CHRISTOPHER KING, J.D.
17006 11TH Avenue
Seattle, WA 98155
617.543.8085 p
206.299.9333f
[email protected]15 July 2017 VIA EMAIL TRANSMITTAL AND TRACKED U.S. MAIL
Final Supplement to KingCast v. Mark Rattan 15-CV-03646 (SDNY)
The simple fact of the matter is that Litchfield, Cavo have been sued in Federal Court for
being sexist pigs so that fits perfectly into this puzzle, along with Wells Fargo hired Counsel
walking around calling people who look like Petitioner niggers.
Klein v. Litchfield, Cavo as reported by Above the Law, here is my email to the Office of
Lawyer Regulation, Johnson and others:
Yah if we want to play that game let's talk about a Name Partner and his sexism shall we?
http://abovethelaw.com/2015/05/so-i-cant-tell-my-associate-to-do-more-to-satisfy-her-
husband/
On that subject, another way to get to know your employees is to spend some time
with their family. Defendant Eckert also discussed Plaintiff Kleins sex life with her
husband and said
I feel your pain, I dont know how youre married to Bari.
While each day the conversation would begin relating to work, Defendant Eckert
would inevitably bring the conversation to relate to Plaintiff Kleins personal life.
Those conversations included questions about how often Plaintiff Klein had sex with
her husband, how it felt to have sex in her parents home, why Plaintiff Klein did not
have sex more often and asking if plaintiff Klein would ever cheat on her husband.
*********
Apparently, Klein didnt appreciate all this alleged great advice and asked her firm
to do something about it. As Law 360 reports: Klein regularly told the firms
partners about Eckerts behavior, saying she felt she was being treated differently
because of her gender, but nothing was done to improve the situation, according to
the complaint.
Klein had a severe panic attack one day in the office, but the firm did not call for an
ambulance until Kleins mother, who learned what happened, called one of the
partners and demanded that her daughter be taken to the hospital. By firing Klein
only five days after she returned from her FMLA leave, it will be difficult for
1
CHRISTOPHER KING, J.D.
17006 11TH Avenue
Seattle, WA 98155
617.543.8085 p
206.299.9333f
[email protected]
Litchfield Cavo to argue that the two are not connected, her attorney, Jesse Rose,
told Law 360 Tuesday.
***********
But see, it wasnt retaliation, the firm just thought she needed more time to recover
and yeah, I cant push this pretense any more. Klein seeks compensatory and
punitive damages of an unspecified amount and Litchfield Cavo and Eckert have a
pretty dismal set of allegations to overcome.
........I suppose this is all my fault as well? The fact of the matter is, in my 52 years on this
planet as a black man sensitive to the concerns of all minorities and people of moderate to
lower-incomes (including many white males) I have come to know the presence of
Hegemony, Racism, Sexism and that progeny of social anathema. Consider it as parallel to
the Miller Test for obscenity,
"I know it when I see it."
And so it should come to pass that with a few key strokes in PACER I uncover this gem,
fomented by another PARTNER. That corporate sickness trickles down folks, and it trickles
right on down the tops of the heads of people like Mark W. Rattan, but not on my watch it
doesn't. I have a history of exposing corruption and it is not about to stop now. Apparently I
should have been spending more time in PACER to learn about nasty white men and the
nasty white men who defend them. This one is going up on the blog and into the public
SCRIBD document later today.
Ciao.
Respectfully submitted,
CHRISTOPHER KING, J.D.
[email protected][email protected]http://affordablevideodepo.com
http://iamonlocation.com
http://mortgagemovies.blogspot.com
617.543.8085m
206.299.9333f
2
CHRISTOPHER KING, J.D.
17006 11TH Avenue
Seattle, WA 98155
617.543.8085 p
206.299.9333f
[email protected]
13 July 2017 VIA EMAIL TRANSMITTAL
AND TRACKED U.S. MAIL
In Re: Reply to Respondent Rattans Answer in File no.
I. Supplemental Analysis of Respondents Assault on Petitioner
A. The Video Analysis.
Well Attorney Johnson's obfuscation play almost worked but not quite, so Petitioner is
now placing this one page supplement into the Record via Overnight Mail today:
While addressing all of the extraneous material involved here Petitioner forgot to note
that even Respondent himself admits he is touching my camera and the picture of
blackness in this video frame is proof that this man put his hand over the lens of said
camera. He did this as Petitioner was holding the camera AFTER Respondent is seen
moving it first at 6:56 of the unedited video
https://www.youtube.com/watch?v=m4_E3X_E9yo
Moreover one may audibly hear the following discourse at 6:54 6:57.
"Don't you touch my camera!"
"Oh I'm touching your [inaudible]."
As one may readily see from the still frames Respondent's hand is all over the camera
whilst Petitioner is holding the camera. The camera is the size of a deck of playing cards
so OF COURSE there was contact between the two men's hands. Attorney Dykestra's
self-serving Affidavit to the contrary. She is a Partner in the same firm subject to Civil
Liability, ahem.
The bottom line is that for all of my background matters whether I have attained Justice
for my trainees, fought for Civil Rights, won Mayoral Commendations or whether I be a
reformed mass murderer NONE OF THAT MATTERS.
The proof is in the pictures.
3
CHRISTOPHER KING, J.D.
17006 11TH Avenue
Seattle, WA 98155
617.543.8085 p
206.299.9333f
[email protected]
Respectfully submitted,
CHRISTOPHER KING, J.D.
[email protected][email protected]http://affordablevideodepo.com
http://iamonlocation.com
http://mortgagemovies.blogspot.com
617.543.8085m
206.299.9333f
4
CHRISTOPHER KING, J.D.
17006 11TH Avenue
Seattle, WA 98155
617.543.8085 p
206.299.9333f
[email protected]
5
CHRISTOPHER KING, J.D.
17006 11TH Avenue
Seattle, WA 98155
617.543.8085 p
206.299.9333f
[email protected]
10 July 2017 VIA EMAIL TRANSMITTAL
AND TRACKED U.S. MAIL
In Re: Reply to Respondent Rattans Answer in File no.
