ecf 236 main

BRETT KIMBERLINPlaintiff

v

NATIONAL BLOGGERS CLUB et alDefendants

FiLEDUS ~STRCT CiUin

DISTRICT OF ILrYLMIO

20i5 Jp -5 PH 1234C~E(J Off ICEio-T EREEi-l3ELTTHE UNITEDSTATES S mCT COURT

FORTHEDISTIllCT ~NoSOUTHERNDIVISION

Case No 13-CV-03059-GJR

DEFENDANTROGES REPLY TO ECF No 231 PLAINTIFFS OMNIBUSOPPOSITION TOMOTIONSTO DISMISS

COMESNOWWilliam John Joseph Rage replying to Plaintiffs Omnibus Opposition

to Motions to Dismiss (ECF No 231) In reply Mr Rage reaffirms the contents of his

Motion to Dismiss (ECF No 149) and states as follows

INTRODUCTION

Plaintiffs Omnibus Opposition (OmnibusOp) amounts to an inartfully

camouflaged third amended complaint It is well-established however that a plaintiff

cannot amend his or her complaint through the use of opposition briefs Solomon v

Capital One Banh USA Case No 14-CV-03638-GJR (DMd 2014) ECF No 15 n 2

Rather than properly address the deficiencies noted by the various motions to dismiss the

Second Amended Complaint (ECF No135) (SAC) Plaintiff has offered new allegations in

Case 813-cv-03059-GJH Document 236 Filed 010515 of 16

an attempt to shore up his collapsing case Since the Court ordered that there should be

no further amendments to the complaint (See ECF No 88 at 5) those new allegations

should be disregarded Allegations in the OmnibusOp that are new with respect to Mr

Hoge include but are not limited to-

i) Defrauding some unspecified victims of over $100000 (1 3)

ii) Lying to the FBI (1 3)

iii) Conspiring to use the fraudulent NBC to direct a campaign of destruction

against Plaintiff (1 12)

iv) Some of the Defendants have come to Plaintiffs home (~ 20)

v) Hoge ha[s] stated many times that [he]want[s] to destroy the non-profits

by stopping their funding (1 36) and

vi) Clearly Defendant[] Hoge conspired with Frey to violate Plaintiffs civil

rights (1 78)

In addition to being new those allegations are false

Plaintiffs OmnibusOp fails to address points raised in Mr Hoges Motion to

Dismiss (ECF No 149) (MTD)concerning res judicata resulting from the related lawsuit

Kimberlin u Walfler et al Case No 380966V (Md CirCt Mont Co 2014) Further the

OmnibusOp ignores the SACs lack of specificity related to damages and allegation of the

elements of various torts and crimes It completely ignores the lack of diversity of

citizenship between Plaintiff and Mr Hoge It similarly avoids the topic of Plaintiffs bad

2

Case 813-cv-03059-GJH Document 236 Filed 010515 Page 2 of 16

faith in his conduct of the instant lawsuit On the other hand Plaintiff has gone to some

length to cite overturned case law as controlling authority and has brazenly

misrepresented at least one case cited Plaintiffs case is not viable and should be

dismissed with prejudice

KIMBERLIN V WALKER ET AL AND RES JUDICATA

Because of the results of a related lawsuit all of Plaintiffs claims against Mr Roge

are barred by res judicata under Maryland law [T]he federal court for the District of

Maryland must give to a prior Maryland state court judgment whatever res judicata effect

Maryland law or usage provides[] J Aron and Co Inc v Service Transp Co 515

FSupp 428 438 (DMd 1981)

In his Reply to Plaintiffs Oppositions to the Motions to Dismiss the First Amended

Complaint (ECF No 56) Mr Roge noted that [i]f Plaintiff can make a valid case under

state law he can go forward in the courts ofMaryland where a related case is already in

progress ECF No 56 at 23 Plaintiff did go forward against Mr Roge with that related

case Kimberlin v Wal1~eret al and Plaintiff lost While ordering a directed verdict in

Mr Roges favor Judge Eric Johnson found that Plaintiff had not produced a scintilla of

evidence to support his claims in that related case See transcript in Exhibit B-2 at 266

Judge Terrence McGann had previously dismissed most of the claims in the Walher et al

3


suit via summary judgment See MTD Ex C Summary judgment constitutes an

adjudication on the merits as fully and completely as if the order had been entered after

trial Lawlor v National Screen Service Corp 349 US 322 327 (1955)

