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COMES NOW Defendant William M. Schmalfeldt, Sr. to RESPOND to the WJJ Hoges
developed on discovery to show that Almighty Media, Breitbart Unmasked and William
Schmalfeldt acted together to defame him. He has certainly not provided sufficient undisputed
facts to this court and has resorted to outright misleading this court to pretend that he has.
II. PLAINTIFF IS MISLEADING THE COURT WHEN HE SAYS SCHMALFELDT HAS
ADMITTED TO HAVING MANAGERIAL AND EDITORIAL CONTROL OVER
BREITBART UNMASKED AND HAVING AN OWNERSHIP INTEREST IN
ALMIGHTY MEDIA
Plaintiff cites Rule 424(b) in his assertion that by not having answered his request for
admissions that Defendant has, in fact, admitted to these allegations. This is yet another example
of Hoge trying to pull a fast one on this court. Defendant never received a copy of Hoges
Admission of Facts and Genuineness of Documents. Hoge has claimed to have mailed things in
the past that defendant never received. At first, Defendant thought this might be the document
referenced here.
But no, Hoge claims to have signed and mailed his document on March 14, the day after it was
defendants correct Iowa address. Instead of doing the responsible thing and resending the
document to Defendant in Iowa, Hoge waited for the discovery countdown clock to expire so he
could claim that Defendant had admitted to preposterous things to which Defendant would never
admit. Hoge did manage to find the time to mail a letter on April 17 claiming that he would
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henceforth serve court papers meant for Breitbart Unmasked to Defendants attention. But he
couldnt quite see his way clear to mailing another copy of the request for admissions. The
defendant is left to surmise that Hoge did not send the admissions a copy of which was never
provided to the court until now so he could avail himself of the provisions of Rule 424(b) and
categorically false.
As Hoge has resorted to trickery and did not avail himself of the two weeks he had to
resend the request for admissions when he had Defendants actual Iowa address, Schmalfeldt
For the same reasons as outlined above, Defendant believes Hoge either did not mail or
sat on a piece of returned mail containing his request for admissions and did not bother to resend
the document during the two-week window during which Hoge had Defendants correct Iowa
address.
For the record, Defendant denies each and every allegation in this section of the
Plaintiffs motion.
CONCLUSION
WHEREFORE this Defendant, did not receive a copy of Hoges request for admissions;
and
WHEREFORE Defendant believes Hoge either did not mail the above mentioned request
expiration of the discovery period to mail, e-mail, or otherwise send a copy of the request for
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William M. Schmalfeldt, Sr.
Woodspring Suites, Room 224
220 Whitty Drive
Myrtle Beach, SC 29579
843-429-0581
bschmalfeldt@mediacombb.net
AFFIDAVIT
I, William M. Schmalfeldt, Sr., 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.