IN THE CIRCUIT COURT FOR MONTGOMERY COUNTY, MARYLAND

BRETT KIMBERLIN,
Petitioner
v.
AARON WALKER,
Respondent
Case No. 8526D
EMERGENCY MOTION FOR PARTIAL STAY
OR MODIFICATION OF THE DISTRICT COURT
PEACE ORDER PENDING APPEAL
Respondent, Aaron J Walker, by REGINALD W. BOURS, III, PC, and pursuant
to Maryland Rule 7-112(c), respectfully requests that this Honorable Court issue an
immediate order modifying or staying enforcement of a peace order issued by the District
Court of Maryland for Montgomery County [Vaughey, J.. ] on or about May 29, 2012,
pending a final hearing now scheduled in this court for July 5,2012, and in support of this
request, states as follows:
1. The subject peace order is attached as an exhibit to this motion, and on its
face prohibits "electronic contact" by Respondent with Petitioner.. However, in its oral ruling
issued May 29,2012, the District Court judge stated:
Respondent shall not contact the [petitioner] in person, by telephone, in
writing, or any other means And "any other means" is putting it on a blog, a
Tweet, a megaphone, a smoke signals-what else is out there-sonar,
radar, laser. Nothing.
Transcript at 59.
LAW OffiCES
W BOURS, IlL P C
SUITE 103
2. That, to place this in context, Petitioner claimed at the District Court hearing
401 JEfFERSON STREET
R.OCKVILLE }.lARYLA}/O 20850
(3011 340 7600
that Respondent had written about him on the internet in a blog known as "Allergic to Bull."
Petitioner further claimed that unfavorable comments about him in this blog had caused
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other persons, not Respondent, and none of whom was identified, to "harass" or "threaten"
Petitioner at various times. Petitioner did not establish a direct causal connection between
the communications he did receive and this Respondent, and his entire presentation in
District Court was designed to prohibit the Respondent from exercising his rights of free
speech.
3. That, additionally, the Maryland Peace Order statutes do not allow for the
kind of overly broad order that was passed in this case by the District Court. Specifically,
the statute provides:
(2) If the judge issues an order under this section, the order shall contain
only the relief that is minimally necessary to protect the petitioner.
Md. Code Ann., Cts & Jud Proc 3-1505 (West) [Emphasis supplied]
4. Additionally, neither the Petitioner nor the District Court judge correctly
interpreted the portion of the statute permitting a peace order where it is established that
a Respondent has violated Crim. Law 3-803. That statute provides:
Prohibited
(a) A person may not follow another in or about a public place or maliciously engage
in a course of conduct that alarms or seriously annoys the other:
(1) with the intent to harass, alarm, or annoy the other;
(2) after receiving a reasonable warning or request to stop by or on behalf of the
other; and
(3) without a legal purpose.
Exception
(b) This section does not apply to a peaceable activity intended to
express a political view or provide information to others"
Md. Code Ann, Crim. Law 3-803 (West) [Emphasis supplied]
Further, in Galloway v State, the Court of Appeals specifically stated that
Maryland's harassment statute" expressly eliminates constitutionally protected speech
-3-
from its ambit." 781 A 2d 851,878 (Md. 2001). In other words, constitutionally protected
expression cannot be considered harassment.
5. That, for the foregoing reasons, the District Court peace order should be
modified or stayed for direct violations of the Maryland peace order statutes..
6. To further assist the court in reviewing the matter, this is the second peace
order filed against the Respondent by the Petitioner. On January 9,2012, the Petitioner
appeared before the District Court and a District Court Commissioner following a court
appearance in the Circuit Court for Montgomery County. He successfully obtained a
temporary peace order based on allegations of assault and harassment from the District
Court in case number 0601 SP005392012, and a Commissioner issued a criminal
summons for assault in case number 0000276493.
7. The Montgomery County State's Attorney Office declined to prosecute the
criminal charge after video evidence from a Circuit Court security camera failed to support,
and largely contradicted the Petitioner's claims.. When the Respondent was notified of this
decision, he filed a written opposition to the State's absolute right to enter a nolle prosequi
See attached exhibit.
8 A District Court judge granted a final peace order to the Petitioner solely on
the basis of harassment, but declined to find there was clear and convincing evidence of
an assault. Respondent appealed that decision to Circuit Court, and the Honorable Eric
M. Johnson found that there was no evidence of harassment within the meaning of the
peace order statute and relevant criminal harassment statute, and declined to find a basis
to order an ongoing peace order based on the allegation of assault. Judge Johnson found
in favor of the Respondent based on the Petitioner's presentation only.
II
-4-
9. In the current proceeding, the Petitioner went to a District Court
Commissioner at midnight on Saturday, May 19, 2012 and presented ex parte claims that,
in part, rehash "factual" allegations from his first peace order case and somehow obtained
an interim order on the basis that putting information on the internet about the Petitioner
was somehow a threat to the Petitioner and therefore constituted harassment.
