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COMES NOW William John Joseph Hoge and opposes Defendant Brett
INTRODUCTION
As is shown below, Defendant Brett Kimberlin has failed to obey the Courts
Docket Item 108/0 at 1) Plaintiff responded by sending a second copy of his original
insufficient answers to Mr. Hoge, so on 23 January, 2017, Mr. Hoge asked the Court
to order Kimberlin to show cause why he should not be found in contempt. (Docket
Item 111/0) The Court issued a Show Cause Order on 26 January (Docket Item
112/0), and Mr. Hoge forwarded the Order to the Montgomery County Sheriffs
Brett Kimberlins Response to Order to Show Cause and Motion to Cancel Show
Cause Hearing (Motion to Cancel) via U. S. Mail. A second copy of the new
Defendant Brett Kimberlin has not given the Court any reason to cancel the
pending hearing scheduled for 17 March, 2017. Indeed, by attaching his incomplete
and non-responsive answers to his Motion to Cancel, he has provided the Court with
evidence that he has not yet obeyed its Order to provide complete answers and has
address it.
2
activity as corporate business and the who, if anyone, provides
supervision of those activities.
while Kimberlin may be the Director of Justice Through Music Project, he may be
subject to supervision of some or all of his activities. He is not the principal officer
listed on the corporations IRS Form 990. Exhibit A. That is Jeffery R. Cohen, Esq.
relating to his statement to the U. S. District Court concerning the scope of his
anyone supervise that work? Kimberlin has not answered these parts of the
Interrogatory.
Kimberlins campaign of lawfare against Mr. Hoge. Kimberlins answer bears little
1 Its clear why Kimberlin is dodging this question. If what he told the federal court
is true, then Justice Through Music Project would meet the definition of a law firm
under Md. Rule 16-812, MRPC 1.0(d)(2). In that case, he may be engaged in the
unlicensed practice of law. If it isnt true, then he misled the federal court. Also,
any lawyers associated with JTMP should responsible for supervising Kimberlins
legal endeavors.
3
6. Identify any instances in which corporate funds or other
resources belonging to Justice Through Music or Velvet
Revolution.US have been used to pay for expenses or to provide
other support related to any civil action (state or federal) or
criminal complaint (including, but not limited to, the Applications
for Statement of Charges at issue in this matter) filed by you
against Mr. Hoge, describing the amount paid or support provided
and which entity paid or provided it.
Kimberlins multi-year campaign of lawfare against Mr. Hoge. For example, has
Kimberlin used corporate IT assets to prepare documents for any of the cases he has
brought against Mr. Hoge?3 Kimberlins contact information that he has provided
in his signature block used on filing in this case gives his email address as
have the resources of Justice Through Music Project or Velvet Revolution.US been
used to further Kimberlins multiple lawsuits and false criminal charges against
2 Kimberlin has paid filing fees due in federal cases using Justice Through Music
Project checks on at least two occasions. See Kimberlin v. National Bloggers Club,
et al. (I), Case No. 14-MC-01-JCC, Receipt, ECF No. 1-2 (E.D.Va. Jan 9, 2014) and
In Re Brett Kimberlin, Case No. 16-1670, Receipt, Doc. No. 3-2 (4th Cir. June 14,
2016). Mr. Hoge was a party in National Bloggers Club, et al (I). Have there been
other instances of Kimberlins use of corporate funds to pay for his lawfare?
3 Mr. Hoge or his counsel in other matters occasionally have been served
electronically by Kimberlin with Microsoft Word documents by. The Summary tab
in the Properties windows of those documents often shows the Author and Company
as Justice Through Music. Exhibit B is an extract of such a document forwarded to
Mr. Hoge on 8 February, 2017, by his counsel in Kimberlins appeal of Kimberlin v.
National Bloggers Club, et al. (II), No. 16-825, (Md.App. 2017).
4
Mr. Hoge? Indeed, have those corporations been shadow plaintiffs in Kimberlins
lawsuits? Kimberlin has not denied that corporate assets have been used, but one
Kimberlin has not obeyed the Courts Order to provide complete answers.
