IN THE SUPERIOR COURT

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

)

Plaintiff,

CASE

)

JUDGE______________________
v.

)

CITY OF QUINCY
AND
JAMES S. TIMMINS, Esq.
In his Individual and Official Capacities,
1305 Hancock St.,
Quincy, MA 02169

)

Defendants.

)
)
)

SWORN COMPLAINT IN DECLARATORY JUDGMENT PER MGL 66 §10
PARTIES
1.

Plaintiff has permitting and zoning experience in New England as a
communications attorney who also worked for major press prior to
law school.
He was the first independent journalist to register with the SJC back
in 2012 and has filmed all matter of civil and criminal trials in
Massachusetts courtrooms and will continue to do so, including this
very case. See Appendix A.

2.

He is the investigative journalist who found Joanna Marinova her
lawyers and they sued the Boston Herald for a $.9M settlement
after a $.5M Jury Verdict.
http://christopher-king.blogspot.com/2014/03/kingcast-cheersjoanna-marinova-and.html

1

https://www.youtube.com/watch?v=l_kb8JS-Lk0
https://www.youtube.com/watch?v=ZlaHj9QN9yc
3.

Disgraced Suffolk County Register of Probate told him to “fuck off”
after he noted deceit in her office. https://www.youtube.com/watch?
v=gAnq7Dlq3ls

4.

Defendant City of Quincy was at all times a duly-chartered
municipality in the Commonwealth of Massachusetts.

5.

Defendant Timmins was at all times relevant to this Action the
Quincy City Solicitor charged with administering Public Information
Requests. He is being sued in his Individual and Professional
Capacities as his conduct in this matter is patently ultra vires.

JURISDICTION and VENUE
6.

This is a Court of general jurisdiction fully vested with full authority
to hear all Claims mounted herein.

7.

Defendants Reside in, and work in Norfolk County, Massachusetts.

8.

The misconduct giving rise to this Action occurred in Norfolk
County, Massachusetts.
FACTS

9.

This is a simple matter but the corrupt City of Quincy is making it
very complicated.

10.

The City have refused James Berlo a build permit for the past three
(3) years on his home, which is located on a shoreline with beautiful
views.

11.

Defendant LaForest failed to send Mr. Berlo an email from FEMA
Director Jeb Killion to her, that explained that Mr. Berlo does not
have to have insurance because he owns his own home outright
and he is not in a velocity zone. Appendix B.

2

12.

Margaret LaForest knows as much and she told the general
populous that much in a letter dated but yet she told Plaintiff a
different story as once can see in movies #1 and #2 in para 18 and
at Appendix B.

13.

Further, they have refused to provide Plaintiff any updates to his
Public Records Request when all he wanted was updates from 1
September, 2015 to 20 October, 2015.

14.

Plaintiff has substantial permitting and zoning experience in Texas,
Pennsylvania, Ohio, Virginia and New England as a communications
attorney who also worked for major press prior to law school.

15.

Nonetheless, Defendant Timmins instructed staff on our about 13
October, 2015
I advise each and all of you not to respond to this man. Not certain
where he is coming from, but let’s see…
I will advise each of you if I hear from him again.
James S. Timmins
CITY SOLICITOR
1305 HANCOCK STREET
QUINCY MA 02169
(617) 376-1511
FAX 376-1519
jtimmins@quincyma.gov

16.

Which in turn predicated the following response from Plaintiff, who
has already been crystal clear as to “where he was coming from”
On Oct 14, 2015, at 03:13 PM, Christopher King
<kingcast955@icloud.com> wrote:
Dear Attorney Timmins:
Let me get this straight:
You are advising your clients not to fully respond to a public
records request?
You may wind up being sued as well for that.

3

You want to know where I am coming from, well I am coming
from a position that transparency and open government is
the only government. That would be something not
practiced by certain of your clients, who withheld crucial
FEMA information from Mr. Burlo. And Mr. Fatseas
answering without due diligence. If you want to know where
I am coming from then listen up.
http://mortgagemovies.blogspot.com/2015/10/99-homeskingcast-mortgage-movies.html

4

http://www.piggybankblog.com/2.0/piggybankblog-court-ofpublic-opinion-radio-talk-show-interviews-former-civilrights-and-former-assistant-ohio-attorney-general-turnedpower-blogger-christopher-king-with-hosts-john-wright-andjanet-r/

Very Truly Yours,
CHRISTOPHER KING, J.D.
kingcast955@icloud.com
mortgagemovies007@gmail.com
http://affordablevideodepo.com
http://mortgagemovies.blogspot.com
617.543.8085m
206.299.9333f

17.

