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IN THE UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF WASHINGTON

CHRISTOPHER KING, J.D. )


A/K/A KINGCAST/MORTGAGE MOVIES

and ) CASE No. 2:17-CV-0031


WALLY BROWN
and
CHRIS NUBBE ) JUDGE MARTINEZ
Plaintiffs,
v. )

HON. STAN J. RUMBAUGH


IN HIS INDIVIDUAL AND OFFICIAL CAPACITIES
Defendant. )

RULE 15 MOTION OF PLAINTIFFS'


FOR LEAVE TO FILE A FIRST AMENDED COMPLAINT

Now come Plaintiffs pursuant to Rule 15(a)(2) to file for Leave as previously-
noted before this Honorable Court. Plaintiffs in no ways concede Jurisdiction of
this case, which obviously chiefly turns on the application of GR 16 that reads,
in Pertinent Part:

(b) The judge shall exercise reasonable discretion in


prescribing conditions and limitations with which media
personnel shall comply.

(c) If the judge finds that sufficient reasons exist to


warrant limitations on courtroom photography or recording,
the judge shall make particularized findings on the records
at the time of announcing the limitations. This may be done
either orally or in a written order.

In determining what, if any, limitations should be imposed, the judge shall be


guided by the following principles:
(1) Open access is presumed; limitations on access must be
supported by reasons found by the judge to be sufficiently
compelling to outweigh that presumption; (emphasis added)

At this point we now have more than one isolated incident in which
Defendant has willfully violated carefully crafted State Law in order to chill and
basically eradicate all vestiges of First Amendment and Prior Restraint
protections left in his Courtroom. We have a clearly established pattern,
practice and Policy or Policy-in-Fact that that is material to the entire case,
simple. It is also patently clear that the Washington State Legislature did not

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intend an absurd result in crafting GR 16 so that Judges like Defendant
Rumbaugh could just violate it with impunity in his Individual or Official
Capacities without recompense.
As noted in Plaintiffs First Amended Complaint,
44. His Attorneys are in complicity given that they received this
recent Notice of Media Coverage and obviously advised their
client to ignore it, but sadly this is nothing new as noted by the
Seattle Times and other reputable members of the Fourth Estate:
http://www.seattletimes.com/opinion/editorials/pierce-county-
prosecutor-mark-lindquist-should-resign/

THE people of Pierce County deserve a credible and respected


prosecuting attorney. Today, that is not the case.
Mark Lindquist, the prosecutor since 2009, has managed to
squander a once-promising career in public service. His
unwillingness to accept responsibility for a dysfunctional office
telegraphs his leadership style and his values.
Lindquists pattern of missteps and abuses has triggered
investigations by the Washington State Bar Association and the
county ethics commission. Two whistleblower complaints throw
light on a politicized office, a culture of vindictiveness, and
prosecutorial offenses that undermine the public interest..
Plaintiffs Certify that they have placed Defendant on Actual Notice of
this pending Motion but have not received mutual assent relative thereto.
As leave shall be liberally-granted for Leave to Amend, and as none of
this is Plaintiffs fault, the Motion must be summarily GRANTED even if
GRANTED before the Court of Actual Jurisdiction, which is the King County
Superior Court.

Plaintiffs remain dedicated to TRANSPARENCY IN GOVERNMENT.

Respectfully submitted,

___________________________________________
Christopher King, J.D.

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___________________________________________
Wally Brown

___________________________________________
Chris Nubbe

https://www.youtube.com/watch?v=ZcE0ZiO-deM

CERTIFICATE OF SERVICE
We, the undersigned, solemnly swear that a true and accurate copy of the
foregoing Motion with copy of First Amended Complaint was sent via email and
tracked U.S. Mail
on 6 March 2017 to the following:

Daniel R. Hamilton, Esq.


dhamilt@co.pierce.wa.us

Stephen D. Trinen, Esq.


strinen@co.pierce.wa.us

955 Tacoma Avenue South


Suite 301
Tacoma WA 98402

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___________________________________________
Christopher King, J.D.
___________________________________________
Wally Brown
___________________________________________
Chris Nubbe
IN THE KING COUNTY SUPERIOR COURT
SEATTLE, WASHINGTON

CHRISTOPHER KING, J.D. )


A/K/A KINGCAST/MORTGAGE MOVIES
17006 11TH Avenue ) CASE No. 2:17-CV-0031
Shoreline, WA 98155,

and )

WALLY BROWN ) JUDGE MARTINEZ


16717 Vail Loop, SE
Rainier, Wa 98576
)
and

CHRIS NUBBE )
Judicial Oversight Investigator
PMB 377, 1001 Cooper Pt Rd SW STE 140 )
Olympia, WA 98502
)
Plaintiffs,

v. )

HON. STAN J. RUMBAUGH


IN HIS INDIVIDUAL AND OFFICIAL CAPACITIES )
c/o Pierce County Superior Court
County-City Building )
930 Tacoma Ave. South,
Room 334 )
Tacoma, WA 98402

Defendant )

FIRST AMENDED COMPLAINT

JURISDICTION AND VENUE


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1. This is a Court of General Jurisdiction vested with Authority to hear all
Claims asserted herein. Venue is appropriate as Plaintiff King resides
and is domiciled within King County, where he routinely films
Courtroom Hearings pursuant to his Mortgage Movies Journal page.
Plaintiff in no ways consents to this Courts Jurisdiction
relative to the pending Remand issues.
2. Further, the venue is readily accessible and convenient for all
witnesses and Parties.
THE PARTIES
3. Plaintiff King 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 Kings First
Amendment Page and Mortgage Movies Journal.

