Beruflich Dokumente
Kultur Dokumente
This is all the Court needs to know in order to know that Defendant Stanley J.
Rumbaugh hates cameras in his Courtroom and will violate GR 16 protecting
open access to media with glee.1 But we have presented more much much
more than that, and in their purported defense of all things contrary to the
First Amendment and General Rule 16 Defendant Rumbaughs attorneys have
crossed a legal and ethical line
Now come Plaintiffs pursuant to FRCP 1 201 to note that Defendant Rumbaugh
and his Counsel have steadfastly argued in their most recent filing in
opposition to Plaintiffs First Amended Complaint that Plaintiff King only
attempted to run video on 24 February 2017 to cure a lack of Standing. Said
1 (c) If the judge finds that sufficient reasons exist to warrant
limitations on courtroom photography or recording, the judge shall make
particularized findings on the record at the time of announcing the
limitations. This may be done either orally or in a written order.
Defendant Rumbaugh has never followed this procedure in spite of the
fact that Plaintiffs had notified him prior to hearings.
Page 1 of 75
purported lack of standing purportedly dates back to his Amended Notice of
Media Coverage filed on or about 4 August, 2016.
2 Moreover, Ms. Duzan informs Plaintiff in an email of 1 April, 2017, no joking: Looks
like a court review hearing on 10/21/16, my motion to dismiss on 1/6/17 combined with
a court review, my motion for reconsideration on 2/24/17. So there may have been
SEVERAL hearings conducted by the Court after Plaintiff King filed his Notice of Media
Coverage but the Court never granted access for any of them, then again ignored King
on 24 February 2017 in yet another case in which King has legitimate questions as to
how Judge Rumbaugh is dispensing Justice in his Courtroom.
Page 2 of 75
As such, Plaintiffs bring to the Court the fact that there was at least one
other scheduled hearing before Defendant Rumbaugh (in addition to the
hearing of 24 February 2017) in which he AGAIN refused to follow the dictates
for GR 16. And of course GR 16 directly references the News Media and that
in turn directly implicates the Federal and State Constitutions relative thereto.
But Defendant and his lawyers commit a Fraud Upon the Court because
they write:
After King interrupted that separate February 24, 2017, hearing in Judge
Rumbaugh's courtroom without previously filing or noting a motion
much less filing ahead of time even what he labels a "notice of media
coverage"1
first place, and further there is the fact that Plaintiff King filed his
Notice of Media Coverage prior to Court and had courtesy copies with
him for Defendant Rumbaugh and all Counsel who might be present.
Page 3 of 75
King is fairly certain of his position in this case. And his Notice of
So then, it is clear that Plaintiff King has Standing in this case and
Defendant and his attorneys are both engaged in lying to this Court and trying
to cover up continued violations of GR 16. Such unrestrained and continued
disrespect for the integrity of Pleading must have consequences. See e.g. FRCP
11(b)(1); FRCP 12(f). Plaintiff hereby issues this Rule 11 Motion after a Safe
Harbor warning in addition to his Notice of Fraud Upon the Court filed in the
early morning hours of 3 April, 2017.
This is pretty simple unless Defendant and his Counsel are busy lying
and hiding material facts in order to to cover up the Truth: Ordinarily when
Plaintiff King files a Notice of Media Coverage on the same morning of the
event the Courts notify him that he is fine to record as long as the Judge then
agrees, and they have always agreed in Washington in approximately 100
opportunities. If the scheduled event is to occur in the future, then the Courts
simply notify Plaintiff King of the scheduled event and allow him to be heard
and to present, and this is precisely why Plaintiff King has not had to sue any
other judge in Washington State. Simple.
In sum, Defendant and his Counsel knew about the next scheduled
hearings but lied by omission to this Honorable Court, and this Honorable
Court will not stand for it and should no doubt issue sanctions sua sponte for
this sort of shenanigans.
Page 4 of 75
3.Judicial Notice and Lie #2.
In addition to the Judicial Notice of the scheduled hearing that Defendant and
his lawyers are trying to hide by omission there is also the fact that they try to
claim that Plaintiff did not notify them of his media purpose in an email. The
email is contained at Appendix A.
I'm going to get to the specifics and substance of the case soon, and it
involves a purportedly lost Note with a date uncertain for when an
indorsement was issued on it, but for now you need to know that my
First Amendment Rights as a Citizen, as a Journalist, and as a Citizen
Journalist were somewhat imperiled today when I was called back into
Honorable Monica Benton's Judicial Chambers where the following
colloquy ensued:
"Well Your Honor I was a reporter for a large daily newspaper, and editor
of a statewide daily before law school.... and I've been shooting these
movies in courtrooms throughout the Country for 4 or 5 years now, and
I've been covering this case already...." (I neglected to tell her I was an
escrow attorney who worked for WAMU but that is noted in my Notice of
Media Coverage, as is the fact that Joseph McIntosh and his buddies
unlawfully threatened to have me arrested as seen in this video, Judges
Will Watch as Foreclosure Mill Attorneys Threaten Depo Videographer
with Security and Arrest).
"Well Your Honor Judge Schubert has (one and two) and we and are on
great terms. He respects what I do and he said as much, I have that on
video I recorded on prior occasion."
Page 5 of 75
"I have some concerns about whether you are media."
You might audio but I'm not certain that entitles you to run video
(Googling Pooley+Mortgage Movies after I had told her to Google
Mortgage Movies) I'm at your website now and I see you have the
hear/see/speak no evil monkeys and skeletons...."
"Well I believe it does, and if this Court cannot take any step that would
infringe on my right to portray what I see as I see it, because that would
be inimical to the First Amendment."
Yet there is more: There was another email the following day clearly requesting a respo
*************
Christopher King kingcast955@icloud.com
7/21/16
to mreagan, duzabalm, fortune2000, cpeterson, me, Steve, Michelle, Scott
To All:
Thank you.
