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Case 8:13-cv-03059-GJH Document 335 Filed 01/29/16 Page 1 of 6

UNITED STATES DISTRICT COURT


DISTRICT OF MARYLAND
BRETT KIMBERLIN,
Plaintiff,

Civil Action No.: 8:13-CV-03059


(GJH)

vs.
PATRICK FREY,
Defendant.

OPPOSITION TO PLAINTIFFS MOTION TO VACATE PROTECTIVE ORDER


Defendant Patrick Frey, through the undersigned counsel, respectfully submits this
opposition to the motion of plaintiff Brett Kimberlin to vacate this Courts protective order.
Plaintiff claims that several reporters have contacted him to ask to review the discovery
produced by Mr. Frey in this action. In fact, however, these reporters current or former
bloggers at a Web site, breitbartunmasked.com, which is no more than a vehicle created by longtime confederates of plaintiff, two of whom are Bill Schmalfeldt and Matt Osborne, and which is
operated in cooperation with him for the sole purpose of harassing his critics.
Plaintiffs rationale does not constitute a legitimate reason for the Court to lift the
protective order. It is simply a ruse by which he hopes to utilize this litigation to strip Mr. Frey of
as much of his privacy and dignity as possible, such as by publishing his personal emails and
details of his private and professional life on the Internet, despite the absence of any bona fide
public purpose, much less any relation to this litigation. These reporters, whose own secondhand (i.e., hearsay) requests form the basis of plaintiffs application, are no more than beards
whose (hearsay) inquiries are mere pretexts to advance plaintiffs admitted lawfare objectives.

Case 8:13-cv-03059-GJH Document 335 Filed 01/29/16 Page 2 of 6

The bad faith at the root of this request cannot be established without placing before the
Court some sense of what the individuals in question have, as a matter of public record, made
quite clear concerning their objectives in assisting plaintiff in this litigation. Schmalfeldt, for
example, published a violent fantasy about murdering Mr. Frey and his counsel in another
matter, Kenneth P. White, a partner at the firm of Brown, White & Osborn in Los Angeles, in
which Schmalfeldt writes, among other things:
And I am NOT saying that Patrick Frey and Kenneth White deserve to be dragged
from their offices, out to the street in front of their offices, and thus have their
knees broken by ANYTHING, be it a tire iron, or a lead pipe, or a lead-filled
baseball bat. Nor should they be taken by a group of four or five strong men (or
women) and thrown in front of a moving truck. You would have to consider the
emotional damage that would be done to the innocent truck driver, unless the
truck driver agrees to be part of your conspiracy in the first place. And a truck
might swerve to miss Mr. Frey and/or Mr. White, the driver could lose control,
jackknife his trailer and cause a lot of damage to people and property. And if its a
truck with a hazardous payload, like sulfuric acid, I dont think I need to tell YOU
how severe the environmental damage would be.
This material is available at the following website:
anonymouse.org/cgibin/anonwww.cgi/http:///popehatandpattericowhineaboutretaliation/,
last accessed January 27, 2016.
In a similar vein, Osborne penned his own paean to the infliction of pain and torture on
ideological foes in a passage that vividly describes the torture-murder of conservative
commentator Rush Limbaugh:
With a coordinated yanking, Sam and I pulled his legs apart like a wishbone so
that Top could steady himself against the ceiling and give Rush Limbaugh a
powerful kick in the testicles.
Limbaughs scream retreated into his chest. He coughed, strained for air, and
snapped into the fetal position again. We grabbed his legs and pressed his feet flat
on the floor of the van so Top could step on the toes with his artificial foot, slowly
increasing the pressure until Rush Limbaughs sobbing was a plea. Then we
applied Chloroform to the whimpering sack of excrement before us and settled in
for a good, long drive.
2

Case 8:13-cv-03059-GJH Document 335 Filed 01/29/16 Page 3 of 6

This material is available at http://southofstrange.blogspot.com/2009/04/tortureof-rush-limbaugh-ch2.html, last accessed January 29, 2016.


Moreover, the Court may gain a sense of the intended use to which the requested
disclosure would be put from the past practice of the reporters on which plaintiff relies on their
Breitbart Unmasked site, which once dedicated an entire post to one of Mr. Freys commenters
precisely because he was a critic of plaintiff in this action, and which demonstrates exactly why
the protective order in place here is necessary and why plaintiffs motion should be denied.
In the incident in question, the post about the critic of Brett Kimberlin published by the
reporters on which he now relies not only contained his full name and photograph. It also
included detailed information about where the commenter allegedly worked; delved into details
about the commenters marriage, including the name of the commenters wife as well and also
added divorce records. The post then listed the job title of the commenters father, listed past
cities where the commenters father had lived and worked, and published a photo of the
commenters home from Google Street Images.
The message from plaintiffs reporter allies was clear. Mr. Frey is familiar with this
treatment: not long after he started writing about plaintiff, a Web site operated by plaintiffs nonprofit (as evidence by the fact that a donation button on the site went to plaintiffs Velvet
Revolution non-profit) also published the address and Google Street View images of Mr. Freys
home.
Plaintiff argues that under Rushford v. New Yorker Magazine, 846 F.2d 249, 253 (4th Cir.
1988), this Courts protective order violates the presss First Amendment rights. should
overcome Freys protective order. But in Rushford, a newspaper sought to obtain a motion for
summary judgment and the exhibits to that motion, after the summary judgment motion had been

