RICO Motion to Require Verification (OCR) | Virginia Circuit Court | Pleading





v. Case No. PWG 13-3059




COMES NOW Defendant Aaron J. Walker, Esq., and hereby moves this court to require the
Plaintiff to file all future pleadings, motions, oppositions, replies and all other papers filed with this
court under verification, requiring the Plaintiff to swear under penalty of perjury that all facts stated
therein are true and correct. In support of this motion, Defendant Walker states the following:
1. The Plaintiff is a convicted perjurer. Kimberlin v. Dewalt, 12 F.Supp. 2d 487, 490 n. 6
(D. Md 1998).
2. The Plaintiff is a compulsive and, indeed, shameless liar who often lies in course of
criminal or civil litigation. A few examples of his falsehoods should suffice to make this point.
3. The most outrageous example comes in a hearing on May 29, 2012. By way of
background, the Plaintiff is a convicted terrorist. This is what the Sixth Circuit wrote about him:


Kimberlin was convicted as the so-called "Speedway Bomber," who terrorized the city of
Speedway, Indiana, by detonating a series of explosives in early September 1978. In the
worst incident, Kimberlin placed one of his bombs in a gym bag, and left it in a parking
lot outside Speedway High School. Carl Delong was leaving the high school football
game with his wife when he attempted to pick up the bag and it exploded. The blast tore
off his lower right leg and two fingers, and embedded bomb fragments in his wife's leg.
He was hospitalized for six weeks, during which he was forced to undergo nine
operations to complete the amputation of his leg, reattach two fingers, repair damage to
his inner ear, and remove bomb fragments from his stomach, chest, and arm. In February
1983, he committed suicide.

Kimberlin v. White, 7 F.3d 527, 528-29 (6th Cir. 1993).
4. On or about May 20, 2012, Mr. Kimberlin filed a petition for a Peace Order in the
Montgomery County (Maryland) District Court against Mr. Walker. Kimberlin v. Walker (II) (Md.
Mont. Co. Dist. Ct. 2012) case number 0601SP019792012. Under Maryland law, a Peace Order (MD
CODE CTS. & JUD. PROC. §3-1501 et seq.) is very similar to the kind of protective or restraining orders
one might see in a domestic violence context, but it can only be obtained by people who are legally
“strangers.” Mr. Kimberlin’s grounds for seeking a peace order was that Mr. Walker had allegedly
harassed him under MD CODE CRIM. LAW. §3-803 by peaceably writing negative articles about him, on
the internet, to a general audience and without contacting him. Mr. Kimberlin claimed that merely
writing such negative stories about him was equivalent to incitement, even though Mr. Walker’s conduct
didn’t meet any part of Brandenburg v. Ohio’s test for incitement. 395 US 444, 447 (1969) (“the
constitutional guarantees of free speech and free press do not permit a State to forbid or proscribe
advocacy of the use of force or of law violation except where such advocacy is directed to inciting or
producing imminent lawless action and is likely to incite or produce such action.”) Mr. Walker had not
even met the first prong of the test, requiring that he advocate that any person engage in violence or
lawlessness toward Mr. Kimberlin.


5. On May 29, 2012, there was a hearing in that case. On cross-examination, Mr. Kimberlin
was asked under oath about his criminal record, resulting in this exchange where Mr. Walker asked:
“And you were known as the Speedway Bomber, were you not?”

6. Mr. Kimberlin replied: “I don’t know that.” When asked if he had ever read that he was
called by this term, he replied “I’ve read a lot of things in my life.” When asked if he had read
Kimberlin v. White, quoted above, he denied having read it. The entirety of this exchange is attached as
Exhibit A, lines 5-19.
7. In addition to the facial implausibility of the claim that he didn’t know he had earned this
nickname for which he is nationally famous, Mr. Kimberlin referred to himself by that nickname
previously in court. Specifically, on January 9, 2012, about four months before the May 29 hearing,
there was a hearing in Kimberlin v. Allen, (Md. Mont. Co. Cir. Ct. 2011) case number 339254V. Mr.
Kimberlin had asserted that Mr. Allen had violated an injunction prohibiting defamation by writing
pieces on the internet that allegedly defamed him. In the hearing, Mr. Kimberlin had the following
exchange with Judge Rupp when discussing a particular piece Mr. Allen had written:
THE COURT: All right. This one is dated November 23rd. I don't see anything in here
that would constitute --

MR. KIMBERLIN: Well, I mean --

THE COURT: -- defamation.

MR. KIMBERLIN: -- there's a lot of stuff in there, so I could certainly find it, you know.
But what [he] does is he mixes, he posts something, and then he'll say, oh, and then
Kimberlin, the speedway bomber, the terrorist, the perjurer, and the pedophile did this
or that.

A reasonable person might wonder how this convicted perjurer was allowed to testify in light of MD
CODE CTS. & JUD. PROC. §9-104 forbidding the testimony of perjurers. The simple answer was that the
parties involved were ignorant of this rule at the time. None of them learned of it until early in 2013.


(Emphasis added). The entirety of this exchange is attached as Exhibit B, lines 13-21.
8. This is not the only instance of the Plaintiff lying in a court hearing. On November 14,
2011, there was a prior hearing in the case of Kimberlin v. Allen. At that point in time Mr. Allen had a
default judgment against him after failing to make a timely response to this suit, but in this hearing he
was granted an opportunity to challenge Mr. Kimberlin on the topic of monetary damages. Mr. Allen
cross-examined Mr. Kimberlin, resulting in this exchange:
Q [Allen] Were you released and then sent back to prison for a parole violation, for
failure to pay compensation to the, Ms. Delong (phonetic sp.), the wife of Carl Delong,
who took his own life after those bombs --

A [Kimberlin] No.

Q -- tore up half his body?

A No, I wasn’t.

See attached, Exhibit C, lines 12-18. This was a lie. Mr. Kimberlin’s parole had been revoked, and for
precisely that reason. Further, Mr. Kimberlin was fully aware of the reasons for his parole revocation.
In Kimberlin v. DeWalt, 12 F.Supp.2d 487, 494 (D. Md. 1998) challenging the revocation of his parole,
the court notes that “Petitioner [Kimberlin] first argues that parole revocation was improperly based
upon his failure to pay a civil judgment which should be held void and unenforceable.” Logically
speaking, one cannot challenge the grounds of a parole revocation without knowing it was the grounds
cited. Further, Mr. Kimberlin must have made that challenge personally and not through counsel, since
the DeWalt court notes that he appeared pro se.
9. Further, the DeWalt case itself documents other instances of Mr. Kimberlin’s dishonesty.
For instance, the DeWalt court documents the findings below as follows:


The examiner found that petitioner used “deceitful maneuvers to hide his ability to pay”
[the DeLong widow] and that his “relatives and friends are obviously acting to help him
by filing claims and liens to protect his money and property from being available to
satisfy the victim's judgment.”

Id. at 494. The court also noted that he had committed mortgage fraud by lying about DeLongs’ prior
judgment against him as follows: “On May 16, 1996 he submitted a mortgage loan application denying
that he had any ‘outstanding judgments’ against him.” Id. at 491. (footnotes omitted.) He was able to
obtain a loan of over $300,000 in part based on that falsehood.
10. Mr. Kimberlin has also lied repeatedly about the conduct of Defendant Walker. The most
egregious example of this was when Mr. Kimberlin first tried to bully Mr. Walker into silence with a
threat of filing false criminal charges, and when Mr. Walker refused to buckle to that extortionate
pressure, Mr. Kimberlin actually tried to frame Mr. Walker for a crime.
11. Mr. Walker recognizes that this claim might be difficult to believe, but attached to this
motion is video and documentary proof of this fact. Essentially, Mr. Kimberlin claimed that Mr. Walker
beat him up outside a courtroom in the Montgomery County (Maryland) Circuit Courthouse. He even
produced false
hospital records and false photographs of his alleged injuries. However, there was a
security camera outside that courtroom and it recorded enough of the incident to prove that that Mr.
Kimberlin lied about almost every detail.

In stating that Mr. Kimberlin’s hospital records and photographs are false, Mr. Walker is simply
claiming that they are not what they purport to be. Given that Mr. Walker never harmed Mr. Kimberlin
or caused Mr. Kimberlin to be harmed, there are only two logical explanations for how these medical
records and photos came into being: either this convicted document forger created fake hospital records
and fake photographs; or Mr. Kimberlin actually harmed himself or had someone harm him and then
falsely blamed Mr. Walker for his injuries. Mr. Walker doesn’t pretend to know which of these two
possibilities are the truth. He is only certain that if Mr. Kimberlin was genuinely injured on January 9,
2012, it was not by Mr. Walker.


12. By way of background, in December, 2011, Mr. Kimberlin attempted to enforce an
abusive subpoena in an attempt to get Mr. Walker to testify against Mr. Allen in the contempt hearing
set for January 9, 2012 in the case of Kimberlin v. Allen (the same one discussed in paragraph 7 above).
Prior to this subpoena, Mr. Walker’s only contact with Mr. Allen was to give him a bit of free legal
advice in a handful of emails that prior August, but Mr. Kimberlin took this innocent and slight help as
somehow being proof that Mr. Walker was part of a great conspiracy to write bad things about Mr.
Kimberlin on the internet. See Exhibit D, a copy of Mr. Kimberlin’s Motion to Compel. At the time
Mr. Walker was an anonymous writer on the internet. Mr. Kimberlin’s subpoenas were aimed at
revealing Mr. Walker’s true identity so he could be subpoenaed to testify.
13. Mr. Walker had sought to protect his anonymity for two reasons. First, Mr. Walker has
hidden disabilities and wanted to shield himself from discrimination because of those disabilities while
being able to be free to discuss his disabilities on his site. Second, Mr. Walker had participated in the
free-speech, anti-terrorism protest known as Everyone Draw Mohammed Day, by creating a website
called Everyone Draw Mohammed. While much of the data from that site has been lost, Mr. Walker has
been able to recover the text of the site’s Mission Statement and has attached it as Exhibit E so this court
can understand this protest’s mission and methods more completely and to correct Mr. Kimberlin’s false
statements about it.
14. On or about December 29, 2012, Mr. Walker filed a motion to quash those subpoenas in
the Allen case. Further, because ordinarily one is required to file any motions under one’s real name,
Mr. Walker filed, through counsel, a motion to allow Mr. Walker to file motions anonymously in order
to protect his anonymity. Mr. Walker posted a redacted copy of his motion to quash on his website as
well as several reports on what had been going on in the case. Mr. Walker’s motion to quash pointed


out that Mr. Kimberlin most likely committed perjury in the Kimberlin v. Allen hearing on November
14, 2011, as referenced above and suggested that the court refer the matter to the State’s Attorney.
15. On or about January 3, 2012, Mr. Kimberlin sent a “settlement offer” to Mr. Walker’s
attorney, Beth Kingsley, Esq., in which Mr. Kimberlin threatened to file false criminal charges, bar
complaints and Peace Orders if Mr. Walker didn’t remove everything he had written about Mr.
Kimberlin—including where he posted a redacted copy of the motion to quash—and withdraw the
motion to quash before the court. A copy of that settlement offer is attached as Exhibit F. When Mr.
Walker didn’t give in to that extortionate demand,
upon information and belief Mr. Kimberlin decided
to frame Mr. Walker for a crime and looked for the opportunity to carry out his plan.
16. This settlement offer gave Ms. Kingsley the impression that Mr. Kimberlin did not yet
know Mr. Walker’s true identity. That impression was false. Mr. Kimberlin later admitted to learning
Mr. Walker’s identity on December 31, 2012 in a hearing on April 11, 2012. See Exhibit G. page 60,
line 25, through page 61, line 18.
17. On or about January 5, 2012, Mr. Kimberlin sent a letter to law enforcement warning that
because “Mr. Walker... has been identified in a civil case in Maryland,” referring to the Allen case, that
“there exists the very real probability that Mr. Walker could be subjected to serious harm or death[.]”
That letter is attached as Exhibit H.
18. At about the same time, Mr. Kimberlin filed a Motion to Withdraw his subpoenas seeking
Mr. Walker’s identity on the grounds that he had learned his identity by other means. The motion not

The court might reasonably ask why this settlement offer is called extortionate by Defendant Walker
and the offer made by Dan Backer is not. The difference is that the Plaintiff made the filing of criminal
charges a penalty of not settling. Indeed since Mr. Kimberlin didn’t know Mr. Walker’s identity, those
charges would have necessarily been false charges. By comparison Mr. Backer’s settlement offer did
not include such terms precisely because it would be unethical and illegal to make such an offer.


only identified Mr. Walker as the anonymous writer “Aaron Worthing” but gratuitously put the
following information into the motion:
a. Mr. Walker’s home address;
b. Mr. Walker’s date of birth;
c. What high school he attended;
d. The fact Mr. Walker dropped out of high school;
e. The fact Mr. Walker got a GED;
f. What university he attended;
g. What law school he attended;
h. Facts related to a federal lawsuit Mr. Walker filed that was supposed to be under
seal; and
i. Mr. Walker’s then-current employer, then-current job position, and their address.
A redacted copy of that motion is attached as Exhibit I.
19. Mr. Kimberlin didn’t serve this motion on Mr. Walker or his counsel until Saturday,
January 7, 2012 when the courts were closed and at that time he served Mr. Walker by email. The
following Monday was January 9, 2012, the date of the contempt hearing—the same one for which Mr.
Kimberlin claimed to need Mr. Walker’s testimony. Mr. Walker showed up for that hearing and made
an emergency motion to place Mr. Kimberlin’s motion to withdraw under seal. That motion was
immediately granted. See Exhibit J, page 4, line 6, through page 10, line 3.
20. Mr. Kimberlin never called Mr. Walker to testify in that hearing, despite having
previously declared that Mr. Walker was “an important witness in this case.” Exhibit D, ¶10.


21. As Mr. Walker and Mr. Kimberlin were leaving the courtroom, Mr. Kimberlin said to
Mr. Walker in a threatening tone: “I would suggest, Mr. Walker, that you leave me alone.”
22. Mr. Walker replied, “I will continue to tell the truth about you.” Mr. Walker also asked
why Mr. Kimberlin didn’t call him to the stand, stating that, “the truth is you didn’t want my testimony,
you just wanted my identity.”
23. Mr. Kimberlin turned to Mr. Walker, in anger and sneered, “And I got it!”
24. This is Mr. Walker’s version of what happened next. At about that time, Mr. Kimberlin
took a few steps away from Mr. Walker and attempted to do something with his iPad. Concerned that
this convicted terrorist might have snuck in a dangerous device inside his iPad, Mr. Walker took the
iPad from him. He did not once strike Mr. Kimberlin or otherwise harm Mr. Kimberlin. Instead, he
simply snatched the iPad from Mr. Kimberlin without difficulty and peaceably kept it from him until
courthouse security could arrive and straighten things out.
At that time, Mr. Walker freely and
peaceably gave the iPad to the courthouse security officers who in turn gave it back to Mr. Kimberlin.
25. Mr. Kimberlin’s version of events were markedly different. As will be demonstrated in
the following paragraphs, Mr. Kimberlin has made the following claims about the incident: that Mr.
Walker “decked” him; that Mr. Walker had to be restrained by courthouse security as he repeatedly
attempted to charge at Mr. Kimberlin like a wild bull; that courthouse security needed to separate Mr.
Walker from Mr. Kimberlin; that Mr. Walker wrestled with Mr. Kimberlin; Mr. Walker pushed Mr.
Kimberlin; and that Mr. Walker hit Mr. Kimberlin repeatedly.

