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Case No. V 339254
SETH ALLEN Aka ANONYMOUS CYBER STALKER, SOCRATES, PREPOSTERICITY, DAVE FROM QUEENS2,
MOTIO FOR HEARING ON PLAINTIFF S MOnO TO UNSEAL
Plaintiff Brett Kimberlin moves this Court to hold a hearing on Plaintiff s Motion te Unseal John Doe Aaron Worthing's sealed motions.
1. PlaintiffbeJjeves that there is no legal or-justifiable basis for sealing any documents in this case and would like to present argument and evidence to the
Court showing that John Doe Aaron Worthing has identified himself or been
identified using his real name in other court filings in Montgomery County and
irginia, which lists his name, address, phone number and even the fact
that he is Aaron Worthing, the publisher of his Muslim bating blog. These include
a criminal case, two Peace Order cases, a ci il lawsuit, a civil appeal and a request for prosecution.
2. Mr. Worthing engaged in a twitter' ar on February 4 201 with. a third party and
was identified by his real name many times.
3. Many anonymous bloggers have been identified recentl ,and the Courts have repeated] held that people cannot proceed anonymously in COWl cases absent exceptional circumstances. In Liberty Media Holding v. warm O. 11-10802-
WGY (October 31. 2011). the court rejected the John Doe partys' request for anonymity rei ing on well-established case law.
In Ro \I. General Ho pital Corp.• Ci '1 Action No. 11-991-BLSI. 2011 WL 2342737, at" I (Mass. Super. Ct. Ma 19.2011) (Lauriat, J.) attached as Exhtbit ~ the court stated that the proponent bears the burden ofdemonstrating the need to proceed anonymousl , and that relief will be granted onl in exceptional circumstances. The court held that detennining whether alitigant may proceed anonymousl requires balancing the 'litigant s substantial right to privacy' with the 'constitutionally embedded presumption of openness injudiciaJ proceedings," noting that circumstances such as economic harm or mere embarrassment will not suffice to 0 ercome the public's interest in disclosure. ld citations omitted). In West Coast Productions. the D.C. district court stated that th Federal Rilles require that persons filing papers in this Court identify themsel es in their papers. 275 F.RD. at 12. There, the defendants requested to proceed anonymousl so that the plaintiff \ ouId be pre ented from obtaining their contact information and using that information to target them for the alleged infringement at issue. ld at 12-13. The court held that the defendants coilld not proceed anonymous I because their privacy interest in their identifying information was minimal and not significant enough to allow anonymous filing. Id. at 13.
4. There are no exceptional circumstances for allowing Mr. Worthing to proceed in
this case anonymousl . He is a blogger '\ ho by choice regularl insults the
Prophet Mohammed thereby inciting Muslims. He has no more right to remain anon mous than do Ku Klux Klan members who wear their robes and hoods while screaming in ecti es against African Americans. 5. Mr. Worthing has construed this Court s sealing orders as a permanent gag order against Plaintiff e er mentioning his name in any context. He has stated that if Plaintiff mentions his name then Plaintiff i somehm guil terrorists to kill him, which, Mr. of conspiring with
orthing asserts. makes Plaintiff guilty of
violating criminal statutes. He has said on his blog that the mere fact that Plaintiff has filed motions in this Court proves that Plaintiff is trying to get him killed Mr. Worthing has said that an one who donates to Plaintiff' non-profits or talks to Plaintiffabout Mr. Worthing is aiding and abetting Plaintiff Wherefore, Plaintiff requests a hearing to argue his Motion to Unseal Respectfully s Brett Kimberlin
Certificate of Service I certify that J mailed a copy of this motion to Seth Allen and John Doe Aaron Wortbing this 6 th <fa ofFebruary 2012.