10. Following issuance of the interim order Petitioner appeared again in an ex
parte proceeding before a District Court judge on May 22, 2012 That judge issued a
temporary order that was never served on the Respondent Before a final hearing was
even held, and again on a weekend night, the Petitioner went to a commissioner and
obtained criminal charges [See attached] alleging violations of the unserved temporary
peace order based on the Petitioner's claimed receipt of threats following blogs and tweets
on the internet Blogs and tweets do not involve direct contact by the author with this
Respondent, but were communications about the Petitioner directed toward a general
audience. In short, the effect of the District Court peace order" .. is not attempting to stop
the flow of information into [the Respondent's] own household, but to the public."
Organization fora BetterAustin v. Keefe, 402 U.S. 415, 419-420 (1971), an act considered
inherently questionable by the Keefe court.. See also United States v. Cassidy, 814 F.
Supp. 2d 574 (D Md.. 2011) (dismissing a prosecution for "stalking" by twitter and blogs
because they are released to the general public and only seen by the "victim" voluntarily).
11 . The record of the District Court peace order hearing demonstrates that there
was absolutely no evidence that the Respondent had personally threatened the Petitioner
II
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or that anyone did so at the Respondent's direction. Tr.. at 17-18.. Rather, the court found
that the Respondent had incited threats against the Petitioner merely by asserting that the
Petitioner had engaged in reprehensible conduct Tr at 55.
12. The District Court imposed a broad-based prior restraint upon the
Respondent's speech to a general audience As the Supreme Court said in Keefe, supra,
" ... [a]ny prior restraint on expression comes to this Court with a heavy presumption against
its constitutional validity." 402 US at 419 (internal quotations omitted) Rather than
overcome that burden, the District Court disregarded by name controlling Supreme Court
precedent on what constitutes incitement:
A [Walker] But, your honor, I did not incite him within the Brandenburg
standard..
Q [the court] Forget Brandenburg. Let's go by Vaughey right now, and
common sense out in the world
The "Brandenburg" that Judge Vaughey chose to ignore was Brandenburg v. Ohio, 395 US
444 (1969). where the Supreme Court stated that:
The constitutional guarantees of free speech and free press do not permit a
State to forbid or proscribe advocacy of the use of force or of law violation
except where such advocacy is directed to inciting or producing imminent
lawless action and is likely to incite or produce such action
395 US, at 447 [Emphasis supplied]
There was no evidence in the District Court hearing that the Respondent advocated
the use of force or "law violation" as required by the Brandenburg standard. Indeed, the
uncontradicted testimony of the Respondent indicates that he actively took steps when
writing about the Petitioner to prevent vigilantism:
II
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[Walker] I have told the world about what this man did to me, but it's all I've
done. Now I know, Your Honor.. that when you. say to the world,
"Someone has done something evil," that you do obviously have a risk of
things like violence and things like that It's inescapable. But I have never
incited violence.. I have always told people every time they have said
anything violent in my presence, I said, "I don't endorse violence even as a
joke." .
On top of that, I put numerous, numerous, numerous primary documents on
my website. Many of those documents originally had [Kimberlin's] home
address, had his phone number, had his email address, etcetera, etcetera
I carefully redacted every single instance of that. I didn't put any current
photos of Mr.. Kimberlin on the website[.. ]
Tr.. at 43-44, copies attached. In Near v. Minnesota, the Supreme Court specifically held
that merely stating that a person has engaged in "reprehensible conduct" and that law
enforcement had failed to address that conduct is not sufficient to constitute incitement
justifying a prior restraint of freedom of expression, even when there is fear that such
expression might "disturb the public peace and ... provoke assaults and the commission of
crime." 283 US 697,721-22 (1931)
13. Further, as noted above, the court cannot find that harassment has occurred
if the conduct is done for a "legal purpose." MD. CRIMINAL LAwCODE 3-803(a)(3). And the
Respondent's purpose is not only legal, but specifically enumerated in the First
Amendment: he was petitioning the government for a redress of grievances. Respondent
believes that the Petitioner (who has a long and deplorable criminal record) has actually
attempted to frame the Respondent for a crime and has asked the State's Attorney to file
charges relating to perjury and other false statements the Petitioner has made while
attempting to cause the Petitioner to be incarcerated. Despite having video evidence
proving that the Petitioner lied in his first criminal complaint, lied in his first petition for
II
-7-
peace order and perjured himself in every proceeding related to that first peace order, the
State's Attorney has rebuffed Respondent's request for the Petitioner to be charged with
a crime. Therefore having exhausted official channels, the Respondent has gone public
with his story, asking for the public to urge the State's Attorney to prosecute Petitioner:
[Walker] Look at, for example, what happened with the Trayvon Martin
incident, okay? A man named George Zimmerman shot this young man
named Trayvon Martin His parents felt that [Zimmerman] deserved to be
charged with a crime The police did not charge him. So they raised a
national uproar. And what happened? They've now charged him.
Now, I disagree with the decision to charge Mr Zimmerman, but that is the
model of what I am trying to do. I'm trying to create enough of a national
uproar to create pressure on [Montgomery County State's Attorney] John
McCarthy to finally charge [Kimberlin] with the crimes related to him trying to
frame me for a crime I'm trying to get justice.. And he wants to shut me up.