Upon information and belief, courthouse security in the Montgomery County Circuit Courthouse is
handled by a combination of Sheriff’s Office personnel, and personnel from an outside contractor.


26. However, this court does not need to take Mr. Walker’s or Mr. Kimberlin’s word for
what had happened. As noted earlier, there were security cameras that captured the entire incident. The
footage has been adapted to play in most Windows operating systems and is attached as Exhibit V.
27. The video is not continuous. Instead as explained by Lt. Col. Bruce Sherman of the
Sheriff’s Office in Exhibit M (page 24, line 23, through page 26, line 22), their security system takes
“snapshots” of what is occurring in intervals of about 1.75 seconds apart. As such it cannot absolutely
prove Mr. Walker’s version of events, but it is not even slightly inconsistent with his account, while it
also proves that Mr. Kimberlin told significant lies about the incident.
28. It is important to note that Mr. Walker didn’t know video of the event existed until mid-
March. Mr. Walker had asked officials with the Sheriff’s office whether footage existed on or about
January 10, 2012, and they mistakenly told him it didn’t. Upon information and belief, Mr. Kimberlin
didn’t know that the footage existed until around the same time Mr. Walker did. Not knowing there was
proof of what actually happened, this court will see that Mr. Walker told a story fully consistent with
what the footage showed, while Mr. Kimberlin did not.
29. Upon information and belief, Mr. Kimberlin decided between when Mr. Walker took the
iPad and when security arrived, to try to frame Mr. Walker for committing a serious assault when he
knew at worst Mr. Walker committed a slight and technical assault which was unlikely to be even
prosecuted, especially because Mr. Walker hadn’t caused Mr. Kimberlin to suffer any harm. Mr.
Kimberlin has since claimed that this “assault” placed him in the hospital. But before he allegedly went
to the hospital, Mr. Kimberlin went straight across the street to the commissioner’s office in the
Montgomery County District Courthouse and filed an Application for Statement of Charges. That
application stated in relevant part:


Defendant [Walker] attacked me physically while exiting the courtroom. He hit me on
the shoulder and chest and pushed me, and grabbed my iPad away from me and refused
to return it. Mr. Walker has been harassing me and stalking me online for months, and as
we were exiting the Courthouse / Room 5 / Floor 9, he said he was going to continue
harassing me, and as we left the courtroom, he grabbed my iPad, hit me in the face,
shoulder and chest and wrestled the iPad away from me. Several people witness [sic] this
event and the police were immediately called. They got my iPad back and safely
escorted me from the building. Mr. Walker tried to come at me several more times but
was restrained.

A copy of that Application is attached as Exhibit K. If this court reviews Exhibit V, it will immediately
see that this version of events is significantly contradicted by the security footage. First and most
obviously, Mr. Walker did not try to charge at Mr. Kimberlin after courthouse security arrived and
courthouse security never had to restrain him. Further, Mr. Kimberlin’s description of the incident
indicates that Mr. Walker struck multiple blows—i.e. “[Mr. Walker] hit me in the face, shoulder and
chest and wrestled the iPad away from me” and “[Mr. Walker] hit me on the shoulder and chest and
pushed me, and grabbed my iPad away from me and refused to return it.” Mr. Walker maintains he
never struck Mr. Kimberlin or caused anything to strike him, but because of the gaps in the video
footage it is impossible to rule out the possibility that Mr. Walker touched him even once, even slightly.
Still, one can rule out the possibility that Mr. Walker struck multiple blows, pushed him or wrestled with
him. To believe that Mr. Walker struck Mr. Kimberlin three times (“in the face, shoulder and chest”),
one would have to believe that Mr. Walker timed each action precisely between “snapshots” so that one
not only doesn’t see the blow, but one doesn’t see any movement from Mr. Walker indicating that he
was about to strike, or had just struck, and one doesn’t see any reaction from Mr. Kimberlin in terms of
being knocked by the blow or recovering from it. The same can be said of the allegations that Mr.
Walker wrestled with him or pushed him; one would have to believe that both Mr. Walker’s actions and


Mr. Kimberlin’s actions were timed perfectly so that the complete motion was missed by the
30. After filing criminal charges, Mr. Kimberlin also filed for a Peace Order, just as he
threated to in his Settlement Offer. In his petition for a Peace Order (Exhibit L), Mr. Kimberlin writes in
relevant part: “Mr. Walker assaulted me while leaving the courtroom. He hit me in the face, chest, &
shoulder and took my iPad, and threatened to harass me more.” Mr. Kimberlin affirmed under oath that
the petition was accurate in an ex parte temporary peace order held that afternoon—also before Mr.
Kimberlin allegedly went to the hospital. A temporary peace order was granted with the court finding
that assault and harassment occurred based solely on Mr. Kimberlin’s testimony.
31. That same evening he wrote an email to Beth Kingsley, Mr. Walker’s attorney. In it he
wrote in relevant part:
I just finished pressing charges against him [Mr. Walker] for assault and battery and got a
Peace Order against him. Nine deputies had to back him off. He decked me in the face,
hit me in the shoulder and chest, pushed me, grabbed my iPad away from me and
wrestled me....

Went to doctor and they sent me to ER at Suburban, said I need a CAT scan.

You client [sic] is very dangerous...

That email is attached as Exhibit N. Mr. Kimberlin subsequently stated under oath that the contents of
the email were true and correct. Exhibit O, page 76, line 17, through page 77, line 9. And yet if this
court reviews the video at Exhibit V, it is plain that what he wrote was not true. Mr. Walker not only
didn’t strike multiple blows, or push Mr. Kimberlin, but his claim that Mr. Walker decked him—that is,
knocked him down with a punch
—is plainly false as well.

See e.g. WEBSTER’S NEW WORLD COLLEGE DICTIONARY 358 (3d ed. 1996) (defining “deck” as
“[Slang] to knock down; floor.”).


32. On February 8, 2012, there was a final peace order hearing where Mr. Walker and Mr.
Kimberlin were both allowed to present evidence. Mr. Walker forthrightly admitted to taking the iPad
and argued that it was done in self-defense. Exhibit P, page 13, line 13, through page 15, line 2. Mr.
Kimberlin was sworn in and gave the following testimony:
But so as we were exiting the courtroom on the 9th floor, Courtroom 5, I believe, we
walked out of the courtroom and he’s screaming at me and telling me that he’s going to
continue harassing me. And as we got outside the door, right outside the courtroom, he
began lunging at me. I picked up my iPad and took a picture of him lunging at me. He
decked me in the eye and wrestled with me.

A man that followed us out of the courtroom raced back into the courtroom and told two
people that were working for Judge Rupp that he was attacking me and attacking me.
They came out and told him to get off of me and they called the police. Nine police came
up to the -- or, sheriffs came up there and separated him. He had my iPad in his hand at
the time and refused to give it back.

The sheriff went over and took the iPad away from him and told me to come down and
press charges against him.

Relevant excerpts from that testimony is attached as Exhibit Q, page 7, lines 11 through page 8, line 5.
The court found that no assault occurred. Since Mr. Walker admitted to taking the iPad from Mr.
Kimberlin, the judge necessarily believed that Mr. Walker did so in valid self-defense. Further, since
this represented a finding on the merits, Mr. Kimberlin is collaterally estopped from claiming that Mr.
Walker assaulted him and it was improper for him to allege it in his Complaint or First Amended
33. However, the court did find that Mr. Walker had harassed Mr. Kimberlin by writing
about him on the internet to a general audience. Mr. Walker appealed that decision and at a de novo


hearing in the Circuit Court (Kimberlin v. Walker (I) (Md. Mont. Co. Cir. Ct. 2012) case number
8444D), the entire peace order was vacated.

34. Meanwhile, this court can see for itself that the testimony was false and likely perjurious.
Mr. Walker didn’t begin lunging at him and indeed made no motion toward Mr. Kimberlin until after he
lifted his iPad. Further, Kimberlin claimed that when courthouse security arrived that they separated
Mr. Walker from Mr. Kimberlin (“Nine police came up to the -- or, sheriffs came up there and separated
him.”) But, in fact, this court can clearly see in the video that when security arrived Mr. Kimberlin was
so far away from Mr. Walker that he was no longer on screen. He was easily over thirty feet away from
Mr. Walker. And once again Mr. Walker didn’t deck him or wrestle with him.
35. Still, as noted above, it wasn’t until sometime in March of that year Mr. Walker learned,
through his attorney Reginald Bours III, Esq., that there was video footage of the incident. As one

By way of background, Mr. Kimberlin has filed two petitions for Peace Orders against Mr. Walker.
The first is referred to as Kimberlin v. Walker (I). It was originally filed in Montgomery County
(Maryland) District Court and had a case number of 0601SP005392012. In it, Mr. Kimberlin charged
Mr. Walker with stalking, assault and harassment. The court ultimately only found harassment. Any
person with an adverse ruling in the District Court can make an appeal of right to the Circuit Court for a
de novo hearing. Mr. Walker exercised that option, and the Circuit Court heard the case under case
number 8444D and denied the Peace Order after giving Mr. Kimberlin a ten minute lecture on freedom
of expression. About a month after the hearing Mr. Kimberlin sought a second Peace Order in the case
labeled Kimberlin v. Walker (II), case number 0601SP019792012. At this hearing Mr. Kimberlin
offered the unique theory that any negative reporting about him was inherently incitement and therefore
harassment. Mr. Kimberlin even convinced Judge Vaughey to adopt this approach, his honor literally
disregarding controlling Supreme Court precedent by name with the words, “forget Brandenburg”
(referring to Brandenburg v. Ohio, 395 U.S. at 447 (1969) (establishing the legal standard for
incitement)) and prohibited Mr. Walker from writing about Mr. Kimberlin for six months. Mr. Walker
appealed a second time. On an emergency motion, the Circuit Court vacated this unconstitutional prior
restraint and in a hearing held on July 5, 2012, dismissed the petition. That Circuit Court case number
was 8526D.
It is worth noting that the emergency motion lifting this unconstitutional prior restraint was granted on
June 25, 2012. Later the same day Mr. Walker was SWATted.


might imagine, Mr. Walker was greatly relieved to learn this exonerating evidence existed. Shortly after
this revelation, the State’s Attorney chose to nolle prosequi the charges against Mr. Walker. Upon
information and belief, they made this decision after reviewing this video.
36. In addition to all of that, Mr. Kimberlin has lied in the instant case. For instance, in
paragraph 63 of the Plaintiff Kimberlin’s First Amended Complaint, he writes that Mr. Frey appeared on
Defendant Glenn Beck’s radio/television show. The Plaintiff specifically wrote that during that
interview “Defendant Frey stated that Plaintiff ‘could have gotten me killed.’” He cites a YouTube
video at the following address: http://www.youtube.com/watch?v=o8F0gXl8bUE.
37. The problem is, this isn’t true. The entire video is has been converted to an appropriate
format for viewing on most Windows-based systems and is attached as Exhibit W. In the exchange,
which starts at around 8:20, Mr. Beck states specifically that Mr. Frey has no proof that Mr. Kimberlin
was involved in the SWATting and Mr. Frey accepted that statement. So when Mr. Frey makes the
quoted statement, he was clearly saying that his SWATter, whoever he is, could have gotten him killed.
Any claim by the Plaintiff that Mr. Frey was talking about Mr. Kimberlin is simply a lie.
38. This is not the only time that the Plaintiff lied about Mr. Frey in a manner that could be
easily verified simply by examining the very evidence that the Plaintiff points this court toward. In
paragraph 90, the Plaintiff makes the following fanciful accusation:
Defendant Frey secretly contacted Barrett Brown and sought his help and the help of the
hacker group Anonymous to intimidate Plaintiff. Defendant Frey used his position as
Deputy District Attorney to make that contact and implied to Mr. Brown that because of
his position he may be able to provide a quid pro quo to help Mr. Brown with his legal
problems in exchange for Mr. Brown helping Defendant Frey. http://pastebin.com/
WGdG5cBD Mr. Brown refused that request and posted his chat logs with Defendant


39. However, if this court actually looks up that internet address (http://pastebin.com/
WGdG5cBD) and reads the contents of that discussion, it will see that the Plaintiff has wholly
misrepresented the content and import of this conversation. For this court’s convenience a copy of that
document has been attached as Exhibit R. Once the court reviews it, it will see that the Plaintiff plainly
lied on three major points.
40. First, Mr. Frey was not attempting to convince Mr. Brown to commit any unlawful act.
Instead, he was simply asking him to state publicly that the Nadia Naffe litigation was frivolous,
referring to the same Naffe v. Frey et al. (C.D. California, 2012) case number 2:12-cv-08443-GW-MRW
discussed in Defendant Walker’s Motion to Dismiss. Since that litigation was ultimately dismissed, Mr.
Frey’s assessment was presumably correct. At any rate, it is not unlawful for Mr. Frey to say to Mr.
Brown, “If you think I have proven Leiderman’s
lawsuit is bull____, I'd like you to call it bull____[.]”
Exhibit R, line 318 (curse words omitted).
41. Second, Mr. Frey never offers Mr. Brown any help with his legal troubles or implies he
would give such help. Given that Mr. Frey is a California prosecutor and Mr. Brown is, upon
information and belief, under indictment in Texas on Federal charges, one wonders what exactly Mr.
Frey could do for Mr. Brown even if he was inclined to do it. All Mr. Frey offers to Mr. Brown is to
defend him on his blog against the writings of Defendant McCain, writing: “If you prove to me that
McCain is saying bull____ about you, I'll call it bull____[.]” Exhibit R, line 316 (curse words omitted).
This amounts to a promise to help Mr. Brown with his public relations difficulties, and only if Mr. Frey
thought he was in the right.

Upon information and belief, “Leidernman” is Jay Leiderman, Esq., Nadia Naffe’s attorney in that suit.


