WILLIAM HOGE Petitioner v.

BILL SCHMALFELDT Respondent * * * * * *

* * * * * *

IN THE CIRCUIT COURT FOR CARROLL COUNTY Case No.; C-13-63359 * * * * * *

ANSWER MOTION TO MODIFY PEACE ORDER NOW COMES Petitioner, WILLIAM HOGE, through his attorney, Zoa D. Barnes, Hill, Barnes & McInerney, LLC in filing this Answer states: 1. That he denies the allegations in Paragraph 1 of the Motion. 2. That he admits in part and denies in part the allegations in Paragraph 2 of the Motion. In particular he admits that Respondent’s contact has been through Twitter but denies it has been only “a few attempts” as alleged. 3. That he admits in part and denies in part the allegations in Paragraph 3 of the Motion. In particular he admits that he writes about Respondent but denies it is every day as alleged. 4. That he denies the allegations in Paragraph 4 of the Motion. 5. That he admits in part and denies in part the allegations in Paragraph 5 of the Motion. In particular he admits that “journalism” is protected by the First Amendment but denies the remaining allegations. 6. That he denies the allegations in Paragraph 6 of the Motion. 7. That he denies the allegations in Paragraph 7 of the Motion, except to state that the State has filed charges against Respondent for violating the Peace Order upon notification by

Petitioner of the violation. 8. That he admits the allegations in Paragraph 8 of the Motion, but in further answer states that the case cited is not relevant to the facts in this matter. 9. That he admits in part and denies in part the allegations in Paragraph 9 of the Motion. In particular he denies that he is a “public figure’ or that the Peace Order is used to stop Respondent from tweeting about him as alleged, but admits the remaining allegations. 10. That he denies the allegations in Paragraph 10 of the Motion.

___________________________________ William Hoge

______________________________ Zoa D. Barnes Hill, Barnes & McInerney, LLC 23 N Center Street Westminster, MD 21157 (410) 840-8900 Attorney for Petitioner CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this ____day of ___________________, 2013 a copy of this Answer was mailed, postage pre-paid to: Bill Schmalfeldt 6636 Washington Blvd. #71 Elkridge, MD 21075 Respondent ______________________________ Zoa D. Barnes

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