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v. No. PWG 13 3059
Now comes Plaintiff Brett Kimberlin and responds in opposition to Defendant
Aaron Walker's Motion to Exceed Page Limit and his Motion to Strike. In support of
this motion, Plaintiff states (1) the request violates Court rules, (2) Defendant
Walker is not licensed to practice law in the State of Maryland, (3) DeFendant
Walker does not represent any oFthe other DeFendants for whom he asks relieF, and
(4) DeFendant Walker has filed the documents For the improper purpose of
introducing prejudicial and false information into the record so he and others can
post it on the Internet and raise more funds from their readers.
The Pleadings Violate The Court's Rules
1. DeFendant Walker admits that his Response violates Local Rule 105.3, which
limits a Reply to 25 pages. Yet he asks to violate that Rule in essence to
respond to Plaintiffs Responses to other Defendants' Motions to Dismiss.
2. Defendant Walker requests to exceed the Reply page limit by seven pages (32
pages total in the Reply). But in reality, he is asking to exceed the limit by
vastly more pages because he filed a separate Motion to Strike which is
another 25 pages, and which just continues on where his Reply left off. In
Case 8:l3-cv-03059-PWG Document 6l Filed 02/ll/l4 Page l of 6

fact, the relief in that Motion to Strike is to reject Plaintiffs Response and
other pleadings not only for himself but also for other Defendants. Clearly,
this Court should deny Defendant's Walker's blatant attempt to circumvent
the rules.
Defendant Walker Is Not Licensed To Practice In Maryland Courts
3. Defendant Walker submits his pleadings at "Aaron Walker Esq. Va Bar#
48882." However, Defendant Walker is not licensed to practice law in
4. Rule 101 (l)(a) states the following:
1. Who MayAppear as Counsel; Who MayAppear Without Counsel
a) Generally. Except as otherwise provided in this Rule and in L.R.112.3 and
28 U.S.C.~ 515, only members of the Bar of this Court may appear as
counsel in civil cases. Individuals who are parties in civil cases may only
represent themselves." (emphasis added).
5. Defendant Walker has not requested to appear pro hac vice and has not
sought local counsel to represent him as required by Local Rule 101 (l)(b)(i).
6. Defendant Walker is using his legal status to file his pleadings without
complying with the Local Rules. Clearly, this Court should only allow
Defendant Walker to proceed pro se, unless he seeks permission to file pro
hac vice and finds local counsel to represent him in that capacity.
7. Ifhe files to proceed pro hac vice, he will have to prove that he is a Member
of the Virginia Bar in good standing, which could be difficult in light of his
unemployed and unemployable status after being terminated from his last
legal position two years ago for anonymously publishing a blog dedicated to
insulting the Prophet Mohammed.
Case 8:l3-cv-03059-PWG Document 6l Filed 02/ll/l4 Page 2 of 6

