IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON

DIVISION I

CHRISTOPHER KING, J.D. KING COUNTY CASE NO. 22-2-17896-5

vs. Court of Appeals No. 85326-1

BLACK EXCELLENCE
IN CANNABIS et al

RULE 12.4 MOTION WITH DEMAND FOR JUDICIAL NOTICE

OF APPELLANT CHRISTOPHER KING, J.D.

Christopher King, J.D. APPELLANT

515 E. Fulton Street
Mt. Vernon, WA 98273
kingcast955@icloud.com

Ryan Agnew ATTORNEY FOR APPELLEES

P.O. Box 601 BLACK EXCELLENCE IN CANNABIS
Milton, WA 98354-0601 AND PETER MANNING
agnew.rr@gmail.com

1
 NOW COMES PLAINTIFF-APPELLANT KING to 4ile this Motion for the simple fact
that this Honorable Court’s own cited case supports his position in full. To wit, the
Court cited Hook v. Lincoln County 166 Wn. App 145 (2012). Hook is inapposite to
this case because in that case “The cross motions were argued in February 2010,
following which the parties requested and were granted leave to file supplemental
briefing..”
The litigant in that case then, subsequently filed supplemental briefing and did not
prevail in that briefing, but here is the key distinction: At no point in time had there
been a blanket edict from the Court foreclosing any possible Amendment. The factual
predicate in that case is materially different because the litigant in that case could have
and should have prepared an Amended Complaint, whereas in the case at bar Plaintiff-
Appellant NEVER GOT THAT CHANCE because the Court foreclosed on any
such opportunity during Oral Argument. This is a distinction with substantial
difference and it mandates that this Court issue a completely different rationale
in the event the Court continues to deny Appellant’s voice.1
Appellant considers the possibility that the Court assumed that the situation in this
case mirrored that of Hook, but alas it most certainly does not. With such in mind let
us turn to the material issues in seriatim, commencing with the Demand for Rule
201 Judicial Notice, in addition to the succinct Declaration by Plaintiff-Appellant at
the close of this 4iling.
I. The Decision of the Lower Court was Clearly Reversible Error.
II. The Deviation by this Court was Based on a False Assumption.
III. The Deviation by this Court Forces Appellant into an Untenable Position.
IV. The Deviation by this Court was Unwarranted Given the Undisputed Facts.
of the Case and the Shameful History of Washington’s Cannabis Social
Equity Program.

1
Again, given the social justice matters in this case involving Washington’s largest cash crop this
Honorable Court should have granted Appellant’s request for Oral Argument, ab initio.

2
 Each of these Assignments of Error will be addressed in the few succinct
paragraphs that follow. First of all this Court thoroughly and completely ignored the
well-settled Maxim that a Court speaks through its entries and that entry read in
pertinent part:
Plaintiff’s request for leave to amend the complaint is denied as new claims
are markedly different from those asserted herein. Plaintiff may pursue new
litigation/legal courses of action as warranted. Defendant Manning’s Motion
for Award of Costs is DENIED.
(Appendix A, previously-4iled, emphasis in original).

The Reversible Error portion comes into play because the “new claims” that
Plaintiff desired to advance were clearly contemplated by the plain language in the
First Amended Complaint in which Appellant highlighted his Intellectual Property
Concerns that were supported by the Declaration of Black Excellence in Cannabis
Founder Aaron Bar4ield.2
Speci4ically FAC Complaint Para 11 cited these concerns yet and still the lower
Court and this Court both ignored Appellant’s citation to the Lower Court’s own
precedent case of Estate of Summer Jolie Williams v. City of Seattle et al. King County

2Rule 201 Judicial Notice is reasonably sought at this point because just last week the Washington
Cannabis Observer, a well-received professional industry news publication, cited to Peter Manning
as “Black Excellence in Cannabis Co-Founder.” Obviously then there is at least one other Co-Founder
and potentially others who have valid intellectual property claims in light of the fact that the First
Amended Complaint clearly noted that Defendant manning ran off to the Secretary of State without
telling Aaron BarSield or Appellant. Mr. BarSield will be suing on his own right as Appellant
continues on his own path as well because this is obviously an unjust result. See the online
Cannabis Observer coverage at Exhibit B; Court routinely take judicial Notice of News publications.

Appellate courts have increasingly cited information found on the Internet, often with less care than
they should. As with hard-copy publications, courts are most willing to take judicial notice of
information found on government Web sites, such as the time of sunrise found on the Web site of
the U.S. Naval Observatory [U.S. v. Bervaldi, 226 F.3d 1256, 1266 n.9 [11th Cir. 2000]]; the prime
interest rate on the Federal Reserve Board Web site [Levan v. Capital Cities/ABC Inc., 190 F.3d 1230,
1235 n.12 [11th Cir. 1999]]; and records of retired military personnel on a federal Web site [Denius,
330 F.3d at 926]…. Appellate courts are also likely to take judicial notice of relevant newspaper
articles [see, e.g., The Washington Post v. Robinson, 935 F.2d 282, 291-92 [D.C. Cir. 1991]] and
historical information contained in authoritative publications, such as a text on the history of
Lincoln Center [see, e.g., Hotel Employees, 311 F.3d at 540 n.1.].

3
No. 20-2-14351-SEA (2021) with Judge Ramseyer in which new claims and new Parties
were liberally-granted leave to file written Amended Complaints! Appellant’s Brief read
as follows:

Plaintiff’s position is clearly noted in the FAC para 11 as someone whose Intellectual
Property and viewpoint are being violated:

c) Manning telephoned Plaintiff, accused him of being “counter intelligence” and

asked him “why do you always put pictures in your Briefs?” Plaintiff told him “Be-
cause I’m a journalist by training, I’ve done this for years as a licensed Attorney and
advocate in general, and because pictures are less likely to lie than people in the
pictures.”

d) Defendants Manning and Asai continually appear before the WSLCB Board
meetings and falsely proclaim that Plaintiff, Saad, Shelton and their friend Libby
Haines are unreasonably attacking only Ollie Garrett. These are materially false
statements that are known to be false by Defendants and by any reasonable person
given the multitude of media showing that these individuals have openly and
frequently criticized the entire Board. These statements are being published to
convince known and unknown third parties that Plaintiff, Saad, the Sheltons and Ms.
Haines are ignorant and on a personal vendetta against a Black woman, when nothing
could be further from the truth. Notwithstanding same, Defendant Manning as
recently as 26 October, 2022 stated “Leave the Sister ALONE!”

