I’ve been trying to make some sense of the responses that The Dread Pro-Se Kimberlin filed to the motions to dismiss from Aaron Walker, DB Capitol Strategies, The Franklin Center, and me in the Kimberlin v. the Universe, et al. RICO Madness. Some of his allegations contradict others.
Here’s an example. This first bit is from TDPK’s Amended Complaint.The important thing to note from this is TDPK’s allegation that his mythical RICO Enterprise existed since November, 2011, and that all the defendants were members from the beginning.
One the points that each of the motions to dismissed raised was that TDPK failed to meet the requirement to outline the structure of the RICO Enterprise in his Amended Complaint. He attempted to address that error by pleading new “facts” in his response to my motion. (That’s improper. He’s supposed to explain why his allegations were sufficient, not make new ones.) In that response he imagines that the National Bloggers Club is the RICO Enterprise.However, TDPK creates a problem for himself by trying to make the National Bloggers Club the RICO Enterprise. He alleged the following in his Amended Complaint.Do you see the problem?
TDPK alleges that the RICO Enterprise existed since November, 2011, and that it is an organization that was created in February, 2012.
Also, he alleges that all members were in the RICO Enterprise from Day One. I suppose I might have remembered something about a guy who claimed to have been Dan Quayle’s dope dealer, but I really wasn’t aware of Brett Kimberlin until late May, 2012. I wrote my first post about him on 23 May. Oh, and I didn’t join the National Bloggers Club until March, 2013.