Case 8:13-cv-03059-GJH Document 335 Filed 01/29/16 Page 4 of 6

granted and the case had been dismissed and even then, the Fourth Circuit held that the
protective order should be enforced before any summary judgment motion was filed, as is the
procedural posture here.
The Court went on to explain that, in contrast, only after a motion for summary
judgment was filed by the party protected by the protective order, would any exhibits
attached to that motion be treated as exhibits submitted at a trial. The newspaper would be
permitted access to them precisely because the exhibits were filed by the very party that had
sought to protect them. Here, however, Mr. Frey has not filed, submitted or in any way relied on
any of his own private emails or other materials produced by him in discovery, either as exhibits
to a summary judgment motion or for any other purpose. Thus neither the holding nor the
rationale of Rushford have no application here.
If it were otherwise, and plaintiff were correct, merely propounding irrationally broad,
burdensome and intrusive discovery would automatically render all pretrial discovery a matter
of public record. There would be no standard whatsoever for the entry of protective orders or
their maintenance, and merely succeeding at not having a lawsuit dismissed would enable a
litigant to turn his adversarys private life into an endless stream of Internet fodder.
Of course, it is no secret this has been precisely plaintiffs intention in bringing this
action and filing this motion; he and his confederates have admitted the same freely. But neither
Rushford nor any other case support their scheme, and this application should be denied.
WHEREFORE Defendant Patrick Frey respectfully requests that this Honorable Court
deny Plaintiffs motion to lift the protective order.

Case 8:13-cv-03059-GJH Document 335 Filed 01/29/16 Page 5 of 6

Respectfully submitted,

____________________________
T. Bruce Godfrey #24596
Jezic, Krum & Moyse LLC
2730 University Blvd. West, #604
Silver Spring, MD 20902
240-292-7200
facsimile: (888) 241-3135
godfrey@jezicfirm.com
ARCHER & GREINER
A Professional Corporation
By:______________________________
Ronald D. Coleman (Pro Hac Vice)
Court Plaza South
21 Main Street, Suite 353
Hackensack, NJ 07601
201-342-6000
rcoleman@archerlaw.com
Attorneys for Defendant Patrick Frey
Dated: January 29, 2016

Case 8:13-cv-03059-GJH Document 335 Filed 01/29/16 Page 6 of 6

CERTIFICATE OF ELECTRONIC FILING AND REGARDING WAIVER OF


MAILINGS
I, T. Bruce Godfrey, hereby certify that I have filed a copy of this document with the
United States District Court electronically and by so doing have provided compliant notice to
those parties who are registered with ECF through counsel as of this filing consistently with
Local Rule 102.1(c) on January 29, 2016. Additionally I have provided an electronic copy of
this document by email to Plaintiff Brett Kimberlin by consent on that date. All parties,
including pro se parties, have agreed to accept service by electronic mail only and an electronic
copy has been distributed to all parties.
_________________________________
T. Bruce Godfrey #24596

1/2/13

@Popehat and @Patterico Whine About Retaliation | Breitbart Unmasked [Anonymoused]

01

03

2013

Case 8:13-cv-03059-GJH Document 335-1 Filed 01/29/16 Page 1 of 7

Headline:

TheLiberalGrouch,
Editor
I'llGrindYerBonest'MakeMe
Bread!Har,Har,Har!
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@POPEHATAND@PATTERICOWHINEABOUTRETALIATION

@Popehatand@PattericoWhineAboutRetaliation
Postedabout4daysago | 9comments
Writtenby:LiberalGrouchonDecember29,2012.
Readthis,andtrynottobemovedtotears.

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INTERESTINGBLOGS

AndrewSullivan
AngryBlackLady
CrooksandLiars
DemocratsForProgress
DeusExMalcontent
DiaryofaRpublicanHater
ExtremeLiberal
LiberalValues

Thesepoor,downtroddenRWNJsareTRYINGtoenjoytheirlittlemeanhighschool
cheerleaderbitchwhosuckedthemostestin2012pollandpeoplearetryingtoRUIN
theirFUNbyRETALIATING!
Canyoufeelthesadness?TheheavyweightofdarknessinpoorDeputyDistrictAttorney

LittleGreenFootballs
MotorCityLiberal
NealRauhauser

forLosAngelesCountyPatrickFreysheartashewasforcedtorevealthefearinwhich
helives?Ashewhinestothelawyerwhoisdefendinghiminacivilsuitforpublishinga
womansSocialSecuritynumberandpersonalmedicalinformationaboutthehorrible,
horribleRETALIATIONbeingRETALIATEDagainsthimandotherswhobelieveBrett
KimberlinsuckedmorethananyoneelsecouldPOSSIBLYsuckin2012?

