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CHRISTOPHER KING, d/b/a KingCast/Mortgage Movies,

) CASE NO. K15C-03-028







Plaintiff hereby removes his Jury Demand as he simply does not feel
safe in Delaware, legally in this Courtroom and definitely not free from
lynchings as noted in an email chain repeated in its entirety below:
On Aug 04, 2015, at 10:57 AM, Christopher King <>
I get it now.
If the AG's Office won't investigate the Delaware lynchings then they sure as
hell won't investigate a First Amendment Free Press Complaint.
How shameful. I recall the video I did a couple of weeks ago showing how Joe
Biden blew off the information I provided about multiple felon Gregory Floyd,
who continued on a rampage and criminally threatened his neighbor.
So my next video will go to an altogether different place, and don't expect me
to appear at any more kangaroo Court hearings and I may withdraw my Jury
Demand because as a former Civil Rights litigator I know my history and I
know I love living more than the alternative.

Because none of these motherfuckers would investigate my death, I'll tell you
that much. Nope, time to submit it on paper, get on up to the Supreme Court
and then on to SCOTUS once Delaware finishes its Dirty Work. And I do mean
This nigger stays at home:


Begin forwarded message:

From: Christopher King <>
Date: August 04, 2015 12:02:29 PM
Subject: Re: Delaware The First Amendment Denials are Nothing
Compared to the Lynchings.
Yep, now I see why Delaware hates cameras in its public meetings.
I've already got these videos downloaded.
May the Defendants enjoy whatever pyrrhic victories they may have in my
case, because I am opening up a whole 'nother can of whupass on the entire
state of Delaware, and any and all of the house negroes who sit there and
take it. If you are offended by this then you are part of the problem so fuck
you too.
And I mean that with all of my heart.
A copy of this email chain will be submitted to Court with my withdrawal of
Jury Demand.

Yep. Apparently it's the Delaware Way
The following information remains valid and true and is incorporated
herein merely so the the Record remains complete in showing that Plaintiff
clearly has enough law and facts on his side to obtain a Jury View were he
ever to return to the State of Delaware, but owing to his concerns of public
safety in a State that has actually covered up several recent lynchings of
black men, he will definitely not be setting foot into that crooked, racist --and criminally dangerous State. Please return the $150.00 to the __006
address in the file.
Plaintiff at once notices the Court and Defendants of payment of the
requisite $150.00 Jury Fee and further moves the Court to issue a Jury View of
the subject area. A Jury view is essential in a case such as this because these
cases are based on what is reasonable under the circumstances.
The Court has incorrectly referenced cubicles and interior offices in its
29 June 2015 Opinion at p. 15
As an initial matter, Plaintiff makes no argument for the
existence of a tradition of public access to the interior offices of the
Recorder of
Deeds.41 Furthermore, the Plaintiff does not contend that the function
of the Recorder of Deeds is positively promoted by granting access to
its interior offices. Thus, the Court finds that filming the employees of
the Recorder of Deeds in their cubicles or at the water cooler fails to
create a database of property ownership, among other raisons detre.
Notwithstanding the fact that the Third Circuit Plaintiff in Pomykacz v.
Borough of W. Wildwood, 438 F. Supp. 2d 504 (2006) had no such tradition,
nor did Plaintiff in Tisdale v. Gravitt, 51 F. Supp. 3d 1378 (N.D. Georgia 2014),
this is at once an incorrect analysis of law and incorrect inference about what

areas Plaintiff came to video. Nothing in the pleadings suggests that he came
to video interior offices or cubicles.
As such, the analysis comes down to what is reasonable and Plaintiff of
course cannot show the areas he tried to film because he was THREATENED
WITH ARREST and therefore chilled and in effect seized pursuant to the
Fourth Amendment.1 Therefore a Jury is entitled to see what Plaintiff saw and
was attempting to film. From Delaware Trial Handbook 20:11. VIEW OF
In certain circumstances, a party may wish to have the jury or other
trier of fact view the scene where the event or transaction at issue occurred.
Whether or not to allow such a jury view is within the discretion of the trial
court.133 The court may deny a request for a jury view if, in the courts
opinion, such a view would serve no useful purpose, for example, where
photographs adequately inform the jury as to the scene.
As such, there has to be at a minimum photographs and diagrams but the
best evidence is of course an actual visit. Thompson v. State, 399 A.2d 194
(Del. 1979). See also State v. Bilinski, Cr. A. No. 1N83-06-l725, slip op. at 6-9,
Poppiti, J. (Del. Super. May 25, 1989), affd mem., 574 A.2d 262 (Del. 1990)
(permitting view where trial court concluded that photographs and diagrams
were inadequate).
In at least one non-jury case, the trial court accepted into evidence a
videotape of the subject premises, thereby bringing the view to the court..
Fairwinds Shopping Center v. Five Star Video, Inc., C.A. No. 9lC-06-161, Del
Pesco, J. (Del. Super. Apr. 2, 1993).
If there is available video of the subject scene it should be properly
introduced into evidence as it aids the Trier of Fact. See also State v.
Restrepo-Duque, 2014 Del. Super. LEXIS 240 (2104) Robert B. Young
presiding. While this case is not final and subject to review, the point remains
that if there is anything that could help a Jury fairly decide a case, it must be
properly introduced or seen by a Jury. As Defendants have of course
prevented Plaintiff from gathering any visual evidence, still photographs, a