Tr. at 50-51 This is undeniably a legal purpose and therefore rebuts any claim that
Respondent is "harassing" Petitioner Thus for this reason as well, the District Court failed
to overcome the "heavy presumption" against the constitutional validity of this prior
restraint Keefe, 402 US at 419
14. Emergency relief and indeed ex parte relief is appropriate in this case First,
this is a continuing and intolerable violation of Respondent's First Amendment rights that
if left unaddressed will ironically go through Independence Day. "Where .. a direct prior
restraint is imposed ... , each passing day may constitute a separate and cognizable
infringement of the First Amendment" Nebraska Press Assn v Stuart, 423 U. S. 1319,
1329 (1975) (BLACKMUN, J, in chambers). And indeed expedited process has frequently
been used to prevent irreparable harm to First Amendment rights. In Patuxent Publishing
Corp v. State, 429 A2d 554 (Md Ct Spec. App 1981), the Court of Special Appeals
II
-8-
provided next day review of a Howard County Circuit Court order that implicated the First
Amendment and in CBS, Inc. v. Davis, 510 U.S. 1315 (1994) (Blackmun, J, in chambers)
another prior restraint on the press went from the initial temporary restraining order in
South Dakota Circuit Court to a stay issued by a US. Supreme Court justice in fifteen
days. And while all of those cases involved the institutional press, the Supreme Court has
"consistently rejected the proposition that the institutional press has any constitutional
privilege beyond that of other speakers." Citizens United v FEC, 130 SCt 876, 905
(2010)
15 Further, under Carroll, it is clear that the default position is that the
Respondent should be free to express himself without prior restraints until and unless the
Petitioner can overcome the presumption against such restraints at a fulsome hearing.
"[E]ven where this presumption [against prior restraints] might otherwise be overcome, the
Court has insisted upon careful procedural provisions, designed to assure the fullest
presentation and consideration of the matlerwhich the circumstances permit" Carroll, 393
U. S at 181. The District Court hearing, where the judge refused to review the allegedly
harassing writings (Tr.. at 48), and disregarded controlling Supreme Court precedent by
name, does not meet this standard.
16. Accordingly, this court should find immediately and on an ex parte basis that
the Petitioner did not meet his burden under Carroll to justify this prior restraint on the
Respondent's speech and stay the enforcement of the prohibition against discussing the
Petitioner to a general audience until such time as this burden is met This should be done
immediately and ex parte because it is already clear based on the record below that an
11
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insufficient factual basis exists to support this prior restraint If Petitioner, at some later
date, comes to this court with sufficient evidence to justify the prior restraint on the
Respondent's freedom of expression-either in a responsive pleading or at the July 5,
2012 hearing-at that time this court can re-impose this prior restraint
17 This emergency motion does not address the prohibitions in the peace order
that prevent the Respondent from entering the Petitioner's residence, harming the
Petitioner or threatening to do so, or indeed by contacting him with directed
communications, such as phone calls, e-mails, letters, text messages, or any other
messaging service whereby a person directs communications to specific person or
persons.. A proposed order for limited ex parte relief is attached.
WHEREFORE, Respondent respectfully requests that this Honorable Court sign an
appropriate ex parte order modifying or staying the provisions of the District Court peace
order that purports to limit is right of free speech>
REGINALD W. SOURS, III
Attorney for Respondent
401 East Jefferson Street
Suite 103
Rockville, Maryland 20850
(301) 340-7600
-10-
POINTS AND AUTHORmES
(cl Modification of Peace Orders Pending Appeal. In an appeal from the grantordenial
of a peace order, the circurt court, on its own initiative or on motion of any party, may
modify, stay, or issue a peace order for good cause shown pending the determination of
the appeal
Authority: Maryland Rule 7-112
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that, on June 20, 2012, a copy of the foregoing was mailed,
first-class postage pre-paid, to Brett K i m b e ~ i n , Bethesda,
Maryland 20817 Another copy will be delivered via e-mail at ,
together with correspondence indtcating this motion would be presented to the
Administrative Judge or a duty judge of the Circurt Court on the moming of June 25, 2012.
REGINALD W. BOURS, III
1//11111/11/111/111111111111111111111111111111111111111111111IIIIIIIJ/il Wif-.
DISTRICT COURT OF MARYLAND FOR MONTGOMERY COUNTY
191 EAST JEFFERSON ST, ROCKVILLE, MD 20850 Case No. 0601SP019792012
Date: OS/29/2012 10:52 am.
BRETT KIMBERLIN vs AARON JUSTIN WALKER
FINAL PEACE ORDER
After the appearance of the PETITIONER, and RESPONDENT, and in consideration of the Petition and
evidence,
the Court makes the following findings:
A 1 That there is clear and convincing evidence that within 30 days before the filing of the Petition, the
Respondent committed the following act(s):
Placed Person Eligible for relief in fear of imminent serious bodily harm: COUNTLESS NUMBER OF
BLOGS EITHER THREATENING DEATH
2 That there is clear and convincing evidence that Respondent is likely to commit a prohibited act in the future
against the Petitioner
Based on the foregoing, the Court hereby ORDERS:
1 Unless stated otherwise below, this Order is effective until 11/15/2012.
2 That the Respondent SHALL NOT commit or threaten to commit any of the following acts against Petitioner:
an act which causes serious bodily harm; an act that places the Petitioner in fear of imminent serious bodily
harm; assault; rape, attempted rape, sexual offense, or attempted sexual offense; false imprisonment;
harassment; stalking; trespass; or malicious destruction of property.