Thus, he has failed to purge his contempt, and the Court should deny his Motion to
Cancel.
his compliance with discovery by resubmitting his initial set of answers. See
Plaintiffs Motion for Show Cause, Docket Item 111/0, Exs. B and C. Examination
of the two sets of answers provided in December and January shows that they are
identical, except for the location of Kimberlins signatures with respect to the
printed signature block. The two documents were clearly signed at different times
4 Additionally, line 11b of Part VIII of the 2015 Justice Through Music Project IRS
Form 990 (Exhibit A) shows $21,688 of revenue from a settlement in lawsuit. On
information and belief, Justice Through Music Project has not been a party to any
lawsuit since 2012, and it did not receive a settlement from that case. Most likely,
these funds were actually derived from a settlement from one of the four lawsuits
Kimberlin filed since 2013 which included Mr. Hoge as a defendant. Why would a
settlement have been paid to Justice Through Music Project if it were not a shadow
plaintiff in one of those cases? One of Kimberlins claims in his first RICO action
against Mr. Hoge was that he had been injured by a loss of donations to Justice
Through Music Project allegedly caused by Mr. Hoges truthful reporting on
Kimberlins past and present activities. Plaintiff has suffered injury to his name,
property and business, including, but not limited to: losing funding
opportunities, and other pecuniary and [sic] losses to real or personal property.
Kimberlin v. National Bloggers Club, et al. (I), Case No. 13-CV-3059-GJH. Amended
Complaint, ECF No. 2 (D.Md. Oct. 17, 2013), 152. Emphasis added.
5
which supports Mr. Hoges testimony that he received them on different days.
2016, Kimberlin submitted his first set of incomplete answers to Mr. Hoges
On 23 January, Mr. Hoge filed his Motion for a Show Cause Order. Mr. Hoge
served a copy of that motion on Kimberlin by mail on the 23rd. On 26 January, the
Court issued its show cause order. Also, on that date, Mr. Hoge received
Kimberlins opposition to the Motion for a Show Cause Order which had a copy of
the second version of the answers attached. There is no evidence that the new
version of the answers existed prior to Mr. Hoges serving his Motion for a Show
Cause Order on Kimberlin. Yet, Kimberlin seems to claim in his Motion to Cancel
that the copy of the new version of the answers he attached to that motion is
somehow the third copy of that version of the answers that he has sent. There is no
evidence to support his claim. Indeed, all the admissible evidence refutes it.
Given the likelihood that the second set of answers was created on or after 23
January, 2017, the fact that version claims to have been signed under penalty of
Based on these facts, the Court should deny Kimberlins Motion to Cancel.
6
III. THIS COURT SHOULD NOT TRUST BRETT KIMBERLIN
Brett Kimberlin is a convicted felon. His first conviction was for perjury.5
Walker, et al., Case No. 380966V (Md. Cir.Ct. Mont. Co. 2014) lawsuit.7 He was
caught forging a summons in Kimberlin v. National Bloggers Club, et al. (I), Case
called out for lying on the witness stand. Consider the following exchange he had
with Judge Mason during the recent Walker v. Kimberlin, et al., Case No. 398855V
(Md. Cir.Ct. Mont. Co. 2016) trial concerning Kimberlins claim that Mr. Walker
THE COURT: You specifically said you have never been arrested,
prosecuted, or convicted of any of the crimes in his blogs, which now
7
puts at issue you having testified that hes lied about everything hes
ever blogged about you, the bombing.
THE COURT: But that is what you said in front of this jury, sir,
that everything hes ever posted about you is a lie is what you
testified, and that's why I specifically note even the time that you
said it, because it creates an enormous issue in the case.
And you had asked, and I had kept out any reference to the earlier
Speedway bombing case, but you now have denied having been
convicted, arrested, or prosecuted for any offense that he blogged.
THE COURT: That is not what you testified to in front of the jury.
Okay.
THE COURT: So --
THE COURT: But Id just like that piece for me so we can go direct
there tomorrow morning.
THE COURT: If you doubt that you said it, I can play it back for
you precisely what you said.
Walker v. Kimberlin, et al., Trial Transcript, Oct. 12, 2016, at 271 - 273. Transcript
8
again the next day, Judge Mason excused the jury for a conference with the parties
THE COURT: Wait. If you, Mr. Kimberlin, want to take the stand
and, under oath, dispute that you were convicted of these offenses,
then I may well not let him use them. But if youre lying under
oath, you will subjecting yourself to prosecution for perjury.
