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Case 8:13-cv-03059-GJH Document 350 Filed 02/22/16 Page 1 of 2

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Brett Kimberlin,
Plaintif(,
v.

Patrick Frey,
Defendant.

.. :.J UNITEDSTATESDISTRICTCOURT
""~"'IF6R'THEDISTRICT
OFMARYLAND
,
J
SOUTHERNDIVISION
Case No. 13-CV-03059-GJH

MOTION TO SEAL

Comes Now Non-Party William Hoge and seeking leave to file a brief portion of his
Opposition to Plaintiffs Motion to Impose Sanctions and/or Contempt on Third Party
Witness William Roge for Violating Court Ordered Subpoena (ECF No. 319) under seal.
This motion is made pursuant to L.R. 105.11, the Court's Protective Order, Oct. 15, 2015,
ECF No. 312, and the Court's Letter Order, Feb. 11, 201G, ECF No. 344.
The sealed material consists of five paragraphs which partially divulge the contents
of confidential discovery material Plaintiff represents was provided by Mr. Frey and which
Mr. Hoge believes is subject to the Protective Order. Compliance with a protective order is
within the scope contemplated by Doe v. Public Citizen, 749 F.3d. 24G (4th Cir. 2013), and
sealing these five paragraphs only complies with the requirement in Doe to seal no more
than necessary. Mr. Roge is unaware of any other means of protecting the information he
wishes to place before the Court other than sealing these paragraphs.
WHEREFORE,Mr. Hoge asks the Court's leave to file paragraphs five through nine,
inclusive, of his Opposition to Plaintiffs Motion to Impose Sanctions and/or Contempt on

Case 8:13-cv-03059-GJH Document 350 Filed 02/22/16 Page 2 of 2

Third Party Witness William Roge for Violating Court Ordered Subpoena (ECF No. 319)
under seal and for such other relief as the Court may deem just and proper.

Respectfully submitted,

Date: 22 February, 2016

Wi lam John oseph Roge, pro se


20 Ridge Road
Westminster, Maryland 21157
(410) 596-2854
himself@wjjhoge.com

CERTIFICATE OF SERVICE

I certify that on the 22nd day of February, 2016, I served a copy of the foregoing to
Brett Kimberlin via First Class U. S. Mail to 8100 Beech Tree Road, Bethesda, Maryland
20817, and to counsel for Patrick Frey via email by permission.

Case 8:13-cv-03059-GJH Document 350-1 Filed 02/22/16 Page 1 of 1

Brett Kimberlin,
Plaintiff,

UNITEDSTATESDISTRICTCOURT
FORTHE DISTRICTOF MARYLAND
SOUTHERNDIVISION

v.

Case No. 13-CV-03059-GJH

Patrick Frey,
Defendant.

PROPOSED
Upon consideration
thereto, this
file paragraphs

ORDER

of Non-Party William Hoge's Motion to Seal and any opposition

day of

.,2016, Mr Hoge is hereby GRANTEDleave to

5 through 9, inclusive, of his Opposition to Plaintiffs

Motion to Impose

Sanctions and/or Contempt on Third Party Witness William Hoge for Violating Court
Ordered Subpoena (ECF No. 319) under seal.
It is so ORDERED.

George J. Hazel,
United States District Judge

Case 8:13-cv-03059-GJH Document 350-2 Filed 02/22/16 Page 1 of 1

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HogWash!
20 Ridge Road
Westminster, Maryland 21157

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Kimberlin v. Frey
Case No. 13-CV-3059-GJH

NON-PARTY WILLIAM HOGE'S OPPOSITION TO


PLAINTIFF'S MOTION TO IMPOSE SANCTIONS AND/OR
CONTEMPT ON THIRD PARTY WITNESS WILLIAM HOGE
FOR VIOLATING COURT ORDERED SUBPOENA (ECF No.
319)
SEALED

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VERSION

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