42. Third, there was no deal, no quid pro quo. This is stated explicitly, Frey writing: “Not a
deal[.] Just intellectual honesty[.] Send me whatever proof you like that McCain is full of it[.] I'll look
at it[.] I think I have a track record[.] I call out bull____ when I see it[.]” Exhibit R, lines 319-324
(curse words omitted). At most, it was a promise by both parties to treat the other with intellectual
honesty despite political disagreements, something that is laudable, and not even slightly nefarious.
Therefore, Mr. Kimberlin’s description of Mr. Frey’s online chats with Mr. Brown bear no relationship
to reality, as this court can see for itself.
43. Meanwhile, in paragraph 80 of his amended complaint, the Plaintiff writes that
Defendant Michelle Malkin used her blog and Twitter compiler, Twitchy, to repeatedly
state that Plaintiff committed the SWATtings. For example, on May 30, 2012, she wrote
a blog post titled “Breakthrough: Fox News Covers Brett Kimberlin/ Patterico

A full copy of this piece is attached as Exhibit S. Only the comments by readers are omitted.
44. First, the Plaintiff misrepresents the very title of the piece. The piece actually is entited:
“Breakthrough: Fox covers Brett Kimberlin/ Patterico SWATting, bloggers continue pressing the story.”
By adding an S after “SWATting” the Plaintiff has attempted to imply that Mrs. Malkin was discussing
a series of crimes known as the “Brett Kimberlin/Patterico SWATtings.” But, in fact, it is clear in
context she is actually talking about two stories: Patterico getting SWATted and Mr. Kimberlin’s
thuggish activities (such as filing abusive Peace Orders against Mr. Walker to silence him).
45. This is made even more clear when one reads the first line of her piece which refers to
another article at Twitchy which reads: “Fox News covers Brett Kimberlin and Patterico SWATting
story.” A copy of this piece is attached as Exhibit T (readers’ comments omitted). The piece goes on to
talk about efforts by Fox News to cover the SWATting story, including how Mr. Frey and Erickson had


been SWATted, and the article also mentions an old Fox News piece on Mr. Kimberlin. Neither this
piece on Mrs. Malkin’s eponymous site nor the Twitchy piece she linked to state that Mr. Kimberlin was
in any way responsible for any of the SWATtings and the Plaintiff’s claims to the contrary are simply
46. Meanwhile, in paragraph 102 the Plaintiff accuses Defendant McCain of “posting an
article on his blog that imputed and stated that Plaintiff committed SWATtings” (emphasis added).
However, if this court examines the piece the Plaintiff cites, attached as Exhibit U (readers’ comments
omitted), this court will see that at worst it was implied (and even that is a stretch) by someone they
quoted, and certainly not “stated” as a certain fact anywhere in the piece by its author.
47. The Plaintiff also falsely accuses Mr. Walker of unauthorized practice of law and other
questionable conduct. For instance, in paragraph 37 in his amended complaint, the Plaintiff writes in
relevant part:
In December 2011, Defendant Walker... contacted Seth Allen and offered pro bono to file
post-judgment motions in Maryland to overturn the judgment against Mr. Allen. Mr.
Walker... then prepared and filed numerous pleadings for Mr. Allen attacking the Plaintiff
and the judge who issued the judgment.

Mr. Walker is an attorney, admitted to practice in Virginia and the District of Columbia, but not in
Maryland. Thus, Mr. Walker can only represent himself in a Maryland court, and Mr. Kimberlin’s
claims amount to a scandalous and unfounded accusation of unauthorized practice of law. Mr. Walker
challenges Mr. Kimberlin, should he choose to respond to this motion, to produce a single document that
he can prove Mr. Walker filed on Mr. Allen’s behalf and to swear out an affidavit that it is a true and
correct copy of a genuine document.


48. Mr. Walker states unequivocally that Mr. Kimberlin’s claim was a lie. In every
appearance he has made in the case of Kimberlin v. Allen, he has appeared representing himself and no
one else.
49. Further Mr. Walker challenges Mr. Kimberlin to produce a single pleading or motion
where Mr. Walker “attacks” (read “criticizes”)
Judge Jordan and also swear out an affidavit that it is a
true and correct copy of a genuine document. Once again, this claim is an utter lie.
50. Indeed, the complaint as a whole is riddled with half-truths and outright falsehoods. A
five hundred page motion is unlikely to catalogue them all, and this court would need at least a full week
of hearings to prove each of them. However, this court can look at the websites cited above for itself
and see Mr. Kimberlin is lying about their content, and if Mr. Kimberlin cannot prove Mr. Walker filed
a pleading on Mr. Allen’s behalf and not to protect his interests, or that Mr. Walker “attacked”
(criticized) Judge Jordan, this court will be able to draw some conclusions from that failure.
Therefore, in consideration of the foregoing, Mr. Walker moves that the Plaintiff be required to
verify all pleadings, motions, oppositions, replies and all other papers filed with this court, swearing
under penalty of perjury that all factual assertions in such pleadings, motions, opposition or replies are
true and correct to the best of the Plaintiff’s knowledge and belief and all attachments are true and
correct copies of their originals. The fear of prosecution for perjury is obviously no guarantee that Mr.
Kimberlin will not lie. But upon information and belief, the Plaintiff remains presently on federal parole
(but not on supervision), and therefore he might not wish to risk having his parole revoked again and
that deterrent effect can only yield positive results.

Whenever Kimberlin describes criticism that he doesn’t approve of, he describes this in the most
violent terminology possible, hoping that readers might get confused and think someone is physically
attacking someone else.


Further, Mr. Walker moves that this court consider this motion on an expedited basis so that Mr.
Kimberlin might be required to file any opposition to Mr. Walker’s Motion to Dismiss as a verified

Monday, December 16, 2013 Respectfully submitted,

Aaron J. Walker, Esq.
Va Bar# 48882
7537 Remington Road
Manassas, Virginia 20109
(703) 216-0455



I, Aaron Walker, state under penalty of perjury under the laws of the United States of America ,
that the foregoing information is true and correct and that all exhibits are true and correct copies of the



(print name of notary public)

My commission expires on: .

Exhibit A: Excerpts from Transcript of May 29, 2012 Hearing; Kimberlin v. Walker (II) (Md. Mont.
Co. Dist. Ct. 2012) case number 0601SP019792012; Mr. Kimberlin claims he didn’t
know he was called the Speedway Bomber

Exhibit B: Excerpts from Transcript of J anuary 9, 2012 Hearing; Kimberlin v. Allen, (Md. Mont. Co.
Cir. Ct. 2011) case number 339254V; Mr. Kimberlin refers to himself as the Speedway

Exhibit C: Excerpts from Transcript of November 14, 2011 Hearing; Kimberlin v. Allen, (Md. Mont.
Co. Cir. Ct. 2011) case number 339254V; Mr. Kimberlin claims his parole wasn’t
revoked for failure to pay the DeLong widow

Exhibit D: Copy of Mr. Kimberlin’s Motion to Compel; Kimberlin v. Allen, (Md. Mont. Co. Cir. Ct.
2011) case number 339254V

Exhibit E: Recovered Text of Mission Statement from Everyone Draw Mohammed website

Exhibit F: Settlement Offer by Mr. Kimberlin; J anuary 3, 2012

Exhibit G: Excerpts from Transcript of April 11, 2012 Hearing; Kimberlin v. Walker (I) (Md. Mont.
Co. Cir. Ct. 2012) case number 8444D; Mr. Kimberlin states that he learned of Mr.
Walker’s identity on December 31, 2011

Exhibit H: Letter from Brett Kimberlin to various law enforcement agencies; J anuary 5, 2012

Exhibit I: Redacted copy of Mr. Kimberlin’s Motion to Withdraw; Kimberlin v. Allen, (Md. Mont.
Co. Cir. Ct. 2011) case number 339254V

Exhibit J : Excerpts from Transcript of J anuary 9, 2012 Hearing; Kimberlin v. Allen, (Md. Mont. Co.
Cir. Ct. 2011) case number 339254V; Mr. Walker orally moves the court to seal the un-
redacted version of Exhibit I and the motion is granted

Exhibit K: Application for Statement of Charges; filed J anuary 9, 2012 by Mr. Kimberlin against
Mr. Walker

Exhibit L: Petition for Peace Order; Kimberlin v. Walker (I) (Md. Mont. Co. Dist. Ct. 2012) case
number 0601SP005392012

Exhibit M: Excerpts from Transcript of April 11, 2012 Hearing; Kimberlin v. Walker (I) (Md. Mont.
Co. Cir. Ct. 2012) case number 8444D; Lt. Col. Sherman of the Montgomery County
Sheriff’s Office explains how footage is recorded in the Montgomery County Circuit
Courthouse’s security camera system

Exhibit N: Email from Mr. Kimberlin to Beth Kingsley, Esq.; J anuary 9, 2012

Exhibit O: Excerpts from Transcript of April 11, 2012 Hearing; Kimberlin v. Walker (I) (Md. Mont.
Co. Cir. Ct. 2012) case number 8444D; Brett Kimberlin states under oath that the
contents of Exhibit N are truthful

Exhibit P: Excerpts from Transcript of February 8, 2012 Hearing; Kimberlin v. Walker (I) (Md.
Mont. Co. Dist. Ct. 2012) case number 0601SP005392012; Mr. Walker testifies to his
version of the events of January 9, 2012

Exhibit Q: Excerpts from Transcript of February 8, 2012 Hearing; Kimberlin v. Walker (I) (Md.
Mont. Co. Dist. Ct. 2012) case number 0601SP005392012; Mr. Kimberlin testifies to his
version of the events of January 9, 2012

Exhibit R: Pastebin Document: Internet “Chat” Between Barrett Brown and Defendant J ohn Patrick

Exhibit S: Michelle Malkin, “Breakthrough: Fox covers Brett Kimberlin/ Patterico SWATting,
bloggers continue pressing the story,” May 30, 2012

Exhibit T: “Fox News covers Brett Kimberlin and Patterico SWATting story,” May 30, 2012

Exhibit U: “Sen. Saxby Chambliss Requests DOJ Investigate SWATting,” J une 6, 2012

Exhibit V: Video Exhibit: Footage from Security Camera, Montgomery County Circuit Court,
J anuary 9, 2012

