Case 8:13-cv-03059-GJH Document 251 Filed 01/21/15 Page 1 of 6

FILED
U.S. DiSTRICT COUrT

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF MARYLAND
GREENBELT DIVISION
BRETT KIMBERLIN,
Plaintiff,

DISTRICT OF r'i!dIYLAlJD

2015 JAN 21 PH /2: 26

[.'.':f: ;'3

Or-FICE
AT GRW,ILLT

BY

v.

eV

DEPUTY

No. GJH 13 3059

NATIONAL BLOGGERSCLUB, et al
Defendants.

PLAINTIFF'S REPLY TO DEFENDANT ACE OF SPADES' OPPOSITION TO BEING

IDENTIFIED
Now comes Plaintiff Brett Kimberlin and replies to Defendant Ace of Spades'
Opposition to Plaintiffs Motion to Identify Defendant Ace of Spades.
1. Defendant AOS repeatedly

states that since Plaintiff has not identified AOS as

a person in the Complaint, he cannot seek the identity of ADS. This circular
argument

highlights one of the basic reasons why Plaintiff needs to know the

identity of AOS. Had Plaintiff had an identity of AOS when he filed his Complaint, he
could have named him as he named the other Defendants.

However, because

Plaintiff did not have a name, he stated that AOS was a blog written by "an
anonymous

blogger," Plaintiff then did everything possible to find out that

anonymous

blogger's identity prior to filing the Second Amended Complaint,

including filing for subpoenas

in two federal courts, contacting a business that

provides services to AOS, and asking ADS's attorney to provide his name. AOS
responded

by hiring attorneys

to prevent Plaintiff from learning his identity.

have filed motion after motion to keep AOS from being served and from being
identified, yet now they argue that AOS the person is not a Defendant

They

Case 8:13-cv-03059-GJH Document 251 Filed 01/21/15 Page 2 of 6

2. The pleading standard of Fed. R. Civ. P. 8 only requires that a plaintiff plead
"factual content that allows the court to draw the reasonable inference that the
defendant is liable for the misconduct alleged." In the instant case, the Court can
reasonably infer that Plaintiff sued Ace of Spades the person since Plaintiff stated
that the Ace of Spades blog was written by an anonymous blogger and Plaintiff has
gone to great lengths to find out the identity of that anonymous blogger throughout
this case. ADS's first attorney, Paul Levy,and this Court always believed that
Plaintiff was suing ADS the person. Dnly after 15 months of litigating has ADS's new
attorney now argued that Plaintiff did not sue ADS the person. This
mischaracterizes the Complaint, the inferences therein, and the positions of the
parties for the past year.
3. Counsel argues, speculatively and gratuitously, that if ADS is identified, he
could suffer opprobrium and loss of employment

And counsel uses the case of

Defendant Aaron Walker as an example of what can happen to a person who

anonymously attacks people on the Internet only later to be identified. Counsel says
that Aaron Walker was terminated from his employment after being identified. This
is factually inaccurate and without merit.
4. Defendant Walker was not identified pursuant to a court order under Brodie.
Instead, he was identified after representing a defendant in a civil case in
Montgomery County Circuit Court while using an anonymous name. Lawyers
cannot represent people anonymously, but Defendant Walker did. Why? Because he
was simultaneously publishing a Muslim hate blog called Everyone Draw
Mohammed that posted over 800 vile and pornographic depictions of the Prophet

Case 8:13-cv-03059-GJH Document 251 Filed 01/21/15 Page 3 of 6

Mohammed, including many showing the Prophet having sex with children and
animals. On that blog. he begged Muslim "bitches" to come and get him in Manassas,
Virginia to he could engage in a gun battle with them. He insisted that every vile
depiction be "fatwah worthy." He taunted Muslims and said if they were mad at him,
they could come and "behead" him. 8 A.
5. Who told Defendant Walker's employer about his hate blog? Not Plaintiff but
rather Defendant Walker himself. And when he did so, the employer searched his
office and discovered troves of documents strewn all over attacking the Prophet, so
much so that his regular work product could not even be found. Exhibit B.
Therefore, the employer terminated Defendant Walker for being incompetent and
endangering the employer and other employees. 1/

