William John Joseph Hoge,

Plaintiff,
v.
Brett Kimberlin, et al.,
Defendants.

IN THE

CIRCUIT COURT FOR CARROLL COUNTY

MARYLAND
Case No. 06-C-16-070789

PLAINTIFFS OPPOSITION TO DEFENDANT SCHMALFELDTS MOTION FOR

SUMMARY AND TO DECLARE PLAINTIFF WILLIAM JOHN JOSEPH HOGE III
A VEXATIOUS LITIGANT (DOCKET ITEM 79)
COMES NOW William John Joseph Hoge and opposes Defendant
Schmalfeldts Motion for Summary Judgment for Failure to State a Claim Upon
Which Relief Can be Granted and to Declare Plaintiff William John Joseph Hoge III
a Vexatious Litigant (Docket Item 79). In opposition Mr. Hoge states as follows:
DEFENDANT SCHMALFELDT FAILS TO STATE ANY GROUNDS TO SUPPORT A
MOTION FOR SUMMARY JUDGMENT ON COUNT IV
Failure to state a claim upon which relief can granted is a ground for
dismissal of a complaint, but it is not a ground for granting summary judgment.
The ground for summary judgment is that there is no genuine dispute as to any
material fact and that the party is entitled to judgment as a matter of law. Md.
Rule 2-501(a). Schmalfelts Motion fails to show that there are no genuinely
disputed facts alleged in Count IV. Instead, it disputes facts alleged in Mr. Hoges
Complaint. In Schmalfeldts Answer (Docket Item 1/3) he denies the facts alleged in
paragraph 44 of the Complaint and partially denies the facts alleged in paragraph
43. Schmalfelts Answer at 3.

The disputed facts relevant to Count IV are summarized in Mr. Hoges

attached Affidavit (Exhibit A). They are as follows:
a. The Compliant states that Schmalfeldts comment endorses the contents
of the [4 March] article and is, in essence, a restatement of the defamatory remarks
contained in the 4 March, 2016, article published at Breitbart Unmasked.
Complaint, 43. Schmalfeldt admits writing the comment in his Answer but
den[ies] Plaintiff characterization of [the comment]. Schmalfeldts Answer at 3. A
true and correct copy of the Breitbart Unmasked article containing Schmalfeldts
comment is attached as Exhibit 1 to Mr. Hoges Affidavit.
b. The Complaint states that Schmalfeldt stated that Mr. Hoge committed
the committed the crimes of stalking and subornation of perjury. Complaint, 44.
Schmalfeldts Answer denies the that Schmaldeldt made such a statement.
Schmalfeldts Answer at 3. A true and correct copy of the Breitbart Unmasked
article containing Schmalfeldts comment is attached as Exhibit 1 to Mr. Hoges
Affidavit. Furthermore, Mr. Hoge denies ever engaging in subornation of perjury in
his Affidavit.
c. The Complaint states that Schmalfeldt relied on independent and
undisclosed facts not in the Breitbart Unmasked article. Complaint, 44.
Schmalfeldts Answer denies relying on such facts. Schmalfeldts Answer at 3. Mr.
Hoge expects that evidence related to this allegation will be more fully developed in
discovery. He believes that summary judgment is inappropriate prior to discovery.

d. The Complaint states that Schmalfeldt knew his statement was false or
made his statement with a reckless disregard for the truth. Complaint, 44.
Schmalfeldts Answer denies that he knew the his statement was untrue or that he
made it with a reckless disregard for the truth. Schmalfeldts Answer at 3.
Mr.Hoge expects that evidence related to this allegation will be more fully
developed in discovery. Summary judgment is inappropriate prior to that discovery.
e. The Complaint states that Defendants Osborne and Breitbart Unmasked
acted with bad faith in publishing Schmalfeldts comment. Complaint, 44.
Schmalfeldts Answer denies that Osborne or Breitbart Unmasked acted in bad
faith. Schmalfeldts Answer at 3. Mr.Hoge expects that evidence related to this
allegation will be more fully developed in discovery. Summary judgment is
inappropriate prior to that discovery.
f. The Complaint states that the 4 March, 2016, article published in
Breitbart Unmasked is false. Complaint, Count II. Schmalfeldts Motion for
Summary Judgment states that Mr. Hoge can not prove the allegations were
untrue. Schmalfeldts Motion for Summary Judgment at 2. Mr. Hoge alleges that
the article falsely accused him of the crimes of stalking and subornation of perjury.
My Affidavit rebuts Schmalfeldts accusations. True and correct copies of the
District Court and Circuit Court denials of the Peace Order Petition underlying the
false story of stalking and harassment of a minor child are attached to Mr. Hoges
Affidavit as Exhibits 2 and 3. Additionally, Tetyana Kimberlin testified during the
12 August, 2013, hearing in Kimberlin v. Kimberlin, [cite] that the charges she filed
3