I. The Merits: The Plain Language of Referee Winiarskis Edict and the Supporting
Video Clearly Demonstrate Respondents Ethical Violations.
A. The Video Analysis.
The day prior to Respondents loss of control Referee Winiarski expressly held that
Petitioner could run video and take stills. While the Referee and Petitioner would argue
over whether or not he could take 2 versus 3 still pictures with his DSLR there never was
ANY dispute about the presence and operation of the still camera that Respondent
traversed the entire room to attack. At bottom this is a simple case as noted in an email to
Counsel for Respondent in which Petitioner stated:
All I care about is why you and Respondent believe he had the right to alight from
his chair, charge across the room and assault me. You may continue to ignore the
emails and wait for the full response and the full audio/video or you can read along
with the others, the choice is yours.
With such in mind we now turn to the full, unedited portions of the hearing. Contrary to the
implications of Respondent, they do him no favors and in fact when viewed by any neutral
observer reveal Petitioner as a logical, professional person in a very hostile environment.
Respondents excuses carry no moment whatsoever as Petitioner has taken stills and shot
video of attorneys and their clients in much closer quarters than those at the hearing as
seen at one of Petitioners websites:
http://www.affordablevideodepo.com/
http://www.affordablevideodepo.com/motion-reel
6
CHRISTOPHER KING, J.D.
17006 11TH Avenue
Seattle, WA 98155
617.543.8085 p
206.299.9333f
[email protected]
Now then, turning to the analysis of all that is relevant:1
OLR v. Nora - Day 2 - March 23, 2017
https://www.youtube.com/watch?v=m4_E3X_E9yo
The effect a cameraman has on a subject is completely irrelevant. There have been video
depositions for ages on end, and Petitioner has run video at them and publicly posted them.
Petitioner has a right to take pictures, pure and simple and he never has had to ask
permission to take a few stills but yet and still that is what he did. He had not violated any
rules yet the Hearing Officer is treating him as if he was the problem, which is complete
nonsense. Referee Winiarski then proceeded to browbeat Petitioner with the notion that he
is illegally leaving his camera on but this is yet another red herring as Petitioner had already
explained to him that he always turns his camera off during recesses as he has for literally
hundreds of other occasions except for ONE TIME when there was an equipment
malfunction because of a loose mechanism on the record on/off button.
1Contrary to the wishful thinking of Respondent, nothing about Petitioners alleged background as
presented by him is relevant to his actions on the day in question, as a matter of fact and law. If
Respondent believes Petitioner has committed fraud then he is free to use this as a defense in
damages when he is sued for Assault and he may report the conduct, along with a copy of the full
video, to the Ohio Bar Association. It is that simple.
7
CHRISTOPHER KING, J.D.
17006 11TH Avenue
Seattle, WA 98155
617.543.8085 p
206.299.9333f
[email protected]
The way that Referee Winiarski and the Respondent treated Petitioner was abusive and
patently ABSURD.
*************
But prior to Respondents unethical and unprofessional explosion the Referee had
begrudgingly outlined the ambit of Petitioner's authority in this video, noting:
"We will call him the press in this case...."2
Well that's good because that is exactly what Petitioner is. He currently works for a Seattle-
based media company. He worked for large daily and weekly press and now he is his own
press. Welcome to the 21st Century whether Respondent likes it or not.
OLR v. Nora - Day 1 - March 22, 2017 a/k/a Get up, stand up..(for your Rights).
https://www.youtube.com/watch?v=_nJ7XjK37C4
Respondent: "Stop taking my picture, he is not allowed to take my picture."
Note: Again, FALSE.
Respondent: "I ask that this man be removed."
Petitioner: "No."
Hearing Examiner: "My research shows that this is a public hearing and my research
shows that he is allowed to be here."
Hearing Examiner: "It borders on harassment when he sticks the camera in someone's
face" ....... states Winiarski as he states that taking pictures is intimidating and implores
Petitioner to stand up when taking photos, failing to realize that he had already admonished
Petitioner for standing up. This led Petitioner to note "I can't win for losing."
2 As if Referee Winiarski is being charitable in calling Petitioner a member of the press. He works for
a media concern, he has his own independent press and has written for a major weekly (Indianapolis
Star) and edited a statewide weekly (Ohio Call & Post). The Referees disdain is palpable and is
completely unacceptable.
8
CHRISTOPHER KING, J.D.
17006 11TH Avenue
Seattle, WA 98155
617.543.8085 p
206.299.9333f
[email protected]
Again, Referee Winiarski's Petitioner routinely runs video Depositions in rooms smaller
than this and the proof has been provided, above. There was no need for the abuse tendered
toward Petitioner from Respondent and from Referee Winiarski.
Petitioner: "These are the issues of living in a free society.... that is his burden."
A video card reproduction of these original, unedited videos will be posited with the OLR
shortly along with this full reply.
B. The Affidavit of Attorney Dykeman is Completely Irrelevant and False.
The Affidavit of Attorney Dykeman is completely irrelevant as for all of the reasons noted
above and throughout this Reply. Respondent did in fact touch Petitioners right hand and
his camera when he grabbed his camera and that is SWORN UNDER OATH by this response.
As a matter of law by touching Petitioners camera whilst Petitioner was holding it is ALSO
the same as a touching, but we need not delve into that in this space because we ALL know
by the video that Respondent grabbed Petitioners camera. That much is 100% CLEAR.
The fact that someone may be offended by a stationary video camera is of no legal import in
this proceeding, and as noted elsewhere in this filing others have been placed in much
closer proximity to Petitioners cameras without incident. See the still image from Lucero v.
Bayview vis a vis the resulting case of KingCast v. Wright, Finlay & Zak, infra.3
C. The Swiveling of the Video Camera is Completely Irrelevant.
At pp. 48-50 Respondent attempts to make issue of Petitioner standing and taking pictures,
but the problem with that is the fact that the Hearing Officer alternately barked directions at
Petitioner to stand up, or to sit down. It was completely arbitrary and capricious, not to
mention the fact that, again, Petitioner has routinely shot counsel and witnesses from even
closer proximity so that issue is of no moment.
