IN THE DISTRICT COURT OF CARROLL COUNTY, MARYLAND

WILLIAM JOHN JOSEPH HOGE III )Petitioner )

v. ) Case # 06-C-14-067023)

WILLIAM M. SCHMALFELDT, SR. )Respondent )

RESPONSE IN OPPOSITION TO PETITIONER’S MOTION TO MODIFY AND EXTEND THE PEACE ORDER

Now comes respondent William M. Schmalfeldt, Sr. (Respondent) with a

motion to this honorable court to deny WJJ Hoge III’s (Petitioner) motion to modify

and extend the “Peace Order” issued by this court on August 27, 2015

STATEMENT OF FACTS

1. CJ § 3-1506(a)(1) clearly states “A peace order may be modified or

rescinded during the term of the peace order after: (i) giving notice to the

petitioner and the respondent and (ii) a hearing. (emphasis added)

2. CJ § 3-1505(f) clearly states “All relief granted in a final peace order

shall be effective for the period stated in the order, not to exceed 6 months.”

(emphasis added).

3. The order issued by Circuit Court Judge Michael Galloway on August

27, 2014, clearly states, “…unless stated otherwise below, this order is effective

until 08/27/2015.” (emphasis added) That is one year, not six months.

4. As the one year term of Judge Galloway’s order was not in keeping

with the state’s law mandating a six month maximum with the possibility of another

six month extension after a hearing and for good cause, the order was invalid from

the moment it was issued.

5. Had Respondent been in attendance at the hearing, instead of being

misled by Petitioner into believing that there was going to be no appeal of the

District Court’s denial of the initial peace order attempt, Respondent would have

noticed the error, asked for it to be corrected, and there would have been a valid

peace order, assuming one was issued.

6. Petitioner had ample opportunity to inform the court of this

“scrivener’s error” but chose not to do so.

7. Even if this had been a valid peace order for the first six months, that

six months expired February 27, 2015. It is not April 21, 2015 – nearly two months

later. The plaintiff cannot go back to the well a day, a month, two months, six years

after an order expires and demand that it be modified and extended. If this ever was

a valid peace order, it died on February 27, 2015.

8. Petitioner claims that Respondent continues to violate this non-extant

peace order. This is simply a lie. This court rejected Petitioner’s attempt to find

Respondent in contempt of court for violations of this alleged peace order. This

Petitioner had the Respondent charged with a count of violating the peace order and

the Respondent was found Not Guilty in a Carroll County District Court on April 16,

2015.

9. Respondent maintains that Petitioner’s motion is yet another

manifestation of the Petitioner’s malignant, megalomaniacal personality disorder.

He cannot be wrong. He must never be proven incorrect. This petitioner was found

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to have no cause for charges against respondent in Howard County in 2013. So

through his blog readership, he organized an “Everybody Blog About Howard

County Day,” distributing the e-mail address and phone number of the States’

Attorney in Howard County, disrupting that office’s ability to do its job of enforcing

the laws of the state and county, all because someone told him he was wrong. He

created and sold a line of “Maryland is for Stalkers” bumper stickers” on his website.

All because someone told him he was wrong.

10. After 367 nolle prosequi charges against respondent, Petitioner

continues to exhort his readership into continued acts of harassment against

Respondent. All because someone told him he was wrong.

11. Petitioner went so far as to file a fraudulent copyright infringement

suit against Respondent, details of which have been forwarded to the FBI for

investigation, naming himself as a copyright claimant which he is not as he does not

own all rights to the work, claiming that the pseudonymous author “Paul Krendler”

lives at his address, thereby defrauding the US Copyright Office, the US District

Court for the District of Maryland and this respondent with a frivolous, illegal

lawsuit. All because somebody told him he was wrong.

12. In his misbegotten contempt of court case against Respondent,

Petitioner introduced into evidence a forged letter, an obvious forgery with a traced

signature, a forgery a respondent will prove should one of our state’s law

enforcement agencies decide to investigate the claim, baldly stating that it was

mailed to him by Respondent, who had never seen the letter before Petitioner

included it in a motion to this court. All because someone told him he was wrong,

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CONCLUSION

13. This is a closed case.

14. This case has been closed for two months.

15. The peace order died at birth as it was improperly drafted and

nobody took the time or effort to point out the error to the court.

16. Assuming the peace order did not die at birth, it died on February 27,

2015 at the end of its six month lifespan.

17. Petitioner cannot apply salve to soothe the searing pain of being told

by a District Court Judge that the peace order was invalid and even if it was not,

there was no mens rea in the Respondent’s conduct and therefore he is not guilty, by

attempting to breathe life into a dead peace order.

THEREFORE: Respondent asks this court to:

A. Immediately deny Hoge’s motion to modify and extend the peace

order;

B. Order that Hoge get the permission of the court before issuing any

new charges or filing any new motions against this respondent.

C. Order that Hoge undergo a thorough psychiatric evaluation to

determine the reasons for this vexatious, malicious, vindictive, and bizarre need to

punish Respondent; and

D. Any other relief the Court may find just and proper.

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Dated April 21, 2015 Respectfully Submitted

William M, Schmalfeldt, Sr.Pro Se Respondent6636 Washington Blvd. #71Elkridge, MD 21075410-206-9637bschmalfeldt@comcast.net

CERTIFICATE OF SERVICE

I certify that on April 21, 2015, I mailed a copy of this filing to William John Joseph Hoge, 20 Ridge Road, Westminster, MD 21157 via First Class US Mail.

William M. Schmalfeldt, Sr.

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