ECF 346 Redacted

8/20/2019 ECF 346 Redacted

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UNITED STATES DISTRICT COURT

DISTRICT OF MARYLAND

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BRETT KIMBERLIN,

Plaintiff,

v.

PATRICK FREY,

Defendant.

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No. GJH 13.3059

PLAINTIFF'S RESPONSE TO NON.PARTY LOS ANGELES COUNTY OPPOSITION

TO MOTION TO AMEND

Now comes Plaintiff Brett Kimberlin and replies to the January 28, 2016 letter by

non-party LACounty opposing Plaintiffs motion to amend.

1. LACounty mistakenly states that Plaintiff did not notify the Court of his

intent to add LA County as a defendant as required by the Scheduling Order. In fact,

in the last paragraph of ECF 286, filed on June 11, 2015, Plaintiff stated: "I am

notifying the Court and Defendant Frey that I intend to add the Los Angeles County

District Attorney's Office ... as [a party] in due course." Clearly, Plaintiff could not

add LA County until Frey and LACounty produced the discovery that implicated LA

County in the violations under 42 USC 1983. Because that discovery was only

provided over the past 45 days, Plaintiff has good cause for not amending the

complaint at an earlier time.

2. Plaintiff would been derelict had he added LACounty prior to having hard

evidence of it aiding, assisting and enabling Patrick Frey in his retaliation of Plaintiff,

and acting under color of law itself in retaliating against Plaintiff for making

legitimate complaints against government official Frey.

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5. On February 10, 2016, the Sheriff of LACounty, Lee Baca, pleaded guilty to

lying to the FBI about the Sheriffs Department engaging in wholesale retaliation

and intimidation in other cases. In the instant case, it is reasonable to believe, and

Plaintiff will alleged in an amended complaint, that either LACounty or Defendant

Frey, knowing that the Sheriff ran a rogue operation, contacted the Sheriffs

Department with instructions to send the above intimidating threat to Plaintiff to

leave Defendant Frey alone.

6. Along with this Reply, Plaintiff has filed under seal a number of emails to and

from Defendant Frey to his supervisors, investigators with LACounty, and the FBI.

These incredible documents demonstrate that LACounty was working hand in glove

with Defendant Frey to target Plaintiff. Frey's supervisor, Anne Ingalls, tipped him

off to Plaintiffs complaints, discussed paying for criminal investigations of Plaintiff,

and offered to have the criminal Bureau investigators target Plaintiff. Here is a

summary of just some of the Frey documents that are filed under seal today.

• Bates Number 0002-From Frey to Anne-Kimberlin filed another complaint

against Frey, ''I'm still curious about whether I'll ever get any help from the

Bureau of Investigation, since it's been 3 V2 months and I never even got the

security review from High Tech Investigators that Joey had promised ...."

Signed by Patrick Frey Deputy District Attorney ("PF ADA ") 3/26/12

• OOOS-From Frey to Anne-I believe Brett Kimberlin is responsible for the

police showing up at my house. "In our meeting with Joey [Esposito] last

December, I showed you and Joey a printout of a blog post in which

Rauhauser said he wanted a picture of Christi, and that he wanted me bankrupted, fired, disbarred, humiliated, disgraced and sued. Bottom line:

Rauhauser is out to cause me professional trouble on behalf of Brett

Kimberlin." "I am completely tired of this, but it's clear to me that they are

never going to stop harassing me as long as they believe their repeated

complaints will harm my career." Signed PF ADA 9/12/12

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0012-From Frey to Anne-HR person from PHRI called me yesterday to say

she is afraid of Kimberlin. 1/10/12

0030-From Frey to Anne-says Ron sent police to Frey's home. 11/09/11

Signed PF ADA

0035a-To Joey Esposito from Anne Ingalls-Anne asks Joe for an update on

Frey swatting investigation, which is serious. Asks Bureau to follow up on

Frey's requests to investigate Brett Kimberlin who set into motion

"something more extreme." 8/16/11 Signed Anne Ingalls, Head Deputy,

Hardcore Gang Division.

