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. )

PLAINTIFF’S MOTION FOR RULE 11 SANCTIONS
I. Introduction:
“What’s with the camera?”
“I’m news media.”
“Remove the camera from the courtroom….. RIGHT NOW.”
https://m.youtube.com/watch?v=ZcE0ZiO-deM

This is all the Court needs to know in order to know that Defendant Stanley J.
Rumbaugh hates cameras in his Courtroom and will violate GR 16 protecting
open access to media with glee.1 But we have presented more… much much
more than that, and in their purported defense of all things contrary to the
First Amendment and General Rule 16 Defendant Rumbaugh’s attorneys have
crossed a legal and ethical line
Now come Plaintiffs pursuant to FRCP 1 201 to note that Defendant Rumbaugh
and his Counsel have steadfastly argued in their most recent filing in
opposition to Plaintiff’s First Amended Complaint that Plaintiff King only
attempted to run video on 24 February 2017 to cure a lack of Standing. Said
1 (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 record at the time of announcing the
limitations. This may be done either orally or in a written order.
Defendant Rumbaugh has never followed this procedure in spite of the
fact that Plaintiffs had notified him prior to hearings.

Page 1 of 75
purported lack of standing purportedly dates back to his Amended Notice of
Media Coverage filed on or about 4 August, 2016.

2.Judicial Notice and Lie #1.

The problem with this game is that Defendant Rumbaugh conducted at
least one more hearing from the time that Plaintiff filed his 4 August 2016
Notice of Media Coverage as noted in the thumbnail below. A hearing was
conducted on 6 January 20172 and naturally the Court never granted Plaintiff
King access, in spite of the fact that his Amended Notice of Media Coverage
contained the header:
“Hearing Date: 22 July 2016 & prospective”

2 Moreover, Ms. Duzan informs Plaintiff in an email of 1 April, 2017, no joking: “Looks
like a court review hearing on 10/21/16, my motion to dismiss on 1/6/17 combined with
a court review, my motion for reconsideration on 2/24/17.” So there may have been
SEVERAL hearings conducted by the Court after Plaintiff King filed his Notice of Media
Coverage but the Court never granted access for any of them, then again ignored King
on 24 February 2017 in yet another case in which King has legitimate questions as to
how Judge Rumbaugh is dispensing Justice in his Courtroom.

Page 2 of 75
As such, Plaintiffs bring to the Court the fact that there was at least one
other scheduled hearing before Defendant Rumbaugh (in addition to the
hearing of 24 February 2017) in which he AGAIN refused to follow the dictates
for GR 16. And of course GR 16 directly references the “News Media” and that
in turn directly implicates the Federal and State Constitutions relative thereto.
But Defendant and his lawyers commit a Fraud Upon the Court because
they write:

After King interrupted that separate February 24, 2017, hearing in Judge
Rumbaugh's courtroom without previously filing or noting a motion –
much less filing ahead of time even what he labels a "notice of media
coverage"1

So we see that to be a lie because Notice of Media Coverage

clearly stated it was prospective in nature relative to Duzan in the

first place, and further there is the fact that Plaintiff King filed his

Notice of Media Coverage prior to Court and had courtesy copies with

him for Defendant Rumbaugh and all Counsel who might be present.

That is all that could conceivably be required by Rule 16. When we

advance toward discovery we will see what the Court requires of

mainstream press but having worked for mainstream press Plaintiff

Page 3 of 75
King is fairly certain of his position in this case. And his Notice of

Media coverage expressly notes:

“KingCast – Mortgage Movies employs Mr. King’s 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.”

So then, it is clear that Plaintiff King has Standing in this case and
Defendant and his attorneys are both engaged in lying to this Court and trying
to cover up continued violations of GR 16. Such unrestrained and continued
disrespect for the integrity of Pleading must have consequences. See e.g. FRCP
11(b)(1); FRCP 12(f). Plaintiff hereby issues this Rule 11 Motion after a Safe
Harbor warning in addition to his Notice of Fraud Upon the Court filed in the
early morning hours of 3 April, 2017.
This is pretty simple unless Defendant and his Counsel are busy lying
and hiding material facts in order to to cover up the Truth: Ordinarily when
Plaintiff King files a Notice of Media Coverage on the same morning of the
event the Courts notify him that he is fine to record as long as the Judge then
agrees, and they have always agreed in Washington in approximately 100
opportunities. If the scheduled event is to occur in the future, then the Courts
simply notify Plaintiff King of the scheduled event and allow him to be heard
and to present, and this is precisely why Plaintiff King has not had to sue any
other judge in Washington State. Simple.
In sum, Defendant and his Counsel knew about the next scheduled
hearings but lied by omission to this Honorable Court, and this Honorable
Court will not stand for it and should no doubt issue sanctions sua sponte for
this sort of shenanigans.

Page 4 of 75
3.Judicial Notice and Lie #2.

In addition to the Judicial Notice of the scheduled hearing that Defendant and
his lawyers are trying to hide by omission there is also the fact that they try to
claim that Plaintiff did not notify them of his media purpose in an email. The
email is contained at Appendix A.

From Defendant’s Reply to Plaintiff King’s First Amended Complaint:

King's emails prior to the hearing made no claim he wanted to make a
recording as "news media" but only that he had "run courtoom video
throughout the County" as a business and was "request[ing] access as
well" because "you have denied by colleague Wally Brown camera
access …." Dkt. 1-2 at 2-4, 11-18.

Not so fast. There is a thing called the Rule of Completeness folks:
That email also contained two direct links to other First Amendment activity,
including the following colloquy before King County Superior Judge Monica
Benton:

I'm going to get to the specifics and substance of the case soon, and it
involves a purportedly lost Note with a date uncertain for when an
indorsement was issued on it, but for now you need to know that my
First Amendment Rights as a Citizen, as a Journalist, and as a Citizen
Journalist were somewhat imperiled today when I was called back into
Honorable Monica Benton's Judicial Chambers where the following
colloquy ensued:

"What are your credentials?"

"Well Your Honor I was a reporter for a large daily newspaper, and editor
of a statewide daily before law school.... and I've been shooting these
movies in courtrooms throughout the Country for 4 or 5 years now, and
I've been covering this case already...." (I neglected to tell her I was an
escrow attorney who worked for WAMU but that is noted in my Notice of
Media Coverage, as is the fact that Joseph McIntosh and his buddies
unlawfully threatened to have me arrested as seen in this video, Judges
Will Watch as Foreclosure Mill Attorneys Threaten Depo Videographer
with Security and Arrest).

"Well I haven't seen you with a camera in this case."

"Well Your Honor Judge Schubert has (one and two) and we and are on
great terms. He respects what I do and he said as much, I have that on
video I recorded on prior occasion."
Page 5 of 75
"I have some concerns about whether you are media."

"Well Your Honor even if my prior experience and background weren't
enough as a journalist, I am still authorized as a public citizen to video
these proceedings."

"Where is your website?"

"It's right there Your Honor," as I handed her my card. "

“You might audio but I'm not certain that entitles you to run video
(Googling Pooley+Mortgage Movies after I had told her to Google
Mortgage Movies) I'm at your website now and I see you have the
hear/see/speak no evil monkeys and skeletons...."

"Well I believe it does, and if this Court cannot take any step that would
infringe on my right to portray what I see as I see it, because that would
be inimical to the First Amendment."

"We'll see about that. Have a seat in the Courtroom."
3
Upon which First Amendment access as a reporter was GRANTED.