against Brett Kimberlin were true and that she was not offered any thing of value
to induce her to file them. While that case is now sealed, Mr. Hoge will seek to have
the relevant portion of Tetyana Kimberlins testimony unsealed for use in this case
and to seek further evidence during discovery. Summary judgment is inappropriate
prior to that discovery.
Although Schmalfeldts Motion for Summary Judgment relies on facts not in
the record, he has provided no Affidavit.
Schmalfeldt is not entitled to summary judgment on Count IV because of the
denials in his Answer and the facts he disputes in his own Motion. The Court
should deny Schmalfeldts Motion for Summary Judgment as it relates to summary
judgment on Count IV.
SCHMALFELDT IS NOT ENTITLED TO SUMMARY JUDGMENT ON COUNT XII
On the other hand, there are no material facts in dispute with respect to
Count XII, and all the material facts favor Mr. Hoge. Schmalfeldt has admitted in
his Answer to all the relevant facts alleged in the Complaint necessary to establish
his liability. Schmafeldts Answer at 5. Because it is Mr. Hoge who is entitled to
summary judgment on Count XII, he has simultaneously filed a Cross Motion for
Partial Summary Judgement as to Count XII, and he incorporates the arguments
from that motion herein by reference. A copy of Mr. Hoges Affidavit supporting his
Cross Motion is attached as Exhibit B.
The Court should deny Schmalfeldts Motion as it relates to summary
judgment on Count XII.
4

SCHMALFELDT ANSWER WAIVES THE AFFIRMATIVE DEFENSES LISTED IN

RULE 2-323(g)
Md. Rule 2-323(g) sets out a list of defenses which must be specially pleaded
and which are waived if not specially pleaded in an answer. Brooks v. State, 85
Md.App. 355, 584 A.2d 82, 87 (1991). Because Schmalfeldt has not pleaded any of
the twenty affirmative defenses listed in the Rule, he has waived all of them. They
are no longer available to Schmalfeldt either for summary judgment or at trial. If
Schmalfeldt puts forth no defense, then Mr. Hoges Complaint is essentially
unopposed by him.
Therefore, the Court should deny Schmalfeldts Motion as it relates to
summary judgment on Counts IV and XII.
SCHMALFELDTS MOTION FOR SUMMARY JUDGMENT RELIES ON FACTS NEITHER
IN THE RECORD NOR SUPPORTED BY AFFIDAVIT
Schmalfeldt makes allegations in his Motion concerning facts he supposes are
related to defenses he has not actually set forth. He alleges that Mr. Hoge has
violated the Settlement Agreement based on his understand of Twitters Terms of
Service. However, there is nothing in the record concerning those Terms of Service,
and Schmalfeldt has not produced any other competent, admissible evidence to
support his allegations. This includes all of Schmalfelts attached exhibits. As
noted supra, Schmalfeldt has filed no affidavit with his Motion for Summary
Judgment.
The Court should deny Schmalfeldts Motion for Summary Judgment as it
relates to summary judgment on Count XII.
5

SCHMALFELDT HAS NOT SHOWN ANY NEW EVIDENCE DEMONSTRATING THAT

MR.HOGE IS A VEXATIOUS LITIGANT
After considering the Kimberlins Motion to Find Plaintiff a Vexatious
Litigant (Docket Item 47/0) during the 27 September, 2016, motions hearing, the
Court denied the Kimberlins motion. Schmalfeldt has not provided any new
competent evidence in his Motion that might tend to show that Mr. Hoge has
engaged in vexatious litigation. Indeed, as the Court noted during that motions
hearing, it is Mr. Hoge who has been the defendant in almost all of the preceding
civil actions. The Court has not been given any reason to rule differently on
Schmalfeldts Motion than it did on the Kimberlins. Therefore, the Court should
deny Schmalfelds Motion for Summary Judgement as it relates to finding Mr. Hoge
to be a vexatious litigant.
CONCLUSION
WHEREFORE, Mr. Hoge asks the Court to DENY Defendant Schmalfeldts
Motion for Summary Judgment for Failure to State a Claim Upon Which Relief Can
be Granted and to Declare Plaintiff William John Joseph Hoge III a Vexatious
Litigant (Docket Item 79) and to GRANT such other relief as the Court may find just
and proper.
Date: 20 October, 2016