First of all Plaintiff is not even adding a new Plaintiff. Second, there are no new
Defendants. Third, where is the Prejudice to Defendants? Fourth, Judicial Economy
has been thwarted. Fifth, the Theory of the Case is only marginally changed to reflect
the cur- rent existing Plaintiff’s Intellectual Property and Group Rights Interest. The
primary point of focus in the case has always been on Aaron Barfield’s Intellectual
Property and the Good- will and Path of Black Excellence in Cannabis, adding
Plaintiff King’s Intellectual Property concerns simply is not a substantial departure
from the law of the case and Judicial Economy in these circumstances always favors
Amendment; just as the Court agreed in Williams, supra and any other approach
begets an Equal Protection and Arbitrary and Capricious issue.

With such in mind then, we turn to the false assumption: In the event it was not
clear already, it is now patently obvious the factual pattern in Hook is not the same
as the one presented now and therein lies the basis of the Appeal. As such, this
Court’s denial based on Appellants purported failure to 4ile a Draft Second Amended
Complaint is not a Just Result.

4
 In point of fact, this Court’s Decision, when taken to its logical conclusion, places
Appellant in an untenable position: In order for Appellant to 4ile an Amended
Complaint he would have had to have been a disrespectful Negro and just 4iled one
anyway. But Appellant is not a disrespectful Negro. He is instead a top-50 law school
graduate who continues to review the law for relevancy, such as the Lower Court’s
own case supporting liberal amendment with new claims and parties3 (Williams,
supra.) and this Court’s cited case of Hood, supra, which on further review actually
buttresses Appellant’s position.
A quick note about Alternate Bases of Decision and the social and legal
signi4icance of this case: Appellant is well aware that a Court of Appeals may 4ind
reasons outside of the Record Rationale to sustain a Decision, “wrong rationale –
correct 4inding” is the approximate mantra. However, the fact that this Court would
go so far as to create Rationales not mentioned by the Court for a Defendant who
defamed both Plaintiff and BEiC founder Aaron Barfield, i.e. “disbarred and in trouble
in New Hampshire” and “$80,000 embezzler” respectively does not bode well for the
Cause of Justice in any measure but then again given the ruling in the first place why
is no one surprised. Not coincidentally the embezzler lie was manifest exactly one (1)
year ago to the day at 5:40 et seq. of this #KingCast Facebook live video feed of a
public meeting.

https://www.facebook.com/KingCast/videos/1491821031301352. 4

3 Remember, Plaintiff-Appellant in this case was not even adding any new Parties; such fact
obviously militates in favor of Amendment.
4 Appellant previously Siled the Peter Manning apology for Manning’s Defamatory statements

regarding him because these facts are important to a reviewing Court so that they can get a feel for
what is Just in any given instance. Cases do not develop in a vacuum, yet the Court’s Decision was
seemingly developed in one.

5
 Further, on another occasion as Appellant noted in the Oral Argument video linked
in his Declaration the ongoing theft against Aaron Barfield and our entire Black
Excellence in Cannabis movement is completely absurd and is legally startling, at
39:20:

6
 “They are taking the sweat equity from their Black brothers, and pimping us
out like 2-bit tricks to get 5% of a cannabis interest and it is disgusting.”
https://youtu.be/yGtOq4q15Tc?si=IczptpF7Rc_QdW7I&t=2360

Lastly, the social and legal significance of this case cannot be ignored yet the
Court already refused to grant Oral Argument when Appellant showed the Court that
the theft of Generational Black Wealth in cannabis resulted in none other than Aaron
Barfield having his business stolen from him as noted on the front page of the Seattle
Times, so clearly the matter is important, particularly now since a second and further
theft offense against Mr. Barfield has occurred by his own former Partner and his
friends as they all get licenses in the so-called Social Equity Program and gloat over
it: Appellant is just here to document all of these shenanigans as they unfold.

7
 DECLARATION OF PLAINTIFF-APPELLANT CHRISTOPHER KING, J.D.

NOW COMES PLAINTIFF, being first Duly Sworn and subject to the Pains and

Penalties of Perjury to state:

1. The Lower Court refused to allow me have standing on behalf of Mr. Barfield
or on behalf of a the nonprofit entity, which is not an issue of this Appeal.
As heard starting near 28:55 of the Oral Argument.
https://youtu.be/yGtOq4q15Tc?si=M2xaVRF5dmVqFuEN&t=1734; and

24:30 / 43:34
Court Lets Peter Manning and Phony Black Excellence in Cannabis Rape
Pillage and Plunder for WSLCB
2. The Court never addressed my own Intellectual contributions when I stated at
36:05 “I have my own Intellectual Property Interests with Black Excellence in
Cannabis that have been violated in addition to being defamed…. My own
sweat blood and tears went into this”; and
3. Through practice and firsthand observation I am quite familiar with the
processes involved in filing Amended Complaints up to and including at Trial;
and

4. Typically in this situation the Court would instruct a Plaintiff to file an

Amended Complaint and then review it and make a decision; and

5. Had the Lower Court followed conventions of practice it would have instructed
me to draft a Second Amended Complaint and I most certainly would have

8
10
3
 CERTIFICATE OF SERVICE

I hereby certify that on December 11, 2023 I electronically filed the foregoing with the
Clerk of the Court by and through the electronic portal designed to effectuate Service on
Counsel for Appellees. Further, an emailed copy was sent on this Day as well to:

Ryan Agnew
P.O. Box 601
Milton, WA 98354-0601

agnew.rr@gmail.com

ATTORNEY FOR APPELLEES

BLACK EXCELLENCE IN CANNABIS
AND PETER MANNING

_________________________
Christopher King, J.D.
Appellant

Date: December 11, 2023

515 E. Fulton Street
Mt. Vernon, WA 98273

11
 IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON
DIVISION I

CHRISTOPHER KING, J.D. KING COUNTY CASE NO. 22-2-17896-5

vs. Court of Appeals No. 85326-1

BLACK EXCELLENCE
IN CANNABIS et al

NOTICE OF INTENT TO FILE RULE 12.4 MOTION

OF APPELLANT CHRISTOPHER KING, J.D.