Since that time, on or about 19 October, 2015 Defendant Timmins
willfully violated the Statute, in an action that is at once clearly
ultra vires and arbitrary and capricious in nature, by demonstrating
his contempt for the Statute:1
“….Here is my response to your email, to the extent a response
is warranted:
The material you want from Jay Duca will cost a total of $55.60.
A check payable to the city of Quincy should be mailed or
delivered to Jay Duca, Quincy Building Department, 55 Sea
Street, Quincy MA 02169; and he will then produce the
requested copies.

1 For more proof of this assertion see further his attitude in condemning Mr.
Berlo in Appendix C without ever even discussing the matter with him.

5

I will not be providing any “updates” on any matters…..”
(emphasis added in case the Court can’t smell how foul this is
to start with,
see generally Worcester Telegram & Gazette Corp. v. Chief of
Police of Worcester, 436 Mass. 378 (2002))

18.

Timmins has conducted his own research on Mr. Berlo and
determined that he would just go away and that the “clatter” would
die down. He further took it upon himself to conduct his own
Google search of Mr. Berlo – without ever contacting Berlo to get his
side of the story mind you – and determined that Mr. Berlo was
properly found to have an illegal narcotic in his system while
opining that Mr. Berlo’s inquiry was “beyond the pale.” See
Appendix C.

6

19.

In response to the allegations of Defendant Timmins, Mr. Berlo
claims that he did make a call regarding whether or not it was legal
for certain staff members to hold multiple positions in different
municipalities and he was told by an ethics administrator that it was
not. Further, he and Plaintiff have noted that even if it were actually
true that he was on an unauthorized narcotic when he sustained a
work-related injury, it would not have any bearing on his build
permit: He claims that he could not even obtain a dumpster at the
residence at the inception, which is ridiculous, and he claims further
that despite the allegations in Appendix C, he did in fact permit full
documentation excepting the elevation documentation because it
simply is not needed because he owns his property in full, and he is
not in a velocity zone and the proper evaluation is market value,
see para 20.

20.

Timmons claimed to have been overseeing and advising the whole
permitting process, which would include the deliberate
miscalculation that Margaret LaForest and Jay Duca and others used
when calculating whether Mr. Berlo’s property was subject to FEMA
regulations. They used appraisal value when it is clearly MARKET
VALUE:

7

21.

Lastly, as to the Public Records request that is allegedly complete,
Mr. Berlo, on behalf of Plaintiff, dropped off the money on or about
19 October, 2015 with Inspection Director Jay Duca but did not
receive an opportunity to actually retrieve the documents until 26
October, when Plaintiff was compelled to send yet another
threatening email seen at Appendix D.
*******
The relevant online links are here:
http://mortgagemovies.blogspot.com/2015/08/kingcast-andmortgage-movies-say-quincy.html
First video:
https://www.youtube.com/watch?v=NJlz4YEoEF4
Second video:
https://www.youtube.com/watch?v=DkCDlVmr6XE
And the most recent emails are seen below as Appendix D.

8

CLAIMS
1.Willful violation of MGL 66 §10, for refusing to provide all documents from 1
September, 2015 to 20 October, 2015.
DEMAND
1.

Immediate Declaratory Judgment that the Defendants individually
and collectively violated the Statute by refusing to provide
information up to and including 20 October, 2015.

2.

Injunctive relief against any and all further such failures to provide
information pursuant to Statute: When a document is requested,
the government has to produce it unless the demands or clearly
onerous. Plaintiff’s Demands are clearly NOT onerous.

3.

Assessment of all Costs against Defendants for willful derogation of
Law.

4.

Punitive Damages in an amount and degree commensurate with the
wrong.
CERTIFICATION

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

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

9

APPENDIX A

10

APPENDIX B

11

12

13

14

APPENDIX C

15

16

17

APPENDIX D
On Oct 19, 2015, at 06:56 AM, Jim Timmins <jtimmins@quincyma.gov>
wrote:
Here is my response to your email, to the extent a response is warranted:

