Information
I I Same as home address.
Billing Address
I I
Billing Address (line 2)
City
I
State
I : I
Zip/Postal
I ]
I want to publish my name to the National Bloggers Club Breitbart Scholarship giving stream! (Note:
your contribution amount will not be shown)
Submit II
By clicking submit you agree to our refund policy in our tenDS of service.
National Bloggers Club, Inc. is a 501(c)(3) -- status pending.
p ryx
Tt1
htlps:l/sec ure. piryx.comldonate/c97AfwVclRemembering-Breitbarti 4/5
-' www.guidestar.org/SearchResults.aspx
:ream your iTune
l
GUIDESTAR:
_lIl,1,
Donate to GuldeStar Products News Blogs About Us Contact Us Help My Account r:;:;t
Wolcom. Gu..U SlRn In I CM' Account Upd t Nonprofit Report Anelyu Nonprofit Om Give to Charity Rovlew A Charity
SearchGuideStar I
Home> Se.rch Results
Your search for National Bloggers Club produced 0
results. Donate
VieWing 0 0 of 0 results
Did you mean: National loggers Club
Remove Criteria:
Keywords: Nal!onalll!ooocrs Clyb
No results were found.
Organization Name
Organization Name
Powered By:
:fas
Detans
Detans
the nonprofit for aK nonprofits
[() GuidcStar
Sort Results By I : l
Sort Results By I Relevancy
----'----
1/16/2014 BREAKING: Demand fur National Bloggers Oub Accountability NolV Bipartisan I Osborne Ink
BREAKING: Demand For National Bloggers Club Accountability Now Bipartisan
Tweet 18 l,> Cl " C ( Ems. I 8+1 2 "Share
Ali Akbar (right), founder and President of the National Bloggers Club, is a Karl Rove
favorite with a criminal record. Worse, he kept that record hidden from donors from
2008, when he was convicted, until May of this year, when his probation expired. In the
meantime, he has repOltedly been asking NBC donors for sensitive personal information -
without meeting any of the transparency requirements and standards for such
organizations.
Along with the anonymous Breitbart Unmasked website, Bill Schmalfeldt of The Liberal Grouch.com
publicized Akbar's criminal record. While investigating the National Bloggers Club, Schmalfeldt found that
Akbar and company had never actually applied for 501(C)(3) charitable nonprofit status. His queries to the IRS
have apparently sparked an investigation by that agency, and Schmalfeldt now says he has made a formal
complaint to the Federal Trade Commission as well.
Schmalfeldt's requests for comment on Twitter and in email have met with a stone wall of resistance, but that
dam may finally be breaking. In June, conservative blogger Paul Lemmen called foul on the National BlQggers
.cluh. SQ did Ladd Ehlinger, Jr., the conservative blQgger and filmmaker knQwn as FilmLadd. With Sinclair
nQW joining them, a bipartisan critical mass is forming.
At his website tQday, Schmalfeldt is asking fellQw bloggers from all sides tQ demand that Ali Akbar, the
NatiQnal Bloggers Association, and Vice & Victory Agency immediately publish:
The names of every NatiQnal Bloggers Club BQard member including the date each became associated with the
NBC;
A complete financial report showing the amounts of all mQnies paid to in contributions; services, Qr
spQnsQrships made to NBC or BlogBash;
A complete financial repQrting Qf all funds paid out by NBC or BIQgBash including the names of thQse receiving
said payments and the reasons for each;
A complete financial accQunting Qf all funds paid out by NBC/Blogbash including an accounting of what the
payments were for .and if they were made for the persQnal benefit of Ali Akbar or any other member Qf the NBC
Board;
A complete accounting of all cQntributiQns made to the Breitbart Scholarship Fund as well as an accQunting of
all disbursements Qf said funds as well as the name of the financial institutiQn(s) where contributiQns are Qn
deposit;
A statement as to Bill Murphy's past and current connections with NBC and BlogBash; whether Murphy has
been involved in any NBC/BlogBash activities and or promotions since becoming the Qfficial SQcial Media
Director for the Romney/Ryan campaign;
-
'-.1
http://www.osborneink.com/2012/08/breaking-demand-for-national-bloggers-club-accountability-now-bipartisan.html 1/3
1116/2014 BREAKING: Demand For National Bloggers Oub Accountability Now Bipartisan I Osborne Ink
The IRS 50l(c)(3) documents confirming the belowstated claim by NBC:
National Bloggers Club is a new 501(C)(3) founded by top new media operatives, bloggers and
journalists as a loose association of bloggers who are for free enterprise and limited
government and to advocate on bloggers behalf.
INDICTMENT NO. t052lS08 [)
INnmNAME AND BY Al1JlfORITYOf' nmSTATEOF11lXAS:
11DGRAND.R1IlORS OFTAIUtAHI' COCNIY. lUAS,
eIoeted. Iried. empaneIc:d, swom. and dwJcd 10 of offen- <:ommined in T_<AuDry, in
Swe of TcxlS, upon their 0IlIha do praenlin and to the
CRIMINAl DISTRICTCOURTNO.2
of Aid CouDty lhaI AU AKBAR, hereinafter called DefendaIK. in the Couocy ofTamDl MId Swe aforaaid, OD or
aboul the 411I day ofNovemba' 2006. did
UNU.WFUU.YAPPROPRIATE. BY ACQUlRlNO OR O1lII!ItWlSB IlXERC1SINGCONTllOLOVER
PR.OPERTY, TO-WIT: FIVEMP3 PLAVERS. TWENTYen.. 11IRJ!ECAMCORDERS. TWODVD
PLAVERS. ONEBACKMASSAGER. ONEa.oac. R>UIt SHDlTS. TWO BELTS AND APIECE OP
LUGGAGE" OF11tE VALUEOFS1500 ORMORE Bur LESS mANS20,OOO wrmIN'I1!NTTO DEPRIVE
THE OWNER, QUETACALVDLO. OP11tEPROPERTY. AND AIl.OP11tE SAID PROPIlRTY WAS
OBTAINEDPURSUANTTO ONE SOIEME ORCOIImNUINGCOU1tSEOFCONDUCTWHIaf BEGAN
ON OR ABOUJ' NOVEMBER 1,2006 ANDCONTINU1lDumn. ON ORAIlOUI' NOVEMBER29,2006.
Rally For Roger: Legal
Defense Fund Created
For Legal SchnauzM
William Hoge's Downfall EXCLUSIVE: RogM
Shuler Arr9llt Scene
Photos (VIDEO
UPDATE)
Austin Smith Clem Must
Be Kept Away From
Children
Tweet 18 Llku 0 ., I 0 l Email J 8+1 2 iJShare
About Matt Osborne
Veteran blogging the culture wars from Alabama. Video journalist, mash-up artist, aspiring novelist, and metalhead. Expect
bUlIlues, geekery, dark humor, and snark)' empirical analysis to annoyidealists of an stlipes. You can followme onT\\ltter. but
be ready 'cause it might get loud.
Viewall posts bv Matt Osborne -..
http://www.osborneink.com/2012/08/breaking-demand-for-national-bJoggers-club-accoul1tability-now-bipartisan.hlJul
A.
ff)
(\
r\
.S . . . .
Any Information copied from such Reports and Statements may not be sold or used by any person for the purpose of soliciting contributions
or for commercial purposes. other than using the name and address of any political committee to solicit contributions from such committee
~ NAME OF COMMITTEE (In Full)
Conservative Action Fund
Full Name (Last. First. Middle n ~ j a J
Transaction 10: 88218.4111
Vice & Victory Agency LLC Date of Disbursement
M M 0 D Y Y Y
Mailing Address
I I
06 20 20 1 1
City State Zip Code Amount of Each Disbursement this Period
Fort Worth TX 76137
.-
Purpose of Disbursement
7400.00
Web, technology. marketing consulting
001
,
Candidate Name Categoryl
Type
Office Sought: House Disbursement For:
Senate Primary General
President Other (specify) y
State: District:
A.
SCHEDULE B (FEe Form 3X)
Use separate schedule(s)
FOR LINE NUMBER:
[PAGE 7 . ~ ~ _
(check only one)
ITEMIZED DISBURSEMENTS
for each categOt)' of the
X 21b - - - .... 25 r-- 26
Detailed Summary Page
22 23 24
l- I-- ~
-
I- ~
27 28a 28b 28c 29 30b
Any Information copied from such Reports and Statements may not be sold or used by any person for the purpose of soliciting contributions
or for commercial purposes. other than using the name and address of any political committee to solicit contributions from such committee
~ NAME OF COMMITTEE (In FuU)
Conservative Action Fund
Full Name (Last. First. Middle Initial)
DB Capitol Strategies PLLC Date of Disbursement
M'M 0 D Y Y
y ~ v
Mailing Address
PO BOX 1
I
05 1 4 2 0 1 1
City State Zip Code Amount of Each Disbursement this Perioo
Washignton DC 20013
1350.00
Legal services
001
- ~
Candidate Name
Category!
Type
, .
"., --_._-_._----- '--------
Office Sought: House Disbursement For:
Senate Primary General
President Other (specify) ..
State: District:
c.
I
Full Name (Last, First, Middle initial)
Vice & Victory Agency LLC
Date of Disbursement
. '".:'
- --
M M : 0 0 'I Y Y Y
Mailing Address
I
05 1 4 20 1 1
..
City State Zip Code
Amount of Each Disbursement this Period
Fort Worth TX 76137
"
8400.00
Web. technology, marketing consulting
001
-
Candidate Name
Category!
Type
Office Sought House Disbursement For:
. Senate Primary General
President Other (specify) ..
Stale: District:
1/16/2014 PICKET: FLA Congresswoman leads '07 member effort demanding Swat-ting investigation from DOJ - Washington Times
PICKET: FLACongresswoman leads 87 member effort
demanding Swat-ting investigation from DOJ
<- return to Water Cooler
PHILLIPS: Michelle Obama -
Aqueen comes to town
FISIIER !:-:VESTMDlT
WESTWOOD: Republicans
can win the war on poverty
ISTOOK: IRS to get 'license
to kill' groups that oppose
Obama agenda
,. Ctick here to download
Ready to Rebuild Your Retir1!ment?
If you have a $500,000 portfoho, download
the guide by Forbes columrust and money
manager Ken FISher's firm It s called 'The
15-Minule Retirement Plan.' Even if you
have somethIng else In place right now, it
stili makes sense to request your guideI
YOU MIGHT ALSO LIKE
WRIGHT: Thug life - Who's
your daddy? Apparently, no
one
June 10,2012, 11 :58PM
Congresswoman Adams is a first term Capitol Hill lawmaker and has a
military and law enforcement background. Following her time in the Air
Force, she served for seventeen years as a deputy sheriff in the Orange
County, Florida.
"We were dispatched from 911 calls where there were shots fired and
holding of a hostage. Those were the things that you went to and you're
going to want to know that," she said.
"My concern is someone is going to get hurt," Rep. Adams told me on
Friday. "It's very dangerous for the people living in the home that didn't
call 911, because they have no awareness whatsoever that something
like that had happened. So they open the door to law enforcement
whether it's with or without guns drawn.'
The SWAT-ting issue caught the Florida Congresswoman's attention
when she heard that CNN contributor and Red State blogger Erick
Erickson was a victim of a swat in late May. Another bragger who was
SWAT-ted, Patrick Frey, a Los Angeles assistant district attorney, went
through the terrifying experience in july of 2011.
"It's a danger to the law enforcement agency that is being sent there,
and it's also a danger to the people in the community, because you're
pulling people away from what could be a real emergency."
Congresswoman Sandy Adams, Florida Republican, sent 8 letter on
Monday, signed by 87 House Republicans, to Attorney General Eric
Holder urging him to assign Justice Department officials to investigate
the recent threat of "SWAT-tings." (Scroll further down for letter in bold)
A SWAT-ting happens when a person calls 911 emergency dispatch
services under another individual's name and falsely claims he or she is
committing a violent crime. Such an act is committed to cause local law
enforcement authorities (like a SWAT team) to surround and enter the
residence of an innocent Individual, who was Impersonated and framed
for a violent crime through the 911 call. The false call can be made via
the internet, so as to mask the true caller's Identity and location.
15 SIZE: + I - PRINT
By Kerry Picket The Washington Times
Mike Huckabee wants to
outlawthe word 'RINO' in
the name of GOP unity
Moment of mirth:
Americans admire Rush
Limbaugh more than
Hillary Clinton
Fed up tea partyand
consen'ative critics attack
Jolm Boehner over
'ideologically bankrupt'
GOP
RECENT ENTRIES
President Obama's
proclamation for
'Religious Freedom Day'
recognizes atheists and
agnostics
Neh\urks offer 44 times
more coverage to
Christie's traffic woes
than to IRS targeting of
conservative groups
2/10
JAMISON: Emancipation
Proclamation vs. Democrat
slavery
"Years ago, when someone dialed 911 from a hard line, you could figure
out where it was coming from. With mobile lines you can pretty much tell
where it's from, but when you have a Voice Over Internet Protocol
(VOIP), it's apparently making it a lot harder to do this," said Adams.
House members on the letter to AG Holder join Senator Saxby
Chambliss, Georgia Republican, and Rep. Kenny Marchant, Texas
Republican, who previously called on the attorney general to investigate
the recent spate of swat-tings.
"81oggers shouldn't be targeted for exercising their first amendment
right. It isn't right these folks are being subjected to swat-ting," said Lisa
Boothe, Rep. Adams's press secretary, who pointed out that the Florida
GOP'er wants to protect first amendment rights on this issue as well.
Adams collected a little over 80 House signatures for her letter last
http://www.washingtontimes.com/blog/watercooler/2012/jun/10/picket-fla-congresswoman-leads-errort-demanding-sw/
1/16/2014 PICKET: R-A CongresslVoman leads 87 member effort demanding Swat-ting investigation from DOJ - Washington Times
Friday afternoon from her colleagues on the House floor during votes, a
task rarely accomplished in such a short period of time before the
weekend of a recess week. Members are known to dash out of the Capitol after final votes are taken
at that particular period.
