What Is DB Capitol Strategies and What Did It Do to Plaintiff 1.

Defendant DB Capitol Strategies ("DBCS") is a Virginia based law firm headed by attorney Dan Backer. Mr. Backer is best known for his representation of many Tea Party groups and PACs. He has a reputation for pushing the boundaries of the law, and has sued the FEC, IRS and Plaintiff, losing most of his cases. He is the treasurer of several Tea Party PACs such as StopHillaryPAC. JoinTheTeaParty.us and TheTeaParty.net Exhibit A. Several of these PACs/entities have come under scrutiny for misappropriation of funds. Id. 2. In 2012, Mr. Backer, on behalf of Defendant Aaron Walker, sued Plaintiff in three cases. The first, in Prince William County Virginia Circuit Court, Walker
v. Kimberlin, CL 12-631, consisted of 32 counts requesting damages of 60

million dollars. The lawsuit was so patently frivolous and malicious that Judge Potter dismissed it in a scathing decision from the bench, saying: "The Court finds that the complaint is not well grounded in fact, it's not warranted by existing law, and it's imposed for an improper purpose as part of an ongoing political dispute between the parties." Exhibit Bat 24. 3. The second was filed in this Court, Walker v Kimberlin et aI, 12-CV-01852JFM, and it sued Plaintiff for a series oftorts, and it was dismissed, apparently for improper service. The third, an amended complaint, sued Plaintiff and two non-profit organizations with which he is involved. It alleged in essence that the Montgomery County Courts were so inept and corrupt for protecting Plaintiff from Defendant Walker that the federal courts had to step in a stop