Case 8:13-cv-03059-GJH Document 388 Filed 10/07/16 Page 1 of 5

UNITED STATES DISTRICT COURT

DISTRICT OF MARYLAND
BRETT KIMBERLIN
Plaintiff

Civil Action No.: 8:13-CV-03059

(GJH)

vs.
PATRICK FREY
Defendant

JOINT STATUS REPORT FOR OCTOBER 7, 2016

The parties inform the Court as follows pursuant to the direction of ECF 387 (Paperless
Order Re: Joint Status Report) regarding certain items in this case.
1. Discovery is complete and there exists no immediate discovery dispute other than that
which is currently under interlocutory review by the United States Circuit Court for
the Fourth Circuit (4th Circuit) regarding confidentiality designations in Plaintiffs
request for a writ of mandamus, Case Number 16-1670.
2. There have been no recent settlement negotiations; Plaintiff has no current demand
and Defendant has no offer.
3. Plaintiff Brett Kimberlin would prefer to defer dispositive motions until after the 4th
Circuit has ruled on his request for mandamus relief. The case manager at the 4t

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Circuit has informed him that the matter is before a judicial panel, and that

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mandamus petitions typically require 60-90 days for review. Defendant Patrick Frey
is neutral as to the precise timing of the filing of dispositive motions, other than to
prefer to maintain the previously agreed order of Plaintiff filing his dispositive motion
first and then Defendant replying with a response and a cross-motion for dispositive
relief.

Respectfully submitted,

____________________________
T. Bruce Godfrey #24596
Jezic & Moyse LLC
2730 University Blvd. West, #604
Silver Spring, MD 20902
240-292-7200
facsimile: (888) 241-3135
godfrey@jezicfirm.com
Attorney for Defendant
/s/
____________________________
Brett Kimberlin, pro se
8100 Beech Tree Road
Bethesda, MD 20817
justicejtmp@comcast.net
Plaintiff pro se
CERTIFICATE OF SERVICE
The undersigned certifies that he has provided a copy of this document in electronic
format by electronic transmission to Brett Kimberlin this day October 7, 2016. Mr.
Kimberlin has previously agreed to accept service of court filings by electronic transmission.
/s/
_______________________________
T. Bruce Godfrey

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Case 8:13-cv-03059-GJH Document 388 Filed 10/07/16 Page 5 of 5

CERTIFICATE OF ELECTRONIC FILING AND REGARDING WAIVER OF

MAILINGS
I, T. Bruce Godfrey, hereby certify that I have filed a copy of this document with the
United States District Court electronically and by so doing have provided compliant notice to
those parties who are registered with ECF through counsel as of this filing consistently with
Local Rule 102.1(c) on April 1, 2016. All parties, including pro se parties, have agreed to accept
service by electronic mail only and an electronic copy has been distributed to all parties.
/s/
_________________________________
T. Bruce Godfrey #24596