4. Plaintiff Brown is also a professional-grade journalist with years of


experience as a videographer.

5. Plaintiff Chris Nubbe is a Judicial Oversight Investigator who


witnessed the July 22nd, 2016 court proceeding who has a Derivative
First Amendment Right to receive video court coverage from the
news sources of his choice, such coverage being distinctly different,
i.e. fuller and more dynamic and less expensive than obtaining a
written official Court transcript. Plaintiff Nubbe therefore brings this
challenge pursuant to the First Amendment to the United States
Constitution and related State Constitution that grant Standing in
cases where the government has conducted chilling activity.

6. Defendant Rumbaugh is a duly-appointed Pierce County Judge who


may be sued for the transgressions of law enumerated herein. He is
being sued in his Official and Individual capacities.

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7. On information and belief, Defendant Rumbaugh has been, and
continues to be, a Managing Partner of an active law firm, i.e.
Rumbaugh, Rideout, Adkins & Wallace, PLLC some three (3) years
after his ascension to the Bench. This Conduct will be the subject of
an independent Complaint for violation of Canon 3, Rule 3.10:
Practice of Law

(A) A judge shall not practice law. A judge may act pro se or on
behalf of his or her marital community or domestic partnership and
may, without compensation, give legal advice to and draft or review
documents for a member of the judge's family,* but is prohibited
from serving as the family member's lawyer in any adjudicative
forum.

FACTS
8. Plaintiff King and Plaintiff Brown are Western Washington area
journalists who routinely run Courtroom and other video pertaining to
the fallout from Americas 2008 financial/mortgage crisis.
9. The two of them have worked together on several projects since King
moved to Seattle in 2013.
10. Neither of them has been subject to reprimand or sanctions
regarding their in-Court or out-of-Court news coverage.
11. On or about 20 July, 2016 Plaintiff Brown contacted Plaintiff King
regarding a denial of camera coverage of a Friday, 22 July 2016
hearing pending in case number 14-2-12022-8, Federal National
Mortgage Association (FNMA) v. Brenda J. Duzan.
12. King was concerned as he had never been denied access to a
Courtroom in Washington, and in point of fact had only been denied
access to two (2) Mortgage hearing in Courtrooms across America in

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the States of Massachusetts, New Hampshire, California, Maryland,
Minnesota and Washington.
As such, he emailed the Court, by and through Judicial Assistant
Merri Reagan.

*******

On Jul 20, 2016, at 01:45 PM, Christopher King


<kingcast955@icloud.com> wrote:

Dear Ms. Reagan:

As I understand it, you have denied my colleague Wally


Brown camera access to a foreclosure hearing this Friday.

I hereby specifically request access as well.

I have run courtroom video throughout the County on this and


other issues and I believe the denial runs counter to
Constitutional and Statutory and Common Law in the State of
Washington and if it is not rescinded, I will sue.

I am not here to be popular or liked. Judge Monica Benton


can't stand the very sight of me, in spite of the fact that I was
a Civil Rights lawyer and she has Malcolm X and Martin Luther
King on her wall. But she still granted access and that is all... I
repeat ALL.... that I care about.
http://christopher-king.blogspot.com/2015/05/kingcast-
mortgage-movies-malcolm-x-and.html
https://www.youtube.com/watch?v=zVNVyijeQKU

As you will see, I've been running Courtroom video since the
mid 1990's.

Please advise.

Respectfully submitted,
CHRISTOPHER KING, J.D.

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13. Plaintiff King also submitted via email an original and Amended
Notice of Media Coverage, requesting an immediate response prior to
the 22 July 2016 hearing, noting the Rule GR16 and noting his
concerns for Prospective Relief. See Appendix A, attached.
Lastly, please note not only the Constitutional issues but the Statutory

Presumptions:

RULE GR 16 -- COURTROOM PHOTOGRAPHY AND RECORDING BY THE


NEWS MEDIA

(a) Video and audio recording and still photography by the


news media are allowed in the courtroom during and between
sessions, provided
(1) that permission shall have first been expressly granted
by the judge; and
(2) that media personnel not, by their appearance or
conduct, distract participants in the proceedings or
otherwise adversely affect the dignity and fairness of the proceedings.

(b) The judge shall exercise reasonable discretion in


prescribing conditions and limitations with which media
personnel shall comply.

(c) If the judge finds that sufficient reasons exist to


warrant limitations on courtroom photography or recording,
the judge shall make particularized findings on the records
at the time of announcing the limitations. This may be done
either orally or in a written order.