0046a-To Joe Esposito from Anne-setting up meeting between Frey and Joe E

to discuss Kimberlin. 12/01/11

0047-48-Frey to Anne-asking if Office is going to investigate Kimberlin. Says

"we can have the Bureau [of Investigation] pay for voice comparisons, issue

subpoenas on relevant leads, ...." Kimberlin's complaints "all fit neatly with

the July 1 police visit to my home - it is a coordinated effort to harass, defame

and intimidate. There is evidence that people aligned with Kimberlin may be

behind that crime. There are obvious leads the FBI has declined to pursue.

Neither the FBI, the Sheriffs Dept or (to date) this office has yet thrown itself

fully into the investigation and tried to connect the dots. That has been left to

me and the other people who have been harassed by Kimberlin and his

associates. I would welcome the office's help on this. It this is truly going to

become an office matter, I think it should become an office matter all the

way." 11/29/11 Signed by PF ADDA

0055 and 55c-Anne to Frey and Frey to Anne-Anne tips off Frey that

Kimberlin filed a complaint against Frey and Frey thanks her. Frey tells Anne

he would love to see what I said in the complaint. Tells Anne that he has a

number of references to use to discredit Kimberlin 11/03/10

0062-Frey to Anne-telling her new developments, and Walker fired, and Frey

will forward emails to Anne. 1/10/12 Signed PF ADA

0084f-Frey to Anne-requesting update on investigations, and says swatting

suspect has ties to Kimberlin. Offers to pay for voice analysis unless officedoes, and it will cost $500.8/12/11 Signed PF ADA

0090-Frey to Anne-Asks her about "high-tech safety review." Every single

complaint comes back to Kimberlin. 5/15/12

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0093-Frey to Anne-says he was contacted by LATimes and LAWeekly about

swatting, and says Weekly will do story about swatting and Kimberlin

harassment. 10/23/12 PF ADA

0094a and 95e-Anne to Frey et al requesting info on any media coverage .12/22/12 and 10/22/12

0096f-Frey to Anne telling her that CNN doing swatting story. 5/31/12 5/ /PF

ADA

0097f-Frey to Anne telling her that FOXdid a story on swatting and

mentioned that Frey is a Deputy District Attorney, and mentioned Kimberlin.

5/31.125/ /PF ADA

0099-Frey to Anne telling her that Neal is coordinating with Kimberlin .

9/14/12 PF ADA

0106-Frey to Anne-Kimberlin associate Neal is planning something. Frey

wants to hire his own audio expert because "I did not want to wait for law

enforcement to do it." It's costing $750-1000. I could use some help on this,

FBI closed case so "I am on my own." 1/31/12 PF ADA

0109-Anne to Joe Esposito-inferring that LACounty could cover the expense

for the audio investigator. 8/16/11

0110a and 0121a-Frey to Anne-asking if LACounty would pay for audioexpert and saying to her, "thanks for backing me on all this." 8/16/11

0117-Frey to Anne asking of high tech security review is going to happen,

and wants a copy of Kimberlin suit. 5/21/12

0122f-Frey to Anne warning her that she will hear from Kimberlin and

maligning him. 11/1/10

0142-Frey to Anne giving her heads up about media attention and pointing

finger at Kimberlin 5/1/29/12

0143-Frey to Anne-"Hooray, Another complaint from Brett Kimberlin."

Falsely says that Kimberlin working with Barrett Brown who has "extensive"

connections to Kimberlin. Kimberlin's account is a total distortion. 9/14/12

PF ADA

0160f-Frey to Anne-re Nadia Naffe complaint, who is associated with

Kimberlin. Suit by people who tried to get Frey killed. Kimberlin is a violent

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psychopath who is apparently obsessed with me. Is security review still on

table? Tells Anne again about voice analysis. 5/4/12 PF ADA

o 161f-Frey to Anne complaining that Kimberlin filed complaint and wanting

to document a couple of points. Says he cut off Seth. Says Kimberlin site

posted his address. Kimberlin contacts with office part of premeditatedsmear campaign. Trashes Kimberlin. PF ADA