3Respondent attempts to use this case in his favor even though these bank attorneys lied and
claimed that Petitioner issued a DEATH THREAT. No police report or call to the FBI was initiated at
any point in time. They were sued in State Court, attempted to Remove to Federal Court and were
resolutely SLAMMED by Senior District Judge James L. Robart. The case settled on Remand. How this
supports Petitioner is anyones guess. In reality it just goes to show the outright hubris demonstrated
by abusive bank attorneys, nothing more nothing less. Everyone knows Respondent did not threaten
anyones life, it is ridiculous and that is why no criminal complaint was filed it certainly was not
because Wright, Finlay & Zak was being charitable to Petitioner.
9
CHRISTOPHER KING, J.D.
17006 11TH Avenue
Seattle, WA 98155
617.543.8085 p
206.299.9333f
[email protected]
The only somewhat arguable point made by Respondent is whether or not Petitioner turned
the video camera to him instead of the witness. Of course he turned the still, stationary
camera toward the Respondent because they were engaged in active discourse in a
public forum and Respondent was the initiator of that very discourse concerning
Petitioners substantive rights.
Surely Respondent and Counsel dont believe that such conversation is somehow in any way
exempt from public review, because it is not. Respondent has posited a completely baseless
and silly argument.4
4 For that matter, had Petitioner set up his camera at a different angle Respondent would have been
in the frame the entire time anyway, so whats the point? There is no point.
10
CHRISTOPHER KING, J.D.
17006 11TH Avenue
Seattle, WA 98155
617.543.8085 p
206.299.9333f
[email protected]
D. Racial and other Invective Raised by Respondent.
First of all the racial invective most prominent on Petitioners Mortgage Movies page from
another Wells Fargo contract attorney who called Petitioners video client A nigger.
https://www.youtube.com/watch?v=iJ5LI-t2C8c
It is fascinating that racial invective is mentioned by Respondent relative to Petitioners
website given that he is a Civil Rights activist and Ohio Supreme Court Disciplinary Panel
member Lou Jacobs opined that Racism and Reactionary Politics played a role in
Petitioners suspension not disbarment from practice.5 (Appendix A).
Moreover, in the NAACP/Willie Toney matter, that young black man faced three (3) drawn
police guns and a visual body cavity search for LOITERING, and thats a fact. Along the way
Jaffrey Police Chief Martin Dunn laughed audibly in a deposition about a racially-tinged
piece of hate mail that read You bout to be bubbas bitch. You coconut head racist. Better
get that Vaseline ready. Dunn said Of course its funny. (Appendix B)
Classy.
5Attorney Johnson playing fast and loose with the facts. Apparently he never lets the facts get in the
way of a good argument.
11
CHRISTOPHER KING, J.D.
17006 11TH Avenue
Seattle, WA 98155
617.543.8085 p
206.299.9333f
[email protected]
Lastly, as noted below, the entire American Tower case involved racism as American Tower
Corporation was upset about the pending Department of Labor matter and Petitioner being
a whistleblower so they actually called him a Dangerous Black Man. Naturally this
resulted in litigation and settlement for Petitioner and for Attorney Ana Crnilovic, a white
woman who defended Petitioner and told American Tower they could not buy her off with a
promotion. And we also know that American Tower Company was sued by the SEC for
fraudulent conduct involving backdated stock options, and Petitioner was interviewed by
the SEC attorneys about that as well. (Appendix C).
Good company that Respondent is keeping then.
Classy.
As to other invective, perhaps Respondent is referring to a certain security guard in New
Jersey: Petitioner had appeared with a homeowner to ask a few simple questions at the
foreclosure mill office of Phelan Hallinan & Schmieg at what Petitioner believes to be yet
another unlawful foreclosure. Everyone in the office abandoned ship, causing the retired
police officer to become visibly upset at them as he uttered:
We dont know what the fucking problem is, because no one is answering the door.
http://christopher-king.blogspot.com/2011/07/jackasses-at-phelan-hallinan-smieg.html
https://www.youtube.com/watch?v=JqtYaURdqMI
Whereupon he and his assistant engaged in genuine conversation with Petitioner and the
homeowner about Americas mortgage crises and the dirty law firms who protect big banks.
So perhaps THAT is the invective that truly concerns establishment attorneys like
Respondent and his Counsel.
12
CHRISTOPHER KING, J.D.
17006 11TH Avenue
Seattle, WA 98155
617.543.8085 p
206.299.9333f
[email protected]
E. Wells Fargos History of Deceit.
Respondent is a Wells Fargo contract attorney, just like the one who called that black
woman A Nigger. If Petitioners past is relevant then Wells Fargo history is relevant. If
Petitioners background is allowed to be questioned then we can certainly call into question
Wells Fargos background as well because that is who Attorney Rattan represents, and we
already know that Wells Fargo paid out $175M for racist practices:
http://www.rawstory.com/2012/07/wells-fargo-pays-175-million-for-racist-lending/
In addition to the fact that they hire and retain racist attorneys like Howard Apgar who call
elder black women niggers.
There is simply no record of any issues with Respondent as a journalist that reflect
favorably on Respondents case. Citing to a settled lawsuit in Respondents referenced case
involving Wright, Finlay and Zak after Petitioner won Remand in Washington Western
District Court does not help their case either.
Judge Drain (SDNY BK Judge) admitted the Wells Fargo fraud manual into evidence last
year. Franklin v. Wells Fargo 15-CV-1701 (2016)
http://nypost.com/2015/01/31/ny-federal-judge-slams-wells-fargo-for-forged-mortgage-docs/
https://www.nytimes.com/2015/02/01/business/01gret.html
They actually have a process by which they manufacture documents to create the
appearance of Standing or Real Party in Interest. That was precisely the issue at hand in a
prior link shared in which Wells Fargo gave my mortgage client not one but two shady
allonges, none of which was attached to their Note. So that case settled too.
http://christopher-king.blogspot.com/2016/08/kingcast-and-mortgage-movies-update-on.html
Meanwhile, from Judge Drain noting the depths of their deceit:
Because Wells Fargo does not rely on the Assignment of Mortgage to
prove its claim, the foregoing evidence is helpful to the Debtor only
indirectly, insofar as it goes to show that the blank indorsement,
upon which Wells Fargo is relying, was forged. Nevertheless it does
show a general willingness and practice on Wells Fargos part to
create documentary evidence, after the fact, when enforcing its
claims, WHICH IS EXTRAORDINARY
13
CHRISTOPHER KING, J.D.