"I hope that the Attorney General takes a very hard and close look at this, because it's putting our
citizens at risk and in danger-because they're having people arrive at their house with heightened
awareness-because they had a 911 call with a report of shots fired or holding people hostage or
whatever the quote-unquote 911 call was for," Rep. Adams explained.
Some wonder if Mr. Holder will take the swat-ting issue seriously enough to take action on it through
the Justice Department, as the Obama Justice Department is known for not responding to members'
requests for information in a timely manner often.
AG Holder appeared before the House Judiciary Committee last Thursday and was questioned by
members about a range of issues from the failed ATF gun walking program Fast and Furious to
Voter ID. Committee members remain concerned Mr. Holder will not comply with a SUbpoena to
release documents pertaining to Fast and Furious and the AG could face contempt of Congress as a
result.
Other congressmen from both sides of the aisle asked AG Holder why he had not responded to their
requests of him on other concerns. Congressman Jerry Nadler, New York Democrat, appeared
aghast when AG Holder would not definitively commit to releasing a legal memo and copy of a
briefing, which Mr. Nadler requested from DOJ previously, regarding the lethal targeting of U.S.
citizens who are terrorists.
Congressman Louie Gohmert, Texas Republican, grilled AG Holder over DOJ's refusal to release
documents Gohmert's office requested one year ago pertaining to the Holy Land Foundation trial,
which the Justice Department only made available to convicted terrorists, according to Mr. Gohmert.
Rep. Adams observed that Holder committed himself, in the same hearing, to helping law
enforcement do their jobs effectively.
Adams asked, "Didn't [AG Holder] say he was looking towards doing things that would help protect
law enforcement and that would help protect our communities from crime?"
"That is his job. He's the head law enforcement officer in our country, and he wanted to make sure
that our laws are being obeyed."
She added, "He needs to make sure that our citizens are protected in a way that protects them from
dangerous things such as SWAT-ting."
Mr. Frey described his swat-ting experience on his blog "Patterico's Pontlflcatlons": (Listen to
hoax 911 call here)
When I opened the door, deputies pointed guns at me and
ordered me to put my hands in the air. I had a cell phone in my
hand. Fortunately, they did not mistake it for a gun. They ordered
me to turn around and put my hands behind my back. They
handcuffed me. They shouted questions at me: IS THERE
ANYONE ELSE IN THE HOUSE? and WHERE ARE THEY? and
ARE THEY ALIVE? I told them: Yes, my wife and my children are
in the house. They're upstairs in their bedrooms, sleeping. Of
course they're alive.
"I recognize it as being dangerous and I would hope the Attorney General recognizes it as being
dangerous. He needs to focus on how we stop this from happening before someone gets killed from
it," said Rep. Adams.
HAPPENING NOW
Glenn Beck to pay
'sanctimonious' critic to face
'Lone Survivor's' Marcus
Luttrell
Light saver: Spending bill
throws lifeline to
incandescent bulbs
NAPOLITANO:Obama
mocks Catholic nuns for
resisting Obamacare
contraception mandate
COMMENTARY
MILLER: Gun rights reload in 2014,
concealed carry reciprocity back in
Congress
By Emily Miler
A Texas shoolout belWeen John Cornyn and Steve
Stockman for Senate
NAPOLITANO: Obama mocks Catholic nuns for
resisting Obamacare contraception mandate
EDITORIAL: Hackers finding Obamacare website a
tempting target
EDITORIAL: Benghazi murders were preventable,
the White House coverup shameful
HANSON: The cowardice of politically correct anti-
semitism
mJ telldc
Citizen town hall
From Woshu.gtoll TUlles, powered by TellDC
TODAYS QUESTION:
Susan Roberts @ Congressman Gnmm
Congressman Grimm- Do you believe Govemor
Christie handled the New Jersey bridge scandal
appropriately?
'A..olT 1K 161 II' VOTe
PREVIOUS QUESTION:
Adam Dorin, M.D @ Congressman CartBr
How will Republicans refashion healthcare if they
take control of Congress and the Vv1lite House?
OFFICIAL VIDEO RESPONSE:
VIDEO - Rep. Carter
responds to Dr. Adam
Dorin's question about the
GOP plan for healthcare.
play video "
Vetel'3ns Advocate: Budget Bill Is 'Total Betrayal'
Liberal Michael Wolff: Ailes Book 'Quite Absurd'
NFLQB's Wife Forgets AR-15 in Rental Car
Malki n: Why Racists Attacked Black Sitcom Star
Obamacare Shocker: Will Heirs Be Liable?
1116/2014 PICXET: FLA Congresswoman leads f57 member effort demanding Swat-ting investigation from DOJ - Washington Times
Last week we spent a Jot of time writing about Brett Kimberlin and
the incident involving blogger Patterico where someone spoofed
his phone number and told 911 he had shot his wife. Tonight, my
family was sitting around the kitchen table eating dinner when
sheriffs deputies pulled up in the driveway. Someone called 911
from my address claiming there had been an accidental shooting.
Heart Tip: Daily Vitamin May Lower Blood
PresSlll'e
Senion;: Increase Social Security Payouts With
Weird Trick
RateObama's Prcsidency- Vote Now
lMlal's This?
WATER COOLER ARCHIVES
"I hope the Attorney General's office will take a very close look at this-look into what's happening-
look into the rationale behind it-look into who is doing it and if there is any federal law that is being
violated [by individual(s)] .. ." said Rep. Adams ".. then DOJ will have to work to have them brought to
justice."
On the evening Red State blogger Erick Erickson posted that the was a victim of a swat-ting, he
pointed out that he previously contacted his local police department about the issue of swat-ting and
that the nature of his work may provoke individual(s)to attempt to swat him.
Fortunately, as a result of Mr. Erickson's actions, no one was hurt. Rep. Adams made it clear that
DOJ should also make it a priority to reach out to local law enforcement departments to spread
awareness about what exactly swat-ting entails. Other bloggers began to wonder if they should do
the same by contacting their local law enforcement authorities.
"It's their responsibility to reach out to the law enforcement agencies and law enforcement
communities and make them aware of what's happening. Now whenever you do this, you cannot
expect a law enforcement officer who sees a 911 call not to respond in the manner in which is
required, so making them aware of it, making dispatch aware of the fact when they get Voice over
Internet Protocol call, but that does not mean that everyone of those Voice over Internet calls is
going to be a false call, because a lot of people in their homes have those. So the police are going to
have to respond in a way in which they are trained."
June 11,2012
The Honorable Eric Holder
U.S. Attorney General
U.S. Department of Justice
950 Pennsylvania Avenue NW, Suite 5111
Washington, D.C. 20530-0009
January 2014
November 2013
September 2013
July 2013
May 2013
March 2013
January 2013
November 2012
September 2012
July 2012
May 2012
March 2012
January 2012
November 2011
September 2011
July 2011
May 2011
March 2011
January 2011
November 201 0
September 2010
July 2010
May 2010
March 2010
January 2010
November 2009
September 2009
July 2009
December 2000
December 2013
October 2013
August 2013
June 2013
April 2013
February 2013
December 2012
October 2012
August 2012
June 2012
April 2012
February 2012
December 2011
October 2011
August 2011
June 2011
April 2011
February 2011
December 2010
October 2010
August 2010
June 2010
April 2010
February 2010
December 2009
October 2009
August 2009
June 2009
Dear Attorney General Holder:
We write you concerning the growing threat of "SWAT-ting" and its
costly ramifications. These crimes occur when individuals call
emergency dispatchers under the guise of another person's name
with fraudulent claims, causing local law enforcement to swarm
the home of innocent Americans. SWAT-ting first arose in 2002,
but as technology and the Internet has expanded, the dangers of
SWAT-ting are also on the rise.
Investigators have concluded that the majority of SWAT-ting cases
utilize voice over Internet (VOIP) connections between the
suspect's computer and a distant telephone network, and then
dialing 911. This enables the suspect to falsify their identifying
information, such as their telephone number and address, and
make it nearly impossible for emergency dispatchers to identify or
track the true origin of the call, or even pin-point calls from VOIP
connections.
Some of these calls involve embellished schemes, including
armed suspects and hostages, and in some instances, the caller
claims that he has just killed someone. Moreover, the caller
knOWingly uses the identifying information of another person, who
is usually an adversary of the caller. This elaborate hoax is all
done with the goal of having law enforcement swarm the home of
00 You Think the Market
Is Headed for a Fall?
If you have a $1,000,000 portfolio, you
should download the latest report by
Fames columnist Ken Fisher. In it he tells
you Where he thinks the stock market is
headed, and Why. This must-read report
includes his latest stock market prediction,
plus research and analysis you can use In
your portfolio right now. Don't miss itl
Click Here to Download Your Report!
L.- FrlHU IHVUnclHf1-
Most Read Most Shared Most Emalled
MILLER: Harvey Weinstein and Meryl Streep
making movie attacking NRA
Inside the Ring: Moscow creates 1,500-mile
security zone around Sochi
Senator recounts personal run-in with drone
Dolphins QB Ryan Tannehill's wife leaves AR-
15 in rental car
NAPOLITANO: Obama mocks Catholic nuns for
resisting Obamacare contraception mandate
MILLER: Gun rights reload in 2014, concealed
carry reciprocity back in Congress
BENGHAZI W/>S PREVENTABLE: Hillary
Clinton cited for major security lapses
hltp:/Iwww.washingtontimes.comlblog/watercooler/2012/jun/lO/picket-fla-congresswoman-leads-effort-demanding-sw/ 4/10
1116/2014 PICKET: FLA Congresswoman leads '67 member effort demanding Swat-ting investigation from DOJ - Washington Times
the caller's foe, which only incites fear in and tarnishes the
reputation of an innocent person.
Even worse, SWAT-ting is quickly becoming a scare tactic used
against political bloggers, essentially stifling those bloggers' First
Amendment rights. Just last month, a popular blogger in the state
of Georgia, Erick Erickson, became the latest victim of SWAT-ting.
During the Erickson's family dinner, sheriff's deputies were
dispatched to Erickson's home after receiving a 911 call reporting
an accidental shooting that appeared to have come from
Erickson's address. Fortunately, Erickson previously alerted police
to SWAT-ting tactics; however, numerous similar scenarios have
ended with gUiltless victims held at gunpoint.
While none of the SWAT-ting victims have incurred physical harm
from these hate filled ploys, we are gravely concerned that future
victims may not find themselves so lucky. Plus, when law
enforcement officers are responding to SWAT-ling claims,
resources are diverted from those truly in need-all of this
because of differences in political ideology.
Differences of opinion should enrich our lives, not divide us. Each
American has the right to freely express his or her ideas and
should not be subject to fear tactics like SWAT-ting, which run
counter to the liberty that forms the bedrock of our great nation.
These crimes are not to be tolerated and necessitate thorough
examination at every level.
We urge you to hold true to those promises and work to ensure
that criminals using fear in hopes to preventing others from
exercising their First Amendment rights are held to the highest
standard of the law. To this end, we implore you to thoroughly
review each of these cases, determine whether any federal laws
have been breached, and prosecute those crimes accordingly.
Sincerely,
Sandy Adams (R-FL)
Tom Graves (R-GA)
Louie Gohmert (R- TX)
Trey Gowdy (R-SC)
Jim Jordan (R-OH)
Trent Franks (R-AZ)
Andy Harris (R-MD)
Steve Southerland (R-FL)
Joe Walsh (R-IL)
Paul Broun (R-GA)
Lynn Westmoreland (R-GA)
Bob Goodlatte (R-VA)
Morgan Griffith (R-VA)
Chip Cravaack (R-MN)
Jason Chaffetz (R-UT)
Phil Gingrey (R-GA)
Dan Burton (R-IN)
Cathy McMorris Rodgers (R-WA)
Leonard Lance (R-NJ)
Jeff Duncan (R-SC)
Jaime Herrera Beutler (R-WA)
Daniel Webster (R-FL)
Allen West (R-FL)
Dennis Ross (R-FL)
Richard Nugent (R-FL)
http://www.washingtontimes.comlblog/watercooler/2012/jun/lO/picket-f1a-congresswoman-leads-effort-ctemanding-swl
u.s. pilot scares off Iranians with 'Top Gun'-
worthy stunt: 'You really ought to go home'
Bada Bing! Chris Christie's team accused of
'mafia-esque' rule over New Jersey
Light saver: Spending bill throws lifeline to
incandescent bulbs
5/10
1116/2014 PICKET: FLA Congresswoman leads 87 member effort demanding Swat-ting investigation from DOJ - Washington Times
Ben Quayle (R-AZ)
Tom Rooney (R-FL)
Todd Rokita (R-IN)
Renee Ellmers (R-NC)
David Reichert (R-WA)
Ileana Ros-Lehtinen (R-FL)
Mary Bono Mack (R-CA)
Adam Kinzinger (R-IL)
Cory Gardner (R-CO)
Michael Grimm (R-NY)
Ann Marie Buerkle (R-NY)
Don Manzullo (R-IL)
