MARYLAND:

IN THE CIRCUIT COURT OF MONTGOMERY COUNTY

BRETT KIMBERLIN,
Plaintiff,
v.

Case No. 339254V

SETH ALLEN,
Defendant

MOTION TO UNSEAL CERTAIN DOCUMENTS

NOW COMES an interested party, Aaron J. Walker, Esq., and files this Motion to Unseal
Certain Documents. He states the following:
1.

Mr. Walker1 has previously appeared as an interested party in this case in order to

prevent Mr. Kimberlin from gratuitously placing certain private information into the public
record, such as the fact that Mr. Walker wrote on the Internet under the pseudonym Aaron
Worthing. Mr. Walker was identified in docket as John Doe (see, e.g., Dkt. No. 122) and
Aaron Worthing. This Court granted Mr. Walker leave to file under those pseudonyms on
January 9, 2012 (see Dkt. No. 125) and sealed several documents upon Mr. Walkers motion.
2.

Specifically, this Court agreed to seal the following:

a.

Plaintiffs Motion to Withdraw as Moot Plaintiffs Motion to Compel and

Subpoenas to Comcast and Google Seeking Identity of John Doe (Dkt. No 114)sealed at Dkt.
No. 123.

Mr. Walker refers to himself throughout this filing in the third person for stylistic reasons and
in order to de-personalize this matter.

b.

Plaintiffs Motion to Unseal Pleadings Related to John Doe (Dkt. No.

127)sealed at Dkt. No. 133.

c.

Plaintiffs Response to John Doe Aaron Worthings Emergency Request

To Seal Plaintiffs Motion (Dkt. No. 130).

d.

John Does Emergency Motion to Place Plaintiffs Plaintiffs Response

to John Doe Aaron Worthings Emergency Request to Seal Plaintiffs Motion Under Seal and to
Dismiss the Underlying Injunction (Dkt. No. 131).
3.

The primary reason for sealing the documents has evaporated.

After Mr.

Kimberlin constantly put this improper information in filing after filing in case after case, Mr.
Walker publicly acknowledged he was the anonymous writer known as Aaron Worthing.
4.

Furthermore, these documents might constitute evidence in another case. Mr.

Walker presently has a case in Montgomery County Circuit Court entitled Walker v. Kimberlin,
et. al., No. 398855-V, a case about malicious prosecution specially assigned to Judge Mason.
Mr. Walker is the plaintiff, and Mr. Kimberlin is a defendant.
5.

In Walker v. Kimberlin, et. al., Mr. Walker accuses Mr. Kimberlin of filing a false

criminal charge for harassment in revenge against Mr. Walker for his representation of Mr.
Kimberlins wife and Mr. Allen. Mr. Walker is a Virginia and Washington, D.C., attorney who
was at one time Mrs. Kimberlins and Mr. Allens attorney, although his representation was
confined to Virginia,2 including support for local counsel.
6.

Walker v. Kimberlin, et. al. is presently in discovery and is set for trial in October.

Mr. Walker believes that information in the above-captioned case is valuable and admissible
evidence in Walker v. Kimberlin, et. al.

Mr. Walker is not admitted to practice in Maryland.

2

7.

Therefore, Mr. Walker asks for this Court to unseal all documents in this case as

appropriate in order to place it back into the public record and to allow for inspection of the
complete case file. Since Mr. Walker is the one who asked for these documents to be sealed in
the first place, he believes it is appropriate to grant this motion.

WHEREFORE, based on the foregoing, Mr. Walker respectfully requests that this Court unseal
all records in the above-captioned case or to take any other steps appropriate to place those
documents into public record and to make its file available for inspection and duplication, as well
as any other relief that is just and equitable.

Wednesday, July 20, 2016

Respectfully submitted,

Aaron J. Walker, Esq.

Va Bar# 48882
P.O. Box 3075
Manassas, Virginia 20108
AaronJW72@gmail.com
(703) 216-0455
(no fax)

VERIFICATION
I, Aaron Walker, solemnly affirm under the penalties of perjury that the contents of the
foregoing paper are true to the best of my knowledge, information, and belief.

Dated:

CERTIFICATE OF SERVICE
I certify that on the
day of
, 2016, I served copies of this
document on Brett and Tetyana Kimberlin at 8100 Beech Tree Road, Bethesda, Maryland 20817
(they have both given this address as the appropriate mailing address in Walker v. Kimberlin, et.
al.) and Seth Allen at 614 Washington St. 1, South Easton, Massachusetts 02375.