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IN THE SUPERIOR COURT

KING COUNTY WASHINGTON


CHRISTOPHER KING, J.D.
A/K/A KINGCAST
AND MORTGAGE MOVIES JOURNAL
No.__________________
17006 11TH Avenue
Shoreline, WA 98155
Plaintiff,

CASE

JURY DEMAND

JUDGE______________________
v.

WRIGHT FINLAY & ZAK


AND
LUKAZ WOZNIAK, Esq.
AND
RENEE PARKER, ESQ.
c/o Ryan Carson
200 Second Avenue W
Seattle, WA 98119

)
)
)

Defendants.

COMPLAINT
PARTIES
1.

In the past thirty (30) years Plaintiff has been a photojournalist and
editor for small and major press, an Assistant State Attorney, an
Escrow Attorney, a Civil Rights Attorney in State and Federal Court,
and a zoning and permitting communications attorney. He was the
first independent journalist to register with the Massachusetts
Supreme Judicial Court in 2012 (Appendix A) and has filmed all
matter of civil and criminal trials in courtrooms across the Country.

2.

He has no criminal history whatsoever, but among other


accomplishments Plaintiff has investigated employment abuse at

American Tower Corporation and initiated an investigation resulting


in a $290,000 ORDER against them by the Department of Labor.

Further, he received a First Amendment Mayoral Commendation for


his efforts when he was NAACP Legal Chair in New Hampshire, and
he is the investigative journalist who found Joanna Marinova her
lawyers in Boston and they sued the Boston Herald for a 2015 $.9M
settlement after a 2014 $.5M Jury Verdict.
3.

Defendant Wozniak is, on information and belief, an Associate


Attorney for the Defendant law firm of Wright, Finlay & Zak. 1

4.

Defendant Parker is, on information and belief, an Associate


Attorney for the Defendant law firm of Wright, Finlay & Zak.

5.

Wright, Finlay & Zak is a California-based law firm that regularly


practices in the forum Jurisdiction in the areas of securities,
mortgages, mortgage servicing and real estate.

JURISDICTION and VENUE


6.

This is a Court of general jurisdiction fully vested with full authority


to hear all Claims mounted herein.

7.

Defendants all either reside in, or conduct substantial business


within the forum State, consonant with any and all Constitutional
concerns involving Long Arm Jurisdiction.

8.

The misconduct giving rise to this Action substantially occurred in


King County, Washington.
FACTS

1 Name Partner Jonathan Zak is, on information and belief published on a corporate
website, no longer a partner with said firm but is now of counsel, as noted
subsequently.

9.

In the fall of 2014 Plaintiff ran video of several Plaintiff Depositions


involving a foreclosure case of Lucero v. Cenlar, Case No. 20130602, in which Cenlar was denied Summary Judgment on the issue
of Outrage.

10.

All Parties and Plaintiff later stipulated that certain Depositions


would not be broadcast. This will become relevant as noted in
paras 11-14, infra.

11.

Later that year Plaintiff attended a Defendant Deposition in the


case of Lucero v. Cenlar as a videographer. There was some
disagreement as to whether he would be permitted to run video but
all Parties and Counsel AGREED that he would permitted to do so.

12.

Defendant Wozniak was present at that Deposition, as were two


other bank/servicer attorneys, Joseph McIntosh and Heidi Buck
Morrison.2

13.

For reasons never articulated to Plaintiff, these three attorneys


reneged on the agreement and Plaintiff promptly began packing up.

14.

Defendant Wozniak, for no lawful reason, spoke down to Plaintiff


and told him in a very mean-spirited manner to Get out. When
Plaintiff admonished him to Watch your tone to me, Counselor, I
am clearly packing up, the male attorneys threatened to have him
arrested by calling security for no lawful reason. Much of the
exchange was captured on audio and Plaintiffs camera was still
running. Plaintiff contemplated reporting the conduct to the Bar
Association but decided to give the Defendants the benefit of the
doubt. See:
Judges Will Watch as Foreclosure Mill Attorneys Threaten Depo
Videographer with Security and Arrest.