Yet there is more: There was another email the following day clearly requesting a respo
*************
Christopher King kingcast955@icloud.com
7/21/16
to mreagan, duzabalm, fortune2000, cpeterson, me, Steve, Michelle, Scott

To All:

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

Thank you.

3 Not only that, of course the Notice of Media Coverage itself reads: “KingCast –
Mortgage Movies employs Mr. King’s 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.” Plaintiffs are not exactly sure how much more clear it can be….. unless of
course you are dishonest and trying to run from the cameras, and whether or not such
argument is ad hominem or not if the shoe fits then Defendant wears it. Such is not
our fault or shame, but is rather the shame of Defendant and his lawyers, who have
now poisoned this Court with their lies and deceit, caught red-handed. Appendix B.

Page 6 of 75
CHRISTOPHER KING, J.D.

kingcast955@icloud.com

mortgagemovies007@gmail.com

http://affordablevideodepo.com

http://mortgagemovies.blogspot.com

617.543.8085m

206.299.9333f

But of course Counsel for Defendant fraudulently withheld that crucial
information as directly provided to them, and misleads the Court in
violation of Rule 3.3 Candor to the Tribunal because Plaintiff King’s
email clearly referenced news coverage consistent with the mandates
of GR 16.

4.A Recent and Current Climate of Deceit.

Reporter Sean Robsinon (News Tribune) has succinctly pieced together a
relevant timeline of legal woes involving deceit and other abuses out of the
Pierce County Office. We already know from prior Plaintiff filings that they have
the highest reversal rate in the State for ill-gotten convictions:

http://www.seattletimes.com/seattle-news/crime/many-pierce-county-cases-
reversed-because-of-prosecutors/
An Associated Press review of all Washington cases that were reversed
on appeal since 2012 because of prosecutor misconduct found that 17
of the 30 cases were in Pierce County.
…………but now lets look directly at false filings and withheld evidence in a
Civil Context in the media and via a PACER inquiry:
http://www.thenewstribune.com/news/local/crime/article29751268.html
AUGUST 1, 2015
Pierce County Prosecutor Mark Lindquist’s timeline of legal issues
In Dalsing v. Linquist et al 3:15-cv-05520-BHS they withheld evidence in a
criminal case, just as they are doing in this Civil case:

Page 7 of 75
After losing a series of rulings in Lynn Dalsing’s subsequent false-arrest
lawsuit, prosecutors filed new charges of child rape against her in 2014.
They accused her of knowing about her husband’s actions and aiding
them.
Those were the charges dismissed earlier this year due to prosecutorial
vindictiveness. Superior Court Judge Edmund Murphy found that
prosecutors wrongly claimed that new information justified new charges.
Murphy found that prosecutors were aware of the supposed new
information when the original charges were filed and did not act on it.
Dalsing’s attorney, Fred Diamondstone, said he filed the federal lawsuit
to address actions taken by prosecutors over the last two years that
weren’t part of the original lawsuit.
“Our criminal justice system cannot function properly when government
officials deceive the courts,” he said…….

…….[Dalsing] is also the linchpin of a state bar association
complaint that accuses Lindquist and other high-ranking deputies of
violating rules of professional conduct in their pursuit of a legal win. 4

See more at:

http://www.thenewstribune.com/news/local/crime/article29109742.html
Federal lawsuit accuses Pierce Prosecutor Lindquist and staffer of deceiving
courts

Please note that this corruption comes from the top down and is current:
http://www.thenewstribune.com/news/local/crime/article26299513.html
JUNE 12, 2015
New bar complaint accuses Lindquist of trying to influence judge

A new complaint against Pierce County Prosecutor Mark Lindquist
accuses him of trying to improperly influence a judge, calls for a federal
criminal investigation of his office and declares that Lindquist is “unfit to
practice law.”

http://www.thenewstribune.com/news/politics-
government/article137860268.html
MARCH 11, 2017
Lindquist text message case: Still going, defense bills exceed $584,000

Pierce County Prosecutor Mark Lindquist’s text messages are back in
court again, and taxpayers are still underwriting efforts to prevent their
disclosure.

4 Precisely: Lie to win, at all costs. That is clearly the modus operandi. Plaintiffs are not
having any of it.
Page 8 of 75
According to the latest figures from the county’s risk management
division, the public bill for the long-running legal tussle stands at
$584,989 and climbing, with the next stage of court action set for April 7
in Thurston County.
Coupled with other legal bills tied to complaints of misconduct by
Lindquist and his subordinates, the collective costs rise to $1.92 million,
with no near-term prospects for resolution.

Page 9 of 75
5.Summation and Allegedly Ad Hominem Remarks.
At one point Plaintiffs stated that Defendant Rumbaugh is only running
off to Court to avoid being caught on video, and that he lacks courage as a real
Jurist to face the thorny First Amendment implications of his misconduct.
Frankly, so what? That is part of Plaintiff’s theory of the case, and no
sanction may lie within that framework. But yet and still, Counsel for
Defendant had the nerve to insinuate to this Court that Plaintiff’s writing was
sanctionable.
No. What is sanctionable are the lies set forth in this Motion. As further
indication of the fraudulent nature of this “defense” let us review Defendant's
notion that Plaintiff King's most recent Notice of Media Coverage in which
Judge Rumbaugh unlawfully denied media access is somehow "Contrived:"
Plaintiff submits that the Defendant's Court is not in a position to sit in
judgment of the subject matter of media's production. Similarly nor is this
Court. Bloggers are journalists, pure and simple, and this is particularly true
given Plaintiff King’s empirical knowledge of the subject matter as a residential
closing attorney who continues to work in the field on second mortgage
consultation! Plaintiff’s don’t need any specific reason to be involved in media
in order to please Judge Rumbaugh. See generally Obsidian Finance v. Crystal
Cox (9th Cir 12-35238 Dist. Ct. No. 3:11 CV 00057) Further, in the Bozgoz
case, Plaintiff King as a former Civil Rights litigator and trial attorney most
definitely has an interest in the underlying personal injury subject matter, as
the law and facts of that case are extremely compelling in the mind of any
reasonable journalist:
A grandmother flipped upside down out of her wheelchair by a reckless
County paratransit driver, then abandoned by the driver with a broken
neck..... then the legal wrangling that followed is particularly
fascinating. Just because a major network has not covered this matter
does not mean that Defendant may ignore Rule 16, which he clearly
ignored when it comes to Plaintiffs in this case:

Further, any Notion that a newspaper, television station or other media
must actually file a Notice of Media Coverage and wait for a formal hearing to
be scheduled before coverage ensues is the most ridiculous argument Plaintiffs

Page 10 of 75
have ever heard in their lives and it simply may not be interposed as a defense
in this case.
Plaintiffs King and Brown stand in precisely the same shoes as KOMO or
KING5 and when Discovery hits and we see the disparate treatment all of this
case will be going to Jury, in the King County Superior Court where Jurisdiction
actually exists.
And any insinuation that Plaintiffs are being subjected to a regular
matter of practice in that Courthouse also constitutes a lack of candor toward
the Tribunal, in violation of Rule 3.3 and more and a Complaint is being filed
with the State Bar Association as well. This office has long been involved in
ethically questionable activity and this case is no different.
WHEREFORE PLAINTIFFS DEMAND:

1. Defendant retract each and every argument postulated that asserts that
Plaintiff King lacked Standing to sue relative to the Duzan case, and;

2. Defendant retract each and every statement that “King's emails prior to
the hearing made no claim he wanted to make a recording as "news
media" but only that he had "run courtoom video throughout the
County" as a business and was "request[ing] access as well" because
"you have denied by colleague Wally Brown camera access …." Dkt. 1-2
at 2-4, 11-18.”