Under Maryland law res judicata bars a second suit involving the same parties if

there exists a judgment on the merits in the prior suit Alvey v Alvey 225 Md 386 390

(1961) The doctrine bars a subsequent lawsuit when

(1) the parties in the present litigation are the same or in privity with theparties to the earlier litigation (2) the claim presented in the currentaction is identical to that determined or that which could have been raisedand determined in the prior litigation and (3) there was a final judgmenton the merits in the prior litigation

Chew v Green et al Case No 13-CV-02115-DKC(DMd 2014) ECF No 52 at 14 citing

Cochran v Griffith Energy 426 Md 134 140 (2012)1

With respect to the first and third points of the formula given in Cochran Plaintiff

and Mr Roge were adverse parties in Kimberlin v Wallwr et al and the judgments in

Mr Roges favor (via trial and summary judgment) were on the merits of that case

With respect to the second point Plaintiff did not raise any claim in the instant

lawsuit that he could not have also included in his state case Indeed he filed his second

I Given that the SAC asserts that all of the defendants are co-conspirators res judicatashould be applicable to each of them also because alleged co-conspirators named in alawsuit are considered to be in privity for the purpose of res judicata See eg RSM ProdCorp v Freshfields Brucllhaus Deringer US LLP 800 F Supp 2d 182 193194 (DDC2011) Gambocz v Yelencsics 468 F2d 837 841 (3d Cir 1972) and Airframe Sys Inc V

Raytheon Co 601 F3d 9 17 (1st Cir 2010)

4


(and final) amended complaint in the state suit after the SACwas filed in this lawsuit2

Exhibit C The state suit could have encompassed his federal claims as well because

Maryland courts have heard RICO and 42 USC SS1983 and 1985 claims See Chevy

Chase Banll v Chaires 350 Md 716 (1998)Ritchie v Donnelly 597 A2d 432 (1991) and

De Bleecher v Montgomery County 292 Md 498 (1982) as examples ofMaryland courts

hearing claims based on RICO S1983 and S 1985 respectively Furthermore this Court

has specifically applied res judicata to a S 1983 claim that could have been filed in a

Maryland court Mears v Town of Oxford 762 F2d 368 373 (DMd 1985) Logically the

Court should also apply res judicata to the RICO and S 1985 claims as well as all of

Plaintiffs state law claims

Even if the complaints allegations were well-pleaded and they are not the case is

barred by res judicata That is a sufficient reason to dismiss the instant lawsuit and

judicial economy suggests dismissal for all defendants based on res judicata

2 The SAC in the instant lawsuit was filed on 7 March 2014 The second amendedcomplaint in the state lawsuit was filed on 1April 2014 In the SAC for the instant caseshe identified Kimberlin Unmasked as Lynn Thomas In the second amended complaintfor the state case he identified Kimberlin Unmasked as Lynn Thomas and Peter lIaloneClearly Plaintiff was adding to the state case and he could have included the RICO civilrights and other state laws claims

5


PLAINTIFF HAS LEFT POINTS FROll MR HOGES MTD UNANSWERED

First among these unanswered points is the question of whether lacking a viable

federal claim the Court should have jurisdiction under 28 USC S 1367(a) with respect to

Mr Hoge Plaintiff and Mr Hoge are both residents ofMaryland As noted in Mr Hoges

MTD

Plaintiffs fails to state a claim upon which relief can be granted on any ofhis RICO or civil rights claims leaving him with no federal questionsbefore the Court He cannot rely on diversity of citizenship Thus theCourt should not have jurisdiction pursuant to 28 USC SS 133101 1332Lacking that jurisdiction the Court should not assert jurisdiction over thestate law claims pursuant to S 1367(a) Therefore the Court shoulddismiss the instant lawsuit for lack of subject matter jurisdiction pursuantto Fed R Civ P 12(b)(1)

MTD 2

The Court should take Plaintiffs lack of a cogent answer as his admission that the

lawsuit should be dismissed at least with respect to Mr Hoge because his federal claims

fail resulting in a lack of diversity of citizenship Thus dismissal with respect to Mr

Hoge is proper pursuant to Fed R Civ P 12(b)(1)