MR. KIMBERLIN: Your Honor, you are being very unfair to me.
This man has, this --
THE COURT: -- I have been unfair to you. I kept this out, that
information out entirely, although I thought it was probative, until
you opened the door by lying to the jury.
9
Lets get the jury.
Walker v. Kimberlin, et al., Trial Transcript, Oct. 13, 2016, at 17, 18. Transcript
he did not lie, even when the judge was an eyewitness to Kimberlins false
statement and had the courtroom audio recording to backup his recollection of
Moreover, he has shown a similar disregard for the truth in his Motion to
Cancel, going so far as to accuse Mr. Hoge of lying without producing a scintilla of
evidence to support that allegation. He wants this Court to trust the unsworn word
Kimberlin, whose felony convictions include one for perjury, has claimed that
Mr. Hoge is lying but has offered no evidence or sworn testimony to support his
allegations. On the other hand, Mr. Hoge, who has never been convicted of
anything more serious than a traffic violation, has endeavored to back up all of his
points that might hinge on the evaluation of one persons credibility versus
anothers, the Court should favor the word of the party who has played by the rules
over that of someone who has proven record of obfuscation, perjury, forgery, and
give him an opportunity to produce evidence and to make his case under oath. The
10
Court should deny Kimberlins Motion to Cancel and should hold the show cause
hearing as scheduled.
Mr. Hoge wishes to make the Court aware of a couple of tangentially related
he served Mr. Hoge by certified mail return receipt. That is false. A copy of the
face of the envelope which Mr. Hoge received containing the service of the motion is
While that is sufficient postage for normal First Class Mail, it is insufficient postage
for either Certified Mail or Return Receipt, let alone for both. Kimberlin has made
Also, Kimberlin has insisted that his address is 8100 Beech Tree Road,
Bethesda, Maryland 20817. However, the Montgomery County Sheriffs Office was
unable to serve the Complaint and Summons on him at that address last year. See
Affidavit (Defendant Evading Service), Docket Item 19. On information and belief,
Kimberlin has been residing at 6519 79th Place, Cabin John, Maryland 20818, for
over a year. Mr. Hoge provided that address as well as an office address10 to the
Montgomery County Sheriffs Office as alternate addresses for service of the Show
Cause Order, and the MCSO was able to serve Kimberlin. Kimberlin continues to
11
CONCLUSION
Kimberlins Motion to Cancel Show Cause Hearing and to grant such other relief as
CERTIFICATE OF SERVICE
I certify that on the 14th day of February, 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 (last known address)
Brett Kimberlin by First Class U. S. Mail to 8100 Beech Tree Road, Bethesda,
Maryland 20817 (last known address)
Tetyana Kimberlin by First Class U. S. Mail to 8100 Beech Tree Road, Bethesda,
Maryland 20817 (last known address)
12
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.
13
Exhibit A
Extract from the 2015 IRS Form 990 for Justice Through Music Project.
Exhibit B
Summary tab of theProperties window of a court paper from Brett Kimberlin served
on Mr. Hoge through his counsel in Kimberlin v. National Bloggers Club (II).
Exhibit C
Comparison of signatures on the two copies of the original set of Answers to
Interrogatories received from Brett Kimberlin by Mr. Hoge. The December copy is
on the left.
Exhibit D
Extract from the trial transcript in Walker v. Kimberlin, Case No. 398855V
(Md. Cir.Ct. Mont. Co. Oct. 12, 2016).
IN THE CIRCUIT COURT FOR MONTGOMERY COUNTY, MARYLAND
------------------------------X
:
AARON WALKER, :
:
Plaintiff, :
:
v. : Civil No. 398855
:
BRETT KIMBERLIN, ET AL., :
:
Defendants. :
:
------------------------------X
JURY TRIAL
------------------------------X
:
AARON WALKER, :
:
Plaintiff, :
:
v. : Civil No. 398855
:
BRETT KIMBERLIN, ET AL., :
:
Defendants. :
:
------------------------------X
Rockville, Maryland
matter commenced
APPEARANCES:
Exhibit No. 1 -- 13
Exhibit No. 2 -- 13
Exhibit No. 3 -- 17
Exhibit No. 4 21 21
Exhibit No. 5 -- 22
Exhibit No. 6 -- 24
Exhibit No. 1 -- 37
Exhibit No. 2 -- 41
Exhibit No. 10 -- 79
Exhibit No. 11 -- 83
Exhibit No. 17 -- 106
Exhibit No. 18 -- 105
Exhibit No. 19 -- 107
Exhibit No. 26 -- 114
Exhibit No. 30 -- 164
Exhibit No. 41 -- 246
Exhibit No. 42 -- 250
271
2 told you with respect to you said she talked to you at a time
3 when she told you to go to the clinic after he beat you up.