Respectfully submitted,

William John Joseph Hoge, pro se

20 Ridge Road
Westminster, Maryland 21157
(410) 596-2854
himself@wjjhoge.com
6

CERTIFICATE OF SERVICE
I certify that on the 20th day of October, 2016, I served copies of the foregoing
on the following persons:
William M. Schmalfeldt by First Class U. S. Mail to 3209 S. Lake Drive, Apt. 108,
St. Francis, Wisconsin 53235
Brett Kimberlin by First Class U. S. Mail to 8100 Beech Tree Road, Bethesda,
Maryland 20817
Tetyana Kimberlin by First Class U. S. Mail to 8100 Beech Tree Road, Bethesda,
Maryland 20817

William John Joseph Hoge

AFFIDAVIT
I, William John Joseph Hoge, solemnly affirm under the penalties of perjury
that the contents of the foregoing paper are true to the best of my knowledge,
information, and belief.
Date: 20 October, 2016
William John Joseph Hoge

Exhibit A

William John Joseph Hoge,

Plaintiff,
v.
Brett Kimberlin, et al.,
Defendants.

IN THE

CIRCUIT COURT FOR CARROLL COUNTY

MARYLAND
Case No. 06-C-16-070789

AFFIDAVIT RELATING TO COUNT IV

I, William John Joseph Hoge, depose and say:
1.

I am over eighteen (18) years of age, have personal knowledge of the

facts contained herein, and am competent to be a witness.

2.

The Compliant states that Schmalfeldts comment endorses the

contents of the [4 March] article and is, in essence, a restatement of the defamatory
remarks contained in the 4 March, 2016, article published at Breitbart Unmasked.
Complaint, 43. Schmalfeldt den[ies] Plaintiff characterization of [the comment].
Schmalfeldts Answer at 3. A true and correct copy of the Breitbart Unmasked
article and Schmalfeldts comment are attached as Exhibit 1. Schmalfeldts
statement appears in the Comment section following the main body of the article.
3.

The Complaint states that Schmalfeldt stated that I committed the

committed the crimes of stalking and subornation of perjury. Complaint, 44.

Schmalfeldts Answer denies the that Schmaldeldt made such a statement.
Schmalfeldts Answer at 3. A true and correct copy of the Breitbart Unmasked

article and Schmalfeldts comment are attached as Exhibit 1. Schmalfeldts

statement appears in the Comment section following the main body of the article.
4.

I deny that I have ever engaged in the crime of stalking. Specifically, I

deny that I have ever approached or pursued another person with the intent to
place him or her in reasonable fear of serious bodily injury, assault, rape or sexual
offense, false imprisonment, or death or cause him or her to fear that a third party
would suffer any of those acts. True and correct copies of the District Court and
Circuit Court denials of the Kimberlin v. Hoge Peace Order Petition are attached as
Exhibits 2 and 3.
5.

I deny that I have ever engaged in the crime of subornation of perjury.

Specifically, I deny that I have ever offered anyone any inducement to engage in
perjury, and I deny that I have ever suggested to anyone that he or she should
engage in perjury.
6.

The Complaint states that Schmalfeldt relied on independent and

undisclosed facts not in the Breitbart Unmasked article. Complaint, 44.

Schmalfeldts Answer denies relying on such facts. Schmalfeldts Answer at 3. I
expect that evidence related to this allegation will be more fully developed in
discovery.
7.

The Complaint states that Schmalfeldt knew his statement was false

or made his statement with a reckless disregard for the truth. Complaint, 44.
Schmalfeldts Answer denies that he knew the his statement was untrue or that he

made it with a reckless disregard for the truth. Schmalfeldts Answer at 3. I expect
that evidence related to this allegation will be more fully developed in discovery.
8.