3. Costs to carry the Event and any and all such other Relief as the Court
deems appropriate.

Plaintiffs remain dedicated to TRANSPARENCY IN GOVERNMENT.

Respectfully submitted,

___________________________________________
Christopher King, J.D.

___________________________________________
Wally Brown

___________________________________________
Chris Nubbe

Page 11 of 75
APPENDIX A

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

http://affordablevideodepo.com

http://mortgagemovies.blogspot.com

617.543.8085m

206.299.9333f

Page 12 of 75
APPENDIX B
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

the 1990’s, 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 13 of 75
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. King’s 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 Honor’s 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

Page 14 of 75
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

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:
Page 15 of 75
There was nothing unclear about the Court’s 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 Court’s Rules will
be taken up at the time of hearing on Friday, July 22 nd.

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: 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.

Page 16 of 75
(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.

I specifically note that even if this matter is not addressed for any reason by tomorrow’s

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 17 of 75
Page 18 of 75
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 98155

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

Page 19 of 75
CERTIFICATE OF SERVICE

We, the undersigned, solemnly swear that a true and accurate copy of the
foregoing Notice was sent via email and tracked U.S. Mail on 3 April 2017 to
the following:

Daniel R. Hamilton, Esq.
955 Tacoma Avenue South
Suite 301
Tacoma WA 98402
dhamilt@co.pierce.wa.us

Stepen D. Trinen, Esq.
955 Tacoma Avenue South
Suite 301
Tacoma WA 98402
strinen@co.pierce.wa.us

___________________________________________
Christopher King, J.D.

___________________________________________
Wally Brown

___________________________________________
Chris Nubbe

Page 20 of 75
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. )

PLAINTIFF’S REQUEST FOR JUDICIAL NOTICE
AND NOTICE OF FRAUDULENT DEFENSE
I. Introduction. Now come Plaintiffs pursuant to FRCP 201 to note that
Defendant Rumbaugh and his Counsel have steadfastly argued in their most
recent filing in opposition to Plaintiff’s First Amended Complaint that Plaintiff
King only attempted to run video on 24 February 2017 to cure a lack of
Standing. Said purported lack of standing purportedly dates back to his
Amended Notice of Media Coverage filed on or about 4 August, 2016.

2. Judicial Notice and Lie #1.
The problem with this game is that Defendant Rumbaugh conducted at
least one more hearing from the time that Plaintiff filed his 4 August 2016
Notice of Media Coverage as noted in the thumbnail below. A hearing was
conducted on 6 January 20175 and naturally the Court never granted Plaintiff

5 Moreover, Ms. Duzan informs Plaintiff in an email of 1 April, 2017, no joking: “Looks
like a court review hearing on 10/21/16, my motion to dismiss on 1/6/17 combined with
a court review, my motion for reconsideration on 2/24/17.” So there may have been
SEVERAL hearings conducted by the Court after Plaintiff King filed his Notice of Media
Coverage but the Court never granted access for any of them, then again ignored King
on 24 February 2017 in yet another case in which King has legitimate questions as to
how Judge Rumbaugh is dispensing Justice in his Courtroom.

Page 21 of 75
King access, in spite of the fact that his Amended Notice of Media Coverage
contained the header:
“Hearing Date: 22 July 2016 & prospective”

As such, Plaintiffs bring to the Court the fact that there was at least one
other scheduled hearing before Defendant Rumbaugh (in addition to the
hearing of 24 February 2017) in which he AGAIN refused to follow the dictates
for GR 16. And of course GR 16 directly references the “News Media” and that
in turn directly implicates the Federal and State Constitutions relative thereto.
But Defendant and his lawyers commit a Fraud Upon the Court because
they write:

After King interrupted that separate February 24, 2017, hearing in Judge
Rumbaugh's courtroom without previously filing or noting a motion –
much less filing ahead of time even what he labels a "notice of media
coverage"1

So we see that to be a lie because Notice of Media Coverage

clearly stated it was prospective in nature relative to Duzan in the

first place, and that:

“KingCast – Mortgage Movies employs Mr. King’s 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.”

Page 22 of 75
So then, it is clear that Plaintiff King has Standing in this case and
Defendant and his attorneys are both engaged in lying to this Court and trying
to cover up continued violations of GR 16. Such unrestrained and continued
disrespect for the integrity of Pleading must have consequences. See e.g. FRCP
11(b)(1); FRCP 12(f). Plaintiff will be issuing a Rule 11 Fair Harbor letter this
week in addition to this Notice of Fraud Upon the Court.

This is pretty simple unless you are lying to cover up the Truth:
Ordinarily when Plaintiff King files a Notice of Media Coverage on the same
morning of the event the Courts notify him that he is fine to record as long as
the Judge then agrees, and they have always agreed in Washington in
approximately 100 opportunities. If the scheduled event is to occur in the
future, then the Courts simply notify Plaintiff King of the scheduled event and
allow him to be heard and to present, and this is precisely why Plaintiff King
has not had to sue any other judge in Washington State. Simple.
In sum, Defendant and his Counsel knew about the next scheduled
hearing but lied by omission to this Honorable Court, and this Honorable Court
will not stand for it and wil no doubt issue sanctions sua sponte for this sort of
shenanigans. Meanwhile Plaintiffs are drafting a Rule 11 Motion relative to
each and every argument Defendant and Counsel have made alleging that
Plaintiff King did not have Standing to sue, because it is all based on a lie by
omission. The Devil is in the Details folks, and there is plenty of Devil in this
room.

3.Judicial Notice and Lie #2.

In addition to the Judicial Notice of the scheduled hearing that Defendant and
his lawyers are trying to hide by omission there is also the fact that they try to
claim that Plaintiff did not notify them of his media purpose in an email. The
email is contained at Appendix A.

From Defendant’s Reply to Plaintiff King’s First Amended Complaint:

King's emails prior to the hearing made no claim he wanted to make a
recording as "news media" but only that he had "run courtoom video
throughout the County" as a business and was "request[ing] access as
well" because "you have denied by colleague Wally Brown camera
access …." Dkt. 1-2 at 2-4, 11-18.
Page 23 of 75
Not so fast. There is a thing called the Rule of Completeness folks: That email
also contained two direct links to other First Amendment activity, including the
following colloquy before Judge Monica Benton.

I'm going to get to the specifics and substance of the case soon, and it
involves a purportedly lost Note with a date uncertain for when an
indorsement was issued on it, but for now you need to know that my
First Amendment Rights as a Citizen, as a Journalist, and as a Citizen
Journalist were somewhat imperiled today when I was called back into
Honorable Monica Benton's Judicial Chambers where the following
colloquy ensued:

"What are your credentials?"

"Well Your Honor I was a reporter for a large daily newspaper, and editor
of a statewide daily before law school.... and I've been shooting these
movies in courtrooms throughout the Country for 4 or 5 years now, and
I've been covering this case already...." (I neglected to tell her I was an
escrow attorney who worked for WAMU but that is noted in my Notice of
Media Coverage, as is the fact that Joseph McIntosh and his buddies
unlawfully threatened to have me arrested as seen in this video, Judges
Will Watch as Foreclosure Mill Attorneys Threaten Depo Videographer
with Security and Arrest).

"Well I haven't seen you with a camera in this case."