Osborneink
PatriotOmbudsman
PlanetPOV

OnemightthinksomeonehadtakenpoorPatrickFreysofficetelephonenumber(213
9740524,Fax2136873128)orhisofficeaddress(210W.TempleSt.,Room171116,
LosAngeles,California,90012)andsuggestedthattheybeusedtoimproperlyharass
Mr.Freyastherearerepercussionstobehadfortakingtheprivate,personalinformation
ofaninnocentwomanandusingitinRETALIATIONagainstherforsuingafriendofhis.
NobodyIknowwouldeverCONSIDERdoingsuchathing,howeverdeserveditmaybe.
Itwouldbewrong.Andtwowrongsdonotmakearight.(AlthoughTHREErightsmakea

PleaseCutTheCrap
PoliticalRuminations
PragmaticObotsUnite
Qritiq

LEFT!)
Butletyourheartsnotbeheavy,gentlereader.I,forone,donotbelievethereisany
actualretaliationgoingonhere.DeputyDistrictAttorneyFreyjustSAYShesbeing
retaliatedagainst.HedoesntactuallyidentifywhatFORMthisretaliationistaking.
Isaythatunlesssomeoneisdragging@Popehat

SallyKohn
TheeXiled

WETWEET!

"If@Pattericodideven1%ofthethings
anonymouse.org/cgibin/anonwww.cgi/http:///popehatandpattericowhineaboutretaliation/

1/7

1/2/13

@Popehat and @Patterico Whine About Retaliation | Breitbart Unmasked [Anonymoused]

Case 8:13-cv-03059-GJH Document 335-1 Filed 01/29/16 Ms.Naffealleges,whyishestillin


Page 2 of 7
office?:http://t.co/auMSykaJ#p2
#tlot"

"Listento"Grouchcastfor12/27/2012"via
@spreakerhttp://t.co/73wOBP7R"

FO L L O W @B RE I TB A RTUNMA S K O N TWI TTE R

andFreyOUTOFTHEIROFFICESandBREAKINGTHEIRKNEESWITH
BASEBALLBATSbecauseofthis,thenthereisnothingforthemtoworryabout.Words
arejustwords,andtheycannotharmyou.Sticksandstones,astheysay.
Or,baseballbats.
AndletitNOTbesaidthattheLiberalGrouchadvocatesanyoneusingbaseballbatsto
breakthekneecapsofeitherMr.WhiteorMr.Frey!Nothingcouldbefurtherfromthetruth.
Infact,ifyouhaveitinyourmindthatifNadiaNaffewereafriendofyoursandsome
scumbagattorneyusedthepowersofhisofficetodigupanduseprivateinformation
againsther,whoeverdidit(ordefendshim)DESERVEStohavetheirkneesbrokenwith
baseballbats,letmedissuadeyouofthatnotionhereandnow.
Thatisnotwhatbaseballbatsweremadefor.
Foronething,awoodenbatcouldbreakifitwereusedinsucharecklessandlawless
fashion.Andifyouthinkyoucangetaroundthatbyusinganaluminumbat,guessagain.
Analuminumbat(unlessitisreinforcedwithaleadcenter)wouldlikelybendundersuch
pressure.Now,Ihearthecraftyonesouttheresaying,Yeah?Well,whatifIdrilloutthe
centerofaWOODENbaseballbat,fillITwithlead,coverthetipwithPlasticWood?
WouldntTHATdothejob?
Again,Isay,youarewastingyourtimewithallthateffort.Tireironsaremuchmore
readilyavailable.
AndIamNOTsayingthatPatrickFreyandKennethWhitedeservetobedraggedfrom
theiroffices,outtothestreetinfrontoftheiroffices,andthushavetheirkneesbrokenby
ANYTHING,beitatireiron,oraleadpipe,oraleadfilledbaseballbat.Norshouldthey
betakenbyagroupoffourorfivestrongmen(orwomen)andthrowninfrontofamoving
truck.Youwouldhavetoconsidertheemotionaldamagethatwouldbedonetothe
innocenttruckdriver,unlessthetruckdriveragreestobepartofyourconspiracyinthe
firstplace.AndatruckmightswervetomissMr.Freyand/orMr.White,thedrivercould
losecontrol,jackknifehistrailerandcausealotofdamagetopeopleandproperty.Andif
itsatruckwithahazardouspayload,likesulfuricacid,IdontthinkIneedtotellYOU
howseveretheenvironmentaldamagewouldbe.
So,NO!DoNOThitMr.Freyand/orMr.Whitewithbaseballbatsorleadpipesortire
ironsontheirknees,arms,elbows,shins,oranyotherpartsoftheirbodies.Itwouldbe
painfulanddegrading,moresotoyouasanoutraged,butotherwiselawabidingcitizen.
anonymouse.org/cgibin/anonwww.cgi/http:///popehatandpattericowhineaboutretaliation/

2/7

1/2/13

@Popehat and @Patterico Whine About Retaliation | Breitbart Unmasked [Anonymoused]