2 Attorney Morrison has apparently left the Jurisdiction and resides in Idaho as of this
writing.

https://www.youtube.com/watch?v=mFTCVXNaisY

15.

However, in September or early October of 2015 Plaintiff became


aware that Defendant Wozniak was reprimanded on Record by
Judge Lasnik for failing to treat a witness with compassion.

16.

On hearing this, Plaintiff became concerned about a pattern and


practice on the part of Defendant Wozniak, and he did then issue a
complaint to the Court on 2 October 2015 with a copy to Defendant
Wozniak. The subject line read:
Dear Judge Lasnik: I want you to know how Luke Wozniak
comports himself in general.

17.

In so doing, Plaintiff scolded Attorney Wozniak and used language


remarkably similar to that of Wright, Finlay Partner Jonathan Zak
(see para 18, infra) as Plaintiff admonished Defendants that they
should get good with Jesus, who might in fact, be a brown man.

18.

For the record, pro se Plaintiffs in a Ventura County, California case


allege that Attorney Zak threatened them with malicious
prosecution on a Quiet Title Action involving Bank of New York

3 Significantly, Plaintiff hid nothing and in fact implored Defendant Wozniak to tell
the Court:
Feel free to show this to Judge Lasnik. If you don't, I will.
A full copy of the email is attached hereto as Appendix B.

Mellon, while telling them that he was The Terminator and that
they were Going to have a come-to-Jesus moment. The conduct
was memorialized in a Transcript provided to Plaintiff that reads, in
pertinent part, as noted in the below thumbnail where the litigants
complain that he had told them they had better get on their knees
and have a Come to Jesus Moment because he was the terminator.
19.

As noted by the transcript, and in the near future by way of Affidavit


and live testimony at Trial, the WFZ associate laughed at the notion
that such words could be unreasonably threatening coming from a
name partner to pro se litigants (Appendix C).

20.

Plaintiff asserts that if those words are not threatening from a name
partner to pro se litigants then they are not threatening between
seasoned attorneys, either, and Plaintiff and all Defendants in this
case are indeed seasoned attorneys.

21.

Such conduct hardly constitutes a death threat, but it is certainly


abusive conduct when coming from a 30-year litigator to pro se
litigants, particularly when there is no basis for a malicious
prosecution action, as Plaintiff has publicly noted. On SCRIBD. 4
https://www.scribd.com/doc/289136279/Former-Wright-Finlay-ZakWFZ-Partner-Jonathan-Zak-Issues-a-Come-to-Jesus-Death-Threat-inVentura-Case-No-56-2013-00445950-CU-Or-VTA

22.

In open Court, on or about 27 October, 2015 Defendants, by and


through Defendant Parker, point blank stated that Plaintiff had
issued a Death Threat to Wozniak and to Parker because Plaintiff
knew she would read the email. See Appendix D, attached. They
also uttered such falsity to Attorney Ha Dao outside of Court.

23.

This was a complete lie and cover up and was all part of an unlawful
civil conspiracy because Parker had to be aware that Plaintiff had

4 A copy of the relevant passage from Plaintiffs Court filing complaining of the
conduct toward them is attached at Appendix C.

previously challenged the professional ethics and demeanor of


Defendant Wozniak -- simply because he had to have told her and
the Corporate entity about it -- and it had been on YouTube for a
year prior to the Death Threat.
24.

On information and belief, at no time did any of the Defendants


report any alleged death threat to the Seattle Police.

25.

On information and belief, at no time did any of the Defendants


report any alleged death threat to the FBI.

26.

On information and belief, at no time did any of the Defendants


report any alleged death threat to any law enforcement official
other than Judge Lasnik immediately prior to the hearing on 27
October nearly an entire month after the purported threat was
issued.

27.

Judge Lasnik a former prosecutor on his own right -- did not find
cause to publicly take any action against Plaintiff for the allegedly
threatening email.

28.

Plaintiff was never notified of any cause for alarm by any Law
Enforcement Officials at any time.

29.

On information and belief, the individual Defendants had notified


senior corporate staff to alert them of the purported Death Threat,
and they all conspired to fabricate a death threat, to muzzle a
vigorous journalist, knowing full well that the words used are fairly
commonplace and do not denote or connote any such threat.

