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16 July Update: Boom! -- An independent journalist in Georgia got $200K

when they stopped her cameras, proving, ipso facto, that Georgia leads
Delaware on this crucial issue. I told those bastards a long time ago we are
going to SCOTUS for what they did to me. Let it be known that Georgia and
Alabama provide greater Constitutional protections to independent journos as
opposed to Delaware and its Courts.
KingCast v. McKenna vis a vis Tisdale v. Gravitt, 51 F. Supp. 3d 1378 (2014) --$200K Settlement, ahem.Tisdale v. Gravitt, 51 F. Supp. 3d 1378 (2014)
As an initial matter, the Court agrees that Plaintiff has a First
Amendment interest in filming public officials at a public
meeting. Smith v. City of Cumming, 212 F.3d 1332, 1333 (11th Cir.
2000) ("The First Amendment protects the right to gather information
about what public officials do on public property, and specifically, a
right to record matters of public interest."). Prohibiting Plaintiff from
video recording the meetingeven while permitting her to attend the
meeting, take notes, or make audio recordingsimpacted how she was
able to obtain access to and present information about the City Council
and its proceedings. See Blackston v. State of Ala., 30 F.3d 117, 120
(11th Cir. 1994).
And to think I offered to settle my case for a paltry $12,500 and they
rejected it! They are running around acting as if I don't know what I'm
talking about when I've won several First Amendment Jury trials for
Pete's sake. Judge Robert B. Young, in dismissing my Free Press lawsuit,
in sum:
1. Failed to convert my case to Summary Judgment even though there were
Admissions made by Defendants' Dispositive Motions and substantial
information and an offer of proof on an SD video card was submitted by me. I
had also shot Defendants' arguments about my Kelly Ayotte case full of lead

because now that Ayotte is an elected official -- i.e. a United States Senator
as opposed to a backwoods country-assed Recorder of Deeds mind you 1 -- I
run video of her at will, in her offices and in any public space, and that's a
fact, jack. So the Court didn't want any of THAT information in the Record so it
claimed to have ruled on the Pleadings and then the Court tried to send my
offer of proof SD video card of me running video in another office back to me
in the mail, so I sent it right back to the Court Wednesday. To hell with that: I
will not have him whitewashing the record just because an unsavory Negro
journo is ruffling feathers. See Commonwealth Constr. Co. v. Red Clay Consol.
Sch. Dist, 2010 Del. Super. LEXIS 489 (2010).
On a motion for judgment on the pleadings, if matters outside
the pleadings are presented and not excluded, the motion is
converted to a motion for summary judgment and is disposed of
as one for summary judgment under Rule 56. 3 When such
materials are presented the Court must give all parties a
reasonable [*5] opportunity to present all pertinent material
needed for a motion for summary judgment.
2. Failed to address the Advisory Opinion by the Attorney General who wrote,
in a 2011 Advisory Opinion:
But in 2011, when everyone has a cell phone, and most cell phones
have camera, even video, capability, that time has arrived. To attempt
to ban recording is as pointless as trying to prevent citizens from
taking notes.
CONCLUSION The DOJ should advise its client public bodies that to
outright prohibit any recording of public meetings is highly risky. The
law is evolving in a more permissive direction.
To which I ask, why is Judge Young (and the Defendants)
moving backwards?
Perhaps SCOTUS will help address this in a year or two.

1 See Appendix A.

3. Failed to address what is clearly my strongest case -- Pomykacz v.

Borough of W. Wildwood, 438 F. Supp. 2d 504 (2006).

Pomykacz was a self-described citizen activist who expressed

concern that a suspected romance between the towns mayor and a
police officer were leading to nepotism, conflicts of interest and
preferential treatment. These suspicions led Pomykacz to monitor
the two, which included taking photographs. Eventually she was
arrested on charges of stalking, though the charges were
downgraded to harassment. Pomykacz ended up filing suit asserting,
among other things, that she was arrested in violation of the First
Amendment retaliation for her monitoring activities.
U.S. District Judge Joseph E. Irenas noted,
Pomykacz has put forth sufficient evidence that she was a concerned
citizen who at times spoke her mind to Borough [*513] officials and
other citizens about her concerns regarding the official conduct of the
police department and the mayor. Such speech is clearly protected by
the First Amendment. 14 See Mills v. Alabama, 384 U.S. 214, 218, 86 S.
Ct. 1434, 16 L. Ed. 2d 484 (1966) HN15
("a major purpose of [the
First] Amendment was to protect the free discussion of governmental
affairs."); Roth v. United States, 354 U.S. 476, 484, 77 S. Ct. 1304, 1 L.
Ed. 2d 1498 (1957) ("The protection given speech and press was