Exhibit W: Video Exhibit: Defendant Patrick Frey Interviewed by Glenn Beck about SWATting,
from a YouTube video posted on May 25, 2012
Excerpts from Transcript of May 29,2012 Hearing
Kimberlin v. Walker (11) (Md. Mont. Co. Dist. Ct. 2012) case number 0601SP019792012
Mr. Kimberlin claims he didn't know he was called the Speedway Bomber
Case No. 0601SP019792012
Rockville, Maryland
12321 Middlebrook Road, Suite 210
Germantown, Maryland 20874
(301) 881-3344
May 29, 2012
to allow this" 1
3 uh-huh.
THE WITNESS: I, of course he is, okay. Yes, I was,
6 not?
And you were known as the Speedway Bomber, were you
I don't know that.
You don't know if you were known --
-- as the Speedway Bomber? You did not know that
11 you, you've never read this before in your life?
I've read a lot of things in my life.
Well, if you had a case called Kimberlin v. White,
14 did you ever :read that case?
You did not read Kimberlin v. white? This is a
17 decision involving yourself, and you're claiming you did not
18 read this case?
NO, never read it.
So you wer'e actually, this is you on the docket --
MR. WALKER: And, Your Honor, I'd like to show you
22 this case
THE WITNESS: Judge, that's from --
MR." WALKER: -- where it describes him as the
2S Speedway Bomber.
Excerpts from Transcript of January 9, 2012 Hearing
Kimberlin v. Allen, (Md. Mont. Co. Cir. Ct. 2011) case number 339254V
Mr. Kimberlin refers to himselfas the Speedway Bomber
et al.,
Civil No. 339254
Rockville, Maryland January 9, 2012
12321 Middlebrook Road, Suite 210
Germantown, MD 20874
(301) 881-3344
1 hearing. And the judge, Judge Jordan heard over and over, you
2 know, how, what his goal is --
3 THE COURT: And you have there what's currently on
4 the, what currently exists, is that correct?
5 MR. KIMBERLIN: Like I said, this is all since
6 November 14th.
THE COURT: But that's currently what's on his
MR. KIMBERLIN: That's what on his blog, yeah.
THE COURT: As of right now?
MR. KIMBERLIN: Yes. And I have a ~   t of it --
THE COURT: All right. Let me see it.
MR. KIMBERLIN: You want to see it? Okay.
THE COURT: All right. This one is dated November
14 23rd. I don't see anything in here that would constitute --
MR. KIMBERLIN: Well, I mean
THE COURT: defamation.
MR. KIMBERLIN: -- there's a lot of stuff in there,
18 so I could certainly find it, you know. But what does is he
19 mixes, he posts something, and then he'll say, oh, and then
20 Kimberlin, the speedway bomber, the terrorist, the perjurer,
21 and the pedophile did this or that. And you know, what he does
22 is he tries to do this so that he can get it on Google or get
23 it on the search engines, and then people who might want to
24 donate to my business, which is what Judge Jordan heard the
25 whole case about, won't want to help me, won't want to donate
-------------- ---- ------------------------------
Excerpts from Transcript of November 14, 2011 Hearing
Kimberlin v. Allen, (Md. Mont. Co. Cir. Ct. 2011) case nwnber 339254V
Mr. Kimberlin claims his parole wasn't revokedfor failure to pay the DeLong widow
- -- ------------------------
Civil No. 339254
Rockville, Maryland November 14, 2011
12321 Middlebrook Road, Suite 210
Germantown, MD 20874
(301) 881-3344
THE COURT: You can't --
MR. ALLEN: -- apologize.
THE COURT: You can't talk over each other.
THE WITNESS: Well, that, that's
THE COURT: Next question.
MR. ALLEN: Yes, sir.
MR. ALLEN: I believe, I'd have to check --
THE COURT: That's your question. Get to the next
No, I wasn't.
Do you think private individuals get mentioned, are
16 A
17 Q
18 A
22 question.
25 Q
7 Q More recently than 32 years ago, from your original
8 trial, if that's the date you're getting to, were you --
9 A I am not --
10 Q released?
11 A on parole.
12 Q Were you released and then sent back to prison for a
13 parole violation, for failure to pay compensation to the, Ms.
14 Delong (phonetic sp.), the wife of Carl Delong, who took his
15 own life after those bombs
-- tore up half his body?
Copy of Mr. Kimberlin's Motion to Compel
Kimberlin v. Allen, (Md. Mont. Co. Cir. Ct. 2011) case number 339254V
Case No. V 339254
Plaintiff Brett Kimberlin moves this Court under INDEPENDENT NEWSPAPERS,
INC.v. Zebulon 1. BRODIE. 966 A.2d 432 (2009), to compel the disclosure ofa blogger
who uses the pseudonym name Aaron Worthing ("Mr. Worthing") on various blogs that
have defamed Plaintiff in association with Defendant Seth Allen. One of the BRODIE
standards is that the Plaintiff must "notify the anonymous posters that they are the subject
of a subpoena or application for an order of disclosure.... "
1. Mr. Worthing blogs or has blogged for several blogs, including
www.Patterico.com, www.everyonedrawmohammed.blogspot.com!, and
http://allergic2buI1. blogspot. cmili.
2. Mr. Worthing has been conspiring with Defendant Seth Allen to defame Plaintiff
for over a year and, on August 22, 2011, received an email response from
Defendant Allen, which included a threat to murder Plaintiff. Exhibit A. Mr.
Allen was subsequently arrested for criminal harassment because ofthat threat,
and Judge Sarsfield issued a Peace Order against him.
3. Following this Court's judgment and permanent injunction of November 14,
2011, Defendant Allen continued to correspond with Mr. Worthing. During that
time, Mr. Allen violated the injunction by defaming Plaintiff, and Mr. Allen also
repeatedly attacked Judge Richard Jordan with threats, invectives, and
contemptuous comments and posts.
4. On or about December 6,2011, Mr. Worthing was banned from blogging on
\vww.pat1erico.com after the moderator of that blog, John Patrick Frey, learned
that Mr. Worthing had been blogging under a fake name and had created a
separate blog designed to inflame hostilities of Muslim hardliners called
5. Mr. Worthing has stated on several different blogs that he is an attorney.
6. On December 17,2011, Plaintiff Kimberlin, via an email to Mr. Worthing, asked
him to voluntarily appear as a witness in the January 9, 2012 Contempt Hearing to
give testimony about Defendant Allen's contemptuous and criminal conduct.
Exhibit B. IfMr. Worthing did not want to appear voluntarily, Plaintiff asked Mr.
Worthing to provide his real name and address so Plaintiff could subpoena him.
Mr. Worthing has stated in various blog posts that he lives in the Washington, DC
metro area.
7. Mr. Worthing has not responded to Plaintiffs request.
8. Mr. Worthing, ifhe is an attorney who has been conspiring with Defendant Allen
to commit intentional torts, may be in violation the Rules of Professional Conduct
and may be a conspirator and aider and abettor of Mr. Allen's intentional torts and
contemptuous conduct.
9. Mr. Worthing refused to answer interrogatories sent to him on or about September
26,2011 pursuant to this Court's order allowing post judgment discovery.
Plaintiff served those interrogatories on Mr. Worthing's supervisor at
www.patterico.com because Plaintiff could not locate any attorney in the United
States named Aaron Worthing. It was not until December 6,2011 that Plaintiff
learned that Mr. Worthing had been misleading Mr. Frey and his readers as to his
real identity.
10. Mr. Worthing is an important witness in this case. He has been conspiring with,
advising, and aiding abetting Mr. Allen for over a year regarding Mr. Allen's
defamation, harassment and stalking of Plaintiff Defendant Allen corresponded
with Mr. Worthing dozens of times via email and through various blog posts.
When Defendant Allen told Mr. Worthing that he wanted to murder Mr.
Kimberlin, Mr. Worthing did not report this to law enforcement officials or cease
his communication with Mr. Allen. When the District Court issued a Peace Order
against Defendant Allen on October 13,2011, Mr. Worthing continued to
associate, advise and correspond with him. When this Court issued its judgment
against Defendant Allen on November 14,2011, Mr. Worthing continued to
associate, advise and correspond with him.
11. Mr. Worthing, as a conspirator and aider and abettor of Defendant Allen, had
actual knowledge that Defendant Allen was defaming, harassing, and stalking
Plaintiff Mr. Worthing not only read all of Mr. Allen's defamatory posts and
comments, but he advised Mr. Allen on how he could defame and harass Plaintiff
by using various legal strategies. Defendant Allen relied on Mr. Worthing's
assistance, advice and support.
12. Mr. Worthing has used his pseudonym to hide his unethical, tortuous and
possibly criminal conduct with regard to his association with Defendant Allen.
WHEREFORE, Plaintiff moves this Court to Order Google Inc. or its subsidiary
Blogger.com to provide Plaintiff with the identity of the registrant of the following blogs
and emails belonging to Aaron Worthing:
1. Subscriber/registrant information for the Google Blogspot Blog,
http://allergic2bull. blogspot.com/
2. Subscriber/registrant information for the Google Blogspot Blog,
http://everyonedrawmohammed. blogspot.com/
3. Subscriber/registrant information for the Google email.edmd5.20.1O@gmail.com
4. Subscriber/registrant information for the Google emaiI.AaronJW72@gmaiI.com
An ORDER is attached.
Respectfully submitted,
Brett Kimberlin
[address redacted]
Recovered Text of Mission Statement from Everyone Draw Mohammed website
Note: the following is a cut andpaste ofrecovered text reconstructing the Mission Statement as it
appeared on the website Everyone Draw Mohammed. Due to data loss, the original is gone, perhaps
unrecoverable. However, this is a close facsimile.
Please note that the original text also linked to different websites which are not reflected in this text.
Freedom of speech is at stake here, don't you all see? If anything, we should all make
cartoons of Mohammed and show the terrorists and the extremists we are united in the
belief that every person has a right to say what they want. Look people, it's been really
easy for us to stand up for free speech lately. For the past few decades, we haven't had to
risk anything to defend it. One of those times is right now. And if we aren't willing to
risk what we have now, then we just believe in free speech, but won't defend it.
--Dialogue from South Park
It is time for We the People to fight for freedom of speech.
Freedom of speech has been under attack much of my life. It started with Salman Rushdie. He dared to
write a book in which a fictional character said something bad about Mohammed, and for that they put
out a fatwah, a decree that he should be murdered. And many people died bravely to bring that book to
market. It continued when Theo Van Gogh made a movie critiquing how Islamic culture treated
women. They killed him for that. Then the Danish created cartoons and we didn't stand with them.
Finally, South Park made a two part episode in which they took on the controversy and Comedy Central
censored the image of Mohammed, explicitly citing the fear of violence. And for their 200
and 201st
episodes, the guys at South Park did it again, and under threat from a bunch of idiots called Revolution
Islam, Comedy Central censored them again. They even censored a speech about the need for courage.
This has got to stop. Someone has to stand up for freedom of speech.
In this the government has failed us. How is it that Revolution Islam is allowed to threaten these
people's lives, and to extort them into silence, and walk around as free men? Many reports say that they
didn't "technically" threaten them, but the law of extortion doesn't rest on whether you technically say,
"do this/don't do that or we will kill you." You only have to communicate a threat in language that an
ordinary peson would understand to be a threat. Everyone knows they are threatening them. So why
isn't the police in New York beating down their doors?
In every stage of this, the government has failed to protect us. As a generally libertarian guy, this is one
of the places where I say that government positively has a role to play-to ensure our freedoms not just
by avoiding a violation of our rights, but actively standing between us and anyone who would use
violence and threats to take that freedom from us.
So We the People have to step up.
The idea didn't start here. Indeed, the person who kicked it off changed her mind, or maybe didn't
seriously mean it. But it's not her decision anymore.
The idea is simple. On May 20,2010, we will all draw Mohammed cartoons. And if you would like to
publish them, cheap and easy, I am here to help.
Ideally, you should give your real name, and maybe the general town in which you live. I'll start. My
name is Aaron Worthing. I live in Manassas, Virginia. And pretty soon I will inflict upon you my
artistic skills.
And if you want to publish your creation here, just send it to me. If you can give your real name and
town, that would be good. But even just an image would be fme. There is no censorship in this, except
you can't actually be pornographic. But otherwise, be as offensive as you want. And you can include
anyone else in the depiction. But, and this is key, you must depict Mohammed in some clear way,
preferably with a label. So if you show a picture ofa toilet and call it "Mohammed" we are good.
Also if you know of anyone else creating their own cartoon, send me a link to their site. If anyone else
does this, I want to know. Let's all create a nice little network of sites. Let's in a virtual way, lock
arms together and sing, "we shall overcome." As Benjamin Franklin once said, "We must all hang
together, or assuredly, we shall all hang separately."
But Ann Althouse and James Taranto (who gives a nice backgrounder) reply (in paraphrase) "but you
will offend moderate Muslims." Indeed we will and I want to be very clear. If I could think of any
other way to do this, I would do it. I berated Althouse on her blog over and over, "what is the
alternative?" No one has offered anything.
But they are correct that there is a cost to this approach. We will be posting messages that are dang near
guaranteed to offend good Muslims who both respect their prophet and freedom of speech. To them I
say your sensibilities are collateral damage in the fight for freedom. To them I say it is a ne,cessary evil.
Settlement Offer by Mr. Kimberlin
January 3,2012
Elizabeth Kingsley Esq.
Washington, DC 20036-4523
January 3, 2012
Confidential Settlement Offer Re: Aaron Worthing
Dear Ms. Kingsley:
Please take this letter as an offer to settle issues between me and your client known as
Aaron Worthing. This settlement will allow Mr. Worthing to maintain his anonymity.
1. I will withdraw my subpoenas for Comcast and Google to identify Mr. Worthing
filed in Kimberlin v. Allen.
2. I will forgo any future litigation concerning Mr. Worthing, including bar
complaints, sanctions, civil suits, criminal complaints, peace orders and other
administrative actions.
3. I will not make any public statements about Mr. Worthing, and will not ask others
to make any public statements or posts on the Internet about him.
4. I will not make any future attempt to identify Mr. Worthing in any manner.
In exchange, your client will do the following:
1. Withdraw his motion flIed in Kimberlin v. Allen.
2. Remove all posts and comments from his blogs about me.
3. Refrain from posting any information about me in the future.
4. Refrain from discussing me with other people.
5. Issue a public apology to me for his conduct regarding me, which includes a
statement urging others to leave me alone.
This settlement agreement must be signed in writing, and I will accept Mr. Worthing's