3 Not only that, of course the Notice of Media Coverage itself reads: KingCast
Mortgage Movies employs Mr. Kings legal background and experience as a licensed
title insurance producer and escrow attorney to analyse legal matters relative to
foreclosure; all footage shall be made available for media pooling orders or requests in
this regard. Plaintiffs are not exactly sure how much more clear it can be.. unless of
course you are dishonest and trying to run from the cameras, and whether or not such
argument is ad hominem or not if the shoe fits then Defendant wears it. Such is not
our fault or shame, but is rather the shame of Defendant and his lawyers, who have
now poisoned this Court with their lies and deceit, caught red-handed. Appendix B.
Page 6 of 75
CHRISTOPHER KING, J.D.
kingcast955@icloud.com
mortgagemovies007@gmail.com
http://affordablevideodepo.com
http://mortgagemovies.blogspot.com
617.543.8085m
206.299.9333f
http://www.seattletimes.com/seattle-news/crime/many-pierce-county-cases-
reversed-because-of-prosecutors/
An Associated Press review of all Washington cases that were reversed
on appeal since 2012 because of prosecutor misconduct found that 17
of the 30 cases were in Pierce County.
but now lets look directly at false filings and withheld evidence in a
Civil Context in the media and via a PACER inquiry:
http://www.thenewstribune.com/news/local/crime/article29751268.html
AUGUST 1, 2015
Pierce County Prosecutor Mark Lindquists timeline of legal issues
In Dalsing v. Linquist et al 3:15-cv-05520-BHS they withheld evidence in a
criminal case, just as they are doing in this Civil case:
Page 7 of 75
After losing a series of rulings in Lynn Dalsings subsequent false-arrest
lawsuit, prosecutors filed new charges of child rape against her in 2014.
They accused her of knowing about her husbands actions and aiding
them.
Those were the charges dismissed earlier this year due to prosecutorial
vindictiveness. Superior Court Judge Edmund Murphy found that
prosecutors wrongly claimed that new information justified new charges.
Murphy found that prosecutors were aware of the supposed new
information when the original charges were filed and did not act on it.
Dalsings attorney, Fred Diamondstone, said he filed the federal lawsuit
to address actions taken by prosecutors over the last two years that
werent part of the original lawsuit.
Our criminal justice system cannot function properly when government
officials deceive the courts, he said.
http://www.thenewstribune.com/news/local/crime/article29109742.html
Federal lawsuit accuses Pierce Prosecutor Lindquist and staffer of deceiving
courts
Please note that this corruption comes from the top down and is current:
http://www.thenewstribune.com/news/local/crime/article26299513.html
JUNE 12, 2015
New bar complaint accuses Lindquist of trying to influence judge
http://www.thenewstribune.com/news/politics-
government/article137860268.html
MARCH 11, 2017
Lindquist text message case: Still going, defense bills exceed $584,000
4 Precisely: Lie to win, at all costs. That is clearly the modus operandi. Plaintiffs are not
having any of it.
Page 8 of 75
According to the latest figures from the countys risk management
division, the public bill for the long-running legal tussle stands at
$584,989 and climbing, with the next stage of court action set for April 7
in Thurston County.
Coupled with other legal bills tied to complaints of misconduct by
Lindquist and his subordinates, the collective costs rise to $1.92 million,
with no near-term prospects for resolution.
Page 9 of 75
5.Summation and Allegedly Ad Hominem Remarks.
At one point Plaintiffs stated that Defendant Rumbaugh is only running
off to Court to avoid being caught on video, and that he lacks courage as a real
Jurist to face the thorny First Amendment implications of his misconduct.
Frankly, so what? That is part of Plaintiffs theory of the case, and no
sanction may lie within that framework. But yet and still, Counsel for
Defendant had the nerve to insinuate to this Court that Plaintiffs writing was
sanctionable.
No. What is sanctionable are the lies set forth in this Motion. As further
indication of the fraudulent nature of this defense let us review Defendant's
notion that Plaintiff King's most recent Notice of Media Coverage in which
Judge Rumbaugh unlawfully denied media access is somehow "Contrived:"
Plaintiff submits that the Defendant's Court is not in a position to sit in
judgment of the subject matter of media's production. Similarly nor is this
Court. Bloggers are journalists, pure and simple, and this is particularly true
given Plaintiff Kings empirical knowledge of the subject matter as a residential
closing attorney who continues to work in the field on second mortgage
consultation! Plaintiffs dont need any specific reason to be involved in media
in order to please Judge Rumbaugh. See generally Obsidian Finance v. Crystal
Cox (9th Cir 12-35238 Dist. Ct. No. 3:11 CV 00057) Further, in the Bozgoz
case, Plaintiff King as a former Civil Rights litigator and trial attorney most
definitely has an interest in the underlying personal injury subject matter, as
the law and facts of that case are extremely compelling in the mind of any
reasonable journalist:
A grandmother flipped upside down out of her wheelchair by a reckless
County paratransit driver, then abandoned by the driver with a broken
neck..... then the legal wrangling that followed is particularly
fascinating. Just because a major network has not covered this matter
does not mean that Defendant may ignore Rule 16, which he clearly
ignored when it comes to Plaintiffs in this case:
Page 10 of 75
have ever heard in their lives and it simply may not be interposed as a defense
in this case.
Plaintiffs King and Brown stand in precisely the same shoes as KOMO or
KING5 and when Discovery hits and we see the disparate treatment all of this
case will be going to Jury, in the King County Superior Court where Jurisdiction
actually exists.
And any insinuation that Plaintiffs are being subjected to a regular
matter of practice in that Courthouse also constitutes a lack of candor toward
the Tribunal, in violation of Rule 3.3 and more and a Complaint is being filed
with the State Bar Association as well. This office has long been involved in
ethically questionable activity and this case is no different.
