.

-,

Case 8:13-cv-03059-GJH Document 308 Filed 09/17/15 Page 1 of 2

U.S.li1.
, .. '" ! J 11:T
DISTRICT C;- ,:,'.:', ,'Ui;O
j

UNITED STATES DISTRICT COURT

DISTRICT OF MARYLAND
BRETT KIMBERLIN,
Plaintiff,

ZQ!5SEP 17 PH 2: 02

No. GJH 13 3059

PARTICK FREY,
Defendant.
MOTION TO EXTEND TIME FOR DISCOVERY
Now comes Plaintiff Brett Kimberlin and moves this Court to extend discovery in
this case until February 15, 2016. In support of this motion, Plaintiff states:
1. This Court issued an initial order for discovery to be completed
September,

by

2015.

2. Defendant has not complied with Plaintiffs request for documents,

interrogatories

or despostion.

He finally filed for a protective

order a few

weeks ago blaming Plaintiff for the lack of discovery because he would not
agree to the protective

order.

3. Defendant Frey is apparently

trying to run out the discovery clock for a

tactical advantage.
4. Beginning on June 1, 2015, Plaintiff has repeatedly
a half dozen subpoenas

asked this Court to issue

that are necessary for discovery but this Court has

not acted on those requests.

5. Plaintiff has filed a motion with this Court to expedite discovery by allowing
him to issue his own subpoenas.
Wherefore,

The Court has not yet acted on that motion.

for all the foregoing reasons, Plaintiff moves this Court to extend the

time for discovery in this case to and including February 15, 2016.

.....

Case 8:13-cv-03059-GJH Document 308 Filed 09/17/15 Page 2 of 2

Brett Kimberlin

I certify that I emailed a copy of this motion to attorney Ron Coleman this
day of September, 2015.

~
Brett Kimberlin

Certificate of Service

~?

Case 8:13-cv-03059-GJH Document 308-1 Filed 09/17/15 Page 1 of 7

AO 88B (Rev. 02114) Subpoena to Produce Documents. Infonnation. or Objects or to Permit Inspection of Premises in a Civil Action

UNITED STATES DISTRICT COURT

for the

El

District of Maryland
Brett Kimberlin

)
)
)
)
)
)

Plain/iff

v.

Patrick Frey
Defendanl

il.S.:;: ; i~.. ~. r f l..;,~f

DISTRI:;T U ,I.\F:': L.',::lJ

2Ji5SEPI7

P1Z:OI

~i:

:,1 :.. ,.':EI:Lf:LT

Civil Action No. GJH 133059

:,

y.-!l ~

_ DEPUTY

SUBPOENA TO PRODUCE DOCUMENTS, INFORMATION, OR OBJECTS

OR TO PERMIT INSPECTION OF PREMISES IN A CIVIL ACTION
Aaron Walker, 7537 Remington Rd Manassas, VA 20109

To:

(Name a/person to whom this subpoena is directed)

~ Production: YOU ARE COMMANDED to produce at the time, date, and place set forth below the following
documents] electronicallY stored informati0'1 o.c.obiects. and to permit inspection, cODving, testing, or samolinl! of the
. .Ai commumca rons oelween you a,ia J-'atl1cKt-rey concermng tlrett Kimoennnrom septemoer <!U1 f tnrougn
matcnalMay 2013, including those conerning alleged swattings of you and Mr. Frey

Date and Time:

Inspection of Premises: YOU ARE COMMANDED to permit entry onto the designated premises, land, or
other property possessed or controlled by you at the time, date, and location set forth below, so that the requesting party
may inspect, measure, survey, photograph, test, or sample the property or any designated object or operation on it.

I Date

Place:

and Time:

The following provisions of Fed. R. Civ. P. 45 are attached - Rule 45(c), relating to the place of compliance;
Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and (g), relating to your duty to
respond to this subpoena and the potential consequences of not doing so.
Date:
CLERK OF COURT
OR
Attorney's signature

Signature a/Clerk or Deputy Clerk

The name, address, e-mail address, and telephone number of the attorney representing
8100 Beech Tree Rd, Bethesda, MD 20817 (301) 3205921

(name a/parry)

Brett Kimberlin

, who issues or requests this subpoena, are:

justicejtmp@comcast.net
Notice to the person who issues or requests this subpoena
If this subpoena commands the production of documents, electronically stored information, or tangible things or the
inspection of premises before trial, a notice and a copy of the subpoena must be served on each party in this case before
it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).