Christopher King, J.D. APPELLANT

515 E. Fulton Street
Mt. Vernon, WA 98273
kingcast955@icloud.com

Ryan Agnew ATTORNEY FOR APPELLEES

P.O. Box 601 BLACK EXCELLENCE IN CANNABIS
Milton, WA 98354-0601 AND PETER MANNING
agnew.rr@gmail.com

1
 NOW COMES PLAINTIFF-APPELLANT KING to note that the Court’s decision is
untenable because, inter alia, he would have had to disrespect the premature Order
of the Lower Court in order to Gile a written Motion for Leave to File an Amended
Complaint. This will become clear when the Motion is Giled. Also, Hook v. Lincoln
County 166 Wn. App 145 (2102) is inapposite to this case because in that case “The
cross motions were argued in February 2010, following which the parties requested
and were granted leave to file supplemental briefing…..”
After such point that litigant in that case filed to file. Plaintiff-Appellant in this
case of course, NEVER GOT THAT CHANCE and so he is not going to sit here and
allow the Court to run him out of town like some ignorant Negro. We’re not having
any of that here.
More on this within the time provided by Law.
Respectfully submitted,

___________________________
Christopher King, J.D.
Plaintiff-Appellant

2
 CERTIFICATE OF SERVICE

I hereby certify that on November 23, 2023 I electronically filed the foregoing with the
Clerk of the Court by and through the electronic portal designed to effectuate Service on
Counsel for Appellees. Further, an emailed copy was sent on this Day as well to:

Ryan Agnew
P.O. Box 601
Milton, WA 98354-0601

agnew.rr@gmail.com

ATTORNEY FOR APPELLEES

BLACK EXCELLENCE IN CANNABIS
AND PETER MANNING

_________________________
Christopher King, J.D.
Appellant

Date: November 23, 2023

515 E. Fulton Street
Mt. Vernon, WA 98273

3
 IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON

CHRISTOPHER KING, J.D. A/K/A

KINGCAST, No. 85326-1-I

Appellant, DIVISION ONE

v.
UNPUBLISHED OPINION
BLACK EXCELLENCE IN CANNABIS,
PETER MANNING, and MIKE ASAI,

Respondents.

MANN, J. — Christopher King appeals the superior court’s order dismissing his

complaint against Peter Manning, Mike Asai, and Black Excellence in Cannabis. We

affirm.

In 2022, King filed an amended complaint in King County Superior Court against

Manning, Asai, and Black Excellence in Cannabis, for “unlawful filing and use of a

nonprofit corporation” and defamation. King alleged that Manning and Asai licensed

Black Excellence in Cannabis with the Washington Secretary of State in summer 2022,
No. 85326-1-I/2

without the knowledge or permission of Black Excellence in Cannabis’s original founder

Aaron Barfield. 1

King first moved for a preliminary injunction, seeking to enjoin Manning from

misappropriating the good will of Black Excellence in Cannabis. The superior court

denied King’s motion because King failed to establish standing to seek the requested

injunction and failed to show that he personally had a legal or equitable right in the

organization.

Manning then moved to dismiss the complaint under CR 12(b)(6) asserting that

King did not possess standing either as an individual or as a derivative action on behalf

of the nonprofit entity because King sought to protect the alleged property of a third

party, not his own. In response, King asserted that he had standing as a taxpayer and

as a member of Black Excellence in Cannabis.

The superior court agreed with Manning and granted the motion to dismiss. The

superior court also denied King’s oral request for leave to amend the complaint because

the “new claims are markedly different than those asserted herein.” However, the

superior court wrote on the order that King “may pursue new litigation/legal causes of

action as warranted.”

King appeals. 2

1King only provided this court with his first amended complaint filed November 8, 2022.
2Respondents filed a declaration in lieu of a response brief opting to stand on the existing record
and asserting “[i]n the absence of clear error on the part of the trial court, there is no justifiable cause to
remand this case for further proceedings.” We accepted the declaration as the respondents’ brief in this
matter.

-2-
No. 85326-1-I/3

II

King asserts that the superior court erred by failing to allow him to amend his

complaint for the second time.

We review a trial court’s denial of a motion to amend pleadings for an abuse of

discretion. Del Guzzi Constr. Co. v. Glob. Nw. Ltd., 105 Wn.2d 878, 888, 719 P.2d 120

(1986). CR 15(a) provides that “a party may amend the party’s pleading only by leave

of court or by written consent of the adverse party; and leave shall be freely given when

justice so requires.” See Caruso v. Loc. Union No. 690 Int’l Bhd. of Teamsters, 100

Wn.2d 343, 349, 670 P.2d 240 (1983) (leave to amend should be freely given “‘except

where prejudice to the opposing party would result’” (quoting United States v. Hougham,

364 U.S. 310, 316, 81 S. Ct. 13, 5 L. Ed. 2d 8 (1960))). The court may consider such

factors as delay. Caruso, 100 Wn.2d at 349.

However, “[i]f a party moves to amend a pleading, a copy of the proposed

amended pleading, denominated ‘proposed’ and unsigned, shall be attached to the

motion.” CR 15(a). The word “shall” is presumptively imperative and operates to create

a duty. Crown Cascade, Inc. v. O’Neal, 100 Wn.2d 256, 261, 668 P.2d 585 (1983).