WHEREFORE PLAINTIFFS DEMAND:
1. Defendant retract each and every argument postulated that asserts that
Plaintiff King lacked Standing to sue relative to the Duzan case, and;
2. Defendant retract each and every statement that King's emails prior to
the hearing made no claim he wanted to make a recording as "news
media" but only that he had "run courtoom video throughout the
County" as a business and was "request[ing] access as well" because
"you have denied by colleague Wally Brown camera access ." Dkt. 1-2
at 2-4, 11-18.
3. Costs to carry the Event and any and all such other Relief as the Court
deems appropriate.
Respectfully submitted,
___________________________________________
Christopher King, J.D.
___________________________________________
Wally Brown
___________________________________________
Chris Nubbe
Page 11 of 75
APPENDIX A
As I understand it, you have denied my colleague Wally Brown camera access
to a foreclosure hearing this Friday.
I have run courtroom video throughout the County on this and other issues and
I believe the denial runs counter to Constitutional and Statutory and Common
Law in the State of Washington and if it is not rescinded, I will sue.
I am not here to be popular or liked. Judge Monica Benton can't stand the very
sight of me, in spite of the fact that I was a Civil Rights lawyer and she has
Malcolm X and Martin Luther King on her wall. But she still granted access and
that is all... I repeat ALL.... that I care about.
http://christopher-king.blogspot.com/2015/05/kingcast-mortgage-movies-malcolm-x-
and.html
https://www.youtube.com/watch?v=zVNVyijeQKU
As you will see, I've been running Courtroom video since the mid 1990's.
Please advise.
Respectfully submitted,
kingcast955@icloud.com
mortgagemovies007@gmail.com
http://affordablevideodepo.com
http://mortgagemovies.blogspot.com
617.543.8085m
206.299.9333f
Page 12 of 75
APPENDIX B
KingCast.net Mortgage Movies
By: Christopher King, J.D.
17006 11th Avenue NE
Seattle, WA 98155 Hearing Date: 22 July 2016 & prospective
617.543.8085
Plaintiffs,
Defendants.
Now comes Christopher King, J.D., KingCast.net and Mortgage Movies Journal,
Washington Right to Access Law and all other applicable law to note that he intends to cover any
and all Courtroom exchanges relative to the above-captioned matter as well as any and all
I am a former Assistant Attorney General who has also managed a title insurance company as
a title insurance producer. I have also practiced First Amendment and Civil Rights Law throughout
the 1990s, routinely running video of said trials in an age before broadband. Prior to those
activities I was an editor and reporter for mid-sized and large daily press.
Page 13 of 75
I have run video since 2010 in courtrooms throughout the Country and in western Washington
on murder trials, civil litigation and foreclosure without incident including countless King County
KingCast Mortgage Movies employs Mr. Kings legal background and experience as a
licensed title insurance producer and escrow attorney to analyse legal matters relative to
foreclosure; all footage shall be made available for media pooling orders or requests in this regard.
In this particular case I have grave concerns that there is a pending First Amendment violation
of law. To wit, in email exchanges between Court personnel and the homeowner I emailed Ms.
As I understand it, you have denied my colleague Wally Brown camera access
to a foreclosure hearing this Friday.
I have run courtroom video throughout the County on this and other issues and
I believe the denial runs counter to Constitutional and Statutory and Common
Law in the State of Washington and if it is not rescinded, I will sue.
I am not here to be popular or liked. Judge Monica Benton can't stand the very
sight of me, in spite of the fact that I was a Civil Rights lawyer and she has
Malcolm X and Martin Luther King on her wall. But she still granted access and
that is all... I repeat ALL.... that I care about.
http://christopher-king.blogspot.com/2015/05/kingcast-mortgage-movies-malcolm-x-and.html
Page 14 of 75
https://www.youtube.com/watch?v=zVNVyijeQKU As you will see, I've been running
Courtroom video since the mid 1990's.
Please advise.
Respectfully submitted,
kingcast955@icloud.com
mortgagemovies007@gmail.com
http://affordablevideodepo.com
http://mortgagemovies.blogspot.com
617.543.8085m
206.299.9333f
*********
To compound injury I see that the Court is now actually contemplating levying ex parte
Sanctions against the homeowner for inquiring about First Amendment/Free Press Activity. That
strikes me as ridiculous because the nature of her inquiry as nothing to do with the Merits of the
case, and that is the true ambit of ex parte analysis. In point of fact, the homeowner likely has
Standing to Sue as well because the application of the Law is arguably overbroad in a manner that
Sincerely,
Merri Reagan| Judicial Assistant to Judge Stanley J. Rumbaugh | Pierce County Superior Court | Dept. #18 | 930 Tacoma
Avenue South, Room 334, Tacoma, WA 98402 | Phone: (253) 798-6650 | Email: mreagan@co.pierce.wa.us
IMPORTANT: In order to avoid inappropriate ex parte contact, you are hereby directed to forward this communication to all
other counsel/parties not already copied on this email.
Think Green. Before printing this e-mail ask yourself: "Do I need a hard copy?"
*********
************
Lastly, please note not only the Constitutional issues but the Statutory Presumptions:
Page 16 of 75
(b) The judge shall exercise reasonable discretion in
prescribing conditions and limitations with which media
personnel shall comply.
I specifically note that even if this matter is not addressed for any reason by tomorrows
hearing, it must be addressed immediately owing to future, prospective Relief: Open Courts are the
best Courts.
and all pending motions. The Proceedings will be on video for subsequent broadcast and
photographed with still camera, and available for any media pools per industry standard should
inquiry arise.
Respectfully submitted,
The undersigned certifies that a true and correct copy of the foregoing was delivered via
email on 21 July 2016 and 3 August 2016 and mailed via USPS mail on 3 August 2016 to the
following:
Plaintiff Duzan
and
_____________________________
Christopher King, J.D.
http://KingCast.net
http://MortgageMovies.blogspot.com
http://affordablevideodepo.com
617.543.8085/m
206.299.9333/f
Page 19 of 75
CERTIFICATE OF SERVICE
We, the undersigned, solemnly swear that a true and accurate copy of the
foregoing Notice was sent via email and tracked U.S. Mail on 3 April 2017 to
the following:
___________________________________________
Christopher King, J.D.
