IN THE KING COUNTY SUPERIOR COURT

SEATTLE, WASHINGTON
CHRISTOPHER KING, J.D.
A/K/A KINGCAST/MORTGAGE MOVIES
17022 11TH Avenue
Shoreline, WA 98155,
Plaintiff,

)

v.

) JUDGE __________________________

) CASE NO. _______________________

BETTY LOU MCKENNA,
KENT COUNTY RECORDER OF DEEDS
IN HER INDIVIDUAL AND OFFICIAL CAPACITIES
and
HOLLY MALONE
DEPUTY KENT COUNTY RECORDER OF DEEDS
555 Bay Road
Dover, Delaware 19901
and
JOHN W. PARADEE, ESQ.
C/O PRICKETT, JONES & ELLIOTT, P.A.
1310 North King Street
Wilmington, DE 19801

)
)

)
)

COMPLAINT
JURISDICTION AND VENUE
1.

This is a Court of General Jurisdiction vested with Authority to hear all Claims
asserted herein. Venue is appropriate as Plaintiff resides and is domiciled within
King County, where he routinely films Courtroom Hearings pursuant to his
Mortgage Movies Journal page.
THE PARTIES

2.

Plaintiff is a former daily news reporter and escrow attorney who has closed
several dozen commercial real estate purchases and refinances. He has
successfully tried several First Amendment Jury Trials and has operated several
politically and legally-charged online journals over the past decade, most
notably Chris King’s First Amendment Page and Mortgage Movies Journal.

1

3.

Defendant Betty Lou McKenna was at all relevant times, and is the putative Kent
County Recorder of Deeds pending the ballot recount ordered on 23 December,
2014 extant to La Mar Gunn’s successful Petition Challenge to the Kent County
Recorder of Deeds Election.1 She is being sued in her Official and Individual
Capacities.

4.

Defendant Holly Malone was and is at all relevant times, the Deputy Director of
Deeds to Defendant Betty Lou McKenna. She is being sued in her Official and
Individual Capacities.

5.

Defendant John Paradee, Esq. is an area attorney and Partner at Prickett, Jones &
Elliott. He is not a State Actor but did consult and advise Defendant McKenna on
matters relative to the election and to First Amendment, Free Press conduct of
Plaintiff. He stated in a 30 December 2014 email to Plaintiff that he thinks this
whole thing makes him laugh.
FACTS

6.

In early November, 2014 Plaintiff telephoned Defendants KcKenna and Paradee
specifically seeking interviews and commentary regarding potentially
Defamatory commentary that Defendants had circulated about La Mar Gunn, i.e.
claiming that he had unlawfully pedaled absentee ballots to an elder (Romaine
Whitcomb), and that he unlawfully personally conducted voter registration
drives at a local college. The phone calls made to Defendants’ voicemails are
preserved at the following YouTube link “La Mar Gunn Kent County Recorder
Election Challenge” https://www.youtube.com/watch?v=sphjqHQuNTA.

7.

The absentee issue appears below as presented on the 8 November 20014
Journal Entry, “KingCast and Mortgage Movies Frown as La Mar Gunn gets his
Kent County Recorder of Deeds Election Victory stolen.”

The Court has ordered that the Department of Elections, rather than the Board of Canvass, conduct
a recount. The Court specifically eschewed Defendant McKenna’s argument that the Court could not
conduct inquiry into any malfeasance that may have occurred during the Board of Canvass recount
because that recount occurred two days post hoc, whereas her limited reading construes “holding of
an election” to mean “the same day of the election.” Ridiculous. The purported result on 29 Dec. 2014
was “a tie.” I wrote to Governor Markell in this video:
https://www.youtube.com/watch?v=92cEwptyHnI
1

2

8.

When neither Defendant returned a telephone call or sent an email, Plaintiff left
the comforts of his North Seattle residence and journeyed cameras in hand to
555 Bay Road, whereupon he was met with stern rebuke by Defendant Malone
on or about 25 November, 2014. Malone told him that he could not run any
video or recording equipment in the building pursuant to written policy.

3

9.

Malone made two phone calls, ostensibly to Defendants McKenna and Paradee.

10.

The purpose of these phone calls was to further the conspiracy to deprive
Plaintiff of the Rightful exercise of his State and Federally-Protected First
Amendment and Free Press Rights.

11.

