CIRCUIT COURT OF CARROLL COUNTY
WILLIAM HOGE
Plaintiff,
ve No. 0616070789
BRETT KIMBERLIN, et al
Defendants.
DEFENDANT WILIAM M SCHMALFELDT’S
RULE 2-504.2 STATEMENT
Pursuant to Maryland Rule 2-504.2, William M. Schmalfeldt,
Sr. states the following.
(2) A brief statement by each defendant of the facts to be relied on as a
defense to a claim; PLAINTIFF HAS A FOUR-YEAR HISTORY OF USING
THE CARROLL COUNTY AND HOWARD COUNTY COURTS TO HARASS
THIS DEFENDANT. HE HAS CAUSED TO BE FILED 367 CRIMINAL
COMPLAINTS AGAINST SCHMALFELDT IN THAT TIME, ALL OF WHICH BUT
ONE WERE NOLLE PROSS'D. THE ONE THAT WAS PROSECUTED BY THE
CARROLL COUNTY STATE'S ATTORNEY RESULTED IN AN ACQUITTAL.
THIS PLAINTIFF HAS RELIED ON TRICKERY AND LYING TO HAVE HIS WAY
WITH THIS DEFENDANT, ONCE PROMISING WITH A HANDSHAKE THAT HE
WOULD NOT PURSUE A PEACE ORDER DENIAL APPEAL, THEN WITHOUT
INFORMING SCHMALFELDT WHO DID NOT ATTEND THE HEARING BASED
ON HOGE’S WORD, HE APPEARED IN COURT AND WON ANUNCONTESTED PEACE ORDER. THIS PLAINTIFF HAS LIED TO THIS AND
OTHER COURTS ON MULTIPLE OCCASIONS. HE IS, IN DEFENDANT'S
OPINION, A VEXATIOUS LITIGANT WHO NEEDS TO BE REINED IN BY THIS
COURT BEFORE HE CAN INFLICT FURTHER DAMAGE.
(6) Stipulations of fact or, if unable to agree, a statement of matters of which any
party requests an admission; SCHMALFELDT REQUESTS AN ADMISSION
THAT PLAINTIFF IS A VEXATIOUS LITIGANT WHO HAS NO GOOD REASON
FOR FILING THE INSTANT SUIT. SCHMALFELDT REQUESTS AN
ADMISSION FROM HOGE THAT SCHMALFELDT IS NONE OF THE ENTITIES,
OTHER THAN WILLIAM M. SCHMALFELDT, THAT HOGE CLAIMS IN HIS
MOTION FOR SUMMARY JUDGMENT.
(2) The details of the damage claimed or any other relief sought as of the
date of the pretrial conference; SCHMALFELDT REQUESTS IMMEDIATE.
DISMISSAL OF THE SUIT, SCHMALFELDT REQUESTS PLAIHTIFF BE
DESIGHATED A VEXATIOUS LITIGANT,
(8) A listing of the documents and records to be offered in evidence by
each party at the trial, other than those expected to be used solely for
impeachment, indicating which documents the parties agree may be
offered in evidence without the usual authentication and separately
identifying those that the party may offer only if the need arises; THE
DEFENDANT WILL RELY ON HOGE'S OWN WORDS TO PROVE THE
VEXATIOUS NATURE OF HIS ACTIONS, THESE ARE DOCUMENTS THAT
ARE ALREADY IN HOGE’S POSSESSION.(9) A listing by each party of the name, address, and telephone number of
each non-expert whom the party expects to call as a witness at trial (other
than those expected to be used solely for impeachment) separately
identifying those whom the party may call only if the need arises; Witnesses
will be Aaron Walker, William Hoge, Patrick G. Grady, Sarah Palmer, Eric P,
Johnson,, Brett Kimberlin, Tae Kim, Assistant State's Attorney Ken Grote, Mary du
Bravo, and Carroll County Circuit Judge Stansfield.
(10) A listing by each party of those witnesses whose testimony is
expected to be presented by means of a deposition (other than those
expected to be used solely for impeachment) and a transcript of the
pertinent portions of any deposition testimony that was not taken
stenographically: None
(12) Any other matter that the party wishes to raise at the conference.
Respectfully submitted,
tA
William M. SchmalfeldtCertificate of Service
I certify that I served a copy of this motion on Plaintiff this 27% day of May, 2017.
William M. Schmalfeldt
Aff
‘Myrtle Beach, NC 29579
Broadwaybill947@outlook.com