Case No. V 339254
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plaintiff Brett Kimberlin pro se hereby files this Complaint against Seth
• aka Anonymous Cyber Stalker,
hereinafter called "Socrates;' his most common eyber srnlking name.
1. PlaintiffBrett Kimberlin ('Kimberlin") is a resident ofMontgomery County
2. Defendant Socrates is an anonymous cyber stalker hiding in the shado ofthe
Internet He was identified as Seth Allen after the Court Ordered Google to
disclosehis identity and Venzon complied \Vith a subpoena 1yinghimto an
Internet Protocol address.
3. Kimb rIin is a private citizen who has worked at the same job for at least seven
years as the director ofa non profit public charity called Justice Through Music,
whose missionis to use inspire young people to get engaged with progressi e
social causes.
4. In2005, Justice Through Music co-founded a public charity caIled Velvet
Revolution with another co-founder called The BradBlogto focus on election
protection and accountability issues.
5. On or about 2007, Socrates started making anonymous posts on various national
websites and forums attacking the editor ofThe Brad Blog with anti-Semitic slurs
and other false and defamatory accusations.
6. Socrates' attacks quickly became more personal, callingthe editor a c.<stra.wman,,..
«stupid," "'a fake progressive:' "a scammer" and a «stale act"
7. Socrates' attacks quickly escalated and spread to the moderators at The Brad Blog
and then to other people associated with the editor.
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8. Socrates' became obsessed with the The Brad Blog editor and started digging into
everything about him.
9. Socrates discovered that The Brad Blog co-founded Velvet Revolution with
Justice Through Music, andthat Kimberlin was the director ofJustice Through
10. Socrates then began digging into Kimberlin and disco ered that he had been
arrested and convicted for a crime that occurred 31 years ago.
11. Socrates then began posting on various national Internet sites that The Brad Blog
editor was connected to a convicted felon named BrettKimberlin.
U. From200&through October 2010. Socrates has made scores ofanonymous posts
on numerous nati :ebsites accusingKimberlin. ofmurder, pedophili"'a, and a
host ofo1her unspeakable crimes, with each post mentioning The BradBlog
13. From2008 through 2010, Socrates was banned by many national websites on
which he has posted about Kimberlin because those posts violated the terms of
service by being defamatory, threatening and harassing.
14. Socrates bas been banned from posting on The Brad Blog, Democratic
Underground, Daily Kos, Raw Story and others.
15. On many occasions, after Socmtes was banned for his threatening posts, he re-
registered under a different name or names and posted even more threatening
posts. These names included Prepostericity• and these names and their IP
addresses w e ~ e also banned from the sites.
16. When Socrates was banned from a website, he threatened the editors ofthose
websites \\lith more anonymous emails and posts.
17. Several other people have contacted Kimberlin who have been threatened and
harassed by Socrates to the point that they feel their lives are in danger.
18. Kimberlin has beentold that by other injured parties that they have attempted to
seek protection from law enforcement and through the civil process but have been
unable to learn who Socrates is.
19. 'W"hen ocrates could no longer post harassing attacks against Kimberlin on
legitimate websites, he startedhis own blog inMarch2009 on Google's
BLOGGER site, "', . .blogger.oom.
20. Socrates named his site htlIr//davefromqueens2.blogsootcoml.
21. SinceMarch 2009, Socrates has anonymously posted dozens of harassing,
defamatory, threatening attacks against Kimberlin, the editor ofThe Brad Blog
and other editors who have banned or exposed him..
22. Socrates has falsely accused Kimberlin ofmurder, pedophilia, financial scamming,
hoaxing, wild conspiracies, con artistry, and being a rip off
23. On September 10,2010, Socrates titled a post"... Brett Kimberlin Can Run,
But... Can't Hide," in which he concluded: "To Brett Kimberlin, the world knows
you are the ultimate scumbag. We knowyou're a liar, conman, murderer ofCarl
Delong's spirit and most probably involved with Julia Scypher's and
basically the personification of scum...
24. Socrates has attacked Kimberlin's personal cha:racterand business practices and
posted hundreds ofinsults, false statements and negative comments on numerous
websites and Internet forums in order to harm and interfere with Kimberlin's
business and cause him suffering, opprobrium and humiliation.
25. Socrates has maliciously engaged in a three-year campaign against Kimberlin of
intentional harassment, eyber bullying, Internet defamation, online harassment and
cyberterrorismby accusing him of illegal, immoral and unethical conduct in order
to harmKimberlin's personal and professlonal reputation.
26. Socrates has engaged in Internet hOeI by publishing his defiunatory statements
with the intent to cause Kimberlin harmto his personal and business reputation.
27. The harassing and defamatory posts by Socrates against Kimberlin have been
reposted by Internet search engines and have been viewed by others.
28. Kimberlin has received threats to his life because ofthe defamatory and harassing
posts by Socrates.
29. Kimberlin has had to respond to repeated questions by business associates and
o1hers about the false statements made by Socrates.
30. Socrates has contacted at least one oftbe funders ofKimberlin's business using
the name STruth40 to intimidate her and pressure her to stop funding the business.
CO 1
Defamation and Libel
31. Paragraphs I-29 above are hereby adopted and incorporated into all counts of this
32. Socrates has encoa.e.oed in a three-year campaign of defamation against Kimberlin
through dozens offalse Internet postings.
33. The false statements made by Socrates were published on the World Wide Web,
\¥hich constitutes libeL
34. Socrates' posting and actions were malicious and intentional and done with an
intent to cause harm.
Harassment and lolation of Privacy
35. Socrates has in1entionally harassed, annoyed, stalked, 1hreatened, and attacked
Kimberlin withscores of false, insulting, annoying, and threatening Internet
postings over a tbrec>year period.
36. The posts made by Socrates constituted malicious harassment of Kimbertin and
violated his privacy, and caused unknownparties to make threats against
Interferenee with Business
37. Socrates repeatedly, over athree-year period, made Internet postings in order to
harmKimberlin's business relationships, to stop people from supporting his
business enterprise, and to create doubts about his business in order to hann
WHEREFORE, Kimberlin prays that the Court grant the following relief:
a. Find that Socrates has defamed and hOOled Kimberlin.
b. Find that Socrates has harassed and cyber stalked Kimberlin, and violated his
c. Find that Socrates has interfered with Kimberlin's business and business
d. Issue a Cease and Desist Order a.:,<7Clinst Socrates prolnbiting himfrom 'writing
about, contacting, contacting other people about;. or having anything to do \-vith
e. Issue an Order to remove all references to Kimberlin on Socrates' Google
Blogger page.
f. Enterjudgment infavor of Kimberlin in the amount of 1,250,000 in
compensatory damages.
g. Enterjudgment in favor on Kimberlin in the amount of $1,000,000 in punitive
a Such other and further relief as the Court deems appropriate.
Respectfully submi