Professional Documents
Culture Documents
rll_~n
27
I;T GkW;8ELT
BRETT KIMBERLIN,
Plaintiff,
BYT-OEPUiY
GJH 13-3059
v,
to Defendant Lee
Stranahan's
Motion to Dismiss filed on January 5, 2015. Rather than file his own
arguments,
Defendant Stranahan's
"Defendant Stranahan
incorporates
one-paragraph
herein by reference and adopts the reasoning contain therein in support of this
motion." The Motion is without merit and should be denied.
1. Defendant Stranahan, as set forth in the Second Amended Complaint, is one
of the key instigators
fraud
because he worked for the publication and took his orders from
its owner, the late Andrew Breitbart, to go to "war" against Plaintiff. See Exhibit A
where Defendant Akbar tweeted: "#BrettKimberiin
Breitbart and we're going to finish it He'll go to jail this time." Defendant Stranahan
wrote scores of articles and tweets that stated or imputed that Plaintiff was involved
with swatting and other criminal activity. Exhibit B. He participated
in the webinar
hosted by the Franklin Center, [which has settled this case with Plaintiff], which was
held live on the Internet and made into a YouTube video, [which Franklin Center has
since removed], which stated and imputed that Plaintiff was swatting conservative
bloggers. ("Aaron Walker was swatted last night and is a very high profile victim of
Brett Kimberlin.") He conceived and launched the "Everybody Blog About Brett
Kimberlin Day," which caused a widespread defamatory attack on Plaintiff with
thousands of blogs posts and tweets falsely accusing Plaintiff of crimes and causing
Defendant Walker's termination. He created a YouTube video that portrayed
Plaintiff in a false light. He targeted others who defended Plaintiff and he flew to
Maryland to press charges against a reporter who discovered Defendant
Stranahan's long history of creating and selling pornography. The Howard County
Prosecutors rejected those charges. He participated in the "Everybody BlogAbout
Howard County Prosecutors" campaign of intimidation after those prosecutors
refused to arrest Plaintiff for charges made up by Defendants. He solicited and
participated in calls to raise funds for the fraudulent National Bloggers Club, and
received funds from DefendantAkbar to continue the attacks on Plaintiff. He
attacked Montgomery County District Court Judge Vaughey for siding with Plaintiff
in a Peace Order against Defendant Aaron Walker [which caused courthouse
security to provide extra security to the judge after his home address was posted on
the Internet]. He wrote articles and published tweets imputing that Plaintiff was
involved with the swatting of Defendants Aaron Walker and Patrick Frey. And he
has even recently attacked the other defendants who have settled this case. E.g.,
httpJJleestranahan.com/the-american-sRectator-
I(
This rule's
purpose '''is to test the sufficiency of a complaint and not to resolve contests
surrounding
of defenses.'''
ld.
(quoting Presley Y. City of Charlottesville, 464 F.3d 480, 483 (4th Cir. 2006)). To that
end, the Court must bear in mind the requirements
considering
entitled to relief," Fed. R. Civ. P. 8(a)(2), and must state "a plausible claim for
relief." /3ell Atlantic Corn.
Y.
U.S. 662, 678-79 (2009). "A claim has facial plausibility when the plaintiff pleads
factual content that allows the court to draw the reasonable
defendant
defendants,
and the
of the remaining
5. False Light-Several
defendants
Special Appeals' decision in Allen v. Bethlehem Steel Corp., 547 A.2d 1105,1108
(Md.
Ct. Spec. App. 1988), that false light claims are governed by Maryland's three year
statute of limitations,
Allen. This is
for
false light and held that it is three years. Piscatelli did not even mention the statute
of limitations or Allen in the entire opinion and only made a passing reference that
false light had to meet the same legal standards
mean the elements of the offense. Clearly, Plaintiffs false light claims were filed
timely within the three-year
SOL.
Pleaded-Several
defendants
did not plead false light and that calling him a swatter, a person who caused
Defendant Walker's termination.
a terrorist,
"escalate" to violence if not taken off the streets, did not portray him in a false light
This is without merit.
7. The Defendants, including Defendant Stranahan,
repeatedly
inserted
themselves
into Plaintiffs
statements
reasonable
person.
that portrayed
misconduct
him in
resulted
in Plaintiffs photo being placed on several of the Defendants' websites and Twitter
feeds depicting him as a Nazi, a pedophile, a supporter
None of these statements
of terrorism,
and a swatter.
in
"One who gives publicity to a matter concerning another that places the
other before the public in a false light is subject to liability to the other for
invasion of his privacy if
(a) the false light in which the other person was placed would be highly
offensive to a reasonable
person, and
(b) the actor had knowledge of or acted in reckless disregard as to the falsity
of the publicized matter and the false light in which the other would be
placed."