Case 8:13-cv-03059-GJH Document 335-1 Filed 01/29/16 Page 3 of 7

Itwouldruinyourlife.Iftheauthoritiescaughtyou.Andiftheydid,iftheypressed

charges.Iunderstandinsomecommunities,theauthoritiestendtoturnablindeyeto
bulliesgettingtheirdeservedcomeuppance.IdontthinkLosAngelesissucha
community.
So,letsleavethingsastheyare.LetMr.FreyandMr.WhiteFEELtheyarebeing
retaliatedagainstinawarofwordstheystartedandarebeingsmearedwithfecesbeing
hurledbackatthemafterbeingfirsthurledBYthem.Letyourselfnotbedraggeddownto
theNeanderthallevelofaMr.FreyoraMr.White(oraMr.R.StacyMcCainoraMr.Lee
StranahanoraMr.AliAkbaroraMr.AaronWorthing)anddegradeyourselfbyusing
bruteforcetopunishthemfortheirmany,manyalleged(byme)crimesagainstnature
andhumanity.
Knowthatthesternestpunishmentonecanlegallyemployagainstsuchblackguardsis
thesureandcertainknowledgethatwhentheyawakeinthemorning,theywillstillbe
Them.
AndletGoddealwiththeirsins.AsHewill.Probablywithsoresandpainfulboils.On
theirfaces.
Tags:baseballbats,breaking,BrettKimberlin,civilsuit,deputydistrictattorney,featured,
frey,gentlereader,grouch,headline,heavyweight,highschoolcheerleader,innocent
woman,kne,mostest,officeaddress,officetelephone,retaliation,room17,socialsecurity
number,sticksandstones,templest,top,twowrongs
LiberalGrouch

Averygrouchyliberalwhohasseenwhattherightwingwantstodoand
vowstostopthem.TheBreitbotsaretheworstofthebunch.Wewillstep
ontheirthroatsuntiltheairstopsmovingintheirlungs.Metaphorically.
ViewallpostsbyLiberalGrouch

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9COMMENTSON@POPEHATAND@PATTERICOWHINEABOUTRETALIATION

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@Popehat and @Patterico Whine About Retaliation | Breitbart Unmasked [Anonymoused]

Case 8:13-cv-03059-GJH Document 335-1 Filed 01/29/16 Page 4 of 7

@OccupyRebelliononDecember30,2012at2:07am

ItsurewouldbeswellifLosAngelesDeputyDA
PoopericogavesomesortofEVIDENCE&FACTS
astowhatthehellhestalkingabout.ButIforgotIm
dealingwithasociopathhere.ThesamesociopathS
inAaronsemailsthatshowedthemallframing
people,settingpeopleup,conspiracyplots,and
stings.
Reply

LiberalGrouch
onDecember30,2012at6:32am

EVIDENCE?WhyTHATSforPUNKS!Yeah!
Ysee?Yeah!Yeah!
Reply

@OccupyRebelliononDecember30,2012at8:33pm

Whyis@Liberty_ChickagainstRoseanneBarrtrying
tohelpintheSteubenville,Ohiogangrapecase?
MandytweetedalinktoaGawkerarticletitledWhy
isRoseanneBarrAligningHerselfwithAnonymous
andCallingHerselfRononomous?
Mandyclaimstobearapevictimbutshetweetsout
alinkwhereotherBreitbarttrashthenstartattacking
rapevictimRoseanneforaligningherselfwith
AnonymousintheSteubenvillegangrapecaseofan
underageteen.
Mandyearlierclaimedshewassoupsetaboutthe
gangrapecaseinIndiawherethegirllaterdied.But
heywhocaresaboutthegangrapecasein
Steubenville??MandyslawyerPopehattriedtohelp
bloggers/commentorsinthatcasewhowerebeing
suedbyoneoftherapistsfordefamation.
IsMandyonlyclaimingtobeupsetaboutthe
gangrapecaseinIndiabecausesheshopingthe
rapistsmightbeMuslim??
SoitsperfectlyfinethatRoseanneBarralignsherself
withgoodfriendLeeStranahanbutitsnotokayifshe
alignsherselfwithAnonymous??IwouldLOVEto
knowMandysthinkingbehindallthis.
IhadtweetedtoRoseanneafewtimesbeforetelling
heraboutStranahanbeingarape&pedophile
apologist,releasingarapevictimsnameforcoming
forwardaboutwhatGeorgeZimmermandidtoher,
anonymouse.org/cgibin/anonwww.cgi/http:///popehatandpattericowhineaboutretaliation/

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@Popehat and @Patterico Whine About Retaliation | Breitbart Unmasked [Anonymoused]

Case 8:13-cv-03059-GJH Document 335-1 Filed 01/29/16 Page 5 of 7

andforbeingoutragedthatoccupierscameforward

aboutbeingrapedbypolice.Sheneverrepliedtome
eithertimeItweetedtoher.
Themorepeoplewhoshineaspotlightonrape
happySteubenville,thebetter.Iwouldhavethought
thatsocalledrapevictimMandywouldhaveput
politicsasideandwantthisgirltogetsomebitof
justice.Idontseehertryingtohelpinthecasewhile
Anonymousis.
Theyounggirlwasliterallydraggedfrompartyto
partybythefootballteambeinggangrapedinfrontof
partiers.Isawoneofthepicturesofherwheretwoof
herrapistswereaboveherlaughing,shewasonthe
floor,onewasdraggingherbyherlegs,whilethe
otherwasdraggingherbyherarms.Theycall
themselvestheRapeCrew.
Ifanyonewantstodoastoryonthecase,Icansend
thepicturetoyou.Oneoftherapistspostedthe
pictureonhisownaccount!!!Shesclothedand
blurredinthepicture.
https://twitter.com/Liberty_Chick/status/285129153672540160
WhyisRoseanneBarrAligningHerselfwith
AnonymousandCallingHerselfRononomous?
@Gawkerhttp://gawker.com/5971947/whyis
roseannebarraligningherselfwithanonymousand
callingherselfrononomous
Reply

