Case 8:15-cv-00723-GJH Document 98 Filed 12/14/15 Page 1 of 1

December 13, 2015

Honorable Judge George ]. Hazel

6500 Cherrywood Lane
Greenbelt, MD 20770

Re: Kimberlin v. Hunton and Williams, et al __

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No. 8:15-cv-00723 GJH
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ENTERED
RECEIVED

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CLERK U,S, DISTRICT COURT

DISTRICT OF MARYLAND

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A GREENBELT

Dear Judge Hazel:

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DEC I 4 2015

Important Information re Discovery

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Please be advised that Ihave received approximately 3000 pages of discoveryln my

other case before you, Kimberlin v. Frey, no 13-3059. That discovery was produced
pursuant to a protective order and I have asked you to modify that order so I can
use the discovery as necessary.
The reason this is relevant to the instant case is that many of the Defendants have
asked you to dismiss this case based on statute of limitations, failure to state a claim,
and lack of specificity. I in turn have requested discovery from the Defendants prior
to a ruling on those motions.
I can now state for the record that there are numerous documents within the 3000
my claims in the instant case, including, as I have alleged,
documents tying the instant Defendants to the original Frey defendants.

Frey pages that support

This underscores the profound need for discovery in the instant case prior to a
ruling a ruling on the Motions to Dismiss.

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Brett I
In
8100 B ch Tree Road
Bethesda. MD 20817
(301) 320 5921
justice jtmp@comcast.net

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