Bagwell v. Peninsula Reg 'I Med. Ctr., 665 A.2d 297, 318 (Md. Ct
Spec. App. 1995) (quoting Restatement
(Second) of Torts
S 652E
(1977)).
"s 652A.
(b) Appropriation
(c) Unreasonable
above four courses of conduct may give rise to a cause of action and, on occasion,
there may be an overlapping
or concurrent
Second, 652A,
460 A.2d
intruded on Plaintiffs
gave publicity to
stating that Plaintiff committed the crime of swatting and other crimes
are protected
speech.
per se defamation.
"the injurious
character
of which the court takes judicial notice and need not be pleaded
Haskins v. Bayliss, 440 F.Supp.2d 455,461
statements
are defamatory
characteristics.
constitute
or proved."
Hearst Corp. v. Hughes, 297 Md. 112, 125, 121 A.2d 466, 492 (1983). Accusing an
individual of committing
a crime is an example
of a statement
(2003)(allegation
that is defamatory
Services, Inc., 153
per se): American Stores v. Byrd, 181 A2d 333 (Md. 1962) (if statement
made in ordinary lay language that would impute a crime or guilt, sufficient to prove
libel); Brown v. Farkas, 511 NE 2d 1143 (Ill. 1986) (call to DSS that employee
bragged about sex with daughter
is per se defamation);
542 (LA App. 2002); Smith v. Danielczyk, 928 A2d 795(Md. 2007)(per se defamation
to impute commission
punished);
Pollitt v. Brush Moore Newspapers, 136 A2d 573 (MD 1957) (same);
Black's Law Dictionary 5th Ed, West 1970, page 376 states the following with
regard to defamation per se:
In respect of words, those which by themselves, and as such, without
reference to extrinsic proof, injure the reputation of the person to
whom they are applied.
Defamation per se means "defamation in itself." Again, according to Black's
at p 1245.:
Stranahan
for some reason has adopted Defendant Dan Backer and DBCapitol Strategies'
Motion to Dismiss that raises the issue of lawyer immunity for the proposition that
since lawyer Backer and his firm represented Aaron Walker in two malicious suits
against Plaintiff, they cannot be sued. This is without merit and perverse.
The conduct of Defendants Backer and DBCSwent far beyond that which falls
under the protections provided for attorneys. For example, the defendants filed two
malicious suits against Plaintiff in bad faith and used those suits for wrongful
purposes. In the Virginia suit, with virtually every filing, they asked for sanctions in
the tens of thousands of dollars, along with requests for contempt and
imprisonment
judge Potter found that the suit was not only without merit but filed
in bad faith for an improper purpose. In the federal suit, the defendants attempted
to use it to get Plaintiff fired from his job of ten years, to get copies of all the financial
books of the employer, and to extort the employer. Moreover, in that case, the
defendants, prior to any rulings in the case, sent a letter to the employer's largest
institutional funder falsely accusing Plaintiff and the employer of criminal activity
for the sole purpose of causing that funder to deny future funding from the
employer, which it did. judge Potter rejected all of the defendants' requests for
sanctions, and judge Motz found that he did not have jurisdiction to do what the
defendants requested (and continue to request), that is, taking over the Maryland
court system that is so corrupt because it would not buy into the false narratives of
the Defendants and denying Plaintiff the right to file any lawsuits to protect himself
from tortious conduct
Not only did Defendants Backer and DBCSfile malicious legal actions, they also
created websites and Twitter accounts that falsely accused Plaintiff of swatting and
other crimes. Reputable lawyers do not do such things. They then held fundraisers
on those sites and raised tens of thousands of dollars that they stuffed in their
pockets although they portrayed themselves as representing Defendant Walker pro
bono. Exhibit C. Through their Conservative Action Fund, they paid Defendant
Akbar using one of his fraudulent money laundering entities, Vice and Victory.
Exhibit D. When DefendantAkbar was exposed in the press as a felon and fraudster
on probation for credit card theft and other crimes, Defendants Backer and DBCS
money raising/laundering
operation
from
to sanitize
activities
of thousands
t~a =partY-=I1Cw-=ma
iler-=
th e mon ey. E.g" http://J lte.stranahan. C9JIl LexplQ!ting=-the-=
QU ie:gQh me rtf;
fro m -dan- bac ke r-co nn ected -groli P-=--USJts-1
http-JL&stmoilbil!l.comLstories/Jhe-tea:party-rip-off/.