"Well Your Honor Judge Schubert has (one and two) and we and are on
great terms. He respects what I do and he said as much, I have that on
video I recorded on prior occasion."

"I have some concerns about whether you are media."

"Well Your Honor even if my prior experience and background weren't
enough as a journalist, I am still authorized as a public citizen to video
these proceedings."

"Where is your website?"

"It's right there Your Honor," as I handed her my card. "

“You might audio but I'm not certain that entitles you to run video
(Googling Pooley+Mortgage Movies after I had told her to Google
Mortgage Movies) I'm at your website now and I see you have the
hear/see/speak no evil monkeys and skeletons...."

Page 24 of 75
"Well I believe it does, and if this Court cannot take any step that would
infringe on my right to portray what I see as I see it, because that would
be inimical to the First Amendment."

"We'll see about that. Have a seat in the Courtroom."
6
Upon which First Amendment access as a reporter was GRANTED.

But of course Counsel for Defendant fraudulently withholds that
crucial information as provided to them, and misleads the Court in
violation of Rule 3.3 Candor to the Tribunal because Plaintiff King’s
email clearly referenced news coverage consistent with the mandates
of GR 16.
4.Summation.

As further indication of the fraudulent nature of this “defense” let us
review Defendant's notion that Plaintiff King's most recent Notice of Media
Coverage in which Judge Rumbaugh unlawfully denied media access is
somehow "Contrived:"
Plaintiff submits that the Defendant's Court is not in a position to sit in
judgment of the subject matter of media's production. Similarly nor is this
Court. Plaintiff King must definitely has an interest in the underlying personal
injury subject matter, as the law and facts of that case are extremely
compelling in the mind of any reasonable journalist:

A grandmother flipped upside down out of her wheelchair by a reckless
County paratransit driver, then abandoned by the driver with a broken
neck..... then the legal wrangling that followed is particularly
fascinating. Just because a major network has not covered this matter
does not mean that Defendant may ignore Rule 16, which he clearly
ignored when it comes to Plaintiffs in this case:

Further, any Notion that a newspaper, television station or other media
must actually file a Notice of Media Coverage and wait for a formal hearing to

6 Not only that, of course the Notice of Media Coverage itself reads: “KingCast –
Mortgage Movies employs Mr. King’s 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.” Plaintiffs are not exactly sure how much more clear it can be….. unless of
course you are dishonest and trying to run from the cameras, and whether or not such
argument is ad hominem or not if the shoe fits then Defendant wears it. Such is not
our fault or shame, but is rather the shame of Defendant and his lawyers, who have
now poisoned this Court with their lies and deceit, caught red-handed. Appendix B.

Page 25 of 75
be scheduled before coverage ensues is the most ridiculous argument Plaintiffs
have ever heard in their lives and it simply may not be interposed as a defense
in this case. Plaintiff King stands in precisely the same shoes as KOMO or
KING5 and when Discovery hits and we see the disparate treatment all of this
case will be going to Jury, in the King County Superior Court where Jurisdiction
actually exists.
And any insinuation that Plaintiff are being subjected to a regular matter
of practice in that Courthouse also constitutes a lack of candor toward the
Tribunal, in violation of Rule 3.3 and more. This office has long been involved in
ethically questionable activity and this case is no different.

Plaintiffs remain dedicated to TRANSPARENCY IN GOVERNMENT.

Respectfully submitted,

___________________________________________
Christopher King, J.D.

___________________________________________
Wally Brown

___________________________________________
Chris Nubbe

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
Page 26 of 75
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

the 1990’s, 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 27 of 75
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. King’s 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 Honor’s 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

Page 28 of 75
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

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:
Page 29 of 75
There was nothing unclear about the Court’s 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 Court’s Rules will
be taken up at the time of hearing on Friday, July 22 nd.

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: 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.

Page 30 of 75
(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.

I specifically note that even if this matter is not addressed for any reason by tomorrow’s

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 31 of 75
Page 32 of 75
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 98155

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

Page 33 of 75
CERTIFICATE OF SERVICE

We, the undersigned, solemnly swear that a true and accurate copy of the
foregoing Notice was sent via email and tracked U.S. Mail on 3 April 2017 to
the following:

Daniel R. Hamilton, Esq.
955 Tacoma Avenue South
Suite 301
Tacoma WA 98402
dhamilt@co.pierce.wa.us

Stepen D. Trinen, Esq.
955 Tacoma Avenue South
Suite 301
Tacoma WA 98402
strinen@co.pierce.wa.us

___________________________________________
Christopher King, J.D.

___________________________________________
Wally Brown

___________________________________________
Chris Nubbe

34
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. )

NOTICE OF INTENT TO FILE FIRST AMENDED COMPLAINT

Now come Plaintiffs pursuant to Rule 15 to note that Plaintiff King shall

be appearing as a journalist before Defendant Rumbaugh on 24 February

2017 relative to a case in which a family endured substantial pain and

hardship following catastrophic injury to their loved one. There have been

multiple attempts to limit recovery in that case and things appear suspicious

to this Reporter.

As such, Plaintiff attaches his Notice of Media Coverage relative

thereto, noting that he anticipates an Amendment to the pending Complaint

regardless of the outcome of this coming Friday’s engagement.

Plaintiff wrote:

WHEREFORE in this instance I provide this Notice to his honor via fax transmittal,
email transmittal and Priority U.S. Mail on this 21st day of February, several days prior to
hearing. I anticipate an email and phone call GRANTING this Notice by the close of
business, Thursday 21 February 2017. Otherwise here is what is going to happen: I am
going to appear in Court and the Court is going to follow the LAW as contemplated by
the United States and Washington Constitutions as well as Washington State GR 16
which reads --- again – as follows:……

35
Plaintiffs anticipate an Amended Complaint within the following

fourteen (14) calendar days but it may be sooner depending on the ongoing

litigation regarding Plaintiff King’s dog Livi, who was basically murdered at a

negligent and reckless boarding facility on 29 December 2016.

Plaintiffs as always remain dedicated to TRANSPARENCY IN
GOVERNMENT.

Respectfully submitted,

___________________________________________
Christopher King, J.D.

___________________________________________
Wally Brown

___________________________________________
Chris Nubbe

CERTIFICATE OF SERVICE

We, the undersigned, solemnly swear that a true and accurate copy of the
foregoing Notice was sent via email and tracked U.S. Mail on 21 February
2017 to the following:

Daniel R. Hamilton, Esq.
955 Tacoma Avenue South
Suite 301
Tacoma WA 98402
dhamilt@co.pierce.wa.us

Stepen D. Trinen, Esq.
955 Tacoma Avenue South
Suite 301
Tacoma WA 98402
strinen@co.pierce.wa.us

___________________________________________
Christopher King, J.D.

___________________________________________
Wally Brown

___________________________________________

36
Chris Nubbe

KingCast.net – Mortgage Movies
By: Christopher King, J.D.
17006 11th Avenue NE
Seattle, WA 98155 Hearing Date: 24 Feb. 2017 &
617.543.8085
prospective

SUPERIOR COURT OF THE STATE OF WASHINGTON
IN AND FOR THE COUNTY OF PIERCE

MARGARET BOZGOZ,
Case Number: 16-2-121303-7
Plaintiffs,

v.
NOTICE OF MEDIA COVERAGE
YOUSEFF

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 scheduled for hearing at or

about 9:00 a.m. Friday, 24 February 2017 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 the 1990’s, 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.

