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"#$$#%& '()*+, %-."*/. 0( #-0*//()%0(/#*.

William Hoge, Defendant, through his undersigned attorney, F. Patrick Ostronic, and in
answer to interrogatories submitted by Plaintiff, generally notes:
a) The following responses and objections are based upon information now
known. Mr. Hoge has not yet completed discovery or preparation for trial in this
action and therefore will supplement these responses and objections to the extent
required by the Maryland Rules.
b) Although these are Mr. Hoges answers, he has relied on his attorney for
assistance in their preparation. Accordingly, some of the answers reflect the
sentence structure and wording of Mr. Ostronic.
c) Without waiving any applicable objections and by way of response, Mr. Hoge
provides the following responses.

Note: As required by Maryland Rules, Mr. Hoge provides his answer after restating each
interrogatory as originally submitted by Plaintiff. Where marked, Px refers to Plaintiffs
original numbering of the interrogatory, Dx refers to the actual number (cumulative to
that point) of the interrogatory.

#123445672548 -59 :;< =;> Please state youi full name, auuiess anu employei. If you aie
not employeu, when you weie last employeu in a full time capacity anu the name of youi
last full time employei, anu state if you aie ietiieu oi on uisability, anu if uisableu, what
type of uisability.
%1,?34 25 #123445672548 -59 :;< =;> My name is William John Joseph Hoge, III. I reside at
20 Ridge Road, Westminster, Maryland 21157. I am semi-retired, working part-time doing
occasional consulting work as an electrical engineer. I previously employed full-time by MEI
Technologies, Inc. at Goddard Space Flight Center, Maryland. My last day with MEI was 1 July,
2013. I have just recently started working again but will object to answering that portion of the
question as I was never employed by this company during the time covered by this lawsuit, and I
fear answering it may subject my employer to potential harassment. I cite generally similar
problems one of my co-defendants had concurrent with a previous litigation matter also
involving Plaintiff.

#123445672548 -59 :@< =@> Please state if you know the iuentity of youi co-uefenuant
Kimbeilin0nmaskeu
%1,?34 25 #123445672548 -59 :@< =@> I do not know the identity of Kimberlin Unmasked
(hereon KU).

#123445672548 -59 :@< =A> anu if you have evei spoken by phone oi Skype oi othei
telephonic uevice with Kimbeilin0nmaskeu. If so, please pioviue the uate, time anu all
iecoius you have iegaiuing the numbei oi name useu by Kimbeilin0nmaskeu.
%1,?34 25 #123445672548 -59 :@< =A> Mr. Hoge objects to this question on the grounds of
Privilege. KU is a co-defendant in this action and so they share a Common Interest. It is
uniformly held that under the common interest rule, parties with shared interests in actual or
pending litigation against a common adversary may share privileged information without
waiving their right to assert the privilege. Gallagher v. Attorney General, 787 A.2d 777 at 784-5,
(Md. App., 2001). Accordingly, Mr. Hoge objects and refuses to respond to this Interrogatory to
the extent that it seeks material that is privileged under the common interest rule, as
attorney/client communication, attorney work product and/or undertaken or prepared in
anticipation of this or related litigation. Further, Mr. Hoge objects because the Interrogatory is
overly broad in its scope and vague as to the time period covered by the request. Subject to and
without waiving these objections, Mr. Hoge notes the following: Prior to the filing of this lawsuit
by Plaintiff, Mr. Hoge had never spoken with anyone purporting to be KU. Any conversations
Mr. Hoge had with anyone purporting to be KU after the filing of this lawsuit would have been
for the purpose of sharing information generally about the Plaintiffs-initiated litigation and thus
privileged under the common interest rule. Further, any such conversations could not, by
definition, have been a factor in any of the allegations made by Plaintiff in his complaint. Finally,
to even include post-Complaint conversations would mean that Plaintiff is entitled to an ongoing
report of contacts between co-defendants. This would obviously be burdensome and unfair to Mr.
Hoge while providing nothing of relevance to Plaintiff.