3. That the Respondent SHALL NOT contact (in person, by telephone, in writing, or by any other means),
attempt to contact, or harass the Petitioner
4. That the Respondent SHALL NOT enter the residence of PETITIONER at ANYWHERE
(Residence includes yard, grounds, outbuildings, and common areas surrounding the dwelling)
5. That the Respondent SHALL STAY AWAY from:
The Petitioner's place(s) of employment at:
ANYWHERE
Comments:
THREATS
COND#1- NO ELECTRONIC CONTACT
Date: OS/29/2012
J
NOTICE TO RESPONDENT
Vioiation of this Peace Order may be a crime or contempt of court or both, and couid result in imprisonment or fine or both
PC/PO 3 (Rev 12/2004)
Page 1
IN THE DISTRICT COURT FOR MONTGOMERY COUNTY, MARYLAND
------------------------------x
BRETT KIMBERLIN,
Plaintiff,
v,
AARON JUSTIN WALKER,
Defendant ..
------------------------------x
Case No, 0601SP019792012
. ~
HEARING
Rockville, Maryland
DEPOSITION SERVICES, INC,
12321 Middlebrook Road, Suite 210
Germantown, Maryland 20874
(301) 881-3344
May 29, 2012
IN THE DISTRICT COURT FOR MONTGOMERY COUNTY, MARYLAND
------------------------------x

BRETT KIMBERLIN,
,
Plaintiff,

,
v.
,
Case No. 0601SP019792012
,
AARON JUSTIN WALKER,

,
Defendant.
,

------------------------------x
Rockville,
May 29, 2012
WHEREUPON, the in the above-entitled
matter commenced
BEFORE: THE HONORABLE CORNELIUS J. VAUGHEY, JUDGE
APPEARANCES:
FOR THE PETITIONER:
BRETT KIMBERLIN, Pro Se
Bethesda, Maryland 20817
FOR IKE RESPONDENT'
AARON JUSTIN WALKER, Esq., Se
(NO
DEPOSITION SERVICES, INC.
WITNESSES
For the Petitioner:
Brett Kimberlin
DIRECT
5
.1 N D E X
CROSS
21
REDIRECT RECROSS
For the Respondent:
Aaron Justin Walker 40
kc
1
2
3
THE COURT: No, you can't right now,
MR" WALKER: All right,
THE COURT: That's what you got to, as when I was
59
4 over in Munich in the appeals courts over there --
MR, WALKER: Okay, Your Honor, 5
6 THE COURT: - - appeal" All right, sir" This order
7 shall remain in effect until November the 15th, 2012" During
8 that period of time, you not shall commit any act that causes
9 him, puts him in fear and apprehension of bodily harm, any act
10 that places the gentleman in fear and apprehension of grave
11 bodily harm, any assault, rape, attempt to rape, sexual
12 offense, false imprisonment, harassment, stalking, trespass, or
13 malicious destruction of property"
14 Respondent shall not contact the person in person, by
15 telephone, in writing, or any other means, And "any other
16 means" is putting it on a blog, a Tweet, a megaphone, a smoke
17 signals - - what else is out there - - sonar, radar, laser
18 Nothing"
19
20
21
22
23
24
25 me?
MR" WALKER: So, I'm not allowed to --
THE COURT: You
MR, WALKER: speak about him for six months?
THE COURT: How many times are you going to
- -
MR WALKER: What happened to the First Amendment?
THE COURT: How many times are you going to interTupt
kc
43
1
Q
-- can't even get to the point I just asked a
2 simple question, Were you convicted?
What?
No, I was not,
I apologize, Your Honor,
That's quite all right, Were you convicted?
Okay" Then what happened to the case?
It was nolle prossed after he filed --
Okay, Nolle prossed, that's an action of the State,
I apologize, Your Honor, No,
Q
Q
A
Q
A
Q
A
A 3
4
5
6
7
8
9
10
11 not by you and not by him, that's a State action, Okay,
12 That's all I want to know, Nolle prossed.,
13
14
A
Q
Right,
That can be brought back in the statute of
15 limitations or whatever
it's something different,
I reported on my, I have told the world about
That's true, Your Honor,
I don't want, keep going,
So So that's, okay, -- the time it becomes --, okay
Okay,
Q
A
A
16
17
18
19
20 what this man did to me, but it's all I've done Now, I know
21 Your Honor, I know Your Honor, that when you tell, say to the
22 world, n Someone has done something evil, n that you do obviously
But I have never incited violence, I have always
23
24
have a risk of things like violence and things like that,
inescapable,
It's
25 told people every time that they have said anything violent in
kc
44
1 my presence, I said, "I do not endorse violence even as a
2 joke .. " And even if they joke about it, "Oh, wouldn't it be
3 funny if he went to prison and got raped," I would say, "That
4 is not cool, I'm not cool with that" I was always clear with
5 that ..
6
On top of that, I put numerous, numerous, numerous
7 primary documents on my website.. Many of those documents
8 originally had his home address, had his phone number, had his
e-mail address, etcetera, etcetera. 9
10 single instance of that.