17006 11TH Avenue
Seattle, WA 98155
617.543.8085 p
206.299.9333f
[email protected]
Next, speaking of Seattle and King County, my colleague Marie McDonnell was hired by the
City to conduct a MERS audit for King County. When she found complete illegality on the
part of Wells Fargo, MERS and others and recommended legal action such as that taken by
Multnomah County in Oregon (i.e. suing MERS) Seattle Council sat on the audit. As the
Council had attended a housing forum I organized two years prior I called them on the mat
and leaked the audit from an inside source when they dragged their feet on releasing it and
refused to call Ms. McDonnell to present at City Hall. At any rate Seattle City Councilors
might take issue with Petitioner from time to time but they attended his forum on
mortgages and underwater homes and never accused him of anything illegal because
Petitioner is a consummate mortgage professional and videographer. Thats why award-
winning author David Dayen featured Petitioner in a major news story:
https://theintercept.com/2015/09/18/leaked-seattle-audit-concludes-many-mortgage-
documents-void/
14
CHRISTOPHER KING, J.D.
17006 11TH Avenue
Seattle, WA 98155
617.543.8085 p
206.299.9333f
[email protected]
http://mortgagemovies.blogspot.com/2013/10/kingcastmortgage-movies-applaud-6-of-8.html
Be that as it may, we brought her in to town ourselves and had our own summit:
http://mortgagemovies.blogspot.com/2015/12/kingcast-and-mortgage-movies-
present.html
Mind you all of this was shortly after Ms. McDonnell was expert witness in a record $5.4M
Wolf v. Wells Fargo case involving a Fraudulent Transfer of Lien.
http://stopforeclosurefraud.com/2015/11/13/wolf-vs-wells-fargo-wells-fargo-must-pay-
5-4m-in-robosigning-foreclosure-row/
So yes any attempts by a Wells Fargo attorney to impugn Petitioners character prove that
every time they point a finger at him hey have several pointing back at themselves. Such
attempts are not to be well-taken by this Tribunal. We shall stick to the issue at hand as
Petitioner told Attorney Johnson in a recent email:
"All I care about is why you and Respondent believe he had the right to alight from
his chair, charge across the room and assault me. You may continue to ignore the
emails and wait for the full response and the full audio/video or you can read along
with the others, the choice is yours."
15
CHRISTOPHER KING, J.D.
17006 11TH Avenue
Seattle, WA 98155
617.543.8085 p
206.299.9333f
[email protected]
16
CHRISTOPHER KING, J.D.
17006 11TH Avenue
Seattle, WA 98155
617.543.8085 p
206.299.9333f
[email protected]
F. Alleged Perjury on Petitioners Statements.
With respect to the wishful thinking of Attorney Johnson there is no Perjury involved here.
Petitioner left the following comment on YouTube:
Nope, cops come along and say nothing to see here.... I could have lied and said my
finger was tweaked and THEN you have a battery case. But I won't lie. The behavior
speaks for itself and he will be identified and it will be broadcast thoroughly in all of
his circles shortly. BTW it was NOT surreptitious he knew damn well from
YESTERDAY I was running video of the event and the fucking tripod is sitting 4 feet
from me. Watch yesterday:
Later when Petitioner did say his finger was tweaked the only issue was whether there was
DIRECT CONTACT on the finger in question or not. Petitioner told the police at the time that
he was not certain as to whether the exchange added to the existing tweak or not but
Petitioner specifically told the police that his finger had been tweaked for years and as such,
when Petitioner issued his Demand Letter to Attorney Johnson, it specifically alleged only
ASSAULT and not BATTERY so there is no material inconsistency at issue here.6 Again
Petitioner wrote:
When an aggrieved person brings an action for assault, he or she must prove all the
elements of the cause of action, [ 11], which elements are the following:
(1) the actor made an overt act [12, 13];
(2) intending to cause a harmful or offensive contact, or imminent apprehension of
such a contact [14,15];
(3) with or by the person of the other [ 16];
(4) without consent [ 17];
(5) and the other was thereby [ 18];
(6) put in reasonable imminent apprehension of a harmful or offensive contact
[19, 20].
6Interestingly, Respondent has publicly filed a confidential settlement demand, believing his Waiver
would someone support his cause. Why he would believe as much is anyones guess but Petitioner
will remind him that when he is assaulted or encounters material interference with his Constitutional
Rights, yes he will sue.
17
CHRISTOPHER KING, J.D.
17006 11TH Avenue
Seattle, WA 98155
617.543.8085 p
206.299.9333f
[email protected]
Moreover, one can clearly hear Petitioner state contemporaneously "Now he's all up on me"
so there was contact between the two men and Respondents hand definitely touched
Petitioners camera and his hand but Petitioner also believes he bumped his finger on the
camera himself, because of Respondents actions.
A picture of the pinky appears below such that one can see that it is indeed already tweaked
so when it is bumped Petitioner is hard-pressed to say there was any ADDITIONAL
damages, hence his claim and arguments do not include any Action for Battery, only
Assault. And Respondent clearly assaulted Petitioner.
Once again perhaps Counsel for Respondent would do well to notice the distinction as it is
not overly difficult. In fact it is just about as easy as the difference between disbarred
and suspended if one is making an argument with any integrity. But alas, as we have seen,
Respondent shall not apparently allow the facts to get in the way of a good story so there we
are.
G. The Hegemonic and Impliedly Racist Notion that Respondent Travels from State to
State to Manufacture Litigation.