Case 8:13-cv-03059-GJH Document 308-1 Filed 09/17/15 Page 2 of 7

AO 8813 (Rev. 02114) Subpoena to Produce Documents, Information. or Objects or to Permit Inspection of Premises in a Civil Action

UNITED STATES DISTRICT COURT

for the

District of Maryland
Brell Kimberlin

)
)

Plaintiff

v.

)
)

Patrick Frey

Civil Action No.

"' !\::O

ZDI5SEP 17 PI 2: 01
.',

)
)

Defendant

u.s. ,il.. ,
DISTRICT CF , I."

.. !L:~

GJH 133059 'C:,:t!JeLT

BY_&U

_DEPUTY

SUBPOENA TO PRODUCE DOCUMENTS, INFORMATION, OR OBJECTS

OR TO PERMIT INSPECTION OF PREMISES IN A CIVIL ACTION
William Hoge, 20 Ridge Road, Westminster, MD 21157

To:

(,Vame of person to whom this subpoena is directed)

16

Production: YOU ARE COMMANDED to produce at the time, date, and place set forth beiow the following
documents] electronicallv stored infonmation. or.obie,9ts. and to permit illsp~ction. cODvjng. testin "Oo[samplin!!. of the
. .AI communlca rons Delween you ana t-'atnc, rrey concermng I:lren KlmDerlllTTromMay 2 1;<tnrougn"May
matenal2014, including those conerning alleged swattings of Aaron Walker and Mr. Frey. All communications with any
other person during that time frame regarding those alleged swattings.
Place:8100"Beechiree
Rtf
Bethesda, MD 20817

Date and Time:

Inspection of Premises: YOU ARE COMMANDED to penmit entry onto the designated premises, land, or
other property possessed or controlled by you at the time, date, and location set forth below, so that the requesting party
may inspect, measure, survey, photograph, test, or sample the property or any designated object or operation on it.

I Date and

I Place:

Time:

The following provisions of Fed. R. Civ. P. 45 are attached - Rule 45(c), relating to the place of compliance:
Rule 45(d), relating to your protection as a person subject to a subpoena: and Rule 45(e) and (g), relating to your duty to
respond to this subpoena and the potential consequences of not doing so.
Date:
CLERK OF COURT
OR
Signature of Clerk or Deputy Clerk

Attorney's signature

The name, address, e-mail address, and telephone number of the anorney representing (name ofpar,>~
8100 Beech Tree Rd, Bethesda, MD 20817 (301) 320 5921
justicejtmp@comcast.net

Brett Kimberlin

, who issues or requests this subpoena, arc:

Notice to the person who issues or requests this subpoena

If this subpoena commands the production of documents, electronically stored information, or tangible things or the
inspection of premises before trial, a notice and a copy of the subpoena must be served on each party in this case before
it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).

Case 8:13-cv-03059-GJH Document 308-1 Filed 09/17/15 Page 3 of 7

AO 888 (Rev. 02114) Subpoena to Produce Documents, infomlation, or Objects or to Pemtit Inspection of Premises in a Civil Action

UNITED STATES DISTRICT COURT.

JJ~ I.
c,uJ;,T
DISTRIC',' If , .. ~.(L.~.i:C'

for the

2015 SEP 17 PH 2: 0 I

District of Maryland
Brett Kimberlin

_.

v.

)
)
)

Defendant

Plaintiff

Patrick Frey

., .- CE

. : l:lt~
:::BELT

Civil Action No.

G,i~ ~eJ DEPUTY

13

SUBPOENA TO PRODUCE DOCUMENTS, INFORMATION, OR OBJECTS

OR TO PERMIT INSPECTION OF PREMISES IN A CIVIL ACTION
Twitter Inc. 795 Folsom Street, Suite 600 San Francisco, CA 94107

To:

(A'ame of person to whom this subpoena is directed)

~ Production: YOU ARE COMMANDED to produce at the time, date, and place set forth below the following
documents electronicallv stored information, or obiects, and to Der~l1it.insneJ:tioo,fooving, testinl!. or Satll[1II'11l!
of the
, ,AI
1 records related to tile person or persons who create'd tl,e (gI tlKWatcn wmer-accounr: Incl uOing I-'"'
matenaladdresses,
emails, phone numbers, names and other identifying information.