I carefully redacted every
I didn't put any current photos of
11 Mr.. Kimberlin on the website. I
Did you send all those e-mails that he had there? 12
13
Q
A I did not send any nasty e-mail to him.. I've never
14 sent him an e-mail, period ..
So those 54 pages, 540 e-mails, never came from you?
Well, the 54 pages he's talking about is Twitter, and
That was not the question.. You've changed it again ..
Well, I apologize.
Did you send those e-mails?
15
16
17
18
19
20
Q
A
Q
A
Q
A
No, I didn't.. I've never e-mailed him, period.
21 Twitter is something where you talk to the world, not to Brett
22 Kimberlin.. Brett Kimberlin believes that if you speak anywhere
23 on the Internet, it is equivalent to putting a letter in his
24 mailbox .. And he is trying to use, he's trying to equate it to
25 Galloway, in Galloway v. State, saying Your Honor, that, or in
ff:r...
1ey
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DISTRICT COURT OF MONTGOMERY COUNTY MARYLAND
STATE OF MARYLAND,
Plaintiff,
v No.OD00276493
en
,\.
o
AARON JUSTIN WALKER,
Defendant.
VICTIM/COMPLAINANT BRETTKIMBERLlN'S MOTION IN OPPOSITION TO
STATE'S MOTION TO NOLLE PROS THIS CASE
Now comes Victim/Complainant Brett Kimberlin ("Victim") and hereby opposes
the State's Motion to Nolle Pros this case In SUppOlt of this motion, Victim states
that this is not simply a rull of themiJI assault case but rather one that has both
._,.__. _ , , - , - ~ --'-' ",.."-'--' -
'llatlt5l1ii]'alfd1fiternationalramlfiCatlonsan:a Ei beIngwatched byfecterallaw
enforcement authorities, Stilte Department contractors, or ganizationsthat monitor
hate groups, foreign countries with large Muslim populations, and national Mljslim
and civil rights organizations. There are many aggravating factors piesent in this
case that warrant full prosecution and even consideration of additional charges
against Mr Walker.
Factual Statement
1. Defend\lnt Aaron Walker is a Virginia attomey who assaulted Victim on
January 9, 2012 after a civil court hearing in Montgomery County Circuit
Court
2 Prior to the hearing, Mr Walker had been stalking and harassing Victim on his
personal blog with defamatory, aggressive, and derogatory posts He asked
-- . _ - - - , - ~ - - , - - - - - - - "."'--'-"'-'--"'-------"'---' ------_._._.. _,--_._,-,.., _ . _ - _ . _ - _ . , ~ - - . __.__...._ . ~ . _ . _ ~ , - _ . __.__.
his readers to "get out the popqorn" to watch how he would destroy Victim
He did all this using a pseudonym, "Aaron Worthing Esq."
3 Victim could not locate any listing for an attorney named Aar on Worthing so
he sought assistance from the Montgomery County Circuit Court to ascertain
the real identity of Mr Worthing prior to a court hearing set for january 9,
2012. However, several days prior to the hearing, Victim learned that Aaron
Worthing was actually Aaron Walker
4 Victim then filed a motion in the court dismissing as moot his motion to
compel the identity of Mr Worthing/Walker.
5 On january 9, 2012, Ml. Walker showed up at the hearing and made an
- - "_.. _,-,.-.' ,,-
-emergency-oralmotioi1fiiseaiVlctlm'S motion i;rentiiYing him a ~ Aaron
Walker. He argued that since he (as AalOn Worthing) was the publisher of a
Muslim hate blog called Everyone Draw Mohammed, he would be killed by
Muslims if theyknew he was really Aaron Walker Judge Rupp was taken
aback by Mr. Walker's appearance in the case but did grant Mr Walker's
motion to seal the motion However, even after the judge told Mr Walker to
sit in the spectatOl section, Mr Walker continued to interject until Judge Rupp
warned him that sheriff deputies would escort him from the courtroom ifhe
continued
6 As Victim was exitingthe courtroom, Mr. Walker began berating Victim for
identifying him and said that he would continue to harass Victim As Victim
exited the courtroom doors, Mr Walker became more irate and began making
threateningmoves toward Victim including coming toward Victim. Therefore,
Victim, using his iPad, snapped a photo of Mr Walker with his hand coming
toward Victim Exhibit A
7 Mr Walker struck Victim with his hand, and Mr Walker began wrestling with
Victim for possession of the iPad Aperson who followed Victim r'om the
courtroom repeatedly called back into the court, "He (Mr Walker) attacked
him" Two courtroom staff came running from the court and separ ated Mr
Walker from Victim Mr Walker retained possession of the iPad The staff also
called for assistance of courtroom deputies who arrived shortly thereafter
8 Approximately nine deputies arrived and Victim immediately told them that
Mr Walker had attacked him and still had his iPad One deputy retrieved the
iPad fl'om Mr Walker and several deputies advised Victim to go to the
Commissioner's office to press criminal charges against Mr, Walker for
assault
9 The deputies safely escorted Victim down the elevator, and Victim went
straight to the Commissioner's office and filed both seconddegree assault
charges and for a Peace Order, which was granted
10 Victim then immediately went to a nearby medical clinic to be treated for his
injur ies during the assault When the doctor at the clinic evaluated Victim, he
said that Victim had to immediately go to the Emergency Ward at Suburban
Hospital because of a contusion to the eye, blurry vision, twitching and a
severe headache The Doctor was concerned that Victim suffered a
concussion and even said that Victim should take an ambulance rather than
drive.