___________________________________________
Wally Brown
___________________________________________
Chris Nubbe
Page 20 of 75
IN THE UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON
5 Moreover, Ms. Duzan informs Plaintiff in an email of 1 April, 2017, no joking: Looks
like a court review hearing on 10/21/16, my motion to dismiss on 1/6/17 combined with
a court review, my motion for reconsideration on 2/24/17. So there may have been
SEVERAL hearings conducted by the Court after Plaintiff King filed his Notice of Media
Coverage but the Court never granted access for any of them, then again ignored King
on 24 February 2017 in yet another case in which King has legitimate questions as to
how Judge Rumbaugh is dispensing Justice in his Courtroom.
Page 21 of 75
King access, in spite of the fact that his Amended Notice of Media Coverage
contained the header:
Hearing Date: 22 July 2016 & prospective
As such, Plaintiffs bring to the Court the fact that there was at least one
other scheduled hearing before Defendant Rumbaugh (in addition to the
hearing of 24 February 2017) in which he AGAIN refused to follow the dictates
for GR 16. And of course GR 16 directly references the News Media and that
in turn directly implicates the Federal and State Constitutions relative thereto.
But Defendant and his lawyers commit a Fraud Upon the Court because
they write:
After King interrupted that separate February 24, 2017, hearing in Judge
Rumbaugh's courtroom without previously filing or noting a motion
much less filing ahead of time even what he labels a "notice of media
coverage"1
Page 22 of 75
So then, it is clear that Plaintiff King has Standing in this case and
Defendant and his attorneys are both engaged in lying to this Court and trying
to cover up continued violations of GR 16. Such unrestrained and continued
disrespect for the integrity of Pleading must have consequences. See e.g. FRCP
11(b)(1); FRCP 12(f). Plaintiff will be issuing a Rule 11 Fair Harbor letter this
week in addition to this Notice of Fraud Upon the Court.
This is pretty simple unless you are lying to cover up the Truth:
Ordinarily when Plaintiff King files a Notice of Media Coverage on the same
morning of the event the Courts notify him that he is fine to record as long as
the Judge then agrees, and they have always agreed in Washington in
approximately 100 opportunities. If the scheduled event is to occur in the
future, then the Courts simply notify Plaintiff King of the scheduled event and
allow him to be heard and to present, and this is precisely why Plaintiff King
has not had to sue any other judge in Washington State. Simple.
In sum, Defendant and his Counsel knew about the next scheduled
hearing but lied by omission to this Honorable Court, and this Honorable Court
will not stand for it and wil no doubt issue sanctions sua sponte for this sort of
shenanigans. Meanwhile Plaintiffs are drafting a Rule 11 Motion relative to
each and every argument Defendant and Counsel have made alleging that
Plaintiff King did not have Standing to sue, because it is all based on a lie by
omission. The Devil is in the Details folks, and there is plenty of Devil in this
room.
In addition to the Judicial Notice of the scheduled hearing that Defendant and
his lawyers are trying to hide by omission there is also the fact that they try to
claim that Plaintiff did not notify them of his media purpose in an email. The
email is contained at Appendix A.
I'm going to get to the specifics and substance of the case soon, and it
involves a purportedly lost Note with a date uncertain for when an
indorsement was issued on it, but for now you need to know that my
First Amendment Rights as a Citizen, as a Journalist, and as a Citizen
Journalist were somewhat imperiled today when I was called back into
Honorable Monica Benton's Judicial Chambers where the following
colloquy ensued:
"Well Your Honor I was a reporter for a large daily newspaper, and editor
of a statewide daily before law school.... and I've been shooting these
movies in courtrooms throughout the Country for 4 or 5 years now, and
I've been covering this case already...." (I neglected to tell her I was an
escrow attorney who worked for WAMU but that is noted in my Notice of
Media Coverage, as is the fact that Joseph McIntosh and his buddies
unlawfully threatened to have me arrested as seen in this video, Judges
Will Watch as Foreclosure Mill Attorneys Threaten Depo Videographer
with Security and Arrest).
"Well Your Honor Judge Schubert has (one and two) and we and are on
great terms. He respects what I do and he said as much, I have that on
video I recorded on prior occasion."
You might audio but I'm not certain that entitles you to run video
(Googling Pooley+Mortgage Movies after I had told her to Google
Mortgage Movies) I'm at your website now and I see you have the
hear/see/speak no evil monkeys and skeletons...."
Page 24 of 75
"Well I believe it does, and if this Court cannot take any step that would
infringe on my right to portray what I see as I see it, because that would
be inimical to the First Amendment."
6 Not only that, of course the Notice of Media Coverage itself reads: KingCast
Mortgage Movies employs Mr. Kings legal background and experience as a licensed
title insurance producer and escrow attorney to analyse legal matters relative to
foreclosure; all footage shall be made available for media pooling orders or requests in
this regard. Plaintiffs are not exactly sure how much more clear it can be.. unless of
course you are dishonest and trying to run from the cameras, and whether or not such
argument is ad hominem or not if the shoe fits then Defendant wears it. Such is not
our fault or shame, but is rather the shame of Defendant and his lawyers, who have
now poisoned this Court with their lies and deceit, caught red-handed. Appendix B.
Page 25 of 75
be scheduled before coverage ensues is the most ridiculous argument Plaintiffs
have ever heard in their lives and it simply may not be interposed as a defense
in this case. Plaintiff King stands in precisely the same shoes as KOMO or
KING5 and when Discovery hits and we see the disparate treatment all of this
case will be going to Jury, in the King County Superior Court where Jurisdiction
actually exists.