The Complaint states that Defendants Osborne and Breitbart

Unmasked acted with bad faith in publishing Schmalfeldts comment. Complaint,

44. Schmalfeldts Answer denies that Osborne or Breitbart Unmasked acted in
bad faith. Schmalfeldts Answer at 3. I expect that evidence related to this
allegation will be more fully developed in discovery.
9.

The Complaint states that the 4 March, 2016, article published in

Breitbart Unmasked is false. Complaint, Count II. Schmalfeldts Motion for

Summary Judgment states that I can not prove the allegations were untrue.
Schmalfeldts Motion for Summary Judgment at 2. True and correct copies of the
District Court and Circuit Court denials of the Peace Order Petition underlying the
false story of stalking and harassment of a minor child are attached as Exhibits 2
and 3.
10.

Additionally, Tetyana Kimberlin testified during the 12 August, 2013,

hearing in Kimberlin v. Kimberlin protective order cases1 that the charge she filed
against Brett Kimberlin was true and that she was not offered any thing of value to
induce her to file them. While that case is now sealed, I will seek to have the
relevant portion of Tetyana Kimberlins testimony unsealed for use in this case and
to seek further evidence during discovery.

Kimberlin v. Kimberlin, Case No. 113163-FL (Md. Cir.Ct. Mont. Co. 2013) and
Kimberlin v. Kimberlin, Case No. 113164-FL (Md. Cir.Ct. Mont. Co. 2013).
3

11.

I, William John Joseph Hoge, solemnly affirm under the penalties of

perjury that the contents of the foregoing paper are true to the best of my
knowledge, information, and belief.
Date: 19 October, 2016

Respectfully submitted,

William John Joseph Hoge, pro se

20 Ridge Road
Westminster, Maryland 21157
(410) 596-2854
himself@wjjhoge.com

Exhibit 1

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William Hoge Stalking A Teenager For His Conspiracy Theory

William Hoge Stalking A Teenager For His Conspiracy Theory

BY MATT OSBORNE ON MARCH 4, 2015

Right on cue, one day after defending convicted con artist Paul Lemmens dubious claims to

12

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be an ordained Orthodox priest, William Hoge of Maryland indicated that he still pays
entirely too much attention to Kelsie Kimberlin, the teenage daughter of his chief
obsession.
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Remember, this is the girl whose family, personal life, and budding music career were destroyed when
Hoge and his sociopathic friends colluded to suborn perjury from her mother. Playing his accustomed
role as unlicensed Maryland attorney, Aaron Walker of Virginia wrote up a steamy BDSM rape fantasy
and actually submitted it to a state court in her name. Not content with mere perjury, Walker contacted
Agent Dan Borsuk of the FBI and told him where and when to interview Tetyana Kimberlin to have her
confirm it. She had just returned from a weeks-long, out-of-state romantic affair, and was in the middle
of her ensuing marital dispute with Mr. Kimberlin, when Borsuk showed up for her custody interview
with Child Protective Services. The unspoken message: endorse this perjury and you can have your children.
Tetyana understandably balked and disavowed Walkers perverted tale of sexual torture. His fevered
fiction imagined the basement level she shared with Mr. Kimberlin was secretly also (1) a terrorist bomb
factory, and (2) a sinister version of Christian Greys playroom, complete with pictures of past victims

JULY 28, 2014

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framed on the wall. The perjury was unsupportable, for key facts and documentation absolutely
contradict Walkers sordid narrative. Mr. Kimberlin succeeded in having these ludicrous

NOVEMBER 16, 2014

accusations sealed, but not before Mr. Hoge ran to the courthouse and made a copy of the sickening

I Will Not Comply: 5000+ Gun Nuts

RSVP For Washington State Gun

document so that he and his friends could all publish it in their blogs.

Law Rebellion

Through the magic of Google, Walkers bizarre and strained pedophilia scenario suddenly dominated

MARCH 17, 2015

search results for the Kimberlin family just as Kelsie was emerging as a fledgling star. Its hard to

That Went Well: Patterico Faces

overstate this: Walker, Hoge, and their felonious friends ruined a teenage girls public debut in the worst

Color Of Law Charge

way imaginable. Whereas Kelsie had been in discussions with Nashville agents in June, by September of
2013 she was forced to change schools in order to escape vicious, constant bullying based on the vomitinducing contents of Aaron Walkers disturbing masturbation fantasy. Upon disavowing Walker, Tetyana