Bob Turner (R-NY)
Jon Runyan (R-NJ)
Don Young (R-AK)
Mike Kelly (R-PA)
Tom Marino (R-PA)
Lamar Smith (R- TX)
Marsha Blackburn (R- TN)
Michele Bachmann (R-MN)
Jeff Fortenberry (R-NE)
John Kline (R-MN)
Mo Brooks (R-AL)
Austin Scott (R-GA)
Pete Olson (R-TX)
Scott Desjarlais (R- TN)
Vicky Hartzler (R-MO)
Ted Poe (R-TX)
Patrick McHenry (R-NC)
Alan Nunnelee (R-MS)
Candice Miller (R-MI)
Mark Amodei (R-NV)
Kenny Marchant (R- TX)
Sue Myrick (R-NC)
Todd Akin (R-MO)
Randy Forbes (R-VA)
Paul Gosar (R-AZ)
Diane Black (R- TN)
Jeff Landry (R-LA)
Steve Stivers (R-OH)
Randy Hultgren (R-IL)
Mike Pompeo (R-KS)
David Schweikert (R-AZ)
Bill Posey (R-FL)
Steve Chabot (R-OH)
Quico Canseco (R- TX)
Bill Johnson (R-IL)
Pete Sessions (R- TX)
Tim Griffin (R-AR)
Walter B. Jones (R-NC)
Lynn Jenkins (R-KS)
Billy Long (R-MO)
Steve Scalise (R-LA)
Stephen Fincher (R- TN)
Jack Kingston (R-GA)
Scott Rigell (R-VA)
Tom Price (R-GA)
Robert Hurt (R-VA)
Jeff Miller (R-FL)
Bill Huizenga (R-MI)
Steve King (R-IA)
http://www.washingtontimes.com/blog/watercooler/2012/jun/lO/picket-fla-congresswoman-leads-effort-demanding-sw/ 6/10
MONDAY, JULY 2, 2012
The Story I Couldn't Tell, Part II: Brett
Kimberlin's Latest Petition for a Peace
Order
Well, yes, I have suggested that people such as George Soros,
Teresa Heinz Kerry and Barbra Streisand all stop donating to
Brett Kimberlin's organization, but in fact that is protected
speech. Seriously, are people under the impression that you
cannot recommend or recommend against donating to a specific
charity?
Aaron Walker's personal blog
http://allergic2bull.blogspotcom/2012/07 /story-i-couldnt-tell-part-ii-brett.html
htt: socie ;bytes.word ress.com 2012 05 24 weakell-brett-kimberlin-b '-
oin -after-barbara-streisand-teresa-heillz-kerrv- eor e-soros-alld-eve rone-
'\'ho-backs-kimberlin-\vith-flnallcial-dollations
Weaken Brett Kimberlin By Going After Barbara
Streisand, Teresa Heinz-Kerry, George Soros
And Everyone Who Backs Kimberlin With
Financial Donations
crime. politics terrorism May 24} 2012 12:38 pm
Freedom of speech is under assault in America by liberals, radicals,
Leftists, and known convicted terrorists like Brett Kimberlin,
whose anti-America agenda is being funded and financially
supported right now by some of the most well-known Americans.
However, instead of attacking terrorist Brett Kimberlin directly,
which many bloggers have found to be a dangerous inethod, go
after those people who are supporting him through financial
donations either directly or through his Justice Through Music
Project. Hammer Streisand; hammer Heinz-Kerry; hammer Soros.
These people know what they are doing; they know who they are
donating money to; they know they are contributing their money to
a known and convicted terrorist. However, there are many people
who donate money via Brett Kimberlin's JTMP who may
legitimately not know that the money they are contributing is
actually going to help fund Kimberlin's radical anti-American
agenda. The JTMP, which, in its "About" page, does not mention
Kimberlin as one of the founders (and probably for obvious
reasons) is a radical, left-wing, "Occupy" movement supporting,
anti-capitalist feeding trough for other liberals, socialists and
Leftists who want to transform America into a totalitarian Left-
wing autocracy. By positioning and setting itself up as a website
dedicated to "music" it entices, and entraps young teens into a
world of liberal activism, pretending to be, and disguised as, a
website that uses music merely to promote voter registration
among America's youth.
We must be vigilant, courageous and persistent in demanding
Kimberlin's backers (especially those like Streisand, Kerry and
Soros who are public celebrities) be held accountable for their
wicked, sinister and corrupt actions.
We must demand, directly, why Barbara Streisand supports a
known convicted terrorist. Why then, Barbara Streisand,
do you support a known convicted terrorist, Brett Kimberlin? Since
Streisand remains silent, we must accept Streisand supports the
type of terrorism that Kimberlin has conducted.
We must demand, directly, why Teresa Heinz-Kerry supports a
known convicted terrorist. Why then, Teresa Heinz-Kerry,
do you support a known convicted terrorist, Brett Kimberlin? Since
Kerry remains silent, we must accept Kerry supports the type of
terrorism that Kimberlin has conducted.
We must demand, directly, why George Soros supports a known
convicted terrorist. Why then, George Soros, do you support a
known convicted terrorist, Brett Kimberlin? Since Soros remains
silent, we must accept Soros supports the type of terrorism that
Kimberlin has conducted.
We must demand directly, why the Democrat Party has opened
itself up and invited Brett Kimberlin into its fold. By not rejecting
Kimberlin, by not distancing itself from Kimberlin, by not
renouncing Kimberlin, the Democrat Party is guilty of supporting
this known convicted terrorist. Therefore we must accept that the
Democrat Party, because of its silence, supports the type of
terrorism that Kimberlin has conducted.
If a known convicted terrorist was ever outed to be a conservative,
and to have infiltrated the republican Party; if well-known
conservative activists had ever donated money to such a person
and the liberal MSM ever got hold of that information - what the
hell does anyone think the response to that would be?
Barbara Streisand supports terrorism as long as it is directed at
American capitalism and meant to thwart conservatism.
Teresa Heinz-Kerry supports terrorism as long as it is directed at
George Soros supports terrorism as long as it is directed at
The Democrat Party supports terrorism as long as it is directed at
The lIJustice Through Music Project", which may be a shill non-
profit organization with a hidden agenda, supports terrorism as
long as it is directed at American capitalism and meant to thwart
conservatism.
What other conclusions can we draw?
Hammer the donors, publicly expose them, and the finances
Kimberlin needs to continue his operations will dry up. Or, does
Barbara Streisand think she can bolster her image among her fan
base when her fans know she is contributing her money to a known
convicted terrorist? Does Teresa Heinz-Kerry think she can bolster
her image, and help her husband's (John Kerry) image by
contributing her money to a known convicted terrorist?
American who support terrorism directed against America are
traitors. What does that tell you about Streisand, Kerry, Soros and
all the others who support a known and convicted terrorist, Brett
Kimberlin?
MONDAY, JULY2,2012
The Story I Couldn't Tell, Part II: Brett
Kimberlin's Latest Petition for a Peace
Order
Well, yes, I have suggested that people such as George Soros,
Teresa Heinz Kerry and Barbra Streisand all stop donating to
Brett Kimberlin's organization, but in fact that is protected
speech. Seriously, are people under the impression that you
cannot recommend or recommend against donating to a specific
charity?
Aaron Walker's personal blog
http://allergic2bull.blogspot.com/2012/07jstory-i-couldnt-tell-part-ii-brett.html
FBI meeting
Thu, Dec 2011 at 7 25 PM
gmail.com>, Aaron Worthing
gmaiLcom> Mike Stack
Patrick Frey mail. com>
_
0 tibe ..rt ChICk.. gmall.com>., Dustin F
@gmal .com>, 0 gla5 Stewart
yahoo. com>
Met with the Oatlas FBI today in person, as well as a cyber crimes
Assistant U.S Attorney. One of the agents reads my blog and Ace's and
has heard of Mandy. He was already familiar with Kimberlin and
generally remembered Ace's and my cO\erage of Wemer and the threat
from AliCia Pain. You couldn't ask for a more appropriate person to
talk to.
They totally understand the swattmQ phenomenon and approached this
like political retaliation, which is what it is. They can't take ~
the case but can give adlAce to the L.A office. They explained that
the phone records actually might take 6 months due to the nature of
the specific informatIon sought. However, he will talk to the LA.
Office to make sure they' are obtall1lng the correct information in the
most efficient manner
I asked what I can personally do to ensure that these people go to
prison. The answer is: if you ha\e a blog, set your settings to gather
the maximum amount of information poSSible. Keep meticuloos records
and notes ~ our screenshots are good,
Ultimately, the goal is to catch the hackers slipping- be able to
trace a criminal act back to a specific computer so they can execute a
search warrant He is more concerned about targeting the computer than
the person. Things like ",ice comparisons and inteNews they would
S3\e for after someone is charged; they would not really consider It
probable cause to ha\e a positive \Oice match, because of how
mconclusi\le it is,
They thought my call sounded like Ron, They thought the 810g Talk
Radio call sounded like the New Jersey call. They said Ron being on
the line with me was a typical MO - they like to be on the phone when
it happens, They think If we can get a search warrant, we will find a
recording of the call on their computers. They like to record the
calls and replay them, HalAng me on the phone was hog heawn for Ron.
they suspect
Basically we ha\e to keep monitoring their IPs and tie a computer not
hidden behind the Tor Project or somethmgsimilar to a crime, I ha\e
a feeling these people would have pursued Ron for his threats to me
and my Wife, but the agent kept stressing that it's not his case and
he can't set LA's priorHies.
He also stressed what we pretty much already knew: the continued
1116/2014 LA Prosecutor Patrick Frey Qmts with Barrett Brown 2
Donale for lhe CQ/Dlome archive ofGles from June 199610 Ihe Dresenl
7 September 2012
LA Prosecutor Patrick Frey Chats with Barrett Brown 2
Part 1:
Barrett Brown sends:
This is the kind of thing that interests this fucking prosecutor after
HBGary caught going after journalists, me, Anonymous, Greenwald, etc.
***
Patrick: How is it that Think Progress is reporting that the Chamber
of Commerce dug up info on Velvet Revolution -- yet we only see
e-mails about Brad Friedman and not about his partner, convicted
bomber Brett Kimberlin?
me: Velvet Revolution?
11:41 PM You and I may use differing terminology
I don't read Think PRess as they get their info from us
Patrick: It's almost as if Think Progress didn't publish the e-mails
about Kimberlin that certainly were sent
me: Nor am I a liberal, remember
one sec
I should note that we've been going over tens of thousands of e-mails
plus docs that Barr wanted to sell to FBI, with my name in them
Patrick: Velvet Revolution is the organization that Brad Friedman set
up with convicted bomber Brett Kimberlin
me: who's this person?
11:42 PM oic
I'll make sure it's run
give me a summary, plz?
Then I'll go through raws and find it all
Patrick: I have written about Kimberlin
me: You know we have an app up by which you can search through all
the e-mails, right?
anonleaks.ru
it goes up and down
we're building mirrors
I'll tell you, though
Patrick: http://patterico.com/2010/10/11/brad-friedmans-partner-and-
bUddy-a-conyicted-bomber-periurer-and drug-smuggler-suspected-murderer-
and-e1ection-integrity-hero/
11:.43 PM me: that I spoke to Tom Callamore on Friday
of the Chamber
and spoke to Aaron Barr on Sunday, right after we jacked his info
and took over HBGary's server
neither did very well
11:44 PM okay, so Kilberlin is a terrorist
and Brad..
okay, how does this involve Chamber?
11:45 PM As I said, I've been kind of busy with the conspiracy against
Greenwald, Wikileaks, and me and my friends
Patrick: Think progress says they were gathering info on Friedman
me: the one done by federal contractors
does this info come from our heist?
Patrick: Yes
me: Ok
who do these people work for, one of the firms?
Patrick: These people? Friedman?
11:46 PM me: Yeah, who's Brad Friedman?
I've got a cast of characters here about a hundred strong
and like I said
we're kind of at war
so I don't know who this is
htlp:llcryptome.org/2012/09/frey-chal-brown-02.htm
Do
=C=-...
--------
1/7
1116/2014 LA Prosecutor Thtrick Frey Chats with Barrett Brown 2
to put it another way
did you do a piece on Greenwald?
Patrick: http://thinkprogress.org/2011/02/10/ch
am
berleaks-target-families/
No
me: You know, this campaign to commit crimes in order to destroy him?
11: 47 PM ok
Patrick: I know very little about it
me: but you want ThinkProgress to cover certain things?
Maybe you should read some different venues
Greenwald's a friend
Patrick: They're going to cover what they cover
me: and even if he weren't
yeah, same with you
right?
Like, I can give you scoops
I've been handing them out like candy to Bloomberg et al
Some of these might even help conservatives
11:48 PM Speaking of which
We're going after Chavez soon
You guys really should consider working with us
Patrick: Feels too . illegal
me: Anonymous is an anarcho-libertarian movement to the extent that
it has politics
101
Would you be willing to work with Chamber of Commerce?
cause they do illegal shit, too
11:49 PM Except they do it to those who've done nothing except for
present opinions
Patrick: Maybe not, depending on what they were doing
me: whereas we do it to people who try to wrongly accuse people to the FBI