30.

Judge Lasnik declined the requested relief to expel Plaintiff from the
Courtroom, and at no point in time did he lend any credence to
Defendants claims, nor did he at any point in time take any sua
sponte action against Plaintiff for any alleged threat.

31.

The false statements about a crime of moral turpitude were made


with malice aforethought, with complete knowledge of their falsity

and were broadcast to the World Public by way of communication in


a public federal courtroom.
32.

The malicious, false and Defamatory statements were made with


the direct intent to provoke a Federal Judge and former prosecutor
to take action against Plaintiff, when any Court reprimand or arrest
of his person would at once prevent him from being a licensed
attorney again and ruin his credibility as an online journalist.

33.

The malicious, false and Defamatory statements were steeped in


racism, as there is no way that these attorneys would have
attempted to say that a white male in Plaintiffs position had issued
a Death Threat. We know this because a white male Senior Partner
of the Corporate Defendant did indeed issues those words and they
were not considered as a Death Threat.

34.

The malicious, false and Defamatory statements were made in an


attempt to limit scrutiny of the underlying case, which ended in a
$214,000.00 bench Judgment against Wright, Finlay & Zak client
Cenlar, FSB, for the Tort of Outrage.

35.

As goes the client as goes the law firm, two peas in a pod.

36.

Plaintiff has a history of other racist, mean-spirited people attacking


him for being A Dangerous Black Man and Plaintiff was and is
foreseeably damaged by these actions. Defendants were aware of
this fact prior to publication as Plaintiff had written all parties in
2014. See Appendix D.

37.

The Defendants were again reminded a year ago that Plaintiff was
not violent, in an email to Heidi Buck et al. noting the RCO was
observing the situation. See Appendix E.

38.

Some of the heinous current actions of Defendants may be seen in


the following YouTube video. https://www.youtube.com/watch?
v=5dVPEy7Pygo

CLAIMS5
1.

Defamation/Defamation per se The Defendants without


privilege, knowingly and intentionally broadcast the false
assertion regarding a crime of moral turpitude, i.e. murder, in
claiming that Plaintiff had indeed issued a colorable death
threat with an intent to cause harm to Plaintiff, and indeed
harm was caused as these false accusations exposed a living
person to hatred, contempt, ridicule or obloquy, and, if
successful, would have deprived him of the benefit of public
confidence or social intercourse, and (2) injured him in his
business, trade, profession or office." Caruso v. Local Union
No. 690, 100 Wn.2d 343, 353, 670 P .2d 240 (1983).
Defendants jointly and severally engaged in Defamation and
Defamation per se.

2.

False Light Per Eastwood v. Cascade Broad. Co., 106 Wn.2d


466,469,722 P.2d 1295 (1986) A false light claim arises when
someone publicizes a matter that places another in a false
light if (a) the false light would be highly offensive to a
reasonable person and (b) the actor knew of or recklessly
disregarded the falsity of the publication and the false light in
which the other would be placed. Defendants conduct, made
without Privilege, violated False Light Principles.

3.

Outrage -- The elements of the tort of outrage are


(1) extreme and outrageous conduct,(2) intentional or
reckless infliction of emotional distress, and (3) severe

5 A Death Threat in Washington carries a five (5) year prison sentence and a $250K

fine. Just ask Anthony Orton and the FBI.... an office the Defendants in this case never
approached because they knew they were lying. http://www.justice.gov/usaoedca/pr/washington-man-charged-sending-death-threats

emotional distress on the part of plaintiff. Rice v. Janovich,


109 Wn.2d 48, 61 (1987). Defendants jointly and severally
engaged in Outrageous conduct not protected by Privilege.
4.

Intentional Infliction of Emotional Distress Defendants,


without Privilege, jointly and severally engaged in intentional
infliction of emotional distress by engaging in conduct that
would shock the conscience of a reasonable person by
publicly lying about an attempted crime of moral turpitude.

10

5.

