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KingCast v. Ayotte, GOP and Nashua PD 2010-CV-501 Third Amended Complaint, Free Press

KingCast v. Ayotte, GOP and Nashua PD 2010-CV-501 Third Amended Complaint, Free Press

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Published by loanmodspec
http://christopher-king.blogspot.com/2011/07/kingcast-fourth-of-july-independence.html .....

04 JULY 2011

A KingCast Fourth of July Independence Day Third Amended Complaint for Senator Kelly Ayotte, NH GOP and Nashua PD in NH Dist. 2011-CV-501.
http://christopher-king.blogspot.com/2011/07/kingcast-fourth-of-july-independence.html .....

04 JULY 2011

A KingCast Fourth of July Independence Day Third Amended Complaint for Senator Kelly Ayotte, NH GOP and Nashua PD in NH Dist. 2011-CV-501.

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Published by: loanmodspec on Jul 04, 2011
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02/02/2013

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IN THE UNITED STATES DISTRICT COURTNEW HAMPSHIRE
CHRISTOPHER KING, J.D.)OWNER OF KINGCAST.NETCHRIS KING’S FIRST AMENDMENT PAGE) CASE NO. 2010-CV-501131 Boston StreetSuite Three,)Boston, MA 02125,Plaintiff-Petitioner,v. )JUDGE PAUL BARBADOROKELLY AYOTTE, ESQ.)4 Tuckerwood Court,NASHUA, NH 03064)FRIENDS OF KELLY AYOTTE,) MAGISTRATE LANDYA McCAFFERTY101 Charles StreetManchester, New Hampshire 03101,)NEW HAMPSHIRE REPUBLICAN STATE COMMITTEE)
PLAINTIFF’S THIRD
10 Water Street
AMENDED COMPLAINT
Concord, New Hampshire 03301,)NASHUA REPUBLICAN CITY COMMITTEE,)JURY DEMAND ENDORSED HEREON11 Concord StreetSuite Four,)Nashua, New Hampshire 03064,)RYAN WILLIAMS,c/o NH Republican Committee,)DI LOTHROP,)c/o Nashua Republican City Committee,)DENNIS HOGAN, ESQ.c/o Nashua Republican City Committee,)CITY OF NASHUA POLICE DEPARTMENT,)POLICE CHIEF DAN CONLEYIN HIS INDIVIDUAL AND OFFICIAL CAPACITIESLIEUTENANT JOHN FISHER)IN HIS INDIVIDUAL AND OFFICIAL CAPACITIES)OFFICER JAMES HARGREAVESIN HIS INDIVIDUAL AND OFFICIAL CAPACITIES0 Panther Drive)Nashua, New Hampshire 03062,Defendants.)
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I.Jurisdiction
Jurisdiction is conferred by way of 28 U.S.C. §1441(B), 28 U.S.C. §1331, 28U.S.C. §$1446 and 2201. Further, given the significance of the harms involved,Plaintiff does not object to Diversity Removal pursuant to 28 U.S.C. §1332(a).
II.The Parties
1.
KingCast and Chris King’s 1
st
Amendment Page and Kelly Ayotte Senate blog areowned and managed exclusively by Plaintiff, a black former AssistantAttorney General and former 7-year resident of New Hampshire with anUndergraduate Degree in Communications, Rhetoric minor. He is a recentNew England News and Press (NENPA) guest panelist for their 2011 AnnualConference. On 25 September, 2010 he joined the press pool for a DevalPatrick rally in South Boston where he rolled video and took stills and madea 14 minute movie showcasing,
inter alia
, GOP and Democratic responses tohis journalistic endeavors. On 16 October 2010 he joined the press galleryat a Democratic Rally sponsored by the White House.
3
The main portal and 1
st
Amendment pages have been up and operating atthe same web addresses for approximately five (5) years.
His blog has20,700 profile views, and countless page hits, in the millions.
2
 
He has worked as a reporter for the Indianapolis Star, as an Editor with theOhio Call & Post, and he holds a Nashua Mayoral Certificate for FirstAmendment activity in the Public Interest.State Legislators including State Rep. Paul Sorg and Edmond Gionet have writtenPlaintiff at his blog with respect to issues on HB 1428 and SB154, Bruce McKay Highwaythat was properly tabled.Subject: RE: Please reject or table NH HB 1428 and reschedule public hearing.Date: Tue, 8 Jan 2008 20:58:22 -0500From: "Gionet, Edmond" Edmond.Gionet@leg.state.nh.usTo: "Christopher King" kingjurisdoctor@yahoo.comThanks, I am glad you surfaced…. I was really upset when I found the bill listedto be heard in my committee and who the sponsor was. I feel like 99% of theresponses I got to S--- C-- the bill. What a mockery. I attended both funeralsout of respect and found that if it hadn't been for paid employees for theState, County and various town governments at tax payers expense there wouldhave been a small attendance at Corporal McKay's funeral…..He has also instigated a First Amendment Policy change at the Nashua School Board, inwhich the Board changed a restrictive speech policy after Plaintiff threatened to suethe School Board and City of Nashua in 2007. As noted in Inj. Attachment 1.
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More recently, the Revere Journal twice published photographs of his trialphotography in the Dan Talbot Police Murder case, and WBZ used his courtroomfootage of the historic, record-breaking $1.8M anti-Semitic trial of Scott Hyman v.Hemlock Association/Lakeville, Massachusetts as noted in Inj. Attachment 1.In September, 2010 in response to Defendants’ actions in threatening to arresthim for his mere presence at the GOP Fundraiser event that was open to the public,Phoenix Arizona New Times writer Stephen Lemons opined:
1
 
Per Local Rule 15.1(b) Plaintiff is not incorporating these items into this Complaint per se, heis merely noting that these items are part of the record and known to all counsel for allDefendants.
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