Place:8100BeectlTfeeRd
Bethesda, MD 20817

Date and Time:

lmpection of Premises: YOU ARE COMMANDED to permit entry onto the designated premises, land, or
other property possessed or controlled by you at the time, date, and location set forth below, so that the requesting party
may inspect, measure, survey, photograph, test, or sample the property or any designated object or operation on it.

I Date and Time:

I Place:

The following provisions of Fed, R, Civ. P. 45 are attached - Rule 45(c), relating to the place of compliance;
Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and (g), relating to your duty to
respond to this subpoena and the potential consequences of not doing so.
Date:
CLERK OF COURT
OR
Attorney's signature

Signature o/Clerk or Deputy Clerk

The name, address, e-mail address, and telephone number of the attorney representing
8100 Beech Tree Rd, Bethesda, MD 20817 (301) 320 5921
justicejtmp@comcast.net

(name afparty)

Brett Kimberlin

, who issues or requests this subpoena, are:

Notice to the person who issues or requests this subpoena

If this subpoena commands the production of documents, electronically stored information, or tangible things or the
inspection of premises before trial, a notice and a copy of the subpoena must be served on each party in this case before
it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).

Case 8:13-cv-03059-GJH Document 308-1 Filed 09/17/15 Page 4 of 7

AO 888 (Rev. 02/14) Subpoena to Produce Documcllls. Infonnation.

or Objects or to Pennit Inspection of Premises in a Civil Action

UNITED STATES DISTRICT COURTu,~

I I'

DISTRICT 2,

for the

District of Maryland
Brett Kimberlin

2015SE) 17 Pd 2: 01
1.1 ..

)
)
)
)
)

v.
Patrick Frey
Deftndant

, .ICE

l.

Plaintiff

,.,JiJi,1'

'J I .: '.,
I I.e.,.\ i l-r\ItL

,::'::.:8ELT

GJH 13..~0;;9
C.IVI '1 A'ctlon No. 8Y_U,V_DEPUTY

SUBPOENA TO PRODUCE DOCUMENTS, INFORMATION, OR OBJECTS

OR TO PERMIT INSPECTION OF PREMISES IN A CIVIL ACTION
Los Angeles County District Attorneys Office, 211 W Tempie Street Suit 1200, Los Angeles, CA 90012

To:

(Name of person to whom this subpoena is directed)

16 Production:

YOU ARE COMMANDED to produce at the time, date, and place set forth below the following
documents! electronicallv stored infonnation, or objects. and to.penuit l'nsoec\ion"cUDving, testing,.or samoling of the
.. AI recoras relateo to tfie complaints maoe-agarnstDeputy UIS net At orn"y l"atnCKt-rey oy tlren Klmoonln
matenalbetween 2010 and 2014, including memos, notes, conclusions and interviews. All policies of your office related
to blogging by employees. All records related to complaints by others against Patrick Frey.
Place:8100BeecnTree
Rd
Bethesda, MD 20817

Date and Time:

Inspection 'if Premises: YOU ARE COMMANDED to permit entry onto the designated premises, land, or
other property possessed or controlled by you at the time, date, and location set forth below, so that the requesting party
may inspect, measure, survey, photograph, test, or sample the property or any designated object or operation on it.
[ Place:

Date and Time:

The following provisions of Fed. R. Civ. P. 45 are attached - Rule 45(c), relating to the place of compliance:
Rule 45(d), relating to your protection as a person subject to a subpoena: and Rule 45(e) and (g), relating to your duty to
respond to this subpoena and the potential consequences of not doing so.
Date:
CLERK OF COURT
OR
Attorney's signature

Signature o/Clerk or Deputy Clerk

The name, address, e-mail address, and telephone number of the atlomey representing
8100 Beech Tree Rd, Bethesda, MD 20817 (301) 320 5921
justicejtmp@comcas!.net

(name aJparl)~

Brett Kimberlin

, who issues or requests this subpoena, are:

Notice to the person who issues or requests this suhpoena

If this subpoena commands the production of documents, electronically stored information. or tangible things or the
inspection of premises before trial, a notice and a copy of the subpoena must be served on each party in this case before
it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).