Tortious Interference with Business Expectancy Defendants,


without Privilege, attempted to ruin the legal and journalistic
career of Plaintiff and to ruin his chances of obtaining Court
access by labeling him as a violent Felon. Defendants jointly
and severally engaged in Tortious Interference with Business
Expectancy. Prior to Defendants lies Plaintiff had a business
relationship with the law office representing Plaintiff with
respect to Deposition videos. As the tensions raised
regarding this issue said counsel reasonably became
concerned about her first priority, which is naturally to her
client. The relations between Plaintiff and the law firm were
essentially soured and severed unnecessarily because of
Defendants orchestrated lies.

6.

Civil Conspiracy State -- In this case we have Defendants


Wozniak and Parker, and potentially other members or
associates of the Corporate entity, joining together without
Privilege to posit a known lie to a Federal Court, in open
Federal Court. We therefore have two or more people
gathering to accomplish an unlawful purpose of threatening
and chilling news gathering and expressive conduct
protected by the Washington State Constitution, Article I 3, 5
and 7, and (2) entering into an agreement to accomplish said
conspiracy. Corbit v. JI Case Co., 70 Wn.2d 522, 528-29, 424
P.2d 290 (1967). The existence of a civil conspiracy must be
established by clear, cogent, and convincing evidence. Id.
The existence of a conspiracy may be based on
circumstantial evidence but mere suspicion is insufficient. Id.
Defendants engaged in conduct amounting to a civil
conspiracy when, including but not limited to: engaging in
conduct that would shock the conscience of a reasonable
person by publicly lying about an attempted crime of moral
turpitude, particularly after having been warned of Defendant
Wozniaks unprofessional conduct one year prior. Defendants
jointly and severally engaged in Civil Conspiracy with full
knowledge by the Corporate Entity.

7.

Civil Conspiracy per 42 U.S.C. 1985 In this case we have


Defendants Wozniak and Parker, and potentially other
members or associates of the Corporate entity, joining
together without Privilege to posit a known lie to a Federal
Court, in open Federal Court. We therefore have two or more
people gathering to accomplish an unlawful purpose of
threatening and chilling news gathering and expressive
conduct protected by the First Amendment to the United
States Constitution. The existence of a civil conspiracy must
be established by clear, cogent, and convincing evidence. Id.

11

The existence of a conspiracy may be based on


circumstantial evidence but mere suspicion is insufficient. Id.

12

Defendants engaged in conduct amounting to a civil


conspiracy when, including but not limited to: engaging in
conduct that would shock the conscience of a reasonable
person by publicly lying about an attempted crime of moral
turpitude, particularly after having been warned of Defendant
Wozniaks unprofessional conduct one year prior. Defendants
jointly and severally engaged in Civil Conspiracy with full
knowledge by the Corporate Entity.
DEMANDS
1.

Immediate Declaratory Judgment that the Defendants individually


and collectively are responsible for all Claims.

2.

Injunctive relief against any and all further such failures

3.

Assessment of all Costs against Defendants for willful derogation of


Law.

4.

Punitive Damages in an amount and degree commensurate with the


wrong.

JURY DEMAND
Plaintiff hereby DEMANDS a Jury of appropriate size and composition to hear
these Claims.
_______________________________________
Christopher King, J.D.

VERIFICATION
The foregoing Complaint is true and accurate to the best of Plaintiffs
recollection and belief.
____________________________________________________
NOTARY PUBLIC
My Commission Expires_________________________

