The Brett Kimberlin Saga:

Follow this link to my BLOCKBUSTER STORY of how Brett Kimberlin, a convicted terrorist and perjurer, attempted to frame me for a crime, and then got me arrested for blogging when I exposed that misconduct to the world. That sounds like an incredible claim, but I provide primary documents and video evidence proving that he did this. And if you are moved by this story to provide a little help to myself and other victims of Mr. Kimberlin’s intimidation, such as Robert Stacy McCain, you can donate at the PayPal buttons on the right. And I thank everyone who has done so, and will do so.

Tuesday, June 30, 2015

The Final Failure of Adjudicated Pedophile Brett Kimberlin’s Human Shield Strategy (Part 2 of 3): My Motion to Dismiss These Criminal Charges

This is the latest post in what I half-jokingly call The Kimberlin Saga®.  If you are new to the story, that’s okay! Not everyone reads my blog.  The short version is that convicted terrorist Brett Kimberlin has been harassing me for over three years, his worst conduct being when he attempted to frame me for a crime.  I recognize that this might sound like an incredible claim, but I provide video and documentary evidence of that fact; in other words, you don’t have to believe my word.  You only have to believe your eyes.  Indeed, he sued me for saying this and lost on the issue of truth.  And more recently when his wife came to us claiming that this convicted terrorist had threatened her harm, we tried to help her leave him, and for that, he sued myself, John Hoge, Robert Stacy McCain and Ali Akbar for helping his wife and he is suing Hoge, McCain, Akbar, DB Capital Strategies, Michelle Malkin, Glenn Beck, Patrick “Patterico” Frey, Mandy Nagy, Lee Stranahan, Erick Erickson,, the Blaze, Mercury Radio Arts, Red State, the National Bloggers Club, and  others alleging that we are all in organized crime for reporting factually about the spate of SWATtings committed against myself, Frey and Erickson.  So, if you are new to the story, go to this page and you’ll be able to catch up on what has been happening.

This is the latest post in a continuing series that started here.

So yesterday, I shared with you a redacted copy of Tetyana Kimberlin’s false charges and some of my general thoughts about them.  Now, today as promised, I will share my motion to dismiss.  Well, not the actual motion to dismiss because the motion itself is just a “rump” motion to dismiss that says “please dismiss this case because of the stuff I say in my memorandum of points and authorities.”  You can see an example of this kind of motion, here.  You literally gain nothing from reading that so I am not even bothering to upload that.  So instead, what I have embedded is the Memorandum of Points and Authorities, below the fold, which give you the actual argument for why the case should be dismissed (with slight redactions of personal information):

All the popcorn! All the
I did debate whether to release what I wrote at all.  After all, some of what I wrote might educate Team Kimberlin on the law.  I mean if I never said publicly that I filed a motion to dismiss, they might never have guessed that I had done so, and would have had no idea what I said.  After all, I wasn’t obligated to serve it on the Kimberlins.  Technically they weren’t parties to this case—Maryland was the party.  It was styled State v. Walker.  So they might have had no idea that it existed.

But what made me decide I wanted to publish it is my iron conviction that this Grace’s Law, a.k.a. Md. Code Crim. L. §3-805(b)(2), is absolutely unconstitutional.  In fact, I am convinced that its unconstitutionality is not a bug but a feature.  I was even tempted to use that phrase (“not a bug but a feature”) in my motion, but I figured it was too nerdy to assume the court would understand it.  Lawyers as a rule are not very good with computers or computer lingo, although exceptions are getting more common.

It goes back to the “Grace” at the center of this law, Grace McComas.  According to news reports she was a teenager who was made fun of viciously on social media by classmates (this being off-campus speech, limiting the ability of school officials to address it).  She eventually killed herself.  And I think in all frankness it sparked a moral panic, partially born out of the belief that the internet is something “new and different and scary.”  I don’t really think so, as a rule; I tend to think the same First Amendment applies to the internet as anything else—and so far the Federal Courts have agreed.  Bluntly, kids have been making fun of their classmates ever since school was invented, and tragically there are some kids who have decided to take their own life as a result.  This is not a new problem, requiring a new, draconian solution in violation of the First Amendment.