Defendant Stranahan
because
I.
res judicata.
defendants
Defendants
Instead, they were the attorney and the law firm. Moreover, the claims were
different than those in the instant case. Res judicata has no application
to that case.
Second, the state case had different claims, over a different time period, with
a different set of defendants,
that litigation.
filed a motion for new trial because the trial judge failed to follow unanimous
law regarding the matter before the court and, on January 13,2015,
case
of the Maryland Court of Special Appeals issued a stay to allow the trial judge to
correct his error.
Exhibit E.
do not want this Court to even consider them and their relationship
the defendants
fraudulent
to
Enterprise,
with other
defendants
steinbaugh.
Your honor, your honor, plaintiff alleges that I give a fuck. I give none.
@bombersues."
Exhibit F.
National Bloggers Club yet they were all intimately involved with them during the
time period alleged in the Complaint
Internet was blaring false narratives
the defendants
accountable,
the
act as though they do not exist, and tell the Court that the Complaint
Malkin/Twitchy
to re-write
at
(and memories).
15. Plaintiff
Does Not Have To Prove His Case At This Stage Of The Case-
Several of the Defendants argue their motions to dismiss as if they were motions for
summary judgment or motions for directed verdicts.
prove his case at this stage, prior to discovery, and urge this Court to ignore the
exhibits attached to his Global Response.
precedent
First Mariner Bank, No. CCB-12-1569, 2013 WL 1308582, at *2 (D. Md. Mar. 28,
2013); see also CACI Int'l v. St. Paul Fire & Marine Ins. Co.. 566 F.3d 150, 154 (4th Cir.
2009). Therefore, this Court can consider the exhibits attached to the Global
Response and this response to show that the Complaint meets the plausibility
requirement
As this Court ruled in Malibu Media, LLC v. Doe, PWG 13-365 (D. Md. Dec. 16,
2014), "to require Malibu to prove that the subscriber
infringer-that
that Malibu
present at this stage actual evidence to support the merits of its infringement
allegations.'"
(citations omitted).
Plaintiff has properly pleaded his case and set forth the elements of the torts
alleged in the Complaint
were responsible
about
of
of
with many specific instances of tortious misconduct, and discovery will show the
"who, what, when, where and how" of the specific misconduct.
The Court can also consider the fact that the defendants
the Complaint about defendants
the defendants
from any discussion, and hope for default against those two defendants
so they will
not be subjected
misconduct
in
This Court must reject this bad faith gaming of the civil process.
defendants
under color of law because he stated that he was acting in his personal capacity on
his blog and elsewhere.
to use a standard
.1/
to grant him immunity from suit under section 1983. However, his
attempting
to imprison Plaintiff,
repeatedly
relying on
his official position of Assistant States Attorney, and telling his co-defendants
knows things that he can't discuss because of criminal investigations,
disclaimers,
1/ Moreover,
that he
belie his
many federal and state prosecutors have been fired for blogging on
their own time because of the clear nexus between their job and their blogging, and
the affect it can have on their prosecutorial duties. These cases demonstrate that a
prosecutor always represents his office. See. e.g., United States v. Bowen, 969 F. Supp
2d 518 (ED La 2012) (federal prosecutors blogging anonymously fired). In Andrew v.
Shirvel/, Michigan Assistant Attorney General was fired for blogging about a gay
activist The activist sued in federal court and won a $4.5 million defamation
judgment against the former AAG. Case No. 2:11-CV-11921 D. E.D Michigan, 2012).
http..:I.Lww~V'!..h u ffi ngt;QnP.Q~t<:'0rotl, 0)2 L 08 /Jll.a n.dJ:.lLW
-~hirveJI~!awY.eJ:::.
or n 1795737.htIl11, Another deputy attorney general from Indiana was fired for
blogging that force should be used against demonstrators
in Wisconsin.
htlp.J /www.cnn.coIl]L2011/USLOUZ3LiJl..9!i!na.all]illQ,illeet{
The Attorney
General's Office issued the following statement: "Civility and courtesy toward all
members of the public are very important to the Indiana Attorney General's Office,"
the agency said in a prepared statement "We respect individuals' First Amendment
right to express their personal views on private online forums, but as public
servants we are held by the public to a higher standard, and we should strive for
civility."
December 19, 2011 email to Defendants Walker and Nagy, attached as Exhibit G,
Defendant Frey states the following:
"I can't give you everything that connects Ron to Brett because there is an
ongoing investigation ....