This is at once specious and heinous and is also addressed below in the Motion to Strike, but
it must be specifically called out here:
[Petitioner] moves from state to state for the purpose of shamefully manufacturing
incidents that he unsuccessfully tries to parlay into lawsuit and disciplinary actions"
(Response p3) writes Respondent.
18
CHRISTOPHER KING, J.D.
17006 11TH Avenue
Seattle, WA 98155
617.543.8085 p
206.299.9333f
[email protected]
Petitioner is a Civil Rights activist. Sometimes he and his subjects win, sometimes they draw
and sometimes they lose. But along the way and first and foremost Petitioner moved about
the Country because he was in the wireless industry and thats what one does as a Project
Manager before opening a Title Company. See some of Petitioners business cards at
Appendix F. He is now a mortgage professional who conceived and hosted a Seattle City
Council forum on foreclosure and underwater mortgages as seen above.
Plaintiff has lectured and continues lecturing in college classrooms (some with police
enforcement and AFTER the entire indictment case) and is decorated by Mayoral and
Aldermanic First Amendment Commendation in the very City and State in which he was
wrongfully indicted. The Commendation and Aldermanic participation occurred AFTER the
bogus Indictment and Unauthorized Practice of Law cases brought by NH AG Kelly Ayotte
were all well-known and DISMISSED.
Below, Petitioner is lecturing about a multiple homicide police coverup with Randolph
Police Lieutenant George McNeil. McNeil is now Police Chief over in Somerset, ahem. He
hates dishonest law enforcement just as much as Petitioner.
http://christopher-king.blogspot.com/2009/11/kingcast-joins-lieutenant-george-
mcneil.html
19
CHRISTOPHER KING, J.D.
17006 11TH Avenue
Seattle, WA 98155
617.543.8085 p
206.299.9333f
[email protected]
II. Motion in Limine and/or Motion to Strike.
A. The Hearsay Affidavit of Attorney Dykeman.
First of all, with his sworn signature Petitioner hereby declares that one of Respondents
hands did in FACT touch the top of Petitioners hand, so her Declaration from 8 feet away is
of no moment and there is practically no way should could even discern as much from that
distance and in the flash of a second. Done.
Further, as noted in todays email:
Wow Attorney Johnson,
"The police officer who entered the conference room after having spoken to King
in the corridor outside the conference room stated that King had told him that
Respondent did not touch King during the March 23 Nora proceedings."
Move to Strike, what a complete JOKE.
First of all, Petitioner is pursuing these officers legally because they completely violated
their own protocol by not even issuing a Report, and the area prosecutor mentioned
that to Petitioner herself.
Petitioner told the police his finger was tweaked but honestly could not tell if it was
from direct contact with Respondent or from his finger against the camera. Had the
police actually done their job this would have been in the official Report, ahem.
This was 15 minutes after the fracas so it is not an excited utterance. Go get that cop to
say that on the Record with a straight face or pack it in.7
7 And then Petitioner can cross examine him and ask why he failed protocol by not even logging the
matter. Brown man in a white town in a white establishment dealing with a high-powered white
lawyer, fancy that. Things will be MOST interesting at that point, yes. But until it happens, this
Affidavits paragraph must be summarily stricken for all the reasons noted herein.
20
CHRISTOPHER KING, J.D.
17006 11TH Avenue
Seattle, WA 98155
617.543.8085 p
206.299.9333f
[email protected]
21
CHRISTOPHER KING, J.D.
17006 11TH Avenue
Seattle, WA 98155
617.543.8085 p
206.299.9333f
[email protected]
B. Overview and Attorney Johnsons Commitment to Cultural Hegemony and Racism.
Respondent, hopelessly mired in obfuscation, attempts to direct this Tribunals attention
away from his horrific acts that cannot be disputed.8 None of these issues are truly pertinent
to Respondents conduct and this would not change even if Petitioners character were at issue
and even if this Tribunal found such character to be relevant. Period.
* Ohio Bar Association
-Petitioner and another attorney surreptitiously tape recorded a landlord who had
called Petitioners client a nigger lover as verified by several reliable, credible sources. In
Ohio at the time there was no prohibition against such taping because Ohio is a one-party
state. Moreover, Ohio had NOT adopted the ABA model code which contained a prohibition
against surreptitious recording and Petitioner knew he should have been protected as his
recalled his parents were part of the landmark litigation in Heights Community Congress v.
Hilltop Realty 774 F.2d 135 (1985) involving similar issues.
-Petitioner is not disbarred. He is suspended, and Attorney Johnson shows himself
to be ill-prepared or loose with the facts as it suits his whimsy in this arguably Defamatory
pronouncement.
-The suspension was according to Professor Louis A. Jacobs, a member of the
disciplinary committee, a byproduct of racism and reactionary politics. (Appendix A,
supra). Petitioner could get more into a sanction-by-sanction analysis but that is simply not
worth it nor is it relevant, but there were definitely arbitrary and capricious rulings,
including a sanction for using the term shenanigans a term that Counsel for Respondent
an establishment white male bandies about with glee in his filings. This is typical of a
double-standard America as Petitioner writes this Reply the day after Independence day, 5
July 2017.
Since Petitioner anticipated that Attorney Johnson would accuse him of playing the race
card, he may continue to reference Professor Lou Jacobs' comments that "racism and
reactionary politics" played a role in Petitioners SUSPENSION (i.e. NOT DISBARMENT).
8 Petitioner provides the full, unedited oral Order from Referee Winiarski as well as the full, unedited
sequence of the attack by Respondent, in which he alighted from his chair, traversed an entire room
and approached and touched my camera whilst declaring that he didnt want cameras in his face.
Contrary to with wishful thinking of Respondent and Counsel Terry L. Johnson, he gains no traction
with the full footage but Petition now goes on Record as not objecting to a Surreply after Respondent
views the footage. I have absolutely nothing to hide here.
22
CHRISTOPHER KING, J.D.