I'm assuming you have'nt seen my Guardian piece?
on why we do what we do?
Or the Bloomberg piece on us?
Patrick: The only thing that got my attention about all this was the
angle having to do with the convicted bomber
Nope
me: I'll bet
Patrick: But send the links
11:50 PM me: Look
We're seriously at war here
Patrick: I have limited time and my own reasons -- the bomber has
threatened a lawsuit against me. That tends to get your attention
me: Yeah, and I've got the feds after me
Patrick: He has done much else as well
Yup
So that has your attention
me: plUS several security firms with NSA ties
yes, but we're still on Tunisia
and Egypt
11:51 PM the latter, no thanks to the folks who have decided that
Muslim Brotherhood is behind this
If you look
You'll see that I called Egypt
before it began
the reason is
that we have good intel
and of course are involved
so, regarding those of your friends who are going with MB angle on Egypt
11:52 PM I'd ask them to show where they've gotten results in terms of
predictions, etc
I work directly with Egyptian protest leaders
I didn't use to talk about this shit because no one was going to
believe me anyway
Sorry, I don't mean to be standoffish
We've just had a busy week
Now, as for Friedman
11:53 PM Patrick: Interesting
me: can you summarize who he is, etc?
If you can
I'll put some people on it
Do you know much about Anon?
Patrick: Professes to be an "election integrity" guy.
me: oic
love those types
they were popular in Nicaragua, 101
11:54 PM as P.J. O'Rourke noted back when he was good
Patrick: No, don't do anything with him
Christ
me: No, I'm kidding
wait, what?
http://cryptome.org/2012/09/frey-chat-brown-02.htm 2/7
1116/2014 LA Proseclitor Patrick Frey Chats with Barrett Brown 2
l",lQ.'y.iJO;:: :tv ..... ~ l V U L U 1.,;Q..1....L. .me
Patriok: OK, jokes don't always translate on ohat
me: 512-560-2302
Patriok: Anyway, he is partnered with a oonvioted bomber
me: okay
Patriok: Who wants to sue me
me: so is Obama
11:55 PM Patriok: Not business partners
me: ?
oh
And this is all in the public reoord, right?
Patriok: Friedman is the guy who oredits himself with revealing that
the ACORN videos were supposedly a hoax
Yes
I fought him on it
He and Kimberlin have tried to get me fired
11:56 PM me: okay
for what are they suing you?
or trying to?
Patriok: written numerous posts distorting the faots
me: libel or some shit?
Patriok: For writing about the faot that Kimberlin is a oonvioted bomber
Yes, libel
me: I imagine it's bullshit, right?
Patriok: Kimberlin has oalled my offioe and olaimed I am stalking him
oomplete and utter bullshit
me: heh
that's a funny way to go about it
11:57 PM Patriok: Friedman's assooiation with Kimberlin disoredits him
when people find out who Kimberlin is
So they try to squash it
I'm quite sure the Chamber was interested in Kimberlin if they were
interested in Friedman
So Think Progress portrays Brad as a viotim
But not a word about Kimberlin
Whioh I found interesting
me: I see
Patriok: Anyway, the searoh engine is what I was looking for
11:58 PM me: Do you know what Chamber was trying to do via those other firms?
Patriok: Not really
me: HBGary, eto?
Okay
Patriok: Nope
me: here
http://www.youtube.oom/watoh?v=VSI9L6XNQKI
two minutes
Patriok: The Think progress pieoe sounded to me like they were
gathering sooial media intel
11:59 PM me: heh
no
I have all the e-mails
some of whioh are publio, some of whioh I'm still going through
they wanted to release a fake dooument in suoh a way as that the
unions or some suoh would obtain it
and run it
rather, just watoh this olip
from Friday
12:00 AM Patriok: Oh, I think I did see something about that. Yeah,
that's despioable
me: at any rate, I've never talked to Think Progress
been working with Bloomberg
NYT
al-JAzeera
others
some Japanese TV show
12:01 AM we made the first round of e-mails available for download
first night we got ern
and then media started going through
the thing is
there are a lot of stories here
like, a lot
touohing on NSA and whatnot
I spoke to NSA lady a few days baok
regarding Stuxnet
whioh, thanks to the inoompetenoe of the federal oontraotor orowd
we now have
12:02 AM bottom line is
we're at war
burt
but
I've split my own org into two
1/16/2014 LA Prosecutor Patrick Frey Chats with Barrett Brown 2
one tactlon stays wltn me
the other goes with one of our tops guys and continues overt,
respectable, non-illegal ops
you might look into it at some point
12:03 AM they're trying to build secular, liberty-oriented
institutions in Tunisia, etc
meanwhile
I'm in talks with the fellow who wrote Nepal's constitution
about creating a framework for Tunisia
which I guess is now a confirmed operation although of course this
is in early stages
12:04 AM Jenik Radon is the fellow
this is off the record for now, btw
so
If you have any interest in joining the team
let me know
if you need to verify this stuff
talk to Barry Eisler
12:05 AM ex-CIA directorate of operations fellow
Patrick: I am firmly against doing anything illegal, just so you and
the FBI agents monitoring this chat know
me: now a novelist, commentator
heh
like I said
well, should also note I'm not a hacker
certainly people within state of California engage in crimes?
as in, employees
cops, etc
obstruction
but you're not a criminal
neither am I
Patrick: Yes. I prosecute them if the crimes are bad enough
me: and as I said
12:06 AM of course
anywho, there are a lot of options, totally legal and overt
and the constitution thing
might be up your alley
Patrick: Fair enough. Too bUsy to make much of it now, but thanks for the offer
me: Okay, thanks for considering
now, regarding Friedman
12:07 AM you want us to look through e-mails for that?
12:08 AM Patrick: For what?
me: I don't know, why'd you come to me on this again?
12:09 AM Patrick: Actually, pretty much to ask what you told me: is
there some place on the Web where all this shit is?
me: ah, yes
as I said
Patrick: Because I figure they looked into Kimberlin if they looked
into Friedman
me: anonleaks.ru is shaky
12:10 AM was up all week but been up and down depending on one's location today
if you have problems, let me know
and I'll see what else is available
we actually have a much better version going up soon
trying to find a server for it
Patrick: Also: Think Progress makes it sound like Friedman's home
address was disclosed. They redact it. But Friedman posts an address
on his own damn site that looks like a home address -- a place to send
checks. I wanted to see if that is the address they got
12:11 AM me: ah
yeah, you can see raws via that site
I never download the file itself
as I'm on shitty connection at the moment
Patrick: I'm doing a search and not finding this stuff
12:12 AM me: try a sample search real quick
look up Endgame
I mean, are any searches working?
Patrick: Yes
me: okay
Patrick: Maybe I'm just using it wrong
me: are you sure these corne from us?
12:13 AM our stuff was extracted from HBGary servers
includes messages from other folks only to the extent that they were
e-mailing HBGary folks
Patrick: When I put in "bradley louis friedman los angeles" I get
e-mails that do not have those terms
me: or Aaron Barr himself, as we got all his e-mails
oh
I'd just search Friedman
try that
Patrick: I put that in because Think Proqress listed that as his name
http://cryptome.org/2012/09/[rey-chat-brown-02.htm 4/7
1116/2014 LA Prosecutor Patrick Frey Chats with Barrett Brown 2
and location
me: tell me what happens
12:14 AM wait, give me link to ThinkProgress piece?
Patrick: Yeah, but there are 63 results
me: let me make sure these are ours
you know that to the extent you look around
Patrick: I think I gave it to you up the chat thread, no?
me: you'll find incredible scoops, right?
lemme see
12:15 AM Patrick: Maybe not
me: k
got it
okay, so Think Progress redacted the info for the guy's partner
12:16 AM Patrick:
http://thinkprogress.org/20ll/02/l0/chamberleaks-target-families/
me: this is partner as in gay lover?
Patrick: Don't think so
me: yeah, I got it, you did give it earlier
so what you're saying is that Think Progress intentionally avoided
using the name?
Patrick: I think it's for his "life partner" which is different from
Kimberlin, his business partner
me: of the bomb enthusiast?
Patrick: Right
me: ok
12:17 AM Patrick: Who set off bombs and blew off a guy's leg
More than an enthusiast
Which guy later killed himself
me: yeah, I was being wry, it's very sad
12:18 AM much sadder than anything that hurts conservatives, of course
101
anyway
frankly, I can see why
as an editorial decision
they would keep the info out of the story
even without knowing who the guy is
Patrick: Sure
Doesn't help their cause
me: your background is in law, I guess?
not media
or
it could be what you're saying
12:19 AM there's not going to be any way to prove it by seeing the e-mails
unless I'm missing something
Patrick: They want to make the Chamber look bad. If the Chamber was
gathering info on one of these people being a convicted bomber, that
doesn't help
me: well
right now, Pat
Patrick: well, if they redacted Brad's address which he puts himself
on his site, it makes him less of a martyr
me: the Chamber is known to have looked at gathering intel on people's children
12:20 AM Patrick: It didn't look that way to me
me: it's not like they said, "Oh, just this one guy who bombed someone"
Yeah, but you're not capable of making that call yet
You haven't been going through these e-mails and drafts for a week
Patrick: It looked like they got info on a Chamber guy's children to
show how easy it is
me: 10101010101
no, it doesn't
You need to do your homework on this one
I'll show you in a second
12:21 AM Chamber wasn't trying to show everyone that they need to be careful
for instance
they weren't going to leak that document in order to make the union look bad
just to show how easy it is
or, contrarily
we just hacked into those people's servers in order to show how easy it is
in which case, yeah, I love your take and I'd love you to defend us
12:22 AM 001000100010101011
seriously, though
need to read the e-mails
HBGary specialized in certain things
as did their NSA-affiliated buddies
among those things
Patrick: Hahahaha
me: were trying to break into Greenwald's financial records
Patrick: Found it
12:23 AM me: ah, did you?
on anon1eaks.ru?
ic:: in +hA Tl1,-.lrinN
1116/2014 LA Prosecutor Patrick Frey Chats with Barrett Brown 2
story
link
what
out,
they have been doing
I assure you
me: well, there you go!
aren't you glad we're out there doing our thing?
don't tell me you're not having fun right now
you are
12:24 AM it's fun as shit
and now you've got your
Patrick: Thanks for that
Give me the stuff about
me: oh, happy to give it
who?
12:25 AM chamber?
Patrick: So I can do my homework
Yes
me: K
but they're not the most interesting ones
just the most high-profile
what you want to look at
oh, also
Patrick: I only want links to things that are out there on the Internet
me: of course
Patrick: Remember, FBI agents, I don't commit crimes!
me: http://www.mediafire.com/file/7vb98xu7cobcif2/AaronBarrBarrettBrownLULZ.wma
12:26 AM heh
I can tell you that Bloomberg et al are using stuff that's not out there
we give out favors, remember
we love our friends in the business press
but listen to that recording
before you look into the rest
will give you an overview of how this went down and why
I'll tell you something else funny
12:27 AM we got into all of Aaron Barr's accounts due to him using
same passwords on all of them
except
EXCEPT
for his World of Warcraft account.
he kept that secure
otherwise I'd be playing his character right now
12:28 AM also
when you put up your story
give me link
and I'll shoot it around
12:29 AM Patrick: Big Media publishes all sorts of classified and
other illegal shit that a) they shouldn't and b) I wouldn't dare
me: true
Patrick: As engaging as I find you, I'm not sure we see eye to eye on hacking
me: well
I'm not a hacker
let's put it this wway
I come from a military family
12:30 AM mostly air force
mostly bombers, up until 80s
they all blew up children in fighting fascism and communism
I just help hackers hack things to fight corruption
it's all, like, RELATIVE, man. You're just too, like, ESTABLISHMENT, maaaan.
12:31 AM srsly though
hacking is a very small part of what we do
Anon is chaning
we're into nation-building now
12:32 AM Patrick: I am indeed too establishment, I'll grant you
me: 101
I'm kidding
Patrick: I never wear beanies, for example
me: my second in command is a retired gov't lawyer
12:33 AM dude, I only wear polo shirts
I went to school with Bush kids
all the conservatives have me all wrong
Patrick: YOU WEAR A BEANIE. I'VE SEEN IT
me: oh, that
12:34 AM well
I wear ralph lauren jackets with it
also it's a running gag with Diary of Daedalus
before I befriended that tribe
they talked about my hair a lot
12:35 AM but it's mainly because it's actually snowing in Dallas
and I'm not big on that shit
you lose most heat through your head
and feet
12:36 AM also
anything interesting happen in blogosphere lately?
fights, .drama, etc?
1/1612014 LA Prosecutor Patrick Frey O1ats wilh Barrett Brown 2