aka in lieu of his real name if you also sign the agreement.
This settlement offer is on the table until 5:00 pm Tuesday, January 3, 2012. If I do not
hear from by that time, I will take that as a rejection and will proceed accordingly. And
even though the actual drafting and signing of the settlement may take another day, as
long as I know that this offer is accepted by COB today, I will abide by the conditions of
the settlement pending actual signing. However, if accepted, the motions to withdraw
must be filed no later than Noon Thursday, January 5,2012.
I am available all day today and can come to your office if necessary.
Thank you,
Brett Kimberlin
Excerpts from Transcript of April 11, 2012 Hearing
Kimberlin v. Walker (1) (Md. Mont. Co. Cir. Ct. 2012) case number 8444D
Mr. Kimberlin states that he learned ofMr. Walker's identity on December 31, 2011
Rockville, Maryland
Civil No. 8444D
April II, 2012
12321 Middlebrook Road, Suite 210
Germantown, MD 20874
(301) 881-3344
cc 60
1 I needed to refer to notes. Uh-huh. They last -- the battery
2 lasts a long time.
3 Q But the proceedings were completely finished in front
4 of Judge Rupp that day, correct?
Excuse me?
The proceedings had completely finished, is that
7 right?
8 A I believe I had it on during the proceedings, yeah,
9 just as a -- when you say on, I mean the cover is closed. The
10 iPad that I had has a cover that closes and puts it to -- it's
11 kind of to sleep when it's closed. So the iPad was technically
12 on, but the cover was closed. So in other words --
13 Q So it would have been closed when you walked out of
14 the courtroom?
Exactly. Uh-huh.
The hearing that day was designed to get damages
17 against Mr. Allen or a contempt citation against Mr. Allen, the
18 defendant in that case, for continuing to interfere with your
19 business and
And for violation of the court order. Uh-huh.
In order to support the claim that he had done that,
22 didn't you ask that the identity of Aaron Worthing be
23 established so you could subpoena him as a witness?
Yes, I did.
Then you learned who Aaron Worthing was, the blogger
cc 61
1 Aaron Worthing was, is that correct?
Not through the court proceedings.
I understand that, but how and when did you learn
4 that?
I learned it on December 31st.
I got a tip, anonymous tip.
An anonymous tip via the internet, e-mail, or what?
Yes. It was actually by phone.
By telephone?
After you received that information, what did you do
13 with it?
14 A I tried to verify it. I did Google searches and
15 tried to verify that, in fact, Mr. Walker was Aaron Worthing
16 and vice versa, and I was able to locate a bunch of -- a lot of
17 documents online that made me comfortable that Aaron Walker was
18 actually Aaron Worthing.
19 Q Pending before the Court, in that civil action
20 against Mr. Allen, was a motion to require Google to disclose
21 the identity of Mr. Worthing, is that correct?
Right. Right.
So after you learned the information December 31st,
24 you filed a request to withdraw that motion, is that right?
25 A Yes, because I had already learned the information.
Letter from Brett Kimberlin to various law enforcement agencies
January 5, 2012
FBI Richmond
1970 E. ParlmmRoad
Richmond, VA 23228
Virginia State Police
P.O. Box 274n
Richmond. VA23261
January 5,2012
Fairfax County Police Department-Mason Division
6507 ColmnbiaPike
Annandale, VA22003
Manassas PoliceDepartment
9518 FairviewAve
Manassas. VA 20110
Via Email and First Class Mail
He: PolIce Protec:Ii ofAaron J. Walker, DOB
Dear Law EnforcementAgencies:
( am writing to ask your agencies to provide protection to Aaron justin Walker,
who has expressed concern for his and his wife's physical safet;y from Muslim
extremists. Mr. Walker is an attorneylicensed bythe Washington. DCbar. who lives
at Manassas, VA 20109. He is now woIking as corporate
counsel at a health care provider by the name of
The reason Mr. Wallrer's life may be in danger is that he has been identified in
a civil case in   a r y l a n ~ Kimberlin v. Allen.. 339254-V, Montgome.ry County
Cll'CUit Court. as the creator of a blog called
www.EveeyoneDtawMohammed.bloppot.com.Mr. WaIkeccrcamd and has
published that blog for more than a year using the pseudonym "Aaron Worthing."
He urged people to draw and submit pictures to him of the MuslimProphet
Mohammed in various derogatory ways inorder show snpportfor Danish
cartoonists who had a fatwa issued against them for drawing cartoons ridiculing
Mohammed. MnsJims who were offended by the depictions then made several
violent attacks against the Danish cartoonists and publisher.
Mr. Walker bas published hundreds of depictions on Mohammed on his
EveryoneDrawMobammed blog. and he has indicated that he fears that he and
wife will be subjected to harm now that he has been identified as die creator of the
blog. His bloghas been banned in Muslim conntries. and the State Department has
stated that his blog is harming the interests of the United States becansc it inflames
anti-American sentiments. Therefore. there exists the very real probability that Mr.
Walker could be subjected to serious harmor death now that his identity has been
exposed. Moreover, because he lives in a townhouse with many adjacent
neighbors. and worts in a large building with hundreds ofothel' people. any attack
against himcould R:SUh in collateral harm to others. In light of these concerns, I
strongly urge your agencies to develop a plan to protect not only Mr. Walker and
his wife from any such harm both at work and in their o   ~ but also to protect
those who live and wort near them.
Brett Kimberlin
Redacted copy oiM!. Kimberlin's Motion to Withdraw
Kimberlin v. Allen, (Md. Mont. Co. Cir. Ct. 2011) case number 339254V
f O\\' comes PlaimffBren I-:imberlin and mo,·cs thi Coun to allo\\ him to \\ilhdraw as
moOT hIS ( J I subpoena 1 (j ogle. (_ J subpoena 1 Com a5t and (.3 i ; ,1011On To Compd
seeking to idenll a \\ltm: and blogg r who g es Ih P ud Aaron Worthing
Plaintiff ha_ Ie, rned l.hat Mr. Worthing's actual name I aron Justin Walker
I. A ron.l. ","'all..cr I ao anomey lie nscd Ihe WashHl!,.'10n, DC bar. \\ h<,1 1t\C' at
. 1ana 'SUS. A 20I O<) He \\ ib born n
_.anended Pro\"lden e High 'ho I in eh rlone.. 'orth Carolina
and without graduating on Augu t . 19I.JL Mr. \Valkcr later
rec i\ ed his GCD, and in 1999. earned hIS Bachelor or. r15 d grce LH the
l'lll\cr:-.i£\ 0t'.· rth Te\:' . In Demon, Te,a On JuneS- 19 l!.. lr V,'-ulker
sued the La\\ 'chool Adllli sion. Council [0 aiiO\\ hun to take the L AT
\\ ith 3ccommod;JtioIlS. and the case \\'a settled on August I..t I<i98 in AJW
\' LSAC. 3-98, I 329-R-CV.. D TX. Oalla..<; 01\ ision He \ 'as admitted to
Yale La\\ chool and graduated wllh the class 01'2001. He i now working
as corporate counsel at a heollhar pr \ ider by Ih" na ne of
. located at . Annandale.
WHEREFORE. because Plaintl ff no\'\' knm\s lhal   bloggaand \\itne.s ' aron
W rthmg ,- Aaron J \-\'alker. he mo\c to \\lthdra\\- hI ubpoe:na to
and Google and hI- Motion to Comp"'l Google 10 di.close Aaron idemif}
I certify thai I mailed 3 copy of lhi: motion to Elizabeth King ley. anome). b) Fir t Class
1all this 5th day of January.  
Brett Kllnberlm
Excerpts from Transcript of January 9, 2012 Hearing
Kimberlin v. Allen, (Md. Mont. Co. Cir. Ct. 2011) case number 339254V
Mr. Walker orally moves the court to seal the un-redacted version ofExhibit 1 and the motion is granted
----------- - --
THE COURT: Civil 339254, Kimberlin versus Seth
4 I
3 Allen. And you are?
MR. KIMBERLIN: I'm Brett Kimberlin.
THE COURT: All right.
MR. WALKER: My name is Aaron Walker. I am the
7 blogger known as Aaron Worthing. And I have an emergency
8 motion against Mr. Kimberlin for his gross misconduct in this
9 case, and I'd like to be heard. I know it's unusual.
THE COURT: It's not here on your proceeding.
MR. WALKER: I understand, Your Honor.
THE COURT: So I'm not going to hear it.
MR. WALKER: Your Honor, he filed an improper motion
14 before this Court on Friday. I had no notice until Saturday
15 morning that he had done that. He has, in a blatant attempt to
16 stalk and oppress me, he has put --
THE COURT: Hold it. Hold it.
MR. WALKER: Yes. I'm sorry.
THE COURT: First off, you don't have any right to be
20 saying anything. And you don't have a right to be laughing.
21 There's a motion to withdraw as moot plaintiff's motion to
22 compel seeking identity of Aaron Worthing.
THE COURT: And then there's a, plaintiff's response
25 to Aaron Worthing's motion to quash. And you're Mr. Worthing?
1 MR. WALKER: Well, I'm Aaron Walker, and I blog as
2 Mr. Worthing, that's correct.
4 today?
THE COURT: Are you requiring that he corne to court
MR. KIMBERLIN: Judge, initially I, he's an anonymous
6 blogger who's been involved with the stalker.
THE COURT: But why are you, why is he here?
MR. KIMBERLIN: And so, I didn't ask him to be here.
9 He just foisted himself on this hearing.
THE COURT: Well, he says he's been summonsed.
MR. WALKER: Well, no, no, no.
MR. KIMBERLIN: He wasn't summonsed.
MR. WALKER: If I may explain, Your Honor.
THE COURT: All right.
MR. WALKER: He did actually initially ask me to
17 testify today in his initial correspondence with me. If he's
18 not interested in my testimony today, then I would ask why he
19 has subpoenaed this Court in order to obtain my identity.
MR. KIMBERLIN: I withdrew that.
THE COURT: It's been withdrawn.
MR. WALKER: Yes. But I understand, but why did he
23 do that in the first place?
24 THE COURT: Well, it's been withdrawn, so it's, he
25 says it's withdrawn. It's moot.
1 MR. WALKER: But Your Honor, if you look at what he
2 has filed today, all he had to do in order to file that motion
3 was to tell the Court that he obtained my information. He did
4 not have to even say my name. Instead, in this public document
5 now, he has put my name, he has put my home address, he has put
6 my birth date, he has put the high school I went to. He put
7 the fact that I dropped out of high school in this. He put the
8 fact that I received a GED. He put the fact that I went to the
9 University of North Texas. He went and put in the fact that I
10 sued the law school admissions council. He put in the fact
11 that I was admitted to Yale Law School and graduated in the
12 class of 2002. He put down my current job with my current
13 employer and their address as well.
14 His intent in doing this was so that it becomes a
15 public record so that him and his friends can put this out into
16 the public so they can stalk and harass me. It is plain on the
17 face of this. And I would ask Your Honor to swear him in and
18 ask why he put all this unnecessary information in this, in
19 this filing.
THE COURT: Well, it's been withdrawn as moot.
MR. WALKER: Well, I'm talking about the motion to
22 withdraw itself.
24 effect.
THE COURT: Well, it's done. It's no longer in
MR. WALKER: But this is a public document. And his
am 7
1 friends will then take this public document, his motion to
2 withdraw as moved, and they will put it out, and then put out
3 all of my information.
6 like--
THE COURT: Are you asking that this be sealed?
MR. WALKER: I would like this to be sealed. I would
THE COURT: Any objection to sealing it, Mr.
8 Kimberlin?
MR. KIMBERLIN: Judge, this
THE COURT: Say yes or no.
MR. KIMBERLIN: Yes, I object.
THE COURT: Yes, why. Why should all of this be a
15 matter of public record?
16 MR. KIMBERLIN: This man has engaged in stalking with
17 the defendant in this case.
18 THE COURT: Well, there's no order against him in
19 this case.
21 But he --
MR. KIMBERLIN: No, there's no order against him.
THE COURT: So why is he even a part of this case?
MR. KIMBERLIN: He did it anonymously. Initially, I
24 wanted to call him as a witness. And then when I filed the
25 motions to call him as a witness, he began trying the case in,
am 8
1 on his blog. He filed every, he posted every motion on his
2 blog. And he kept accusing me of all kinds of terrible things
3 on his blog. And he ridiculed me. He taunted me. He
4 threatened me. He had people posting on his blog that I was a
5 terrorist and a pedophile and all this other stuff.
6 And he engaged in unethical behavior. He said that
7 he represented the defendant in this case as an anonymous
8 person. He can't, a lawyer cannot represent someone as an
9 anonymous person. He asked to be identified. I mean, he went
10 on his blog and said I am representing, I entered into an
11 attorney-client privilege relationship with Seth Allen as Aaron
12 Worthing. And he's not even a lawyer in this jurisdiction. He
13 lives in Virginia. He can't represent somebody as a fake
14 person, in a pseudonym. I mean, that's -- and so he put
15 himself out there to be identified.
16 I mean, if he's a lawyer, fine. I have a right to
17 determine if he's a lawyer. He can't say that he's anonymous
18 and he's representing Seth Allen. It just, it didn't make
19 sense. And so I said, well, I need to find out who this guy
20 is. If he's saying he represents somebody in a case against
21 me, then I need to be able to identify him. And so I
22 identified him. And I didn't want him to come out and say
23 the reason I put all that information in the document was
24 because Mr. Worthing has called me a liar over and over and
25 over. And I wanted to, everybody to know
1 THE COURT: Why is this even in the court? This is
2 incredible to me.
MR. KIMBERLIN: I know. It's really incredible.
THE COURT: No. I mean, the whole thing is
5 incredible. I'm going to, there's a motion that was, to quash
6 that was filed on behalf of, it was filed originally by --
8 suspect.
MR. WALKER: If you're looking, it's Seth Allen, I
THE COURT: No. It was filed by Elizabeth --
MR. KIMBERLIN: Kingsley.
THE COURT: Kingsley.
MR. WALKER: Oh, that would be the attorney who
14 represented me in the past.
15 THE COURT: And she filed a motion to file
16 anonymously or to file under seal.
THE COURT: And she's filed that. And I'm going to
19 grant the request to file this anonymously or under seal.
THE COURT: And I'll grant the request to seal the
22 information that's contained at Docket Entry 114, which is the
23 motion to withdraw as moot.
All right. Sir, that concludes your --
MR. WALKER: Actually, I would like a little more
1 relief, if you don't mind me taking a moment.
2 THE COURT: That's it. No. I'm done. You're done.
3 MR. WALKER: All right. Thank you, Your Honor.
4 THE COURT: All right. Mr. Kimberlin, i received a
5 phone call, well, actually, my secretary received a phone call
6 from Mr. Allen --
8 THE COURT: with a 508 area code number --
10 THE COURT: requesting that he be allowed to
11 participate by telephone. And he made representations that he
12 had submitted written requests to participate by telephone. I
13 checked with the clerk's office. I don't see any written
14 requests having been made.
15 But I've reviewed Docket Entry Nos. 99 and 100, which
16 are your motions for contempt of court, against Mr. Allen. And
17 I have to tell you I'm a little puzzled as to what it is you're
18 claiming that he's done that constitutes contempt of court.
MR. KIMBERLIN: All right. I'll be happy to go into
20 that. Are we going to have Mr. Allen on the phone or --
MR. KIMBERLIN: So I proceed. Okay.
THE COURT: I want to know why you think he should be
24 held in contempt of court.
MR. KIMBERLIN: Well, I have a memorandum. Can I
Application for Statement of Charges
Filed January 9,2012 by Mr. Kimberlin against Mr. Walker
COlviPLAIi'{ANT:i· .
'. ... - _.
C::V \\