“Both the opposing party and the court have a legitimate need to see the proposed

amended pleading in order to address and assess relevant issues of prejudice and

futility.” Hook v. Lincoln County Noxious Weed Control Bd., 166 Wn. App. 145, 159,

269 P.3d 1056 (2012).

-3-
No. 85326-1-I/4

King neither filed a motion for leave to amend nor provided a proposed amended

complaint as required by CR 15(a). Instead, he orally requested to amend his complaint

at the hearing to dismiss his complaint. 3,4

King’s failure to provide the amended complaint required by CR 15(a) alone was

a sufficient basis for denying the motion. The superior court did not abuse its discretion

in denying the motion.

We affirm.

WE CONCUR:

3 King did not provide a verbatim report of this hearing for our review. The superior court’s written
order incorporated “reasons stated on the record.”
4 In King’s response to the respondents’ motion to dismiss, King stated, “[i]f necessary Plaintiff

will Amend the Complaint to properly Summons the Secretary of State.” While this may have notified
Respondents that King might seek leave to amend the complaint, it was not a motion, nor did it provide
the court and respondents an opportunity to “address and assess relevant issues of prejudice and futility.”
Hook, 166 Wn. App. at 159. Further, it is not the same argument that King asserts on appeal: that King
should have been allowed to amend the complaint “to place him as [a Black Excellence in Cannabis]
member plaintiff as opposed to a taxpayer Plaintiff.”

-4-
 IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON
DIVISION I

CHRISTOPHER KING, J.D. KING COUNTY CASE NO. 22-2-17896-5

vs. Court of Appeals No. 85326-1

BLACK EXCELLENCE
IN CANNABIS et al

REPLY BRIEF OF APPELLANT CHRISTOPHER KING, J.D.

Christopher King, J.D. APPELLANT

515 E. Fulton Street
Mt. Vernon, WA 98273
kingcast955@icloud.com

Ryan Agnew ATTORNEY FOR APPELLEES

P.O. Box 601 BLACK EXCELLENCE IN CANNABIS
Milton, WA 98354-0601 AND PETER MANNING
agnew.rr@gmail.com

1
 To the extent that things seem to have gotten a bit informal here Plaintiff-
Appellant will grant Defendants-Appellees that latitude so that they are spared the
embarrassment of attempting to explain Defendant Manning’s actions in terms of:

a) Defaming Plaintiff King, i.e. “disbarred.”

b) Defaming Witness and BEiC founder Aaron BarJield “$80,000 Felon.”
c) Founding a for-proJit venture without notifying Plaintiff or Witness BarJield.1

Perhaps a pictorial will assist Appellees, remembering Jirst that the Lower Court
DID NOT make any determination on Standing as a member of BEiC; it implied a
ruling for Taxpayer Standing. Remember this as we move forward.
1. Aaron BarJield was and is the founder of the social political association
bearing the name “Black Excellence in Cannabis” and was properly recognized by
the media as such on countless occasions including this one in which he decries how
Blacks like him have had their businesses stolen. The funny thing is how this so-
called Reporter refused to ever follow up with him when he complained about Peter
Manning stealing the name for his own corporate gain without Notice:

1That having been said, obviously this lower Court, on Remand, must take these matters into account when it
comes to deciding the case at Law or at Equity, unless there is some sort of new legal system of which
Plaintiff-Appellant and Witness BarDield are unaware.

2
2. Next we have Appellee Manning in audio decrying Governer Inslee and his
appointees for practicing racist programs whilst indicating that Inslee “Used their
Equity program for a soda coaster” in unretracted print; but now all of a sudden
Inslee is not a racist and BarJield and King are a felon and disbarred, respectively
(both lies that to a reasonable person just *MIGHT* indicate some sort of wrongdoing
and Bad Faith but what do I know right).
https://www.youtube.com/watch?v=hUHPahv9exI&t=157s

This dovetails with noted local Attorney Douglas Hiatt when discussing State
policies and practices that subjugated Blacks: “Big fuckin’ surprise…. The ones that
we have seen take the most egregious hit are all minority-owned or they are serving
the minority community” so it’s hardly just KingCast screaming this at the top of his
lungs. Everyone knows that Washington Cannabis is and has been an Anti-Nigger
Machine and we are going to discuss this very important context AT ORAL
ARGUMENT unless the Court does not want to allow this particular nigger to have a
word for the Record. It’s that simple.

3
3. To add insult to injury Plaintiff-Appellant has seen a Federal Court Judge lie
about our friend Sami Saad applying for an i502 recreational license, falsely claiming
he never applied for one and that the other Blacks “abandoned their businesses” in
order to throw those niggers out of Court.2
4. Next, to continue the veil of secrecy we have the WSLCB refusing to provide
public information on the Request for Information/Request for QualiJications
process that brought in William N. Lukela as Board Director after he sustained
criticism in his former State of Colorado. The WSLCB redacted EVERYTHING and so
they will be sued shortly because Appellant King has worked with RFQ’s for decades
now and knows that everything about them is indeed PUBLIC excepting personal
information of the applicant; it’s not rocket science here but to complete the façade
WSLB now has complete control over the recommendations from the Ponder Group
that was the successful RFQ bidder on Diversity. 3

2 You see, empirically the only niggers who are friends with WSLCB’s Ollie Garrett and friends can hope to
obtain recreational licenses; this is a matter that is currently on Appeal in the 9th Circuit where it is drying on
the vine so to speak.
3 Note the maniacal manner in which Board Member David Postman circles Appellant’s name at public

speaking because he asks thorny questions. Appellant as a former AAG (among other things) knows a bit
about how government works in actuality and his questions and position upset a lot of people. So what. This
Court is not supposed to care about any of that in the way that these politicians clearly do. This Court is here
to determine not whether Law or Equity support Plaintiff’s position but whether he is even allowed to make
that argument without needlessly Diling another case. That point should now be patently clear to Appellees
and Counsel in the unlikely event that it was not before; they were being disingenuous with this Honorable
Court and Plaintiff-Appellant will not grant quarter to any such nonsense.

