You are on page 1of 4

MARYLAND:

IN THE CIRCUIT COURT OF MONTGOMERY COUNTY

BRETT KIMBERLIN,
Plaintiff
v.

Case No. 403868V

NATIONAL BLOGGERS CLUB, ET AL.,


Defendants

DEFENDANT WALKERS MOTION FOR LEAVE TO FILE A SUPPLEMENT TO HIS


OPPOSITION TO THE PLAINTIFFFS MOTION TO STAY
NOW COMES Defendant Aaron J. Walker, Esq., and files this Motion for Leave to File a
Supplement to his Opposition to the Plaintiffs Motion to Stay and states the following:
1.

Mr. Walker respectfully requests to be granted leave to file a supplement to his

Opposition to the Plaintiffs Motion to Stay (Dkt. No. 156) in order to inform this Court of a
decision of the Court of Special Appeals that bears directly on the Plaintiffs motion.
2.

Specifically, the Court of Special Appeals has ruled in Mr. Walkers favor in

Kimberlin v. Walker, et al., Sept. Term 2014 Nos. 1553 and 2099, Sept. Term 2015 No. 365 (Md.
App. 2016), which is an appeal of this Courts decision in Kimberlin v. Walker, et al., No.
380966V (Md. Mont. Co. Cir. Ct. 2013).
3.

As this Court will recall, on January 19, 2016, the Plaintiff filed a motion to stay

this Courts January 12, 2016, ruling granting a dismissal and partial summary judgment in Mr.
Walkers favor (Dkt. No. 155).

4.

In that motion, the Plaintiff specifically asked this Court to delay its ruling until

the Court of Special Appeals could rule on his appeal if Kimberlin v. Walker, et al.
5.

The Court of Special Appeals ruling is obviously highly relevant since it moots

the Plaintiffs motion for a stay on its own terms: he asked for a stay until the Court of Special
Appeals ruled, and it has, affirming this Courts decision. Further, Mr. Walker could not have
brought it up when opposing the Plaintiffs motion to stay, because the Court of Special Appeals
had made its decision public at that time Mr. Walker filed his opposition on January 28, 2016.
6.

Therefore, Mr. Walker requests that he be granted leave to file a three-page

supplement to his motion to stay (which has been filed simultaneously with this motion),
informing this Court of that ruling and providing a copy of it.

WHEREFORE, Defendant Aaron J. Walker, Esq. should be granted leave to file a Supplement to
his Opposition to the Plaintiffs Motion to Stay (Dkt. No. 156), and all other relief that is
appropriate.

Wednesday, February 03, 2016

Respectfully submitted,

Aaron J. Walker, Esq.


Va Bar# 48882
P.O. Box 3075
Manassas, Virginia 20108
(703) [redacted]
AaronJW72@gmail.com
(No fax)

CERTIFICATE OF SERVICE
I certify that on the
day of
, 2015, I served copies of this
document on Brett Kimberlin at [redacted], Bethesda, Maryland 20817, via U. S. Mail, on the
following co-Defendants via email: William Hoge via Patrick Ostronic; DB Capital Strategies
and Dan Backer, Esq. via Dan Backer, Esq; and Lee Stranahan.

MARYLAND:
IN THE CIRCUIT COURT OF MONTGOMERY COUNTY

BRETT KIMBERLIN,
Plaintiff
v.

Case No. 403868V

NATIONAL BLOGGERS CLUB, ET AL.,


Defendants

ORDER GRANTING DEFENDANT WALKERS MOTION FOR LEAVE TO FILE A


SUPPLEMENT TO HIS OPPOSITION TO THE PLAINTIFFFS MOTION TO STAY
Upon consideration of the Defendant Walkers Motion for Leave to File a Supplement to
his Opposition to the Plaintiffs Motion to Stay, and any other filings in support or opposition
thereto, it is this

day of

, 2016, hereby

ORDERED that Defendant Walkers Motion for Leave to File a Supplement to his
Opposition to the Plaintiffs Motion to Stay is GRANTED.

Hon. Michael D. Mason


Judge, Circuit Court of Maryland for Montgomery County