Also, 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"
If there is one thing only a person acting under color of law can do that those
acting in the private capacity can't do, it is criminally investigating
someone.
and imprisoning
Clearly, Defendant Frey was acting under color of law when he tried to
crimes.
that Plaintiffs Section 1985 claim must be dismissed because he failed to allege any
kind of invidious discrimination.
Under the Civil Rights Act, Congress has provided, and the Supreme Court has
consistently
to intimidate
or threaten
from attending
fully, and truthfully, or to injure such party or witness in his person or property on
account of his having so attended
or testified."
525 US 121, 126 (1998) (an at will employee may file a claim under 42 USC 1985(2)
for damages against a third party who conspires with his employer to fire him to
deter him from testifying at an upcoming criminal trial); Kush v. Rutledge, 460 US
719,726-7
(l983)(permitting
In the instant case, Plaintiff has made very clear in his Complaint that the
defendants
conspired
from attending,
participating
Moreover, Plaintiff
For
County Circuit Court, and after Plaintiff testified, followed him out of
the courtroom,
intimidated
stepped into the court waiting area. During the assault, he wrestled
him as he
Plaintiffs iPad
away from him, sucker punched him in the face, and all this sent Plaintiff to the
Emergency Room at Suburban
the eye, possible concussion and back pain; (2) the defendants
years long intimidation
then engaged in a
telling
Plaintiff not to go to court and to leave Defendant Frey alone (or else); (3) caused
supporters
of the defendants
home and child, and call Plaintiffs home with death threats and call Plaintiffs
neighbors and tell them false information
many malicious and retaliatory
dismissed; and (5) attempt to deter him from filing any federal court lawsuits, and
(6) attempt to use the federal court to deprive Plaintiff from access to the courts and
then use that malicious lawsuit to get Plaintiff fired and injure his property right of
employment
Plaintiff and to deter him from testifYing in the future in both federal and state
courts. The FBI and Congress were investigating
cooperating
material assistance
the swattings
provided information
The defendants
went to
Plaintiff
from filing any action in federal court by asking that he be declared a vexatious
litigant and have appointed
to protect Plaintiffs
interests
want their
to a claim for damages under the Civil Rights Act of 1871, Rev. Stat ~1980, 42 U. S. C.
~1985(2)).
under 42 USC
1985(2).
17. The Second Elephant
offered one shred of evidence that Plaintiff committed any acts of swatting or any
other criminal acts for which they tried to have him arrested.
defendants
None of the
nor any
any crimes
whole cloth and used these charges to convict and defame Plaintiff in the court of
public opinion for their own twisted purposes. The defendants
to convince any official in any capacity to take any action against Plaintiff because
there was no evidence to support their false narratives.
instead
raised a vigilante mob to convict Plaintiff in the only court they could, and that court
was the Internet blog court of public opinion, in a campaign conceived, managed,
owned and operated
of the defendants.
tortious misconduct.
Conclusion
For all the above reasons and the reasons set forth in Plaintiffs Global Response,
Defendant Stranahan's
Brett Ki berh
8100 Beec
ee Rd
Bethesda, MD 20817
1usticgjtmp@c_o_mC.ast11ej:
(301) 320 5921
Certificate of Service
I certify that I mailed a copy of this motion to Attorney Smith and Defendants
Walker and Hoge, and emailed it to the remaining Defendants this 20th day of
January, 2014.