@OccupyRebelliononDecember31,2012at7:26pm

Thisisprobablyasign.Iprobablyhaventwatchedan
InsideEditionshowinyears.TheonlyoneIwatched
wasrecentlywastheonewhichhadWeinergateco
pilotMikeStackonit.ImherenowwiththeTVonin
thebackgroundandtheyreplayingthesameStack
episodenowwithDarbysvoiceinthe911call.
Reply

@OccupyRebelliononDecember31,2012at7:26pm

HAPPYNEWYEAREVERYONE!!!!
Reply

XCitizen10onDecember31,2012at9:04pm

HappyNewYearLady.Ihopethatjusticeisserved
thisyearonthatreprehensiblecrewofsociopaths.
anonymouse.org/cgibin/anonwww.cgi/http:///popehatandpattericowhineaboutretaliation/

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@Popehat and @Patterico Whine About Retaliation | Breitbart Unmasked [Anonymoused]

Case 8:13-cv-03059-GJH Document 335-1 Filed 01/29/16 Page 6 of 7

Reply

@OccupyRebelliononJanuary1,2013at5:32pm

Gettingjusticeisslow,drawnout,painful,and
exhausting.IwishthisyearwouldbetheendofitbutI
haveafeelingitwont.Unfortunately.
Reply

rmnixondeceasedonJanuary2,2013at11:29am

Theseasshatscauseusdeadfolksmuch
consternation.AlmostlikethatasshatSpiroAgnew
whoplaguesmeasmuchdeadashedidalive!
Reply

@OccupyRebelliononJanuary2,2013at5:17pm

Likethesamepeoplewhoaresoupsetatpeople
whoarehopingGeorgeH.W.Bushdies.Thesame
peoplewhowouldbedancingnakedatthelocalbar
ifBillClintondied.Manyrepublicansdonteven
supporteitherBush.NeitherBushwasnteveninvited
tothe2012RNC.Butnowtheyclaimtobesoupset
thatpeoplearehopinghedies.
Letsberealhere.TheMichelleMalkinsoftheworld
donotcareifBushlivesordies.Theywouldpreferhe
diessotheycanblameLiberalsforsupposedly
mockinghisdeath.IwouldntcheerBushsdeath
eventhoughInevercaredfortheguy.BothBushs
areBillClintonsbestfriends.Theyallbecamemore
likableafterleavingoffice.Whichisthecasewith
everypresident.
ButifsomeonewantstomockBush,thenitstheir
rightforwhateverreason.ItscalledFREESPEECH,
isntit?Hedidalotofhorriblethings,likemost
presidentsdo.ItsnotlikeBushisa17yearoldkid
holdingskittles&iceteamindinghisownbusiness
walkingbacktothehomehewasstayingatgunned
downbyapedophile.Thesamepeoplewhowere
dancingonTrayvonMartinsgravehaveNORIGHT
tocomplainifpeoplesaywhateveraboutBush.
Theguyis88yearsold.Helivedalonglife.Wouldit
surpriseanyoneifhediddie?Iwasmoreshocked
thatSchwarzkopfrecentlydied.Thepeoplewhowere
tearingapartadeadteenagerarethesamepeople
upsetoveranyonehappyan88yearoldguymight
anonymouse.org/cgibin/anonwww.cgi/http:///popehatandpattericowhineaboutretaliation/

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@Popehat and @Patterico Whine About Retaliation | Breitbart Unmasked [Anonymoused]

Case 8:13-cv-03059-GJH Document 335-1 Filed 01/29/16 Page 7 of 7

die.Iwouldntcheeronanyonesdeath.Unlessits

peoplelikeBinLaden,CharlesManson,andGeorge
Zimmerman.
TheyrealsomockingHillaryClintonshealth
problemstoo.Shehasahistoryofthis.Reportsare
thatherconstanttravelingmayhaveleadtothis.
Sittingtoolongonplanesforhoursonendyearafter
yearcandothat.LookathowDavidBloomdied.
Similarsymptoms.Toomuchtravelingandtoomuch
sitting.Getupfromyourcomputersandwalkarounda
bit!!Theyrecommendeveryhalfhour.
Reply

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1/24/2016

South of Strange: The Torture of Rush Limbaugh [Anonymoused]

Case 8:13-cv-03059-GJH Document 335-2 Filed 01/29/16 Page 1 of 10

WEDNESDAY, APRIL 22, 2009

WHO IS MATT OSBORNE?