In determining what, if any, limitations should be imposed, the judge shall be


guided by the following principles:
(1) Open access is presumed; limitations on access must be
supported by reasons found by the judge to be sufficiently
compelling to outweigh that presumption;

(2) Prior to imposing any limitations on courtroom


photography or recording, the judge shall, upon request,
hear from any party and from any other person or entity
deemed appropriate by the judge; and
(3) Any reasons found sufficient to support limitations on
courtroom photography or recording shall relate to the
specific circumstances of the case before the court rather
than reflecting merely generalized views.
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I specifically note that even if this matter is not addressed for any reason

by tomorrows hearing, it must be addressed immediately owing to future,

prospective Relief: Open Courts are the best Courts. The case will be posted on

several YouTube channels, including but not limited to Plaintiffs YouTube

Channel https://www.youtube.com/watch?v=ZcE0ZiO-deM

*********
14. The Court did not respond to Plaintiff King.
15. Plaintiff King did then hand file his Notice of Media Coverage on 2
August 2016 for prospective relief in this case and for precedential
value in other cases before this Honorable Court. See Appendix A.

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16. The effect of Plaintiff Kings actions, coupled with the complete non-
response of Defendant, grants King full Standing and Real Party in
Interest authority as to each and every Claim and Demand for
Damages, same as Plaintiff Brown.
17. Plaintiff Brown also submitted his Notice of Media Appearance, filing
it before the hearing, on 21 July 2016. See Appendix B, attached.
18. In open Court on 22 July 2016 the Courtroom assistants refused to
deliver a copy of Mr. Browns Notice to the Defendant.
19. The Defendant scolded Mr. Brown and told him to Get out of here...
get out of here now. A copy of the Transcript will be ordered to
verify the exact quote.
20. The Defendant completely failed to honor any of the provisions of
Rule GR16.
21. The Defendant violated RULE GR 16(c) by his failure to make
particularized findings on record, either written or oral, at the time of
announcing his limitations on open access to news media to video.
22. The Defendant violated RULE GR 16(c)(1) by his failure to give
legitimate or any reasons to limit video open access to news media
which are sufficiently compelling to outweigh the open access
presumption.
23. The Defendant violated RULE GR 16(c)(3) by his failure to give
legitimate or any reasons to limit video open access to news media
which relate to the specific circumstances of the case before the
court.
24. After litigation ensued and a subsequent improvident and
manipulative, evasive Removal to this Court was filed,
25. Plaintiff King placed the Court on Actual Notice by filing a Notice of
Media Coverage prior to Court in the Bozgoz case 16-2-12303-7 on
24 February, 2017.
26. Plaintiffs had also placed the Court on Constructive Notice by
emailing a copy of same to Counsel of Record in this case on or
about 22 February, 2017.

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27. Plaintiffs placed the Defendants in the case on Actual Notice by
emailing and mailing a copy of same to Counsel of Record in this
case on or about 22 February, 2017.
28. Nonetheless, at approximately 10:00 a.m. on 24 February 2017 the
Court looked straight at Plaintiff King, yet refused to call him to
conduct a Rule 16 hearing prior to calling the case for a Record
Hearing. Plaintiff was therefore forced into interrupting the Hearing
whereupon the following colloquy ensued, initially between the
litigant and then between Plaintiff King and Defendant Rumbaugh.
The litigant has full Power of Attorney for her cousin, and was
litigating (using her PoA and the ADA) a wrongful death action after a
Pierce County Public Access driver tipped her aunt onto her head in a
reckless driving maneuver, breaking her neck. She died a year later. 1
29. Court: If you are representing another entity like an LLC or an estate
you cannot represent yourself.

30. Family: I had a full power of attorney Court A POA only allows you to
speak on her behalf. The case law in the state is quite clear. She
cannot speak on her behalf. I understand and I don't dispute that you
have a power of attorney. Non-individual entities must be
represented by counsel.2
31. Family: I gave you several examples.. precedents....
32. Court: You cannot file on behalf of an estate unless you are an
attorney.3
33. Family: "I have given you several past precedents where superior
court where I showed you can file a claim and sign it when you have
full representation. She falls under ADA as I told you..... " 4

1 The Official Transcript is being ordered today, Monday 6 March 2017.


2 [note: I've litigated this issue myself as seen in the thumbnails. If it is different in
Washington State then the Family has a right to certify a conflict between the States
and go Federal on this].
3 [note: This may be a false distinction, a legal red herring -- Susan was representing
the daughter of the Decedent, standing in her shoes.]
4 [note: The Decedent's daughter is, inter alia, PTSD after seeing her mother in the
hospital parking lot where the idiot Pierce County Transit driver left her. As to the ADA,
Dr. Karin Huffer has a few things to say].
Page 11 of 40
34. Court: The Statute of Limitations has run. You may seek review. 5
35. KingCast/Mortgage Movies: Your Honor with all due respect I have a
pending Notice of Media Coverage similar to the one I filed with Wally
Brown last fall.
36. Court: I'm not hearing that. I find your Notice to be contrived.
37. KingCast/Mortgage Movies: How is this contrived? It's the same
document I've used in hundreds of court cases to run video.
38. Court: Your Notice is denied. KingCast/Mortgage Movies: I'll add this
to our lawsuit as a First Amended Complaint.
39. Obviously this was not a Rule 16 hearing as contemplated by any
portion of the Statute. There was no specific findings of fact as
contemplated by the Statute. Ass such, ihe Defendant completely
failed to honor any of the provisions of Rule GR16.
40. The Defendant therefore again violated RULE GR 16(c) by his failure
to make particularized findings on record, either written or oral, at
the time of announcing his limitations on open access to news media
to video.
41. The Defendant therefor again violated RULE GR 16(c)(1) by his
failure to give legitimate or any reasons to limit video open access to
news media which are sufficiently compelling to outweigh the open
access presumption.
42. The Defendant therefore again violated RULE GR 16(c)(3) by his
failure to give legitimate or any reasons to limit video open access to
news media which relate to the specific circumstances of the case
before the court.
43. The aforementioned conduct of the Defendant as referenced now on
several occasions violated, and continues to violate Washington
and Federal Law.6 The Defendant has demonstrated a design,