And any insinuation that Plaintiff are being subjected to a regular matter
of practice in that Courthouse also constitutes a lack of candor toward the
Tribunal, in violation of Rule 3.3 and more. This office has long been involved in
ethically questionable activity and this case is no different.
Respectfully submitted,
___________________________________________
Christopher King, J.D.
___________________________________________
Wally Brown
___________________________________________
Chris Nubbe
Plaintiffs,
Defendants.
Now comes Christopher King, J.D., KingCast.net and Mortgage Movies Journal,
Washington Right to Access Law and all other applicable law to note that he intends to cover any
and all Courtroom exchanges relative to the above-captioned matter as well as any and all
I am a former Assistant Attorney General who has also managed a title insurance company as
a title insurance producer. I have also practiced First Amendment and Civil Rights Law throughout
the 1990s, routinely running video of said trials in an age before broadband. Prior to those
activities I was an editor and reporter for mid-sized and large daily press.
Page 27 of 75
I have run video since 2010 in courtrooms throughout the Country and in western Washington
on murder trials, civil litigation and foreclosure without incident including countless King County
KingCast Mortgage Movies employs Mr. Kings legal background and experience as a
licensed title insurance producer and escrow attorney to analyse legal matters relative to
foreclosure; all footage shall be made available for media pooling orders or requests in this regard.
In this particular case I have grave concerns that there is a pending First Amendment violation
of law. To wit, in email exchanges between Court personnel and the homeowner I emailed Ms.
As I understand it, you have denied my colleague Wally Brown camera access
to a foreclosure hearing this Friday.
I have run courtroom video throughout the County on this and other issues and
I believe the denial runs counter to Constitutional and Statutory and Common
Law in the State of Washington and if it is not rescinded, I will sue.
I am not here to be popular or liked. Judge Monica Benton can't stand the very
sight of me, in spite of the fact that I was a Civil Rights lawyer and she has
Malcolm X and Martin Luther King on her wall. But she still granted access and
that is all... I repeat ALL.... that I care about.
http://christopher-king.blogspot.com/2015/05/kingcast-mortgage-movies-malcolm-x-and.html
Page 28 of 75
https://www.youtube.com/watch?v=zVNVyijeQKU As you will see, I've been running
Courtroom video since the mid 1990's.
Please advise.
Respectfully submitted,
kingcast955@icloud.com
mortgagemovies007@gmail.com
http://affordablevideodepo.com
http://mortgagemovies.blogspot.com
617.543.8085m
206.299.9333f
*********
To compound injury I see that the Court is now actually contemplating levying ex parte
Sanctions against the homeowner for inquiring about First Amendment/Free Press Activity. That
strikes me as ridiculous because the nature of her inquiry as nothing to do with the Merits of the
case, and that is the true ambit of ex parte analysis. In point of fact, the homeowner likely has
Standing to Sue as well because the application of the Law is arguably overbroad in a manner that
Sincerely,
Merri Reagan| Judicial Assistant to Judge Stanley J. Rumbaugh | Pierce County Superior Court | Dept. #18 | 930 Tacoma
Avenue South, Room 334, Tacoma, WA 98402 | Phone: (253) 798-6650 | Email: mreagan@co.pierce.wa.us
IMPORTANT: In order to avoid inappropriate ex parte contact, you are hereby directed to forward this communication to all
other counsel/parties not already copied on this email.
Think Green. Before printing this e-mail ask yourself: "Do I need a hard copy?"
*********
************
Lastly, please note not only the Constitutional issues but the Statutory Presumptions:
Page 30 of 75
(b) The judge shall exercise reasonable discretion in
prescribing conditions and limitations with which media
personnel shall comply.
I specifically note that even if this matter is not addressed for any reason by tomorrows
hearing, it must be addressed immediately owing to future, prospective Relief: Open Courts are the
best Courts.
and all pending motions. The Proceedings will be on video for subsequent broadcast and
photographed with still camera, and available for any media pools per industry standard should
inquiry arise.
Respectfully submitted,
The undersigned certifies that a true and correct copy of the foregoing was delivered via
email on 21 July 2016 and 3 August 2016 and mailed via USPS mail on 3 August 2016 to the
following:
Plaintiff Duzan
and
_____________________________
Christopher King, J.D.
http://KingCast.net
http://MortgageMovies.blogspot.com
http://affordablevideodepo.com
617.543.8085/m
206.299.9333/f
Page 33 of 75
CERTIFICATE OF SERVICE
We, the undersigned, solemnly swear that a true and accurate copy of the
foregoing Notice was sent via email and tracked U.S. Mail on 3 April 2017 to
the following:
___________________________________________
Christopher King, J.D.
___________________________________________
Wally Brown
___________________________________________
Chris Nubbe
34
IN THE UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON
Now come Plaintiffs pursuant to Rule 15 to note that Plaintiff King shall
hardship following catastrophic injury to their loved one. There have been
multiple attempts to limit recovery in that case and things appear suspicious
to this Reporter.
Plaintiff wrote:
WHEREFORE in this instance I provide this Notice to his honor via fax transmittal,
email transmittal and Priority U.S. Mail on this 21st day of February, several days prior to
hearing. I anticipate an email and phone call GRANTING this Notice by the close of
business, Thursday 21 February 2017. Otherwise here is what is going to happen: I am
going to appear in Court and the Court is going to follow the LAW as contemplated by
the United States and Washington Constitutions as well as Washington State GR 16
which reads --- again as follows:
35
Plaintiffs anticipate an Amended Complaint within the following
fourteen (14) calendar days but it may be sooner depending on the ongoing
litigation regarding Plaintiff Kings dog Livi, who was basically murdered at a
Respectfully submitted,
___________________________________________
Christopher King, J.D.
___________________________________________
Wally Brown
___________________________________________
Chris Nubbe
CERTIFICATE OF SERVICE
We, the undersigned, solemnly swear that a true and accurate copy of the
foregoing Notice was sent via email and tracked U.S. Mail on 21 February
2017 to the following:
___________________________________________
Christopher King, J.D.
