COM.

PLAlNT FOR DAMAGES AND lNJU CTIVE RELIEF FOR

DEFAMATION, LIBEL CYBERSTALKING. AND TORTIOUS
INTERFERE CE WITH BUSlNESS,
iN T.H.E CIRCUIT COURT .FORMONTGOMERY COUNTY,
MARYLAND
BRETTKIMBERLIN
Case No.
ANONYMOUS CYBER STALKER
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SOCRATES,
PREPOS1ERICITY,
DAVEFROMQUEENS2.,
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Brett Kimberlin pro se hereby files this Complaint against Anonymous Cyber
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hereinafter called "Socrates." his most common cyber stalking name.
PARTIES
1. PlaintiffBrett Kimberlin (''Kimberlin") is a resident ofMontgomery County
Maryland
2. Defendant Socrates is an anonymous cyber stalker biding in the shadows ofthe
Internet
FACfS
3. Kimberlin is a private citizen who has worked at the same job for at least seven
years as the director of a non profit public called Justice Thr'Ough Music.
whose mission is 10 use inspire young people to get engaged with progressive
t
social causes.
4. In 2005, Justice Through Music co-founded a public charity called Velvet
Revolution with another co-founder called The BradBlog to focus on election
protection and accountability issues.
5. On or about 2007, Socrates started making anonymous posts on various national
websites and forums attacking the editor ofThe Brad Blog with. anti-Semitic slurs
and 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 Brad Blog
and then to other people associated with the editor.
8. Socrates' became obsessed with the The Brad Blog editor and started digging into
everything about him.
9. Socrates discovered that The Brad Blog co-founded Velvet Revolution with
Justice Through Music, and that Kimberlin was the director ofJustice Through
Music.
10. Socrates then began digging into Kimberlin and discovered that he had 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
editor was connected to a convicted felon named Brett Kimberlin.
12. From2008 through October 2010, Socrates has made scores ofanonymous posts
on numerous national websites accusing Kimberlin ofmurder, pedophilia, and a
./"--.
host of other unspeakable with each post mentiomng The Brad Blog
editor.
13. From2008 through 2010, Socrates was banned by every national website on
which he has posted about Kimberlin because those posts violated the tenns of
service by being defamatory, threatening and harassing.
14. Socrates has been banned from posting on The Brad Blog, Democratic
Underground, Daily Kos, Raw Story and others.
15. On many occasions, after Socrates was banned for his threatening posts, he re--
registered under a different name or names and posted even more threatening
posts. These names included Prepostericity, and these names and their IP
addresses were also banned from the sites.
16. When Socrates was banned from a he threatened the editors ofthose
websites with more anonymous emails and posts.
17. Several other people have contacted Kimberlin who have been threatened and
harassed by Socrates to the point that they feel their lives are indanger.
18. Kimberlin has been told that by some ofthese people that they have attempted to
seek protection from law enforcement and through the civil process but have been
unable to learn who Socrates is.
19. When Socrates could no longer post harassing attacks against Kimberlin on
legitimate websites, he started his own blog in March 2009 on GoogIe's
BLOOGER ,,"y\vw.blogger.com.
20. Socrates named his site http://davefromaueens2.blof!SOOlcom/.
28. Kimberlin has received threats to bis life because ofthe defamatory and harassing
posts 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 Libel
30. Paragraphs 1-29 above are hereby adopted and incorporated into all counts ofthis
Complaint
31. Socrates has engaged in a three-year campaign of defamation against Kimberlin
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 were malicious and intentional and done with an
intent to cause harm.
CO ''I'll
.Harassment and Violation of Privacy
34. Socrates has intentionally annoyed, stalked, threatened, and attacked
Kimberlin with scores of false, annoying, and threatening Internet
postings over a three-year period
35. The posts made by Socrates constituted malicious harassment ofKimberlin and
violated his privacy, and caused unknown parties to make tbreats against
Kimberlin.
COU Till
Interference with Business
36. Socrates repeatedly) over a three-year period, made 1n1emet postings inorder to
hann Kimberlin's business relationships, to stop people from supporting his
business enterprise, and to create doubts about his business in order to harm
Kimberlin.
WHEREFORE, Kimberlin prays that the Comt grant the following relief
a. Findthat Socrates has defamed and heeled Kimberlin.
b. Find that Socrates has harassed and cyber stalked and violated his
pnvacy.
c. Find that Socrates has interfered with Kimberlin'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 with
Kimberlin.
e. Issue an Order to remove all references to Kimberlin on Socrates' Google
Blogger page.
f. En1erjudgment infavor ofKimberlin in the amount in
compensato damages.
g. Enterjudgment in favor onKimberlinin the anlOlmt of 1,000,000 in punitive
damages.
h. Such other and further relief as the Comdeems appropriate.
Respectfully ~ ' l } f t f i ~