5 [note: they will]


6 Plaintiffs hereby stipulate to Damages of less than $75,000 and hereby stipulate that
they will Voluntarily Dismiss their First Amendment claims in the event that Counsel for
Defendant informs them that s/he will seek Removal based on that Claim. Plaintiffs
anticipate a Removal to Federal Court in order to avoid the presence of Cameras.
Plaintiff King recently prevailed on Remand in a similar matter earlier this year but it
may have required dismissal of the First Amendment claim, see generally King v.
Wright Finlay & Zak, 2016 U.S. Dist. LEXIS 53130 (2016)
Page 12 of 40
scheme, pattern and practice, policy and/or Policy-in-Fact of outright
denial of all Procedural and Substantive Rights purportedly protected
by the State Legislature, State and Federal Constitutions. 7
44. His Attorneys are in complicity given that they received this recent
Notice of Media Coverage and obviously advised their client to ignore
it, but sadly this is nothing new as noted by the Seattle Times and
other reputable members of the Fourth Estate:
http://www.seattletimes.com/opinion/editorials/pierce-county-
prosecutor-mark-lindquist-should-resign/

THE people of Pierce County deserve a credible and respected


prosecuting attorney. Today, that is not the case.
Mark Lindquist, the prosecutor since 2009, has managed to
squander a once-promising career in public service. His
unwillingness to accept responsibility for a dysfunctional office
telegraphs his leadership style and his values.
Lindquists pattern of missteps and abuses has triggered
investigations by the Washington State Bar Association and the
county ethics commission. Two whistleblower complaints throw
light on a politicized office, a culture of vindictiveness, and
prosecutorial offenses that undermine the public interest.

7 The Plaintiffs have removed their sole Federal Claim in order to obtain Removal in
the exact same manner as contemplated by last years case of KingCast v. Wright,
Finlay & Zack. In the unlikely event that the Court retains Jurisdiction Plaintiffs must be
permitted to Retain the Federal Claim, as Equity and Justice Demand such a result
given that we all know Defendant Rumbaugh only ran off to Federal Court to hide from
Courtroom cameras in the first place instead of facing all claims in State Court like a
Real Man or an Honest Judge.
Page 13 of 40
45. Further, while the exclusion of the Media is not criminal per se,
Defendants reckless conduct mirrors the language in the Criminal
Statute, to wit:
(c) RECKLESSNESS. A person is reckless or acts recklessly when
he or she knows of and disregards a substantial risk that a
wrongful act may occur and his or her disregard of such
substantial risk is a gross deviation from conduct that a
reasonable person would exercise in the same situation.

Defendant Rumbaughs knowing, willful, and reckless actions of:


1) blatantly violating GR16;
2) using threatening and disrespectful behavior toward a member of
the press/news media, Wally Brown, in raising his voice and loudly
saying to Wally to GET OUT OF THE COURT ROOM!

A superior court judge is presumed to know the court rules and


judicial canons by which they are required to abide. When a judge
blatantly violates a court rule, GR16 for one in this case (and
judicial canons), and obstructed the news media from video recording
access to the court without meeting or attempting to meet the
requirements set forth in GR16 for such limitation, it is reflective of
Defendants blatant disregard and disrespect for the rules, and also of
his lack of independence, impartiality, integrity, and competence. The
judges willful and reckless behavior of obstructing news media as
described was patently improper.
The judge raising his voice to Mr. Brown and telling him to GET OUT OF
THE COURT ROOM! was threatening and intimidating.

For a judge to behave in this manner is extremely damaging, or likely to


be extremely damaging, to the pubic confidence in that judges
independence, impartiality, integrity, and competence, and brings the
judiciary into disrepute.

Both news media personnel as Plaintiffs in this case gave timely and
proper notice of intent regarding media coverage for the hearing and for
subsequent hearings, as indicated herein, in harmony with GR16.

A judge who knowingly, willfully, and recklessly ignores/violates court


rules (GR16, for one), as Defendant Rumbaugh did in this matter, gives
the appearance that he is partial and biased in favor of the Plaintiff, in
this case being Fannie Mae, and against the Defendant, Brenda Duzan.
For these reasons he should also enter an Order of Recusal and set the
case for reassignment forthwith.

Page 14 of 40
CLAIMS

I.VIOLATION OF THE FIRST AMENDMENT TO THE UNITED STATES


CONSTITUTION AS PER 42 U.S.C. 19838
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.