The Conspiracy was an agreement between the two State actors and their
Counsel (Paradee) to prevent Plaintiff from gleaning any information or video
that could prove harmful to Defendant McKenna, to the extent that they could.

12.

After said phone calls she maintained her position with substantially increased
vigor, telling other employees that there is a policy prohibiting Plaintiff and
other similarly-situated reporters and members of the public from running
video or audio.

13.

As witnessed by two other witnesses, Malone forbade Plaintiff from running
video in any portion of the building under threat of arrest.

14.

On April 5, 2004, the Delaware Supreme Court issued its Administrative
Directive No. 155, which established a six-month trial court experiment, which
was originally scheduled to end on October 15, 2004. In this experiment, media
coverage was permitted in the Sussex Court of Chancery, and courtrooms in
New Castle, Kent and Sussex Counties. Broadcast of non-confidential, non-jury,
civil proceedings was permitted. Administrative Directive No. 155 was amended
on October 25, 2004, and the experiment was extended until May 16, 2005. On
November 29, 2005, Administrative Directive No. 155 was again amended, this
time extending the experimental period indefinitely.

15.

Plaintiff was compelled to leave without that which he came to get, i.e. video
inside of the building, including a requested interview with Defendant Malone in
lieu of the other Defendants.

16.

All Defendants, particularly Defendant Paradee knew that there was no written
policy of any kind that would forbid any video collection yet they colluded to
give Plaintiff and other staff the impression that there was.

17.

All Defendants, particularly Defendant Paradee knew that there was no
unwritten policy of any kind that would forbid any video collection yet they
colluded to give Plaintiff and other staff the impression that there was.

4

18.

Ultimately, however, and contrary to the misinformed musings of Betty Lou
McKenna's Deputy Recorder, it turns out there is no policy, written or
unwritten, of banning cameras in the Kent County Recorder of Deeds
building.

19.

A letter from attorney Mary E. Sherlock is pure evidence of Plaintiff’s assertion
as noted in bold italic, above (Exhibit 1).

20.

Further, in the event there was an unwritten policy, said policy would again
violate the First Amendment to the United States and Delaware Constitutions.

21.

The aforementioned conduct of the Defendants, jointly and severally,
foreseeably and proximately caused Plaintiff substantial emotional hardship and
consternation, such injury continuing into the foreseeable future.
THE LETTER

5

CLAIMS
I.

INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
Clearly in this instance the actions of all Defendants, jointly and severally, with

several Defendants acting under Color of Law, and with a duty to protect the media from
insidious attacks against the First Amendment, shocks the conscience of any reasonable
person and violates the letter and spirit of the Law.
II.

NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS
Clearly in this instance the actions of all Defendants, jointly and severally, with

several Defendants acting under Color of Law, and shocks the conscience of any reasonable
person and violates the letter and spirit of the Law.
III.

VIOLATION OF THE FIRST AMENDMENT TO THE UNITED STATES CONSTITUTION
AS PER 42 U.S.C. §1983
Amendment I
Congress shall make no law respecting an establishment of religion, or prohibiting
the free exercise thereof; or abridging the freedom of speech, or of the press; or the
right of the people peaceably to assemble, and to petition the government for a
redress of grievances.
Clearly in this instance the actions of all Defendants, jointly and severally, with

several Defendants acting under Color of Law, violates the letter and spirit of the Law.
IV.

VIOLATION OF DELAWARE FREEDOM OF THE PRESS, ARTICLE 1 SEC. 5 AS PER 42
U.S.C. §1983
§5. Freedom of press; evidence in libel prosecutions; jury questions.
Section 5. The press shall be free to every citizen who undertakes to examine the
official conduct of men acting in a public capacity; and any citizen may print on any
subject, being responsible for the abuse of that liberty. In prosecutions for
publications, investigating the proceedings of officers, or where the matter
published is proper for public information, the truth thereof may be given in
evidence; and in all indictments for libels the jury may determine the facts and the
law, as in other cases.
Clearly in this instance the actions of all Defendants, jointly and severally, with

several Defendants acting under Color of Law, violates the letter and spirit of the Law.

6

DEMANDS
1.

Immediate Declaratory Judgment.

2.

Temporary Injunctive Relief against further or repeated transgressions.

3.

Permanent Injunctive Relief against further or repeated transgressions.

4.

Compensatory Damages in Excess of $25,000.00.

5.