(On school grounds, children can be subjected to limitations on free speech that they can’t be subjected to in society in general.  And of course individual parents are not typically subject to the First Amendment at all.  But one kid making fun of another when it is off school grounds, is not a subject of regulation.  There is no right not to be made fun of.) 
For instance, this was the satirical ad that was published in Hustler Magazine that
became the subject of Hustler v. Falwell (1988), which reaffirmed that there is no cause
of action for "butthurt" because someone made fun of you.  Embiggen as necessary.
But the legislators were facing a dead girl and panicked parents who demanded that they do something.  My guess is that they realized they really couldn’t do anything about this, consistent with the First Amendment.  So they decided to pass a flagrantly unconstitutional law so they could assure everyone they are trying to do something, but then they can scapegoat the courts when they inevitably strike it down.

Admittedly that is a surmise, based on publicly reported facts and the way that the lawmakers seem to have looked at the precedents that teach them how to write a constitutional harassment statute, and then literally did the opposite.  That last point—that they did exactly what courts have told legislatures not to do—will be obvious when you read the motion to dismiss itself.

But this sort of thing has happened before.  For instance, in Texas v. Johnson (1989) the Supreme Court declared that flag burning was protected expression under the First Amendment.  And there was a great deal of outcry over this, so Congress passed a law outlawing flag burning... which was struck down the very next year in U. S. v. Eichman (1990).  And you will notice that the opinion is extremely short.  It is one of those times that I half-expected the majority to use the word “duh” at some point in the decision.

Did Congress really think that the Supreme Court was going to uphold this law?  I don’t see how.  So to me it seems obvious that they passed the law just to say they tried to do something.  Which seems to be a disgusting decision to shirk their promise to uphold the Constitution, but what can you do?  I mean, besides voting people out of office...

In that case, at least, Mr. Eichman might very well have been kind of a First Amendment hero.  The district court decision pretty much says that he and two others burned the flag in order to intentionally violate the new Congressional flag burning law, on the steps of the Capital, in order to get the damn thing struck down.  There was a fourth person there, Gregory Lee Johnson, who was the same Johnson from Texas v. Johnson decided the year before.  He was apparently attempting to get charged again, too, but somehow didn’t manage to successfully set the flag on fire.  So he was literally trying to make the caption into U.S. v. Johnson, to make the case even more stark, but because he failed to light the flag, he wasn’t even charged.  I doubt that I agree with Mr. Johnson on very much in terms of politics, but I salute his and his companions’ willingness to go to the mat for free speech.

So at least these people are people who wanted to break the law, because they believed it was an unconstitutional law.  On the other hand, how many people are sitting in Maryland’s prisons, or even “merely” bearing the stigma of criminal conviction because they either 1) were unaware of the law, or 2) naively thought they couldn’t be convicted under it?  And how many people are experiencing a chilling effect because of this statute?  It is shameful that lawmakers were so disdainful of their duty to uphold the Federal and Maryland Constitutions.  I only wish it was more surprising.

While I often say "don't educate the midget" let
me be clear.  I don't feel any prejudice toward
little people. For instance, here's the cheerful 
chap who brought R2D2 to life whom I like as a
So my intent in publishing my memorandum is to educate people about this law.  If anyone is charged with violating it, they now have a lot of interesting case law and arguments they can use to try to dismiss the case and render this unconstitutional law the dead letter that it needs to become.  And maybe prosecutors will realize that this law is unconstitutional.  Maybe even judges might happen to read this and come to the same conclusion.  Maybe I can even shame the Maryland Assembly into repealing it, though I am not holding my breath on that last point.  And that is worth the downside of educating Team Kimberlin—because I am also educating the public, too.

And while the arguments will mostly speak for themselves, a few points of strategy are worth talking about.

First, as I have said before, the States’ Attorney Office for Montgomery County will not talk to an unrepresented defendant—even if he or she is a lawyer.  That is, they will charge you without any independent investigation or even just asking for your side of the story.  Which is unconstitutional and, sooner or later, I believe it will be made to stop—either by their own courts, or by the federal courts.  Bluntly, this Application for Statement of Charges is not probable cause.  Probable cause, at the very least, would include the writings at issue and some discussion of how they know we wrote it.  And without probable cause it is illegal and unconstitutional to have charged us.

So there were two purposes in filing this motion.  The first was obviously to convince the judge that the case needs to be dismissed, or to convince the State’s Attorney to drop the case.  But the second other purpose in filing this was to give a least part of my side of the story to prosecutors.