Patriok: Nah
12:37 AM me: if he ever fucks with you again
I'll give you certain e-mai1s
101
Patrick. As long as they're not hacked!
me: heh
Patrick: We dId get into again somewhat recently
Maybe a month ago?
12:38 AM me: 101 bout what?
Patrick: Charles Johnson was lying about me to try to get people to
threaten my job
me: oh, I saw that
Patrick: r noted that it was not the first time someone had done that
to me and referenced Goldstein obliquely
me: he lies about me too now
Patrick: He went apes hit
So I proved it
me: really?
12:39 AM so Goldstein took time off from work to attack you, eh?
Patrick. He likes to pretend r went after him on Google and he never did
me: he'll fight you
he wrestles
by my count, he's killed like 300 people so far
assuming he followed through on threats
Patrick: He wrote a post with my name and job title several
actually -- and linked it dozens of times to bump it up on Google
me: ah
well
12:40 AM let me know
Patrick: Since he denied trying to harm me professionally, I laid that out
me: oh, wait
he's already Google fucked
you should see the SAdly, No oompilation
Patriok: Not as bad as me
mel are you?
Patrick: Google Patrick Frey
One of his bullshit posts is on the first page
Regards,
Barrett Brown
512-1...__---'
hnp://cryptome.orgI2012109/rrey-chat-brown-02.htm
patt,e
To_gmail.com
Ha'oe supporting POints ready for anything he questions or wants to hear more about
p
[Quoted lext

