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KingCast Emergency Motion for Rule 11 Sanctions against Brian Cullen, Gordon MacDonald, Jack Middleton and NH Bar President Jennifer Parent in KingCast v. Ayotte, NH GOP and Nashua PD 2010-CV-501.

KingCast Emergency Motion for Rule 11 Sanctions against Brian Cullen, Gordon MacDonald, Jack Middleton and NH Bar President Jennifer Parent in KingCast v. Ayotte, NH GOP and Nashua PD 2010-CV-501.

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Published by Christopher King
http://christopher-king.blogspot.com/2011/10/kingcast-and-bobby-knight-tell-mclane.html I don't give a fuck who you are, who you know or what your goddamn title is, if you are a lying-assed attorney I will call you on it every goddamn time.
http://christopher-king.blogspot.com/2011/10/kingcast-and-bobby-knight-tell-mclane.html I don't give a fuck who you are, who you know or what your goddamn title is, if you are a lying-assed attorney I will call you on it every goddamn time.

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Published by: Christopher King on Oct 06, 2011
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05/25/2012

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IN THE UNITED STATES DISTRICT COURTNEW HAMPSHIRE
CHRISTOPHER KING, J.D. )a/k/a KINGCAST.NET, ) CASE NO. 2010-CV-501Plaintiff-Petitioner,v. ) JUDGE PAUL BARBADOROFRIENDS OF KELLY AYOTTE, et al., ) MAGISTRATE LANDYA McCAFFERTYDefendants.
PLAINTIFF
’S
EMERGENCY MOTION FOR RULE 11 SANCTIONSRELATIVE TO HIS MOTION TO VOID REPORT AND RECOMMENDATIONOF MAGISTRATE JUDGE LANDYA B. McCAFFERTY, WHO ALONG WITH MCLANE GRAFATTORNEYS NEVER DISCLOSED THE FACT THAT SHE WORKED AT DEFENDANT KELLY
AYOTTE’S OLD LAW FIRM ALONGSIDE PLAINTIFF’S OPPOSING COUNSEL
 
Now comes Plaintiff to issue this emergency Motion against all named Counselfor Defendants and Defendants themselves for interjecting materially false andmorally and ethically-challenged commentary into this case. These facts begin withthe fact that they all actively and willingly participated in a process in which a sittingJudge with known ethical conflicts failed to report her work history with McLane, Graf when even 1L law students know better than that, and culminating with all of themfalsely representing to this Court that Plaintiff has been disbarred. These Sanctionsmust issue immediately in order for the Court to regain some semblance of proprietyand Honor now that Plaintiff has CORRECTLY identified many procedural andsubstantive faults on the part of 
not one but two Judges
that has led to theirrecusals. Further, Defendants fail to cite any controlling or persuasive cases that showthat the Court had any au
thority whatsoever to deny Plaintiff’s right
to file additionalpleadings -- including a Third Amended Complaint showing pattern and practice as:1) Named Defendant Nashua PD made disparaging comments against the FirstAmendment YouTube videos of Plaintiff and of Dave Ridley/Ridley Report as theyarrested Mike Gannon for videotaping them, in clear violation of Glik v. Boston and;2) Reporter Dave Ridley was illegally arrested and acquitted under virtuallyidentical situation as Plaintiff by Nashua PD, again a named Defendant in the case atbar.There simply comes a point in time where this sort of contumacious behaviorcannot and will not be tolerated. Now is that time.
 
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Plaintiff will be brief and cite the following issues, using Defendant’s own
pleading filed yesterday:
The Defendants simply cannot make this argument with a straight face whiletersely acknowledging in their own Pleading yesterday that Her Honor did in factrecuse herself. That statement is sanctionable in and of itself.
May the Court takeJudicial Notice that Judges are loathe to recuse themselves and that recusal onlyoccurs when there are serious substantive and/or procedural issues at hand. Moreover,
Plaintiff has already addressed the fallacy of Judge Barbadoro’s ruling as follows:
 ****************************
The reason for the Void is simple: Magistrate McCafferty, a formerethics/discipline staffer at NH Bar Association, was fully aware under a 28 U.S.C.§455 analysis before she took the Bench in this case that she had substantialconnections with McLane, Graf et al. --
Defendant Kelly Ayotte’s former law firm.
 Not only did she work at McLane, Graf, her predecessor Judge Muirhead worked thereand trained her. Moreover, her former boss and firm founding partner Jack Middleton(who likely wrote a letter of recommendation for her ascension to the bench) joinedher former co-worker and current NH Bar President Jennifer Parent across fromPlaintiff as lead Defense Counsel for now Senator Kelly Ayotte. Plaintiff herebyretenders his Request for Full Disclosure, which the Court and Counsel haveassiduously avoided because production of same would only show how correct Plaintiff was,
ab initio
.
 
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Defendants fail to point out what those alleged errors were, and it is patentlyobvious that the issue advances a material issue because the Court is still laboringunder an Order that was harshly and unfairly biased against Plaintiff, written by aJudge who has finally admitted that she had an ethical conflict and who recusedherself, albeit initially through an underhanded manner, only putting her recusal towritten Order at least three (3) weeks after being called on it by Plaintiff.But while Defendants are making vague assertions about errors allegedly madeby Plaintiff, they miss the fact
despite being warned
that Plaintiff never wasdisbarred. Even casual due diligence would uncover that fact so the Statement issued
in Brian Cullen’s email and republished in this Court that Plaintiff was disbarred is also
 Sanctionable in and of itself.
1
 
Tur
ning now to Defendant’s misrepresentations of Plaintiff’s arguments and
case law they erroneously wrote:
That is once again a false Statement that also belies common sense. Plaintiff hasREPEATEDLY stated and argued this point, using case law but rather than face themusic the Defense counsel have joined together in a pleading to outright lie to thisCourt. Specifically Plaintiff wrote in his Motion to Void/Vacate:
1
 
Not that disbarment would constitute any sort of barometer on a NH Attorney’sability to practice law. As we all know, Shaheen & Gordon’s Michael McLaughlin was
not only disbarred but is a convicted felon. Note further that Counsel stated thePlaintiff was interjection extraneous matter into this case, nothing is more extraneousthan a lawyer like Brian Cullen trying to threaten Plaintiff with an old suspension (not:disbarment) order from another Court when he has a recent Contempt Order in thisvery Court. See
Bourne v Town of Madison
, 2005-CV-365 at the end of this documentand as Appendix A.
 

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