5 time after she showed you an e-mail that he had sent her that
6 she told you, and I think also, no, sorry, you were talking
7 about the documents that you said he had prepared for her, she
8 told you all that information was false, and not true. You've
21 while they key it up for tomorrow, but you did not limit it to
22 sexual crimes.
1 blogs, which now puts at issue you having testified that he's
2 lied about everything he's ever blogged about you, the bombing.
4 intent at all.
6 this jury, sir, that everything he's ever posted about you is a
8 even the time that you said it, because it creates an enormous
10 And you had asked, and I had kept out any reference
11 to the earlier Speedway bombing case, but you now have denied
13 that he blogged.
18 THE COURT: So --
2 THE COURT: If you doubt that you said it, I can play
8 and things like that at the time, and I meant that I had never
12 you'll say that you can do that. I'm not agreeing that that's
20 marked up.
25 copy.
279
Digitally signed by Pat Ives
AARON WALKER
v.
By:
_________________________
PAT IVES
Transcriber
Exhibit E
Extract from the trial transcript in Walker v. Kimberlin, Case No. 398855V
(Md. Cir.Ct. Mont. Co. Oct. 13, 2016).
IN THE CIRCUIT COURT FOR MONTGOMERY COUNTY, MARYLAND
------------------------------X
:
AARON WALKER, :
:
Plaintiff, :
:
v. : Civil No. 398855
:
BRETT KIMBERLIN, ET AL., :
:
Defendants. :
:
------------------------------X
JURY TRIAL
------------------------------X
:
AARON WALKER, :
:
Plaintiff, :
:
v. : Civil No. 398855
:
BRETT KIMBERLIN, ET AL., :
:
Defendants. :
:
------------------------------X
Rockville, Maryland
matter commenced
APPEARANCES:
Exhibit No. 7 65 66
Exhibit No. 8 72 74
Exhibit No. 9 87 --
Exhibit No. 10 107 --
Exhibit No. 12 121 122
Exhibit No. 13 123 131
Exhibit No. 14 132 --
Exhibit No. 15 139 140
Exhibit No. 16 141 --
Exhibit No. 17 144 --
Exhibit No. 18 155 --
Exhibit No. 19 158 --
Exhibit No. 20 166 169
Exhibit No. 21 175 175
Exhibit No. 6 -- 38
Exhibit No. 29 -- 39
Exhibit No. 43 18 42
Exhibit No. 44 18 42
Exhibit No. 45 21 --
Exhibit No. 46 21 --
Exhibit No. 47 21 --
Exhibit No. 48 21 --
Exhibit No. 49 21 --
Exhibit No. 50 21 --
Exhibit No. 51 32 --
Exhibit No. 52 32 --
Exhibit No. 53 32 --
Exhibit No. 54 32 --
Exhibit No. 55 59 --
Exhibit No. 56 188 --
17
5 take the stand and, under oath, dispute that you were convicted
6 of these offenses, then I may well not let him use them. But
11 there and you're, if you can say, truthfully, you were not
12 convicted, fine.
16 this. As I've explained, you may think I'm being very unfair
20 because you had violated, and your wife had violated, the rules
25 jury, and a jury should hear this, and let them decide.
18
6 was probative, until you opened the door by lying to the jury.
13 don't know what the numbers are, but those next two exhibits
19 identification.)
23 mind.
25 is, I'll let you take up the transcript, and you can refer to
225
Digitally signed by Kimberly L. Chwirut
AARON WALKER
v.
By:
_________________________
KIMBERLY L. CHWIRUT
Transcriber
Exhibit F
Copy of the face of the envelope Mr. Hoge received via mail from Brett
Kimberlin on 10 February, 2017.