4
 Now then, to the extent that Appellee’s have posited an articulable response
Appellant replied to them via Counsel:

*******

From: Christopher King <kingcast955@icloud.com>

Subject: King v. "BEic" 853261_Appellee Affidavit in Lieu of Brief.
Date: September 1, 2023 at 9:17:21 AM PDT
To: Ryan Agnew <agnew.rr@gmail.com>
Cc: Aaron Black Excellence <blackexcellenceincannabis@gmail.com>, sami sami
<sa615615615@gmail.com>

Ryan,

You are aware that the Court's ORDER said nothing about Standing right?

A Court speaks through its Entries, at least that's the case until you start questioning
Bad Government Actors, which is exactly what Appellees are banking on, just like
the way that the Federal Court actually lied and said that our friend Sami Saad never
filed for a 502 license when I have a copy of the WSLCB acceptance sitting right here
on my desktop.

Best regards,

Christopher King, J.D.

******
Opposing Counsel appears to have lost his way along a well-lit path and even loses
sight of the fact that Standing at bottom, is not the issue in this case:

The issue in this case is whether or not Plaintiff-Appellant had a right to Amend his
Complaint a Second time. The relevant facts include:

1. I am a seasoned journalist who has written for a large daily (Indianapolis

Star) and edited a Statewide Black-owned paper (Cincinnati Edition of Ohio
Call & Post) prior to winning Jury Trials and subsequently working with
government on hundreds of occasions in the Communications industry,
writing and editing contracts. SufJice to say I tend to believe my

5
 communications skillset yields cogent product.

2. The Court never ruled that Plaintiff-Appellant’s proposed Amended

Complaint would fail for want of standing. What the Court actually said in the
four corners of the Order was that the claims were too attenuated to be
subject to Amendment;

3. The Court speaks through its Entries, not the wishful dicta of Defendant and
Opposing Counsel;

4. Aaron BarJield stated in Open Court “King you have standing as a member….”
This in addition to his Declaration that Appellee’s and Counsel would rather
not address so instead they write an AfJidavit. The Court must issue stern
rebuke for this sort of Jlippant, churlish and insouciant conduct. Aaron
BarJield’s Declaration is one of the more important factors in this case, along
with the fact that Appellee Manning is indeed a known and proven LIAR: I am
not disbarred nor have I ever been, and Aaron BarJield is not a criminal nor
has he ever embezzled anything;

5. Relevant Case Law was set forth from the very Trial Court involved herein as
consistent with basic (and advanced) principles of Stare Decisis. The factors
were analyzed and applied to this case so there is no need to repeat them here
for Counsel that portends not to understand. See again Estate of Summer Jolie
Williams v. City of Seattle et al. King County No. 20-2-14351-SEA allowing for
advancing Theories of the Case and Substitution/Addition of Parties.

6. I believe Counsel full well understands the arguments at hand because we

have discussed them at length in attempted negotiation in which Appellees
refused to accept a name change to “Peter’s Black Excellence.”

7. I believe that fact clearly shows the strength and goodwill involved with the
name “Black Excellence in Cannabis” that Discovery will show was penned by
none other than Witness BarJield, whose Declaration was of course
completely ignored by Defendants.

8. As to whether or not Counsel understood what the points were, I submit that
he was absolutely clear on it as we had wide-ranging discussions on this case,
other cases and of course, BMWs. Counsel for Defendants-Appellees drives an
E88, what is commonly known as a 135i (the only newer BMW sedan worth
buying) and Plaintiff-Appellant drives an E28, what is commonly known as a
535is (at bottom).

6
9. The following passage from Plaintiff’s First Amended Complaint clearly
shows that he has a vested interest in how the entity “Black Excellence in
Cannabis” is portrayed and he should have been able to argue this without
Jiling another separate lawsuit according to basic principles of Judicial
Economy and all of the other reasons set forth by the same Judge in the Lower
Court just two (2) short years ago!

c) Manning telephoned Plaintiff, accused him of being “counter

intelligence” and asked him “why do you always put pictures in your
Briefs?” Plaintiff told him “Be- cause I’m a journalist by training, I’ve done
this for years as a licensed Attorney and advocate in general, and because
pictures are less likely to lie than people in the pictures.”

d) Defendants Manning and Asai continually appear before the WSLCB

Board meetings and falsely proclaim that Plaintiff, Saad, Shelton and their
friend Libby Haines are unreasonably attacking only Ollie Garrett. These
are materially false statements that are known to be false by Defendants
and by any reasonable person given the multitude of media showing that
these individuals have openly and frequently criticized the entire Board.

7
 CONCLUSION

Plaintiff-Appellant spent substantial amounts of time, mental and Spiritual

energy deJining the voice of Black Excellence in Cannabis (hereinafter “BEiC”) as
noted by King from the living room of Defendant-Appellee Peter Manning
(“Manning”). Uncontroverted evidence by way of Declaration and supporting
documents from Aaron BarJield further establish the fact that he conceived and
managed the social site “Black Excellence in Cannabis” only to have Manning
turncoat the entire mission to take a different path and register the name in a
commercial sense. It’s pretty straightforward and the Court again DID NOT issue any
sort of negative ruling here on this point but the Court’s dicta in a public hearing did
in fact indicate that Standing could be possible on this theory but tended to indicate
that taxpayer Standing might not apply. We are here today because the Court falsely
claimed – counter to its own recent ruling – that these claims were too attenuated
from the pending FAC, which is just Jlat wrong:
In the end, a Jury will be entitled to hear this case at a minimum as a matter of
Equity and vote to issue limitations on the use of the Black Excellence in Cannabis
moniker by a proven liar, including but not limited to a Constructive Trust being
placed on any and all Jinancial windfalls that these thieves may enjoy.