Mr Hoges MTD details significant failings in the SAC to properly state a case for

the Plaintiff Plaintiffs OmnibusOp merely repeats the same debunked allegations

without showing how the SACmakes sufficiently specific allegations of the elements of the

various torts and crimes To briefly summarize the main points from the MTD which were

not addressed-

6


i) The First Claim (RICO) fails to specify any damage to business or property

and fails to specify any act by Mr Hoge that might have injured Plaintiff

ii) The Second Claim (42 USC i 1983) does not apply to Mr Hoge but he notes

that Plaintiff fails to specify what acts done by Defendant Frey in his capacity as a

Deputy District Attorney might have injured Plaintiff

iii) The Third Claim (42 USC i 1985) does not specify any federal nexus or

invidious discrimination or any act by Mr Hoge that might have injured Plaintiff

iv) The Fourth Claim (Defamation) is barred by the statue of limitations

v) The Fifth Claim (False Light) is barred by the statue of limitations

vi) The Sixth Claim does not apply to Mr Hoge

vii) The first Seventh Claim (Interference With Prospective Economic

Advantage [sic]) fails to specify any act by Mr Hoge that might have caused

damage to Plaintiff and fails to specify what damages he allegedly suffered

viii) The second Seventh Claim does not apply to Mr Hoge

ix) The Eight Claim (Intentional Infliction of Emotional Distress) is barred by

collateral estoppel because of summary judgment in Kimberlin v Walller et al

x) The Ninth Claim (Conspiracy) alleges something that is not a tort

All these problems existed with Plaintifflawsuit before he lost the related state trial and

before his entire case was thus affected by res judicata

Again the Court should take Plaintiffs failure to answer as Plaintiffs admission

7


that Mr Hoges arguments are correct and that Plaintiffs case is deficient Plaintiff has

failed to state a claim upon which relief can be granted and dismissal pursuant to Fed R

Civ P 12(b)(6) is proper

GIVEN PLAINTIFFS CONTINUED BAD FAITH DISMISSAL PURSUANT TORULE 41(b) IS ApPROPRIATE

As Mr Hoge noted in his MTD (1 61) the Court has the authority under Fed R

Civ P 41 and the inherent power under US v Hudson 11 US 32 34 (1812) to dismiss a

lawsuit with prejudice where a plaintiff engages in misconduct constituting a violation of

the Courts rules or a court order-as has repeatedly been the case with Plaintiff Plaintiff

is a convicted perjurer3 He has admitted attempting to defraud this Court in the instant

lawsuit by forging a summonsl and he has denied making that admission to a Maryland

state court He has admitted to spoliation of evidence related to the instant lawsuit6

The deficiencies in the OmnibusOp are in a document that Plaintiff produced after

3 See US v Kimberlin 805 F2d 210 234 (7th Cir 1986)

See ECF No 102

5 See MTD Ex D D-1 and D-2 Plaintiff sued Mr Hoge and Messrs Walker McCainand Akbar and Ms Thomas in the related case in the Circuit Court for MontgomeryCounty (Case No 380966V) Plaintiff denied making the admission found in ECF No 102in his response to a Request for Admissions during discovery in that matter

6 See ECF No 124 A full transcript of the state court hearing is attached to thatmemorandum Plaintiff has sought to use the same altered Certified Mail green card atissue in the state suit as proof of service in the instant lawsuit

8


two extensions of time (See ECF Nos 133 and 211) The slapdash nature of Plaintiffs

OmnibusOp taken together with his repeated foot dragging is in line with his previously

stated goal of using lawfare to inflict punishment on his perceived enemies and is further

evidence of his bad faith in the conduct of the instant lawsuit Plaintiff outlined his

vexatious strategy at the conclusion of the Kimberlin v Walher et al trial on 12August

2014 when he stated the following in an interview conducted by Dave Weigel of The Daily

Beast

And tomorrow I can file another lawsuit against them And now I knowwhat I need to do Its going to be endless lawsuits for the rest of theirlives

httowwwthedailybeastcoma rticles20 140830the -weird est-storv -about-a-conserva tive-

obsession-a -convicted-bornber-and -taylor-swift- you-have-ever-readhtml retrieved 20

December 2014 Further in his letter to this Court dated August 28 2014 Plaintiff

wrote

I now state for the record that I have decided to file a separate federallawsuit against those defendants for conduct outside the current case andI will file a preliminary injunction motion under that case number

ECF No 192 Plaintiffs clearly stated intention to subject the Defendants to vexatious

litigation for the rest of their lives is surely an example of bad faith

Plaintiffs actions are not the missteps of an inexperienced pro se litigant Judge