Exhibit G
Kimberlin v. National Bloggers Club, et al. (I), Case No. 13-CV-3059-GJH,
Supplemental Memorandum, ECF No. 124 (D. Md. Apr. 28, 2014)
Case 8:13-cv-03059-PWG Document 124 Filed 04/28/14 Page 1 of 5
BRETT KIMBERLIN, *
Plaintiff, *
v. * Civil Action
PWG 13-3059
NATIONAL BLOGGERS CLUB, et al., *
Defendants *
* * * * * * * * * *
Michael F. Smith
The Smith Appellate Law Firm
1717 Pennsylvania Avenue N.W., Suite 1025
Washington, D.C. 20006
smith@smithpllc.com
(202) 454-2860
Bar No. 29941
Counsel for Defendants
Michelle Malkin and Twitchy
Mr. Kimberlin has pending a Maryland state-court action against various defendants in this case,
though not Mrs. Malkin or Twitchy. Kimberlin v. Walker et al., Montgomery Cir. Case No. 380966. At
an April 9, 2014 oral argument on defendant Ali Akbar's motion to dismiss that case, he admitted
altering a Postal Service return-of-service card in connection with his purported service of the complaint
on Mr. Akbar, to indicate he had requested "restricted delivery" before filing it with the court:
THE COURT: Did you alter the return receipts between docket entry 38 and 50
whatever, did you change them?
MR. KIMBERLIN: I did not change them intentionally. When I go to the post office, I
ask them to do it so it's registered or whatever it's called, restricted
delivery, and they did not do it. [Defendant Akbar is] saying that
there's an extra fee. I've never paid an extra fee for restricted
delivery. I've sent literally 50 or 100 of these things and never
once faked a [unintelligible] restricted delivery, but, you know,
Mr. Akbar here sitting right there that this was sent in January 2nd
to Mr. Akbar. It came back, it's restricted delivery. This one here
is January 25th, again, Mr. Akbar came back restricted delivery,
you know, undeliverable. And you know he keeps accusing me of
not paying the extra fee.
THE COURT: This is about the exact same brief green card being filed -- the
support motions you filed, the different docket entries, one
showing the restricted delivery box checked and one not.
MR. KIMBERLIN: Your honor, like I said I asked the post office to send it restricted
delivery.
1
Case 8:13-cv-03059-PWG Document 124 Filed 04/28/14 Page 3 of 5
THE COURT: And then you filed it representing that it accurately reflected the
green card that had been filled out.
MR. KIMBERLIN: No, no, no, I filed it and accurately said -- it accurately reflected
what I told the post office to do and that's what it is. You know,
like I said I'm a pro se litigant and --
THE COURT: You know it's one thing to say I'm pro se so I don't understand
rules or I don't understand how to get something in and the rules of
evidence and another thing to alter something and file it.... [Ex A,
TR 4/9/14, pp 21-23 (emphasis added)].
DISCUSSION
I. Mr. Kimberlin's statements show a pattern of misconduct that undermines his defense of
inadvertent pro se mistake, and supports dismissal and/or a significant monetary sanction.
After first ignoring the allegations regarding the Twitchy summons, ECF 67, Mr. Kimberlin
admitted forging it but offered this Court various excuses, including his pro-se status. ECF 102
Response. But as his comments to the state court show, Mr. Kimberlin's falsification of the summons is
part of a pattern of similar litigation misconduct that vitiates the defense he has proffered here.
In the state court, as in this Court, Mr. Kimberlin when caught in misconduct sought refuge
behind his pro-se status. Ex A, TR 4/9/14, pp. 14, 22; also ECF 102 Response, pp. 1-2. In both courts,
he claimed his action was necessitated by a public employee's improbable neglect of his or her routine
duties. Ex A, TR 4/9/14, pp. 21-22 (postal clerk failed to honor his request for restricted delivery); ECF
102 Response, pp. 1-2 (deputy clerk of this Court failed to issue Twitchy summons). In both courts he
assumed a chastened air and said he had learned his lesson but only after a defendant was forced to
expend resources exposing his conduct, and extracting an admission of wrongdoing. Ex A, TR 4/9/14,
pp. 22, 25 ("I understand"); ECF 102 Response, pp. 1-2 (private session with Clerk for summons
2
Case 8:13-cv-03059-PWG Document 124 Filed 04/28/14 Page 4 of 5
instruction). And in each court he has blamed the victim of his unsuccessful deception for complaining
about it. Ex A, TR 4/9/14, pg. 22 (criticizing Mr. Akbar for supposedly objecting that he failed to pay
for restricted delivery); ECF 111-1 Response, pg. 1 (Twitchy is being "petty" and "wasting the court's
This Court's inherent authority "extends to a full range of litigation abuses," Chambers v. Nasco,
Inc., 501 U.S. 32, 46 (1991), and a pattern of litigation misconduct may justify dismissal under it.
