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IN THE COURT OF APPEALS OF MARYLAND BILL SCHMALFELDT Petitioner v.

WILLIAM HOGE Respondent * * * * * * * * * * * * * * * * * * Petition Docket 320 September Term 2013

ANSWER TO PETITIONERS MOTION TO RECONSIDER THE COURTS DENIAL OF HIS MOTION TO STAY. NOW COMES, William Hoge, through his attorney, Zoa D. Barnes, Hill, Barnes & McInerney, LLC in filing this Answer states: 1. That he admits in part and denies in part the allegations in Paragraph 1. Specifically he admits that a Petitioners Motion to Modify Peace Order will not be heard until October 16, 2013 but denies the remaining allegations. 2. That he admits the allegations in Paragraph 2 of the Motion. 3. That he admits in part and denies the allegations in Paragraph 3 of the Motion. Specifically he admits that Petitioner is still subject to criminal charges if he continues to violate the Peace Order but denies the remaining allegations. 4. That he admits the allegations in Paragraph 4 of the Motion. 5. That he denies the allegations in Paragraph 5 fo the Motion. 6. That he denies the allegations in Paragraph 6 of the Motion.

7. That he admits the allegation in Paragraph 7 of the Motion and in further answer states that Respondent will continue to consider all legal avenues available to him which will protect him from Petitioners ongoing harassment. 8. That he denies the allegations in Paragraph 8 of the Motion and states that the October 16, 2013 hearing pending in Carroll County Circuit Court is based upon Petitioners request and demonstrates his ability to make arrangements and travel. 9. That he denies the allegations in Paragraph 9 of the Motion. 10. That he admits he filed a Supplement to his Petition for Writ of Certiorari as stated in Paragraph 10 of the Motion, but the remaining statements do not require an answer as they are not allegations but prayers for relief. 11. That he denies the allegations in Paragraph 11 of the Motion. 12. That in further answer Petitioner bases his Motion on his perceived need and right to continue to contact and harass Respondent without the threat of criminal charges, which clearly serves a basis to deny his Motion. 13. That Petitioner still fails to apply for appropriate relief in Circuit Court as required by Md Rule 8-425. WHEREFORE, Respondent prays that Petitioners Motion be DISMISSED.

___________________________________ Zoa D. Barnes Hill, Barnes & McInerney, LLC 23 N Center Street Westminster, MD 21157 (410) 840-8900 Attorney for Respondent

CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this ___________ day of _____________________, 2013, a copy of this Answer to Petitioners Motion to Reconsider the Courts Denial of His Motion to Stay was delivered via first class mail, postage prepaid to the following:

Bill Schmalfeldt 6636 Washington Blvd. #71 Elkridge, MD 21075 Petitioner

________________________________ Zoa D. Barnes