11 When Victim arrived a Suburban Hospital, he was immediately admitted to
the Emergency Ward and quickly evaluated and taken for a CT scan, given eye
exams, given medication for both pain and for contusion to the eye Victim
was kept under observation for several hauls and then released with orders
to rest for several days and to take steroids eye drops for one week He was
also ordered to get a follow-up evaluation from his primary care physician
12 Victim suffere!i a black eye from second-!iegree assault It lasted throughout
the week Exhibit B
13. Victim did seek follow up care, and was given an EKG and more XIays due to
pain in the chest ar ea
-14 Victfmwasl.uiiiblefo work auring the 9
th
due to his injuries
and his medical care
15. Mr Walker responded to Victim's legal filings in the following retaliatory
ways: (1) he filed a malicious criminal charge against Victim for perjuIY, (2)
he filed a false and malicious Peace Or der application "gainst a third party
named Neal Rauhauser, and falsely told the sheriff that he lived at Victim's
address (when he had never even visited Victim's home) which caused three
sheriffs to come to Victim's home to ser ve Mr Rauhauser, (3J he filed a
frivolous and malicious $66,000,000 lawsuit against Victim and two others,
which has sInce been served on Victim, (4) he used Twitter to attackVictim in
dozens of tweets, and (5) he blogged that Victim is "human filth" and told
people, as an attorney, that if they donate to Victim's non profits, they would
------ ----- -- - - .- __
be liable for criminal and civil consequences because Victim exposed his real
name.
16 When Mr Walker appeared on February 8,2012 for Victim's Peace Order
hearing for his assault, he told the judge that he did not assault Victim but
rather took the iPad Without incident because he thought it might be a
"bomb" He said that Victim must have ended up in Suburban Hospital
Emergency Room with injuries by having someone else beat Victim up so
Victim could file false assault charges against him. Asheriff deputy testified
at the hearing that Victim stated that Mr Walker had assaulted Victim
immediately after the attack and that he had to take myiPad away from Mr,
. "Walker, ana'anoHier aeputshowed the judge the ' i n ~ i d ~ ~ t report from that
assault which said the same Victim presented the judge with evidence of Mr
Walker's harassment of Victim as noted in paragraph 15 above After hearing
all the evidence, the Judge found, by clear and convincing evidence, that Mr
Walker had assaulted and harassed Victim, and the judge issued a final Peace
Order prohibiting Mr Walker from further haraSsing Victim Exhibit C
17 When Mr Walker appeared on Febr uary 16, 2012 for his Peace Order hearing
against Mr Rauhauser, at which Mr Rauhauser did not even appear, Mr
Walker engaged in a most bizarre statement of events telling the judge that he
needed a Peace Order because, according to him, Mr Rauhauser posted
something called "Kookpopohs" on the Internet which contained three items, .
, a map of Manassas, Vir ginia, a map of Boston, Massachusetts, and a
beheading video in a foreign language He begged the judge to see these as a
threat to Mr, Walker since he lived in Manassas, a client lived in
Massachusetts, and Muslims behead people The judge was incredulous, even
at one point asking Mr Walker if he was really an attor ney Finally, the judge
said that even without Mr Rauhauser present to defend himself, she was
going to find that Mr Walker failed to meet the statutory burden neceSsaryfor
issuance of a Peace Order, Exhibit D
18 The criminal charge that Mr. Walker filed against Victim did not even result in
summons or make it past the screeners at the District AttOrney's office
ExhibitE
Ef, 1<11'; Walker has stalkeci, assaulted and harassed Victim because of Victim's
worKas DirectoroJ'aMaryIaniCbasednatlonalnon.proflttn.at, inter alia,
supports Muslim activists, musicians and artists opposed to violence and
oppression, Mr, Walker runs a Muslim hate blog, which has over 800 vile
depictions of the Prophet Mohammed on itto insult Muslims, He useS that
blogto taunt Muslims by calling them "bitches" and teUingthem to come to
Manassas, Virginia so he can engage in a gun battle with them (of course he
used his false name for such taunts) MI. Walker's criterion for posting a
depiction of Pr ophet Mohammed is whether it is "fatwah-worthy," meaning
whether a Muslim cleric would issue a fatwah (edict) condemningto death the
person(s) who create and published the depiction
20, Facebook has banned Mr Walker and his hate blogfrom Facebook because
they promote hate against a religion, The Pakistan government has banned
the blog because it blasphemes the Prophet Mohammed The State
Department has condemned the blog because it creates anti-American
sentiment Osama Bin Laden has used to the blog to recruit suicide bombers
to kIll Americans in Afghanistan
21 Victim has talked to the Souther n Law Poverty Center ("SLPC'j about Mr
Walker's hate blog and his team of Muslim haters SLPC is in the process of
naming them as a hate organization that uses bullying, intimidation, threats
and violence to secure their goals
22. Victim has talked and met with numerous civil rights and national Muslim
organizations about Mr Walker's conduct, his hate blog, his malicious and
criminal conduct, and his attempt to gag Victim. They view Mr. Walker's
conduct,hate15lbgam:1 assoCiates as simiiai totnatOf tIleK1YKhixKlanaiid are""
considering a broad set oflegal actions, both criminal and civil, to dismantle
the operation.
