IN THE CIRCUIT COURT OF
CARROLL COUNTY, MARYLAND
WILLIAM HOGE,
Plaintiff,
v. No. C-16-70789
BRETT KIMBERLIN, et al.,
Defendants
DEFENDANT BRETT AND TETYANA KIMBERLIN'S RESPONSE TO THE JUDGE
MASTER'S ORDER DEFERRING RULING ON REQUEST FOR POSTPONEMENT OF
‘TRIAL DATE
Defendants Brett and Tetyana Kimberlin respond to the judge Master's April 24,
2017 Order Deferring Ruling On Request For Postponement of Trial Date.
1. The Court requests that Defendants (1) confer with Plaintiff to determine the
other party's position, (2) set forth an agreeable date with the Plaintiff and
Assignment Officer, and (3) attach documentation establishing the need for
postponement.
2 Defendants are unable to comply with the Court’s order for the following
reason, First, Plaintiff s an adjudicated stalker of Defendants and their minor child
who has been stalking and harassing them for years. As such, Defendants will have
absolutely no communication with him outside of the courtroom,
3. Second, Defendants have never agreed to anything with Plaintiff and will not
startnow. Defendants assume, and this Court should also assume, that the parties
cannot agree on atrial date. Defendants can state for the record that they can
attend any trial dates in September and October 2017,
4. Third, Defendants will not provide any information on the dates, times or
places they will be traveling in August. Why? Because Plaintiff is a dangerous,deranged stalker who tracks and follows Defendants and has attempted to kidnap
with others, Defendant Tetyana Kimberlin and her minor daughters. Defendants
have had to provide round the clock, 24/7 security to themselves and their minor
daughter because of Plaintiffs obsessive behavior that has terrorized and victimized
Defendants, and continues to do so.
5. Defendants believe that providing any information on their whereabouts,
their itinerary, or whether of not they are traveling together or alone will give
Plaintiff lead that he can use to track, harass and terrorize them.
6. Defendants are shocked that this Court would even issue the order for
Defendants to communicate and cooperate with the person who has victimized,
harassed and stalked them and their minor daughter. Judge Creighton from
Montgomery County Circuit Court found that Plaintiffs stalking and cyber bullying
of the minor daughter constituted “child abuse” that could land him in state prison,
Yer this Court has ordered Defendants to communicate with him.
7. Judge Hecker is well aware that Plaintiff has been stalking and harassing
Defendants and their child for years and Defendants have had to file Peace Orders
and criminal charges against Plaintiffin order to get him to stop. Yet, not even that
has worked. Now Plaintiff is under federal investigation for violating the Violence
Against Women’s Act because of his obsessive stalking of Defendants and their child,
8. Summary judgment motions have just been filed in this case and therefore it
may be prudent for the Judge Master to wait until those have been ruled on prior to
setting a trial date. Ifnot, any trial date after August 2017 is acceptable to
Defendants.9. Defendants have consulted with Defendant Bill Schmalfeldt and he is
agreeable to any date in September or October 2017.
Respect
Bethesda, MD 20817
Justicejtmp@comcast.net (301) 320 5921
Certificate of Service
served a copy of this motion on Plaintiff this 28 day of April, 2017 by US
Mail.
Brett Kim