37
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. King’s 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 a prior case currently in litigation and improvidently Removed to Federal Court (2:17-

CV-0031) all Plaintiffs harbored grave concerns that there is a pending First Amendment

violation that we are 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 Honor’s 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

38
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

*********

Be that as it may in that case counsel for Defendant Rumbaugh gathered up a million

invalid reasons for completely violating the law, including but not limited to the false claim that I

had not notified the court in a timely manner of my request to appear as media.

WHEREFORE in this instance I provide this Notice to his honor via fax transmittal,

email transmittal and Priority U.S. Mail on this 21 st day of February, several days prior to hearing.

I anticipate an email and phone call GRANTING this Notice by the close of business, Thursday

21 February 2017. Otherwise here is what is going to happen: I am going to appear in Court and

the Court is going to follow the LAW as contemplated by the United States and Washington

Constitutions as well as Washington State GR 16 which reads --- again – as follows:

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

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
(2) that permission shall have first been expressly granted by the judge; and

39
(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.

WHEREFORE, I respectfully request permission to video the pendency of this case as I

have done in countless courtrooms in Washington State and throughout the United States for the

past seven (7) years without censure. 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

40
41
CERTIFICATE OF SERVICE

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

USPS Tracked Priority Mail on 21 February 2017 to the following:

Lesley J. Fleming, Esq.
One N. Tacoma Ave
Suite 200
Tacoma WA 98403

Roy A. Umlauf, Esq.
901 5th Avenue
Suite 1400
Seattle, WA 98164

___________________________________________
Christopher King, J.D.

___________________________________________
Wally Brown

___________________________________________
Chris Nubbe

/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

42
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. )

PLAINTIFFS’ REPLY MEMORANDUM
IN SUPPORT OF REMAND
Defendant spends several pages attempting to distinguish the
indistinguishable:
KingCast v. Wright, Finlay & Zack is directly on point.7 After prompt
Removal of the sole Federal Claim there remains only parallel State
Constitutional claims involving unlawful prior restraint or related First
Amendment-types of issues. In point of fact, there is no Federal Counterpart
to GR 16 anyway so there’s not much point to the Court trying to evaluate
precisely what this uniquely-crafted State Statute is meant to address.
The Defendant, by and through Counsel continues to mislead the Court
just as they claimed that Plaintiff Brown had not properly sought Leave of
Court to video prior to the day date and time Defendant Rumbaugh rudely
threw him out. This time they claim that KingCast v. Wright, Finlay is but one
case when of course it is the latest and most recent case in this exact
jurisdiction, citing many other relevant cases. The Attorneys’ attempt to
denigrate the highly-esteemed Judge James Robart must not be well-taken,
particularly as His Honor preserves the integrity of our United States Justice
system in State of Washington v. Trump et al. 2:17-cv-00141-JLR. Certainly

7 The Defendants are free to make those same 12(b)(6) arguments in State Court.
Either way they are going to make them so there is simply no compelling reason to
retain Jurisdiction. See also Plaintiff’s Declaration that explains why the written
request to dismiss the Federal Claim went unanswered.

43
Plaintiffs believe that His Honor has a great knowledge and understanding of
the Law.

44
Lastly, as to the fact that there appears to be a letter written to Plaintiff
requesting dismissal of the sole Federal claim, Plaintiff’s Declaration noting
the 29 December 2016 mauling death of his Best Friend and Soulmate speaks
to that. As such, Plaintiff King as lead Plaintiff was pretty much incapacitated
mentally and emotionally, well beyond the realm of ordinary litigation as his
mental health Counselor and his Attorney Counselor will verify if necessary.
He is still going through mail received last month but an actual phone call
would have worked much better but alas, none was offered. One might
readily infer a bit of gamesmanship at play, again nothing new for that office
or that Defendant as noted in prior filings.

CONCLUSION AND PRAYER FOR RELIEF

The Defendant has engaged in a bit of invidious forum-shopping that
must gain no quarter within. The case must be hereby Remanded, it being
thematically and factually indistinguishable from the 2016 case of KingCast v.
Wright, Finlay & Zack that resulted in prompt Remand from a highly-
respected Jurist in this actual Jurisdiction.

Respectfully submitted,

___________________________________________
Christopher King, J.D.

___________________________________________
Wally Brown

___________________________________________
Chris Nubbe

45
CERTIFICATE OF SERVICE

We, the undersigned, solemnly swear that a true and accurate copy of the
foregoing Motion was sent via email and tracked U.S. Mail on 10 February
2017 to the following:

Daniel R. Hamilton, Esq.
955 Tacoma Avenue South
Suite 301
Tacoma WA 98402
dhamilt@co.pierce.wa.us

Stepen D. Trinen, Esq.
955 Tacoma Avenue South
Suite 301
Tacoma WA 98402
strinen@co.pierce.wa.us

___________________________________________
Christopher King, J.D.

___________________________________________
Wally Brown

___________________________________________
Chris Nubbe

46
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. )

PLAINTIFFS’ MOTION FOR LEAVE
TO FILE REPLY MEMORANDUM IN SUPPORT OF REMAND

Now come Plaintiffs, by and through lead Plaintiff King to move this
Honorable Court for Leave to file a brief Reply in Support of Remand, as
personal tragedy has been manifest, there is no untoward delay or prejudice
to Defendant and Justice compels the granting of the Request.

47
CERTIFICATE OF SERVICE

We, the undersigned, solemnly swear that a true and accurate copy of the
foregoing Declaration was sent via email and tracked U.S. Mail on 10
February 2017 to the following:

Daniel R. Hamilton, Esq.
955 Tacoma Avenue South
Suite 301
Tacoma WA 98402
dhamilt@co.pierce.wa.us

Stepen D. Trinen, Esq.
955 Tacoma Avenue South
Suite 301
Tacoma WA 98402
strinen@co.pierce.wa.us

___________________________________________
Christopher King, J.D.

___________________________________________
Wally Brown

___________________________________________
Chris Nubbe

48
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 JUDGE MARTINEZ

and
CHRIS NUBBE )
Plaintiffs,

v. )

HON. STAN J. RUMBAUGH
IN HIS INDIVIDUAL AND OFFICIAL CAPACITIES )

Defendant. )

ORDER GRANTING PLAINTIFFS’ MOTION FOR LEAVE TO FILE REPLY BRIEF
IN SUPPORT OF MOTION TO REMAND

This matter came before the Court pursuant to Plaintiffs’ Request for
Leave to file a brief Reply to Defendants’ Response to his Motion to
Remand.
Good Cause having been shown, the Court hereby GRANTS said
Motion. The Plaintiffs’ Reply Memorandum shall be filed and docketed.

IT IS SO ORDERED THIS ____ Day of February, 2016

___________________________________

JUDGERICARDO MARTINEZ

49
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. )

PLAINTIFFS’ DECLARATION
Plaintiffs apologize for missing the written request to dismiss the First
Amendment Claim. There is however a valid reason for this oversight:
On 29 December 2016 I was on the East Coast, headed to New York
when my Partner and I got the phone call that nobody wants to receive: Our
Best Friend and Soulmate Livi had been mauled and killed in a kennel where
dogs were allegedly watched “24/7” and “never unattended” according to
their zoning application.
That begat immediate litigation as the two of us secured Pacific
Northwest Attorney Adam Karp to represent us and the defensive owner
obtained a patently abusive Stalking TRO against me that was immediately
DISMISSED as soon as the Snohomish South District Court hear all arguments
on 7 February 2016. It turns out that while I have not once had a Court Order
against me for abusing the First Amendment, Kristina Robinson of Precious
Paws was on the receiving end of a TRO that was GRANTED just last year for
abusing the First Amendment against someone else. It seems that cameras
scare a lot of people.
In the meantime coincidence brought my Partner and me a new puppy
Peppers and we have been mourning and trying to rebuild a family where
Livi’s little brother was in desperate need of another big sister and the two of
us were in desperate need of a companion in similar stature to Livi. It was
and continues to be completely devastating.