17006 11TH Avenue
Seattle, WA 98155
617.543.8085 p
206.299.9333f
[email protected]
http://christopher-king.blogspot.com/2005/12/incredible-comments-from-my-
jewish.html
This is Professor Jacobs recommendation for Petitioner as a Title Insurance Producer,
which led to him learning more about mortgages which in turn led to Petitioner learning
about MERS and other unlawful conduct on the part of entities like Respondent Rattan's
client, Wells Fargo. Petitioner settles second mortgages with Wells Fargo, by the way.
http://mortgagemovies.blogspot.com/2015/07/kingcast-and-mortgage-movies-see-
wells.html
https://www.youtube.com/watch?v=nBmxD635DTw
*American Tower Corporation
-$290K fine assessed by DOL
-Illegally backdated stock options
-Called Plaintiff a Dangerous Black Man and successfully sued for Defamation.
First of all to Petitioners recollection the requested $500 fine for contacting someone at
American Tower Corporation was not GRANTED when he and a Caucasian female sued
American Tower for Racism and unlawful Retaliation. The cases settled but then it is a
FACT American Tower Corporation then violated the Settlement Decree in talking with
disgraced Police Chief Martin Dunn, allowing all of the 2005 American Lawyer segments
to be publicly posted to the Internet where they are currently archived by Archive.org:
American Lawyer, loaded to the Internet before YouTube even existed:
https://archive.org/details/ChrisKingAmericanLawyerPartII
https://archive.org/details/ChrisKingAmLawPtIII
https://archive.org/details/American_Lawyer_Part_1
Petitioner was their best employee until they started disrespecting his trainees. He spoke
up and that was that, then came up all kinds of accusations about how he allegedly sexually
harassed a white female SENIOR TO HIM and how he was a "Dangerous Black
Man." Meanwhile the DOL found in Petitioners favor as noted, so he helped not only his
immediate group but all ATC employees in and under Petitioners range, just the facts. See
Employee of the Week image at (Appendix C, supra).
Deceit you say? Look no further than ATC as they were also guilty of backdating stock options
and Petitioner provided whistleblower information to the winning law firm on that too in U.S.
23
CHRISTOPHER KING, J.D.
17006 11TH Avenue
Seattle, WA 98155
617.543.8085 p
206.299.9333f
[email protected]
Dist. Court MA 06-CV-10933) http://securities.stanford.edu/filings-
documents/1036/AMT_01/2007326_r01c_06CV10933.pdf
http://archive.fortune.com/magazines/fortune/fortune_archive/2006/10/30/8391767/index.htm
Yet these are the types of people that Respondent relies on to make his defense.
Classy.
* NAACP/Police Chief Martin Dunn/Willie Toney Affair
-Willie Toney faced 3 drawn police guns and visual body cavity search of LOITERING
(See Appendix D)
-Disgraced and fired Police Chief Martin Dunn lied and claimed that Petitioner had
not read the police reports when there was information that Petitioner used that ONLY
could have come from such reports. Yet Respondent finds this man to be a support system.
-Petitioner was fully in his legal right as NAACP Legal Chair to say that NAACP would
sue and expose this police abuse.
-Petitioner was charged with Attempted Felony Extortion and a related Unlicensed
Practice of Law Complaint. Both were DISMISSED and Petitioner received a Mayoral and
Aldermanic COMMENDATION for work in the First Amendment as he and an Alderman also
threatened to sue the City over a restrictive speech covenant at the Nashua School Board.
(See Commendation and news story at Appendix E).
-Jaffrey Police Chief Martin Dunn was FIRED.
-County Prosecutor Bill Albrecht RESIGNED amidst an ETHICS INVESTIGATION.
-NAACP President Gloria Timmons lied and said the NAACP does not sue, or
threaten to sue people because she was scared of NH politics. The NAACP, as a matter of
public record, definitely sues and threatens to sue people. Thats why they have a Legal
Defense Fund.
-NAACP President Gloria Timmons brought a stalking action against Petitioner for
his online postings and the Court summarily DENIED such motion. Timmons failed to
appear at the scheduled hearing. (Appendix F)9
-The only Affidavit provided by anyone in the NAACP was that of one Cleaven
Ferguson, the Veterans Chair. His Affidavit clearly stated that Petitioner had not
misrepresented anything at any time. Gloria Timmons tried to make him change his
Affidavit and he told her to GO POUND SAND. (See Ferguson Affidavit at Appendix F).
9 There was also a note about a shop owner Jackie Ellwood who allegedly claims that Petitioner
represented that he was a licensed attorney. Ms. Ellwood however never came to Court to swear to
that, and she disappeared. Further research indicated that she had friends who were tied to Gloria
Timmons and NAACP VP Melanie Levesque.
24
CHRISTOPHER KING, J.D.
17006 11TH Avenue
Seattle, WA 98155
617.543.8085 p
206.299.9333f
[email protected]
*KingCast v. Wright, Finlay & Zak
http://www.leagle.com/decision/In%20FDCO%2020160421D73/KING%20v.%20WRIGH
T%20FINLAY%20&%20ZAK
-Defendant Law Firm reneged on agreement with Attorney Ha Dao and Petitioner to
allow video Deposition of their clients. The other litigants in Lucero v. Bayview Loan
Servicing had already been set to video as seen at one of my websites, Affordable Video
Depo, here is one of the videos of Deponent Vonnie McElligot (Northwest Trustee Services)
as hosted at YouTube:
https://www.youtube.com/watch?v=gIN4o4LB9g8
Here is one of NWTS Jeff Stenman. https://www.youtube.com/watch?v=3mctafbG9sM
Note that both of these Deponents were in a room SMALLER than the one in which
Petitioner used the EXACT SAME CAMERA to run video. The camera that Respondent
attacked. These Deponents were clearly not happy to be on video. Petitioner couldnt care
less about that because he was duly authorized to run the video in that case just as he was in
this case, period.
25
CHRISTOPHER KING, J.D.
17006 11TH Avenue
Seattle, WA 98155
617.543.8085 p
206.299.9333f
[email protected]
-Plaintiff Lucero prevailed to the tune of $214,000.00 because of FRAUD and
DECEIT.
-Wright, Finlay & Zak fabricated a racist tale in which Plaintiff had allegedly issued a
DEATH THREAT to certain members of the firm. There was no police report filed, nor was
the FBI contacted. The DEATH THREAT was nothing more than shenanigans in an attempt
to prevent Petitioner from attending further Court sessions and the Court DENIED the relief
and Petitioner continued covering the case.