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immediately tried to be publicly supportive of her daughter, but Kelsies family is irretrievably broken.
(CORRECTION: I am informed that the Kimberlins have been patching up their relationship for several
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months now.)
Mind you, all of this came after a man named John Norton was inspired by the same right wing blogs to
sneak into the Kimberlins yard with a camera and creep on their younger daughter. After chasing

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Norton to a stoplight to get his license plate number, Kimberlin filed a police report and took legal

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action to protect his family. Hoge blogged regularly about that affair, celebrating each minor legal step
as if it were some sort of sweet victory over the evil Brett Kimberlin, never once questioning Nortons
absurd pretext of being in the neighborhood by sheer coincidence.

Breitbart Unmasked

Hogewash.com currently features a black and white photo of Mr. Kimberlin standing on the porch of his
office building during an incident in 2013, when Hoge was filing frivolous litigation on a regular basis.
On this particular occasion, Hoges process server was belligerent and intrusive, so an office employee
refused to accept his papers and told him to leave. At that point, the process server called the police; so
did the staff, who were disturbed by his hostile lingering in the yard. The legal papers were eventually
left on the sidewalk, because the whole point of this exercise was to get a photograph of the devil
Kimberlin. Now, Hoge wants readers to celebrate the photo, which features the subject of his delirium
talking to the police, as proof that Kimberlin lied at some obscure past hearing about receiving proper
process service on that occasion.
Hoges focus on minutiae is indicative of his madness. Contrary to his notion of what constitutes proper
delivery of his own legal paperwork, ever since Kimberlin got fed up and started suing Hoge and his
friends, they have scrutinized every checkbox of Kimberlins certified mail to construct further elaborate
conspiracy theories. When he shows up to court, Hoge always has thick folders stacked on the table, as
if their weight adds gravitas to his weaksauce litigating.
These are stuffed with the collected breadcrumbs of his conspiracy narrative, which in turn excuses

Thursday THREATCON 24 September 2015

9/24/2015
Its Thursday Threatcon, your intelligence briefing on
right wing activity. Below are the best reports,
investigations, exposes, and debunkery of
VIDEO: Anti-Gay Judge Roy Moore Picketed In
Huntsville
9/24/2015
When Roy Moore arrived for a reception at the
Elbert Parsons Law Library in downtown Huntsville
this week, he found a demonstration across the
Ben The Friendly Fascist
9/22/2015
My latest article and music video Ben The Friendly
Fascist features Ben the Friendly Fascist from the
GOP! Dr. Ben

everything he does. If Hoge actually lived in Kimberlins neighborhood, he would be creepy like Craig
Hicks, the Chapel Hill, North Carolina man who shot his Muslim neighbors dead after obsessing about
parking spaces.

Each unit got permits for up to two cars, but only one assigned spot. Building 20 had 13 spaces.
Mr. Barakat and Ms. Abu-Salha were assigned space 20B. The next, 20C, belonged to Mrs. Hicks.
Five spaces in the middle were unassigned and could be used for extra cars. Drivers also
regularly parked on the side street.
The housing association allowed residents to have improperly parked cars towed. But Mr. Hicks
abused this power until the housing association asked him to stop, his wifes lawyer said.
According to a police search warrant, he kept pictures and detailed notes on parking activity
on his computer.

William Hoge is trying to prove that Kimberlin lied about a parking space two years ago to justify the lies
he told about Kimberlins family at the same time. Hoge and his Lemmengs like to imagine they have
helped Tetyana and Kelsie, but they know what theyve really done, and secretly they have to be

82

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worried. They must fear the day this girl turns eighteen and has the right to speak for herself, because
then she might just thank the liars who ruined her family by singing unforgettable lyrics. Frankly, I hope
she destroys them.

Tweets

by @BreitbartUnmask

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Copyright2015BreitbartUnmasked

Why, Yes, As a Matte

Brett Kimberlin

creepy

fraud

frauds

libel

stalking

I don't know why it's

important to anybody. I
certainly do not need to
explain
my reasoning for
breitbartunmasked.com
getting a driver's license
and a good old
41m

William John Joseph Hoge

ABOUT AUTHOR

MATT OSBORNE

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Mark in MD 2 years ago

INTERESTING BLOGS

Hoge keeps getting creepier and crazier.

