IN THE CIRCUIT COURT OF MONTGOMERY COUNTY AARON WALKER, Plaintiff, v. No 398855-V BRETT KIMBERLIN and TETYANA KIMBERLIN, Defendants. DEFENDANTS’ REPLY TO PLAINTIFF'S OPPOSITON TO SECOND MOTION FOR SUMMARY JUDGMENT AND MOTION TO STRIKE IT Defendants Brett and Tetyana Kimberlin reply to Plaintiff's Response to their Second Motion for Summary Judgment, and to Plaintiff's Motion to Strike same. 1. Plaintiff complains that Defendants did not send the pleadings to him via certified mail with a green card. While this is absolutely correct, Defendants did comply with this Court's order by sending the pleadings via Priority Mail with a tracking number that can be verified on the Postal Service's online tracking service. ‘The whole reason this Court ordered proof of service was in order to dispense with Plaintiff's repeated false accusations that Defendants had not served him. Now the Postal Service allows mail to be tracked via Priority Mail, and Plaintiff knows this because he attached the Priority Envelope with the “USPS TRACKING NUMBER” right on the front of the envelope and he also attached the online tracking proof. Finally, he responded to the pleadings. 2. Inshort, PI tiff is once again wasting this Court's time and harassing Defendants over a non-issue that he created out of whole cloth.3. Plaintiff makes the bald assertion that “pain and suffering” damages are allowed for torts that do not result in personal injury, and he cites Larimore v. American Ins, 69 Md. App 631 (Md. App. 1987). Clearly, Plaintiff did not read the case since it involved an automobile accident. 4. Plaintiff also fails to address Defendants’ argument that punitive damages cannot be part of compensatory damages as Plaintiff has done in his Complaint. 5. Plaintiff argues that the implied malice from lack of probable cause meets the actual malice standard required for punitive damages. This is a non sequitur that is not supported by any case law. 6. Moreover, Plaintiff argues that he is not defamation proof while ignoring the fact that he is one of the most hated, depraved and repulsive people on the planet because of his multi-year activities as the publisher of the vile “Everyone Draw Mohammed” blog that featured over 800 insulting and pornographic depictions of the Prophet Mohammed. That blog was banned by Facebook and Google because of Plaintiffs hate mongering of a religion comprising billions of people, And according to intelligence sources, Plaintiffs blog was found in Osama bin Laden’s compound in. Pakistan where it was used to inspire terrorists to kill Americans on the battlefield in Afghanistan. Clearly, no jury is going to believe that Plaintiff suffered any damages to his horrible reputation any more than it would find that Charles Manson's reputation was sullied for some defamatory statement. 7. Plaintiff's argument that his claim for injunctive relief gives this Court jurisdiction is without merit. This Court specifically dismissed that claim, and limited this case to only one claim alleging malicious prosecution.Wherefore, for all the above reasons, this Court must reject Plaintiffs ‘opposition and motion to strike. Brett KimberM ae Vo = Certificate of Service YA" | certify that I served a copy of this motion on Plaintiff via certified mail this 8th" day of july, 2016