II.VIOLATION OF WASHINGTON ARTICLE I 5

The Right to Speech is part of the same rubric that provides Freedom of
the Press and the Publics Derivative Right to Know. The Defendants conduct
in this case is violative of these Principles.

III. VIOLATION OF WASHINGTON COURTS RULE GR 16.


Clearly in this instance the actions of Defendant violates the Letter and
Spirit of the Rule.

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.

8 Should the Court retain Jurisdiction there is simply no reason at Law or


Equity that Plaintiffs should be compelled to relinquish this Claim. See Fn 6-7,
supra.
Page 15 of 40
Respectfully submitted, with Jury Demand to be subsequently filed,

________________________
Christopher King, J.D.
A/K/A KingCast/Mortgage Movies

________________________
Wally Brown

________________________
Chris Nubbe

Page 16 of 40
APPENDIX A

From: Christopher King <kingcast955@icloud.com>


Date: 7/23/2016 3:58 PM (GMT-08:00)
To: mreagan@co.pierce.wa.us, duzabalm@yahoo.com, fortune2000@fair
point.net, cpeterson@robinsontait.com
Cc: Christopher King <mortgagemovies007@gmail.com>, Steve
Morberg <stevemorberg@yahoo.com>, Michelle Darnell
<michelledarnell7@gmail.com>, Scott Stafne
<scott@stafnelawfirm.com>, jean7.fts@gmail.com
Subject: Re: Notice of Media Coverage and Unlawful denial of camera
access.

I am appalled at what I heard about Judge Rumbaugh's blatant


disrespect of Stautory and Constitutional Law.

Be prepared for litigation in the next calendar month, that much is


certain.

The only things uncertain will be the number of Plaintiffs and whether it
will be filed in the next week or two.

Sent from my iPhone

On Jul 21, 2016, at 5:34 PM, Christopher King


<kingcast955@icloud.com> wrote:

To all please note the Amended Notice of Media Coverage.

Thank you.

CHRISTOPHER KING, J.D.tyr


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

On Jul 21, 2016, at 02:13 PM, Christopher King


<kingcast955@icloud.com> wrote:

To All:

Page 17 of 40
Please be advised that I seek a response to my Notice of Media
Coverage by the Close of Business today.

Thank you.

CHRISTOPHER KING, J.D.


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

On Jul 20, 2016, at 01:45 PM, Christopher King


<kingcast955@icloud.com> wrote:

Dear Ms. Reagan:

As I understand it, you have denied my colleague Wally Brown camera


access to a foreclosure hearing this Friday.

I hereby specifically request access as well.

I have run courtroom video throughout the County on this and other
issues and I believe the denial runs counter to Constitutional and
Statutory and Common Law in the State of Washington and if it is not
rescinded, I will sue.

I am not here to be popular or liked. Judge Monica Benton can't stand


the very sight of me, in spite of the fact that I was a Civil Rights lawyer
and she has Malcolm X and Martin Luther King on her wall. But she still
granted access and that is all... I repeat ALL.... that I care about.
http://christopher-king.blogspot.com/2015/05/kingcast-mortgage-
movies-malcolm-x-and.html
https://www.youtube.com/watch?v=zVNVyijeQKU

As you will see, I've been running Courtroom video since the mid 1990's.

Please advise.

Respectfully submitted,

CHRISTOPHER KING, J.D.


kingcast955@icloud.com
mortgagemovies007@gmail.com
Page 18 of 40
http://affordablevideodepo.com
http://mortgagemovies.blogspot.com
617.543.8085m
206.299.9333f
KingCast.net Mortgage Movies
By: Christopher King, J.D.
17006 11th Avenue NE
Seattle, WA 98155 Hearing Date: 22 July 2016 & prospective
617.543.8085

SUPERIOR COURT OF THE STATE OF WASHINGTON


IN AND FOR THE COUNTY OF PIERCE

FEDERAL NATIONAL MORTGAGE


ASSOCATION, et al., Case Number: 14-2-12022-8

Plaintiffs,

v. AMENDED NOTICE OF MEDIA


COVERAGE
BRENDA J. DUZAN

Defendants.

NOTICE OF MEDIA COVERAGE

Now comes Christopher King, J.D., KingCast.net and Mortgage Movies Journal,

http://mortgagemovies.blogspot.com/, pursuant to general First Amendment Principles, Washington

Right to Access Law and all other applicable law to note that he intends to cover any and all

Courtroom exchanges relative to the above-captioned matter as well as any and all subsequent

public Courtroom hearings. May it please the Court:

I am a former Assistant Attorney General who has also managed a title insurance company as

a title insurance producer. I have also practiced First Amendment and Civil Rights Law throughout

Page 19 of 40
the 1990s, routinely running video of said trials in an age before broadband. Prior to those

activities I was an editor and reporter for mid-sized and large daily press.

Page 20 of 40
I have run video since 2010 in courtrooms throughout the Country and in western Washington

on murder trials, civil litigation and foreclosure without incident including countless King County

Courtrooms, completely without incident.

KingCast Mortgage Movies employs Mr. Kings legal background and experience as a

licensed title insurance producer and escrow attorney to analyse legal matters relative to

foreclosure; all footage shall be made available for media pooling orders or requests in this regard.