Punitive Damages in an amount to be determined by Jury.
JURY DEMAND
Plaintiff hereby demands that this Cause be heard by a duly-empaneled Jury of

appropriate size and composition.
________________________
Christopher King, J.D.
A/K/A KingCast/Mortgage Movies
VERIFICATION
Plaintiff solemnly swears that all factual representations herein are accurate and
true to the best of his recollection and issued with absolute Good Faith.
DATE: _______________________________________
________________________________________________
Christopher King, J.D.
A/K/A KingCast/Mortgage Movies

_________________________________________________
NOTARY
MY COMMISSION EXPIRES: _________________________________________

7

IN THE KING COUNTY SUPERIOR COURT
SEATTLE, WASHINGTON
CHRISTOPHER KING, J.D.
A/K/A KINGCAST/MORTGAGE MOVIES
17022 11TH Avenue
Shoreline, WA 98155,
Plaintiff,

)

v.

) JUDGE __________________________

) CASE NO. _______________________

BETTY LOU MCKENNA,
KENT COUNTY RECORDER OF DEEDS
IN HER INDIVIDUAL AND OFFICIAL CAPACITIES
and
HOLLY MALONE
DEPUTY KENT COUNTY RECORDER OF DEEDS
555 Bay Road
Dover, Delaware 19901
and
JOHN W. PARADEE, ESQ.
C/O PRICKETT, JONES & ELLIOTT, P.A.
1310 North King Street
Wilmington, DE 19801

)
)

)
)

PLAINTIFF’S FIRST SET OF RULE 26 DISCOVERY REQUESTS
INTERROGATORIES
1.

State why Defendant Malone told Plaintiff he could not run video in the 555 Bay
Road building otherwise known as the Kent County Register of Deeds.

2.

State who told Defendant Malone that Plaintiff he could not run video in the 555
Bay Road building otherwise known as the Kent County Register of Deeds.

3.

State who told Defendant Malone that video was impermissible in the 555 Bay
Road building otherwise known as the Kent County Register of Deeds.

4.

State who told Defendant Malone, prior to 1 November, 2014 that video was
impermissible in the 555 Bay Road building otherwise known as the Kent
County Register of Deeds.

8

5.

State whether John Paradee told any Defendant or any employee at in the 555
Bay Road building otherwise known as the Kent County Register of Deeds that
video was impermissible in said building.

a) If the answer to the foregoing is in the affirmative state to whom the
communication was made, the manner of the communication and
approximate date and time of the communication.

6.

State what authority that any Defendant has had, at any point in time up to 27
November 2014 that indicates that video was verboten in the 555 Bay Road
building otherwise known as the Kent County Register of Deeds that video was
impermissible in said building.

7.

State who made the initial, any subsequent and final Decision(s) that Plaintiff
could not run video in the 555 Bay Road building otherwise known as the Kent
County Register of Deeds.

8.

State whether Plaintiff would have been permitted to run video had he worked
for a major news network, i.e. CNN.

9.

State why Defendant McKenna did not respond to the early November, 2014
telephone calls made by Plaintiff.

10.

State why Defendant Paradee did not respond to the early November, 2014
telephone calls made by Plaintiff.

11.

State who pays Defendant Paradee’s fees in conjunction with his representation
of Defendant McKenna.

12.

Provide case captions for any Civil Action against any Defendant since 1994.

9

The preceding interrogatories are pattern interrogatories, which the undersigned certifies
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.
Respectfully submitted,
_____________________________________________
CHRISTOPHER KING, J.D.
kingcast955@icloud.com
mortgagemovies007@gmail.com
http://affordablevideodepo.com
http://mortgagemovies.blogspot.com
617.543.8085m
206.299.9333f

10

IN THE KING COUNTY SUPERIOR COURT
SEATTLE, WASHINGTON
CHRISTOPHER KING, J.D.
A/K/A KINGCAST/MORTGAGE MOVIES
17022 11TH Avenue
Shoreline, WA 98155,
Plaintiff,

)

v.

) JUDGE __________________________

BETTY LOU MCKENNA,
KENT COUNTY RECORDER OF DEEDS
IN HER INDIVIDUAL AND OFFICIAL CAPACITIES
and
HOLLY MALONE
DEPUTY KENT COUNTY RECORDER OF DEEDS
555 Bay Road
Dover, Delaware 19901
and
JOHN W. PARADEE, ESQ.
C/O PRICKETT, JONES & ELLIOTT, P.A.
1310 North King Street
Wilmington, DE 19801

) CASE NO. _______________________

)
)

)
)

PLAINTIFF’S FIRST SET OF RULE 26 DISCOVERY REQUESTS
REQUEST FOR PRODUCTION OF DOCUMENTS
1.