.1/ Incredibly, counsel for AOSincludes as an exhibit in his reply a letter that
Plaintiff wrote to law enforcement officials asking that they protect not only
Defendant Walker but also his employer and co-workers. Counsel calls this letter
"nauseating" and accused Plaintiff of using the letter to "engineerO" Defendant
Walker's termination. Counsel is attempting to mislead the Court since it was Mr.
Walker himself, not law enforcement, who told his employer about his hate blog.
which caused his termination. Plaintiff was being responsible in informing law
enforcement about Defendant Walker's hate blog and the potential for it to cause
mass casualties to his co-workers. As the world witnessed last week in Paris,
fanatics who wanted to avenge insults of the Prophet Mohammed killed 12 people
and wounded many others at the offices of Charlie Hedbo.
What is nauseating is Defendant Walker's response to the lawyer who terminated
him. That lawyer begged Defendant Walker to issue a public statement that he no
longer worked at the place of employment The lawyer wanted this statement
published so that fanatics did not come to the employer and commit a terror attack
Defendant Walker not only refused to issue such a public statement but he berated
the attorney for bothering him during dinner with his wife. Exhibit B.

Case 8:13-cv-03059-GJH Document 251 Filed 01/21/15 Page 4 of 6

6. Defendant Walker's identification is a far cry from the instant case where
Plaintiff is seeking the identity of ADS because he is a defendant in this civil case and
Plaintiff has a due process right to face those he is suing for tortious conduct
Moreover, ADS has not always sought to keep his identity unknown: he is known to
many people, including the Defendants, and has spoken at the very public CPAC
conference, and on FDXNews, memorialized in this YouTube video.
https:L/~ww'YQUtl.lb_e,cQmLw.iltj:J}
?v=p_C_U..2.!:I~~~EyO#t=
11, Photos of these are
posted on social media. Exhibit C. If ADS did not want anyone knowing who he was,
he would not have made those public appearances. Indeed, this Court could
construe those appearances as waivers of anonymity.
7. ADS repeatedly states that Plaintiff is seeking "expedited discovery" when

that is not the case at all. Simply put, ADS has filed a motion to dismiss and Plaintiff
has right to effectively respond to that motion. As this Court noted in Malibu Media,
LLC v. Doe, No. PWG-13-365, 2014 WL 7188822 (D. Md. Dec. 16, 2014), a plaintiff

cannot effectively litigate a civil case if he does not know the identity of the
defendant

("Malibu cannot engage in discovery to probe the underlying facts

underlying its claim without first naming a defendant Unless Malibu is permitted, at
least at the initial stages of litigation, to proceed against a subscriber, it will be
caught in a Catch-22 ...."). In Malibu, this Courtgranted

the plaintiffs motion to

identify the anonymous subscriber. Moreover, all the cases cited by Plaintiff in his
motion to identify ADS concerned identifying a defendant prior to a motion to
dismiss. In most of those cases, they were identified prior to service a/process.

Case 8:13-cv-03059-GJH Document 251 Filed 01/21/15 Page 5 of 6

8. It should be noted that this Court has granted the issuance of subpoenas in
scores of cases brought by Malibu Media to identify anonymous civil defendants
who violated copyrights by illegally downloading films. See e.g., Malibu Media v. Doe,
Civ No WDQ-14-0252 N. D. Md. (6/23/14).

Many of those defendants made

arguments similar to ADS, (e.g., they would be subjected to harassment or pressured

into settlement), yet every Maryland federal judge in each of those cases rejected
their arguments.
9. ADS wants to have an advantage over the other defendants who are all

named in the Complaint He wants to be granted immunity by not being identified

and argue that he has a right to commit tortious acts anonymously. This is unfair.
10. ADS argues that Plaintiff has not met the standards for requiring the identity

of ADS. This is wholly without merit Plaintiffs Complaint sets for numerous
tortious acts by ADS, and they are well pleaded. So well in fact, that ADS had no
trouble whatsoever filing a motion to dismiss or otherwise responding.
11. Finally, ADS makes the bald faced argument that Plaintiffs Complaint is in
"bad faith" and therefore ADS should not be identified. However, there is nothing
bad faith about using the legal system to redress tortious conduct ADS falsely
accused Plaintiff of the crime of swatting. demanded a Bill of Attainder be passed
against him, falsely stated that Plaintiff was going to "escalate" the swattings to
commit a horrible and violent crime, conspired with others to have Plaintiff
imprisoned for a crime he had nothing to do with, wrote that Plaintiff was a one man
"crime wave," and many other actionable torts.