So toward that end, I made sure the memorandum was littered with several of what I call “oh sh*t” moments, as in moments that would really make them wake up and take notice, and realize their case has serious problems.  In other words, it would make them go “oh sh*t!  We have a problem!”  The most obvious example of this is when I say:

Indeed, in this case, the application of the law is arbitrary.  For instance, in the fourth paragraph on the first typed page, the Application claims that “[t]hey have attacked her repeatedly, directly and indirectly, through their online presence by falsely accusing Brett Kimberlin of sexual offenses and insinuating and imputing that [K.K.] is in danger.”  What Mrs. Kimberlin is not telling this Court is that both Mr. Kimberlin and Mrs. Kimberlin have accused Brett Kimberlin of being a pedophile.

On July 28, 2013, Mrs. Kimberlin filed criminal charges, alleging that Mr. Kimberlin first seduced her in Ukraine when she was fourteen years old and he was in his forties, that he transported her to Maryland when she was fifteen and seduced her at least fifty times, and that he also attempted to seduce her twelve year old cousin who was visiting them.  State v. Kimberlin, No. 0601SP005392012 (Md. Mont. Co. Dist. Ct. 2013).  The Application for Statement of Charges she filed in that case is attached as Exhibit D.  She had also stated in protective order petitions that she was afraid for her life and the safety of her daughters, [Ed: extremely personal information about the Kimberlin family that supported Tetyana’s fears about her husband redacted].  Attached as Exhibit E is the post Mr. Walker wrote first accusing Mr. Kimberlin of being a pedophile.  It was based significantly on Mrs. Kimberlin’s own filings.  However, in an apparent confession that she violated Md. Code Crim. L. §9-503, she is claiming now that her husband was innocent of everything she had accused him of and that Messrs. Walker and Hoge somehow harassed her daughter by quoting her and believing her prior claims.

(Footnote omitted).  I don’t think there is a prosecutor alive who could read that passage without their eyes bulging out of their heads and the next parts of the memorandum that I am not quoting is likely to make any reader at least wonder if Brett Kimberlin actually is a pedophile.  Indeed, there is a decent chance that this actually would cause an investigation to be opened, though I am not holding my breath.

But besides that, I am also making the point that their complaining witness is a liar.  First, given the irreconcilable conflict between these charges and the previous charges, they have to figure she was lying in at least one of the charges she filed.  And second, if she foolishly didn’t tell them any detail about those prior charges, they are going to feel like she is holding things back from them.

And best of all, the point is independently valid.  How can it possibly be criminal harassment of K. Kimberlin, to believe and quote Tetyana Kimberlin’s newsworthy allegations against Brett Kimberlin?  Put simply, if that is a crime under §3-805(b)(2), then the statute is unconstitutional, because there can be no reasonable doubt that this is protected speech.

So the passage works on more than one level.

In another example I dealt with the false allegation that I said K. Kimberlin is fair game to be targeted.  It was independently valid to discuss it because I was talking about whether my conduct was targeted toward Maryland.  If my conduct was targeted toward Maryland, a court might find it is proper to exercise jurisdiction over me, and so I wanted to negate that argument.  So I wrote this:

A few examples might illustrate how the allegations [that I targeted my comments toward Maryland] simply cannot be supported by facts.  For instance, on the second typed page of the Application, it states that “[t]hey have said that [K.K.] is a proper target for harassment because of ‘corruption of blood.’”  Mr. Walker not only didn’t say that, he said the opposite.  As Mr. Walker said in the August trial of Kimberlin v. Walker, et al. when confronted with the same accusation:

Q [Kimberlin]: Have you stated on your blog that people have a right to attack my daughter because of corruption of blood?

A [Walker] No, I have literally said the opposite of that. I said one of the things that makes this country great is that we judge people by them, not by who your father is, not by who your daughter is, not by anything. And I talked about how in the treason clause they do away with the principle of the corruption of the blood. I specifically cite that as an example what makes America great. We do not judge people by race, religion or who your parents are, even when you’re a traitor. We do not judge your children by your treachery, even when you’re a terrorist.