In this particular case I have grave concerns that there is a pending First Amendment violation

that I am entitled to challenge as a Constitutionally overbroad, arbitrary and capricious application

of law. To wit, in email exchanges between Court personnel and the homeowner I emailed Ms.

Reagan in His Honors Chambers:

On Jul 20, 2016, at 01:45 PM, Christopher King <kingcast955@icloud.com>


wrote:

Dear Ms. Reagan:

As I understand it, you have denied my colleague Wally Brown camera access
to a foreclosure hearing this Friday.

I hereby specifically request access as well.

I have run courtroom video throughout the County on this and other issues and
I believe the denial runs counter to Constitutional and Statutory and Common
Law in the State of Washington and if it is not rescinded, I will sue.

I am not here to be popular or liked. Judge Monica Benton can't stand the very
sight of me, in spite of the fact that I was a Civil Rights lawyer and she has
Malcolm X and Martin Luther King on her wall. But she still granted access and
that is all... I repeat ALL.... that I care about.
http://christopher-king.blogspot.com/2015/05/kingcast-mortgage-movies-malcolm-x-
and.html
https://www.youtube.com/watch?v=zVNVyijeQKU

Page 21 of 40
Page 22 of 40
As you will see, I've been running Courtroom video since the mid 1990's.

Please advise.

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

*********

To compound injury I see that the Court is now actually contemplating levying ex parte

Sanctions against the homeowner for inquiring about First Amendment/Free Press Activity. That

strikes me as ridiculous because the nature of her inquiry as nothing to do with the Merits of the

case, and that is the true ambit of ex parte analysis. In point of fact, the homeowner likely has

Standing to Sue as well because the application of the Law is arguably overbroad in a manner that

violates First Amendment and Free Press principles, To Wit:

From: Merri Reagan


Sent: Thursday, July 21, 2016 10:45 AM
To: Brenda Duzan
Cc: cpeterson@robinsontait.com ; Wally Brown
Subject: RE: GR 16

Counsel and Ms. Duzan:

The Court further orders as follows:

There was nothing unclear about the Courts earlier order to Ms. Duzan to
desist ex parte contact with the court, yet she persists in doing so. Sanctions
to be imposed on defendant for this repeated violation of the Courts Rules will
be taken up at the time of hearing on Friday, July 22 nd.

Sincerely,

Page 23 of 40
Merri Reagan for Judge Stanley J. Rumbaugh

Merri Reagan| Judicial Assistant to Judge Stanley J. Rumbaugh | Pierce County Superior Court | Dept. #18 | 930 Tacoma
Avenue South, Room 334, Tacoma, WA 98402 | Phone: (253) 798-6650 | Email: mreagan@co.pierce.wa.us

IMPORTANT: In order to avoid inappropriate ex parte contact, you are hereby directed to forward this communication to all
other counsel/parties not already copied on this email.

Think Green. Before printing this e-mail ask yourself: "Do I need a hard copy?"

*********

From: Brenda Duzan [mailto:duzabalm@yahoo.com]


Sent: Thursday, July 21, 2016 10:31 AM
To: Merri Reagan <mreagan@co.pierce.wa.us>
Cc: cpeterson@robinsontait.com; Wally Brown <fortune2000@fairpoint.net>
Subject: Re: GR 16

My understanding is the proper procedures were followed and yes, I will


bring this up at the hearing.
Brenda Duzan

************

Lastly, please note not only the Constitutional issues but the Statutory Presumptions:

RULE GR 16 -- COURTROOM PHOTOGRAPHY AND RECORDING BY THE NEWS


MEDIA

(a) Video and audio recording and still photography by the


news media are allowed in the courtroom during and between
sessions, provided
(1) that permission shall have first been expressly granted

by the judge; and


(2) that media personnel not, by their appearance or
conduct, distract participants in the proceedings or
otherwise adversely affect the dignity and fairness of the proceedings.

(b) The judge shall exercise reasonable discretion in


prescribing conditions and limitations with which media
personnel shall comply.

(c) If the judge finds that sufficient reasons exist to


warrant limitations on courtroom photography or recording,
the judge shall make particularized findings on the records
at the time of announcing the limitations. This may be done

Page 24 of 40
either orally or in a written order.

In determining what, if any, limitations should be imposed, the judge shall be


guided by the following principles:
(1) Open access is presumed; limitations on access must be
supported by reasons found by the judge to be sufficiently
compelling to outweigh that presumption;
(2) Prior to imposing any limitations on courtroom
photography or recording, the judge shall, upon request,
hear from any party and from any other person or entity
deemed appropriate by the judge; and
(3) Any reasons found sufficient to support limitations on
courtroom photography or recording shall relate to the
specific circumstances of the case before the court rather
than reflecting merely generalized views.

I specifically note that even if this matter is not addressed for any reason by tomorrows

hearing, it must be addressed immediately owing to future, prospective Relief: Open Courts are the

best Courts.

WHEREFORE, I respectfully request permission to video an oral hearing or argument on any

and all pending motions. The Proceedings will be on video for subsequent broadcast and

photographed with still camera, and available for any media pools per industry standard should

inquiry arise.