Case 8:13-cv-03059-GJH Document 251 Filed 01/21/15 Page 6 of 6

Wherefore, for all the above reasons and the reasons set forth in Plaintiffs
motion, this Court should order the identity of Ace of Spades.

Certificate of Service
I certify that I emailed a copy of this motion to the attorneys for the
Defendants and Lee Stranahan, and mailed a copy to Defendants McCain,Walker,
Hoge, and to attorney Michael Smith this 2ltth day of January 12,2015.

Case 8:13-cv-03059-GJH Document 251-1 Filed 01/21/15 Page 1 of 2

:"0011; no actual propbl!'tl or peopll!' wl!'r.barm~ in th. creation

or pllblitanon ofthi$ tartoon. So lighun th. hfCk lip ana S{op
b.tng so Jenrith' .

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C..IS'

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Another Cartoon
ByJim )Iartin. Jr.

Help.

I am eutt_~in9 t~om

amne.ia.
I do not
know if I a~ an
imago_ of the
P~ophet
Mohammed

If I Sill
Prophet
must b_
"

WHAT DO l'OU DO NOW!?!?I

I/.rill. )'011Al"'IUppo$td to sctllall~' a<!'pin)Iohammtd. That

ana my rill. against porn (to prf\'<!'ntthe lite from bttns: lilt<!'redl.
are my onl~' rul.s. Slit .her. th.re i.sc!."e calIon wh'thf
)loh~med it actually Mini depitltd.llJkrnynlfi$
tbi5
As

fatwah,,,'ortb}.:-I . Itis.so in in.

("fatwah-wortby'is a trtdemiU"kofth.l\'.r)'on.
Dral"
)Ioh.mmtd .l'bsit . J>i!'nonlcaught \iolattng diM trld. mark ill
~ lubjted
to sf'oPinl UI \'-11" our naughty biu at )'ou.)

Case 8:13-cv-03059-GJH Document 251-1 Filed 01/21/15 Page 2 of 2

LS:!a'~~J
pc:".uf'd b}' C.~

A WekOIlll?

10 Two :'-tort' Author!"

I'd like to introduc:e you Allto two ne ..authon for this blog.
The lint is Du~tin, Dustin is a r.gular comm.nter It Patteric:o's
PontiJiC:<ltions"n('re I hal', ~en a guest bloggl'f for MOIIndsi~
months, He is sensible and UprlfSle5 hims.1f ",II.
The IKond is JD. \'ou might re<:ognil' JD as the artist bflIind lb.
~err 6'lt ofm" Dreildfod$tidJigtl: ~ ofBlll$phl'lJ'l" Co ah"ad, tilk.
look ~t hi5 artwork. It land of mues rou mjft}',ertd, if5 so
~ll\ltiful.

Home
~fiision Statement
Ho,,-to Submit I Cartoon. \'ideo or
Link
Ha.ll of Film"(th C..,rtoon Ardll~l
J)@MSoutit Park
Th. l..eaJ...-l Stic~ figur!'S of

Bluphtm,
Oft"Mi\- C~rtoonl
:.r.HI C~t.>on BIoI P"m;
Cartoun lndu
!'on

Joking md , it was rully a big help ~au$.l! I think too rnm)'

people thought -I can't draw" and th.r~ore didn t. But I "'anttd to
dri'" hom. th. point that it "'un-t .bout cr.lting art, 50 much .s
making a Itatfmenl that we arent afraid oime lerrorisu,
Th.)' are going to be doing99~ of me hU\Tliftinl but to be blunt,
if you terrorist5 an~ loing to go get mad or kill In)'otle, come at
Il'lf, I stiD inrolt ,'our prophH on ;I.fl!g\llat bni5 IIl'Id I lIill
continue to do 50 until this Jorl of thing stoPI gening a nolent
re5pon~, And rhis blog il min., So ii ~'ou art f~ing like
MIIeading J<lmf'One,I m right here .-\.aton Worthing of ~lanaJ~.
Virgina, b.tchl's.

I"'" :-.
1<0"

""H,O" laTf"(N~

O\lltln

said ...