The Torture of Rush Limbaugh


From the motels security room, Robert guided us to our target: Hot
water, he signaled. Objects one. This meant chief voice of the
Republican Party was dodging drafts in the indoor hot tub. We all
acknowledged and proceeded. Because capturing the demagogue was
the most dangerous part of our plan, it was the most carefully
rehearsed; we had covered seven different scenarios, training to the
Colonels exacting standards.
The extraction went like clockwork. Sam, Don, and I carried out the
kidnapping in less than two minutes. Rush Limbaugh objected to our
masked, armed entry, but was immediately subdued with the help of
a taser. We gagged, hooded, and handcuffed the fat bastard before
levering him into a wheelbarrow with scrap twobyfours.
Keying my mike, I whispered the word secured.

Matt Osborne writes fiction under a


fictitious name. He lives in a secure
and undisclosed location. He has
been mortally afraid of the number
23 since the age of 24. He is most
commonly sighted stalking a good
song in the NW Alabama area on
warm weekend nights. He denies any
involvement with the political blog
known as Osborne Ink.

Roger. Tango, Robert replied, naming our exit route. We left the
scene while Robert pointed the critical camera in another direction.
Our threats of immediate execution kept Rush Limbaugh silent until

THIS BLOG SHAMELESSLY


INFLUENCED BY:

he heard the van, specially modified for paraplegic drivers, come to a

ERROR

halt almost on top of him. With a supreme effort, we dumped the


demagogue into the van and climbed in after him, abandoning the
wheelbarrow.

The
requested
URL
could
notbe
retrieved

The Colonels oporder was extremely detailed, right down to the


unwritten insults: Rush Limbaugh is so fucking fat, we had to use a
wheelbarrow.
Underway, the three of us in back took turns kicking Rush Limbaugh
in his stomach with our combatbooted feet (Top using only his solid
prosthetic foot). Rush Limbaugh made a terrified scream through the
gag. He tried to curl into a fetal position, but the gelatinous mass of
fat on his stomach forestalled him. Drawing my Tanto knife, I cut
away at his swimming trunks and ripped them from his naked body,
causing him to scream again. His genitals looked pathetically small
under his putrescent flab. Sam and I each took one leg, straining

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against all his strength, for he knew exactly what we intended, and
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shrieked at the imminent damage to his manhood. With a

Comments

coordinated yanking, Sam and I pulled his legs apart like a wishbone
so that Top could steady himself against the ceiling and give Rush
Limbaugh a powerful kick in the testicles.
Limbaughs scream retreated into his chest. He coughed, strained for
air, and snapped into the fetal position again. We grabbed his legs
and pressed his feet flat on the floor of the van so Top could step on
the toes with his artificial foot, slowly increasing the pressure until

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Rush Limbaughs sobbing was a plea. Then we applied Chloroform to


the whimpering sack of excrement before us and settled in for a
good, long drive.
Driving far out of our way was an essential part of Operation

U.K. TELEGRAPH NEWS OF THE


WEIRD

Punchface. Our first destination was no more than a fortyfive minute

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drive from the hotel, but we didnt want Rush to sense this; we
wanted him disoriented in time and location to encourage feelings of
hopelessness.

WEEKLY WORLD NEWS

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First was a scheduled stop at a highway gas station. Sam had
arranged for the automatic car wash to be left on after the store was
closed. The Colonel supplied a roll of quarters; five minutes later,

WEIRD NEWS BITS.COM

the waterbased paint was gone, and whereas a skyblue van had

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kidnapped Rush Limbaugh, we were now in a dark green van.


Less than one minute with a cordless drill, and the van had its
original licenseplate back on. The Colonel was one hell of a planner.

STRANGE YOUTUBE

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We turned back onto the highway and made for the interstate.
Altogether, we spent six hours on the move. At one point, we revived

ODDLY ENOUGH

Rush Limbaugh with kicks to the stomach so he could hear the section

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of highway passing under us. He soiled himself on the blue plastic


tarp as we snapped on rubber gloves to insert a soporific suppository.
He remained unconscious all the way to the prison, reviving only

MSNBC WEIRD NEWS

when we forcemarched him into the building and deloused him.