Respectfully submitted,

/s/Christopher King, J.D.


_____________________________
Christopher King, J.D.
http://KingCast.net
http://MortgageMovies.blogspot.com
http://affordablevideodepo.com
617.543.8085/m
206.299.9333/f

Page 25 of 40
CERTIFICATE OF SERVICE

The undersigned certifies that a true and correct copy of the foregoing was delivered via

email on 21 July 2016 and 3 August 2016 and mailed via USPS mail on 3 August 2016 to the

following:

Plaintiff Duzan

and

Craig Peterson, Esq.


c/o Robinson Tait
710 Second Avenue
Suite 710
Seatttle, WA 9810

Page 26 of 40
Dated: 21 July 2016

/s/Christopher King, J.D.

_____________________________
Christopher King, J.D.
http://KingCast.net
http://MortgageMovies.blogspot.com
http://affordablevideodepo.com
617.543.8085/m
206.299.9333/f

27
APPENDIX B

From: Wally Brown


Sent: Wednesday, July 20, 2016 1:02 PM
To: mortgagemovies007@gmail.com
Subject: Fw: FNMA v Brenda J. Duzan Case No. 14-2-12022-8 (Wally Brown)

From: Merri Reagan


Sent: Wednesday, July 20, 2016 10:30 AM
To: Brenda Duzan ; fortune2000@fairpoint.net
Cc: cpeterson@robinsontait.com
Subject: RE: FNMA v Brenda J. Duzan Case No. 14-2-12022-8

Ms. Duzan and Mr. Brown,

The official Court Reporter will be making the stenographical court record, which
can be transcribed and provided to any person, litigant or otherwise, upon payment
of the usual and customary fee for that service. Video recording of the proceedings,
or use of cameras in the court room is prohibited.

Sincerely,

Merri Reagan for Judge Stanley J. Rumbaugh

Merri Reagan| Judicial Assistant to Judge Stanley J. Rumbaugh | Pierce County Superior Court | Dept. #18 | 930 Tacoma Avenue
South, Room 334, Tacoma, WA 98402 | Phone: (253) 798-6650 | Email: mreagan@co.pierce.wa.us

IMPORTANT: In order to avoid inappropriate ex parte contact, you are hereby directed to forward this communication to all other
counsel/parties not already copied on this email.

Think Green. Before printing this e-mail ask yourself: "Do I need a hard copy?"

From: Wally Brown [mailto:fortune2000@fairpoint.net]


Sent: Tuesday, July 19, 2016 11:28 AM
To: Merri Reagan <mreagan@co.pierce.wa.us>
Subject: video in the court

Hi Merri,
I am Wally Brown and I have been contracted by Brenda Duzan to be
added to her defense team in the court proceeding for Friday July 22nd. I am
giving the normal 3 day notice to the judge that is presiding over her
case: FNMA v Brenda J. Duzan Case No. 14-2-12022-8

28
Unless I hear back from you to the contrary, I will be driving up there to
Tacoma to record this hearing. I am a professional court room reporter and
will stand by the normal procedures for courtroom recording, staying out of
the way of all that is going on.

Wally Brown
16717 Vail Loop, SE
Rainier, Wa 98576
(360) 446-1015

From: Brenda Duzan [mailto:duzabalm@yahoo.com]


Sent: Tuesday, July 19, 2016 10:27 AM
To: Merri Reagan <mreagan@co.pierce.wa.us>
Cc: fortune2000@fairpoint.net
Subject: FNMA v Brenda J. Duzan Case No. 14-2-12022-8

Hi Merri,
I am Brenda the defendant in the noted case in the subject line. The
opposing counsel has a motion scheduled for this Friday, July 22nd.
I have retained a videographer to record the hearing on my behalf as part of
my defense. He will be there on Friday to tape the hearing unless the hearing
is cancelled or I do not hear from you stating otherwise.
I have cc'd him as well.
Thank-you,
Brenda J. Duzan
No virus found in this message.
Checked by AVG - www.avg.com
Version: 2016.0.7688 / Virus Database: 4627/12648 - Release Date: 07/20/16

29
IN THE KING COUNTY SUPERIOR COURT
SEATTLE, WASHINGTON

CHRISTOPHER KING, J.D. )


A/K/A KINGCAST/MORTGAGE MOVIES

WALLY BROWN ) CASE No._____________________

CHRIS NUBBE )

Plaintiffs,

v. )

HON. STAN J. RUMBAUGH


IN HIS INDIVIDUAL AND OFFICIAL CAPACITIES )

Defendant )

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).

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

30
which you have resided for the past ten years and the dates you resided at each
address.

ANSWER:

INTERROGATORY NO. 2: State why Plaintiff King did not receive a response from
Defendant allowing him to run video at the Duzan hearing conducted on Friday, 22
July 2016.

31
ANSWER:

INTERROGATORY NO. 3: State why Plaintiff Brown was not permitted to run video
at the Duzan hearing conducted on Friday, 22 July 2016.

ANSWER:

INTERROGATORY NO. 4: State exactly, to the best of his recollection,


what Defendant recalls telling Plaintiff Brown at the Duzan hearing conducted on
Friday, 22 July 2016.