1 And even if he were not seized there still remains the issue of prospective relief for
the next time Plaintiff appears at the Recorder of Deeds so he needs to know if it is
permissible for Defendants to arrest him.

video or a jury view must be made and/or conducted because testimony

without visuals is worthless in this context.
At this point there is nothing in the record excepting the Courts
incorrect assertion.
Lastly, note that while Delaware is apparently teeming with unlawful
First Amendment conduct, not all of it requires a Jury View. For example while
some of Newcastle County allows cameras as noted in Plaintiffs First
Amended Complaint, the Board of Adjustment apparently needs a mental

Delaware Coalition for Open Government

PO Box 493
Montchanin, DE 19710

Mr. David H. Burt, Chair

New Castle County Board of Adjustment
87 Read's Way
New Castle, DE 19720

August 2, 2015

Dear Mr. Burt:

The Delaware Coalition for Open Government is a non-profit organization committed to
promoting and defending the people's right to transparency and accountability in government.
We serve as a resource through education and advocacy, and we work to strengthen Delaware's
Freedom of Information Act, its application and its enforcement.
I am writing to express our concern over the New Castle County Board of Adjustment failure to
post over 20 meeting minutes on your web-site as well as your prohibiting bona-fide journalists
from video/audio recording the June 11th meeting, as well as future meetings of the Board.
As you are aware, Delawares Freedom of Information Act was enacted, in part, to provide the
public the opportunity to observe the performance of public officials and to monitor their
decisions in formulating and executing public policy.
This opportunity for the public to observe and monitor your performance as public officials is
thwarted by not posting your meeting minutes in a timely manner and prohibiting bona-fide
journalists from video recording your meetings.

Delaware Code Title 29, 10004 Open Meetings (f) states that, Each public body shall maintain
minutes of all meetings, including executive sessions, conducted pursuant to this section, and
shall make such minutes available for public inspection and copying as a public record.
Our perusal of the Board of Adjustments web-site found that the last Board of adjustment
meeting minutes were posted on June 26, 2014. Since then, over 20 meeting minutes have yet to
be posted.
In addition to the timely posting of meeting minutes, there are no prohibitions under Delawares
Freedom of Information Act, 29 Del. C. ch. 100 that exclude bona-fide members of the news
media from video recording the proceedings of public bodies.
I have attached a legal memo dated April 1, 2011 from Lawrence W. Lewis, then Delaware
Attorney General Solicitor that speaks to the issue of the right of the public to record open
meetings of public bodies.
Solicitor Lewis ends his memo by stating; the Department of Justice should advise its client
public bodies that to prohibit any recording of public meetings is highly risky. The law is
evolving in a more permissive direction.
We agree with the solicitor and urge the Board to make reasonable accommodations for bona-fide
journalists to video-record future meetings of the Board of Adjustment as well as timely posting
of meeting minutes.
We thank you for your time in this matter.
John D. Flaherty
John D. Flaherty, President
Delaware Coalition for Open Government
bcc: David Grimaldi, DelCOG
As such, a camera view is not ipso facto necessary in that case even
though the wrong is equally heinous.
In any event, Plaintiff who is not a self-proclaimed web video
journalist (29 June 2015 Opinion p.3) but rather a former AAG, Daily
Reporter/Editor, Escrow attorney and successful First Amendment litigator as
attorney and private citizen has some experience on this matter.
To wit, in 2013 he shot the Jury view in State v. Cody Eller, a road rage
situation in which a conviction was ultimately overturned because of a dirty
cop. As a former law enforcement attorney I blanche at this result but it was
the only fair thing to do.
Motorcycle Road Rage? Cody Eller Trial Day One.