Respectfully submitted

13

___________________________________________
Christopher King, J.D.
a/k/a KingCast/Mortgage Movies Journal
APPENDIX A

14

APPENDIX B

From: Christopher King <kingcast955@icloud.com>


Date: October 2, 2015 at 11:42:02 AM PDT
To: lwozniak@wrightlegal.net, lasnikorders@wawd.uscourts.gov
Cc: mortgagemovies007@gmail.com
Subject: Dear Judge Lasnik: I want you to know how Luke
Wozniak comports himself in general.
This is what I wrote him, Your Honor. And he deserves every bit of it.
I will never suffer any indignities from a jerk like him or anyone else
for that matter. Watch the video.
Respectfully submitted,
Christopher King, J.D.
On Oct 02, 2015, at 11:15 AM, Christopher King
<kingcast955@icloud.com> wrote:
Treat the witness with compassion.... you were warned in Lucero v.
Bayview 2013-CV-0062 the other day. Good thing for you that
Federal Court is not on video but that Transcript is available and it
will show that you seem to have a difficult time bringing up a Veep
to testify on your client's behalf.
If I see you later this month my friend, outside the courtroom, on a
public street.... you can't flip me from Invitee or Licensee to
Trespasser in a hot second.
Perhaps Judge Lasnik knew you were an abusive person from
watching KingCast media LOL dude one way or another you will
learn your place, Counselor. I'm just getting started with you.
http://mortgagemovies.blogspot.com/2014/08/kingcast-andmortgage-movies-see-judges.html
https://www.youtube.com/watch?v=mFTCVXNaisY
You have a friend in Ferguson and all the other pricks who are trying
to run homeowner attorneys out of business but you can't touch a
journalist because I'm going to say whatever the hell I want to about
you, to your face and on my journals, subject to Defamation of
course. But thankfully your prior actions have given me plenty of
latitude there because you were such a complete asshole toward

15

me, and that's a fact. On record. I don't know who the fuck you
think you are, but you will not run that game with me, kid.
Feel free to show this to Judge Lasnik. If you don't, I will.
Ciao.
CHRISTOPHER KING, J.D.
kingcast955@icloud.com
mortgagemovies007@gmail.com
http://affordablevideodepo.com
http://mortgagemovies.blogspot.com
617.543.8085m
206.299.9333f
PS. I haven't been to Europe in a decade but my Croatian pals just came
back..... They tell me they have confirmed proof that Jesus was black. So you
better get good with him.

16

APPENDIX C

17

18

19

APPENDIX D
Re: Lucero v. Bayview, August 11, 2014
August 12, 2014 at 8:35 AM
FromChristopher King
To"Ha Dao"
Cc"Vicente Omar Barraza"
"Joseph McIntosh"
Production"

"Heidi Buck Morrison"

"Lukasz I. Wozniak"
"Virginia Parsons"

"Michelle Darnell"

"Steve Morberg"

"Julia Paris"

production@centralreporting.com
m

"YOM

info@mccarthyholthus.co

"ha dao"

Bcc"Scott Stafne"

"Terri Conklin"

Dear Attorney Dao:


It is most certainly unfortunate that Defense Counsel used the
situation yesterday to somehow imply that there were security
issues of any kind. You don't have to go to Court for anything I'll
handle it myself if they chose to go there. That sort of conduct
smacks of the "dangerous black man" mentality that American
Tower Corporation used when they called the police on me and the
police also asked them WTF is going on. We made a movie about
that too and they settled. Two of us -- myself and a Caucasian
female successfully sued them for Defamation and wrongful
termination as we had been stellar employees in the land use
acquisition department until they asked us to commit illegal acts.
Moreover, because of my complaint written with my trainee
Michael Mae the DOL fined ATC $290K
http://www.dol.gov/whd/media/press/whdpressVB2.asp?
pressdoc=Northeast/NEarchive/20041020.xml
I am sick and tired of people with ill intentions trying to make me
into the Bad Guy when review of the audio clearly reveals
otherwise. The only thing they are scared about.... is my camera
putting the Truth to Light.

20

Sincerely,
CHRISTOPHER KING, J.D.

21

APPENDIX E
RCO sniffing around my websites and FB but their counsel won't speak to me.
August 18, 2014 at 9:26 PM
From Christopher King
To"Ha Dao"
Cc" " "Vicente Omar Barraza" ""
McIntosh"
Parsons"

"Heidi Buck Morrison"

"Lukasz I. Wozniak"
"Steve Morberg"

"YOM Production"
"Michelle Darnell"

production@centralreporting.com

"Joseph
"Virginia
"Julia Paris"

info@mccarthyholthus.com

"ha dao"
Bcc" " "Scott Stafne" ""

"Terri Conklin"

Heidi,
I told you before -- as noted below -- that I am a reasonable man and I pose
absolutely no threat to you that should make you justifiably refuse my
presence at video depositions. But apparently there is something threatening
about me, enough so that your co-counsel completely disrespected me last
week. And you are continuing in that vein by not answering my wellreasoned question.
Please advise because obviously I can see you and your people are reading
and so can anyone else for that matter because I am posting these three
screen captures -- showing RCO, NWTS and FEI process servers at IP
address 97.65.96.138 reading assiduously -- on my journal page.
The issue isn't exactly going to go away Heidi because other lawyers will be
using my services, and they will be much more likely to force your hand on
this. And when they do, and if you fight, the evidentiary trail is right here in
these emails, and in that audio from last week.
Don't forget that for one minute.
Sincerely,
CHRISTOPHER KING, J.D.