The steps are:
1) Get out your pomt
2) Make sure he gets the point
3) Make sure you support anything he indicates you haloen'! proven
p
{Ovoted text hiddenl
Sun, Jan 8, 2012 at 8:30 PM
Sun, Jan 8, 2012 at 8:31 PM
Sun, Jan 8, 2012 at 8:45 PM ....-.mgmall.com

Then it seems like I need to start by asking for the relief. Then go thru hiS crim record".
Sent from my iPhone
IQ\ioted text hidden]
517
10/1/12
Sun, Jan 8, 2012 at 848 PM Patterico
To:
No. You haloe to start with ten seconds of labeling him a con'victed bomber and com,;cled perjurer, and say this is
established by major media stories and by published court decisions. Then say he obtained the injunction by
repeatedly himself and that you can it. It should take only ten seconds or fewer to say that, but
you haw to lead with that
Ethos first. Then logos. Then pathos.
P
Patterico
To: "A.W.
n
Cc: Uberty Chick
Sun, Jan 8
1
2012 at 8: 16 PM
Ifs still way, way t way too long: but a good beginning. You'U get cut off. Decide what the 3-5 top points you want
to make are, and make them aU the first 30-60 seconds. If you get cut off, and you wilt try to get in what you
can.
Good luck. Let us know what happens. Hey Mandy, can \Ye get the attorney seNce on board to pull the audio
ASAP?
1116/2014 Courthouse News Service
Thursday, October 04,2012 Last Update: 1:49 PM PT
/ HOME PAGE IABOUT us : BACK ISSUES i COlUMNS IDARKROOM ) ALMANAC IENTERTAII\MENT LAWIREPORTS rAPPELLATE OPINIONS IMASTHEAD I
1/2
Subscribers
Service News Courthouse