1

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Alan Colmes

William Hoge Is Mentally Ill 2 years ago

Andrew Sullivan

Boy what a bunch of sick fucks. Now they are having fantasies about the guys teenage
daughter? What sick miserable losers they are.

Aurelio Montemayor

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Bundy's Buddies

William A. Ferguson 2 years ago

Claire Conner

Kelsie's 18th birthday can't get here soon enough.

Corey Robin

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Bill Schmalfeldt 2 years ago

Matt, that was an appropriately brutal and true depiction of events. And it never stops. The hits
just keep on coming. Here's a measure of Hoge's litigious nature. How many people do you
know who have over 300 Scribd legal documents in their folder relating to things they are
involved with? He gets handed loss after loss (like today) and declares it victory, while his son
gets more obese and his wife gets sicker with cancer. This is an example of a man who should
NOT have a security clearance or firearms. He's out of his mind, and will hurt someone
physically before all is said and done.
1

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Counterpunch
Crooks & Liars
Democracy Chronicles
Democrats For Progress
Diary of a Republican Hater
Digby's Hullabaloo
Disaffected And It Feels So Good

William A. Ferguson 2 years ago

Drums ~n~ Whistles

Well, it appears Hoggy is having some kind of apoplectic fit over this article.

Ed Brayton's Dispatches

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El Machete Illustrated

Amy 2 years ago

her music career wasnt destroyed, i just think she needs to be discovered.

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Eric J Garcia
Extreme Liberal
Havoc and Chaos

William A. Ferguson > Amy 2 years ago

That may be so but the hell Hoge and his cronies have put her through is very much real.

Share

Imagine 2050
Jacobin

Bill Schmalfeldt 2 years ago

BREAKING: MONTGOMERY COUNTY JUDGE ISSUES TEMPORARY PEACE ORDER

AGAINST WJJ HOGE III.

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Job's Anger
Juanita Jean
Left In Alabama

So Many Hoges. > Bill Schmalfeldt 2 years ago

Liberal Values

Which WJJ Hoge? Christian sadist WJJ Hoge, the Goddard employee? The Goddard
employee with security clearance? That WJJ Hoge of Maryland?

Little Green Footballs

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LoL Wut Politics

William A. Ferguson > So Many Hoges. 2 years ago

All the above.

1

More Dot Common Sense

Nomadic Politics

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Osborne Ink
Westminster Winds 2 years ago

I know John Hoge. He is now in trouble. He will not be able to win this. His just desserts are all
on his plate. I can only imagine what is going to happen on Friday. The judge is not going to
entertain any of his 1st Amendment complaints, or his good ol boy well gee I was just providing
this for my readers. The judge is only going to listen to what the young girl has gone through
and that is not going to be pretty. John is going to be adjudicated a sexual predator, a lecher of
the lowest denominator, a pervert and a stalking harasser who engaged in a course of conduct
to bully and terrorize a young girl.

Planet POV
Political Gates
Pragmatic Obots Unite
ProsserJohn
RADAMISTO

John will be arrested, maybe not at the hearing, but shortly thereafter. He will be charged with
violating Grace's law. John will lose his guns. John will lose his blog. John will lose the peanut
gallery which egged him on to commit this horrendous crime against an innocent girl. John will
lose his ability to engage in harassing anyone ever again.

Sally Kohn

Around here, they call me Westminster Winds because I am a blowhard. But a foul smell has
been coming from that small brick frame house on Ridge Road for some time. It's time that the
winds of change to blow it away. I will be there, watching, smiling and wondering .....

The eXiled

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Jury Finds for Brett and Tetyana Kimberlin

5 comments 5 days ago

1 comment a month ago

RogerS Another one of The Hog's friends

convicted for attempted murder.

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DumpTrump This is great to know. Thank

ORAXX Matt Drudge should put his money

you for posting it.

where his mouth is and head out in small boat.

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Frankly, I am shocked and surprised that conservatives could be taken in by the likes of
Akbar, Hoge, Walker, Stranahan, and McCain. This is a band of misfit crazies -adjudicated felon, adjudicated stalker, adjudicated fanatic, adjudicated pornographer and
adjudicated Klan supporter. Before anyone knew about them, they were flying high, but
once BU exposed them, they were only left with their own pitiful echo chamber. And how
many conservatives did they take down, scandalize, stain and harm. Now Mr. Frey, who
was Mr. Walker's trusted ally, is going to lose everything because of his support of Mr.
Walker.