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Finally, we applied Chloroform and laid him on the mat in his new
home, a small cinderblock cell. Wed set up a heater and humidifier
to turn the basement into a sweltering, Central American summer.
He woke up an hour later, gasping and wiping sweat from his
gelatinous folds. We recorded him crawling across the dirty concrete
floor. He retched into a disgusting, lidless toilet. After a few dry
heaves, he wept into his fat hand for a moment, collected himself,
and roared his desire to do us harm.
It was time to begin.
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We opened the metal door with a slamming insistence. Sam and I had
spent an entire afternoon on the installation, making sure it had
precisely the right kind of booming clank when open or shut. The
Colonel gave orders through a megaphone, mixing choice foreign
phrases into his invective: Yallah! Sieze the fatass! Vamos! Drag his
worthless fat ass out here!
All carefully rehearsed. All specially chosen. Operation Punchface
had consumed us all, most especially the Colonel, in the month since
wed learned where the great gasbag would next be speaking.
Robert sicced the German shepherd on Rush Limbaugh, giving it just
enough lead to chase the cowering talk radio king to the back corner
of the cell. Sam and I stepped in as soon as Robert called the dog to
heel.
Rush Limbaugh blubbered, his face contorted in fear as we
approached. We were masked and bore cattleprods at portarms,
like rifles. Oh, no, he moaned, turning. He scratched at the
cinderblocks in his fear, trying to escape an eightbysix foot cell.
We shocked him. He collapsed. We shocked the supine sophist again
before dragging him out into the hall.
The Colonel cursed Rush Limbaugh for a whoreson in Arabic. You
will learn to respect authority, ya ibn sharmouta. He switched to a
bit of Dutch: When we say goede tag, you will greet us with your
backside and your hands on the wall!
After applying hood and handcuffs, we forced Rush Limbaugh to walk
through a plywood maze. It was very important to disorient him this
way. The demagogue gasped for air, fighting to suck oxygen through
the burlap. Finally, we reached the torture chamber and pulled the
hood off so he could take in the tableau we had prepared.
Rush Limbaugh blinked at the light of a single naked bulb.
The Colonel sat in a lounge chair with torn fabric. A bucket sat by the
end of a sixfoot long wooden ramp reinforced with twobyfours.
Waterboarding?! Rush Limbaugh erupted. Still maintaining a veneer
of resistance, he made the word sound as if he had just gotten the
joke, and was not amused.
Live your rhetoric, fatass. The Colonel was the only one of us who
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South of Strange: The Torture of Rush Limbaugh [Anonymoused]

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spoke to Rush Limbaugh. The rest of us had taped out mouths shut to

avoid thoughtless violations of this rule. It was critical that the


Colonels voice be the only one Limbaugh could hear during our
enhanced interrogations.
Rush Limbaugh protested his poor health as we strapped him down.
Do you fear for your constitution? The Colonel asked him. This is
not the draft board, you sniveling turd. You kelb. We wont excuse
you from our service because of hemorrhoids.
Who are you people? Rush Limbaugh demanded as we reinforced
his bonds with duct tape which we would later rip from his flesh.
We are a taxraising, sushimunching, Volvodriving, New York
Timesreading, body piercing, Hollywood loving left wing freak
show, the Colonel said. He never raised his voice a decibel,
delivering his lines in a cool, smooth tone quite eerie, I have to
admit; even I felt a shudder to hear him. We are leftcoast latt
sipping moonbats. We pal around with terrorist appeasers and plot to
install socialism in America and force everyone into gay marriage.
Democrats, Rush Limbaugh spat. He wiggled his head, trying to
refuse the blindfold. Did Nancy Pelosi put you up to this? I always
knew that bitch woul
I punched him in the face. Catharsis became more than a word: the
sound and effect were so satisfying that I punched him again, and
then again, each blow more satisfying than the last, with greater
precision and strength, so that for a moment I wanted to keep
punching Rush Limbaugh in the face until he was destroyed.
Enough, the Colonel said, assuming a voice of authority. He cursed
in Japanese.
A tense moment followed. It was not the first in our groups history. I
should explain that his rank was just an ironic title, a moniker earned
in a poker game. Having humorously declared the establishment of
his own militia group with the sole purpose of becoming its ranking
officer, he demonstrated his authority: You boys can call me
Colonel, he said, handing an empty beer bottle to Top. Top, he
commanded, get the Colonel another beer.
Top is an affectionate nickname for First Sergeants. Prior to his loss
of limb, Top had been exactly that. Now he took the empty. Sure,
Colonel. Would his colonelness like his diaper changed as well?
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For one dangerous instant, the entire room stopped breathing. Top
had directly challenged the manhood of a soldier missing a key half
inch of spinal cord, condemned to a lifetime of sexless incontinence.
But the Colonel spun his wheelchair around to point at me, retorting:
No thanks, Top. Thats the Majors job.
The joke brought the house down and formed our little band of
broken brothers in one instant.
For myself, I had, in fact, been a major once, and the highestranking
expert on Arab extremists in the US Air Force until the bombing of
Khobar Towers took my eye and most of the mobility in one arm.
Robert was missing a lung from oilsmoke and God only knew what
else. Sam was missing an arm from an IED. We were the Band of
Broken Brothers, and Rush Limbaugh had offended us once too often.
This is our plan, the Colonel always reminded us. We are in on this
together. Yet to be honest, it was his plan. His leadership skills were
not in dispute at all by this point. Yet for all his strength of character
and intellect, the Colonel was the youngest and most damaged of us;
and while he had turned these weaknesses into strengths, during the
time we held Rush Limbaugh every one of us found ourselves sullen to
the Colonels orders at some point.
This was strange for us, as we are all men of long military
experience. Here in the torture chamber, this became more
important than ever: the Colonel had to restrain us, to channel our
anger and aggression to maximum effect.
You are taking part in a great experiment, the Colonel told the
demagogue. Your every reaction will be recorded for posterity, so
be sure to give our techniques your utmost attention.
I held a cloth ready over Rush Limbaughs face.
What the hell do you people want from me? Rush Limbaugh
demanded.
To find out how torture works, the Colonel replied. He nodded to
me, and I settled the terrycloth over Rush Limbaughs face. We will
apply water for exactly twenty seconds. Quit squirming! This is no
worse than a college hazing ritual, fatass. Dont be such a little
bitch.
Don poured. Robert ran the camera. Sam held the timer. Everyone
held their breath.
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Rush Limbaugh withstood the procedure wellfor about three