Case 8:13-cv-03059-GJH Document 308-1 Filed 09/17/15 Page 5 of 7

AD 88B (Rev. 02/14) Subpoena to Produce Documents, Information, or Objects or to Permit Inspection of Premises in a Civil Action

UNITED STATES DISTRICT COURT

for the

District of Maryland
Brett Kimberlin
Plaintiff

)
)

v.

Patrick Frey

U.S.

I,

I".

;,

'L ,T
_,\;~C

2m SE~ /7 PI'j 2: 0 I
i.1 ,

Civil Action No. GJH 13.,~,?591)

DISTRICT C .

l5

,',CE
';:','iJELT

DEPUTY

)
)

Defendant

SUBPOENA TO PRODUCE DOCUMENTS, INFORMATION, OR OBJECTS

OR TO PERMIT INSPECTION OF PREMISES IN A CIVIL ACTION
Federal Bureau of Investigation, 601 4th Street, Washington DC 20535

To:

(Name of person to l1.'/lomthis subpoena is directed)

t6

Production: YOU ARE COMMANDED to produce at the time, date, and place set forth below the foJlowing
documents] electronicallv stored infoml atio n. or ohiects and IQ [ll:rmit insneclion. cQDying. testingbOJ:.samDling of the
. I.AI recoras relatea to tf1e Invest Iga tIon by7\gen r uanlel tlorsuk ana a ners orme swatting- T J-'atriCkt-rey,
matena Aaron Walker, and Eric Erickson in 2011 and 2012, and all records related to the false accusations of those
people that Brett Kimberlin was involved with those swattings.
Place:81 00 BeecnTree Rd
Bethesda, MD 20817

Date and Time:

o Impec/ion of Premises: YOU ARE COMMANDED to permit entry onto the designated premises, land, or
other property possessed or controJled by you at the time, date, and location set forth below. so that the requesting party
may inspect, measure, survey, photograph, test, or sample the property or any designated object or operation on it.
i Date and Time:

I Place:

The foJlowing provisions of Fed. R. Civ. P. 45 are attached - Rule 45(c), relating to the place of compliance;
Rule 45(d). relating to your protection as a person subject to a subpoena; and Rule 45(e) and (g), relating to your duty to
respond to this subpoena and the potential consequences of not doing so.
Date:
CLERK OF COURT
OR
Signature of Clerk or Deputy Clerk

Attorney's signalllre

TIle name, address, e-mail address, and telephone number of the attorney representing (name a/party)
8100 Beech Tree Rd, Bethesda, MD 20817 (301) 320 5921
justicejtmp@comcas!.net

Brett Kimberlin

,who issues or requests this subpoena, are:

Notice to the person who issues or requests this subpoena

If this subpoena commands the production of documents, electronicaJly stored information, or tangible things or the
inspection of premises before trial, a notice and a copy of the subpoena must be served on each party in this case before
it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).

Case 8:13-cv-03059-GJH Document 308-1 Filed 09/17/15 Page 6 of 7

AO 88B (Rev. 02/14) Subpoena to Produce Documents, infonnalion,

or Objects or to Permit Inspection of Premises in a Civil Action

UNITED STATES DISTRICT COURT nlSu.s. [)

for the

-'

District of Maryland
Brett Kimberlin

)
)
)

Plaintiff

v.

Patrick Frey

TRIC'!

or.i. I If\;

v,:1
,"./',:ID

2m S~P I 7 PH 2: 0 I
v~

~.I

"

Civil Action No. GJH 13 305g

.Y_IJV

)
)

IL.E

:'::r..lj~IC:LT

__ DEPUTY

Defendant

SUBPOENA TO PRODUCE DOCUMENTS, INFORt'\1ATION, OR OBJECTS

OR TO PERMIT INSPECTION OF PREMISES IN A CIVIL ACTION
Google Inc. 1600 Ampitheater Parkway, Mountain View. CA 94043

To:

(Name a/person to u'hom this subpoena is directed)

~ Producrion: YOU ARE COMMANDED to produce at the time, date, and place set forth below the following
documents! electronicallv stored infomlation~ or obiects. and to oJ::r.hmit
inspecti0'1 cOl1yinl!.te.stinl!. urlsampll'nl! of the
. .AI recoros relateo to tne person or I'ersons wno createa tl e www.speeuwayoomoernistory.oogspo.com
matenalaccount, including IP addresses, emails, phone numbers, names and other identifying information

Place:8100'Beecn Iree Rd
Bethesda, MD 20817

Date and Time:

IlISpecrion of Premises: YOU ARE COMMANDED to permit entry onto the designated premises, land, or
other property possessed or controlled by you at the time, date, and location set forth below, so that the requesting party
may inspect. measure, survey, photograph, test, or sample the property or any designated object or operation on it.