8. Defendant Walker can represent himself pro se, but he cannot do so as an
attorney unlicensed in the State of Maryland.
Defendant Walker Cannot Represent The Other Defendants
9. Throughout Defendant Walker's latest pleadings, he asks for relief for his co-
defendants. In the Motion to Strike on the first and last pages, he asks the
Court to strike Plaintiffs Responses not only to his Motion to Dismiss, but
also to Defendant DBCapitol Strategies and to The Franklin Center, as well as
a Declaration related to 0 BCapitol Strategies. And throughout that pleading,
he objects to statements and exhibits filed in Plaintiffs Responses to other
10. In Defendant Walker's Reply, he repeatedly asks the Court to dismiss the
complaint for "all parties." Reply at 1 and 31.
11. As noted above, Defendant Walker cannot represent others in Maryland
because he is not licensed to practice in Maryland courts. Moreover, many of
the other Defendants are represented by their own lawyers in this case and
have not given Defendant Walker permission to represent them.
Defendant Walkers Pleadings Are Done For An Improper Purpose
12. Defendant Walker has spent the past 30 months stalking, harassing,
defaming, suing and harming Plaintiffin every possible way. His latest
pleadings are more of the same, and show just why Plaintiff brought this
Complaint Defendant Walker is a bully in every sense of the word. He
admittedly suffers multiple psychiatric handicaps and has let his obsessive
Case 8:l3-cv-03059-PWG Document 6l Filed 02/ll/l4 Page 3 of 6
personality latch on to Plaintiff in the same way other compulsive stalkers
dangerously fixate on targets.
13. Defendant Walker acts as though Plaintiff must wear a Scarlett Letter on his
forehead for life and must be attacked mercilessly until he is imprisoned,
ostracized or killed. That Scarlett Letter is dated 1979 and before in the form
of a conviction and prison sentence. Defendant Walker believes it is his call
in life to protect the world from Plaintiff and to do so at all cost According to
Defendant Walker, Plaintiff has no right to live his life without harassment
and fear from reprisals. Defendant Walker has spent the past two plus years
depriving Plaintiff of humanity with his constant sick and twisted false
narratives. His perverted justifications for this daily bullying of Plaintiff are
similar to those used by others to bully vulnerable students at school for
making mistakes, to torture a gay man in Wyoming and leave him tied to a
fence post to die, to hang blacks in the South, and to burn witches in New
England. Defendant Walker believes in whipping up the mob with false
narratives in the hope that the mob will constantly pillory Plaintiff, turn
vigilante and destroy Plaintiff. Therefore, he increasingly escalates with
more and more vile allegations and then publishes articles with comments
about his guns and how he will use them to protect himself and others from
14. Defendant Walker has used his latest pleadings to make more defamatory
allegations against Plaintiff in order to whip up his readers to engage in
vigilante action against Plaintiff. He filed these pleadings so he could publish
Case 8:l3-cv-03059-PWG Document 6l Filed 02/ll/l4 Page 4 of 6
yet more articles on his blog accusing Plaintiff of more imagined crimes. See
Exhibit A, entitled, "Convicted Document-Forger Brett Kimberlin's Fraud On
The Court," dated February 6, 2014. And of course, Defendant Walker asks
his readers to "get out the popcorn" and to send him money so he can rid the
world of Plaintiff once and for all. ld.
15. Every legal pleading that Defendant Walker has filed against Plaintiff over
the past 26 months has been denied, dismissed, nolle prossed, or ignored by
a dozen judges, prosecutors and other law enforcement officials. Defendant
Walker in virtually every filing has bullied Plaintiff for 3S year-old crimes.
He has filed literally thousands of pages of pleadings and exhibits in his sick
attempt to persuade one person in an official capacity to accept his warped
view of reality. And he has failed in every instance. Plaintiffthoughtthat
Defendant Walker would get the message 16 months ago when Judge Motz
and Judge Potter excoriated him for filing malicious pleadings against
Plaintiff. As Judge Potter said: "The Court finds that the complaint is not well
grounded in fact, it's not warranted by existing law, and it's imposed for an
improper purpose ...."
Wherefore, for all the above reasons, Plaintiff moves this Court to deny Defendant
Walker's Motion to Exceed Page Limit, along with his underlying Reply and Motion
to Strike.
Case 8:l3-cv-03059-PWG Document 6l Filed 02/ll/l4 Page 5 of 6
Brett Kim
8100 Beech ree Rd
Bethesda, MD20817
(301) 320 5921
Certificate of Service
I certify that I mailed a copy of this motion to Defendants Walker, McCain
and Hoge and to Attorney James Skyles, and emailed a copy to Defendant
Stranahan, Michael Smith, Mark Bailen, Ron Coleman this 11
day of
February, 2014.
Case 8:l3-cv-03059-PWG Document 6l Filed 02/ll/l4 Page 6 of 6
.J. -' >
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Allergic to Bull: Convicted DocUI1lent.rorger Brett Kimberlin's Fraud on the Court
.' ,
Followthis linkto my BLOCKBUSTERSTORYof how Brett Kimberlin, a convicted terrorist and
peljurer, attempted to frame me for a crime, and then got me arrested for blogging when I exposed
that misconduct to the world. That sounds like an incredible claim, but I provide primary documents
and video evidence proving that he did this. Andif you are moved by this story to provide a little help
to myself and other victims of Mr. Kimberlin's intimidation, such as Robert StacyMcCain,you can
donate at the PaypaJ buttons on the right. And I thank everyone who has done so, and will do so.
Convicted Document-Forger Brett Kimberlin's Fraud
on the Court
This is the latest post in what I half-jokingly call The Kimberlin Saga@. If you are
new to the story, that's okay! Not everyone reads my blog. The short version is that
Kimberlin has been harassing mefor over a year, his worst conduct being when he
attempted to frame me for a crime. I recognize that this might sound like an
incredible claim, but I provide video and documentary evidence of that fact; in
other words, you don't have to believe my word. You only have to believeyour eyes.
So, ifyou are new to the story, go to thispage and you 71 be able to catch up on what
has been happening.
Well, dear reader, in the last post I said that I wasn't going to blog until I got a little
more under my belt in terms of the RICO case, and so we have some catching up to
do. This will be the first in a series where I present to you various filings that have
occurred in this case, in this case by Michelle Malkin and the non-party Twitchy.
And 1 can almost hear you, dear reader. "Wait a minute," you might say, "I thought
T\\itchy was being sued, too? Since when are they a 'non-party.'" Well, I will let the
http://allergic2bu1l.blogspolcoml2014102/comicted-document.forger- bre lthtml
Case 8:l3-cv-03059-PWG Document 6l-l Filed 02/ll/l4 Page l of 2
Allergic to Bull: Com"icted Document-lbrgcr Brett Kimberlin's rnud on the Court
able Mr. Smith explain it to you, below the fold in his
memorandum in support of their motion to dismiss:
Case 8:l3-cv-03059-PWG Document 6l-l Filed 02/ll/l4 Page 2 of 2

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