50
As such, I pretty much incapacitated mentally and emotionally, well
beyond the realm of ordinary litigation as my mental health Counselor and
my Attorney Counselor will verify if necessary. I am still going through mail
received last month but an actual phone call would have worked much better
but also none was offered.

51
**********

FURTHER AFFIANT SAYETH NAUGHT

___________________________________________
Christopher King, J.D.

_________________________________________
NOTARY PUBLIC

MY COMMISSION EXPIRES___________________

CERTIFICATE OF SERVICE

We, the undersigned, solemnly swear that a true and accurate copy of the
foregoing Declaration was sent via email and tracked U.S. Mail on 10
February 2017 to the following:

Daniel R. Hamilton, Esq.
955 Tacoma Avenue South
Suite 301
Tacoma WA 98402
dhamilt@co.pierce.wa.us

Stepen D. Trinen, Esq.

52
955 Tacoma Avenue South
Suite 301
Tacoma WA 98402
strinen@co.pierce.wa.us

___________________________________________
Christopher King, J.D.

___________________________________________
Wally Brown

___________________________________________
Chris Nubbe

53
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. )

PLAINTIFFS’ MOTION FOR ENLARGMENT OF TIME
The Defendant has not only refused to conference with Plaintiff to
discuss Removal in a reasonable manner, he has now of course attempted to
run this case through the Federal Court so that he can completely avoid
showing more of his rancorous relationship with the press.
Plaintiffs assert that the Defendant’s Motion to Dismiss be heard in the
Court of original Jurisdiction in the time frame allotted by the State Court after
Remand is ORDERED in this case, as the case law submitted by Plaintiff is
clearly at once more temporal and more persuasive than that submitted by
the Defendant: KingCast v. Wright, Finlay & Zack just happened half a year
ago, stemming from the Courtroom immediately adjacent to His Honor!
Moreover, in the Motion to Dismiss Plaintiff has noticed a conspicuous
lie: Plaintiff Wally Brown clearly filed his GR 16 Rule prior to the time that
Defendant so rudely threw him out. At Complaint Para 17:

“Plaintiff Brown also submitted his Notice of Media Appearance, filing it
before the hearing, on July 21, 2016. See Appendix B, attached.”
It is not unusual for Pierce County Attorneys to manipulate, lie and
twist the Truth however. In fact, such conduct is de rigueur:

54
http://www.thenewstribune.com/news/local/crime/article26279821.html
That is because “Pierce County Prosecutors lead the State in cases
overturned because of their “flagrant” actions. There is a treasure trove of
information in that feature that tells a neutral observer all they need to know
about the lengths that a Pierce County Prosecutor will go to in an attempt to
try to win a case. It’s sad but true, and it informs this Court’s judgment of the
integrity of Defendant’s specious arguments.
Pulliam v. Allen 466 U.S. 522 (1984) provides for Injunctive relief and
Plaintiffs have sought same. See also Dalsing v. Ausserer, Lindquist et al. WD
3:15-CV-05520.
Moreover, Judge Rumbaugh does not enjoy absolute immunity in this
context either on the merits or with respect to prospective relief owed to Mr.
King should the Court of proper Jurisdiction determine that Mr. King does not
have a live case in controversy.8
This case is all about Defendant Rumbaugh’s abject failure to follow
Washington GR 16, which sets out a number of substantive and procedural
safeguards that must be addressed by a Judge before any Prior Restraint may
be contemplated by the Court. The Rule speaks in absolute:

 (b) The judge shall exercise reasonable discretion in         
prescribing conditions and limitations with which media         
personnel shall comply.
Obviously Statutory Construction reveals that the legislature would not intend
an absurd result, i.e. ORDER a Judge to do something then not allow for any

8 Recall that Plaintiff King filed an ongoing Notice for Media Coverage, requested a ruling and
never heard anything from Defendant so he has a ripe case. All of this is material that is
appropriately suited to Summary Judgment analysis anyway.

55
sort of Judicial relief in the abject failure of the Court to follow the Rule. All of
this will be addressed in further detail in the appropriate Court at the
appropriate time.
The analysis of the reach of GR 16 is naturally a STATE COURT
FUNCTION in the first place, and this Court really has no proper business
delving into it for the same reasons cited by this Honorable Court in KingCast
v. Wright, Finlay & Zack:

3. Fairness

When analyzing fairness in the context of a motion to remand,
courts have looked to whether "a surer-footed reading" of state law
would be available in state court, Gibbs, 383 U.S. at
726; Schneider, 938 F.2d at 996; whether "the plaintiff has engaged
in any manipulative tactics" in seeking remand, Carnegie-
Mellon, 484 U.S. at 357; see also Albingia Versicherungs A.G., 344
F.3d at 939; and where the plaintiff originally filed the
action, Fletcher v. Solomon, No. C-06-5492 RMW, 2006 WL
3290399, at *3-4 (N.D. Cal. Nov. 13, 2006) (remanding action to
state court after the plaintiffs voluntarily dismissed their only
federal claims, finding that the "plaintiffs clearly desire a state
forum, as they could have filed this action as an original matter in
federal court but chose not to do so"). "[T]he Ninth Circuit has found
nothing wrong with plaintiffs promptly dropping federal claims and
seeking to have a matter remanded." Fletcher, 2006 WL 3290399,
at *4 (citing Baddie v. Berkeley Farms, 64 F.3d 487, 490-91 (9th Cir.
1995)).

Like judicial economy and convenience, fairness arguably supports
remand and at least does not weigh against it. The court has no
doubt that Washington courts will provide a sure-footed reading of
the state-law issues in this case, and no party has suggested
otherwise. See Gibbs, 383 U.S. at 726. Furthermore, the court does
not find that Mr. King's tactics have been manipulative.

**********

In point of fact, if anyone is manipulative here it is Defendant and
Counsel, sad to say but true. To allow this case to proceed in Federal Court by
retaining Jurisdiction is to provide negative reinforcement to a Courtroom
bully who fancies bellowing and respectful, peaceful citizen journalists.

56
CONCLUSION AND PRAYER FOR RELIEF

The Defendant has engaged in a bit of invidious forum-shopping that
must gain no quarter within. The case must be hereby Remanded, it being
factually indistinguishable from the 2016 case of KingCast v. Wright, Finlay &
Zack that contemplated the exact same theme.

Respectfully submitted,

___________________________________________
Christopher King, J.D.

___________________________________________
Wally Brown

___________________________________________
Chris Nubbe

57
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 JUDGE MARTINEZ

and
CHRIS NUBBE )
Plaintiffs,

v. )

HON. STAN J. RUMBAUGH
IN HIS INDIVIDUAL AND OFFICIAL CAPACITIES )

Defendant. )

ORDER GRANTING PLAINTIFFS’ MOTION FOR ENLARGEMENT

This matter came before the Court pursuant to Plaintiff’s Motion to
Remand, Defendant’s Motion to Dismiss and Plaintiff’s Motion for
Enlargement of Time in which respond to Defendant’s Motion to Dismiss.
Good Cause having been shown, the Court hereby GRANTS said Motion.
As the case may be Remanded to the King County Superior Court for
further litigation or resolution that Court shall set an appropriate briefing
schedule.
In the event this Court retains Jurisdiction Plaintiff shall be required to
file a complete Memorandum in Opposition to Defendant’s Motion to
Dismiss no later than seven (7) calendar days from the Court’s ORDER
denying Remand.

