IN THE CIRCUIT COURT OF CARROLL COUNTY, MARYLAND WILLIAM HOGE, Plaintiff, v No. C-16-70789 BRETT KIMBERLIN, et al,, Defendants MOTION TO FIND ns WILLIAM HOGE AVEXATIOUS LITIGANT Now come Defendants Brett and Tetyana Kimberlin and move this Court, following a hearing, to find William Hoge a vexatious litigant. 1. Plaintiff Hoge is a mentally disturbed individual who is obsessed with Defendants and those associated with Defendants. Over the past three years, he has filed close to 400 legal actions against Defendants and those associated with them in three different counties in Maryland, including Carroll, Howard and Montgomery. Every single one of those legal actions was dismissed, nolle prossed, or denied except one Peace Order that he procured through fraud even though the court did not have jurisdiction to issue that Peace Order. 2. Plaintiff Hoge forum shops in various courts to harass his victims. When one court denies him, he files in another court. 3. Plaintiff Hoge is a sexual predator who has stalked and harassed Defendants Brett and Tetyana Kimberlin and Defendants’ teenage daughter for years. Plaintiff Hoge has a personal blog where he has posted sick and twisted blog articles about Defendants, and has a “Team Kimberlin Post of The Day” every day for the past three years. i “ai4, Defendants have repeatedly asked Plaintiff to leave them alone but he will not. He isa classic, obsessed stalker who admitted on the stand that he has investigated every single detail of Defendants’ lives. He is a cloned copy of the twisted and depraved sadist in the movie, Silence of the Lambs. 5. Maryland courts have the statutory authority to declare a litigant who has abused the legal system as vexatious. Riffin v. Baltimore County, 985 A.2d 612 (Md. 2010). In Riffin, the litigant had filed more than 100 meritless legal actions. 6. Riffin requires that a judge provide due process prior to issuing a vexatious litigant order, including making a record stating the reasons for the order with a list of the frivolous litigation, 7. Defendants urge this Court to hold a due process hearing where Defendants will provide the Court with a list of close to 400 legal actions filed by Plaintiff over the past three years. Defendants then urge this Court to issue an order finding that Plaintiff is a vexatious litigant, along with the necessary restrictions on his ability to file additional pleadings. Wherefore, Defendants move this Court to hold a hearing and then find that Plaintiff Hoge is a vexatious litigant. Respe i Brett fn na Kimbgplin Certificate of Service I certify that I mailed a copy of this motion on Plaintiff this 9 day of May, 2016. Brett lin