22

kingcast955@icloud.com
mortgagemovies007@gmail.com
http://affordablevideodepo.com
http://mortgagemovies.blogspot.com
617.543.8085m
206.299.9333f

23

IN THE SUPERIOR COURT


KING COUNTY WASHINGTON
CHRISTOPHER KING, J.D.
A/K/A KINGCAST
AND MORTGAGE MOVIES JOURNAL
No.__________________
17006 11TH Avenue
Shoreline, WA 98155
Plaintiff,

CASE

JUDGE______________________
v.

WRIGHT FINLAY & ZAK


AND
LUKAZ WOZNIAK, Esq.
AND
RENEE PARKER, ESQ.
c/o Ryan Carson
200 Second Avenue W
Seattle, WA 98119

)
)
)
)
)

Defendants.

PLAINTIFFS FIRST SET OF INTERROGATORIES

TO EACH NAMED DEFENDANT: The following interrogatories are in


compliance with King County Local Rule 33. In accordance with Washington Superior
Court Rules 26 and 33, please answer each of the following interrogatories separately,
fully, in writing and under oath. Each answer must be as complete and straightforward as
the information reasonably available to you permits after reasonable inquiry, including
the information possessed by your attorneys or agents. If an interrogatory cannot be
answered completely, answer it to the extent possible.
The answers are to be signed by the person to whom they are addressed and must
be served on all parties within thirty (30) days after the service of the interrogatories
unless these interrogatories were served upon you along with the service of the summons
and complaint in which case the answers must be served within forty (40) days.
NOTE: Answers must be in compliance with the Civil Rules, Local Rules, and
Washington State case law, including the duty set forth in CR 26(e).

24

INTERROGATORIES

INTERROGATORY NO. 1: State your full name and any other names
you have been known by during the last ten years, your present address, date of birth, and
place of birth. In addition to your present address, state all other addresses at which you
have resided for the past ten years and the dates you resided at each address.
ANSWER:

INTERROGATORY NO. 2:

State the day, date and time that you

became concerned that Plaintiff may have issued a death threat.


ANSWER:

INTERROGATORY NO. 3:

State the dates of any and all

communications from Plaintiff that you believed indicated the presence of a death threat.
ANSWER:
INTERROGATORY NO. 4: State the dates and approximate time of day
that Defendant Wozniak first raised the issue of a purported Death Threat with any name
partner at Wright, Finlay & Zak.
ANSWER:
INTERROGATORY NO. 5: For Interrogatory No. 4 identify by name,
each name Partner with whom Defendant Wozniak discussed the purported Death Threat
prior to 27 October, 2015.
ANSWER:

25

INTERROGATORY NO. 6: State the dates and approximate time of day


that Defendant Parker first raised the issue of a purported Death Threat with any name
partner at Wright, Finlay & Zak.
ANSWER:
INTERROGATORY NO. 7: For Interrogatory No. 6 identify by name,
each name Partner with whom Defendant Wozniak discussed the purported Death Threat
prior to 27 October, 2015.
ANSWER:
INTERROGATORY NO. 8: Identify any law enforcement authority to
whom any Defendant issued concern regarding the purported Death Threat.
ANSWER:

INTERROGATORY NO. 9: For Interrogatory No. 8 state the date(s) on


which communications were made to said law enforcement authorities.
ANSWER:

INTERROGATORY NO. 10: State why Defendant Wozniak never


responded to Plaintiff regarding the 12 and 18 August 2014 emails seen at Verified
Complaint paras 36-37.
ANSWER:

INTERROGATORY NO. 11: State why Defendants never notified the


FBI regarding the purported Death Threat.
ANSWER:

26

INTERROGATORY NO. 12: State why Defendants never notified the


Seattle Police regarding the purported Death Threat.
ANSWER:

INTERROGATORY NO. 13: State why Judge Lasnik was the only legal
entity Defendants notified regarding the purported Death Threat.
ANSWER:

INTERROGATORY NO. 14:

State why Defendants never notified

Defendant prior to 27 October 2015 that they were concerned a purported Death Threat
ANSWER:

INTERROGATORY NO. 15: State whether Defendant Wozniak was


also in fear of his life owing to the purported Death Threat as alleged by Defendant
Parker.
ANSWER:

INTERROGATORY NO. 16: State whether Defendant Wozniak shared


any of the 2014 emails he received from Plaintiff with Defendant Parker prior to 27
October 2014.
ANSWER:

INTERROGATORY NO. 17: Identify any and all correspondence


received by Plaintiff that Defendant Parker reviewed prior to 27 October 2015.
ANSWER:

27

INTERROGATORY NO. 18: Identify by caption each Civil lawsuit


filed against any named Defendant concerning professional liability from 1 January 2010
to present.
ANSWER:

SUBMITTING PARTYS CERTIFICATION


The undersigned pro se plaintiff, or attorney for the plaintiff, certifies
pursuant to KCLR 33(b) and (c) that these interrogatories are appropriate to the facts of
this case
Dated this _______ day of February, 2016.

Plaintiff
Name:
Address:
Respectfully submitted,
___________________________________________
Christopher King, J.D.
a/k/a KingCast/Mortgage Movies Journal

28

IN THE SUPERIOR COURT


KING COUNTY WASHINGTON
CHRISTOPHER KING, J.D.
A/K/A KINGCAST
AND MORTGAGE MOVIES JOURNAL
No.__________________
17006 11TH Avenue
Shoreline, WA 98155
Plaintiff,

CASE

JUDGE______________________
v.

WRIGHT FINLAY & ZAK


AND
LUKAZ WOZNIAK, Esq.
AND
RENEE PARKER, ESQ.
c/o Ryan Carson
200 Second Avenue W
Seattle, WA 98119

)
)
)
)
)

Defendants.

PLAINTIFFS FIRST DEMAND FOR PRODUCTION OF DOCUMENTS


TO EACH NAMED DEFENDANT: The following interrogatories are in
compliance with King County Local Rule 34. In accordance with Washington Superior
Court Rules 26 and 34, please respond within the time allotted by Rule.
1. Provide a copy of any and all documents Defendants relied upon in reaching the
conclusion that any of them were in fear of a purported Death Threat.
2. Provide a copy of any and all documents that any and all Defendants sent to

Attorney Ha Dao regarding Plaintiff from 1 August, 2014 to 27 October, 2015.


3. Provide a copy of any and all documents that any and all Defendants sent to any

law enforcement agency or individual regarding Plaintiff from 1 August, 2014 to


27 October, 2015.

29

4. Provide a copy of any and all documents that any and all Defendants sent to any

law enforcement agency or individual regarding Plaintiff from 27 October, 2015


to 23 February, 2016.
5. Produce a copy of any and all correspondence from Plaintiff that Defendant

Wozniak shared with Defendant Parker prior to 27 October 2015.


6. Produce a copy of any and all correspondence from Plaintiff that Defendant

Parker reviewed prior to 27 October 2015.


7. Provide a copy of any and all professional liability insurance declaration pages

and policies for each named Defendant in place for the calendar years 2014, 2015
and 2016.

SUBMITTING PARTYS CERTIFICATION


The undersigned pro se plaintiff, or attorney for the plaintiff, certifies that
these document requests are appropriate to the facts of this case
Dated this _______ day of February, 2016.

Plaintiff
Name:
Address:

Respectfully submitted,
___________________________________________
Christopher King, J.D.
a/k/a KingCast/Mortgage Movies Journal

30

IN THE SUPERIOR COURT


KING COUNTY WASHINGTON
CHRISTOPHER KING, J.D.
A/K/A KINGCAST
AND MORTGAGE MOVIES JOURNAL
No.__________________
17006 11TH Avenue
Shoreline, WA 98155
Plaintiff,

CASE

JUDGE______________________
v.