IT IS SO ORDERED THIS ____ Day of February, 2016

58
___________________________________

JUDGERICARDO MARTINEZ

CERTIFICATE OF SERVICE

We, the undersigned, solemnly swear that a true and accurate copy of the
foregoing Motion was sent via email and tracked U.S. Mail on 30 January 2017
to the following:

Daniel R. Hamilton, Esq.
955 Tacoma Avenue South
Suite 301
Tacoma WA 98402
dhamilt@co.pierce.wa.us

Stepen D. Trinen, Esq.
955 Tacoma Avenue South
Suite 301
Tacoma WA 98402
strinen@co.pierce.wa.us

___________________________________________
Christopher King, J.D.

___________________________________________
Wally Brown

___________________________________________
Chris Nubbe

59
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. )

PLAINTIFFS’ MOTION FOR REMAND
This case is all about Defendant Rumbaugh’s abject failure to follow
Washington GR 16, which sets out a number of substantive and procedural
safeguards that must be addressed by a Judge before any Prior Restraint may
be contemplated by the Court. To allow this case to proceed in Federal Court
by retaining Jurisdiction is to provide negative reinforcement to a Courtroom
bully who fancies bellowing and respectful, peaceful citizen journalists.
And as noted by the attached video (hard copy on file with the Court)
Defendant Rumbaugh clearly engaged in Prior Restraint by throwing Plaintiff
Brown out of Court the minute he stated “I’m media,” and by refusing to rule
on Plaintiff King’s Notice of Media Coverage requests, when taken in the light
most favorable to Plaintiffs.
http://christopher-king.blogspot.com/2016/08/kingcast-mortgage-movies-wally-
brown.html
https://www.youtube.com/watch?v=ZcE0ZiO-deM

60
This Removal was nothing more than a dilatory tactic in the hopes that
this Honorable Court would retain Jurisdiction so that Plaintiffs could not run
video of these proceedings in King County Superior Court – where they have
NEVER ONCE been denied camera access, and that’s a fact.

In the 2016 Removal Case of KingCast v. Wright, Finlay & Zack9 the
Establishment
Defendants ran off to Court whilst ignoring Plaintiff’s reasonable requests to
resolve Jurisdiction in extrajudicial manner simply because they didn’t want
to appear on camera. Plaintiff King prevailed on Remand just as Plaintiff’s
must prevail in this instance for all the same reasons.

Sadly the same pattern exists with this camera-adverse Defendant in
this case: Even though Plaintiffs expressly stipulated to Damages less than
$75,000.00 and stipulated to Dismiss the sole Federal Cause of Action,
Defendant and his Counsel is so scared of this case being caught on camera
that they thought it prudent to waste Judicial and taxpayer resources to make
a run on Removal instead of simply picking up the phone and asking Plaintiffs
if they would remove the Federal Claim. Again, Fn1 to Plaintiffs’ Complaint
read:

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
9 Appendix B

61
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).

Heaven forbid that Defendant would actually want the public to see
him defend First Amendment violations in State Court, but such is his nature,
apparently. Plaintiff is of course quite familiar with Removal, having
successfully tried an settled many Federal Cases since passing the bar in
1993. The issue here however is this: Plaintiff believes pursuant to the case
law he has set forth that he need not Voluntarily Dismiss his sole Federal
Claim in order to obtain Remand. Rather, the Court should Remand on its
own initiative because the heart of the case is an interpretation of GR 16.

The having been said, Plaintiffs nonetheless indeed hereby file a Voluntary
Dismissal and we suppose Defendants’ insurance carrier – ultimately the
Taxpayers of the State of Washington -- may be happier knowing they no
longer have a Federal Cause of Action to Defend.
Moreover, Plaintiffs warned Defendant that any attempts at
gamesmanship will be met with full force opposition. See Appendix A.

Moreover, at least this Dismissal would give Plaintiffs the peace of
mind to know that he may soon run his videos in State Court because they
already stipulated that Damages are not to exceed $75,000.00 as noted in
Calnan v. USAA Cas. Ins. Co., 2014 U.S. Dist. LEXIS 106881 (WD WA 2014) “To
prevent removal a plaintiff may stipulate to damages not exceeding the
$75,000 jurisdictional limit” Oshana v. Coca-Cola Co., 472 F.3d 506, 511 (7th
Cir. 2006); Del Real v. Healthsouth Corp., 171 F.Supp.2d 1041, 1043 (D. Ariz.
2001), supra.10

10 Again, of Course, Defendants never even sought such a conciliation or stipulation
because they don’t want to be subject to cameras in State Court. Based on their
history of conduct that observation is most assuredly a fact and surely not steeped in
hypothetical conjecture. A bit of invidious forum shopping as they say. This Court
must not grant Quarter for it.

62
Defendant’s cited cases are all much older than KingCast v. Wright,
Finlay & Zack and do not hail from this specific Jurisdiction and do not involve
Remand at the outset of litigation and are thus inherently inferior citations as
to Stare Decisis, particularly when all Defendants had to do was to pick up
the phone instead of attempting to run off and hide from cameras in Federal
Court, which is exactly what is going on here.

63
CONCLUSION AND PRAYER FOR RELIEF

The Defendant has engaged in a bit of invidious forum-shopping that
must gain no quarter within. The case must be hereby Remanded, it being
factually indistinguishable from the 2016 case of KingCast v. Wright, Finlay &
Zack that contemplated the exact same theme.

Respectfully submitted,

___________________________________________
Christopher King, J.D.

___________________________________________
Wally Brown

___________________________________________
Chris Nubbe

64
APPENDIX A

On Jan 12, 2017, at 12:36 PM, Christopher King <kingcast955@icloud.com> wrote:

Good Day to All.

I just got a packet from Defendant Rumbaugh with a Notice of Removal.

I am going to move to Remand. You should understand the issues already from
reading the complaint -- I stipulated to damages and offered to waive the First
Amendment claim. This is a blatant attempt to avoid cameras following this event
and I am going to blast away on Remand in Federal Court.

This is familiar turf on which I have prevailed on prior occasion.
http://www.leagle.com/decision/In%20FDCO%2020160421D73/KING%20v.
%20WRIGHT%20FINLAY%20&%20ZAK?

Ciao.

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

206.299.9333f

On Jan 09, 2017, at 09:50 PM, Christopher King <kingcast955@icloud.com> wrote:

Dear Attorneys Hamilton and Trinen:

I have received your Notice of Appearance on behalf of Defendant Rumbaugh.

From it, I anticipate that you and your client may engage in dilatory subterfuge up to
and including waging a war on Service/Service of Process. If that be the case, I would
strongly advise against it.

First of all, I'll have one of the PI firms that worked on the Amanda Berry case serve
him. I trust they can git er done.

Second, everything foolish that wastes more taxpayer resources in an attempt to
evade the Law will be thoroughly posted on social and legal media.