See Exhibit K. Indeed, the entire post where Mr. Walker first made this point is attached as Exhibit L.  In that post, Mr. Walker explains that is was sharing with his readers public documents, but that “I will as usual be redacting personal information from it, as well as any information about [Brett Kimberlin’s] eldest daughter.”  That is, even though the information is public, Mr. Walker still redacted some information to protect the privacy of the Kimberlins—going as far as never to mention K.K.’s real name on his blog.  When explaining why Mr. Walker believed in being decent toward the children of a man who has been tormenting him for years with false charges, peace order petitions and lawsuits, Mr. Walker wrote:

For me, one of the great underappreciated clauses of our Constitution is in the Treason clause.  It says: “but no Attainder of Treason shall work Corruption of Blood, or Forfeiture except during the Life of the Person attainted.”  The second part of that is fairly easy to understand, but what about the first[?]  What the hell do they mean by the corruption of the blood?

Well, the answer is they are saying you cannot punish the family of a traitor as though they were traitors, too.  It is a talisman of what makes this country great.  Fundamentally we don’t care who your ancestors were.  They could have been kings, they could have been beggars.  They could have been heroes and they could have been terrorists.  We don’t care.  Because you are judged as you.

So not knowing this girl, she enjoys the presumption of innocence that belongs to all strangers.  Given the way Brett Kimberlin lies about everything, I have no reason to think he is telling her the truth about what is going on and therefore I have no reason to think she approves of what is actually happening here.  If she knew the truth she would know that her father has been working for years to suppress the truth about his illegal and immoral conduct, and his criminal and immoral conduct, combined with his attempt to silence his critics, has brought all this attention on this family.

But allegedly a few people have harassed her online, on her facebook and the like.  There is always concern, of course, that Brett or his allies might be faking a lot of that behavior.  But regardless, if any person draws any negative conclusion about her based on her father, they are not being charitable enough.  They are forgetting that even when we are talking about Benedict Arnold, we do not hold the child responsible for the conduct of the father.

(Internal hyperlinks omitted).  Every other time Mr. Walker has discussed the concept of the “corruption of the blood,” he has either done so to reiterate that point or to point out where Mr. Kimberlin has previously lied about what he said.   So, far from saying K.K. should be targeted because of her father’s vile behavior, Mr. Walker has made an eloquent and morally persuasive argument that she should not be.  He has said literally the opposite of what the Application claims.

I have omitted a footnote that adds “Mr. Hoge has similarly only mentioned the concept of the corruption of the blood to point out that Mr. Kimberlin had lied about what Mr. Walker said.”  As you will notice, most of my arguments apply with equal force to John’s charges, with the sole exception being the personal jurisdiction issue.  And I suspect that if John got to the point of filing his own motion to dismiss (through Patrick Ostronic), he would have brought up the similar (but not identical) issue of venue.

For those unversed on these issues, jurisdiction is generally about what court system can try a person, and venue is about what court in that system can try him or her.  So for instance, I believe that Maryland courts have no business trying Patrick Grady for what he writes on the internet to a general audience (civilly or criminally).  So I believe ideally his challenge based on personal jurisdiction should be successful.  On the other hand, John Hoge can be sued in Maryland as a matter of jurisdiction, but there are rules dictating where he can be sued in Maryland as a matter of proper venue.  Indeed, he recently convinced the Howard County Circuit Court to dismiss Bill Schmalfeldt’s latest silly lawsuit against him for lack of venue.  The other difference is that jurisdiction almost always has constitutional implications, but issues of venue are purely a creature of statute, which then dictates how seriously the court would take these issues.  The courts care much more about being right by the Constitution than any mere statute.

And sharp-eyed readers would also notice that I have paid Mr. Grady the sincerest form of flattery.  Indeed I have been dropping hints for weeks that Mr. Hoge’s and Mr. Grady’s arguments might be taken up by others.  I specifically mentioned people like Michelle Malkin and Erick Erickson, who are presently defendants in a dumb suit filed by Brett against myself and around a dozen others in Maryland state court.  They very well might do exactly that, although I don’t have any inside information on that subject.  But I was also talking about myself, in this case.  I planned at that time to at least use their citations.

At any rate, there were three purposes to that passage I just quoted to you.  The first was to factually challenge any claim that I was directing activity into that forum.  And that is independently valid.  But it serves a second purpose: illustrating that the Application contained at least one outright lie.  And it served yet a third purpose: to show them how utterly reasonable I am.  So again, it works on multiple levels.