DEFENDAJ<rS DESCRIPTlDN, Dd",', Li,,",'" _............ s" i"1... Roo, r' HI s:::Li.""WI J'3.S"
Hair Eyes _..D:':!-. Complexion .__ Other _ .._ _ _ O.O.B ..7.J:-lD _ _.__.__ _ .
r, the undersigned, apply for statement of charges and a summons or warrant which may lead to the atTest of the
above named Defendant because on or about L{5.L.. .._._ _ at J2ovl,:.v\'l
cc- . q Dale Ploce
..-.. .. ---.<.- _ -.-.-..- --..-.-- , the ab?ve named D.efendant
__.. Ie. __.__ '{.1.. .. .. ...
..               '"'  
..... .Q"'si.....   ..   ..
..-\ \ c£.- Q0R';-.   ..._-.....-..
__._.__   __._.__. y_!.._._._ v c,. . \).Q..-Q .__. _
(Continued on attached .__._ _.... pages) (DCfCR lA)
I solemnly affilID under the penalties of perjury that the contents of this Application are true to the best of my knowledge,
information and belief.
Dote Onker's Signalure
  an::n::rsmnd the of ........
Date n Applicant's Signature \ 2-
Subscribed and sworn to before me this .-...-.. ..-... day of _._..- _·-··-yeai--·-·,
Time: J.. .. Judge/Commissioner __m _._ _J.. _._ m.....
r understand that a charging document will be issued and toat I must appear for trial 0 on .'-'---·"0,1<""···---···-·_·
at ....------...-.----.---.----- .,0 when notified by the Clerk, at the Court location soown at the top of this form.
Time •
DefeR 1 (Rev. 12/2006) Prinl Date (5/2009)
  IJ!l - \ !Yv" i-v\·e.-dz --\-9
...........................................................................\. - _ _.....•.....•..._.....•.........................;;- _ .
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DefeR 1.-\ (Re\'. lI::OO:2) Print Dale (3/2010)
r.n11R, r.npy
Petition for Peace Order
Kimberlin v. Walker (1) (Md. Mont. Co. Dist. Ct. 2012) case number 0601SP005392012
- --  
bo.m. IfI' ask rl:e c1er.t)
p .
The Respondent committed the following acts ag:tinst   _,
wirhin rhe past 30 d:lys on rhe dates stated below. (check all that apply) 0 kicki:1g g/punching 0 chokin", 0 slapping
o shooting 0 raoe or other sexu:ll offense (or at er:1pt) 0 hitting with object 0 ml:.bir.g ... ohiolence
6' st3.lking 0 detaining ag3.ins \\ill U trespass 0 mali ious destn.!c ior. of property 0 other
COJrt Kind of Case Ye3.r Fi ed Res Its or Sta 's (if you know)
/- _ _ _ ..
to contlc , arrempt to conta' . ..
r;;:v>. 'OT to go :0 the residence(s) at
o NOT to go to the seho I(s) at ·······.. ··Niiiie.. - - · - ..
o NOT to go to the work place(s) at _ _ _ .
n To go to counseling. 0 To go to mediation. 0 To pa:1 the fiEng fees and court costs.
speci:!c relie : LV2..t T.. ..CJ. ..   ?...':2 :3-: P
I solemnly affirm under the penalties of perjury rha
.. ..
(-- f.. Da"
OJ indi'/idual who kr-.owingly pro'. ides false informa:ion in 2. Peti:ion fer is guilty of a
nd on conviction is ,;ubj::ct to 2. fine not exceedi g S1,000 or imprisonment not exce::";·ng 90 days or bO.h.
Dc/PO 1 (Rev. }/'2003)
Excerpts from Transcript of April 11, 2012 Hearing
Kimberlin v. Walker (1) (Md. Mont. Co. Cir. Ct. 2012) case number 8444D
Lt. Col. Sherman ofthe Montgomery County Sheriff's Office explains howfootage is recorded in the
Montgomery County Circuit Courthouse's security camera system
So he's not available to testify today?
No, sir.
Were you in the courtroom when he testified in
4 District Court?
A Yes, sir.
MR. BOURS: Judge, I'll just proffer so that we don't
7 have to fence around about it. I do have a disc and I can have
8 it marked. It's currently in the only computer I could get it
9 to work on and I'm reluctant to take it out and ruin that. But
10 I'd like to show this to the Colonel and see if he can agree
11 that this is the full video.
THE COURT: And to Mr. Kimberlin.
MR. BOURS: How long will this last if we don't plug
14 it in again?
17 then?
MR. WALKER: I think we got hal f an hour.
MR. BOURS: Okay. You want to pullout the plug
MR. KIMBERLIN: I have no objection.
THE COURT: Okay. But you might want to take a look
20 at what it is he's showing.
23 Q
MR. KIMBERLIN: I assume it's the same thing. Yeah.
Tell me about the system that these photographs are
24 taken with or these videos are taken with.
25 A There's a Vicon system that has a number of hard
1 drives, maybe two or three hard drives.
I'm not exactly sure
2 about the electronics, but there is a rack in the Sheriff's
3 office on the T8 level in the courthouse that records video
4 feeds from cameras that are installed in the courtrooms,
5 installed in the hallways in the courthouse, pursuant to a
6 security study done by the National Center for State Courts
7 some years ago.
8 They typically some of them are fixed cameras.
9 Some of them are directable cameras and they record what I
10 would call multiplexed video. In other words, it's not a
11 continuous stream of photographs. There are maybe 16 cameras
12 being recorded on one hard disc and it will switch from each of
13 those 16 cameras, as I understand it, take a fraction of a
14 second, switch to the next camera, and then it gets
15 multiplexed. Then there's a software kind of set up that
16 allows it to separate those pictures out again.
So it will take a picture but it will be every
19 sixteenth of a second. There may be some gaps in it.
So it's every sixteenth of a second that it
I don't know the exact fraction of a second. I know
22 that the multiplexing will go through a number of different
23 cameras and then when you view it, it reassembles those. But
24 it won't be like a high definition movie that you would watch
25 on your cable tv where it's continuous.
1 Q
The thing that is recording it is on a, I'll call it,
2 a pole or some kind of extension that comes down from the
3 ceiling and has multiple views around the ninth floor, is that
4 right?
5 A The -- there are cameras installed in various
6 locations in the courtroom, courthouse, in the lobby.
7 Q Can you tell from this video though where this one is
8 from?
9 A This appears to be a camera in the ceiling of the
10 lobby on ninth floor of the courthouse. There's a wire or a
11 conduit, whether it's optical cable or electrical cable, that
12 then runs back down from that camera to the basement in the
13 courthouse to a essentially a computer hard drive. It gets
14 the information gets recorded on that hard drive.
15 Q You know for a fact that the disk that is playing
16 this was recorded for a period of time beginning at roughly
17 11:40 a.m. on January 9th?
18 A I -- other than looking at the data that's displayed
19 on the picture itself, I wouldn't know what the time frame,
20 date of it is or the time frame. It's self authenticating in
21 the sense that the frames have a date indication that I would
22 presume is correct.
23 Q Just so you don't have to come back, I'm going to
24 start this real quick because it doesn't take very long, and
25 ask if it appears to be genuine to you.
Email from Mr. Kimberlin to Beth Kingsley, Esq.
January 9, 2012
12/13/13 Gmai I - One of tv..o forwarded messages
From: Justice Through Music [mailto:jUstiCejtmp@_
Sent: Monday, January 09, 20124:59 PM
To: Beth Kingsley
Subject: Aaron Walker assaulted me in courthouse
I just finished pressing charges against him for assault and battery and got a Peace Order against him.
Nine deputies had to back him off. He decked me in the face, hit me in the shoulder and chest, pushed
me, grabbed my iPad away from me and wrestled me.
He will tell you that the judge sealed my motions and his (even though he posted his on his blog). But
even after that, he harassed the judge until he told him he was going to be escorted out by the Sheriff,
and then he followed me out, threatened me and then physically attacked me.
Went to doctor and they sent me to ER at Suburban, said I need a CAT scan.
You client is very dangerous. If you want copies of the criminal charge and peace orders let me know and
also if you are going to defend him on the criminal charges.
Brett Kimberlin
-------------- -- ----------------------------
Excerpts from Transcript of April 11, 2012 Hearing
Kimberlin v. Walker (1) (Md. Mont. Co. Cir. Ct. 2012) case number 8444D
Brett Kimberlin states under oath that the contents ofExhibit N are truthful
cc 76
A No. I went straight over there.
MR. BOURS: Judge, I'm going to offer Respondent's
4 Exhibit NO.4. Could I explain that I don't know it happened,
5 but when District Court put together this certification, they
6 included somebody else's case.
THE COURT: It happens.
MR. BOURS: Don't know how, but this is all part of
9 one certification and that's the relevance.
10 THE COURT: I see that more times than you would
(The item marked for identification as
Defendant's Exhibit NO.4 was received
in evidence.)
Number 5?
11 guess.
17 Q
Later in the afternoon on January 9th, did you send
18 an e-mail to Beth Kingsley?
Did you use Justice Through Music as your return on
21 e-mail?
Yes. Dh-huh.
Do you want to look at this? The top is irrelevant,
24 but is that your e-mail to Beth Kingsley?
25 A Uh-huh. Yeah.
1 Q
In that e-mail, did you say, I just finished pressing
2 charges against him for assault and battery and got a peace
3 order against him. Nine deputies had to back him off. He
4 decked me in the face, hit me in the shoulder and chest, pushed
5 me, grabbed my iPad away from me, and wrestled me.
That's true.
You say that's true and that's also what you put in
8 the e-mail to her, correct?
Right. Dh-huh.
MR. BOURS: I want to offer No.5.
THE COURT: It will be received.
(The item marked for identification as
Defendant's's Exhibit No.5 was
received in evidence.)
You have become aware that this gentleman is an
17 attorney, correct?
You also became aware, subsequent to the events of
20 January 9th, that the State's Attorney for Montgomery County
21 was not going to prosecute the criminal case, is that right?
22 A Yeah. Had a long talk with him. They said that
23 since there's a peace order, that they didn't think that --
Excuse me. Excuse me.
Excerpts from Transcript of February 8, 2012 Hearing
Kimberlin v. Walker (1) (Md. Mont. Co. Dist. Ct. 2012) case number 0601SP005392012
Mr. Walker testifies to his version ofthe events ofJanuary 9, 2012
Case No. 0601SP005392012
Rockville, Maryland February 8, 2012
12321 Middlebrook Road, Suite 210
Germantown, MD 20874
(301) 881-3344
13 I
1 told numerous lies. He, for example, said that he was
2 convicted of a crime. He has 35 counts conservatively against
3 him. He has been convicted of setting eight bombs in six days
4 in Speedway, Indiana. He has been convicted of conspiracy to
5 distribute 10,000 pounds of marijuana. He's been convicted of
6 perjury and he comes here to this court and says I was
7 convicted of a crime? This is the character of him. He lies
8 about everything. He constantly lies about everything. He,
9 prior to this --
11 and
Well, why don't we get to the, what he said about you
Right. Right. Okay. First, Your Honor, what he --
He said you wrote these blogs. He said you attacked
14 him over in the Circuit Court.
15 A Yeah. I did not, I did not physically touch him
16 once. This is what happened that day. I knew that he was a
17 convicted terrorist. I knew that he was a convicted bomber.
18 We were, I was, I was, frankly, cross-examining him live in
19 front of, right there after the hearing. I was trying to get
20 him to make damaging admissions and I did. I got him to admit
21 that his entire process of attempting to obtain my real
22 identity was a sham.
23 And at that point he stepped back, and now as he
24 admits, broke court rules by attempting to take a photograph of
25 me with his iPad. And I saw him go to do this, and I didn't
--- ----------------
know what he was doing and I had a split second to think, Your
2 Honor, and I didn't know if this convicted bomber had a bomb
3 inside of the device, had who knows what inside of the thing.
4 So I had a split second to think and I reached down and I
5 grabbed the iPad from him and I peaceably held it away from
6 him, and that is all I did.
7 I did not deck him. I did not lay one single finger
8 on his body. Everything, all these photographs, they are lies.
9 I don't know what he has done specifically. I don't know if he
10 is sociopathic enough that somebody had beaten him up to
11 produce the evidence or what. What we can show you -- I have
12 Deputy James Johnson here and he will, I believe, testify that
13 the man had no visible marks, he did not say at the time that
14 he was struck, and he did not see any sign that he had been
15 struck.
Why don't you call a witness then, if you wish --
Well --
-- after you tell me what you want to tell me.
Right. So, all I had done that day, Your Honor, is,
20 you know, I literally took the iPad from him, I surprised him
21 so much it wasn't that difficult to do, frankly, and then I
22 held it one way, you know, the other way -- it's kind of like
23 kids on the playground, honestly, Your Honor. And then finally
24 I just held it above me, and that is all I did. And I did not
25 touch his person one single time. I simply removed the iPad
and held it away from him until the sheriffs could arrive and
straighten the whole thing out, and that is all I did that day.
Now, as far as his claim that I have been harassing
him on the blog, you know, Harry Truman once said,   didn't
give him hell, I told him the truth and they considered it
hell." I have told the truth about him. He has now for over a
month made my life hell. He has stalked and harassed me. He
has used the Court's processes in order to out me and then
intentionally attempted to get me killed. He literally
attempted to get me killed.
And I can show you with his own words where he admits
in engaging in a course of conduct that he says creates a real
risk that I might get killed, my wife might be killed, that my
co-workers might be killed. If I can, I would like to show you
that letter, Your Honor.
What he did, Your Honor, is, as you've heard, he was
using the court's processes to obtain my identity. He then,
when he obtained my identity, he then put it into a court
document in his motion to withdraw. All he had to do in that
motion was to say I got the information by other means. He
didn't have to name me. He certainly didn't have to put my
current address. He didn't have to put where I worked or my
work address. He didn't have to put any of that information,
and yet he did.
And I went in on January 9th and I argued this was a
Excerpts from Transcript of February 8, 2012 Hearing
Kimberlin v. Walker (1) (Md. Mont. Co. Dist. Ct. 2012) case number 0601SP005392012
Mr. Kimberlin testifies to his version ofthe events ofJanuary 9,2012
said I've already learned his identity, I don't need the
motions for Comcast and Google and all these other places where
3 I could get his information. And he came into court on the
4 January 9th hearing in front of Judge Rupp and the judge ruled
5 that there was no contempt of Mr. Allen, but at the same time
6 Mr. Walker kept interfering with the case and the judge finally
7 told him, listen, Mr. Walker, I will get a sheriff here and
8 remove you from the courtroom if you keep interfering with this
9 case, because he had never filed an appearance in the case. So
10 -- and I have those transcripts here if you want to see them.
11 But so as we were exiting the courtroom on the 9th
12 floor, Courtroom 5, I believe, we walked out of the courtroom
13 and he's screaming at me and telling me that he's going to
14 continue harassing me. And as we got outside the door, right
15 outside the courtroom, he began lunging at me. I picked up my
16 iPad and took a picture of him lunging at me. He decked me in
17 the eye and wrestled with me.
18 A man that followed us out of the courtroom raced
19 back into the courtroom and told two people that were working
20 for Judge Rupp that he was attacking me and attacking me. They
21 came out and told him to get off of me and they called the
22 police. Nine police came up to the or, sheriffs came up
23 there and separated him. He had my iPad in his hand at the
24 time and refused to give it back.
25 The sheriff went over and took the iPad away from him
th 8
1 and told me to come down and press charges against him. I
2 pressed charges against him for second-degree assault and I
3 also got this peace order. At that time, the judge in the
4 temporary peace order case told him not to harass me and not to
5 bother me or do anything.
6 And since then he's filed a charge against me for
7 filing a false criminal charge against him for attacking me.
8 He's filed a $66 million lawsuit against me in Virginia. He
9 filed the peace order against Neil Rothauser (phonetic sp.) and
10 had them come out to my house. He's posted scores or dozens of
11 tweets about me. He has --
Do you have the tweets?
you know, he, it goes on and
Do you have the tweets, sir?
Yes, sir.
How do you know they're from him?
Excuse me?
How do you know they're from him?
Oh, it's got his name on it.
20 Q Oh.
21 A But he's -- so here are the tweets, I mean just on
22 and on. And he posted a post just Saturday where he asked,
23 where he says to, in a post on his own blog he says, "If you
24 help this man," me, "Or his co-conspirators, then you are
25 aiding and abetting. If you donate to his non-profits," and I
Pastebin Document
Internet "Chat" Between Barrett Brown and Defendant John Patrick Frey
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---------- Forwarded message ----------
From: Patrick Frey <patterico@gmail.com>
Date: 2012/6/21
Subject: Chat with Patrick Frey
To: barriticus@gmail.com
12:23 AM Patrick: I thought Project PM was partially about posing as others using sock
12:24 AM me: one second
12:28 AM okay, sorry
Project PM has never been about that, where did you get that impression?
Patrick: Maybe I'm wrong, I admit ignorance on the whole thing
Vague memory
12:29 AM Something Rauhauser said, I think
You don't know how to spell his name???
12:30 AM me: Okay, Project PM started in late 2009 and was originally intended to incubate
experimental online activism/philanthropy/blogging setups, I talked about it in my outlets
like HuffPo, Vanity Fair, Skeptical Inquirer when I was recruiting
Patrick: Rauhauser has described himself as a participant
12:31 AM me: He probably thought of himself as a participant, he hung out in our IRC
channel off and on for a while, originally under his own name
12:32 AM As I recall he was keen on telling us about various networks he was developing by
which to keep congressmen appraised of policy info via their assistants or what have you
12:33 AM As back then, our focus was largely on building either a blogging network based
around a schematic I designed, and then using a similar schematic for crowd-sourced
projects along the lines of our Science Journalism Improvement Project
at any rate, that's how I met the guy, I'm assuming he found out about PM via one of my
Huff Po posts
one sec, just saw you sent an e-mail
12:34 AM Patrick: Don't take offense
me: Er, okay
Patrick: It's characteristically blunt
me: Regarding me being unlikely to take McCain at face value, that's absolutely true,
considering the circumstances
Patrick: Most people live their lives as bullshitters and I don't want to be that way
me: but in this case he's excerpting something that Neal wrote in his own words
12:35 AM Patrick: True enough
me: So it doesn't matter who put it forward and whether or not I trust the person
excerpting it
12:36 AM I knew that Neal did something involving Twitter but didn't know the nature of it
until I saw your post from the other day in which you layout these various bizarre
messages about this woman "asking for it" or what have you
Patrick: What woman asking for it?
I don't remember that
12:37 AM me: Also I understand your general SUspIcIon since Neal has been involved in some
extent with portions of Anonymous and all that,
one sec, I'll show you
12:38 AM it's on one of your recent posts, him or one of his people say something like
"you weren't raped it was rough sex"
Patrick: OccupyRebellion
Mocking Liberty Chick
me: yes
12:39 AM Patrick: Well, look
Everything I tell you is with the thought in mind that you could be the earnest Barrett
Brown I like to think of you as being,
me: I guess the best way for me to get you to understand that I'm in earnest is to explain
that I'm in some degree of contact with a huge number of people, and am not able or
inclined to keep track of everything everyone does
Patrick: You could be Neal's best buddy dispatched to find out what I know
12:40 AM I'll just tell the truth either way
Neal has openly declared that he wants to see me:
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prosecuted for God knows what crimes
and so forth
me: Yeah
I'm not sure how to convince you otherwise
Patrick: I believe he is a psychopath
And he is FIXATED on me by all accounts
12:41 AM Don't worry about it
S Again: I'm being straight with you no matter what your role is
12:42 AM He has done his level best to make it seem as though he was involved in my
me: I would simply say that I don't hold you responsible for the things that McCain does,
even though he has publicly accused me of being an FBI informant twice in the past month,
because I know that every relationship is nuanced
that not everyone knows or approves of
everything that every other person does that he has any sort of contact with
0. Patrick: And though I know you have no love for federal law enforcement, I hope they get
to the bottom of that.
~   You know McCain and I have scrapped
, me: Yes
I do
Patrick: I have not taken back anything I said
6 \. 12: 43 AM But what I said was misportrayed by some
DC And I believe he is doing an energetic and good job revealing Neal's role in the
harassment suffered by me and others
12:44 AM Put it this way:
7 Stacy McCain never took any action to have me killed
I can't say the same about Neal with any confidence
You a fan of Jay Leiderman?
12:45 AM me: AnywaYJ I wrote you that e-mail because I generally disapprove of what Neal
seems to have been involved with
and am not asking you for any info
and will happily
answer any questions you might have
although I haven't followed all of this closely
enough to have much insight
71 Patrick: Represents Commander X? Hero to Anonymous activists? Right?
IL. me: Yes and no
71 He doesn't represent Commander X
7 Patrick: Elaborate please
I Then the media articles I read are wrong
7 Because they say he does
17 12:46 AM me: I met Leiderman a while back
he helped to arrange pro bono defense for many
of the people who were raided and then charged with the DDOS attacks against Paypal last
I . Patrick: What a guy
12:47 AM You guys are supposedly in favor of free speech
