WILLIAM M. SCHMALFELDT, SR.

3209 S. LAKE DRIVE, APT 108, SAINT FRANCIS, WI 53235 (414) 249-4379 EMAIL: BSCHMALFELDT@TWC.COM

8/30/2016

Clerk of the Carroll County Circuit Court

55 N. Court St.
Westminster, MD 21157
Regarding the Scheduled Motion Hearing in Civil Case #06C16070789 Sept. 27, 2016
After speaking this afternoon with a civil clerk in your office, I am informed that I have the right to
apply to attend this hearing by telephone. One of the outstanding motions to be discussed at the
hearing is my motion to transfer or dismiss Plaintiffs case against me under the doctrine of forum
non conveniens. (Docket #60/0). I live in St. Francis, Wisconsin, almost 840 miles from Westminster,
Maryland. As I have suffered from Parkinsons disease for approaching 17 years, travel of any
significant distance is uncomfortable and potentially dangerous for me. When my wife was living
she was able to provide the assistance I need getting to and from in an airport, driving to a hotel,
and providing transportation to and from a courthouse. She died on June 17, 2015 and I do not
have a personal caregiver to offer assistance.
The Plaintiff, WJJ Hoge III, who has caused your Court Commissioner to lodge 367 unsuccessful
criminal charges against me between 2013 and 2015, has opposed my motion. His rationale seems
to be that since the Court denied my Motion to Dismiss for Improper Venue, I have exhausted any
recourse to file a further dispositive motion. The Court ruled against me on June 9, 2015. Allowing
three days for mail, my filing of the motion to transfer or dismiss for forum inconveniens, made on
June 25, 2015, was within the 15 days set forth in Maryland Rule 2-321. As this Court has not ruled
on the motion, the clock has not begun ticking on my time to file an answer as there remains a
dispositive motion outstanding.
The Plaintiff will not be prejudiced by this Court allowing me to make my appearance at the
motions hearing by telephone. He can make the same arguments as he could if I were physically
present. If I am required to physically attend this hearing, then and only then does my motion for
forum inconveniens become moot. I will be forced to choose between protecting my health or
challenging Plaintiffs spurious, vindictive and vexatious claims.
The only reason the Plaintiff could possibly have for opposing my request is that causing my
discomfort and placing me in physical danger is exactly what he wants, which the Court should
take into consideration as it debates the merits of any of Plaintiffs open motions concerning this
defendant.

I respectfully ask the court to permit me to enter my appearance by telephone on September 27,
2016, and thus save me the discomfort and potential hazards of traveling alone with Stage IV
Parkinsons disease.
I ask the court to take notice that I am a non-attorney, representing myself in this matter. Mr. Hoge
claims to be a paralegal, though he has no official certification. A look at his Scribd account online
and the 739 legal briefs stored therein could leave one with the impression that litigation is his
favored avocation.
I have e-mailed a copy of this request to the Plaintiff and other served defendants in this matter.

Sincerely,

William M. Schmalfeldt, Sr.

E-Mail Copies Sent To:
William John Joseph Hoge, III
Brett Kimberlin
Tetyana Kimberlin
William J. Ferguson

August 30, 2016 Page 2