Brett Kimberlin writes a letter to Judge Grimm informing him that he intends to file a Rule 11 motion for sanctions against Michael Smith, the attorney representing Defendant Twitchy, for filing a "meritless memorandum" asking for dismissal of the complaint. Kimberlin claims Smith filed the pleading for an improper purpose of harassment. Kimberlin provided Smith with a copy of the unfiled Rule 11 motion as required. However, Smith then provided a copy to Defendant Hoge, who posted it online along with commentary about having insider knowledge that will cause Kimberlin trouble. When asked, Smith admitted giving Hoge permission to post the motion online and told Kimberlin not to file or send things to defendants if he does not want them
Brett Kimberlin writes a letter to Judge Grimm informing him that he intends to file a Rule 11 motion for sanctions against Michael Smith, the attorney representing Defendant Twitchy, for filing a "meritless memorandum" asking for dismissal of the complaint. Kimberlin claims Smith filed the pleading for an improper purpose of harassment. Kimberlin provided Smith with a copy of the unfiled Rule 11 motion as required. However, Smith then provided a copy to Defendant Hoge, who posted it online along with commentary about having insider knowledge that will cause Kimberlin trouble. When asked, Smith admitted giving Hoge permission to post the motion online and told Kimberlin not to file or send things to defendants if he does not want them
Brett Kimberlin writes a letter to Judge Grimm informing him that he intends to file a Rule 11 motion for sanctions against Michael Smith, the attorney representing Defendant Twitchy, for filing a "meritless memorandum" asking for dismissal of the complaint. Kimberlin claims Smith filed the pleading for an improper purpose of harassment. Kimberlin provided Smith with a copy of the unfiled Rule 11 motion as required. However, Smith then provided a copy to Defendant Hoge, who posted it online along with commentary about having insider knowledge that will cause Kimberlin trouble. When asked, Smith admitted giving Hoge permission to post the motion online and told Kimberlin not to file or send things to defendants if he does not want them
6500 Cherrywood Lane Greenbelt, MD20770 Re: Kimberlin v. National Bloggers Club, No, PWG 13-3059 Re: Rule 11 Motion re attorney Michael Smith Dear Judge Grimm: fILED _ 11 s. O:STRICT ~O,U~.i May 9.i',z,OT4'T 0:- ~.(;\i~\Lp,NO :..,,'I~.J i I \ , .~ I would like to file a Rule 11 motion requesting sanctions against Attorney Michael Smith who represents Defendant Twitchy for his filing of the meritless memorandum asking for dismissal of the Complaint on the basis of a hearing in Montgomery County Circuit Court on April 9, 201~. Mr. Smith has filed the pleading for an improper purpose to harass me, to provide more fodder to unrepresented Defendants Hoge, Walker and McCain,and to present a false narrative to this Court On May 6,2014, I advised Mr. Smith that I would be filing a Rule 11 motion based on this issue and provided him with a copy as required by the Rule. I only provided that copy to him and asked that he correct or withdraw the offending pleading. Mr. Smith, in turn, provided a copy of that unfiled Rule 11 motion, either directly or indirectly, to Defendant Hoge who then posted it on his blog and on Scribd along with commentary that he knows things about the case that are going to cause me trouble and that he was "given clearance" to post the motion. Exhibit A. I asked Mr. Smith ifhe gave the Motion to Defendant Hoge along with clearance to post it on his blog and Mr. Smith coyly admitted that he did, and told me that if I did not want things posted by Mr. Hoge, I should not file of send them to him. Exhibit B. I would like to file the Rule 11 motion following the 21-day window required by the rules to address Mr. Smith's initial filing of the meritless, malicious and improper pleading, and his release of the Rule 11 motion to Defendant Hoge for publication which amounts to violations of the ule and extrajudicial communications attacking a party. Sincerel , . Brett Ki 8100 Beec Tree Rd Bethesda, MD20817 (301) 3205921 j usti cejtmp@comcastnet. Case 8:l3-cv-03059-PWG Document l26 Filed 05/09/l4 Page l of l Team Kimberlin Post of the Day Posted on 8 May, 2014 112 26-"'0 Rate This Both of Tho Dread Pro-So Kimberlin's vexatious lawsuits in which I am a defendant are grinding their ways through the state and federal courts. Given the frivolous nature of TDPK's complaints, I havo optimistic expectations concerning the final results of the suits. There have boen several recent developments that lead me to believe that Brett Kimberlin is becoming desperate. Indeed, it seems that panic has driven him to turn the stupid knob up to 4+ 12. All is proceeding as I have foreseen-and I hope to be able to share the details of some of TDPK's latest mistakes before long. Stay tuned. UPDATE-As I've noted above, good legal strategy prevents me from publishing everything I know about. However, I've been given clearance to share this example of TDPK's going full-Acme. 