lAProsecutor Allegedly Defamed Woman to ShieldACORN Saboteur
By MATT REYNOLDS
I '" I Tweet g.1 ShareThis
WS ANGELES (CN) - Awoman says in court that a LaiAngeles County prosecutor
defamed her on his blog to silence her daims that conservative activist James O'Keefe had
wiretapped a oongresswoman's office.
Nadia Naffe sued Deputy District Attorney John Patrick Frey who h3S purportedly
known (nonparty) 0' Keefe si nce the mUCkrakel' worked as an intern in the La; Angeles
County District Attorney's Office as a lawschool student
She also names as defendants Frey's wife, Deputy District Attorney Christi Frey;
District Attorney Steve Cooley and the county of La; Angeles.
Naffe, a reported Hat'Vard graduate, says she too was a friend and oolleague of O'Keefe's
until "a frightening incident" in October 2011 when O'Keefe allegedly drugged her in an
attempt to sexually assault her ina renovated NewJersey barn.
At that time, O'Keefe was on three years probation for entering federal property during
an undercover sting onU.S. senator Mary Lundrieu, D-La., the oomplaint says.
A few weeks later, O'Keefe offered to pay her off in return for her silence, aocording to
tile complaint.
Naffe says that O'Keele threatened to sue when she rejec'l:ed his offer.
After filing a eri mi nal harassment complaint agai nst 0'Keefe, NolTe says the late
conservative commentator Andrew Breitbarr, whom she describes as a "personal friend,"
attempted to distort the "barn incident" to discredit her.
She says she challenged Breitbart on 'l\vitter and on her personal blog.
Between February and March 2012, Frey then published dozens of "threatening,
harassing, and defamatory statements" on ']\,ojtter describing Naffe as "a liar, iTIiterate,
callous, self-absorbed, despicable, a smear artist and absurd," accordi ng to her complai nt
Naffe says Frey defamed her because he knewthat she was planning to hand over
evidence that O'Keefe had ,viretapped the office of U.S. Rep. Maxine Waters, D-u\S
Angeles, and the OneUnited offices where the congresswoman's husband worked.
Frey wanted to keep this evidenoo out of the Los Angeles County District Attorney's
office to "protect the repumtions" of O'Keefe and Breitbart, according to the complaint
In March, 0' Keefe sought an injunction against NalIe to stop her from publishing
settlement documents with Isabel Santa, a former member of O'Keefe's Pro.iectVeritas.
Sanm reportedly won a $20,000 settlement after Project Veritas fired her for blO\ving
the lid on O'Keefe's alleged plan to embarrass a CNN reporter by inviting her on a boat
witil hidden cameras and sex props.
Naffe says she threatened to contact the DistrictAttorney's Office and report Frey Jor
misusing government time by blogging and Tweeti ng about her legal disputes with
O'Keefe, including blog posts about legal action O'Keefe took against Naffe.
Frey allegedly retaliated by publishing 200 pages of a 2005 depa;ition transcript
between Naffe and a former employer on his blog, "Patterico's Ponti ftcations."
TIle published transcript included Naffe's Sodal security number, date ofbirtil, maiden
name, family address and medical intormation, the oomplaintsays.
Naffe says that Frey represented that he had (IDmined the document from the federal
Public Access to Court Electronic Hecords (PACER) system.
Frey allegedly wrote on his blog: ''1 think I may layoff Nadia and give her a c11U1lce to
realize she has made a mistake in threatening to report me for totally bogus reasons."
"She may just be starting to realize that she has made a series of mistakes that could
land her in trouble," Frey wrote, according to the complaint "Maybe she's reronsidering."
Though Frey allegedly removed the transcript, Naffe says that her personal information
was "preserved for several weeks or months in an Internet web cache." Since then, people
have allegedly fraudulently used Naffe's &cial security number.
Naffe accuses Frey of usi ng his ]lOSi tion as a pra;ecutor "to advance his personal political
agenda to increase his audience, and to amplify his harassment agaillstpolitical enemies."
Frey also uses his official title as a deputy district attorney to lend credibility to his
published statements, according to the complaint.
Writing on "Patterico's Pontifications" on 'Thursday, Freysaid he had not seen the
lawsuit but noted that a political activist named Neal Rauhauser had introduccd Naffe to
her attorney .Jason Leiderman.
"As regular readers are well aware, Rauhauser has long wanted me sued, fired, and so
forth for several reasons - one of which is tile fact tlmt [ have defended James O'Keefe on
this blog," Frey "Tote.
In an email to Courthouse News, Frey's attorney Kenneth White called Naffe's
. complaint "frivolous and frankly biwrre."
"It's a politically motivated abuse of the legal system and an effort tu censor speech
protected by the First Amendment," White wrote. "I'm proud tojoin Ron Coleman [,vith
http://www.courthousenews.con1t2012/10/04/50960.htrn --?- R
1/16/2014 Courthouse News Service
Goetz Fitzpatrick of NewYork, N.Y.] in defending Mr. and Mrs. Frey pro bono to vindiC"dte
the important free speech principles at issue. We look forward to addressing the
(X,mplaint's manifest defects in court."
O'Keefe shot to fame in 2009 after releasing undercover videm he shot in several offices
of the nonprofit ACOHN, short te)]' Association of Community Organizations for
Now.
Many media reports charaeteIiz<..'{f O'Keefe as posing as a pimp sinc'B he wore
"stereotypical197OS pimp garb" in the opening and scenes of rertain videos he
released, but he wore a shirt and tie in the actual encounters, identil)'ing himself as the
concerned boyfriend of a purported prcstitute, according to the Caliti,mia Attorney
General's Office.
'1he videos prompted outrage after being broodeaston Fox News and
BigGovernmen!:.c'('m, and lawmakers voted to freeze funding 1:0 ACORN, which was known
for voter drives and organizing in poor comml.lnities. '11,e nonprofit dosed up shop after
filing tor Chapter 7 liquidation in late 2010.
Nafte is represented by Jason Leiderman of Leiderman Devine of Ventura, Calif. She
seek.., damages tel(' violation of her First Amendment rights, public disclosure invasion of
privacy, false light invasion of privacy, defamation, intentional intlietion of emotional
distress, negligence and negligent supervision.
Naffe also made tor1 claim" against the Frey and Cooley in April after Nafte's
harassment complai nt against O'Keefe \Vas dismissed late last year tor lack ofjurisdiction.
Neither representatives for O'Kede nor the iLJS Angeles County Counsel's Ofnce
immediately responded to emailed requests tell' commen!:.
http://www.courthonsenews.com/2012/10/04/50960.htm 2/2
Patrick frey
To: Aaron Worthing <:
Cc: Liberty Chick
This IS way better. You still ha\e a lot of ~ n s to fillm and such
but the overall argument packs a punch the first one didn't If the
judge reads this, you'll win Seth's case for him as well as your 0\\""1.
Marl< Singer not Sanger
Mandy should look in the book for another page (within 10 pages on
either side of the one she sent you) which specifically says the
article in question named him as a suspect. I am pretty sure ion of
the pages is around page 93 and the other is around page 98. Something
like that. It's the noaA part of the syllogism and it's missing right
now.
You didn't say Just Call Me lefty has called himself a Kimberlin
supporter. I sent you that quote and link last night.
This kicks ass. They are going to go apeshit. When you blog It, rll
Thu. Dec 22, 2011 at 222 AM
lCilft2
send it to Glenn Reynolds and teU him I think this is the guy who
swatted me, and in any e-..ent it's just an extraordinary takedawn of
someone trying to out a blogger for nefarious reasons. Your post will
be a hit I predict.
t would like to read the final draft before submission because
whatever my ather fau.lts, I am a pretty strong proofreader. So I think
it would be good to be able to go line by line with a final draft
This, again, kicks serious ass.
Sat Dec 24, 2011 at l' 59 AM A.W. "-gmail.com>
To:
Besides there is a reason why Brett ne\er sued u. He knew you'd kick his ass. NOVlI he is going to leam not to
tuck with me either.
Sent from my iPhone
On Dec 24,2011. at 1:53 AM, Patrick Frey wrote
PatriCk Fre
Te,. "A.W."
gmail,com>
gmail.com>
Sat Dec 24, 2011 at 2:02 AM
Yeah, but he IS "fucking" with me. Just not in court He sends
bullshit interrogatories that he has to know will newr get answered.
But mostly he is trying to make me miserable, publishing my address,
hinng people to swat me. &>ogle bombing me, defaming me, mocking me,
and so on.
Just understand that you will likely be in for this kind of treatment
p
Sent from my ,Phone
PatriCk, rna,il.com>
To: "A,W"
The fact that someone yJiIl tuck with you that way is not a reason not
to do the right thing - and I think you're doing the right thing.
I just want you to understand that Kimberhn is behind all the things
that have happened to me, and that he Is truly dangerous and a
psychopath.
p
Sent from my Phone
On Dec 24,2011. at 1:00 AM, HA.W," _gmall,com> wrote:
Sat Dec 24, 2011 at 2:09 AM
Patrick Frey
To: Aaron Worting
Cc' Uberty Chick
om> Sat. Dec 24, 2011 at l' 53 AM
gmaiLcom>
@gmaiLcom>, 'A.W."_gmail.com>
I kind of skimmed the beginning parts, Looks like not much has changed
and the parts that haw seem
This is your bnef
l
and although theywUI no doubt file a complaint
with my office saying I wrote it for you (because they are liars and
need no proof to le\el an accusation), this is you - and it looks
reaUy good. I am happy to done some proofreading and such but
the legal analysis is all Aaron and I think it's a winner.
I think you are going to make Kimberlin &Co. very angry and I really
hope you know what you are getting into and are steeled for it
il
Mon, Dec 19, 2011 at 10:30 AM
Motion To Compel Re Kimberlin v Allen
Pattenco
To: "A, W.'I
Cc: Uberty C 4C
t can't give you e'lwerythin'g that connects Ron to Brett because there IS an ongoing in-..estigation and because it
would be ve:ry time consuming, but hopefuUy Mandy can explain a tittle more about Raw Story. Ron's guest
bfogging for Brad Friedman, and so forth. There is quite a bit of material but Rants sla\Ash de\Otfon to Brett
evident in some of what I sent yOli. He even pushes the "Brett was exonerated
lf
story. I ha\e a screenshot
somewhere.
Also, don't 'VOlunteer where you got this stuff. Just because of the in\eStigation. But for that I would be shouting
afl this from the hilltops, but f still think we can put these guys in prison, so I ha\e to stay quiet
p
~ iI
Legal Notice From Brett Kimberlin
ad. com>
maiLeam>
Thu, Dec 15, 2011 at 1:27AM
Kimberlin committed perjury three times. I hS\e Ule clips. I tried to get major media to look at it but then my office
asked me to back off while they inwshgate and I said OK.
p
Sent from my Phone
On Dec 14, t at 10-17 PM, Aaron Worthing ~ g m i l :> wrote
A.W.
To: PaUerico
gmad.com>
gmail.com>
Wed, Jan 25, 2012 at 9: 54 PM
if tts not too much troubie, sure, but j don' want to weigh you down with it, is aU i am saying"
Aaron
Patterico
To; "A.W:'
gmaH.com>
gmail.com>
Wed, Jan 25, 2012 at 9' 55 PM
I'm ha\4ng fun. This is what I do: pro\e things. I ha\e a jury out so I ha\e a tittle time tonight
'J
o
Wed, Jan 25,2012 at 9:57 PM gmail.com>
g;mail.com>
A.W.
To: Patteric
did he say anythrng of note befow it?
Aaron
Patteri co
To: "A,W.,"
gmaiiLcom>
gmaiLcorn>
Wed, Jan 25,2012 at 9:58 PM
Yau are getting ewrything of note that mentions you. Giwme 30 minutes. It will come rolling in graduaUy.
p
Patrick frey
To: Aaron Worthing
Cc: Liberty Chick
aitcom>
gmaiLcom>
gmail.com>
Wed,Dec 21, 2011 at 1: 07 AM
You sure you don't want to follow up with Neal just to see what happens?
I don't suggest lying unless it's done under the supei1olsion of law enforcement as part of a sting. But is there any
harm in following up lust to see where it goes?
p
Sent from my :Phone
jQuolen lex! hidden]
Wed, Dec 21, 2011 at 113 AM
10114
1(1/2112 Grnall- Kimberlin P;1.l1)I
To: Patrick Frey
Okay, talk to them. makes me wish a family friend in the FBI was still alive.
You liked him, He was a lawyer, who occasionally eamed anM16,
Aaroh
!Ouol.;1d lexl hidden]
Aaron Worthing
To Liberty Chick
gmaiLcom>
@gmaiLcom>
Wed, Dec 21, 2011 at 1:17 AM
Wed, Dec 21,2011 at 1:26 AM
try taking the pic, but iHhat doesnt woo<. i will trust you to accurately transcribe the rele\.ent part.
AU j want is the part where Brott Kimberlain talks about koowlng he was a suspect So its oot just proof that he
was a suspect, but proof that he knew he was a suspect.
Aaron
[Ouoted Ie>1 hiddenl
Patrick Frey
To: Aaron
I just think it would be kick ass if you gave a completely made up identity to Rauhauser, and then Kimberlin tried
to that person, aod their name was spread all Just Call Me Lefty etc,
But it only makes sense as part of a monitored LE sting.
p
c-J
Wed, Dec 21,2011 at 12:49 AM Patrick Frey
To: Aaron Worthing
Cc. Liberty Chick
Think she was going to send it I haw a ton of proof of that. Mostly comments on Qritiq. Neal says he has met
Brett, works with Vel\et Re\Olution, always has ad'l.0l1ce notice of what happened in the litigatioo, etc. He elA;fl
told ComcastBrett was his client, though he didn't name Brett - just called him the head if an NGO who had
recentty receilA;d a credible threat on his Hfe.
If the goddamned FBI had their shit together we could use this offer from Neal and do a sting. Ha\e you gi'loe him
a fake identity/name and see if it gets back to Brett
Damn.
p
Sent from my iPhone
IQIJoted text l j { j ~ n i
GmaJl - Kimberlin perjury
9/14
Patrick Frey
To: AarooWOfthing
Cc: Uberty Chick
rnaiLcom>
gmail.com>
gmail.com>
Wed, Dec 21, 2011 at 12:54 AM
Maybe don't mention Neal in the brief? I talk to the FBI Thursday. Maybe they'd be willing to do a sting...
p
Sent from my iPhone
!Ot/oled lext hidden)
1011112
Aaron
P,atriek Frey . gmail.com.>
To: "A.W."
W1at Beth said to hm...
Thu, Jan 5, 2012 at 4: 12 PM
\"'Joutd you be willing to send me a short just-the-.facts-ma'am email summarizing your interactions with Ron and
Brett including their threats to sue/file bar complaints/etc. with your real name, suitable for pro\Ading to my
supeNsors and possibly law enrorcement?
3-5 pagagraphs at most I don't need anything too extensi\e.
I would ideally like to send yours With Beth's and Ken's all at once, Your experienc.es help put theirs into context
Is that possible?
P
Sent from my iPhone
HJU!:Jtcd lext hidden]
A.,W.
To: Patrick Frey
wnh the promise that they would keep my confidentiality, yes.
Aaron