9
 CERTIFICATE OF COMPLIANCE

I certify that:

This brief complies with the type-volume limitation because this brief contains 2,075
words in appropriate typeface and font size.

______________________
Christopher King, J.D.
Plaintiff-Appellant
Date: September 11, 2023
515 E. Fulton Street
Mt. Vernon, WA 98273

CERTIFICATE OF SERVICE

I hereby certify that on September 11, 2023 I electronically filed the foregoing with the
Clerk of the Court by and through the electronic portal designed to effectuate Service on
Counsel for Appellees. Further, an emailed copy was sent on this Day as well to:

Ryan Agnew
P.O. Box 601
Milton, WA 98354-0601

agnew.rr@gmail.com

ATTORNEY FOR APPELLEES

BLACK EXCELLENCE IN CANNABIS
AND PETER MANNING

_________________________
Christopher King, J.D.
Appellant

Date: September 11, 2023

515 E. Fulton Street
Mt. Vernon, WA 98273

10
 IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON
DIVISION I

CHRISTOPHER KING, J.D. KING COUNTY CASE NO. 23-2-00328-29

vs. Court of Appeals No. 85326-1

BLACK EXCELLENCE
IN CANNABIS et al

OPENING BRIEF OF APPELLANT CHRISTOPHER KING, J.D.

Christopher King, J.D. APPELLANT

515 E. Fulton Street
Mt. Vernon, WA 98273
kingcast955@icloud.com

Ryan Agnew ATTORNEY FOR APPELLEES

P.O. Box 601 BLACK EXCELLENCE IN CANNABIS
Milton, WA 98354-0601 AND PETER MANNING
agnew.rr@gmail.com
TABLE OF CONTENTS...................................................................................................................i

TABLE OF AUTHORITIES............................................................................................................ii

I. Introduction and Request for Instanter Filing……..………………………………1

II. Jurisdictional Statement……………………………….. …………………………………..5

III. Issues Presented…………………………………….…….. …………………………………..5

IV. Statement of the Case……………………………….….. ……………….…………………..5

V. Summary of Argument…………………..……….…….. …………………………………..6

VI. Law and Argument…………………………….…….. ………………………………..……..7

A. Standard of Review……………………………………………………………………….7
B. Appellant’s Relevant Case Law Shows that the Case Should
Have Proceeded to Trial………………………………………………………………..7

VII. Conclusion………….…………………………………….…….. ………………….………..…10

VIII. Certificate of Compliance ………………….…….. ……………………………………...11

IX. Certificate of Service ……………………………….. ……………………………………..12

i
 TABLE OF AUTHORITIES

Cases

Bertelsen v. Harris, 537 F.3d 1047, 1056 (9th Cir. 2008)…………………………………7

Estate of Summer Jolie Williams v. City of Seattle et al. King County No. 20-2-14351-
SEA………………………………………………………………………………………..7

Herron v. Tribune Pub. Co., Inc., 108 Wn.2d 162, 736 P.2d 249 (1987) (quoting Caruso
v. Local Union 690 of Int'l Bhd. of Teamsters, 100 Wn.2d 343, 349, 670 P.2d 240
(1983)). ………………………………………..…………………………………………..7

Statutes

I502…………….………………………………………………..……………………………………………2

Civil Rule 15 ...................................................................................................................................7

Media and Treatises

https://www.youtube.com/watch?v=jo_aikivXDg&t
The Sheer Madness of Plymouth County DA in the Darrell Jones Retrial………….1

https://www.change.org/p/u-s-department-of-justice-justice-for-african-americans-in-
washington-state-s-billion-dollar-cannabis-industry
Justice for AFRICAN AMERICANS Forced out of Washington State's Cannabis
Industry……………………………………………………………………..……..2

https://www.youtube.com/watch?v=E5FyNGdNhP4
Black Original Cannabis License Holders Tell the Truth About Seattle Racism:
Uglier than New Jersey………………………………………………………………….2

Straight from Mr. Manning’s mouth @2:55 et seq:

https://www.youtube.com/watch?v=hUHPahv9exI&t
Black Excellence in Cannabis Blasts WSLCB & Seattle Cannabis Racism
with Chris King and Friends
May 25, 2022……………………………………………………………………….4

ii
 1 INTRODUCTION AND REQUEST FOR
INSTANTER FILING
2
3 At bottom this case involves a matter of immense public importance in a World
4 where virtually all of the original Black Pioneers of medical cannabis who stuck their necks
5
out to establish a legal Washington market have been forced out of business and otherwise
6
exploited. In an email yesterday to Washington Statespeople the exchange read, in pertinent
7
8 part:
9 From: Christopher King <kingcast955@icloud.com>
Sent: Thursday, July 27, 2023 11:25 AM
10 To: brenda@birdforgovernor.com <brenda@birdforgovernor.com>; corey@birdforgovernor.com <co-
rey@birdforgovernor.com>; Darnell, Michelle <michelledar-
11 nell7@gmail.com>; drew.stokesbary@leg.wa.gov <drew.stokesbary@leg.wa.gov>; dan.griffey@leg.wa.g
12 ov <dan.griffey@leg.wa.gov>; Mary.Soderlind@leg.wa.gov <Mary.Soder-
lind@leg.wa.gov>; jacquelin.maycumber@leg.wa.gov <jacquelin.maycumber@leg.wa.gov>
13 Cc: sami sami <sa615615615@gmail.com>; Libby Marchel <libbymarchel@gmail.com>; John Jung
<fivedot11@gmail.com>; James s <jameskshelton@yahoo.com>; Ben Shelton <bshelton500@hot-
14 mail.com>; Anne Continelli <anne.continelli@outlook.com>