'I ! U~ITEO STATES DISTRICT COURT D1~-rRICT OF l>IARYLAND GRI::f.~HELT DIVISIO~ HRETr KIMHI::RLlN. Plaintiff. ~ ~ v. :'iATIO~AL HLOGGI::RS (LOH. et al. Defendants. ~o PWG 13.3059 """ MOTION AND !ltEMORANDUM IN SUPPORT OF RULE 11 SANCTIONS AGAINST PLANITIFF 1WITCIIY'S ATTORNEY MICIIAI::L S!ltITH Defendant Hn:tt Kimberlin submits this motion and memorandum ollaw in Case 8:l3-cv-03059-PWG Document l26-l Filed 05/09/l4 Page l of l I From: Michael Smith <smlth@smlthpllc.com> Oat", Thursday, May 8, 2014 at 10:54 PM To: Justice Through MusIc <JustlceJtmp@comcast.net> Subject: RE: Kimberlin v. National Bloggers Club et al. ;'.~ ,_ IW-;:.:-:c,ve ."...1i'''P .... 'a ... ''" ?" .. "'-""Il:'O=CTiJlZ>l""" . - ',.- . "PV*dG'1?"W".s.-r d? '.,e... :;;,"~w,~,-"~'?"!i'w . -'.,a=. :::n 3">~ r 'fi'~'..,gzl''''-r-''r'~~~~'''o5!i . ~''''' " Mr. Kimberlin: As you'll recall, yesterday you sent me your Rule 11 motion, saying you would file It in 21 days if Twitchy didn't withdraw Its "motion" (by which I assume you mean, the Supplemental Memorandum). As you'll further recall, I declined your request for withdrawal, and copied several of the 20+ co-defendants on my email to you, along with a copy of your proposed motion. While I suggest Mr. Hoge Is best positioned to answer your specific question, I will say I see no problem whatsoever with any of the defendants you have sued making any lawful use they wish of a baseless motion you drafted, sent to two of the defendants, and threatened to file, While you're of course free to press your case through any permissible means you choose, I would suggest that if you don't want defendants publicizing your Rule 11 motions, you send defendants no further Rule 11 motions. Yours, mfs From: Justice Through Music (mallto'lusticcltmp@comcast.netJ Sent: Thur>day, May08, 20149:39 PM To: Michael Smith Subject: Re: Kimberlinv. N.tional Bloue Oub et.1. Mr. Smith: ~ ~ As quote below, Mr. Hoge has updated his post to say that he has been 'given clearance" to post the Rule 11 motion that has not been flied or placed on Pacer. Would you please confirm that you gave him such clearance, since I do not want to make any factual misrepresentations to the Court. Thank you, Brett Team Kimberlin Post of the Day http://hogewash,com/2014/OS/08/team-kimberlin-post-of-the-day-434/> Both of The Dread Pro-Se Klmberlin's vexatious lawsuits In which I am a defendant are grinding their ways through the state and federal courts, Given the frivolous nature of TDPK'scomplaints, I have optimistic expectations concerning the final results of the suits. There have been several recent developments that lead me to believe that Brett Kimberlin Is becoming desperate. Indeed, It seems that panic has driven him to turn the stupid knob up to 1112. All Is proceeding as I have foreseen-and I hope to be able to share the details of some of TOPIC'slatest mistakes before long. Stay tuned. UPDATE-As rve noted above, good legal strategy prevents me from publishing everything I know about. However, I've been given clearance to share this example of TOPK'sgoing full.Acme. ~ Case 8:l3-cv-03059-PWG Document l26-2 Filed 05/09/l4 Page l of l
Washington v. William Morris Endeavor Entertainment et al. (15A126) -- Petitioner's Application to Stay Extension to Submit Petition for Writ of Certiorari Pending Resolution of July 18, 2015 Motion to Disqualify Loeb & Loeb LLP, or in the Alternative, Application to Exceed Word Limits Exhibits A thru F [September 10, 2015]
Washington v. William Morris Endeavor Entertainment LLC Et Al. (14-4328-CV) - Appellant's Reply To Ex. Motion For Extraordinary Relief From The Second Circuit (December 17, 2014)
G.R. No. 201302 Hygienic Packaging Corporation, Petitioner Nutri-Asia, Inc., Doing Business Under The Name and Style of Ufc Philippines (FORMERLY NUTRI-ASIA, INC.), Respondent Decision Leonen, J.