BNr ith me, folks~

I'm happ)' to nand "ith Aaron, rrHdom isn'tfr , You
rithff lund 101'it. or )'011don't,
llAr,6

~o"(1.0- r~,1

"

Case 8:13-cv-03059-GJH Document 251-2 Filed 01/21/15 Page 1 of 7

Gma~. Your couner can come by this aftemoon ...

1012112

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..

Your courier can come by this afternoon ..

Mon, Jan 16, 2012 at 3:24 PM

JlmHodges~
To: Aaron WaIKe~gman:com>
Aaron,
Th.nk you for .greeing

to have the laptop and other company property

someone from laser Courier outtbere

identified

In your email out of your office and delivered

end, we have confirmed

We note, however,

for filing your complaint

those materials

for any expenses related to legal publications,

in plenty oftime

in private

Ittigation

is not the responsibiltty

this week, which is almost certainty

It is unfortunate

that you still do not grasp the gravttyofwhat

at PHRI. If the situation

it

hours.

Apparently,

major religion,
religion.

its employees

and prohibit

you from returning

to return,

disparagingly,

to incite violent reprisals on the part of the most extreme

even if accurately,

however,

that is considered

fear you have created

do you possess firearms?

circumstances

Is "beyond

is one of the primary

actions related

during normal working

performed

all rationaltty."

second amendment

As for the reasons for your termination,

irresponsible

so given the threats

Now that your identtty

a potential

target.

in your email, but you did not deny possessing

no basis for determining

in terminating

is the incredibly

you for your grossty

Irresponsible

way that you

In your office are piled haphazardly

filing. chronology,

or by subject matter.

in no less than five legal size paper

etc. The few files that were actually stored in

Even those appear to be incomplete

what actions were taken or remain to be taken to conclude the matter.

to personal business, Including your various blog activities.

on for PHRI over the last few weeks, if anything.
that we took to document

PHRI business do not indicate the current

of retracing

steps and contacting

will cost PHRI significant

In fact, it is difficult

(Vour characterization

the actual condttlon

the representation

what you were working

The few documents

that did relate to

to which they relate and PHRI is now in the position

third parties to determine

of PHRI, as necessary.

on top of your desk, relate

to determine

where things stand

sums, including the cost for outside counsel to communicate

Given those circumstances,

https:/lm81lgoogle.ccmJm.IInui.2U~2'c239S&y~q..umbl:Wlrl af~11""2F1%2F

and provide

It is also obvious

of your office as "messy" is belied by the

of that room.)

status of the matters

numerous

and, since July of

to you on Friday. the state of your office is almost beyond

that most of the work that you did in that office, as revealed by the stacks of documents

photographs

under

especially on company time (many of your posts bear time stamps

regard to any kind of organization.

your file cabinet are not filed alphabetically

Thus, PHRI has

rights you exercise, it can be assumed that self-protection

hours) the actual reason for your termination

Most of the legal documents

of that
as a

reasons that you do so.

2011, as an employee of PHRI. As I mentioned

boxes, without

of.

If that is true, then why did you call the police. and why

while PHRI would have been justified

to your blogging,

elements

legal services for PHRI (or failed to) over the past foor years. both as an outside attorney

description.

If you have

exposing tts employees to such risks. Finally, you write that

You c1everty denied possessing "handguns"

of any kind. Whatever

the current

offensive to such people.

anyone with whom you associate can be considered

a duty to act in ways that keep you from further

whatever

for

even after

about at least one person that you have described

Perhaps that is the reason that you dm so under a pseudonym - and understandabfy

has been revealed,

continue

to its offices.

you would not even attempt

you chose to start a blog for the express purpose of showing disrespect to the adherents

which could be calculated

leveled against others who published materi.1

firearms

not true, then yoo will be able to make use of

you have done, .nd the risk that you h.ve created

with the concerns of PHRI's personnel,

You also wrote

"terrorist."

which you kept in

is serious enough for you to alert no less than two local police departments,

is serious enough for PHRI to protect

any ability to empathize

materials,

of PHRI. Also, unless you have a

to draft your complaint.

your co-workers
then

To that

other than the

so ail of those books wiil be Included in the package that we deliver to your home.

that the fact that you might need any of your personal reference

PHRI's office, to draft a complaint

deadline

I will have

we wiil take ail of the property

to your address by courier no later than Wednesday.

that you were not reimbursed

hea~h care Industry publications,

picked up by a couriertod.y.