0165-Frey to Anne-FBI is working on case with me, and has issued

subpoenas. Frey requesting the Bureau investigate Brett Kimberlin and

analyze tape of swatting call, get search warrants, contact NJ LE and

exchange information. Wants person charged with felony. PF ADA

0184-Frey to FBI-Frey still working on Walker swatting call, tells FBI about

unsolicited call from Congressman, and wants to tell Congressman that FBI

reopened investigation. 7/17/12

0299-Frey to FBI-Sends voice analysis accusing Ron of being swatter. And

asks FBI to rely on that report. Talks about other leads and expressing

frustration with accepting FBI conclusions. Tells FBI to pursue this lead.

2/25/12

0300-Frey to FBI-complaining that FBI will not share the phone number used

in swatting call. Says he was stunned not be get that information. Frey says

he is being deprived of vital information because could be neighbor, defense

attorney or any other person. Complains that Frey could help with leads.

Demands explanation. 2/3/12

7. These documents demonstrate that Defendant Frey, LACounty and Frey's

Supervisor, Anne Ingalls, were cooperating and coordinating in the retaliation of

Plaintiff. Whenever Plaintiff complained to LACounty about Defendant Frey, LA

County tipped off Defendant Frey and then criminally investigated Plaintiff rather

than Defendant Frey. Moreover, it enabled, assisted, and aided Defendant Frey's

criminal investigation, knowing full well that he was engaged in retaliation yet

providing him "backing" and cover. Defendant Frey's direct supervisor, Anne

Ingalls, used her influence to pressure the County Bureau of Investigation to launch

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a criminal investigation of Plaintiff based solely on Defendant Frey's paranoid,

delusional and false allegations. And she did this knowing full well that the FBI had

rejected everything that Frey told them about Plaintiff. Moreover, LACounty agreed

to the payment of the voice analysis by Kent Gibson, a person the FBI refused to rely

on because he was considered disreputable and unreliable.

8. LACounty and Anne Ingalls knew, because Plaintiff told them, that Defendant

Frey had enlisted the help of (1) convicted felon Ali Akbar, (2) the spokesman for

the hacking group Anonymous, Barrett Brown, and (3) the publisher of the nation's

most vile Muslim hate blog, Aaron Walker, to target Plaintiff based on Defendant

Frey's false accusations against Plaintiff. Yet LA County not only allowed but

enabled Defendant Frey to use these extra legal ruffians to target Plaintiff.

Defendant Frey has produced scores of emails (which are not included here) that

show direct communications between Defendant Frey and these hooligans

discussing the targeting of Plaintiff. At no time did LACounty order, direct or

counsel Defendant Frey to stop criminally investigating Plaintiff or stop working

with these scoundrels to retaliate against Plaintiff.

9. LACounty and Anne Ingalls also knew, because Defendant Frey told them,

that he was communicating with the media, both social and mainstream, to spread

his false and defamatory narrative that Plaintiff was involved with the criminal act

of swatting. In email after email, Defendant Frey's supervisors asked and were told

about these media contacts yet they never made any attempt, despite Plaintiffs

complaints and complaints by others, to reign in Defendant Frey's manipulation of

the media, to which he always said he was a "Deputy District Attorney." The

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supposed journalists Defendant used to target Plaintiff included convict James

O'Keefe who was convicted of using a ruse to break into Senator Mary Landrieu's

political office as part of a political smear job, and Andrew Breitbart who infamously

created false narratives about the community group ACORN and Department of

Agriculture employee Shirley Sherrod to destroy them. LACounty never once told

Defendant Frey to cease his communications with his rolodex of disreputable smear

artists posing as journalists.

