MARYLAND:

IN THE CIRCUIT COURT OF MONTGOMERY COUNTY

BRETT KIMBERLIN,
Plaintiff
v.

Case No. 403868V

NATIONAL BLOGGERS CLUB, ET AL.,

Defendants

DEFENDANT STRANAHANS MOTION TO DISMISS THE FIRST AMENDED

COMPLAINT
NOW COMES Defendant Lee Stranahan (Stranahan), pro per, and moves to dismiss the
Plaintiffs Complaint with prejudice because the Plaintiff has failed to state a claim for which
relief can be granted under Md. R. 2-322(b)(2). Mr. Stranahan requests that such dismissal be
granted with prejudice, without leave to amend, and for a hearing as soon as practicable. In
support of this motion, he states the following:
INTRODUCTION AND SUMMARY OF ARGUMENT
Stranahans written material referenced by Plaintiff was published by Breitbart News,
Stranahans employer on a work-for-hire basis.
Breitbart News has full editorial control and is the holder of the copyright to said work.
Defendant Breitbart News has been dismissed from the suit.
Aside from written work that is owned by dismissed defendant Breitbart News, plaintiff
Kimberlins other claim about Stranahan relate to Stranahans idea for Everybody Blog About
Brett Kimberlin Day, which was not defamatory and is protected speech. .

When Stranahan announced Everybody Blog About Brett Kimberlin Day, he stated
(emphasis added) : :
On Friday, May 25th write an honest, factually accurate post about what you
learned and what your OPINION is. Brett may try and sue you, so be accurate, factual
and separate fact from opinion.
From : http://leestranahan.com/friday-may-25th-is-everybody-blog-about-brett-kimberlin-day/
Defendant Stranahan also asks the court to dismiss the claim because he believes the
plaintiff does not have personal jurisdiction over him in this case.

CONCLUSION
WHEREFORE Defendant Stranahan requests that all claims are dismissed under Md. Rule 2322(b)(2); that such dismissals be granted with prejudice and without leave to amend; that this
Court should consider motions for sanctions and, upon such motions, grant monetary sanctions
and injunctive relief appropriate for a vexatious litigant; and that this Court grant such other
relief as appropriate.

Thursday, October 22, 2015

Respectfully submitted,

Lee Stranahan
13824 Methuen Green Street
Dallas, TX 75240
(214) 402-1759
stranahan@gmail.com
(No fax)

CERTIFICATE OF SERVICE
I certify that on the 22nd day of
October
, 2015, I served copies of this
document electronicallyon Brett Kimberlin and the following co-Defendants via email: William
Hoge via Patrick Ostronic; DB Capital Strategies and Dan Backer, Esq. via Dan Backer, Esq.