Brett Kimberlin Complaint Against Seth Allen01 (OCR)

8/2/2019 Brett Kimberlin Complaint Against Seth Allen01 (OCR)

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COM.PLAlNT FOR DAMAGES AND lNJU CTIVE RELIEF FORDEFAMATION,LIBEL CYBERSTALKING.AND TORTIOUSINTERFERE CEWITH BUSlNESS,

iN T.H.E CIRCUIT COURT .FOR MONTGOMERY COUNTY,MARYLANDBRETTKIMBERLIN

Case No.ANONYMOUS CYBERSTALKERAkaSOCRATES,PREPOS1ERICITY,DAVEFROM QUEENS2.,v(""\.\


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whose mission is 10 use inspire youngpeople to get engagedwith progressivet

social causes.4. In 2005, Justice Through Music co-founded a public charity called Velvet

Revolutionwith another co-founder called The BradBlog to focus on electionprotection and accountability issues.5. On or about2007, Socrates started making anonymous posts on various national

websites and forums attacking the editor ofThe BradBlogwith. anti-Semitic slursand other false and defamatory accusations.

6. Socrates' attacks quickly became more personal, calling the editor a "strawman,""stupid," "'a fake progressive," "a scammer" and a "stale act"7. Socrates' attacks ~ c k l y escalated and spread to the moderators at The BradBlog

and then to otherpeople associatedwith th e editor.8. Socrates' became obsessedwith the The Brad Blog editor and starteddigging into

everything about him.9. Socrates discovered that The BradBlog co-founded VelvetRevolutionwith

Justice Through Music, and that Kimberlin was the director of Justice ThroughMusic.10. Socrates then began digging intoKimberlinand discovered that hehad been

arrested and convicted for a crime that occurred 31 years ago.11. Socrates then began posting on various national Internet sites that The Brad Blog

editorwas connected to a convicted felon namedBrettKimberlin.12. From 2008 through October 2010, Socrates has made scores ofanonymous posts

on numerous national websites accusing Kimberlin ofmurder, pedophilia, and a


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. / " - - .

host ofotherunspeakable c r i m e s ~ with each postmentiomng The BradBlogeditor.

13. From 2008 through2010, Socrates was banned by every national website onwhich he has posted aboutKimberlin because those posts violated the tenns ofservice by being defamatory, threatening and harassing.

14. Socrates has been banned from posting on The BradBlog,DemocraticUnderground, Daily Kos, Raw Story and others.

15. Onmany occasions, after Socrates was banned for his threateningposts, he re-registered under a differentname or names and posted evenmore threateningposts. These names includedPrepostericity, and these names and their IPaddresses were also banned from the sites.

16. WhenSocrates was banned from a w e b s i t e ~ he threatened the editors of thosewebsites withmore anonymous emails and posts.

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

18. Kimberlin has been told that by some of thesepeople that they have attempted toseek protection from law enforcement and through the civil process buthave beenunable to learnwho Socrates is.

19. When Socrates could no longer post harassing attacks against Kimberlin onlegitimate websites, he started his own blog inMarch 2009 on GoogIe'sBLOOGER s i t e ~ ,,"y\vw.blogger.com.

20. Socrates namedhis site http://davefromaueens2.blof!SOOlcom/.


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

29. Kimberlin has had to respond to repeated questions by business associates and

others about the false statements made by Socrates.COUNT 1

Defamation and Libel30. Paragraphs 1-29 above are hereby adopted and incorporated into all counts ofthis

Complaint31. Socrates has engaged in a three-year campaign of defamation againstKimberlin

through dozens of false Internet postings.32. The false statements made by Socrates were published on the World Wide Web,

which constitutes libel.33. Socrates' posting and actions weremalicious and intentional and done with an

intent to cause harm.CO ' 'I ' ll

.Harassment and Violation of Privacy34. Socrates has intentionally h a r a s s ~ annoyed, stalked, threatened, and attacked

Kimberlin with scores of false, i n s u l t i n g ~ annoying, and threatening Internetpostings over a three-yearperiod

35. The posts made by Socrates constituted malicious harassmentofKimberlin andviolated his privacy, and caused unknown parties to make tbreats againstKimberlin.


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COU Til lInterference with Business

36. Socrates repeatedly) over a three-year period,made 1n1emet postings in order tohannKimberlin's business relationships, to stop people from supporting hisbusiness enterprise, and to create doubts about his business in order to harmKimberlin.WHEREFORE,Kimberlin prays that the Comt grant the following reliefa. Find that Socrates has defamed and heeledKimberlin.b. Find that Socrates has harassed and cyber stalked K i m b e r ~ and violated his

pnvacy.c. Find that Socrates has interferedwithKimberlin's business and business

relationships.d Issue a Cease and Desist Order against Socrates prohibiting him from writing

about, contacting, contacting other people about, or having anything to do withKimberlin.

e. Issue anOrder to remove all references to Kimberlin on Socrates' GoogleBlogger page.

f. En1erjudgment in favor ofKimberlin in the amount o f $ J ~ O , O O O incompensato damages.

g. Enter judgment in favor onKimberlin in the anlOlmt of 1,000,000 in punitivedamages.


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h. Such other and further relief as the Com deems appropriate.Respectfully ~ ' l } f t f i ~

Brett Kimberlin Complaint Against Seth Allen01 (OCR)

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