10. LA County's vague and toothless administrative SOCIALMEDIA POLICY,

attached here as Exhibit A, supposedly "provides both standards and guidelines to

District Attorney employees," on the use of social media to "protect the integrity of

the office ...." Yet, LA County allowed Defendant Frey, despite Plaintiffs many

complaints to his supervisors, to use his personal blog to defame Plaintiff, report on

Defendant Frey's criminal investigation of Plaintiff, publish confidential information

about the investigation, and treat Plaintiff and other complainants disrespectfully.

LACounty, by not taking any action against Defendant Frey, must have considered

Defendant Frey's retaliatory smears, personal attacks and defamation as "best

practices" and "good judgment," as outlined by the administrative policy. How was

Defendant Frey able to get away with his violations of Plaintiffs civil rights?

Because LACounty issued a policy that was unclear, weak and unenforceable. The

Ninth Circuit recently held in Goldstein v. City of Long Beach, 715 F. 3d 750 (9th

Circuit, en bane 2013), that Los Angeles County can be held liable under 1983 where

its policies gave rise to violations of civil rights: "Los Angeles County District

Attorney represents the County when establishing administrative policies and

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training related to the general operation of the district attorney's office, ....

Therefore, a cause of action may lie against the County under S 1983."

11. On February 5, 2016, United States District Judge William Orrick from the

San Francisco federal court, in the case of National Abortion Federation v. Center for

Medical Progress, No. 15-cv-03522-WHO, issued a preliminary injunction against a

group of extremists charged with civil rights violations who used unethical and

illegal tactics to smear Planned Parenthood, including creating edited videos to

make it appear that Planned Parenthood was illegally selling human body parts.

The defendants argued that their posting of false and fraudulent information could

not meet the standard of irreparable injury even though third parties could be

inspired by the information to cause threats, harassment and violence to Planned

Parenthood. Judge Orrick, however, found that this did meet the irreparable harm

standard because if "the NAF materials were publicly released, it is likely that the

NAF attendees shown in those recordings would not only face an increase in

harassment, threats, or incidents of violence, but also would have to expend more

effort and money to implement additional security measures." Id. at pp 36-37.

12. In the instant case, Plaintiff has alleged that Defendant Frey published false

and highly charged accusations against Plaintiff in retaliation for Plaintiff

complaining against him, and Defendant Frey knew that this would result in third

party harassment, threats and acts of violence against him. And Plaintiff has alleged

that in fact he has been harassed by dozens of Frey's readers and associates, that he

has been threatened with scores of online threats of death and injury, that Frey

associate Seth Allen threatened to "murder" Plaintiff, and that one of the editors of

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Defendant Frey's blog, Aaron Walker, assaulted Plaintiff in a courthouse within

hours after he communicated with Defendant Frey. Plaintiff has alleged, as did

Planned Parenthood, he has had to increase security at his home to deal with these

actual threats and attacks.

13. LACounty and Anne Ingalls were aware that Plaintiff was suffering

irreparable injury from Defendant Frey's false narratives. Yet they allowed and

enabled him to continue that retaliatory conduct. As in Planned Parenthood,

therefore, they are responsible for both Defendant Frey's conduct and the conduct

of others who harassed, threatened and harmed Plaintiff.

Wherefore, for all the above reasons, this Court should allow Plaintiff to file an

amended complaint to add Los Angeles County District Attorneys Office and Patrick

Frey's supervisor, Anne Ingalls under Section 1983.

Respec lX,Sub' ,

B I K S- I'

reti1 er In810 Be ~h Tree Rd

Beth a, MD 20817

jill;[email protected]

(301) 320 5921

CERTIFICATE OF SERVICE

I certify that I served a copy of this motion on attorneys for Defendant Frey and

on attorneys for LACounty this 12th day of February, 2016.

Brett Kim rlin

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Los Angeles County District Attorney

Internet and Social Media Policy

I. Internet Use

Prior to logging onto the County Internet, all District Attorney employees must click on

an acknowledgment, certifYing that they will comply with the County's Internet policy,

which states: "County information technology resources, including Internet acccss, are

established 10 be used/or County business purposes." (Board of Supervisors Policy

(BOSP) #6.105 (cmphasis added); See also BOSP #6.101, PPH 7.05.00-7.05.01.) Use of

County internet and computers to post on social media sites or for any other private use is

inconsistent with the intent behind the above policies. Note that internet usage is

monitored and logged.