___________________________________________
Wally Brown
___________________________________________
36
Chris Nubbe
MARGARET BOZGOZ,
Case Number: 16-2-121303-7
Plaintiffs,
v.
NOTICE OF MEDIA COVERAGE
YOUSEFF
Defendants.
Now comes Christopher King, J.D., KingCast.net and Mortgage Movies Journal,
Washington Right to Access Law and all other applicable law to note that he intends to cover any
and all Courtroom exchanges relative to the above-captioned matter scheduled for hearing at or
about 9:00 a.m. Friday, 24 February 2017 as well as any and all subsequent public Courtroom
I am a former Assistant Attorney General who has also managed a title insurance company
as a title insurance producer. I have also practiced First Amendment and Civil Rights Law
throughout the 1990s, routinely running video of said trials in an age before broadband. Prior to
those activities I was an editor and reporter for mid-sized and large daily press.
37
I have run video since 2010 in courtrooms throughout the Country and in western
Washington on murder trials, civil litigation and foreclosure without incident including countless
KingCast Mortgage Movies employs Mr. Kings legal background and experience as a
licensed title insurance producer and escrow attorney to analyse legal matters relative to
foreclosure; all footage shall be made available for media pooling orders or requests in this
regard.
In a prior case currently in litigation and improvidently Removed to Federal Court (2:17-
CV-0031) all Plaintiffs harbored grave concerns that there is a pending First Amendment
capricious application of law. To wit, in email exchanges between Court personnel and the
As I understand it, you have denied my colleague Wally Brown camera access to
a foreclosure hearing this Friday.
I have run courtroom video throughout the County on this and other issues and I
believe the denial runs counter to Constitutional and Statutory and Common Law
in the State of Washington and if it is not rescinded, I will sue.
I am not here to be popular or liked. Judge Monica Benton can't stand the very
sight of me, in spite of the fact that I was a Civil Rights lawyer and she has
Malcolm X and Martin Luther King on her wall. But she still granted access and
that is all... I repeat ALL.... that I care about.
http://christopher-king.blogspot.com/2015/05/kingcast-mortgage-movies-
malcolm-x-and.html
https://www.youtube.com/watch?v=zVNVyijeQKU
38
As you will see, I've been running Courtroom video since the mid 1990's.
Please advise.
Respectfully submitted,
kingcast955@icloud.com
mortgagemovies007@gmail.com
http://affordablevideodepo.com
http://mortgagemovies.blogspot.com
617.543.8085m
206.299.9333f
*********
Be that as it may in that case counsel for Defendant Rumbaugh gathered up a million
invalid reasons for completely violating the law, including but not limited to the false claim that I
had not notified the court in a timely manner of my request to appear as media.
WHEREFORE in this instance I provide this Notice to his honor via fax transmittal,
email transmittal and Priority U.S. Mail on this 21 st day of February, several days prior to hearing.
I anticipate an email and phone call GRANTING this Notice by the close of business, Thursday
21 February 2017. Otherwise here is what is going to happen: I am going to appear in Court and
the Court is going to follow the LAW as contemplated by the United States and Washington
************
39
(2) that media personnel not, by their appearance or
conduct, distract participants in the proceedings or
otherwise adversely affect the dignity and fairness of the proceedings.
have done in countless courtrooms in Washington State and throughout the United States for the
past seven (7) years without censure. The Proceedings will be on video for subsequent broadcast
and photographed with still camera, and available for any media pools per industry standard
Respectfully submitted,
40
41
CERTIFICATE OF SERVICE
The undersigned certifies that a true and correct copy of the foregoing was delivered via
___________________________________________
Christopher King, J.D.
___________________________________________
Wally Brown
___________________________________________
Chris Nubbe
_____________________________
Christopher King, J.D.
http://KingCast.net
http://MortgageMovies.blogspot.com
http://affordablevideodepo.com
617.543.8085/m
206.299.9333/f
42
IN THE UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON
7 The Defendants are free to make those same 12(b)(6) arguments in State Court.
Either way they are going to make them so there is simply no compelling reason to
retain Jurisdiction. See also Plaintiffs Declaration that explains why the written
request to dismiss the Federal Claim went unanswered.
43
Plaintiffs believe that His Honor has a great knowledge and understanding of
the Law.
44
Lastly, as to the fact that there appears to be a letter written to Plaintiff
requesting dismissal of the sole Federal claim, Plaintiffs Declaration noting
the 29 December 2016 mauling death of his Best Friend and Soulmate speaks
to that. As such, Plaintiff King as lead Plaintiff was pretty much incapacitated
mentally and emotionally, well beyond the realm of ordinary litigation as his
mental health Counselor and his Attorney Counselor will verify if necessary.
He is still going through mail received last month but an actual phone call
would have worked much better but alas, none was offered. One might
readily infer a bit of gamesmanship at play, again nothing new for that office
or that Defendant as noted in prior filings.
Respectfully submitted,
___________________________________________
Christopher King, J.D.
___________________________________________
Wally Brown
___________________________________________
Chris Nubbe
45
CERTIFICATE OF SERVICE
We, the undersigned, solemnly swear that a true and accurate copy of the
foregoing Motion was sent via email and tracked U.S. Mail on 10 February
2017 to the following:
___________________________________________
Christopher King, J.D.
___________________________________________
Wally Brown
___________________________________________
Chris Nubbe
46
IN THE UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON
Now come Plaintiffs, by and through lead Plaintiff King to move this
Honorable Court for Leave to file a brief Reply in Support of Remand, as
personal tragedy has been manifest, there is no untoward delay or prejudice
to Defendant and Justice compels the granting of the Request.
47
CERTIFICATE OF SERVICE
We, the undersigned, solemnly swear that a true and accurate copy of the
foregoing Declaration was sent via email and tracked U.S. Mail on 10
February 2017 to the following:
___________________________________________
Christopher King, J.D.