seconds. Then he went into a fit, convulsing and nearly overturning
the board by rocking from side to side in panic. Rush Limbaugh
gagged, coughed, and shook until the twenty seconds were up. This
short interval seemed an eternity to me, and I was only watching.
Our victim alternately sobbed and coughed for several minutes
afterward while the Colonel spoke. According to the Geneva
Convention, he explained, you have just been tortured. By your
own prescient analysis on the air, however, this was not torture at
all. Do you wish to revise your statement at this time?
Limbaugh spluttered Yes. After a wracking fit of coughing, he
refused to say more.
You are one determined fatass, the Colonel observed. Forced, for
the first time in your miserable existence, to admit being wrong, you
have done so. Too bad it took this much. But this is good. You will
need your courage, because we have scheduled this treatment
another onehundred and eightytwo times over the next thirty
days.
Rush Limbaugh made the sound of an immense ego being ripped from
a human soul.

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AT 1 1 : 5 2 PM
L ABEL S: TH E TOR TU R E OF R U SH L I M BAU G H

13 COMMENTS:
Anonymous April 23, 2009 at 10:41 AM
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South of Strange: The Torture of Rush Limbaugh [Anonymoused]

Case 8:13-cv-03059-GJH
335-2 Filed 01/29/16 Page 7 of 10
YOU SOUND
LIKE A REDNECK ASSHOLEDocument
...
Reply

Matt Osborne

April 23, 2009 at 11:48 AM

No, but I took great pains to make sure the story was at fifth
grade reading level so that redneck assholes could read it.
Reply

Joseph Suglia April 23, 2009 at 5:48 PM


Correction: Rush Limbaugh is a "redneck a******."
The only thing dissatisfying about your satire is the fact that
it is fictional.
Joseph Suglia
Reply

Wolfe Tone April 24, 2009 at 4:14 PM


Enjoyable story, Matt.
The only flaw I can find is that I seriously doubt Mr. Limbaugh
would display any sort of personal courage, but that's just my
opinion.
And such as.
Reply

Gabriel McKee May 2, 2009 at 1:45 AM


Pretty trashy, but whatever works for you.
Reply

Matt Osborne

May 2, 2009 at 1:57 AM

If my story is "trashy," then so is torture. Which is kind of the


point...so I shall take the comment as an endorsement.
Reply

Susan Cass May 6, 2009 at 10:19 PM


Brilliant!
Reply

ZIRGAR July 12, 2009 at 3:02 PM


Dude, I am so sorry I never read this before, but I love it.
Great stuff! Especially your responses to the people who
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South of Strange: The Torture of Rush Limbaugh [Anonymoused]

8:13-cv-03059-GJH
seemdCase
to miss
the point of this little Document
exercise. 335-2 Filed 01/29/16 Page 8 of 10
Reply

Anonymous August 24, 2009 at 7:53 PM


And you libs accuse conservatives of being haters. The hatred
in this article is transparent. Let's see. You hate because
conservatives hate. They hate because others hate them. The
others hate because .... Keep the hatred going!!! (not). Sorry
I won't be back to read your response. I can only stomach this
kind of blog for one visit.
Reply

Matt Osborne

August 24, 2009 at 8:53 PM

Anonymous, there is a vast difference between torturing a


man in a story and torturing a man in real life.
Your presence is not missed as I can only tolerate assholes
once.
In fact, don't come back. If you ever do, my wicked software
will send your information directly to Whitehouse.gov, where
you'll be added to the list of sacrificial lambs for the post
2012 socialcommunifascist pagan death rite. Jackbooted
ATF agents will remove you to concentration camps on Long
Island. Got that? Scram.
Reply

Anonymous September 9, 2009 at 9:47 AM


"In fact, don't come back. If you ever do, my wicked software
will send your information directly to Whitehouse.gov, where
you'll be added to the list of sacrificial lambs for the post
2012 socialcommunifascist pagan death rite. Jackbooted
ATF agents will remove you to concentration camps on Long
Island. Got that? Scram."
Regarding the above statement:right/write on!
Dig the story too.
John, from approx.2 miles [as the buzzard flies] from where
the fatazz lives.
Thanks
Reply

Matt Osborne

September 9, 2009 at 11:28 AM

Welcome to the Strange South, John!


Reply

Alisa Rosenbaum October 30, 2009 at 7:50 AM


I claim persistence as a positive attribute, though some may
perceive it as bothersome...
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South of Strange: The Torture of Rush Limbaugh [Anonymoused]

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Mr. Osborne, I have tried repeatedly to comment on your
other blog (from which I found this site). Is it that you do not
wish to receive comments there (as I could not find, try as I
might, a window big enough to allow me to 'verify' the
security word, then post)?
Alas, I shall then keep my thoughts to myself.
Reply

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