II. Usc of Social Media Sites

District Attorney employees should be mindful that they are pcrsonally responsible for

the content they publish on any form of user-generated social media. Although it may

appear that posting on a social media site will remain private, far too ollen a post is

transmitted beyond its original, intended audience. The following policies should be

adhered to when using social media.

A. Be conscious of your online identity.

District Attorney employees are free to express opinions as individuals on matters

of public interest. This includes posting an opinion on a social media site.However, ifan employee has identified himselfor herselfas a member of the

District Attorney's Office on a matter related to the Officc, thc employee must

include a statement that they are speaking as an individual. (Sce PPH 7.16.00.)

District Attorney employees may not usc official badges, identification, business

cards or other items bearing the seals of Los Angeles County or the District

Attorney's Ot1ice for purposes other than the employees' of1icial duties. (See

PPH 7.04.00; LPM 26.10.02.) This includes the use of these images and symbols

on any social nctworking sites.

District Attorney employees should be aware that "friending" or "following"

witnesses, bench officers, victims or jurors may violate ethical rules. (See CARules of Prof Conduct, Rules 2-100, 5-300(B) & (C) (ex parle contact with

judges); CA Rulcs of Prof Conduct, Rules 5-320(A), (B), and (C) (contact with

jurors); LPM 26.08.)

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B. Be respectful.

District Attorney employees are required to maintain respect for courts of justice

and judicial officers, even when posting on social media sites. (Bus. & Prof.

Code 6068(b).) District Attorney employees must also take care when postingcomments about other parties in the criminal justice system, including defense

attorneys, bench officers and law enforcement agencies. District Attorney

employees must treat witnesses and parties with courtesy and respect, even during

non-working hours. (See PPH 7.15.00; Bus. & Prof. Code 6068(b); LPM 24.01;

See also PPH 13.05.00,8.00.00.)

Starting in July of2011, every employee was required to complete the Los

Angeles County Policy of Equity which prohibits "discrimination, unlawful

harassment, retaliation, and inappropriate conduct toward others based on a

protected status in the work place or in other work-related settings." Postings to

blogs, websites, etc., under certain circumstances, may constitute a violation of

the Policy of Equity and may subject the employee to discipline. All DistrictAttorney employees are bound by the Policy of Equity. (See Personnel Policies

Memorandum 11-04.)

C. Keep confidential information confidential.

District Attorney employees may not reveal confidential information, including

information regarding any criminal case or law enforcement investigation on

either closed or open cases on any social media site or by mass dissemination via

any means of electronic distribution (e.g., Twitter). (PPH 7.12.00, Bus. & Prof.

Code section 6068(e).)

Caution should be exercised when using WiFi without an office-issued VPN

(Virtual Private Network) at a library, coffee shop, or even in the courthouse.

These networks may not be secure and your information could be subject to

interception.

Digital communication (e-mail, text messages, etc.) between employees and

witnesses, including victims and investigators, is always retrievable and may be

subject to discovery through Penal Code section 1054 et seq. and/or a Public

Records Aet request. Such communication should be limited to matters

concerning scheduling and other logistics, rather than substantive, case-related

conversations. (See GOM 11-053.)

D. Remember rules regarding pretrial publicity.

District Attorney employees are obligated to follow State Bar rules regarding

pretrial publicity when posting on social media sites. (See CA Rules of Prof.

Conduct, Rule 5-120; Media Relations Poliey; LPM 25.03; See also PPH

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13.05.00,8.00.00 [employees may be disciplined for not complying with Rules of

Prof. Conduct].)

District Attorney employees subject to a "gag order" from the court may not post

anything regarding that specific case on the internet while thc order is in cffect.

Failure to adhere to the provisions of the "gag order" may lead to sanctions by the

court and discipline by the District Attorney's Omce. Note that gag orders

typically extend to iill employees of the District Attorney's Omce.