Titus noted a Memorandum Opinion in the related copyright lawsuit Plaintiff filed against

now-dismissed Defendant Kimberlin Unmasked that Plaintiff is no stranger to the

9


processes of this Court Kimberlin v Anonymous Blogger Unmasked 13-CV-02580-RWT

(DMd 2014) ECF No 12 at 2

Plaintiff has put nothing in the OmnibusOp attempting to explain why dismissal

pursuant to Fed R Civ P 41(b) is not fully justified Given the bad faith Plaintiff has

Judge Titus continues detailing Plaintiffs extensive history oflitigation in this Court-

Following his conviction in the United States District Court for theSouthern District of Indiana for possession of a firearm not registered tohim manufacture of a firearm maliciously damaging by explosion theproperty of an entity receiving federal financial assistance and damagingproperty of a business used in and effecting interstate commerce whichwas affirmed in United States v Kimberlin 805 F2d 210 (1986) hecommenced numerous cases in this Court against the United StatesParole Commission in Brett CKimberlin v Department of Justice andUS Parole Commission CaseNo898-cv-00730-AW Brett Kimberlin vUnited States Parole Commission et al CaseNo 897-cv-03829-AWBrettCKimberlin v United States Parole Commission Case No 897-cv-02066-AWBrett CKimberlin v US Parole Commission et al Case No 897-cv-01687-AW and Brett CKimberlin v United States Parole CommissionCaseNo 897-cv-00431-AW apparently in relation to his efforts to beparoled from his conviction affirmed by the 7th Circuit in 1986 Followinghis release on parole he also brought an action in this Court which wastreated as an effort to overturn his Indiana conviction under 28 UsC l2255 His petition was denied and the denial was affirmed by the 4thCircuit Brett CKimberlin v Warden Case No 804-cv-02881-AWFinally he has been involved in litigation concerning his personalbankruptcy in this Court Brett Coleman Kimberlin v USA v In Re BrettColeman Kimberlin v James Turner Case No 898-cv-03586-AWandBrett Kimberlin v US Tmstee Case No 898-cv-00490-AW Recently hebrought another action in this Court against numerous Defendantsalleging that they had been engaged in a RICO conspiracy a case whichremains pending of this date Brett Kimberlin v National Bloggers Clubet al Case No 813-cv-03059-PG

Kimberlin v Anonymous Blogger Unmaslzed 13-CV-02580-RWT (DMd 2014) ECF No 12at 2 3

10


demonstrated to date and the frauds he has attempted to perpetrate on the Court8 the

Court should dismiss with prejudice on those grounds

PLAINTIFF HAS TRIED TO ALLEGE FACTS THAT ARE FACIALLY FALSE

As a rule factual contentions in a complaint are assumed to be true However

there are exceptions when a complaint is not well-pleaded and [p]rinciples requiring

generous construction ofpro se complaints are not without limits Beaudett v City of

Hampton 775 F2d 1274 1278 (4th Cir 1985) Courts cannot be expected to conjure up

questions never squarely presented to them District judges are not mind readers Id A

complaint must met the pleading requirements ofAshcroft v Iqbal 556 US 662 (2009)

and it must show that there is federal subject matter jurisdiction Weller v Dept of Soc

Servo for City of Baltimore 901 F 2d 387 390-391 (4th Cir 1990) Also [i]n deciding a

motion to dismiss the Court should first review the complaint to determine which

pleadings are entitled to the assumption of truth Solomon (supra) at 3

Additionally Fed R Civ P 1l(b)(3) requires that factual contentions have

8 See eg ECF No 41 at 2-5 for a description of the forged summons sent to DefendantTwitchy Alteration of a Certified Mail green card to support false proof of service isdocumented in ECF No 124 Additional documentation of altered green cards related tothe instant lawsuit is found in Kimberlin V Anonymous Blogger Unmaslled 13-CV-02580-RWT (DMd 2014) ECF No 19 11 8-18 More recently Plaintiff has claimed onCertificates of Service to have mailed court papers on dates contradicted by the postmarkson the mail pieces See Exhibit A

11


evidentiary support Plaintiff has not even taken care to use evidence tha t supports his

allegations Indeed much ofwhat he has cited contradicts his claims For example

consider paragraph 68 in the OmnibusOp which is self-contradictory In that paragraph