WRIGHT FINLAY & ZAK


AND
LUKAZ WOZNIAK, Esq.
AND
RENEE PARKER, ESQ.
c/o Ryan Carson
200 Second Avenue W
Seattle, WA 98119

)
)
)
)
)

Defendants.

PLAINTIFFS FIRST REQUESTS FOR ADMISSIONS

TO EACH NAMED DEFENDANT: The following interrogatories are in


compliance with King County Local Rule 36. In accordance with Washington Superior
Court Rules 26 and 36, please answer each of the following queries separately, fully, in
writing and under oath.
1. If you fail to respond to these Requests for Admissions within the time allowed each
matter set forth in these Requests may be deemed admitted and conclusively established
against you for purposes of this action.
2. If you fail to admit to the truth of a Request, and if Plaintiffs prove the truth of the
matter contained within that Request, the Court may order that you pay Plaintiffs
reasonable expenses, including attorneys fees, incurred in making that proof.
3. If, in responding to these Requests, you encounter any ambiguities when construing a
request or definition, your response should set forth the matter deemed ambiguous and
the construction used in responding.
4. If you cannot respond in full to any of these requests, to the fullest extent possible,
specify the reason(s) for your inability to respond in full.

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5. If you contend that you do not have to respond to any of these Requests under the
attorney-client privilege, the work product doctrine, or any other basis, you should (1)
describe the information with particularity sufficient to allow the matter to be brought
before the Court; and (2) explain the nature and basis for each claim of privilege or
immunity.
6. To the extent any of the following requests are considered objectionable, respond to as
much of each request as is not objectionable and identify the part of each request to
which you object and the ground(s) for your objection.
7. If any of the requests for admissions are denied, please provide the basis for such
denial.

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REQUEST FOR ADMISSIONS

1.

Admit that Defendant Wozniak never raised the issue of a purported Death
Threat with any name partner at Wright, Finlay & Zak prior to 27 October
2015.

2.

Admit that Defendant Wozniak raised the issue of a purported Death Threat
with at least one name partner at Wright, Finlay & Zak prior to 27 October
2015.

3.

Admit that Defendant Wozniak never raised the issue of a purported Death
Threat with any law-related entity other than Judge Lasnik prior to 27
October, 2015.

4.

Admit that Defendant Parker never raised the issue of a purported Death
Threat with any name partner at Wright, Finlay & Zak prior to 27 October
2015.

5.

Admit that Defendant Parker raised the issue of a purported Death Threat with
at least one name partner at Wright, Finlay & Zak prior to 27 October 2015.

6.

Admit that Defendant Parker never raised the issue of a purported Death
Threat with any law-related entity other than Judge Lasnik prior to 27
October, 2015.

7.

Admit that the Corporate Defendant never raised the issue of a purported
Death Threat with any law-related entity other than Judge Lasnik prior to 27
October, 2015.

8.

Admit that as of 27 October, 2015 no Defendant had any knowledge of any


violent tendencies manifest by Plaintiff.

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9.

Admit that Defendant Wozniak shared some 2014 correspondence from


Plaintiff to him with Defendant Parker prior to 27 October 2015.

10.

Admit that Defendant Wozniak did not any 2014 correspondence from
Plaintiff to him with Defendant Parker prior to 27 October 2015.

11.

Admit that Defendant Parker reviewed some 2014 correspondence from


Plaintiff to Defendant Wozniak prior to 27 October 2015.

12.

Admit that Defendant Parker did not review any 2014 correspondence from
Plaintiff to Defendant Wozniak prior to 27 October 2015.

SUBMITTING PARTYS CERTIFICATION


The undersigned pro se plaintiff, or attorney for the plaintiff, certifies that
these Admission Requests are appropriate to the facts of this case.
Dated this _______ day of February, 2016.

Plaintiff
Name:
Address:

Respectfully submitted,
___________________________________________
Christopher King, J.D.
a/k/a KingCast/Mortgage Movies Journal

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