-Petitioners case for Defamation proceeded and was not simply dismissed as
Respondent alleges. It was dismissed from Federal Court Wright Finlay & Zak lost their
attempted Removal and they knew they would have to explain themselves before
Petitioners cameras in state Court and the case SETTLED. Obviously Petitioner is not at
liberty to discuss the amount but it was far from nuisance value that much is certain.
* Marinova v. Boston Herald and KingCast v. Nashua City Schools.
Yes Petitioner helps people find Counsel for Defamation and sues people and institutions for
First Amendment violations. The last time he checked there is nothing unlawful about that.
After Joanna Marinova appeared on Petitioners radio show in 2009 he accompanied her to
the Law Firm of Todd, Weld to explain her Defamation claims against the Boston Herald.
The firm had initially rejected her case but owing to Petitioners explanation they took a
Board vote and sued the Herald. Five years later the Jury returned a $570,000.00 verdict.
Much of this case was subject to court video by Petitioner and while those movies have been
muted from YouTube by Petitioner they are still there and the original radio show may be
heard here:
https://www.youtube.com/watch?v=ZlaHj9QN9yc
Defamation and CORI violations for Boston Herald & Jessica Van Sack?
Next comes the matter of threatening to sue Nashua Public Schools, while Petitioner sat on
the Citys Ethnic Awareness Committee. The City Attorney was not thrilled about the
challenge to the restrictive speech covenant but ultimately agreed with Petitioner and
Alderman Teeboom, who volunteered to fund the litigation! Petitioner makes no apologies
for knowing the law of First Amendment and Defamation and using it to advance his
agenda, which is to highlight hegemonic abuse and Civil Rights violations.
26
CHRISTOPHER KING, J.D.
17006 11TH Avenue
Seattle, WA 98155
617.543.8085 p
206.299.9333f
[email protected]
***************
If nothing else, Respondent's desperate attempts to malign Petitioners use of cameras
tends to indicate the outright hubris patently manifest by many blue blood law firms who,
like Wright Finlay, believe that they can say and do anything they want to:
As to matters of race, in point of fact the Taint of Racism is present in each and every
example cited by Respondent and his attorney; they did their research thoroughly so one
can only assume that they support racism and anyone supporting racism is a racist.
Moreover, nothing in the Record supports the Notion that Respondent knew who
Petitioner was prior to the Nora hearings so of what relevance could ANY of this be as
far as the Tribunal is concerned? And if Respondent was aware of Petitioners
identity then it is even worse because it means he assumed he could act the part of a
fool and get away with it.
If any of these items or of any relevance such relevance is outweighed on a 404 scale by the
outright and continued fraud of Wells Fargo and its attorneys (Respondent is a Wells Fargo
attorney) as noted elsewhere in this filing.
27
CHRISTOPHER KING, J.D.
17006 11TH Avenue
Seattle, WA 98155
617.543.8085 p
206.299.9333f
[email protected]
This is a matter of EXTREME public importance and I will treat it as such. There is an
ongoing war against truly independent Attorneys like Wendy Alison Nora. There is an
ongoing war against strident black men. And there is an ongoing war against truly
independent media as well and this is all part of it.
That war is inimical to the guaranteed, Rights, Privileges and Immunities established
in the United States Constitution and the Bill of Rights, a subject with which Petitioner
is intimately familiar, having written much of the successful appellate brief as Terry
Gilberts law clerk in the seminal Ohio First Amendment case of State v. Lessin 67
Ohio St.3d 487 (1993).
http://www.leagle.com/decision/199355467OhioSt3d487_1461/STATE%20v.%20LESSIN
In sum: Respondent can hate Petitioners cameras and me to his hearts desire.
What he cannot do, under any circumstances - particularly as a licensed attorney -- is
to ignore the plain language of a hearing officer, alight from his chair, traverse an
entire room, and put his hands on my equipment or me in an aggressive manner, yet
that is precisely what happened here and that my friends, is the end of the inquiry.
Do we have any doubt as to what would happen if Petitioner, as a black man, rushed
upon Attorney Rattan in a like fashion?
Please.
We all know the answer to that: Referee Winiarski would have called the police and
Petitioner would have been summarily EJECTED, unlike Respondent, who did not
even receive a warning. That is the white male privilege hard at work. Shenanigans.
Ugly but true.
C. The Tribunal May Strake Matter that is Scurrilous or Irrelevant.
While this is not a traditional Court of Law this Tribunal is certainly free to consider and to
apply basic evidentiary principles under a Rule 402/403 and 404 analysis. That analysis
clearly provides us with the knowledge that whatever other alleged events are contained in
Petitioners background they are no more important to the analysis of Respondents
conduct than the dirty background of his client, Wells Fargo with respect to rules 402, 403
and 404.
28
CHRISTOPHER KING, J.D.
17006 11TH Avenue
Seattle, WA 98155
617.543.8085 p
206.299.9333f
[email protected]
With respect to Rule 404, for each and every accusation regarding Petitioners purportedly
questionable character, Petitioner provides proof of a Civic Mayoral Award for First
Amendment Work, a successful Remand Petition (KingCast v. Wright, Finlay & Zak) or proof
of Employee of the Week status (American Tower) and other supporting documentation
showing his drive to protect his trainees with American Tower, i.e. the $290,000.00
Department of Labor assessment.
With such in mind, first of all Attorney Johnsons sloppy and Defamatory remark that
Petitioner is disbarred is clearly wrong and must be stricken from the Record.
Furthermore, Attorney Johnson's ad hominem remarks that Petitioner "moved from state to
state for the purpose of shamefully manufacturing incidents that he unsuccessfully tries to
parlay into lawsuit and disciplinary actions" (Response p3) is belied by the FACTS of the
American Tower incident and the Mayoral/Aldermanic Award Petitioner received
immediately after the entire NAACP debacle because the Mayor and Aldermen knew the
truth. See attached. Petitioner moved from state to state because he was a WIRELESS
ZONING PROFESSIONAL and a LICENSED TITLE INSURANCE PRODUCER. (see a portion of
Petitioners business cards from 2002-2009 at Appendix G).