Note Judge Jacalyn Coburn, green coat front and center. She has no problems
with KingCast cameras in the Courtroom, on the road or anywhere else in
public. So apparently Delaware now firmly behind East Coast states like
Georgia, New Jersey and New Hampshire, likes its Justice cloaked with an
aura of invisibility. That is because it is a rogue State. See also :
Tuesday, July 21, 2015
KingCast and Mortgage Movies Observe an East Coast First Amendment
Battle Over Right to Film Public Officials: Pomykacz v. Borough of W.
Wildwood, 438 F. Supp. 2d 504 (2006), Tisdale v. Gravitt, 51 F. Supp. 3d 1378
(2014), Gravitt v. Olens, 2015 Ga. App. LEXIS 490 (2015), Tarus v. Borough of
Pine Hill, 189 N.J. 497 (2007), King v. McKenna, 2015 Del. Super. LEXIS 323


To wit, in 1998 this footage of Plaintiff in Hamilton, Ohio references a

Jury View in which his client Michael Isreal was exonerated of Criminal
charges and went on to settle his Civil claims for $57,500.00 against
Hamilton, Ohio officers Hensley and Rodes. Come now to discover years later
that Plaintiff was correct again, ab initio, as Defendants are aware, Hensley
(as a married man) continued to terrorize the community and disciplinary
action finally was taken after several women reported stalking issues.
Tuesday, January 28, 2003
Police uncover officer's dark side
Investigation finds threats, complaints
By Janice Morse
The Cincinnati Enquirer
HAMILTON - Some of William R. Hensley's fellow officers had raised concerns
about him years ago, after they saw him "bully" suspects as early as 1996, a
2002 internal probe reveals.
The 100-page document, released Monday in response to
the Enquirer's public records request, also shows that the now-suspended
detective, though married, has twice been ordered to stay away from women
identified as his "girlfriends" - and he allegedly threatened "to get physical"
with colleagues who were being questioned about him last year.
The document about the internal police probe released Monday depicted a
different picture of Mr. Hensley's record than the mostly glowing city
personnel files released last week.
One officer said he saw then-officer Hensley grab a handcuffed suspect in
1996 and slam him into a wall. "I think Bill hit him with his flashlight. The guy
fell to the ground," the officer said.
During another 1996 incident, an officer said, "I was handcuffing (a suspect),
when Billy hit him in the face. After that, I took Billy off to the side and told
him not to be hitting people in the face. I told him I did not want to be around
when he's hitting people like that. Billy's famous comment to me was, `I like
to see my work.'" (On information and belief this was Plaintiffs client Michael
Isreal, who went on to prove himself as victim of violent crime as noted by
the Ohio Court of Claims with Plaintiff as Counsel, Case no. V96-61481).


In June 1997, another officer said he saw Officer Hensley punch a handcuffed
burglary suspect at least twice.
In the summer of 2000, another officer reported seeing Detective Hensley
"chuck" a boy in the face with his forearm.
KingCast vintage trial footage shows how to protect First Amendment
Published to YouTube in on 17 January 2010.


Lastly, Plaintiff recalls that this is hardly the first time he has had to
sue a government to do the right thing. In 2007 he was awarded a First
Amendment Commendation by Nashua NH Mayor Bernard Streeter, the
longest-sitting member of the Governors Council, who agreed with the
Aldermen that Kelly Ayottes investigation of the double-homicide in
Franconia, NH was bogus. He also agreed with Plaintiff as did the City
Attorney that the School Board had enacted an unlawful First Amendment





This is good background for the Court to understand, as Defendants

have on prior occasion cited to a Free Press lawsuit that Plaintiff lost to
Ayotte, albeit when she was NOT and ELECTED OFFICAL, and when she was
held to be participating in a PRIVATE event. None of which is present in this
case, as noted herein:
Former Trial Atty Rips Judge Robert B Young in Delaware Free Press
First Amendment case.


In Sum, Thomas Paine is still rolling in his grave.


Respectfully Submitted,

I, the undersigned, swear that a true and accurate Courtesy copy of this
document was sent via email and via Tracked U.S. Mail to:
Joseph Scott Shannon, Esq.
Art C. Arnilla, Esq.
1220 North Market Street
5th Floor
P.O. Box 8888
Wilmington, DE 19899-8888
and to:
John A. Elzufon, Esq.
Peter McGivney, Esq.
300 Delaware Avenue,
Suite 1700
P.O. Box 1630
Wilmington, DE 19899
This 4th day of August, 2015