___________________________________________
Wally Brown
___________________________________________
Chris Nubbe
48
IN THE UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON
and
CHRIS NUBBE )
Plaintiffs,
v. )
Defendant. )
This matter came before the Court pursuant to Plaintiffs Request for
Leave to file a brief Reply to Defendants Response to his Motion to
Remand.
Good Cause having been shown, the Court hereby GRANTS said
Motion. The Plaintiffs Reply Memorandum shall be filed and docketed.
___________________________________
JUDGERICARDO MARTINEZ
49
IN THE UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON
PLAINTIFFS DECLARATION
Plaintiffs apologize for missing the written request to dismiss the First
Amendment Claim. There is however a valid reason for this oversight:
On 29 December 2016 I was on the East Coast, headed to New York
when my Partner and I got the phone call that nobody wants to receive: Our
Best Friend and Soulmate Livi had been mauled and killed in a kennel where
dogs were allegedly watched 24/7 and never unattended according to
their zoning application.
That begat immediate litigation as the two of us secured Pacific
Northwest Attorney Adam Karp to represent us and the defensive owner
obtained a patently abusive Stalking TRO against me that was immediately
DISMISSED as soon as the Snohomish South District Court hear all arguments
on 7 February 2016. It turns out that while I have not once had a Court Order
against me for abusing the First Amendment, Kristina Robinson of Precious
Paws was on the receiving end of a TRO that was GRANTED just last year for
abusing the First Amendment against someone else. It seems that cameras
scare a lot of people.
In the meantime coincidence brought my Partner and me a new puppy
Peppers and we have been mourning and trying to rebuild a family where
Livis little brother was in desperate need of another big sister and the two of
us were in desperate need of a companion in similar stature to Livi. It was
and continues to be completely devastating.
50
As such, I pretty much incapacitated mentally and emotionally, well
beyond the realm of ordinary litigation as my mental health Counselor and
my Attorney Counselor will verify if necessary. I am still going through mail
received last month but an actual phone call would have worked much better
but also none was offered.
51
**********
___________________________________________
Christopher King, J.D.
_________________________________________
NOTARY PUBLIC
MY COMMISSION EXPIRES___________________
CERTIFICATE OF SERVICE
We, the undersigned, solemnly swear that a true and accurate copy of the
foregoing Declaration was sent via email and tracked U.S. Mail on 10
February 2017 to the following:
52
955 Tacoma Avenue South
Suite 301
Tacoma WA 98402
strinen@co.pierce.wa.us
___________________________________________
Christopher King, J.D.
___________________________________________
Wally Brown
___________________________________________
Chris Nubbe
53
IN THE UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON
54
http://www.thenewstribune.com/news/local/crime/article26279821.html
That is because Pierce County Prosecutors lead the State in cases
overturned because of their flagrant actions. There is a treasure trove of
information in that feature that tells a neutral observer all they need to know
about the lengths that a Pierce County Prosecutor will go to in an attempt to
try to win a case. Its sad but true, and it informs this Courts judgment of the
integrity of Defendants specious arguments.
Pulliam v. Allen 466 U.S. 522 (1984) provides for Injunctive relief and
Plaintiffs have sought same. See also Dalsing v. Ausserer, Lindquist et al. WD
3:15-CV-05520.
Moreover, Judge Rumbaugh does not enjoy absolute immunity in this
context either on the merits or with respect to prospective relief owed to Mr.
King should the Court of proper Jurisdiction determine that Mr. King does not
have a live case in controversy.8
This case is all about Defendant Rumbaughs abject failure to follow
Washington GR 16, which sets out a number of substantive and procedural
safeguards that must be addressed by a Judge before any Prior Restraint may
be contemplated by the Court. The Rule speaks in absolute:
(b)Thejudgeshallexercisereasonablediscretionin
prescribingconditionsandlimitationswithwhichmedia
personnelshallcomply.
Obviously Statutory Construction reveals that the legislature would not intend
an absurd result, i.e. ORDER a Judge to do something then not allow for any
8 Recall that Plaintiff King filed an ongoing Notice for Media Coverage, requested a ruling and
never heard anything from Defendant so he has a ripe case. All of this is material that is
appropriately suited to Summary Judgment analysis anyway.
55
sort of Judicial relief in the abject failure of the Court to follow the Rule. All of
this will be addressed in further detail in the appropriate Court at the
appropriate time.
The analysis of the reach of GR 16 is naturally a STATE COURT
FUNCTION in the first place, and this Court really has no proper business
delving into it for the same reasons cited by this Honorable Court in KingCast
v. Wright, Finlay & Zack:
3. Fairness
**********
56
CONCLUSION AND PRAYER FOR RELIEF
Respectfully submitted,
___________________________________________
Christopher King, J.D.
___________________________________________
Wally Brown
___________________________________________
Chris Nubbe
57
IN THE UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON
and
CHRIS NUBBE )
Plaintiffs,
v. )
Defendant. )
58
___________________________________
JUDGERICARDO MARTINEZ
CERTIFICATE OF SERVICE
We, the undersigned, solemnly swear that a true and accurate copy of the
foregoing Motion was sent via email and tracked U.S. Mail on 30 January 2017
to the following:
___________________________________________
Christopher King, J.D.
___________________________________________
Wally Brown
___________________________________________
Chris Nubbe
59
IN THE UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON
CHRISTOPHER KING, J.D. )
A/K/A KINGCAST/MORTGAGE MOVIES
60
This Removal was nothing more than a dilatory tactic in the hopes that
this Honorable Court would retain Jurisdiction so that Plaintiffs could not run
video of these proceedings in King County Superior Court where they have
NEVER ONCE been denied camera access, and thats a fact.