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Jury Finds for Brett and Tetyana Kimberlin

Exhibit 2

Exhibit 3

Exhibit B

William John Joseph Hoge,

Plaintiff,
v.
Brett Kimberlin, et al.,
Defendants.

IN THE

CIRCUIT COURT FOR CARROLL COUNTY

MARYLAND
Case No. 06-C-16-070789

AFFIDAVIT RELATING TO COUNT XII

I, William John Joseph Hoge, depose and say:
1.

I am over eighteen (18) years of age, have personal knowledge of the

facts contained herein, and am competent to be a witness.

2.

The Compliant (73) states and Schmalfeld in his Answer (at 5)

admits that he signed the Settlement agreement attached as Exhibit 1.

3.

The Compliant (74-85) states and Schmalfeld in his Answer (at 5)

admits that he published Mr. Hoges copyrighted works without prior written
permission.
4.

The Compliant (86) states and Schmalfeld in his Answer (at 5)

denies that Mr. Hoge filed for copyright registration on the works in question. True
and correct copies of the copyright registrations issued to date for those works are
attached as Exhibit 2.
5.

I, William John Joseph Hoge, solemnly affirm under the penalties of

perjury that the contents of the foregoing paper are true to the best of my
knowledge, information, and belief.

Date: 20 October, 2016

Respectfully submitted,

William John Joseph Hoge, pro se

20 Ridge Road
Westminster, Maryland 21157
(410) 596-2854
himself@wjjhoge.com

Exhibit 1

SETTLEMENT AGREEMENT
Dated: August l4r20l4
This Settlement Agreement ("Agreement") is made and entered into this 14th day of
August, 2014by and between Plaintiff William John Joseph Hoge ("Hoge") and Defendant
William M. Schmalfeldt ("Schmalfeldt") (Hoge and Schmalfeldt are collectively referred to
herein as the "Parties") in the case of Hoge v. Schmalfeldt, Civil No. ELH-14-1683, in the United
States District Court for the District of Maryland ("the case"). The purpose of this Agreement is
to fully settle any and all claims, counterclaims, cross-claims and third-party claims raised in the
case; to document the Parties' agreement to certain conditions; and to allow the Parties to move
for the enforcement of the Agreement.
The Parties agree as follows:

1. Hoge agrees to dismiss all of his claims against Schmalfeldt in this case with
prejudice. Schmalfeldt agrees to dismiss all of his counterclaims and amended counterclaims
against Hoge and all of his counterclaims and amended counterclaims against "Paul Krendler"
(Anonymous Blogger) with prejudice.
2.

In order to facilitate the dismissal of the Parties' claims and counterclaims, the
Parties agree that the Court will enter an Order pursuant to Local Rule 111 dismissing all claims,
counterclaims, cross-claims and third-party claims.

3.

The entry of the Local Rule 111 Order will be without prejudice to the right of the
Parties to move for good cause within 30 days to reopen the case if settlement is not
consummated. If neither of the Parties move to reopen, the dismissal shall be with prejudice.

4. The Panies agree that they will not post or re-publish any work or article written
by the other without receiving written permission, in advance, from the other party, unless the
terms of service permit republication without permission.
5. The Defendant agrees to remove any and all remaining alleged infringement
materials as to Hoge and Hogewash.
6. In the event that either of the Parties breach this Agreement, this Agreement does
not restrict the rights of the non-breaching party to take the appropriate legal actions in the
appropriate legal forum to seek relief for the breach of contract.
7.

The Parties will each bear their own costs, if any.

8. Should any provision of this Agreement be determined by a court of competent

jurisdiction to be void or unenforceable, the remaining provisions shall remain valid and
enforceable unless agreed to by both of the Parties.
g. This Agreement shall be deemed executed in the State of Maryland and will be
governed by the laws of the State of Maryland, except to the extent that other federal law may
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apply. This Agreement sets fonh the entire agreement of the Parties. This Agreement may not be
changed orally, but may be changed only by a writing signed by both of the Parties.

10.

This Agreement represents a fully negotiated agreement. The Parties have both
been afforded the opportunity, which each has exercised, to review the terms of the Agreement.

By:

out"a,

frn ff, Zoll

By:

William M. Schmalfeldt

Page2 ofZ

Exhibit 2