#123445672548 -59 :A< =B> Please state if you have evei ieceiveu oi sent any emails, uiiect
messages oi othei communications with Kimbeilin0nmaskeu anu, if so, please pioviue
those communications.
%1,?34 25 #123445672548 -59 :A< =B> Mr. Hoge objects to this question on the grounds of
Privilege. KU is a co-defendant in this action and so they share a Common Interest. It is
uniformly held that under the common interest rule, parties with shared interests in actual or
pending litigation against a common adversary may share privileged information without
waiving their right to assert the privilege. Gallagher v. Attorney General, 787 A.2d 777 at 784-5,
(Md. App., 2001). Accordingly, Mr. Hoge objects and refuses to respond to this Interrogatory to
the extent that it seeks material that is privileged under the common interest rule, as
attorney/client communication, attorney work product and/or undertaken or prepared in
anticipation of this or related litigation. Further, Mr. Hoge objects because the Interrogatory is
vague as to the time period covered by the request and thus can be overly broad in its scope.
Subject to and without waiving these objections, Mr. Hoge notes the following: Email traffic
with Kimberlin Unmasked which pre-dates the Plaintiffs filing of this lawsuit and of which Mr.
Hoge still has a copy is attached as Appendix A. Mr. Hoge considers all email traffic after the
date of the original complaint as outside the scope of this document request. Alternatively, Mr.
Hoge withholds any email traffic with Kimberlin Unmasked subsequent to that date as Privileged
as it all relates to matters involving the litigation in the instant case as well as a related litigation
matter in Federal District Court, also instigated by the Plaintiff. Further, any such
communications could not, by definition, have been a factor in any of the allegations made by
Plaintiff in his complaint. Finally, to even include post-Complaint communications would mean
that Plaintiff is entitled to an ongoing report of contacts between co-defendants. This would
obviously be burdensome and unfair to Mr. Hoge while providing nothing of relevance to
Plaintiff.


#123445672548 -59 :B< =C> Please state if you have evei posteu on any of the
Kimbeilin0nmaskeu websites oi Twittei pages anu if so unuei what name.
%1,?34 25 #123445672548 -59 :B< =C> I have nevei submitteu a specific Post to the K0
websites oi on the K0 Twittei pages. I have maue comments to the Reaueis' Comments
section unuei the name W}}Boge.

#123445672548 -59 :B< =D> If so, who gave you access to the account, incluuing log in uata.
%1,?34 25 #123445672548 -59 :B< =D> No one - I have no special access to the account or any
login data. All my comments were made in the Comments Section which was available to all.

#123445672548 -59 :C< =D> Please state if you have evei useu any email auuiess associateu
with Kimbeilin0nmaskeu. If so, please pioviue those emails anu f you aie not the
iegistiant, please state how you came to be able to use the email.
%1,?34 25 #123445672548 -59 :C< =D> I have never used as my address an email address
associated with Kimberlin Unmasked.

#123445672548 -59 :D< =E> Please state if you have evei pioviueu any money oi othei
thing of value to Kimbeilin0nmaskeu, anu if so list the amount oi thing of value.
%1,?34 25 #123445672548 -59 :D< =E> I have never knowingly given any money or thing of
value to Kimberlin Unmasked.

#123445672548 -59 :E< =F> Please state if you aie familiai with the conseivative bloggei
anu Illinois u0P opeiative Lynn Thomas, who until iecently liveu in Stieamwoou, IL anu
now, accoiuing to some accounts, lists hei auuiess in St. Chailes, IL,
%1,?34 25 #123445672548 -59 :E< =F> I have heard of a Lynn Thomas. I cannot confirm the
additional details you have included in this Interrogatory.

#123445672548 -59 :E< =G> anu if so, have you hau any contact with hei, anu if so, please
pioviues uates, times anu content fiom those communications.
%1,?34 25 #123445672548 -59 :E< =G> I do not know her and have never knowingly had
contact with her.

#123445672548 -59 :F< =;H> Please state if you have evei useu a viitual Piivate Netwoik
oi any othei masking piogiam, softwaie oi app, to login to any website, email account, oi
comment foim, anu if so please state unuei what name, login, when, wheie anu how.
%1,?34 25 #123445672548 -59 :F< =;H> I do not use a VPN. I occasionally browse the
Internet using the TOR browser. In the past, I have used anonymizers such as anonymouse.org.
Neither TOR nor the anonymizers require logins.

#123445672548 -59 :G< =;;> Please state how much money you have iaiseu on youi blog
foi legal uefenses foi you oi anyone else ovei the past two yeais.
%1,?34 25 #123445672548 -59 :G< =;;> I raised a total of $3,565 for Tetyanas Fund, which
was for the benefit of Plaintiffs wife, Tetyana Kimberlin.