Plaintiff writes

In a 2012 letter to Defendant Walkers attorney Defendant Freyrepeatedly relied on his official position as an Assistant District Attorneyto argue that Plaintiff committed crimes including swattings and shouldbe in prison

OmnibusOp 1 68 He then quotes Mr Frey as writing

I am writing this letter not as a member of the District AttorneysOffice but as a private citizen who has witnessed months ofharassment dishonest and indeed criminal conduct by the violentcriminal Brett Kimberlin

ld (emphasis added) See also OmnibusOp Ex 8 [W]hen a complaint contains

inconsistent and self-contradictory statements it fails to state a claim Hosaell v

Utopian Wireless Corp Case No 11-CV-00420-DKC(DMd 2011) ECF No 15 at 12

There are enough instances of such self-contradictory allegations throughout

Plaintiffs filings in the instant lawsuifJ that the Court should be justified in questioning

whether anything he says is plausible on its face

The Beaudett court was faced with trying to piece together a case from sentence

fragments The obscurity of the instant lawsuits SAC is caused by its verbosity In order

to plead his case Plaintiff must give the Court a short and plain statement of the claim

9 See eg ECF No 56 at 15-22

12


showing that [he] is entitled to relief per Fed R Civ P 8(a)(2) At 82 pages the SAC is

not short and with the inclusion of wild conspiracy theories (eg the Team Themis yarn

SAC I~33-36) it isnt plainPlaintiffs frivolous allegations based on factless facts do not add up to a lawsuit

that states a claim upon which relief can be granted The instant lawsuit should be

dismissed

PLAINTIFF WANTS THE COURT TO IGNORE CONTROLLING PRECEDENTS

In an unnumbered paragraph (OmnibusOp at 1) Plaintiff cites Conley v Gibson

355 US 41 (1957) as the standard by which his allegations should be considered As this

Court knows the Supreme Court has tightened that standard first via Bell Atlantic Corp

v Twombly 550 US 544 (2007) and subsequently via Ashcroft v Iqbal 556 US 662

(2009) Mere arm waving while reciting formulaic descriptions of torts is no longer

satisfactory As has been cited in thousands of briefs over the past five years Threadbare

recitals of the elements of a cause of action supported by mere conclusory statements do

not suffice Iqbal at 678

Plaintiffs most egregious misrepresentation of case law in the OmnibusOp is found

in paragraph 26 Although his error was pointed out months ago in more than one

defendants motion to dismiss (See eg ECF No 55 at 27 and ECF No 56 at 9 10)

13


Plaintiff continues to cite Allen v Bethlehem Steel Corp as a Maryland Court ofAppeals

case It is not It is a Court of Special Appeals decision as can be seen in the correct

citation forAllen 76 Md App 642 (1988) Because Allen is neither a decision by the

Court of Appeals nor this Court nor the Fourth Circuit nor the Supreme Court it is not a

precedent for this Court Smith v Esquire Inc 494 FSupp 967 (DMd 1980) remains

the case law this Court should followwith respect to a one-year statute of limitation on

false light claims

Plaintiffs frivolous arguments based on lawless law do not add up to a lawsuit


dismissed

CONCLUSION

Plaintiff filed the instant lawsuit on 15 October 2013 Over a year has gone by and

the case has not progressed beyond the motions to dismiss Plaintiff has not made a single

viable claim upon which relief can be granted He has engaged in fraud upon the Court as

he pursued this case in bad faith He lost the related state case against Mr Hoge and

now his claims against Mr Hoge are barred by res judicata Enough is enough Its time

to put an end to this vexatious farce

Therefore Mr Hoge asks the Court to

14


i) Dismiss the instant lawsuit with prejudice

ii) Find that Plaintiffs reputation is such that he is defamation proof

iii) Find that Plaintiff is a vexatious litigant and order that he shall not be

permitted to file any further lawsuits against Mr Roge without pre-clearance by a

Magistrate Judge

iv) Order Plaintiff to pay Mr Roges reasonable costs and expenses incurred

defending the instant lawsuit and

v) Order such other relief as the Court may deem appropriate and just

Additionally should the Court dismiss the instant lawsuit Mr Roge asks that he be

allowed to present evidence to the Court relating to sanctions against Plaintiff

5 January 2015 Respectfully submitted

Wi ohn20 Ridge RoadWestminster Maryland 21157himselfwjjhogecom(410) 596-2854

VERIFICATION

I certify that all the foregoing is true and correct to the best of my knowledge andbelief and that all copies are true and accurate reproductions of the originals