I mean one of the more ridiculous things in my motion is that I was having to cite cases involving the Westboro Baptist Church, Hustler Magazine, the Playboy channel, hard core pornography, and speech by the KKK and by comparison my speech is so mild!  This isn’t speech that pushes any kind of envelope—this is basic “meat and potatoes” speech in the heartland of the First Amendment’s protection.  The courts often say they protect outrageous or offensive speech, so that ordinary speech is protected.  This is precisely the kind of speech they are talking about protecting when they protect the more questionable stuff.

And another passage was designed to work on several levels:

In another example of the arbitrariness of the application of the law in this case, on the bottom of the first typed page of the Application, Mrs. Kimberlin complains that “[t]hey have posted comments on blog posts talking about [K.K.]’s ‘titties’ and falsely insinuated ‘sexual abuse.’”  First, this passage is not accusing Messrs. Walker or Hoge of talking about K.K.’s breasts or any potential sexual abuse, but that they commented in a discussion where it was mentioned without any attempt to describe their contribution to that discussion.  Thus, the Application is attempting to practice guilt by association without any attempt to explain how Messrs. Walker and Hoge could be held responsible for the words of third parties.

However, Mr. Walker has looked for the post in question and believes it is the one attached as Exhibit H.  What the relevant discussion (id. at 64-66) concerns is a music video created by K.K. and unknown others called “Whisper.”  The discussion of her breasts was in the context of discussing how K.K. wore an extremely low-cut blouse in that video and leaned forward through about half the video, displaying her cleavage.  A screenshot of one such moment is attached as Exhibit I.  The entire video can be viewed at  Because the video was published when K.K. was only fifteen years old, one commenter quite reasonably was repulsed by what they called a “titty shot” (id. at 65) and others voiced the concern that an adjudicated pedophile was sexualizing his underage daughter.  This is an entirely valid (albeit crude) and reasonable criticism of this video that K.K. and her family has put before the public, and it is protected opinion under the First Amendment.  But as if all of that was not ridiculous enough, the very first comment by Mr. Hoge after these statements were made was “Please leave Miss Kimberlin alone.”   So according to the Application, it was somehow criminal for Mr. Hoge to ask people not to talk about K.K.!  Accordingly, this statute is a content-based restriction on its face and in practice is a ludicrously arbitrary one at that.

That text omits a footnote that notes that I didn’t actually comment on that post at all, in keeping with Brett’s habit of saying “they” when he really means only one of us.

But again, the passage works on several levels.  First, it is relevant to the legal point.  Second, it shows how the Application twists words in a way that manifests a deliberate intent to deceive.  And third, it gives me a chance to show how reasonable John was being about all this.  While John didn’t write out a long essay on how we shouldn’t be targeting K. Kimberlin, I can assure you he feels the same way, and his actual comments in that thread reflected that.

And there are other subtleties.  First, I am not sure if this qualifies as subtle, but don’t just skip over the table of authorities.  The first part of that is entitled “Cases Related to the Kimberlin Family” and it takes up a whole page!  That probably made an impression, as did my discussion of the litigation history.  Even pointing out that he filed charges against Tetyana Kimberlin’s paramour had a point.  It was one of Brett’s dumbest mistakes, because it made it clear to anyone paying attention that he was using the legal system against his enemies.

(And before you ask, I don’t know if she is seeing Jay Elliott anymore and no one has explained to me why it is my business whether she is or not.)

At another point, you see that I refer to Hon. Guido Calabresi as my former professor.  That is my attempt to subtly make them realize they are prosecuting a Yale Law School graduate—he was at one time the Dean of the School and continues to be an important legal thinker.  That was part of an overall strategy of making my memorandum seem scholarly and authoritative.  And yes, to pull intellectual “rank” a little.  I don’t think a bit less of a lawyer who didn’t go to the “right schools” but I will not hesitate to use what school I went to to help me when it matters.

So why did we win?  Well, on Saturday I got a copy of the “line” the States’ Attorney filed in this case commanding that the charges be dropped.  It was filed the day after my request for a hearing was filed (last Monday) so there is the non-zero chance that that request got their attention.  The official reason listed was that “[i]t has been determined that there is insufficient evidence to proceed.”

Is that the truth?  Who knows?  I mean, obviously, there wasn’t sufficient evidence to proceed.  Anyone reading this blog and my twitter knows there isn’t the slightest evidence of any intent to harass, inflict emotional distress or do any form of harm whatsoever to this girl.  My intent is to report on events and to hold Brett Kimberlin responsible.  Even without the protections found in most of Maryland’s harassment statutes, even brushing aside all the constitutional concerns, there is no way my conduct (or John’s for that matter) met the literal language of the statute.