As for your property.

later this afternoon.

1bel'...

Obviously, those efforts

with third party counsel and

it seems clear that you failed to

'12

Case 8:13-cv-03059-GJH Document 251-2 Filed 01/21/15 Page 2 of 7

Gmail- Yo.;r couner can come ~ thIS attemoon ...

1012112

perform your duties as counsel to PHRI, in favor of pursuing your personal interests, while being paid by PHRI. Thus,
PHRI is entirely justified to terminate your employment for cause related to your failure to perform in accordance
with its expectations and with your obligations as a member of the Virginia State Bar. Obviously, even if PHRI had a
severance policy, which it does not, you would not be entitled to receive any such compensation under the
circumstances. Rather, PHRIwould be justified If it sought reimbursement from your for amounts paid for services
that you did not perform or during periods during which you did not perform services.
In light of allth. aba.le, and In the contexl of your activities outside the scope of your employment, If you must
consid.r yourself to be a victim, it is only of your own irresponsible actions. PHRI does not have a responsibility to
provide you with a "soft landing" from those actions In the form of unearned compensation. It is interested,
however, in entering into an agreement with you that will provide certain benefits to txrth parties. Accordingly,
PHRI proposes to agree that your termination was by mutual consent rather than as a termination for cause, that
the parties will waive any claims that they have against the other, and that the parties will agree to confidentiality
terms that will indude a provision that they will not refer to each other in any form (including in anything that you
authorsuch as blogs, books, etc.). PHRlalso proposes to pay you and your wife through the end of last week and to
provide a certain amocnt of severance to Maryin recognition of her many years of service to PHRI. Sh.ls not
considered to be responsible for the current circumstances and PHRI regrets that she has been caught up in these
issues. If you are willing to agree toth. terms set forth in general above, I will draft an agreement for your review.
We would like to get it done by Wednesday, along with the return of your property. If you are not willing to enter
into such an agreement, please let me know immediately.
Jim Hodges
Hodges & Associates, P.e.
11325 Random Hills Road, Suite 400
Fairfax, Virginia 22030
(703)779-5700
(703) 779-0200
p.s. To respond to your personal question to me. no, I was not afraid of you when I met you in the lobby of my
building (a~hough I did not know that you possessfirearms at that time). But I met you in the lobby to avoid the
appearance of you having any association with the company that provides me with office space. You chose to poke
at a group that is known for viorent reprisals, apparently in the name of asserting first amendment rights (even
though the U.S. Government is not involved in suppressing cartoons about Mohammed). And you were f.arful
enough of your adversar~s to alert the police in two counties. So it would be unreasonable for you to condemn
common sense efforts to protect those who have nothing to do with your activities as "beyond all rationality." In
hindsight, do you still consider your "Everyone draw Mohammed" blog to be rational? If so, I would not consider you
to be a credible appraiser of rationality.

From: Aaron Walker

il!'!'~!.'.:C<~"'.~
....
n_

"n

Date: Mon, 16 Jan 20U 13:41:17-0500

To: James Hodges
SUbject Your courier can come by this afternoon ..
[Quoted tl!wt hdd~"1

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i.....-pt&q-kimb5tln

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212

Case 8:13-cv-03059-GJH Document 251-2 Filed 01/21/15 Page 3 of 7

10/2/12

Gmart - Urgent

Urgent
Jim Hodge.

Tue, Feb 14, 2012 at 5:08 PM

To: Aaron WalKer

Aaron,
Apparenttyyour chickens are beginning to come home to roost. We have been informed that PHRI will be a target
of protests and formal diplomatic actions if the groups behind those actions are not informed immediately that you
are no longer employed by PHRI. Under the circumstances, we believe that you have a dutyto prevent any
involvement of PHRI in the situation that you have created. lothat end, we demand that you immediately ad
continuously post prominent notices In every publication to which you contribute, including bfogs, online magazine,
newspapers,

etc., that your employment

w~h PHRI was terminated

effective

January 13, 2012.

If you fail to do so,

you will be liable for any damage incurred by PHRI and/or its personnel arising out of your activities and publications.
Please copy me on all announcements that you publish in accordance with this demand.
Thank you,
Jim Hodges
Hodges & Associates, P.e.
11325 Random Hills Road, Su~e 400
Fairfax, Virginia 22030
(703) 779-5700
(703) 779-0200

https:/lmaiLgooole.

comImaill?ui-2&Ik"'9c272c2395&v

~&q"Jhodge.%AOhodgeHllw. eom&<p"1rue ...