#123445672548 -59 :G< =;@> Please state how that money was spent.
%1,?34 25 #123445672548 -59 :G< =;@> All of the donations were refunded at her request.
#123445672548 -59 :;H< =;A> Please state if you use any "sockpuppet" oi anonymous
accounts to post on any othei sites oi youi own site anu if so please list the names of those
accounts anu wheie anu what you posteu using those sockpuppet accounts.
%1,?34 25 #123445672548 -59 :;H< =;A> . I have two pseudonymous Twitter accounts, a
promotional account in name of @JohnnyAtsign and parody account in the name of
@PBarnumDeceased. I post at eham.net under my amateur radio call sign W3JJH and post
at slashdot.org as audioengineer.


#123445672548 -59 :;;< =;B> Please state if you have been to a iesiuence locateu at 2uu
Capstone Biive, #1u8 in Lynchbuig, viiginia anu if so state when anu who you visiteu theie.
%1,?34 25 #123445672548 -59 :;;< =;B> No, I have nevei been to 2uu Capstone Biive,
#1u8 in Lynchbuig, viiginia.

#123445672548 -59 :;@< =;C> Please state the names, emails anu IP auuiesses of any
commenteis on youi BogeWash website who have stateu, implieu oi imputeu, uiiectly oi
inuiiectly, that Plaintiff has committeu a ciime. Please match the names anu iuentifying
infoimation to the paiticulai comment.
%1,?34 25 #123445672548 -59 :;@< =;C> I object to this interrogatory. First, it is overly
burdensome. I do not maintain a log of all commenters at my site nor do I catalogue the
substance of each of their comments. It is beyond my expertise to decide if a commenter
implied or imputed, directly or indirectly anything about Plaintiffs actions. The Plaintiff is
free to review the online comments at Hogewash! and apply his own judgment as to those
comments. Second, this interrogatory is overly broad as Plaintiff is a notorious felon, convicted
in many courts over the years. Therefore, many references to Plaintiffs crime commissions will
likely be based on well-documented history and outside the purview of relevant discovery. Third,
many of the commenters at Hogewash! are anonymous and are entitled to maintain their
anonymity.


#123445672548 -59 :;A< =;D> Please state if you have ieceiveu any money fiom any
peison oi oiganization ovei the past two yeais ielateu to Plaintiff.
%1,?34 25 #123445672548 -59 :;A< =;D> I have no knowledge of receiving any money from
any person or organization over the past two years related to Plaintiff. In other words, no one
has paid me or given me any money to write about the Plaintiff. Nor am I aware of any of
Plaintiffs relatives giving me money.


#123445672548 -59 :;B< =;E> Please state if you have hau any assistance with youi legal
filings, anu if so by whom.
%1,?34 25 #123445672548 -59 :;B< =;E> Ni. Boge objects anu iefuses to iesponu to this
Inteiiogatoiy to the extent that it seeks mateiial that is piivilegeu unuei the common
inteiest iule, as attoineyclient communication, attoiney woik piouuct anuoi piepaieu in
anticipation of litigation. Subject to anu without waiving this objection, I am iepiesenteu by
counsel. Bis infoimation can founu below.

#123445672548 -59 :;C< =;F> Please state if you aie the peison who iegisteieu
Kimbeilin0nmaskeu.Blogspot.com.
%1,?34 25 #123445672548 -59 :;C< =;F> No, I am not.

#123445672548 -59 :;D< =;G> If you aie not the iegistiant, please state the iegistiant who
useu the causalnexus.geoigegmail.com email to iegistei the Kimbeilin0nmaskeu site.
%1,?34 25 #123445672548 -59 :;D< =;G> I uo not know who the iegistiant is.

#123445672548 -59 :;E< =@H> Please state who has oi has hau access to the
Kimbeilin0nmaskeu Blogspot account.
%1,?34 25 #123445672548 -59 :;E< =@H> I woulu guess Kimbeilin 0nmaskeu, but I uo not
know foi suie.

#123445672548 -59 :;F< =@;> Please state who has maue posts on the above Blogspot
account.
%1,?34 25 #123445672548 -59 :;F< =@;> I woulu guess Kimbeilin 0nmaskeu, but I uo not
know foi suie.

#123445672548 -59 :;G< =@@> Please state if you gave othei peisons peimission to post on
the BlogSpot account.
%1,?34 25 #123445672548 -59 :;G< =@@> No; I have no peimission to give. It is not my
account.