23 L!Victim were a member of the Muslim raith, this case would be considered a
hate crime under both state and federal law
Aggravating Factors
There are numerous aggravating factors in this case that warrant robust
prosecution on Mr Walker.
24 Mr. Walker is an attorney Attorneys are bound by the Rules of Professional
Conduct to act in a professional and ethical manner. Yet he came ft om
Virginia to Maryland and assaulted Victim after stalkIng, harassing,
threatening, insulting, defaming, and dispar aging Victim for months
Brett Kimbe
25. Mr. Walker assaulted Victim in a courthouse-a place where Victim went to
seek redreSs of grievances and where he had a rightto be secure and safe
26. Mr. Walker made no amends following the assault, no apology and showed no
contrition Instead, he levictimized Victim by filing (1) a false criminal
char ge against Victim, (2) a false Peace Ordel against N.eal Rauhauser in order
to have the Sherif! corne to Victim's home to startle and harass Victim, .and (3)
a malicious $66,000,000 suit against Victim
27. Followingthe assaUlt, Mr. Walker doubled down on the harassment by
making dozens of disparaging tweets about Victim, by urging other bloggers
to attack Victim, by blogglng that Victim is "human filth," and by threatening
28. Mr Walker has repeatedly lied to every court about his conduct by attempting
to blame Victim He said that Victim made the whole thing up He said tpat he
thought the iPad was a bomb He said that Victim must have had someone
beat himup so he could go to the hospital He said that he never touched
Victim He falsely accused Victim of crimes He falsely accused Neal
Rauhauser of crimes in Order to harass Victim
Conclusion
For all the above reasons, Victim moves this Court to deny the State's nolle pros
motion and to order a trial in this case
Respectfully submitted,
~ )
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.. _ - - " ~ - - - - - ~ - " - , " - _ . __._---"_._-------- - - --- - - - --
Certificate of Service
Icertify Ipersonally served Assistant DistrlctAttorney
served Reginald SOUlS by US Mall this 19
111
dayot March. 2012
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: . DISTRICT COURT OF MARYLAND FOR
".:Jl
191 EAST JEFFERSON ST, ROCKVILLE, MD 20850 Case No, 0801SP005392012
Date: 0210812012 10:46 a m
BRETT K1MBERL.lNE vs AARON WALKER
FINAL PEACE ORDER
After the apPearanoe of the PETfnONER, and RESPONDENT, and in consideration of the Pamion and
evidence,
the Court makes the following findings:
A 1 That there is clear and convinoing eVidenoe that within 30 days before the filing of the Pelition, the
Respondent committed the following aot(s):
Hamssment
2 1hat there is clear and oonvinolng evldenoe that Respondent is IIkeiy to commit a prohibited aot in thEj future
agalnst the Petitioner
Based on lhe foregoing, the Court hereby OI'lOERS:
Unless stated otherwise below, this Order is effec\ive until 08108/2012
2 That the Respc:mdent SHALL NOT commit or lhreaten to commit any of the following acts against Petitioner:
an act whiQh o8Usesseilous bo(fily harm; an act that places the Petitioner in fear of Imminent seiious bodily
harm: essaull; rape,atlemp\edrap,e, sexual offene\', or attempted seXual offense; false impriSonment;
harassment; stalking; lrespass;or malicious dlOlslruCtion ofproperty
3 That the RespondlOlnt NOT contact (in person, by telephone, in writing, or by any other means),
attempt to contact, or harass the Petitioner
4 rhalthe Respondent SHALL Nor enler lhlOlresldence of 6REIT KIM6E;RlINE at WMEREVER l.OCATED
(Residenceiholudes yard, grounds, oulbulldlngs, and common areas surrounding Ihe dwelling)
5 That thl; Respondent SHALL SlAY AWAYfrom:
rhe Petitioner's place{s) of employment at:
WHEREVER l.OCATE;D
Date: 02/0812012
NonCE TO RE.SPONDENT
Violation of this Peaoe Order may be a crime or contempt of oourt or both, and could result In imprisonment or fine or both
PCIPO 3 (Rev 12/2004)

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DISTRICT COURT OF MARYLAND FOR Montgomery County
Located at 191 East Jefferson St, Rockville, Maryland 20850
Case No. SD00279004

Eyes: BRN Hair: BR.N
Phone(W):
Wt240
CC#: SID:
LID: DL#:
Race: 2 Sex: M. Hi: 6' 0"
DOB: Phone(H):
WALKER, AARON
MANASSAS, VA 20109
VS. STATE OF MARYLAND
COMPLAINANT:
KIMBERLIN, BRETT
BETHESDA, MD 20817
STATEMENT OF CHARGES
UPON THE FACTS CONTAINED IN THE APPLICAnON OF KIMBERLIN, BRETT IT IS FORMALLY CHARGED
THAT WALKER, AARON at the dates, times and locations specified below:
NUM CHG/CII STATUTE PENALTY DESCRIPTION OF THE CHARGE
001 20105 CJ 3-1508 90 D &Jor $1,00000
PEACE ORDER: FAIL 10COMPLY
On or About 051'22/2012 - OSn7fl.OI2
"""'111.'BETHESDA
MONTGOMERY COUNTY MARYlAND
... did failw comply with an Order dated 05-22-12, issued under1he Annotated
Code of MlIIyland, Courts & Judicial Proceedings Article, Sec 3-1504 that
ordered the respondent to refrain from committing or threatening to commit any
ofthe acts specified in Section 3-1503 of said Courts & Judicial Proceedings
Article against BREIT KIMBERlIN AND contacting. attempting to contact,
harassing BREIT KIMBERlIN
Against the Peace, Government. and Dignity of the State.