1/1

Case 8:13-cv-03059-GJH Document 251-2 Filed 01/21/15 Page 4 of 7

GmaiI - Urger'll

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.~, ., ' .. '.

-------------------------

..

\;. :.1

-------------

Urgent
Tue, Feb 14, 2012 at 5:59 PM

AaronJW1972
To: Jim Hodges
Jim

Jim
Who exactly has contacted you and what did they say?
Aaron
Sent from my iPhone
[Quoted text hidden]

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~&q

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111

Case 8:13-cv-03059-GJH Document 251-2 Filed 01/21/15 Page 5 of 7

1012112

GINII

Urgent

Urgent

-------------_._-----

-----------------

JimHodges~
To: AaronJW19~

-_._._-_.

Tue, Feb 14, 2012 at 6:02 PM

Aaron,
We are not inclined to prmide more grist for your mill. Please comply
with our demand immediately. We are in the process of notifying the
appropriate authorities on our own. But you h8\e a duty to pubtish the
information conceming your employment immediately, completely, and
eflecti\ely.
Jim Hodges
Hodges & Associates, P.C.
11325 Random Hill. Road, Suile 400
Fairfax, Virginia 22030
(703) 779-5700
(703) 779-0200

[Quoted text hiddenl

https:/lmailgoogle.comImaill?U><2&ik~2c239S&
i.-pt&q.Jnod~ %40h0()ges4aw. com&qs"tl'\le ...

1/1

Case 8:13-cv-03059-GJH Document 251-2 Filed 01/21/15 Page 6 of 7

1012112

Gmaif.

Urgent

Urgent
Tue, Feb 14, 2012 at 8:20 PM

Aaron Walker
To: Jim Hodges
Jim,

This is the last time I am going to let you intentJpt my ewning with my INife.

if you want me to share your concem or your sense of urgency or if you want me to con...;nce anyone else to
I

share it, you h3\e to pl"O'.ideme with information. ~ you would like me to promise, as a condttion of sharing that
information, that I will not publicize what you tell me, I am amenable to that. I will want to share the information
with law enforcement if that becomes necessary, but I will not publicize it. But you are asking me to do a fa""
tor a company that has treated me and my wife very shabbily based on blind faith and I am not prepared to do
that.

Also please infonn Eileen that she is not to contact my mother-tr'Haw any more. If she has concerns for our
safety, she can communicate them to u&--through you, I suppose.

Aaron
{Quoled leld hidden]

htlps: IJmail~.

comImaiV1ui-2&1k:<9c212c23gS&v~&q'"Jhodges
'K.40h0dget.-1aw. com&qs~Ne...

'"

Case 8:13-cv-03059-GJH Document 251-2 Filed 01/21/15 Page 7 of 7

Gmaf - Urgent

1012112

-----------------_._---------------Urgent
Wed, Feb 15, 2012 at 12:42 AM

Jim
Hodges-,-"
To:Aaron
walk'ef~oni>

Aaron,
I apologize for interrupting your evening with your wife. I was not aware that sending email to your account could
be so disruptive.
As to the issuesat hand, you have not addressed our demand that you publish an announcement concerning the
termination of your employment. We can only take from your refusal to respond that you will refuse to do so. As you
are well aware, that refusal to confirm your dissociation with your former colleagues will tend to put them in harm's
way. If the publication of your name. address and place of employment in court filings constitutes an overt threat on
your life, as you have asserted in writing, your refusal to announce that your employment at PHRi has ended is no
lessthreatening to the people who still work at your former place of employment. Sowe ask you one more time to
locate your conscience, put the well.belng of others ahead of your curious concept of your setf.interest and let your
enemies, real and/or imagined, know that you do not work at PHRIany longer. Your former colleagues and those
that care about them may have good reason in the future to thank you for it.
Jim Hodges
Hodges & Associates, P.e.
11325 Random Hills Road. 5u~e 400
Fairfax, Virginia 22030
(703) 779.5700
(703) 779'()2oo

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Case 8:13-cv-03059-GJH Document 251-3 Filed 01/21/15 Page 1 of 1

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