Vargas v. Peltz, 901 F. Supp. 1572, 1579-82 (S.D. Fla. 1995) (persistent pattern of misconduct by
plaintiff and her husband that amounted to fraud on the court, including fabrication of evidence, perjury,
and repeated false deposition testimony) (collecting cases); Riverside Mem. Mausoleum, Inc. v.
Sonnenblick-Goldman Corp., 80 F.R.D. 433, 435-436 (E.D. Pa. 1978) (dismissal justified by plaintiff's
pattern of ignoring court orders and deadlines). The April 9 hearing transcript establishes such a pattern,
and shows that falsification of the Twitchy summons was no innocent or accidental pro-se mistake. It
Respectfully submitted,
3
Case 8:13-cv-03059-PWG Document 124 Filed 04/28/14 Page 5 of 5
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the above Supplemental Memorandum and its Ex
A was electronically filed in this case on April 28, 2014 and thus served on counsel of record via the
Court's ECF system. Additionally, I am serving the document via email this date on plaintiff Kimberlin
and on defendants Hoge, McCain, and Walker by the express permission of each.
4
Exhibit H
Kimberlin v. National Bloggers Club, et al. (I), Case No. 13-CV-3059-GJH, Response
to Show Cause Order, ECF No. 102 (D. Md. Mar. 11, 2014)
Case 8:13-cv-03059-PWG Document 102 Filed 03/11/14 Page 1 of 3
('
. '.,-,
, .. I
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MARYLAND
GREENBELT DIVISION
BRETT KIMBERLIN,
Plaintiff,
NATIONAL BLOGGERSCLUB,et al
Defendants.
Now comes Plaintiff Brett Kimberlin and responds to this Court's Order to
occasions for the mistake he made when serving Twitchy. Plaintiff explained
to counsel that the mistake was not in any way done with an intent to
a pro se litigant did not understand, but now understands full well.
the caption. As soon as counsel for Twitchy notified Plaintiff about the error
this Court granted in its Letter Order of February 21, 2014. The Court also
3. When the Clerk initially sent Plaintiff 21 summons, Plaintiff spent hours
compiling them with the Complaints, the envelopes and certified cards only
Case 8:13-cv-03059-PWG Document 102 Filed 03/11/14 Page 2 of 3
to discover that the summons for Twitchy was missing. At the time, Plaintiff
assumed that the Clerk had inadvertently forgotten to include that summons
4. Plaintiff has since discussed this with the Clerk of the Court and was told that
a summons can only be filled out by a party using Form A0440 and then
5. Plaintiff apologizes once again to Defendant Twitchy and counsel, and to the
Court for this misunderstanding. Plaintiff assures the Court that this will not
occur again. In fact, with today's filing, Plaintiff is submitting six A0440
Summons Forms to the Clerk for signature so Plaintiff can initiate service of
6. Plaintiff urges this Court not to impose sanctions on Plaintiff since this was
procedure, he has learned from the mistake, he has apologized to all parties,
Respectfully submitted,
Brett Ki in
8100 Beech Tree Rd
Bethesda, MD 20817
(301) 320 5921
justjcejtmp@comcast.net
Case 8:13-cv-03059-PWG Document 102 Filed 03/11/14 Page 3 of 3
Verification
Certificate of Service
I certify that I have served a copy of this Response on Lee Stranahan, Ron
Coleman, Catilyn Contestable, Michael Smith, and Mark Bailen by email, and
on Defendants Hoge, The Franklin Center, McCain and Walker by First Class
Brett Kimberlin