me: X has another lawyer who actually technically repped him, Leiderman has simply
assisted on that and other cases
Patrick: But I guess you will profess ignorance on Leiderman's thug tactics against me
82 Right?
me: Excuse me
12:48 AM Patrick: You know he is representing someone suing me because of a BLOG POST I
Don't you???
Do you not know that?
me: I don't know what tactics you're referring tO
and if you'd like to tell me I'll
but keep in mind that I don't know everything
Patrick: I am asking
Neal arranged for that representation
me: Can you not ask by starting with "I guess you'll profess ignorance"?
Patrick: OK
12:49 AM I feel defensive because I know you have had interactions with the guy and he is
trying to sue me for a blog post
It seems like you would know about that
but I'll be fair to you and just ask if you do
12:50 AM me: On whose behalf is he suing you
Patrick: Nadia Naffe
Neal arranged it
Neal and Leiderman have also discussed suing me and others for RICO
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me: I've seen her being retweeted, not sure exactly what her deal is?
Patrick: Simple
12:51 AM Neal put her up to suing me
On behalf of Kimberlin
That's her deal
The. End.
me: So, they've sent you something about that?
Patrick: Suing me and my boss, actually
I read about it all online
On Breitbart Unmasked
12:52 AM On emails from Neal sent to others that they forward to me
On Nadia's Twitter feed
I know there is a civil claim against me and my boss
But I get to learn all about it by reading about it on Twitter feeds and sites associated
with Neal and Nadia and Kimberlin
12:53 AM Lawsuits to retaliate against people for commentary on public controversies: is
that part of the Anonymous creed?
Because it's sure part of Neal's creed
And Kimberlin's
12:54 AM It would be interesting to see you publicly pronounce on this
I thought Anonymous stood for free speech. But Neal's version stands for free speech of
the sort he likes -- and retaliating against the sort he doesn't like
12:55 AM me: I've told you, just now, via e-mail, that I don't approve of Neal, and have
apologized to you for having associated with him
As for Anonymous
Patrick: He also has gone after my wife on numerous occasions
12:56 AM Which is totally thuggish as she is a Democrat and doesn't even agree with my
politics. But I love her because my life is about more than just politics
me: There's quite a bit I don't approve of that has gone on under its "banner," and I've
been pretty vocal about that
Patrick: I am not a political automaton
I am a human being with a family
12:57 AM me: You don't need to tell me that, I don't think you are
Patrick: And a job that Neal Rauhauser and Brett Kimberlin are trying their level best to
get me fired from
A job I do well
And honestly, and ethically
And your pal Leiderman is part of their little jihad
12:58 AM me: (an you please slow down a bit and keep in mind that I'm trying to do the
right thing here?
Patrick: I wouldn't be talking to you if I didn't think that was at least a possibility
me: The whole reason I approached you is that I've seen some of this via these recent
posts and don't like what's been directed at you
12:59 AM Patrick: But I'm not stupid either, and I am suspicious, and if my suspicion is
unfair as directed at you I hope you don't take it personally
I am suspicious but open-minded
You have always seemed to have a good heart
1:00 AM me: I understand that, but please remember, again, that I'm answering any
questions you have
Patrick: Maybe you fooled me but that's how you have come across
me: If you want to trade stories about who's family is being targeted by who's faction, I
can tell you some great stuff about what the FBI is doing to my mom
Otherwise, let's keep this on point
Patrick: Well, you owe it to yourself to learn more about Jay Leiderman and his
involvement with trying to ruin my life
1:01 AM I'd listen to what the FBI is doing to your mom
I'm no fan of the FBI these days as I think they have been cavalier about what happened to
me and my family
me: There's no reason for me to tell you about it because it won't help anything and it's
not something you yourself did
Patrick: OK
1:02 AM me: I just want you to understand that I'm also being targeted and that although I
want to be helpful to whomever is being wronged, and do understand that you're being
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wronged, and although I'm willing to do whatever is the right thing even if it's going to
cause me additional problems I don't need, I also don't want to be spoken to along those
Patrick: There are people who would say I am crazy for even talking to you. Maybe I am. I
assume the FBI monitors your chat logs, as I have always said. I don't say anything that I
would be embarassed to have revealed
1:03 AM "I also don't want to be spoken to along those lines" -- what do you mean?
me: As for Leiderman
1:04 AM Patrick: Look, I try to give everyone the respect they have earned. As far as I
know, you have treated me with respect. I don't want you to see me as a sucker, but I
don't mean to insult you in any way
me: That's fine
1:05 AM Look, what questions do you have for me, and I'll answer them
Patrick: I'll give you the benefit of the doubt as I think you have tried to be straight
with me
Expound on him; brb
5 minutes
1:11 AM me: Well, mostly I just know him via efforts I was making in early 2011 to arrange
pro bono defense for those who were raided, and he's also provided advice to various other
activists and all of that, but vis a vis this situation with you, I don't know much. Neal
sent me a message about six months ago give or take that he had gotten Leiderman to rep
him on something but I didn't pay attention to what, or maybe he didn't say
Patrick: Can you forward that?
me: I don't know what he personally knows even about Reahauser, or what he's been told by
him, or whatever
1:12 AM It wasn't an e-mail, is the problem
Patrick: RaUhauser
Screenshot it and forward it
me: most of the communications I've gotten from him have been on IRC or Skype messaging
1:13 AM No, as in don't still have it, assuming you're not familiar with how IRC works but
one has to actively log convos to keep them
Patrick: Never used it
1:14 AM me: It's popular with Anons and the "other side" as well, sort of a niche medium
Patrick: Well, if you truly disapprove of the guy and his actions, I would appreciate your
forwarding whatever he has sent you in the past 1-2 years
me: as for Skype
Patrick: That you can
1:15 AM me: it only keeps from last 3 months, and the only text messages I have from him
on skype consist of him expressing irritation that I haven't picked up his calls
as in
[3/8/2012 9:38:37 PM] Neal Rauhauser: meh
[3/12/2012 1:15:15 AM] Neal Rauhauser: oh
[5/25/2012 12:57:18 AM] Neal Rauhauser: Hey
[6/1/2012 8:54:16 PM] * Missed call from Neal Rauhauser. *
1:16 AM Patrick: Well
1:17 AM How about what I described that Leiderman is doing to me? Thumbs up or thumbs down
from you?
me: as for gmail
Patrick: Go ahead, about Gmail
1:18 AM me: I've got a number of messages from him over last year, most of which I never
responded to, some of which appear to be sent to about ten people and are generally
updates regarding his weiner twitter nonsense
1:19 AM Patrick: I'd be interested in all those
You already sent me a couple
me: then some about occupy, a couple of irritating ones about something he didn't like
about some aspect of Anon that he seems to have thought I had some control over, etc
Patrick: I'd be interested in any and all emails from him
1:28 AM He's trying to destroy my life due to some fantasy he has (or at least professes
to have) about me and Weiner
As if I would care that much about some Congressman from New York
1:21 AM me: there don't seem to be any more here with your name in them other than the two
I sent you
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Patrick: Anything he has sent would be useful
1:22 AM Up to you
Don't know what you really think of him
As for Leiderman
I would like an answer as to your thoughts about his trying to sue me out of a job
1:23 AM me: Pat, I'd really have to see what Leiderman himself has said or done in regards
to suing you out of your job before I comment on that
I haven't asked you to say anything about McCain trying to claim I'm likely to throw a
grenade at the Pentagon
1:25 AM Patrick: Read my blog about Nadia Naffe
me: Neal obviously has a tendency to exaggerate what he's doing and who approves/is
involved, and frankly
1:26 AM Patrick: http://patterico.com/2012/86/12/more-evidence-emerges-of-brett-
me: If I do get an indication that Leiderman is actually going to try to sue you, I'll
talk to him and tell him to reconsider and pass on whatever message from you or do
whatever else is appropriate from my end
Patrick: Oh, Leiderman is the lawyer on the lawsuit against me
Read what I just sent you
1:27 AM me: So there is a lawsuit?
Patrick: Right now it's a civil claim
A "tort claims act" claim
Precursor to a civil suit in regular court
Read the link I just sent
1:28 AM Also, this:
Nadia Naffe's civil claim against me - Nadia Naffe has now filed a civil claim against me
and my boss Steve Cooley - and the lawyer is Jay Leiderman, an online buddy of Neal
Rauhauser's who put out a request on a defense attorney mailing list to investigate
whether any defense attorneys don't like me. Although I have not seen the legal claim
myself, excerpts of Naffe's legal claim have appeared at the web site of self-described
Kimberlin supporter and Rauhauser friend BreitbartUnmasked.com. Before the claim was
filed, Rauhauser and @BreitbartUnmasked encouraged Naffe to file the sorts of claims that
appear in the civil claim.
_11. Naffe has publicly said that she plans to use her lawsuit against me to ask questions in
discovery about the value of my house - a topic in which Rauhauser and @OccupyRebellion
have expressed interest in the past. According to a friend of mine, Naffe has also said
that she plans to ask me and my wife under oath the true identity of conservative blogger
Ace of Spades. Which is not something she ought to care about, since Ace had never said a
word about her (although he has now).
1 You know who cares about Ace's identity? Brett Kimberlin supporter @BreitbartUnmask. He
has written entire posts about Ace's identity. And before I was swatted, someone
threatened me by email. That person threatened one other person the same night: Ace of
Additionally, Brett Kimberlin has used a subpoena in the Seth Allen lawsuit to subpoena
James O'Keefe's stolen emails from Naffe - despite the fact that there has been a final
judgment in that lawsuit.
From this post:
1:29 AM Leiderman is ABSOLUTELY a lawyer in a civil claim against me and my boss
Arranged by Neal
He was snooping around on me, using a defense attorney email list
I heard about it from the defense attorney on one of my cases
Said Leiderman sent out an email asking about me
1:30 AM me: And what is the complaint, or grounds?
Patrick: Read this post:
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1:31 AM Let me know when you're done
1:34 AM me: okay
Patrick: See where I link her depo?
me: So she's trying to sue you for having allegedly provided advice to O'Keefe?
Patrick: It's hundreds of pages, straight from PACER
me: or, rather, filing a bar complaint?
1:35 AM Patrick: Hang on one second
You see that
One, two, three links to her de po
See it?
"The relevance of the laptop is described in her deposition, which I found on PACER as
well, in three parts: one, two, and three. "
1:36 AM me: yes, these are PDFs that will take me a while to download
Patrick: All public documents, you agree?
me: sure
Patrick: I found them on PACER
Well, the idiots who uploaded them didn't redact what they were supposed to redact
For example
They asked her her 55#
It was in there
1:37 AM Within maybe an hour or so of my putting it up, Ron Brynaert triumphantly
announced on Twitter that I had published her 55#
Which of course I had no intention of doing
I IMMEDIATELY took it down
me: Okay, let's stop right there, on Ron Brynaert
1:38 AM Patrick: But now she is suing me for, supposedly, deliberately putting up her 55#
To intimidate her
me: You know that this guy has been harassing me as well?
Patrick: I would believe it
I took it down
Redacted it
me: And thinks I run some sort of major conspiracy involving the media
Patrick: And put it back up
And your pal Leiderman
Now sues me
Claiming I was trying to intimidate her
1:39 AM By publishing her 55# and her "medical records"
Because she was asked in the depo what medications she takes, and she answered
I put up public docs from PACER
And Leiderman and Naffe sue me
There you have it
That is the claim
All arranged by Neal
And Kimberlin
1:40 AM I have the screenshots showing they arranged for Leiderman to be her lawyers
And that they encouraged her to file a complaint with my office
Neal and Brett are using her and Leiderman to 1) sue me and 2) try to get me fired
Nice, ethical, and moral, huh?
You support that?
1:41 AM me: No, I don't
Patrick: That's your pal Leiderman
He's in league with Nealon this
me: So, what would you like me to do on this?
Patrick: It's thuggish
It's anti free speech
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1:42 AM It's everything you are supposedly against
Oppose it, publicly
Speak out
me: Now, if I do so
As in, if I take up your side on this, publicly, in whatever outlets I have remaining to
Patrick: Yes?
1:43 AM You'll confuse the hell out of a lot of people
1:44 AM me: Are you going to follow my example and callout McCain for the several posts
he's written about me being an FBI informant?
The reason I ask is because
1:45 AM I'm more than happy to answer your questions) like I have, things along those
1:46 AM I just don't know what my responsibility should be to you, in terms of conflicts
you're involved in with a lawyer to whom I'm somewhat indebted for having helped to ensure
that various young people who are facing 15 years for DDOSing a corporate website get free
legal representation
1:47 AM Like I said, I don't like Neal, and obviously Brett Kimberlin is deranged
1:48 AM It's just that you're asking me to take your side in a conflict between you and
another party with whom I'm acquainted, Liederman, whereas I just don't think you would be
inclined to take my side in a matter between and another party with whom you're
acquainted, McCain
Do you think that's a reasonable question/point for me to make?
Patrick: It comes down to this:
1:49 AM 1) Have I proven to you that the lawsuit against me is bullshit?
2) Have you proven to me that McCain's allegations about you are bullshit?
I like to think of myself as intellectually honest
You KNOW the shit I have taken from my side for calling them out when I thought it was
1:50 AM Don't deny that
I am not looking for a "deal" here
me: As for 2), you and I haven't spent 45 minutes discussing McCain's allegations against
you, whereas we've just spent 45 minutes discussing Liederman's participation in something
against you
Patrick: If you prove to me that McCain is saying bulls hit about you, I'll call it
me: I don't mean to imply anything in terms of a "deal"
Patrick: If you think I have proven Leiderman's lawsuit is bullshit, I'd like you to call
it bu11shit
Not a deal
1:51 AM Just intellectual honesty
Send me whatever proof you like that McCain is full of it
1'11 look at it
I think I have a track record
I callout bullshit when I see it
me: What I mean is that I would obviously have to think more about this and talk to
Leiberman and see what exactly they're thinking in terms of this before I would go out and
denounce him
Patrick: You can't really plausibly deny that
1:52 AM Whatever
me: Just as you would need me to show you and discuss what MCCain has said about me and
why it's wrong before you'd go out and do anything about that
Again, does that make sense?
Patrick: Nadia wants to use the lawsuit to out Ace of Spades
It's total fucking complete bullshit
1:53 AM me: Please keep in mind that I've forwarded you private e-mails from Neal
concerning you) and I think that's a sign of good faith on my part
1:54 AM That I'm really trying to be intellectually honest and, moreover, functionally
honest, despite the problems I would face to the extent that I get involved in this whole
1:55 AM I guess you left?
Article: "Breakthrough: Fox covers Brett Kimberlin! Patterico SWATting, bloggers
continue pressing the story"
By Michelle Malkin
MAy 30, 2012
12/11/13 MichelleMalkin I Breal4hroogh: Fox cmers Brett Kirrber1inf Patterico SWATting, ~ o     r s continue pressing the story c
Breakthrough: Fox covers Brett Kimberlin/
Patterico SWATting, bloggers continue
pressing the story
By Michelle Malkin· May 30, 201204:06 PM Tweet
Go to Twitchy for details and video Iiule
As r noted last week, Fox News's Ed Barnes had previously covered Brett
Kimberlin's sordid past in 2010.
Brit Hume also weighed in onAaron Walker's hearing yesterday.
Keep shedding light. 'lbe truth about radical, violent,lying, dangerous
felon is getting out there. And we are all better offbecause ofthose who had
the courage to hlow the whistle.
Mattbew Vadum keeps shining light on Kimberlin's left-wing phnanth.l'opic
patrons -this time, it's the Threshold Foundation,
David Hogberg at IBD covered Walker's hearing and the muzzling ofthe
1St Amendment.
William Jacobson blogs about Kimberlin, Walker, and warning signs.
More from Patterico on the online terrorists' abuse ofprocess and
clearing some fog over tbe Walker hearing:
More celebrities SWAT-ted;
meanwhile, anti-Brett Kimberlin
bloggers still under fire
April 8, 2013 02:46 PM by Michelle Malkin
Two big announcements: Book deal
and Twitchy,com deal
December 10, 2013 03:41 PM by Michelle
This post is based on a conple. of first-hand accounts from witnesses
who don't want to be named. I have not had a chance to read
transcripts, listen to court audio, review minute orders, ur see any
other similar material (besides two docket entries shown below)
tbat would definitively establish precisely what happened. But r am
reasonably confident of the following:
Aaron was not a rrestedjol' second degree assault, contrary to
somejalse ,'eportsf/oating OI·ound. The rumor apparently started
because the deputy who arrested him wasjamiliar with the
incident in which Aaron grabbed Kimberlin's iPad when Kimberlin
was trying to tuke a picture ojh;m. AppOl'elltly the deputy believed
thaI he was an'esling Aa1'O"jor Ihat alleged assQldt. BlIt Aaron
was aClually bookedjor violating a peace order.
lIdaes 11OtajJpeC/1' IhatAaron was held in contemplfor his
behavwr ill court today.Aoronmay have irritated thejlldge by
intel'1'Uptmg Kimbe,.Jin and the judge repealedly (a good reason
why you don't ,'epresent YOllrse/fin court; you are too emotionally
iUllolued). BlIt as you'll hear' below, itsolllzds like thejlldge
explicitly disregarded applicable Supreme Court precedent, saying
he didn't car'e abolit it.
As best as I call tell, the aITest occurred becallse Brett Kimberlin
gota warrantfrom ajudge two days ago,jor a criminal charge oj
violation ojapeace order.
I am not an expert on Maryland criminal law, but from talking to
people abnnt this, it appears (stunning as it sounds) that they have a
procedure there in Maryland whereby any citizen can go to a judge
and swear out a complaint against another citizen for a "rime.Hthe
judge makes a finding of probable cause -and it appears that they
mbber-stamp these things, in my opinion - the warrant issues,
v.ithout any prosecutorial oversigbt. Only at some point in the
future does the State's Attorney decide whether the charges are
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October 23, 201309:35 AM by Michelle
micheilemall<in.c0m.2012105l30/breaklhrough-fo*co\ers-brett-l<imberlin-patterico-swatting-b1oggers-continue-pressing-the-story 1/11
12111/13 Michelle Mali<jn I Breal¢hroug h: Fox co\€rs Brett Kimberlin! Patterico SWATting, b10ggers continue pressing the story «
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Maryland. Just another left-wing lunatic state to cross off my
travel list. Left-""oing lunatics do not deserve any of my hard-
eamed money.
.- I . Reply • Siere,
On May 30th, 2012 at 7:33 pm, chapoutier said:
(As an aside, this is my understanding o{what happened when
Aaron was (acing secund degree assault charges several weeks ago.
As hest as r can understand the process, the case was never "fited"
by the State's Attorney. They dismissed it after a video showed
Kimberhn had lied under oath about several aspects of tbe incident.
But the charges bad lingered on fur weeks before they did.)
But neither should the ACLU get criticized if and when
they don't get involved if... you know... no one ever asks
them to.
... So Brett Kimberlin, knowing that Aaron was coming to court to
defend against a civil "peace order,"lay in ambuoh witll a criminal
charge, so that Aaron would De arrested.
Catch 22. And a nice scam i{yon can get judges gullible enough to go
along witb it.
One wonders ifthis is his new strategy: he sues you for your
blogging, and simultaneously obtains a peace order saying you
harassed hi.m. Ifyou blog about him again, he gets ajudgc to rubber
stamp a criminal complaint {or violating tbe peace order.
Now, ifyou don't show up (or the lawsuit, he gets a default
judgment. IfYOll do, you get arrested fur blogging.
Be the first to like this.
Best •
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Where are the fair-weather friends o{freedom o{speech when yon need
Share this: Twitter 90
Provided that they're not selective in terms of whom and what
causes they take the initiative for without being asked.
Categuries: Politics
1 realize I'm delving into some fairly old news here, but did
they not recruit that Scopes guy to defy Tennessee's anti-
Darwin law to make a test case out of it?
Maybe they've changed their approach since then, but
somehow I doubt it.
• Re I) . Share
On May 31st, 2012 at 11:33 pm, bvw said:
I'm slunned that the author doesn't know American
History well enough to know what typically happened in
the Faunding Era courts, and then persisting in valious
forms through the Civil War and post Civil War period as
to how criminal charges were brought against a person.
mchellemal ki n.can'2012105l301breal¢hroug!}-f<*CO\ef's-brett- i<j tTi:lerI il}-patteri co-sv.at:ti ng-b1og9ers-cooti nue-pressi ng-tl'&slor)i 2/11
Article: "Fox News covers Brett Kimberlin and Patterico SWATting story,"
May 30, 2012
12/14/13 FoxNev.s co\€rs Brett Kimberlin and Patterico SWATting story I Twtchy
hary reid
is gud