But on the other hand, you have to wonder if they also dropped the charges out of fear that my arguments against Grace’s Law will ultimately prevail.  That is, they might not only have lost this case, but all cases brought under §3-805(b)(2) or even the entirety of the statute under my Commerce Clause arguments.  They might have preferred to keep that statute on the books if only for the chilling effect.  Or perhaps they would prefer to save it for truly horrifying conduct like threats, or revenge porn involving minors.

Which might not be enough to save it.  There is a doctrine of free speech law called the “overbreadth” doctrine.  It is a natural outgrowth of the idea that it is important to avoid a chilling effect.  Let’s take a hypothetical.  Let’s suppose there was a creepy adjudicated pedophile named Rhett.  And let’s say he was focused on a ten year old girl named Debbie.  And let’s say Rhett was sending constant true threats to rape Debbie by email, causing her to be reasonably afraid for her safety.  This would clearly be a violation of §3-805(b)(2), and it equally clearly would not be protected speech under the First Amendment: true threats are not free speech.

But Rhett could say, “but your honor, even though my speech is not protected, the way this statute is written, it could reach activity that is protected.  Therefore it is overly broad and unconstitutional.”  So even though the law can rightfully ban his conduct, he can argue he should be acquitted because it still bans things the law cannot.  This is something unique to free speech doctrine and doesn’t typically apply to other constitutional protections (the only other instance I know of where overbreadth analysis applies is abortion, actually).  And the reason for this is that the courts find this to be a nice way to avoid the chilling effect of having such overbroad laws on the books.

And, incidentally, there are other protections in Maryland and federal law designed to address Rhett’s hypothetical conduct toward Debbie.  So even if Grace’s law is struck down—heck, even if the entirety of §3-805 is struck down—that doesn’t leave a person truly aggrieved by unprotected expression without options.

What can be said with reasonable confidence is that they didn’t decide to drop the charges over personal jurisdiction.  The proof of that is the fact that they dropped John’s charges at the same time and he couldn’t raise that issue.  So whatever convinced them to drop it had to apply equally to both of us.

So that is my memorandum in support of my motion to dismiss.  And tomorrow I fisk that Application for Statement of Charges.


My wife and I have lost our jobs due to the harassment of convicted terrorist (and adjudicated pedophile) Brett Kimberlin, including an attempt to get us killed and to frame me for a crime carrying a sentence of up to ten years.  I know that claim sounds fantastic, but if you read starting here, you will see absolute proof of these claims using documentary and video evidence.  If you would like to help in the fight to hold Mr. Kimberlin accountable, please hit the donation link on the right.  And thank you.

Follow me at Twitter @aaronworthing, mostly for snark and site updates.  And you can purchase my book (or borrow it for free if you have Amazon Prime), Archangel: A Novel of Alternate, Recent History here.  And you can read a little more about my novel, here.



I have accused some people, particularly Brett Kimberlin, of reprehensible conduct.  In some cases, the conduct is even criminal.  In all cases, the only justice I want is through the appropriate legal process—such as the criminal justice system.  I do not want to see vigilante violence against any person or any threat of such violence.  This kind of conduct is not only morally wrong, but it is counter-productive.

In the particular case of Brett Kimberlin, I do not want you to even contact him.  Do not call him.  Do not write him a letter.  Do not write him an email.  Do not text-message him.  Do not engage in any kind of directed communication.  I say this in part because under Maryland law, that can quickly become harassment and I don’t want that to happen to him.

And for that matter, don’t go on his property.  Don’t sneak around and try to photograph him.  Frankly try not to even be within his field of vision.  Your behavior could quickly cross the line into harassment in that way too (not to mention trespass and other concerns).

And do not contact his organizations, either.  And most of all, leave his family alone.

The only exception to all that is that if you are reporting on this, there is of course nothing wrong with contacting him for things like his official response to any stories you might report.  And even then if he tells you to stop contacting him, obey that request.  That this is a key element in making out a harassment claim under Maryland law—that a person asks you to stop and you refuse.

And let me say something else.  In my heart of hearts, I don’t believe that any person supporting me has done any of the above.  But if any of you have, stop it, and if you haven’t don’t start.

No comments:

Post a Comment