18

The material you want from Jay Duca will cost a total of $55.60. A check
payable to the city of Quincy should be mailed or delivered to Jay Duca,
Quincy Building Department, 55 Sea Street, Quincy MA 02169; and he will
then produce the requested copies.
I will not be providing any “updates” on any matters.
Ms Powers sent to me, and I sent to you, documents attached to a September
21 email, sent at 5:04 PM to you. I don’t know anything about the documents
– we are merely producing what you asked for, and it is really up to you to
sort through things.
I never directed anyone not to respond to a public records request. I told city
officials who have been receiving emails from you for months not to respond
any further, and indicated I will deal with you. I copied Berlo (who is the
campo address) because you are asking about his permits. I have no idea
what you are after or why – if you need something, ask for it, and we will
send it along. If you want to file litigation, do so –
Several of the officials you indicate did not respond to you did in fact respond
– you should check that, and I will as well. If anyone did not respond to the
initial request I will ask them to do so.
Please deal with Jay directly on the document request, as that will be most
expeditious.
James S. Timmins
CITY SOLICITOR
1305 HANCOCK STREET
QUINCY MA 02169
(617) 376-1511
FAX 376-1519
jtimmins@quincyma.gov
**********

19

On Oct 19, 2015, at 08:07 AM, Christopher King <kingcast955@icloud.com>
wrote:
Dear Attorney Timmins:
Don't get salty with me: I can assure you, a response is warranted. We
discussed this matter at length at this weekend's Tea Party Open Government
Training Day, at which I presented on other matters.
http://mortgagemovies.blogspot.com/2015/10/kingcast-and-mortgagemovies-present-at.html
https://www.youtube.com/watch?v=zltbRvhfqZI
(this video is processing and should be available by 11:30 EST today)
Further, litigation is indeed necessary now because you refuse to provide an
update, and my request for such an update was clearly reasonable in light of
the fact that your clients have, on prior occasion, refused to provide crucial
information from FEMA to Mr. Berlo. It is also warranted because Mr. Berlo told
me he has recently sent emails to your clients so don't try to shirk your
client's responsibilities under the Law.
So yes even if I give your prior email the best construction possible, your
current admonition that you will not be providing any updates runs afoul of
the Law. I'm 50-50 on my public information requests and I feel that
percentage will increase in my favor with this litigation that you have now
made necessary. So I am going to ask you one more time to have your
clients provide updated responses to today's date of 19 October, 2015 before
I submit this email chain as an exhibit in a Declaratory Judgment Action under
the Statute.
And if you are still confused about what it is I want, it is the complete chain of
correspondence related to Mr. Berlo's attempts to permit his property. I don't
want litigation, I just want facts.
And if Mr. Berlo asks for an update to today's date you owe him one as well.
In fact, he told me he is going to do just that. So you can't give him one and
not give me one. I'm trying to help you out so you and your clients don't incur
liability over this; you can thank me later.
So you check the responses to me and I will check the incoming emails to me
so that the facts are absolutely clear in the Complaint. Perhaps Ms. Mahoney
will be called as a witness as to her perception of this entire exchange.
Impeach her at your own peril. As to what your clients will do with Jeb Killion
and his email should Mr. Berlo's attorney sue your client, well I look forward
to seeing that.
I told you before: I'm not here to mess around.
Very Truly Yours,
CHRISTOPHER KING, J.D.

20

kingcast955@icloud.com
mortgagemovies007@gmail.com
http://affordablevideodepo.com
http://mortgagemovies.blogspot.com
617.543.8085m
206.299.9333f
********
26 October 2015 email to Attorney Timmins et al.
Dear Attorney Timmins:
I see you are apparently standing your ground on not providing any of the
sought materials since September 1, 2015. Suit yourself, pun fully intended.
I look forward to flying out there to run video when we have our first court
hearing, as well as Mr. Berlo's litigation. Stay tuned for the lawsuit you'll
have a copy of this in a day or two and then it will be filed.
Because as I told you before, I'm not here to, ummmm, play around. Just ask
the Boston Herald after I found Joanna Marinova her Counsel. Herald. lawyers
said they liked my blog. It's all in the video but below I've got it closedcaptioned for the hearing impaired.
http://christopher-king.blogspot.com/2014/03/kingcast-cheers-joannamarinova-and.html
https://www.youtube.com/watch?v=l_kb8JS-Lk0
https://www.youtube.com/watch?v=ZlaHj9QN9yc
Also, it has been a week or so since Mr. Berlo tendered his monies for the first
Public Information Request.
He still doesn't have anything from Jay Duca.
Ciao.
CHRISTOPHER KING, J.D.
kingcast955@icloud.com
mortgagemovies007@gmail.com
http://affordablevideodepo.com
http://mortgagemovies.blogspot.com
617.543.8085m
206.299.9333f

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