Provide a copy of any and all documents that any Defendant relied on in telling
Plaintiff that he could not roll video in the 555 Bay Road building otherwise
known as the Kent County Register of Deeds.

2.

Provide a copy of any and all documents that any Defendant provided to Plaintiff
at any point in time from 1 October 2014 to 27 December, 2014.

3.

Provide copies of any and all checks, vouchers or other documentation that shows
payments made to Defendant Paradee were made in conjunction with his
representation of Defendant McKenna.

4.

Provide copies of any and all checks, vouchers or other documentation that shows
payments made to Attorney Mary E. Sherlock relative to her evaluation of
Plaintiff’s FOIA/Title 29 Public Records Request in which she noted that there “is
no written policy.”

5.

Provide any documents that purport to prove that La Mar Gunn engaged in any
illegal, amoral, immoral or other malum prohibitum during the campaign for
County Recorder of Deeds, and by that I mean, not inclusively, any improper voter
registration drives, any improper courting of absentee votes by elders, or
anything else.

11

Respectfully submitted,
_____________________________________________
CHRISTOPHER KING, J.D.
kingcast955@icloud.com
mortgagemovies007@gmail.com
http://affordablevideodepo.com
http://mortgagemovies.blogspot.com
617.543.8085m
206.299.9333f

12

IN THE KING COUNTY SUPERIOR COURT
SEATTLE, WASHINGTON
CHRISTOPHER KING, J.D.
A/K/A KINGCAST/MORTGAGE MOVIES
17022 11TH Avenue
Shoreline, WA 98155,
Plaintiff,

)

v.

) JUDGE __________________________

BETTY LOU MCKENNA,
KENT COUNTY RECORDER OF DEEDS
IN HER INDIVIDUAL AND OFFICIAL CAPACITIES
and
HOLLY MALONE
DEPUTY KENT COUNTY RECORDER OF DEEDS
555 Bay Road
Dover, Delaware 19901
and
JOHN W. PARADEE, ESQ.
C/O PRICKETT, JONES & ELLIOTT, P.A.
1310 North King Street
Wilmington, DE 19801

) CASE NO. _______________________

)
)

)
)

PLAINTIFF’S FIRST SET OF RULE 36 REQUEST FOR ADMISSIONS
Plaintiff requests that you admit to the following facts pursuant. If you deny any one of
the following, you are to state with particularity the basis for said denial and to attach to
your denial supporting documentation. You are required to fully respond to these Requests
no later than thirty (30) calendar days after receipt of these interrogatories, to the
undersigned . The Instructions and Definitions found in Complainant’s Interrogatories apply
here.
1.

Admit that Defendant Holly Malone telephoned Defendant Paradee while
Plaintiff stood in the lobby area with his cameras.

2.

Admit that Defendant Holly Malone telephoned Defendant McKenna while
Plaintiff stood in the lobby area with his cameras.

3.

Admit that Defendant Paradee made the Decision to tell Holly Malone that
Plaintiff was not entitled to roll video in the 555 Bay Road building otherwise
known as the Kent County Register of Deeds.

4.

Admit that Defendant McKenna made the Decision to tell Holly Malone that
Plaintiff was not entitled to roll video in the 555 Bay Road building otherwise
known as the Kent County Register of Deeds.

13

5.

Admit that Defendant McKenna’s campaign claimed that La Mar Gunn engaged
in an improper voter registration drive.

6.

Admit that Defendant McKenna’s campaign claimed that La Mar Gunn
improperly courted absentee votes by elders, specifically that he had an
absentee ballot in his hand in this photograph:

7.

Admit that no Defendant has any proof that La Mar Gunn engaged in any
improper voter registration drives.

8.

Admit that no Defendant has any proof that La Mar Gunn engaged in any
improper conduct with regard to absentee ballots.

Respectfully submitted,
_____________________________________________
CHRISTOPHER KING, J.D.
kingcast955@icloud.com
mortgagemovies007@gmail.com
http://affordablevideodepo.com
http://mortgagemovies.blogspot.com
617.543.8085m
206.299.9333f

14