With such in mind, I look forward to discussion and litigation on the merits, unless
your client is afraid of same. Because when we get to trial, if we get knocked around
for a year or more on evasive Motions and Memoranda, don't look for any
concessions from us.
Respectfully submitted,

CHRISTOPHER KING, J.D.
kingcast955@icloud.com
mortgagemovies007@gmail.com
http://affordablevideodepo.com
http://mortgagemovies.blogspot.com

65
617.543.8085m

206.299.9333f
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 ) JUDGE MARTINEZ

and

CHRIS NUBBE )

Plaintiffs,

v. )

HON. STAN J. RUMBAUGH
IN HIS INDIVIDUAL AND OFFICIAL CAPACITIES )

Defendant. )

ORDER GRANTING PLAINTIFFS’ MOTION TO REMAND

This matter came before the Court pursuant to Plaintiff’s Motion to
Remand. Good Cause having been shown, the Court hereby GRANTS said
Motion. The case is hereby Remanded to the King County Superior Court
for further litigation or resolution.

IT IS SO ORDERED THIS ____ Day of January, 2016

___________________________________

JUDGERICARDO MARTINEZ

66
67
CERTIFICATE OF SERVICE

We, the undersigned, solemnly swear that a true and accurate copy of the
foregoing Motion was sent via email and tracked U.S. Mail on 17 January 2017
to the following:

Daniel R. Hamilton, Esq.
955 Tacoma Avenue South
Suite 301
Tacoma WA 98402
dhamilt@co.pierce.wa.us

Stepen D. Trinen, Esq.
955 Tacoma Avenue South
Suite 301
Tacoma WA 98402
strinen@co.pierce.wa.us

___________________________________________
Christopher King, J.D.

___________________________________________
Wally Brown

___________________________________________
Chris Nubbe

68
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 ) JUDGE MARTINEZ

and

CHRIS NUBBE )

Plaintiffs,

v. )

HON. STAN J. RUMBAUGH
IN HIS INDIVIDUAL AND OFFICIAL CAPACITIES )

Defendant. )

ORDER GRANTING PLAINTIFFS’ MOTION TO REMAND

This matter came before the Court pursuant to Plaintiff’s Motion to
Remand. Good Cause having been shown, the Court hereby GRANTS said
Motion. The case is hereby Remanded to the King County Superior Court
for further litigation or resolution.

IT IS SO ORDERED THIS ____ Day of January, 2016

___________________________________

JUDGERICARDO MARTINEZ

69
CERTIFICATE OF SERVICE

We, the undersigned, solemnly swear that a true and accurate copy of the
foregoing Motion was sent via email and tracked U.S. Mail on 17 January 2017
to the following:

Daniel R. Hamilton, Esq.
955 Tacoma Avenue South
Suite 301
Tacoma WA 98402
dhamilt@co.pierce.wa.us

Stepen D. Trinen, Esq.
955 Tacoma Avenue South
Suite 301
Tacoma WA 98402
strinen@co.pierce.wa.us

___________________________________________
Christopher King, J.D.

___________________________________________
Wally Brown

___________________________________________
Chris Nubbe

70
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 ) JUDGE MARTINEZ

and

CHRIS NUBBE )

Plaintiffs,

v. )

HON. STAN J. RUMBAUGH
IN HIS INDIVIDUAL AND OFFICIAL CAPACITIES )

Defendant. )

PLAINTIFFS’ RULE 41 VOLUNTARY DISMISSAL
OF HIS SOLE FEDERAL CLAIM OF FIRST AMENDMENT VIOLATION

In the 2016 Removal Case of KingCast v. Wright, Finlay & Zack the
Establishment Defendants ran off to Court whilst ignoring Plaintiff’s
reasonable requests to resolve Jurisdiction in extrajudicial manner because
they didn’t want to appear on camera. Plaintiff King prevailed on Remand.
Sadly the same pattern exists with this camera-adverse Defendant in
this case: Even though Plaintiffs expressly stipulated to Damages less than
$75,000.00 and stipulated to Dismiss the sole Federal Cause of Action,
Defendant and his Counsel is so scared of this case being caught on camera
that they thought it prudent to waste Judicial and taxpayer resources to make
a run on Removal instead of simply picking up the phone and asking Plaintiffs
if they would remove the Federal Claim. Again, Fn1 to Plaintiffs’ Complaint
read:
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

71
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).

Plaintiff is of course quite familiar with said Rule, having successfully
tried many Federal Cases. The issue here however is this: Plaintiff believes
pursuant to the case law he has set forth that he need not Voluntarily
Dismiss his sole Federal Claim in order to obtain Remand. Rather, the Court
should Remand on its own initiative because the heart of the case is an
interpretation of GR 16.
The having been said, Plaintiffs nonetheless indeed file a Voluntary
Dismissal and we suppose Defendants’ insurance carrier – ultimately the
Taxpayers of the State of Washington -- may be happier knowing they no
longer have a Federal Cause of Action to Defend.
Moreover, at least this Dismissal would give Plaintiff the peace of mind
to know that he may soon run his videos in State Court because they already
stipulated that Damages are not to exceed $75,000.00 as noted in Calnan v.
USAA Cas. Ins. Co., 2014 U.S. Dist. LEXIS 106881 (WD WA 2014) “To prevent
removal a plaintiff may stipulate to damages not exceeding the $75,000
jurisdictional limit” Oshana v. Coca-Cola Co., 472 F.3d 506, 511 (7th Cir.
2006); Del Real v. Healthsouth Corp., 171 F.Supp.2d 1041, 1043 (D. Ariz.
2001), supra.11

IN LIGHT OF THE FOREGOING, Plaintiffs hereby Voluntarily DISMISS
their sole Federal Cause of Action Said DISMISSAL shall be with Prejudice and
is made pursuant to Rule 41(a)(1)(A)(i) as Defendants have not Answered nor
have they filed a Motion for Summary Judgment in this matter.
Back to State Court, back to videos in said courtrooms in King County –
where Plaintiffs have NEVER ONCE been denied the Right to run video in ANY
Courtroom.
Respectfully submitted,

11 Again, of Course, Defendants never even sought such a conciliation or stipulation
because they don’t want to be subject to cameras in State Court. Based on their
history of conduct that observation is most assuredly a fact and surely not steeped in
hypothetical conjecture. A bit of invidious forum shopping as they say. This Court
must not grant Quarter for it.

72
____________________________
Christopher King, J.D.

73
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 ) JUDGE MARTINEZ

and

CHRIS NUBBE )

Plaintiffs,

v. )

HON. STAN J. RUMBAUGH
IN HIS INDIVIDUAL AND OFFICIAL CAPACITIES )

Defendant. )

ORDER GRANTING PLAINTIFFS’ VOLUNTARY DISMISSAL
OF FEDERAL CAUSE OF ACTION

This matter came before the Court pursuant to Plaintiff’s Voluntary
Dismissal per FRCP 41(a)(1)(A)(i). Good Cause having been shown, such
Federal First Amendment Cause of Action of Plaintiff’s Complaint is hereby
DISMISSED WITH PREJUDICE.

IT IS SO ORDERED THIS ____ Day of January, 2016

____________________________________

JUDGERICARDO MARTINEZ

74
CERTIFICATE OF SERVICE

We, the undersigned, solemnly swear that a true and accurate copy of the
foregoing Motion was sent via email and tracked U.S. Mail on 17 January 2017
to the following:

Daniel R. Hamilton, Esq.
955 Tacoma Avenue South
Suite 301
Tacoma WA 98402
dhamilt@co.pierce.wa.us

Stepen D. Trinen, Esq.
955 Tacoma Avenue South
Suite 301
Tacoma WA 98402
strinen@co.pierce.wa.us

___________________________________________
Christopher King, J.D.

___________________________________________
Wally Brown

___________________________________________
Chris Nubbe

75