As such, those remarks must be stricken from the Record as well.
In general all of the purported issues raised as noted above are of minimal to zero probative
value before this Tribunal, including the Wright Finlay & Zak, NAACP/New Hampshire,
American Tower and Ohio Bar Association matters.
As a prime example, allegations regarding anything in New Hampshire are ridiculous
because in the end, all of the criminal charges against Petitioner for attempted felony
extortion were DISMISSED as was the failed attempt against me for Unauthorized Practice
of Law, then Petitioner received the Mayoral award. The prosecutor and the police chief
resigned under ethics charges and were fired, respectively but let's not let the facts get in
the way of a good argument, shall we? Prosecutor Albrecht: Unethical:
http://christopher-king.blogspot.com/2006/09/kingcast-and-concord-monitor-reveal.html
(See Appendix H).
29
CHRISTOPHER KING, J.D.
17006 11TH Avenue
Seattle, WA 98155
617.543.8085 p
206.299.9333f
[email protected]
III. Summation.
Let us remind Attorney Johnson and Respondent of the material issue here:
The issues here are AGAIN, as follows: Did Respondent knowingly disobey a standing
Administrative Rule of the Case and Oral Directive to violate:
SCR 20:3.5 Impartiality and decorum of the tribunal. A lawyer shall not:
(d) engage in conduct intended to disrupt a tribunal.
[5] The duty to refrain from disruptive conduct applies to any proceeding of a tribunal,
including a deposition. See Rule 1.0 (m).
SCR 20:4.4 Respect for rights of 3rd persons. (a) In representing a client, a lawyer shall not use
means that have no substantial purpose other than to embarrass, delay, or burden a 3rd person,
or use methods of obtaining evidence that violate the legal rights of such a person.
It is indisputable that Respondent has violated these principles by his conduct and he must
be properly reprimanded for his actions.
Respectfully submitted,
CHRISTOPHER KING, J.D.
[email protected][email protected]http://affordablevideodepo.com
http://iamonlocation.com
http://mortgagemovies.blogspot.com
617.543.8085m
206.299.9333f
30
CHRISTOPHER KING, J.D.
17006 11TH Avenue
Seattle, WA 98155
617.543.8085 p
206.299.9333f
[email protected]
APPENDIX A (see overleaf/jump page)
31
CHRISTOPHER KING, J.D.
17006 11TH Avenue
Seattle, WA 98155
617.543.8085 p
206.299.9333f
[email protected]
32
CHRISTOPHER KING, J.D.
17006 11TH Avenue
Seattle, WA 98155
617.543.8085 p
206.299.9333f
[email protected]
33
CHRISTOPHER KING, J.D.
17006 11TH Avenue
Seattle, WA 98155
617.543.8085 p
206.299.9333f
[email protected]
APPENDIX B
Great. A racist cop laughing at a racist letter, yet Respondent relies upon people like
this to defend his actions, thereby rendering him every bit as racist.
34
CHRISTOPHER KING, J.D.
17006 11TH Avenue
Seattle, WA 98155
617.543.8085 p
206.299.9333f
[email protected]
Great. A racist cop laughing at a racist letter, yet Respondent relies upon people like
this to defend his actions, thereby rendering him every bit as racist.
354
CHRISTOPHER KING, J.D.
17006 11TH Avenue
Seattle, WA 98155
617.543.8085 p
206.299.9333f
[email protected]
APPENDIX C
36
CHRISTOPHER KING, J.D.
17006 11TH Avenue
Seattle, WA 98155
617.543.8085 p
206.299.9333f
[email protected]
Employee of the week turns whistleblower.
Exactly what Respondent believes this proves in his favor remains to be seen.
37
CHRISTOPHER KING, J.D.
17006 11TH Avenue
Seattle, WA 98155
617.543.8085 p
206.299.9333f
[email protected]
Appendix D See Overleaf/Jump page
38
CHRISTOPHER KING, J.D.
17006 11TH Avenue
Seattle, WA 98155
617.543.8085 p
206.299.9333f
[email protected]
39
CHRISTOPHER KING, J.D.
17006 11TH Avenue
Seattle, WA 98155
617.543.8085 p
206.299.9333f
[email protected]
40
CHRISTOPHER KING, J.D.
17006 11TH Avenue
Seattle, WA 98155
617.543.8085 p
206.299.9333f
[email protected]
41
CHRISTOPHER KING, J.D.
17006 11TH Avenue
Seattle, WA 98155
617.543.8085 p
206.299.9333f
[email protected]
APPENDIX E
42
CHRISTOPHER KING, J.D.
17006 11TH Avenue
Seattle, WA 98155
617.543.8085 p
206.299.9333f
[email protected]
43
CHRISTOPHER KING, J.D.
17006 11TH Avenue
Seattle, WA 98155
617.543.8085 p
206.299.9333f
[email protected]
44
CHRISTOPHER KING, J.D.
17006 11TH Avenue
Seattle, WA 98155
617.543.8085 p
206.299.9333f
[email protected]
APPENDIX F (See overleaf/jump page)
45
CHRISTOPHER KING, J.D.
17006 11TH Avenue
Seattle, WA 98155
617.543.8085 p
206.299.9333f
[email protected]
46
CHRISTOPHER KING, J.D.
17006 11TH Avenue
Seattle, WA 98155
617.543.8085 p
206.299.9333f
[email protected]
47
CHRISTOPHER KING, J.D.
17006 11TH Avenue
Seattle, WA 98155
617.543.8085 p
206.299.9333f
[email protected]
APPENDIX G
48
CHRISTOPHER KING, J.D.
17006 11TH Avenue
Seattle, WA 98155
617.543.8085 p
206.299.9333f
[email protected]
49
CHRISTOPHER KING, J.D.
17006 11TH Avenue
Seattle, WA 98155
617.543.8085 p
206.299.9333f
[email protected]
APPENDIX H
50