15 Subject: Black Cannabis Pioneers Deserve Better.

16 Good Day folks,

17
The situation that landed my Black Cannabis pioneer friends in the 9th Circuit Court of
18 Appeals must be addressed by this Legislature:
19
The WSLCB has done a complete turnaround from the initial position on Cannabis Social
20 Equity being put in place to help the Black medical pioneers who stuck their necks out in
the market to pave the way for the whites who replaced them during the so-called i502
21 lottery that was, according to NAACP economic advisor Darrell Powell, "a sham."
22
Now we even have people like Ian Eisenberg saying that the medicals were not legal, when
23 the i502 program gave credence to individuals who were bud tenders in medical when it
came time to obtain i502 licenses so that doesn't work either. Anne Continelli, a New Eng-
24 land media professional and journalist is preparing a global podcast on this matter. I have
25 known her for many years now going back to our joint efforts to expose the injustice when
one Darrell Jones - a Black Man -- was wrongfully imprisoned for thirty years for a crime
26 he did not commit.
27 https://www.youtube.com/watch?v=jo_aikivXDg&t
The Sheer Madness of Plymouth County DA in the Darrell Jones Retrial
28
1
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31
 1 https://www.change.org/p/u-s-department-of-justice-justice-for-african-americans-in-
washington-state-s-billion-dollar-cannabis-industry
2
3 Justice for AFRICAN AMERICANS Forced out of Washington State's Cannabis Industry
4
5

6
7
8
9
10
11
12
Please contact Sami Saad at the email above or at 206.742.1535 for more information.
13
14
n

15
16

17
18

19
20
21
22
23
24 On Jul 27, 2023, at 8:47 AM, Anne Continelli <anne.continelli@outlook.com> wrote:
25
Though technically it was an affirmative defense, Chris is right in that one cannot ignore
26 the fact that the priority system established for i502 specifically included previous work in
cannabis as one of the factors involved in raising one up the priority ladder. This demon-
27 strates that the state acknowledged a de facto legality at play. It's an astute observation,
28 Chris.
2
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31
 1
One also must ask, as I do in the podcast, the culpability that the state holds in (1) not
2
signing into law what had gone to referendum and had been voted on by the people, and (2)
3 then allowing people to open up medical dispensaries, granting them business licenses, etc.,
allowing them to put their blood, sweat, and tears into building their own business and
4 striving for the American dream, only to later be crushed by a new system that favored
5 corporations, wealthy and connected people, etc, over the small business owner.

6 As Kevin Shelton said in his interview,

7
"We did everything we had always been told to do. We pulled ourselves up by our boot-
8 straps."
9 Sizzle reel for the podcast is coming soon.
10
Best,
11 Anne
12
Anne Continelli
13 Producer/Filmmaker
anne.continelli@outlook.com
14 781.526.6350
15
Team Leader, Senior Animation Specialist
16 JoVE, Inc.
anne.continelli@jove.com
17 781.526.6350
18

19 *********
20
The point of this is that Plaintiff-Appellant (hereinafter “King”) spent substantial
21
amounts of time, mental and Spiritual energy defining the voice of Black Excellence in
22
23 Cannabis (hereinafter “BEiC”) as noted by King from the living room of Defendant-Appel-

24 lee Peter Manning (“Manning”). Uncontroverted evidence by way of Declaration and sup-
25
porting documents from Aaron Barfield further establish the fact that he conceived and
26
managed the social site “Black Excellence in Cannabis” only to have Manning turncoat the
27
28 entire mission to take a different path and register the name in a commercial sense.
3
30
31
 1 This case represents a microcosm of what is wrong with this system and how Blacks
2
have been set against themselves in a war of attrition. The only reason this short Brief was
3
not filed last week is because King wrote the due date on the wrong calendar date on this
4
5 calendar; instead of 21 July he set it for 28 July. In reality it turns out according to the Clerk

6 in a conversation this afternoon the Brief was due on July 24, 2023. Fortunately most of
7
the Brief had already been drafted so it only took an hour or so to complete it and get it filed
8
ASAP. As there is no prejudice whatsoever to any Party or to the Court King respectfully
9
10 asks the Court to hear the case on the merits because substantial Justice – and Judicial Econ-

11 omy – are supported by review.

12
The issues are clearly important and the Court will see that straight from Manning’s
13
own mouth before he turncoated without notice to Plaintiff or to BEiC founder Aaron Bar-
14
15 field.

16 Straight from Mr. Manning’s mouth @2:55 et seq:

https://www.youtube.com/watch?v=hUHPahv9exI&t
17 Black Excellence in Cannabis Blasts WSLCB & Seattle Cannabis Racism
with Chris King and Friends
18
103 views
19
20
21
22
23
24
25
26
27
28
4
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 1 JURISDICTIONAL STATEMENT
2
This case comes to the Court pursuant to a Notice of Appeal filed on or about May
3
8, 2023.
4
5 ISSUE(S) PRESENTED

6 1. Whether witness Aaron Barfield provided substantial reliable Evidence that he

was the primary and maintaining founder of the social movement and social me-
7
dia websites “Black Excellence in Cannabis.”
8
2. Whether King has demonstrated that he provided mental, intellectual and spir-
9 itual energy to Black Excellence in Cannabis prior to Manning and others creat-
10 ing a commercial entity with the Washington Secretary of State bearing the name
“Black Excellence in Cannabis” without telling Messrs. Barfield or King.
11
3. Whether the fact that Manning defamed both King and Barfield with false com-
12 ments for criminality (Barfield) and disbarment (King) provides indicia of ill in-
13 tent. See Appendix A.

14 4. Whether the Lower Court’s failure to recognize King’s involvement with BEiC
as granting him an independent right to Amend the Complaint a second time as
15 a BEiC Member violates the Principle that Rule 15 shall be liberally-construed.
16

17 STATEMENT OF THE CASE

18
Plaintiff-Appellant filed an initial lawsuit on or about October 31, 2022, and a First
19
Amended Complaint on or about November 8, 2022. Defendants-Appellees filed a Demur-
20
21 rer on or about March 2, 2023, and the Lower Court dismissed the Case on or about April

22 7, 2023 stating that “Plaintiff’s new claims would be markedly different from those asserted
23
herein.” Plaintiff-Appellant filed a Notice of Appeal on March 15, 2020 and now files this
24
Opening Brief.
25
26
27
28
5
30
31
 1 SUMMARY OF THE ARGUMENT
2 Plaintiff-Appellant has demonstrated that he has a vested interest in the entity
3
known as Black Excellence in Cannabis whose Goodwill was stolen by Defendants when
4
they registered Black Excellence in Cannabis with the Washington Secretary of State with-
5

6 out informing the founder Aaron Barfield or other participants such as Plaintiff-Appellant.