112012015
- (6S1xT19)
Ali A. Akbar
'I Follow
@ali
+-u*
3 RETWEETS 1 FAVORITE
A
http://web.mail.comcastnetiserviceJhomel ..l?auth~loe=eIl.-US&id=
1253206&part=
14
111
https://www.youtube.com/watch?feature=player_embedded&v=6gcoSnQVZYo
http://leestranahan.com/ignore-conservative-writers-on-brettkimberlin-story/
http://leestranahan.com/matt-osborne-claims-kimberlin-rauhauser-didntcall-blogbash-venue/
http://leestranahan.com/do-the-muslims-know-brett-kimberlin-supportssecularism/
http://leestranahan.com/serial-bomber-brett-kimberlins-organizationstarts-anti-gun-campaign/
http://leestranahan.com/brett-kimberlin-begins-explicit-criminalharassment-of-blogbash/
http://leestranahan.com/photo-is-latest-in-kimberlin-quest-to-outwalker-to-extremists/
http://leestranahan.com/texas-tim-reveals-mystery-witness-is-brettkimberlin/
http://leestranahan.com/is-brett-kimberlin-paying-bill-schmalfeldt/
http://leestranahan.com/i-fear-for-my-safety-dangerous-truth-aboutbrett-kimberlin/
http://leestranahan.com/schmalfeldt-kimberlin-believe-walker-is-indanger-if-his-identity-is-exposed/
http://leestranahan.com/bill-schmalfeldt-parses-his-relationship-tobrett-kimberlin/
http://leestranahan.com/bill-schmalfeldt-says-he-removed-tweets-aboutbrett-kimberlin-at-kimberlins-request/
http://leestranahan.com/bill-schmalfeldt-says-he-was-asked-to-removebrett-kimberlin-tweets/
http://leestranahan.com/bill-schmalfeldt2todays-deleted-tweets-aboutbrett-kimberlin/
httpS://www.youtube.com/watch?feature=player_embedded&v=N9QlvWqN7E8
http://leestranahan.com/brett-kimberlin-associate-neal-rauhausercalls-the-bill-schmalfeldt-podcast/
http://leestranahan.com/why-did-osborneink-put-convicted-domesticterrorist-in-quotes-to-describe-brett-kimberlin/
http://leestranahan,com/bill-schmalfeldt-brett-kimberlin/
http://leestranahan.com/steubenville-team-kimberlin-0-degrees-ofseparation/
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http://leestranahan.com/why-kimberlin-matters-watch-the-free-speechwebinar/
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http://leestranahan,com/the-kimberlin-sagas-second-front/
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http://leestranahan.com/everyone-blog-about-aaron-walker-day-is-rightnow/
1/20/2015
- (1563><388)
Launches \\'ebsite.
Raises 66000 towards Defense of Aaron \Valker And Others Against L..'1.W
or other information. please contact the Blogger's Defense Team: bloggersdefense at bloggersdefenseteam
dot
c
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1/20,2015
Any Information copied from such Reports and Statements may not be sold or used by any person for the purpose of soliciting contrib
or for commercial purposes, other than using the name and address of any political committee to solicit contributions from such comn
NAME OF COMMITTEE (In Full)
Conservative
A.
Action Fund
J.AM/ODJVY
Mailing Address
8116 Heritage
06
Place Drive
State
City
Fort Worth
TX
[;1
State:
741
Category!
Type
Candidate Name
Office Sought:
Zip Code
76137
Purpose of Disbursement
Web, technology, marketing consulting
20
House
Senate
President
District:
Disbursement For:
.4 Primary
L...
General
III
BRETT KIMBERLIN,
Appellant,
v.
AARON WALKER, ET AL.,
Appellees.
In the
OF MARYLAND
No. 1553
ORDER
On November 14,2014, the Circuit Court entered an Order dismissing the case. On
November 17,2014, within 10 days of the judgment, Appellant filed a Motion for New Trial.
On December I, 2014, Appellant filed a Notice of Appeal. The filing of the Motion for New
Trial within 10 days of the judgment stayed the time for noting an appeal until 30 days after
a decision on or withdrawal of the motion. To date, the Circuit Court has not entered a
decision on the motion and it has not been withdrawn.
previously filed Notice of Appeal is treated as having been filed the same day, but after the
order disposing of the motion for new trial. Edsall v. Anne Arundel County, 332 Md. 502,
508 (1993).
Accordingly, upon consideration of Appellant's "Motion to Hold Appeal in Abeyance
Until Motion for New Trial is Ruled on in Circuit Court" and no opposition having been
filed, it is this
-2-
1/20/2015
Your honor. your honor. plaintirr alleges that I give a ruck. I give nonc.@v.jjhogc
@rsmccain @aarom\'Orthing
@ ...
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~ Adam Steinbaugh
@AaronWorthing
@adamsteinbaugh . Dec 21
t.'l
Ii
WJJ
_ Hoge @wjjhoge . Dec 21
.2
SearchTwitter
to.
~ Adam Steinbaugh
learing
@adamsteinbaugh . Dec 21
t.'l
*2
+.1.
Ali A. Akbar
Follow
@ali
* ...
t.'l
RETWEET
FAVORITES
~ Adam Steinbaugh
@adamsteinbaugh . Dec 21
t.'l
https:'{twitter.comlaJi/status/546897567284748289
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I can't gi\e you e\erything that connects Ron to Brett because there is an ongoing in\estigation and because it
would be \ery time consuming, but hopefully Mandy can explain a little more about Raw Story, Ron's guest
blogging for Brad Friedman, and so forth. There is quite a bit of material but Ron's slavish de\Otion to Brett is
evident in some of what I sent you. He e\en pushes the "Brett was exonerated" story. I ha\e a screenshot
somewhere.
Also, don't \Olunteer where you got this stuff. Just because of the in\estigation. 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 ha\e to stay quiet.
p
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