Date: 05/2712012 Time: 10:18 PM
Tracking No. 121001348322
Judicial Officer: -==-- 6610
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Case Information
Case Infonnation
DISIRICT COURT Of HAll.YI.AND

htlp://casesearch OOUlts state md jis?caseld .
Plea,
Di'>PO$ition:
toll
Court S)">t...n DISTRICT COURT FOR MONTGOMERY COUNTY. CRIMINAL SYSTEM
0lS<" Number. 50002.79004 Tracking Ng: 121001348322
C/lS<" Type: CRIMINAL
D'strict Cod,,: 06 Code: 01
OOCumel1t Type' WARRANT Issued Dale: 0512712012
c"se St<ttus: CLOSED C..se DispoSition: TRIAL
Defendillnt Information
WALKEIl" AARON
WHnE, CAUCASIAN, ASIATIC INDIAN, ARAB
Se.: III Height' 511 Weight: 200 DOB:
.Addles<;:
Clly: St.lt<ii" VA Zip Code. 201090000
-----_.--
charge and Disposition Information
CNl'ge Ne: 001 Desc!1]J!icn, PEACE ORDER: FAIL TO COMPLY
Statute: CJ..J-1508 Dt'Scrlpllon: PfACf ORDER: I'AIl TO COIllPLY
Dale: dIS Code' 20105 MOIPl.l: Cauw: X
Incident Oa:e from: OS/2212012 TO: OSIZ7/2012 Ifil:linl Ag."
OTHER. PLEA
NOLLf PROSfQUI O'''jKlSlliOlI Date:06/14j2012
Fine. $0,00 Court Ctl'5t5: $0 00 CICf: $0.00
AmtS>JSPe'(lall<l: Fine: ,000 CourtCosb, $0.00 OCF: $0.00
P6l EndDale: Probation End Date: Restitution Amotml: SO 00
),,11 Ternl: Yn>: Mos: Davs:
Suspended lerm, Y.-s: Mos: Days'
Tim<'! served:
(E1Id1 reliJrJ to !he thl>n tM Dl!1lffid.lnt is sh:Jwn)
Name:I(IMBERUN, BRl!!n
Conrl'Ctlon :COMPLAINANT
IWr>e:BOURS, IlfGINALD W DI fSQ
Connectlorl:PRIYATf ATTORNEY fOR DEfENSE
401 EAST JEfFERSON ST
SUITI! 103
City: ROCKVtlLf Slue: MD Zip Code: 2Oll.50 - 0000
_ HiIto..., JrI_
Event Date Comment
WAR! OS/27/2OU 12052.7;ZO 15 ;2;ARR;Dl2Cl3l'261-S
WARS OS/29/2OU 120529)0120372111-5;
INtT 051:19/2012 1205251;OOOOOOOO.OO;ROR ;10&, ;6612
'INs 1$ oWIll'J!1ctrotllccase ronj, FlJII at5Il QIlflO( be mJellVlIilabIe etrher or restrictions
ttl cue rer::DtTh fDvnd;, NaryIimd ruJts 16-1001 tIlrough .16-10.11, I;Jr beuuIie oFlh<! pnKtiraI dffIf<:uItirH
iJlheo "". In reducirlfl :. CiISI! rer:.oro lNl eIi!ctrorJIi:; f!1tmat
6120/20124:43 PM
II
IN THE CIRCUIT COURT FOR MONTGOMERY COUNTY, MARYLAND
BRETT KIMBERLIN,
Petitioner
v.
AARON WALKER,
Respondent
Case No. 8526D
ORDER OF COURT
UPON CONSIDERATION of the Respondent's Emergency Motion for Partial Stay
or Modification of the District Court Peace Order Pending Appeal, and the matters and
facts stated therein, it is this __day of June, 2012, by the Circuit Court for Montgomery
County, Maryland,
ORDERED that Respondent's motion to stay part of the peace order is GRANTED;
and, it is further
ORDERED that the Respondent may communicate about the Petitioner on the
internet or any other medium to a general audience, including on the Respondent's website
or Respondent's Twitter account so long as the Respondent does not threaten the
Petitioner or advocate the use of force or other violation of law against Petitioner, or
otherwise incite imminent lawless action against Petitioner, consistent with the Supreme
Court's holding in Brandenburg v. Ohio, 395 U.S.. 444, 447 (1969), and it is further,
ORDERED, that the District Court peace order shall otherwise remain in effect until
it is heard on de novo appeal on July 5,2012
JUDGE, Circuit Court for
Montgomery County, Maryland