I Place:

[Date and Time:

The following provisions of Fed. R. Civ. P. 45 are attached - Rule 45(c), relating to the place of compliance;
Rule 45(d). relating to your protection as a person subject to a subpoena; and Rule 45(e) and (g), relating to your duty to
respond to this subpoena and the potential consequences of not doing so.
Date:
CLERK OF COURT
OR
Signature of Clerk or Deputy Clerk

Attorney"s signature

The name, address, e-mail address, and telephone number of the attorney representing (name a/party)
8100 Beech Tree Rd, Bethesda, MD 20817 (301) 320 5921
justicejtmp@comcast.net

Brett Kimberlin

, who issues or requests this subpoena, are:

Notice to the person who issues or requests this suhpoena

If this subpoena commands the production of documents, electronically stored information, or tangible things or the
inspection of premises before trial, a notice and a copy of the subpoena must be served on each party in this case before
it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).

Case 8:13-cv-03059-GJH Document 308-1 Filed 09/17/15 Page 7 of 7

AO 8813 (Rev. 02114) Subpoena to Produce Documents. Information. or Objects or

10

Permit Inspection ofPrcmises in a Civil Action

UNITED STATES DISTRICT COURT

for the

)
)
)

Plaimifl

v
Patrick Frey

I ;;.;

?~'."~T

2. i5 SEP 17 Prj 2: 0 I

District of Maryland
Brett Kimberlin

DI~;R:C'Iu;~
'"

CE

~::C:.'.lELT

Civil Action No. GJH 13 30~l?U

__

DEPUfV

)
)

Defendant

SUBPOENA TO PRODUCE DOCUMENTS, INFORMATION, OR OBJECTS

OR TO PERMIT INSPECTION OF PREMISES IN A CIVIL ACTION
Leslie Lynnton Fuller, 1226 West Michigan St, Indianapolis, IN 46202

To;

(Name 01person to whom this subpoena is directed)

~ Production: YOU ARE COMMANDED to produce at the time, date, and place set forth below the following
documents] electronicall\' stored information. Ql' obiectshand to oermil/iinsoection. cop'yin,& testing. or. samnling of the
. .AI recoros relatea to any commUnlC3t10nS"you ave maae Wit any person rega,ull1g tlren Klmoerun, me
matenalallegations against him regarding swattings, your participation on any website about Brett Kimberlin, any
payments you have received to communicate in any manner about Brett Kimberlin
Place;81 00' Beech-nee Rd
Bethesda, MD 20817

Date and Time;

Il1.Ipection of Premises: YOU ARE COMMANDED to permit entry onto the designated premises. land. or
other property possessed or controlled by you at the time, date. and location set forth below. so that the requesting party
may inspect. measure. survey. photograph. test. or sample the property or any designated object or operation on it.

I Place;

I Date and Time;

The following provisions of Fed. R. Civ. P. 45 are attached - Rule 45(c). relating to the place of compliance;
Rule 45(d). relating to your protection as a person subject to a subpoena; and Rule 45(e) and (g). relating to your duty to
respond to this subpoena and the potential consequences of not doing so.
Date;
CLERK OF COURT
OR
A!lome.v's signature

Signature a/Clerk or [)eplllY Clerk

The name, address. e-mail address. and telephone number of the attorney representing
8100 Beech Tree Rd, Bethesda, MD 20817 (301) 320 5921
justicejtmp@comcast.net

(name "[party)

Brett Kimberlin

who issues or requests this subpoena. are;

Notiee to the person who issues or requests this subpoena

If this subpoena commands the production of documents. electronically stored information, or tangible things or the
inspection of premises before trial. a notice and a copy of the subpoena must be served on each party in this case before
it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).