fashioned to assure unfettered interchange of ideas for the bringing

about of political and social changes desired by the people.").
Again, Plaintiffs Fn5 to his Reply Memorandum in Support of
Reconsideration clearly notes that if it is illegal to arrest Pomykacz it is illegal
to threaten to arrest Pomykacz. The same goes for Plaintiff, Apples to Apples.
In fact, not only did the Court ignore this case, the Defendants failed to
address it as well. Like, what they thought I wouldn't catch it or something?
It's a Third Circuit case (NJ) and the fact pattern is clearly most analogous to
mine, but even much more exaggerated as she took pictures of these people
at all times of day, repeatedly. I just wanted to ask a couple of questions of
two high-ranking government officials and run some B-roll footage of
Candidate La Mar Gunn pulling up fraudulent documents on the County fiche
machines. This is simple stuff, folks. They are not compelled to answer my
questions but they are compelled to let me run the B-Roll footage unless I am
disrupting official business, which I would not be doing.
What I am doing, is being a pesky nigger on the Delaware Plantation
and the Defendants and the Court have made that more than clear. I will
however, continue to be that pesky nigger all the way to SCOTUS. Some
Rights they cannot take away.
4. He then lied about my next strongest case by stating that it was not
decided on First Amendment Grounds, but that, too was a lie because in
deciding it on Fourth Amendment grounds the court clearly contemplated Mr.
Iacobucci's First Amendment Right to be a journalist.
The Iacobucci Court gets it:
This case involves a small-town journalist, a small-town police officer,
and rights as grand as the Constitution itself.
See also Iacobucci v. Boulter, 1997 U.S. Dist. Lexis 7010, No.
CIV.A. 94-10531 (D.Mass, Mar. 26, 1997) (unpublished opinion)
(finding that an independent reporter has a protected right

under the First Amendment and state law to videotape public


From Iacobucci:
In the next decade, the SJC narrowed this definition of disorderly
conduct to encompass only activities not implicating the lawful
exercise of a First Amendment right. .
Boulter's repeated demands that Iacobucci cease recording do not
change the disorderly conduct calculus. A police officer is not a law
unto himself; he cannot give an order that has no colorable legal basis
and then arrest a person who defies it. So it is here: because
Iacobucci's activities were peaceful, not performed in derogation of any
law, and done in the exercise of his First Amendment rights, Boulter
lacked the authority to stop them. Id at 678.
5. Downplayed all of my professional background as stated in my Complaint
in favor of writing that Plaintiff holds himself out to be a type of guerrillastyle journalist. No Your Honor, if you were only going off of my Complaint
you know exactly how I project myself: As a trained journalist and
former escrow attorney who has made millions for the banks that
Defendant McKenna protects in her registry of Deeds. Complaint Para
2 reads:
Plaintiff is a former daily news reporter and escrow attorney who has
closed several dozen commercial real estate purchases and refinances.
He as successfully tried several First Amendment Jury Trial and has
operated several politically and legally-charged online journals over the
past decade, most notably Chris Kings First Amendment Page and
Mortgage Movies Journal. He has millions of website and movie hits,
thousands of followers and his work has appeared in alternative and
major press.


Ignored two key issues in my Motion for Reconsideration after

Commissioner Andrea Freud put the screws to me in a Hearing on my Motion

to Compel vis a vis Defendants' Motion for Protective Order.
First, he said that the Court has discretion per Rule 155 to deny me the
right to run video in Court. But as I made clear and as the forthcoming
transcript will show, Freud did not exercise discretion, she said that the Rule
did not apply to Trial Courts, which was another lie.
And, further, if she was going to exercise discretion, why exercise it to
prevent video from someone like me who is a trained professional journalist
and mortgage industry professional? Well I guess I've answered my own
question right there: She and Judge Young are not in the business of
dispensing Justice, they are in the business of protecting the banks and these
Second, he ignored my query about the fact that my image was posted
in the court building as if I were a person of interest or something. I had

Background: It was Completely Inappropriate to Have

Plaintiffs Image
Scattered Throughout the 414 Federal Street Building as if
he Were a Person of Interest.
Plaintiff is aware that there was at least one meeting with security

about him, and he is further aware that his image was posted throughout
the building. Plaintiff carries a Canon but he is not some sort of dangerous
black man who should be on a wanted poster. He is a mortgage industry
professional who has worked for major and small press. He is the new face
of journalism in the Modern Era, much as he was in 1998 when he advised

the Court of his right to run video in a Courtroom, which obviously worked
or you wouldnt be seeing this today:

Here one of her constituents said that Ayotte Is pleasant and sweet and full

of shit.

As such, Plaintiff is returning to the Court his Offer of Proof Video that
demonstrated him doing exactly what he wanted to do in Kent County, in
King County, Washingtons Registry of Deeds.: Only Dirty Deeds Recorders
Like Kent County DE's Betty Lou McKenna Restrict Media Access and

2 This record on Appeal will be as full as it should be, the Courts disdainful
commentary regarding Plaintiffs detailed Motion for Reconsideration