ANSWER:

INTERROGATORY NO. 5: State why there was no particularized


finding on the Record per Rule GR 16 relative to the Courts denial of video access
at the Duzan hearing conducted on Friday, 22 July 2016.
ANSWER:

INTERROGATORY NO. 6: State why Plaintiff Duzan received a Record


Reprimand for Ex Parte Communications relative to her attempts to secure video
coverage of the proceedings in her case.
ANSWER:

INTERROGATORY NO. 7: State whether Defendant has been subject


to any professional ethics complaints in the past fifteen (15) years relating to his
law practice or his Judicial conduct, and if so identify each complaint by Case
Number and indicate the outcome(s).
ANSWER:

32
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 Novembr 2016.

Plaintiff

Name:
Address:

Respectfully submitted,

___________________________________________
Christopher King, J.D.

___________________________________________
Wally Brown

___________________________________________
Chris Nubbe

33
IN THE KING COUNTY SUPERIOR COURT
SEATTLE, WASHINGTON

CHRISTOPHER KING, J.D. )


A/K/A KINGCAST/MORTGAGE MOVIES

WALLY BROWN ) CASE No._____________________

CHRIS NUBBE )

Plaintiffs,

v. )

HON. STAN J. RUMBAUGH


IN HIS INDIVIDUAL AND OFFICIAL CAPACITIES )

Defendant )

PLAINTIFFS FIRST REQUEST 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.

DEMAND FOR PRODUCTION OF DOCUMENTS

1. Provide a copy of any and all correspondence received from Brenda J. Duzan
or any named Plaintiff relative to video coverage of the underlying case
identified as 14-2-12022-8, Federal National Mortgage Association (FNMA) v.
Brenda J. Duzan.

2. Provide a copy of any and all responses issued by Defendant to any and all
correspondence identified in Document Request #1, supra.

3. Provide any documentation showing, or tending to show, that Defendant had


a reasonable fear or concern that that any Plaintiff might, by their
appearance or conduct, distract participants in the proceedings or otherwise
adversely affect the dignity and fairness of the proceedings relative to the
Duzan hearing conducted on Friday, 22 July 2016.

34
4. Provide any documentation showing, or tending to show, that Defendant
made Particularized findings on the Record per Rule GR 16 that would
explain why any or all Plaintiffs were denied video access to the Duzan
hearing conducted on Friday, 22 July 2016.

5. Provide any and all documents that explain, or tend to explain, they Plaintiff
Duzan received a Record Reprimand for Ex Parte Communications relative
to her attempts to secure video coverage of the proceedings in her case.

6. Provide a certified copy of his current Oath of Office, in conformity with


lawful requirements as codified in RCW 2.08.080 or any other
applicable code section.

7. Provide a certified copy of his official bond, in conformity with session


law requirements codified as Chapter 42.08 RCWOFFICIAL BONDS;
and Chapter 36.16 RCW--COUNTY OFFICERS GENERAL (as
applicable).

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 November, 2016.

Plaintiff

Name:
Address:

Respectfully submitted,

___________________________________________
Christopher King, J.D.

___________________________________________
Wally Brown

___________________________________________

35
Chris Nubbe

36
IN THE KING COUNTY SUPERIOR COURT
SEATTLE, WASHINGTON

CHRISTOPHER KING, J.D. )


A/K/A KINGCAST/MORTGAGE MOVIES

WALLY BROWN ) CASE No._____________________

CHRIS NUBBE )

Plaintiffs,

v. )

HON. STAN J. RUMBAUGH


IN HIS INDIVIDUAL AND OFFICIAL CAPACITIES )

Defendant )

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.

37
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.

REQUEST FOR ADMISSIONS

1. Admit that Plaintiff King has not been granted video access to any Duzan
hearing as of 15 August, 2016.

2. Admit that the Defendant has reviewed the Notice of Media Coverage filed by
Plaintiff King on or about 4 August, 2016 (Appendix A).

3. Admit that Defendant received and reviewed a Notice of Media Coverage filed
by Plaintiff Brown prior to 22 July 2015 (Appendix B).

4. Admit that Defendant does not have had a reasonable fear or concern that
that any Plaintiff might, by their appearance or conduct, distract participants
in the proceedings or otherwise adversely affect the dignity and fairness of
the proceedings relative to the Duzan hearing conducted on Friday, 22 July
2016.

5. Admit that Defendant does not have had a reasonable fear or concern that
that any Plaintiff might, by their appearance or conduct, distract participants
in the proceedings or otherwise adversely affect the dignity and fairness of
the proceedings relative to the Duzan hearing conducted on Friday, 22 July
2016.

38
6. Admit that Defendant did not make Particularized findings on the Record
per Rule GR 16 that would explain why any or all Plaintiffs were denied video
access to the Duzan hearing conducted on Friday, 22 July 2016.

7. Admit that Plaintiff Duzan received a Record Reprimand for Ex Parte


Communications relative to her attempts to secure video coverage of the
proceedings in her case.

39
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 November, 2016.

Plaintiff

Name:
Address:

Respectfully submitted,

______________________
Christopher King, J.D.

___________________________________________
Wally Brown

___________________________________________
Chris Nubbe

40