Patrick Fremail.com>
To: "A.W," rna-iteam>
Ofcollrse.
p
Sent from my iPhone
[QuQted le.xl hilidenl
Thu, Jan 5,2012 at 417 PM
Thu, Jan 5, 2012 at 4: 19 PM
Tom sent a message using the contact form at
http://www.jtmp.org/jtmp/index.php?q=contact.
Don't go there.
Report as inappropriate:
http://www.jtmp.org/jtmp/index.php?q=mollom/report/mollom_content/
120524824af8c7a046
Visitor Analysis & System Spec
Search Referral: www.google.com - justice through music project <http://
www.google.com/search?sa=t&rct=j&q=justice%20through%20music
%20project&source=web&cd=1&ved=OCFOQFjAA&url=http%3A%2F%2Fwww.jtmp.org
%2F&ei=yWu9T-K8F6iyiQLK3dDfDQ&usg=AFQjCNEHSaSyGfU3fTgatnLzOesqmLILwg> #1
Host Name:Browser:Firefox 3.6
IP Address:146.233.0.202 - [Label IP Address] <http://statcounter.com/
p6887348/add-ip-address-label/?ip_address=146.233.0.202&return_url=
%2Fp6887348%2Fmagnify%2F%3Fip_number%3D2464743626> Operating System:WinXP
Location:Whittier, California, United StatesResolution:1280xl024
Returning Visits:OJavascript:Enabled
Visit Length:8 mins 29 secsISP:Los Angeles Sheriff's Department
Navigation Path
DateTimeWebPage
www.google.com - justice through music project <http://www.google.com/
search?sa=t&rct=j&q=justice%20through%20music
%20project&source=web&cd=1&ved=OCFOQFjAA&url=http%3A%2F%2Fwww.jtmp.org
%2F&ei=yWu9T-K8F6iyiQLK3dDfDQ&usg=AFQjCNEHSaSyGfU3fTgatnLzOesqmL1Lwg> #1
May 2306:59:38 PM www.jtmp.org/jtmp/index.php <http://www.jtmp.org/jtmp/
index.php>
Page lof2
Thursday, January 16, 2014 4:31 PM
Subject: Walker's sick, twisted obsession with my family is very disturbing and dangerous
Date: Wednesday, December 18, 2013 10:13 PM
From: Justice Through Music <justicejtmp@comcast.net>
To: Patrick Ostronic <fpolaw@fpolaw.com>, Mark Del Bianco <mark@markdelbianco.com>
http://allergic2bull.blogspot.com/2013/12/exclusive-my-motion-to-dismiss.html
Also, I will as usual be redacting personal information from it, as well as any
information about Brett's eldest daughter. One of the more unfortunate facets of this
situation is the effect it is having upon his children. Indeed, given that she has only
heard her father's side of it, she probably thinks we are horrible people. She probably
doesn't lmow about her father tried to frame me for a crime <http://
allergic2bull.blogspot.com!2012!os!summarypreview-of-my-post-how-brett.html> ;
how he had me arrested for bogus reasons (just like her lllother) and obtained a
flagrantly unconstitutional peace order against me <http://allergic2bull.blogspot.com/
2012!o6!new-series-of-posts-story-i-couldnt.html> ; or how he personally stalked my
wife <http://allergic2bull.blogspot.com/2013/o3/exclusive-how-brett-kimberlin-
stalked.html> . She probably thinks Dad is an innocent guy who we just picked on for
no good reason.
She probably even believes her father when he says that I commented on the article
about her successful YouTube video. Little does she knowthat Dan Collins
aka@vermontaigne <https:!!twitter.com!vermontaigne> , has publicly stated he is the
author.
For me, one of the great underappreciated clauses of our Constitution is in the Treason
clause. It says: "but no Attainder of Treason shall work Corruption of Blood, or
Forfeiture except during the Life of the Person attainted." The second part of that is
fairly easy to but what about the first. What the hell do they mean by the
corruption of the blood?
Well, the answer is they are saYing you cannot punish the family of a traitor as though
they were traitors, too. It is a talisman of what makes this country great.
Fundamentally we don't care who your ancestors were. They could have been kings,
they could have been beggars. They could have been heroes and they could have been
terrorists. We don't care. Because you are judged as you.
So not knowing this girl, she enjoys the presumption of innocence that belongs to all
strangers. Given the way Brett Kimberlin lies about everything, I have no reason to
think he is telling her the truth about what is going on and therefore I have no reason to
think she approves of what is actually happening here. If she knew the truth she would
lmowthat her father has been working for years to suppress the truth about his illegal
and immoral conduct, and his criminal and immoral conduct, combined with his
Page 1 of 2
attempt to silence his critics, has brought all this attention on this family.
But allegedly a few people have harassed her online, on her facebook and the like.
There is always concern, of course, that Brett or his allies might be faking a lot of that
behavior <http://patterico.com/2012/o6/26/strong-circumstantial-evidence-that-
brett-kimberlin-is-astroturfing-the-alleged-threats-against-him-and-his-allies/ >. But
regardless, if any person draws any negative conclusion about her based on her father,
they are not being charitable enough. They are forgetting that even when we are
talking about Benedict Arnold, we do not hold the child responsible for the conduct of
the father.
Anyway, I wish there was some way to bring Kimberlin to justice without his elder
daughter or any of his family being dragged into this. But Brett has made that
impossible. Still, I can limit the damage as much as possible, hence why I will be
keeping her name off my blog as well as her younger sister.. Other people feel like what
Brett has done makes her name newsworthy, and I will respect that view, but I will not
follow their approach.
Page 2 of 2

Kimberlin V NBC Res Hoge W M2D (OCR) (Redacted)

Încărcat de

Informații document

Titlu original

Drepturi de autor

Formate disponibile

Partajați acest document

Partajați sau inserați document

Opțiuni de partajare

Vi se pare util acest document?

Este necorespunzător acest conținut?

Drepturi de autor:

Formate disponibile

Kimberlin V NBC Res Hoge W M2D (OCR) (Redacted)

Încărcat de

Drepturi de autor:

Formate disponibile

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF MARYLAND

Service News Courthouse

S-ar putea să vă placă și