In the 2016 Removal Case of KingCast v. Wright, Finlay & Zack9 the
Establishment
Defendants ran off to Court whilst ignoring Plaintiffs reasonable requests to
resolve Jurisdiction in extrajudicial manner simply because they didnt want
to appear on camera. Plaintiff King prevailed on Remand just as Plaintiffs
must prevail in this instance for all the same reasons.
61
will seek Removal based on that Claim. Plaintiffs anticipate a Removal
to Federal Court in order to avoid the presence of Cameras. Plaintiff
King recently prevailed on Remand in a similar matter earlier this year
but it may have required dismissal of the First Amendment claim, see
generally King v. Wright Finlay & Zak, 2016 U.S. Dist. LEXIS 53130
(2016).
Heaven forbid that Defendant would actually want the public to see
him defend First Amendment violations in State Court, but such is his nature,
apparently. Plaintiff is of course quite familiar with Removal, having
successfully tried an settled many Federal Cases since passing the bar in
1993. The issue here however is this: Plaintiff believes pursuant to the case
law he has set forth that he need not Voluntarily Dismiss his sole Federal
Claim in order to obtain Remand. Rather, the Court should Remand on its
own initiative because the heart of the case is an interpretation of GR 16.
The having been said, Plaintiffs nonetheless indeed hereby file a Voluntary
Dismissal and we suppose Defendants insurance carrier ultimately the
Taxpayers of the State of Washington -- may be happier knowing they no
longer have a Federal Cause of Action to Defend.
Moreover, Plaintiffs warned Defendant that any attempts at
gamesmanship will be met with full force opposition. See Appendix A.
62
Defendants cited cases are all much older than KingCast v. Wright,
Finlay & Zack and do not hail from this specific Jurisdiction and do not involve
Remand at the outset of litigation and are thus inherently inferior citations as
to Stare Decisis, particularly when all Defendants had to do was to pick up
the phone instead of attempting to run off and hide from cameras in Federal
Court, which is exactly what is going on here.
63
CONCLUSION AND PRAYER FOR RELIEF
Respectfully submitted,
___________________________________________
Christopher King, J.D.
___________________________________________
Wally Brown
___________________________________________
Chris Nubbe
64
APPENDIX A
I am going to move to Remand. You should understand the issues already from
reading the complaint -- I stipulated to damages and offered to waive the First
Amendment claim. This is a blatant attempt to avoid cameras following this event
and I am going to blast away on Remand in Federal Court.
Ciao.
206.299.9333f
From it, I anticipate that you and your client may engage in dilatory subterfuge up to
and including waging a war on Service/Service of Process. If that be the case, I would
strongly advise against it.
First of all, I'll have one of the PI firms that worked on the Amanda Berry case serve
him. I trust they can git er done.
With such in mind, I look forward to discussion and litigation on the merits, unless
your client is afraid of same. Because when we get to trial, if we get knocked around
for a year or more on evasive Motions and Memoranda, don't look for any
concessions from us.
Respectfully submitted,
65
617.543.8085m
206.299.9333f
IN THE UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON
and
CHRIS NUBBE )
Plaintiffs,
v. )
Defendant. )
___________________________________
JUDGERICARDO MARTINEZ
66
67
CERTIFICATE OF SERVICE
We, the undersigned, solemnly swear that a true and accurate copy of the
foregoing Motion was sent via email and tracked U.S. Mail on 17 January 2017
to the following:
___________________________________________
Christopher King, J.D.
___________________________________________
Wally Brown
___________________________________________
Chris Nubbe
68
IN THE UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON
and
CHRIS NUBBE )
Plaintiffs,
v. )
Defendant. )
___________________________________
JUDGERICARDO MARTINEZ
69
CERTIFICATE OF SERVICE
We, the undersigned, solemnly swear that a true and accurate copy of the
foregoing Motion was sent via email and tracked U.S. Mail on 17 January 2017
to the following:
___________________________________________
Christopher King, J.D.
___________________________________________
Wally Brown
___________________________________________
Chris Nubbe
70
IN THE UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON
and
CHRIS NUBBE )
Plaintiffs,
v. )
Defendant. )
In the 2016 Removal Case of KingCast v. Wright, Finlay & Zack the
Establishment Defendants ran off to Court whilst ignoring Plaintiffs
reasonable requests to resolve Jurisdiction in extrajudicial manner because
they didnt want to appear on camera. Plaintiff King prevailed on Remand.
Sadly the same pattern exists with this camera-adverse Defendant in
this case: Even though Plaintiffs expressly stipulated to Damages less than
$75,000.00 and stipulated to Dismiss the sole Federal Cause of Action,
Defendant and his Counsel is so scared of this case being caught on camera
that they thought it prudent to waste Judicial and taxpayer resources to make
a run on Removal instead of simply picking up the phone and asking Plaintiffs
if they would remove the Federal Claim. Again, Fn1 to Plaintiffs Complaint
read:
Plaintiffs hereby stipulate to Damages of less than $75,000 and hereby
stipulate that they will Voluntarily Dismiss their First Amendment
claims in the event that Counsel for Defendant informs them that s/he
will seek Removal based on that Claim. Plaintiffs anticipate a Removal
to Federal Court in order to avoid the presence of Cameras. Plaintiff
71
King recently prevailed on Remand in a similar matter earlier this year
but it may have required dismissal of the First Amendment claim, see
generally King v. Wright Finlay & Zak, 2016 U.S. Dist. LEXIS 53130
(2016).
72
____________________________
Christopher King, J.D.
73
IN THE UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON
and
CHRIS NUBBE )
Plaintiffs,
v. )
Defendant. )
____________________________________
JUDGERICARDO MARTINEZ
74
CERTIFICATE OF SERVICE
We, the undersigned, solemnly swear that a true and accurate copy of the
foregoing Motion was sent via email and tracked U.S. Mail on 17 January 2017
to the following:
___________________________________________
Christopher King, J.D.
___________________________________________
Wally Brown
___________________________________________
Chris Nubbe
75