#123445672548 -59 :@H< =@A> Please state if you iegisteieu the Kimbeilin0nmask
Twittei account.
%1,?34 25 #123445672548 -59 :@H< =@A> No, I uiu not iegistei that account.

#123445672548 -59 :@H< =@B> If you uiu not iegistei the Twittei account, please state who
uiu anu who has hau access to the Twittei account.
%1,?34 25 #123445672548 -59 :@H< =@B> I woulu guess Kimbeilin 0nmaskeu, but I uo not
know foi suie.
#123445672548 -59 :@;< =@C> Please state whethei you iegisteieu the BK0nmaskeu
Twittei account.
%1,?34 25 #123445672548 -59 :@;< =@C> No, I uiu not iegistei that account.

#123445672548 -59 :@;< =@D> If you uiu not iegistei that Twittei account, please state who
uiu.
%1,?34 25 #123445672548 -59 :@;< =@D> I uo not know who iegisteieu that account.

#123445672548 -59 :@@< =@E> Please state whethei you iegisteieu the
www.Kimbeilin0nmaskeu.com account.
%1,?34 25 #123445672548 -59 :@@< =@E> No, I uiu not iegistei that account.

#123445672548 -59 :@@< =@F> If you uiu not, please state who uiu anu what othei people
have access to that account anu if so who.
%1,?34 25 #123445672548 -59 :@@< =@F> I uo not know "who uiu anu what othei people
have access to that account."
#123445672548 -59 :@A< =@G> Please state whethei you have ieceiveu any iemuneiation
foi cieating oi using the Blogspot, .com oi Twittei accounts above. If so, please state the
amounts anu fiom whom.
%1,?34 25 #123445672548 -59 :@A< =@G> I have ieceiveu no "iemuneiation foi cieating oi
using the Blogspot.com oi Twittei accounts above."

#123445672548 -59 :@B< =AH> Please state the email oi emails associateu with the
iegistiation of the foui accounts above.
%1,?34 25 #123445672548 -59 :@B< =AH> I uo not know "the email oi emails associateu
with the iegistiation of the foui accounts above."

#123445672548 -59 :@C< =A;> Please incluue copies of all communications to anu fiom
those peisons who have hau access to the foui accounts above, if you know.
%1,?34 25 #123445672548 -59 :@C< =A;> I uo not know, so no copies attacheu.

#123445672548 -59 :@D< =A@> Please state any othei names you have useu to post on the
Inteinet, ieal oi anonymous, ovei the past five yeais.
%1,?34 25 #123445672548 -59 :@D< =A@> . I object to this interrogatory as it is overly broad,
covering a time period well in excess of the applicable time period covered in Plaintiffs
complaint. Subject to anu without waiving this objection, I have used the following identities
on the Internet since 2009:

William Hoge, William.J.Hoge, W. J. J. Hoge, WJJ Hoge, wjjhoge, John Hoge,
himself@wjjhoge.com, hogewash@wjjhoge.com, himself@wjjhoge.net, audioengineer, w3jjh,
W3JJH, w3jjh@arrl.net, @JohnnyAtsign, @wjjhoge, @hogewash, @PBarnumDeceased,
Phineas T. Barnum



From: WJJ Hoge himself@wjjhoge.com
Subject: If BS' AR15 is real ...
Date: 7 April, 2013 at 1546
To: kimberlinumasked@hush.com
then the 30 round magazine may be real.
4-305. Detachable magazines -- Prohibited
(a) Scope of section. -- This section does not apply to a .22 caliber rifle with a tubular
magazine.
(b) Prohibited. -- A person may not manufacture, sell, offer for sale, purchase, receive, or
transfer a detachable magazine that has a capacity of more than 20 rounds of ammunition for a
firearm.
If BS acquired the magazine before 1994 or if he physically left the state, acquired the magazine, and brought it into Maryland himself, that
isn't prohibited. OTOH, if someone else brought the magazine into the state after 1994 and BS subsequently acquired it by any means, then
the following may apply.
4-306. Penalties
(a) In general. -- A person who violates this subtitle is guilty of a misdemeanor and on
conviction is subject to imprisonment not exceeding 3 years or a fine not exceeding $ 5,000 or
both.
WJJ Hoge
himself@wjjhoge.com
APPENDIX A