Brett Kimberlin Amended Complaint Against Seth ocr

8/2/2019 Brett Kimberlin Amended Complaint Against Seth ocr

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IN THE CIRCillT COURT FORMONTGOMERYCOUNTY,MARYLANDBREITKIMBERLIN

Plaintiff,v.

SETIIAllENAkaANONYMOUS CYBER STALKER,SOCRA1ES,PREPOSTERICITY,DAVB FROMQUEENS2,

CaseNo. V 339254

DefendantI- -.raG:::. - - ~..,.. : , : : , u . . ~a: c : : . : . ~ : ; -.:....j-.::::I '.I:.-: ..::,:- .. '"~ ~ : : ~ o~ ~ N D E D COMPLAINT FORDAMAGESAND CTIVE RET,lEF FORSw C5 DEFAMATIO. LIBELCYBERSTALKING. ID TORTIO S

1: INTERFERENCEWITH B SINESS,

plaintiffBrettKimberlin pro se hereby files this Complaintagainst Seth aka Anonymous Cyber Stalker,

hereinafter called "Socrates;' his most common eyber srnlking name.P RTIES

1. PlaintiffBrett Kimberlin ('Kimberlin") is a resident ofMontgomery CountyMaryland

2. Defendant Socrates is an anonymous cyber stalker hiding in the shado of theInternet He was identified as SethAllen after the Court Ordered Google todisclosehis identity and Venzon complied \Vith a subpoena1yinghim to anInternetProtocol address.


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FACTS3. Kimb rIin is a private citizen who has worked at the same job for at least seven

years as the director ofa non profit public charity called Justice Through Music,whose mission is to use inspire young people to get engagedwithprogressi esocial causes.

4. In 2005, Justice Through Music co-founded a public charity caIled VelvetRevolution with another co-founder called The BradBlog to focus on electionprotection and accountability issues.

5. On or about 2007, Socrates started making anonymous posts on various nationalwebsites and forums attacking the editor ofThe Brad Blog with anti-Semitic slursand other false and defamatoryaccusations.

6. Socrates' attacks quickly becamemore personal, calling the editor a c.


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11. Socrates then began posting on various national Internet sites that TheBradBlogeditor was connected to a convicted felon namedBrettKimberlin.

U. From 200& through October 2010. Socrates has made scores ofanonymous postson numerous nati :ebsites accusingKimberlin.ofmurder, pedophili"a, and ahost ofo1herunspeakable crimes, with each postmentioning TheBradBlog

13. From 2008 through 2010, Socrateswas banned by many national websites onwhich he has posted aboutKimberlin because those posts violated the terms ofservice by being defamatory, threatening and harassing.

14. Socrates bas been banned from posting on TheBradBlog,DemocraticUnderground, Daily Kos, Raw Story and others.

15. Onmany occasions, after Socmtes was banned for his threatening posts, he re-registered under a different name or names and posted evenmore threateningposts. These names includedPrepostericity and these names and their IPaddresses w e ~ e also banned from the sites.

16. When Socrates was banned from a website, he threatened the editors of thosewebsites \\lithmore anonymous emails and posts.

17. Several other peoplehave contacted Kimberlinwho have been threatened andharassed by Socrates to the point that they feel their lives are in danger.

18. Kimberlin has been told that by other injured parties that they have attempted toseek protection from law enforcement and through the civil process but have beenunable to learn who Socrates is.


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19. 'W"hen ocrates could no longer postharassing attacks againstKimberlin onlegitimate websites, he startedhis own blog inMarch2009 on Google'sBLOGGER site, "', . .blogger.oom.

20. Socrates named his site htlIr//davefromqueens2.blogsootcoml.21. SinceMarch 2009, Socrateshas anonymously posted dozens of harassing,

defamatory, threatening attacks againstKimberlin, the editor ofThe Brad Blogand other editors who have banned or exposed him..

22. Socrates has falsely accused Kimberlin ofmurder, pedophilia, financial scamming,hoaxing, wild conspiracies, con artistry, ~ - S e m i t i s m , and being a rip of f

23. On September 10,2010, Socrates titled a post" ...BrettKimberlin CanRun,But.. .Can'tHide," in which he concluded: "To BrettKimberlin, the world knowsyou are the ultimate scumbag. We know you're a liar, conman, murderer ofCarlDelong's spirit and most probably involved with JuliaScypher's d andbasically the personification of scum...

24. Socrates has attackedKimberlin's personal cha:racterand business practices andposted hundreds of insults, false statements and negative comments on numerouswebsites and Internet forums in order to harm and interferewithKimberlin'sbusiness and causehim suffering, opprobrium and humiliation.

25. Socrates has maliciously engaged in a three-year campaign against Kimberlin ofintentional harassment, eyber bullying, Internet defamation, online harassment andcyberterrorism by accusing him of illegal, immoral andunethical conduct in orderto harm Kimberlin's personal and professlonal reputation.


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26. Socrates has engaged in Internet hOeI by publishing his defiunatory statementswith the intent to cause Kimberlin harm to his personal and business reputation.

27. The harassing and defamatory posts by Socrates against Kimberlin have beenreposted by Internet search engines andhave been viewed by others.

28. Kimberlin has received threats to his life because of the defamatory and harassingposts by Socrates.

29. Kimberlin has had to respond to repeated questions by business associates ando1hers about the false statements made by Socrates.

30. Socrates has contacted at least one oftbe funders ofKimberlin's business usingthe name STruth40 to intimidate her and pressure her to stop funding the business.

CO 1Defamation and Libel

31. Paragraphs I-29 above arehereby adopted and incorporated into all counts of thisComplaint

32. Socrates has encoa.e.oed in a three-year campaign of defamation against Kimberlinthrough dozens of false Internet postings.

33. The false statements made by Socrates were published on the World Wide Web,\hich constitutes libeL

34. Socrates' posting and actions were malicious and intentional and done with anintent to cause harm.


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.'!I':=.

COUNT IIHarassmentand lolation ofPrivacy

35. Socrates has in1entionally harassed, annoyed, stalked, 1hreatened, and attackedKimberlin with scores of false, insulting, annoying, and threatening Internetpostings over a tbrec>year period.

36. The posts made by Socrates constitutedmalicious harassment ofKimbertin andviolated his privacy, and caused unknown parties to make threats againstKimberlin.

COUNTIDInterfereneewith Business

37. Socrates repeatedly, over a three-year period, made Internet postings in order toharmKimberlin's business relationships, to stop people from supporting hisbusiness enterprise, and to create doubts about his business in order to hannKimberlin.WHEREFORE, Kimberlin prays that the Court grant the following relief:a. Find that Socrates has defamed and hOOled Kimberlin.b. Find that Socrates has harassed and cyber stalkedKimberlin, and violated his

privacy.c. Find that Socrates has interferedwith Kimberlin's business and business

relationships.


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d. Issue a Cease andDesistOrder a.:,

Brett Kimberlin Amended Complaint Against Seth ocr

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