E. Deputies must investigate ethically.

Social media sites may provide valuable infornlation to deputy district attorneys

during the invcstigation or pendency of their cases. However, deputies must not

violate ethical standards in their use of social media for investigative purposes.

Deputies are not pennitted to use a ruse or false profile to "friend" a potential

defense witness, defendant, or juror. (See the Sixth and Fourth Amendments of

the United States Constitution; San Diego County Bar Assoc. Legal EthicsOpinion 2011-2 [interpreting California Rule of Professional Conduct 2-100];

Office ofLmvyer Regulation v. Hurley (2/1112009) 2007AP478-D (Supreme

Court of Wisconsin); In the Matter of Poulter (Colo. 2002) 47 P.3d 1175 [DDA

impersonating a deputy public defender]; NY State Bar Assoc. Comm. on

Professional Ethics 402 (1975).)

III. Social Media Best Practices

Following are suggested best practices for use of social media sitcs by District Attorney

employees:

• Ensure that your privacy settings are as restrictive as possible. Review these

settings regularly, as social media sites are continuously evolving thcir user

account defau It security settings.

• Enable HTTPS (Hypertext Transfer Protocol Secure). HTl'PS provides

authentication between the web site and the web server and encryption of

communications. Activating HTTPS is one of the best things you can do to

enable secure browsing and minimize your account from being compromised.

Most social media sites and major personal e-mail services have a setting under

Account Security/Secure Browsing.

• For your security, be careful when identifYing yourselfas a District Attorney

employee on a social networking site.

• Regularly screen postings to your blog or social media site to make sure that

there are no postings that would cause embarrassment to you or anyone else,

including co-workers, or put you in danger.

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• Always consider the possibility that information posted on the internet may

become accessible to unintended viewers.

• Remember that members of the defense and media increasingly use the internet

to investigate the personal lives of adverse parties and witnesses, including prosecuting attorneys.

• All employees should assume their speech and related activities on social media

sites will reflect upon this office. Do not post anything on the internet that you

would not want to read on the front page of the newspaper under your byline.

• Content posted on the internet is public and permanent.

• Use common sense before posting information about promotional exams,

transfers, personnel issues, and other office-related subjects.

• When in doubt, seek guidance from your supervisor or the ProfessionalResponsibility Committee.

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Glossarv

B10g - Website where entries are commonly displayed in reverse chronological order.

can also be used as a verb, meaning to maintain or add content to a blog.

"Bloo"

"

Facebook - A social networking website where users can add "friends" and send them

messages and update their personal profiles to notifY friends about themselves. (Sec "Friend"

below.)

Follow/Following - A term used on "Twiner" when following the "tweet" or message of the

user. (See "Twitter" below.)

FriendlFriending - The term used when adding an associate on Facebook to your network.

Like - A term used on Faeebook to give positive feedback or to connect with content youendorse. You can "like" content that your friends post or pages that you want to connect with

on Facebook.

Online Identity - An online identity or persona is a social identity that an internet user

establishes in online communities and websites.

Social Bookmarks - A method for internet users to store, search, organize and share web

pages.

Social Media - The tool set (including blogs) which people can use to publish content to the

web. This can include audio, video, photos, texts, files, etc.

Social Networking - A term for the tools and platforms used to publish, converse and share

content online. The tools include blogs, "wikis," pod casts, and sites to share photos and

bookmarks.

Twitter - Twitter is a social networking and microblogging service that enables its users to

send and read messages known as "Tweets." Tweets are text-based posts of up to 140

characters displayed on the author's profile page. They are visible to the public and also

delivered to the author's subscribers who are known as "followers."

Virtual Private Network (VPN) - Allows a private network, such as Lotus Notes or

LADAnet, to bc remotely connected over the internet. VPNs allow only authenticated remote

access and use encryption to provide security.

Wikis - A website developed collaboratively by a community of users, allowing any user to

add or edit content.

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Documents

Transcript of ECF 346 Redacted