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Fox News covers Brett Kimberlin and Patterico
SWATting story
Posted at 3:22 pm on May 30,2012 by Twitchy Staff I View Comments
Li 0 Tweet 129
Finally. A national media breakthrough.
Twitchy has covered the chilling story af life-threatening political terrorism at the hands of the Brett
Kimbertin. Conservative bloggers recently rallied together to get the word out. The result? The power of
grassroots and truth to power solidarity made at least one media outlet pay attention.
tv.1tchy.comI2012JOS/30IfoY<-nev.s-co\€rs-bretl-l<imberlin-and-patterico-slMllting-story{ 1/9
Mandy Nagy
Fox NeVvS co\€rs Brett Kimberlin and Patterico SWATting story I Twtchy
The swatting story from @Patterieo featured on FOX News today
video.foxnews.eom/v/166368667900... #BrettKimberlin
Conservative blogger targeted by new 'swatting' tactic
Erick Erickson victim to attack
It begins... Fox News picks up the story... we need to keep them on it!
Fox News FINALLYtalking about the SWATting of convservatives by leftists.
#tcot #teaparty
tWtchy.com/2012/05l301fox- news- co\ers- brett-ki mberl in-ancf.. patterico-swatti ng-story
12/14/13 Fox New.; coW!rs Brett Kimberlin and Patterico SWATting story I Twtchy
Barbara McMahon
#BrettKimberlin RT @lonelycon: Fox News reporting on SWATting of
conservative bloggers. Finally!
Megan Kelley is covering SWATting right now on FOX. Yip, yip
hooray!!! !!!!!! !!
Fox News covering SWATTING, just mentioned Patterico, playing audio of
calls. #BrettKimberlin
We noted earlier today that Brit Hume had weighed in.
And Fox News has covered Brett Kimberlin's past shady activities:
Cheryl Herin
FoxNelM5 cowrs Brett Kimberlin and Patterico SWATting storyl Twtchy
Fox News story from 2 years ago about Kimberlin RT @Guitartom47: Meet
#brettkimberlin foxnews.con1/politics/2010/ ...
Leftist Blogger's Criminal Past Raises Questions About His Real Intent
Even before his release from prison 10 years ago, Brett Kimberlin had learned a lesson
that has served him well: If you publicly accuse a well known political figure of crimes or
misdeeds -- even...
Thank you, Fox News. They're covering the free speech-squelching online terrorists that no one else in
the mainstream media will cover. Any other takers?
50 far, no. Other media outlets are too busy trying to make oh-so-tired hay over "birtherism."
  Anthony De Rosa
CNN, all birthers, all the time. Jeez, give it a rest guys.
Print media? They are too busy continuing to try to convince people that Mormons are nutty nuts.
Gabriel Malar
WaPo front page covers "quiet milestone": Romney is first major-party
Mormon presidential nominee. Hey, did you know?
Quiet milestone. They've been doing nothing but screeching it from their Ivory Tower rooftops. But
tWtchy. com/2012/05/30/fox-n8\M;-cowrs- brett-14mberl in-and-patteri co- swatti ng-story!
12/14/13 Fox News Brett Kimberlin and Patterico SWATting storYI Twtchy
life-threatening political terrorism? Deafening silence.
Some still express hope that others will follow Fox's lead.
.'1 'PoliGrrl
Maybe @cbsnews @abc will do story abt "swatting" ofbloggers since Fox has.
ABC did stories on #BrettKimberlin in 2/03, 3/01. CBS in 2/09.
Time will tell. Kudos, Fox News, for being journalists and reporting on this potentially deadly situation.
We hope others do follow suit.
Related from Mandy Nagy:
Mandy Nagy
Look what #BrettKimberlin's VR blamed on FOX News & US Chamber. Look
similar to what he blamed on @AaronWorthing?
Follow @twitchyteam
o Tweet 129 43
I..... ......... r--
Article: "Sen. Saxby Chambliss Requests DO] Investigate SWATting,"
June 6, 2012
12/11/13 Sen. Sald:JyChambliss Requests DOJ In\estigate SWATting: The Other McCain
• Home
• About Robelt Stacy McCain
• About Smitty
The Other McCain
"One should either write ruthlessly what one believes to be the truth, or else shut
up." - Arthur Koestler
Sen. Saxby Chambliss Requests DO] Investigate
Posted on IJune 6, 201214 Comments
by Smitty
Stacy Caned from the road somewhere to point to an ABC News story by Arlette Saenz that quotes him:
Robert Stacy McCain, a contnbutor to the American Spectator and founder ofThe Other McCain
Blog, wrote about Kimberlin, and shortly after, his wife's place ofemployment received a phone
can from Kimberlin accusing McCain ofharassment. Based on Kimberlin's ability to find his wife's
employer, McCain became concerned Kimberlin also knew the location ofhis home, so the
McCain :fumily relocated to an undisclosed location.
''If! was going to continue doing this story, I couldn't do it from my home," McCain told ABC
News. '1bis kind ofintimidation - it's a threat to protected first amendment expression"
''It's being treated as these are just bloggers playing around on Twitter, but this is serious business.
It's much more serious I think than most people now realize," McCain said.
TIle situation has escalated to the point that Senator Chambliss has taken action:
He has sent a letter to Attorney General Eric Holder urging himto investigate the SWAT-ting cases
to see iffederal laws have been violated.
''I amwriting with concern regarding recent reports that several members ofthe cOIDmrnity of
online political connnentators have been targeted with harassing and frightening actions. Any
potentially criminal action that incites fear, seeks to silence a dissenting opinion, and collaterally
wastes the resources oflaw enforcement should be given close scrutiny at an levels," Chambliss
wrote in the letter.
''Regardless of any potential political differences that may exist, threats and intimidation have no
place in our national political discolll·se. Those who choose to enter into that political discourse
should not have to worry about potential threats to their or their :family's safety," Chambliss
continued. 'While I amcertain that local1aw enforcement is reviewing each ofthese instances, I am
theothermccai n.com'2012/06/06lsen- sIDby. chambl iS5- req uests-doj- in\eSti gate-5'Ncltti ng1 1120
12/11/13 Sen. 8ald:lyChambiiss Requests DOJ In\eStigateSWATting: The Other McCain
asking you to please look into each ofthese cases as well to determine ifany federal laws may have
been violated. Future targets ofSWAT- ting, whether engaged in political speech or not, may not be
so fortunate as to escape physical hann."
Memorandumhas two threads on the topic. A survey oflinked blogs follows:
The Lid
Thank You Saxby Chambliss! There is a glimmer ofhope that he practice ofSWAT-ing taking
place against conservative bloggers may receive some legal attention.
Amel;can We're getting results with the push-back against the left's criminal harassment and intimidation
I Power network!
The Jawa
Well at least this is a start. I know Eric, Nation ofCowards, Holder sux but at least this,
hopefully, will gain more ofour representatives attention as well as the silent MFM. Except for
FNC who at least did a segment on Erick Erickson's SWATting.
U.S. Sen Saxby Chambliss has asked Attorney General Eric Holder to investigate the practice
of"SWAT-ting" conservative political commentators - fuke 911 calls that send police to their
homes, guns bristling.
Senator Saxby Chambliss has sent a letter to AG Eric HoIder demanding action on behalfof
Dan Riehl conservative commentators currently experiencing threats and harassment by an as yet
unidentified source.
The Pirate's I'mcurrently waiting ror my Congress people, Richard BmT (R), Kay Hagan (0) and Brad
Cove Miller (0), but leaving Congress with the redistricting) to fullowon.
Ofcourse, since the DOJ is led bythe corrupt and racist Eric Holder, and the victims ofthe Brett
Urban Kimberlin SWATing are Conservatives and the perpetrators are Liberal political activists .. .I
Grounds would expect about as much help from the DOl as they provided in ensuring that the New Black
Panthers weren't engaged in voter intimidation
Georgia Republican Sen. Saxby Chambliss has written to the Obama administration's
Department ofJustice and asked them to investigate a rash of''SWAT-ting' , attacks that have
recently targeted conservative
The Lonely 1\1<;0, Michelle Malkinjoins in the call fur our representatives inCongress to do something about I
Conservative this menace. I'mnot exactly sure what they can do, but there has to be something.
When I asked Ali Akbar ofthe National Bloggers Club ror help with a website/infrastructure to
Michelle support the blogger targets ofconvicted bomber/online terrorist Brett Kimberlin two weeks ago,
Malkin he didn't hesitate or waver. He stepped up to the plate because he believes in free speech and
new media.
ABC News spoke with both Patterico, and Erick Erickson about their SWATting incidents, and
Nice Deb
reported their stories in the piece.
''It's a phone call that could have gotten me killed," Frey wrote on his blog about the incident.
The Camp
ABC News Online covering this story.
ofthe Saints
On Wednesday, Sen Saxby Chambliss (R-GA) sent a letter to Attorney General Eric Holder
demanding an investigation into the harassment ofconservative bloggers who have been the
theotherrnccain.com'2012/06/06lsen-saJ<by-chambliss-req uests-doj-in\eStigate-sv.etting/ 2120
Sen. SamyChambliss Requests DOJ Inl.eStigate SWATting: The Other McCain
litargets ofa technique known as "swatting."
That's just a quick survey. More SClUtiny is needed. That there is finally sorre government attention, and the
story is finally starting to gain media traction Keep up the struggle fur liberty, people.
For some reason, Stacy McCain rejected Flirtin' With Disaster. Probably that pertains roore to Kimberlin's
Update: linked at Hogewash
a SHARE 11 B ...
Category: The Kimberlin Files
Comments for thl t reaG ar;. no closed.
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To Answer Your Question, Seth ... Because @MikeElk Deserves a Reply
theotherrrccai n.com/2012/06I001sen-sa>dJy-chambl iss- req uests-doj-inl.eStigate-swatti1191 3120
Video Exhibit: Footage from Security Camera
Montgomery County Circuit Court, January 9, 2012
Video Exhibit: Defendant John Patrick Frey Interviewed by Glenn Beck about
SWATtingBrett Kimberlin terrorism
From a YouTube video posted on May 25, 2012
The files are not set to play automatically. Instead one should open the disc using Windows Explorer or
a similar program and select the fIle to view. It will most likely run automatically in Windows Media
The files are named according to their exhibit and thus "Exhibit V" and "Exhibit W," respectively.
Exhibit V is not entirely self-explanatory. As noted in the motion, it is security footage taken from the
Montgomery County (Maryland) Circuit Courthouse, on the ninth floor, outside of courtroom five.
To help the court to interpret what it sees on the video, this is a sample still from the video showing
Walker, Kimberlin and the timestamp at the bottom:
It helps in identification to remember that Mr. Kimberlin is about six inches shorter than Mr. Walker.
If the court encounters any difficulty viewing these files, it should not hesitate to contact Mr. Walker.




v. Case No. PWG 13-3059




Upon consideration of the Defendant Walker’s Motion to Require the Plaintiff to File Verified
Papers In Future Filings, Defendant Hoge’s Motion to Require Verified Pleadings From Plaintiff, and
any opposition thereto, it is this _________ day of _________, 201____, hereby
ORDERED that Defendant Walker’s Motion is GRANTED; and it is further
ORDERED all future pleadings, motions, oppositions, replies and all other papers filed by the
Plaintiff, Brett Kimberlin, with this court in this case of shall be verified, stating that they are true and
accurate under penalty of perjury and appropriately notarized by a notary public.


Honorable , J udge
United States District Court for the District of Maryland
Greenbelt Division

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