IN THE CIRCUIT COURT OF CARROLL COUNTY, MARYLAND WILLIAM HOGE, Plaintiff, v. No. C-16-70789 BRETT KIMBERLIN, et al., Defendants DEFENDANTS BRETT AND TETYANA KIMBERLIN'S RESPONSE TO PLAINTIFF'S MOTION TO STRIKE Now come Defendants Brett and Tetyana Kimberlin and respond in opposition to Plaintiffs latest motion to strike. 1. Here we go again with another abusive motion from serial harasser William Hoge. The docket sheet now has over 65 filings, most initiated by Plaintiff. 2, Plaintiff thrives on making mountains out of non-issues, and obsesses over this or that perceived peccadillo supposedly violating his interpretation of this or that rule. He is truly a vexatious litigant. 3. Incredibly, now Plaintiff has argued that pro se Kimberlin Defendants have to vacate thelr default when there has been no finding of default. He argues that Defendants have not followed the proper procedure to vacate a default that has never occurred. 4. Plaintiffhas argued that in his opinion the Kimberlins’ answer is insufficient and then makes false allegations against Brett Kimberlin. As noted previously, the Kimberlins are pro se litigants who are fighting another one of the nearly 400 legal filings Plaintiff has made against them and their associates the past three years.They are not going to waste time pretending that Plaintiff has any chance in prevailing in this case when he has failed to do so nearly 400 times before. 5. Plaintiff has argued that Defendants’ answer is untimely. Again Defendants are pro se litigants who have been vexatiously harassed by Plaintiff for years and are exhausted by his endless stream of harassing filings. They are not going to jump every time Plaintiff cracks his whip, or expend more time responding to meritless filings. 6. Inthe old days, people would react to someone like Plaintiff by labeling him “nuttier than a fruitcake,” and would then pay him no mind while he mumbled to himself. Unfortunately, today Plaintiff knows that he can abuse people by maliciously filing harassing litigation against them, and the courts, in an effort to provide legal access even to crazy people, will tolerate their lunacy. 7. But this Court must no longer tolerate Plaintiff. He is a man who filed literally hundreds of criminal charges against Defendants and their associates, all of which were dismissed /nolle prossed, yet he has the unmitigated gall to file malicious prosecutions claims in this case against the Kimberlin Defendants because they filed a Grace's Law charge against Plaintiff for online cyber stalking their minor daughter, which Judge Audrey Creighton called “child abuse” and warned Plaintiff that he could “end up behind bars" if he continued to harass the minor, Wherefore, Plaintiff's motion should be denied and he should be found to bea vexatious litigant.Respectfully submitted, Brett KimBertin ‘Tetyana oe in Certificate of Service Icertify that I mailed a copy of this motion on Plaintiff this 9 day of July, 2016. Bret berlin pet / i