15


CERTIFICATE OF SERVICE

I certify that on the 5th day of January 2015 I served a copy of this Reply on BrettKimberlin by First Class U S Mail and by electronic means on all counsels of recordAaron Walker Robert Stacy McCain Ali Akbar and Lee Stranah n

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an attempt to shore up his collapsing case Since the Court ordered that there should be

no further amendments to the complaint (See ECF No 88 at 5) those new allegations

should be disregarded Allegations in the OmnibusOp that are new with respect to Mr

Hoge include but are not limited to-

i) Defrauding some unspecified victims of over $100000 (1 3)

ii) Lying to the FBI (1 3)

iii) Conspiring to use the fraudulent NBC to direct a campaign of destruction

against Plaintiff (1 12)

iv) Some of the Defendants have come to Plaintiffs home (~ 20)

v) Hoge ha[s] stated many times that [he]want[s] to destroy the non-profits

by stopping their funding (1 36) and

vi) Clearly Defendant[] Hoge conspired with Frey to violate Plaintiffs civil

rights (1 78)

In addition to being new those allegations are false

Plaintiffs OmnibusOp fails to address points raised in Mr Hoges Motion to

Dismiss (ECF No 149) (MTD)concerning res judicata resulting from the related lawsuit

Kimberlin u Walfler et al Case No 380966V (Md CirCt Mont Co 2014) Further the

OmnibusOp ignores the SACs lack of specificity related to damages and allegation of the

elements of various torts and crimes It completely ignores the lack of diversity of

citizenship between Plaintiff and Mr Hoge It similarly avoids the topic of Plaintiffs bad

2











FSupp 428 438 (DMd 1981)









3


















4
















5






MTD


MTD 2









not addressed-

6






















7















See ECF No 102



8








Beast





wrote







9









10

















11





Plaintiff writes














12






dismissed













13








false light claims



dismissed

CONCLUSION








14






Magistrate Judge








VERIFICATION


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FSupp 428 438 (DMd 1981)









3


















4
















5






MTD


MTD 2









not addressed-

6






















7















See ECF No 102



8








Beast





wrote







9









10

















11





Plaintiff writes














12






dismissed













13








false light claims



dismissed

CONCLUSION








14






Magistrate Judge








VERIFICATION


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00000001

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4
















5






MTD


MTD 2









not addressed-

6






















7















See ECF No 102



8








Beast





wrote







9









10

















11





Plaintiff writes














12






dismissed













13








false light claims



dismissed

CONCLUSION








14






Magistrate Judge








VERIFICATION


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5






MTD


MTD 2









not addressed-

6






















7















See ECF No 102



8








Beast





wrote







9









10

















11





Plaintiff writes














12






dismissed













13








false light claims



dismissed

CONCLUSION








14






Magistrate Judge








VERIFICATION


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MTD


MTD 2









not addressed-

6






















7















See ECF No 102



8








Beast





wrote







9









10

















11





Plaintiff writes














12






dismissed













13








false light claims



dismissed

CONCLUSION








14






Magistrate Judge








VERIFICATION


15




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7















See ECF No 102



8








Beast





wrote







9









10

















11





Plaintiff writes














12






dismissed













13








false light claims



dismissed

CONCLUSION








14






Magistrate Judge








VERIFICATION


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See ECF No 102



8








Beast





wrote







9









10

















11





Plaintiff writes














12






dismissed













13








false light claims



dismissed

CONCLUSION








14






Magistrate Judge








VERIFICATION


15




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Beast





wrote







9









10

















11





Plaintiff writes














12






dismissed













13








false light claims



dismissed

CONCLUSION








14






Magistrate Judge








VERIFICATION


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10

















11





Plaintiff writes














12






dismissed













13








false light claims



dismissed

CONCLUSION








14






Magistrate Judge








VERIFICATION


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11





Plaintiff writes














12






dismissed













13








false light claims



dismissed

CONCLUSION








14






Magistrate Judge








VERIFICATION


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Plaintiff writes














12






dismissed













13








false light claims



dismissed

CONCLUSION








14






Magistrate Judge








VERIFICATION


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dismissed













13








false light claims



dismissed

CONCLUSION








14






Magistrate Judge








VERIFICATION


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false light claims



dismissed

CONCLUSION








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Magistrate Judge








VERIFICATION


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Magistrate Judge








VERIFICATION


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ecf 236 main

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