IN THE CIRCUIT COURT OF CARROLL COUNTY WILLIAM HOGE Plaintiff, v No. 0616070789 BRETT KIMBERLIN and TETYANA KIMBERLIN, Defendants. ‘THE KIMBERLIN DEFENDANTS’ OPPOSITION TO PLAINTIFF'S MISINFORMED MOTION IN LIMINE Now comes Defendants Brett and Tetyana Kimberlin and respond in opposition to Plaintiff's misinformed Motion in Limine. Plaintiff requests have already been raised and denied in his Motion for Summary Judgment and therefore he cannot re- raise them under a Motion in Limine. Moreover, his statements that Defendants have admitted elements of the torts simply because they filed a Motion for Summary Judgment is utterly devoid of merit. Clearly, Plaintiff has no clue what he is talking about with regard to his Motion in Limine. 1. This Court has already denied Hoge’s Motion for Summary Judgment in which he argued that Defendants could not argue certain elements of the torts, doy ide 2. This Court has already ruled with regard to Hoge’s complaints about the “three inch stack” of discovery provided to Hoge by Defendants that it was sufficient £9 put him on notice of the evidence they intended to use in this case. At that time, the Court rejected Hoge’s complaint that the discovery should be meticulously tagged and identified since that same discovery had been used in multiple trials involving Hoge. Defendants argued that Hoge was well aware of the contents of the [34001discovery and that the Defendants were pro se litigants who must, under well established case law, be granted latitude in this case. 3. Hoge is misleading the Court with regard to the scheduling order. Defendants have provided Hoge notice of all the evidence they will use at trial. See attached Notice of Transmittal sent to Hoge on August 1, 2017. 4. Defendant Brett Kimberlin has not “admitted” any of the elements of defamation and Hoge clearly does not correctly articulate the four elements of defamation in Maryland. 5. Defendants have not “admitted” any of the elements of malicious prosecution and they insist that Hoge prove all four elements of that tort, 6. Virtually every filing Hoge has made in this case has been to exclude evidence by Defendants that will show that he has harassed, stalked and frightened Defendants with his relentless obsession of them and their children. As Defendants will show at trial, Hoge is a real life persona straight out of a horror movie, a man who insanely follows every aspect of Defendants’ lives, and their children. A man who feeds off of the word “Kimberlin” like a heroin addict feeds off of drugs. A man who salivates over sex and sees everything the Kimberlins do through the lens of perversion. A man who rubs his hands together in glee with every bone this Court throws him a bone because it allows him to continue his sick, depraved and gravely immoral campaign against the Defendants. Wherefore, this Court should deny Hoge’s Motion in Limine and allthis case to proceed to trial on the merits,Respectfully subrhjtted, Brett Kimberlin Bethesda, MD 20817 (301) 320 5921 justicejtmp@comeast.n CERTIFICATE OF SERVICE I certify that I mailed this motion to Plaintiff this August 12, 2017. Bret ‘berlin / /IN THE CIRCUIT COURT OF CARROLL COUNTY, MARYLAND WILLIAM HOGE, Plaintiff, v. No. C-16-70789 BRETT KIMBERLIN, et al., Defendants NOTICE OF TRANSMITTAL OF TRIAL EXHIBITS Pursuant to the Trial Court’s Scheduling Order, please be advised that my list of exhibits for the trial in this case will be all those documents sent to you as discovery In this case, those documents attached to the Summary Judgment filed by me and my wife in this case, the video of the song “Whisper” which you provided to the Court in Montgomery County, the transcript of the hearing before judge Audrey Creighton which you already have, and the attached transcripts of the May 13, 2013 hearing in Hoge v Kimberlin from the Carroll County Circuit Court before Judge Stansfield. Please also accept this last document as part of my continuing response to your discovery request since | only received it from the Court Reporter today in the mail. August 1, 2017.