19 October 2015

Re:

RCW 42.56.010 Public Records Act Demand for Information on Checks
and Balances, Consumer Law Attorneys.

Dear Attorney Ferguson:
I am aware that you cherish the First Amendment and open government as
noted by your website and general support for the process and ultimate
Decision in Nissen v. Pierce County:
http://www.atg.wa.gov/news/news-releases/attorney-general-applauds-statesupreme-court-ruling-access-public-records
From your recent press release you noted:
“I am committed to enhancing transparency in government…..Open
government is vital to a free and informed society, and this updated
guide will help both public officials and the people they serve
understand our state’s public disclosure laws.”
"The advancement and diffusion of knowledge is the only guardian of true
liberty."
-James Madison
The laws are based on three important principles:
 The people of this state do not yield their sovereignty to the agencies
that serve them.
 The people, in delegating authority, do not give their public servants
the right to decide what is good for the people to know and what is not
good for them to know.
 The people insist on remaining informed so that they may maintain
control over the instruments that they have created.
As a former Assistant Attorney General I couldn’t agree more. Wherefore, I
look forward to a prompt, principled and full response to the following points
of inquiry:
1. Provide a copy of all employment applications for all consumer law section
attorneys hired from January 2010 to present, including their Curriculum Vitae
or Resumes.
2. Provide any documents that show, or tend to show, whether the pending
subpoena or investigation into Attorney Stafne's office was initiated by a third
party or within your office.

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3. Produce a copy of any third party complaints filed with your office by
anyone regarding Attorney Stafne or anyone in his employ for the past five
(5) years.
4. If there are such complaints and you claim that any such complaints may
not be released for confidentiality reasons, then provide them with identities
of the complaining parties redacted.
5. If there are such complaints and you claim that any such complaints may
not be released for confidentiality reasons then provide documents that
indicate the date of intake relative to such complaints against Attorney Stafne
or anyone within his employ.
6.
For the period of 1 January 2013 to present: All emails or other
correspondence to or from Daniel Davies, Esq. or Benjamin Roesch, Esq. that
are to or from any employees of the City of Seattle or King County Recorder
of Deeds.
7. If any different response than that to item 6 is contemplated by the
following, provide full responses relative thereto: For the period of 1 January
2013 to present: All emails or other correspondence to or from any Consumer
Attorney or his or her staff that are to or from any employees of the City of
Seattle or King County Recorder of Deeds.
8. All public record writings by Attorney General Office employees created
during Bob Ferguson's term of office which reference Marie McDonnell and/or
McDonnell Analytics and/or any version of the audit titled, City of Seattle
Review of Mortgage Documents, the City of Seattle commissioned McDonnell
Analytics to prepare and/or any concerns regarding such audit or different
versions of it.
For purposes of these requests the terms public record and writings shall be
construed consistently with RCW 42.56.010(3) & (4) and shall include public
documents and/or writing sent or received on private on privately owned
technology. See Nissen v. Pierce Cnty., No. 90875-3, 2015 WL 5076297, at *1
(Wash. Aug. 27, 2015); O'Neill v. City of Shoreline, 170 Wash.2d 138, 150, 240
P.3d 1149 (2010). For purposes of this request the term invoices should is
defined to be consistent with RCW 45.56.904 and 42.65.030.
Lastly, you should know that the issues countenanced by the Marie
McDonnell Report – conducted with advisement from Attorney Stafne – shall
be manifest in the case of Daviscourt v. Quality Loan Servicing Corp., King
Cty Superior 14-2-19520-6 SEA. See case caption at Appendix A.
This is crucial – of paramount importance in fact -- because your office is
investigating Attorney Stafne in some measure even as he last month
defeated Summary Judgment and won Partial Summary Judgment over a
MERS issue in Schiavone v. MERS et al. up in Whatcom County as noted in my
recent video that I played this weekend at the Washington Tea Party Open
Government Training Day:

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http://mortgagemovies.blogspot.com/2015/10/kingcast-and-mortgagemovies-present-at.html
https://www.youtube.com/watch?v=zltbRvhfqZI
Here is the full video in which I note that I will be seeking a video interview
with Attorney Ferguson after I review the responses.
http://mortgagemovies.blogspot.com/2015/10/kingcast-and-mortgagemovies-interview.html
https://www.youtube.com/watch?v=Qyc5vtbqBLM

Please provide these material in an electronic format within the statutory
time period required for doing do so.
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
cc:

blind copies
World Wide Web

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APPENDIX A

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