7 As such, the Lower Court committed Reversible Error under any standard.
8
9
10
11
12
13
14
15
16

17
18

19
20
21
22
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24
25
26
27
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 1 LAW AND ARGUMENT
2
I. APPELLANT’S STATED INTEREST IN BLACK EXCELLENCE IN CAN-
3 NABIS SHOULD HAVE ALLOWED FOR AMENDMENT IRRESPECTIVE
OF TAXPAYER STANDING TO SUE
4
5 A. Standard Of Review

6 The case turns on an interpretation of Law, because the uncontroverted facts clearly
7
demonstrate that King used video and Declaratory statements to demonstrate that he as a
8
member of Black Excellence in Cannabis. As such the Court erred on the Law by not al-
9
10 lowing him to Amend the Complaint to place him as BEiC Member Plaintiff as opposed to

11 a taxpayer Plaintiff. Bertelsen v. Harris, 537 F.3d 1047, 1056 (9th Cir. 2008).
12
B. Appellant’s Relevant Case Law Shows that the Case Should Have Pro-
13 ceeded to Trial.
14 In the Lower Court Plaintiff cited to Estate of Summer Jolie Williams v. City of Se-
15 attle et al. King County No. 20-2-14351-SEA in his prior filings and in Open Court. Plain-
16 tiff now then produces the exact same argument in that case where the Court GRANTED
17 Leave to Amend, to wit:
18
Civil Rule 15 provides that a party may amend a pleading by leave of the court,
19 “and leave shall be freely given when justice so requires.” Courts universally take
the “freely given” requirement seriously. Leave should be given “except where
20
prejudice to the opposing party would result.” Herron v. Tribune Pub. Co., Inc.,
21 108 Wn.2d 162, 736 P.2d 249 (1987) (quoting Caruso v. Local Union 690 of Int'l
Bhd. of Teamsters, 100 Wn.2d 343, 349, 670 P.2d 240 (1983)).
22
23 The proposed amendment to the complaint benefits Plaintiffs by alleging additional
facts and causes of action, and by joining additional Plaintiffs with similar allega-
24 tions as well as parties that may be adjudged liable for their damages. This case
was only recently filed in late September and trial is still seven months away.
25
26 One could substitute Plaintiff King for the Plaintiff’s arguments in that case because

27 they mirror each other, and moreover what was not mentioned in that case – Judicial Econ-

28 omy – also clearly militates in favor of Leave to Amend. So what has Plaintiff King missed
7
30
31
 1 in this example? Plaintiff’s position is clearly noted in the FAC para 11 as someone whose
2 Intellectual Property and viewpoint are being violated:
3
c) Manning telephoned Plaintiff, accused him of being “counter intelligence” and
4 asked him “why do you always put pictures in your Briefs?” Plaintiff told him “Be-
5 cause I’m a journalist by training, I’ve done this for years as a licensed Attorney
and advocate in general, and because pictures are less likely to lie than people in
6 the pictures.”
7 d) Defendants Manning and Asai continually appear before the WSLCB Board
8 meetings and falsely proclaim that Plaintiff, Saad, Shelton and their friend Libby
Haines are unreasonably attacking only Ollie Garrett. These are materially false
9 statements that are known to be false by Defendants and by any reasonable person
10
given the multitude of media showing that these individuals have openly and fre-
quently criticized the entire Board. These statements are being published to con-
11 vince known and unknown third parties that Plaintiff, Saad, the Sheltons and Ms.
Haines are ignorant and on a personal vendetta against a Black woman, when noth-
12 ing could be further from the truth. Notwithstanding same, Defendant Manning as
13 recently as 26 October, 2022 stated “Leave the Sister ALONE!”

14 First of all Plaintiff is not even adding a new Plaintiff. Second, there are no new
15 Defendants. Third, where is the Prejudice to Defendants? Fourth, Judicial Economy has
16 been thwarted. Fifth, the Theory of the Case is only marginally changed to reflect the cur-
17 rent existing Plaintiff’s Intellectual Property and Group Rights Interest. The primary point

18 of focus in the case has always been on Aaron Barfield’s Intellectual Property and the Good-

19
will and Path of Black Excellence in Cannabis, adding Plaintiff King’s Intellectual Property
concerns simply is not a substantial departure from the law of the case and Judicial Econ-
20
omy in these circumstances always favors Amendment; just as the Court agreed in Williams,
21
supra and any other approach begets an Equal Protection and Arbitrary and Capricious is-
22
sue.
23
Query, how exactly are Plaintiff’s new claims so divergent from what he already
24
articulated in his FAC, seen above? As noted throughout the filings Peter Manning repeat-
25
edly turncoated BEiC and everything it stands for by now claiming that BEiC has no prob-
26 lem with many politicians when in reality it is only *HIS* ill-conceived version of BEiC
27 that feels this way.
28
8
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 1 Standing as a Member of Black Excellence.1
2
Ultimately the Taxpayer question is a red herring: The exact same nucleus of opera-
3 tive facts cloaks Plaintiff with enough Standing and Substantive merit to gain a Jury Trial
4 for very simply reasons: Any member of a group in this circumstance has the right to contest
5 another member usurping the name of the group to covet financial gain by forming an LLC
6 and materially changing the focus and directive of the group. Let us examine the following
7 scenario:
8 Plaintiff King is clearly a founder of “Big Twin Motorcycle Group.” For years the
9 group focuses on European motorcycles with twin engine configuration with a focus on

10 road racing sport models. Next, Ray Weishar joins the group. All of his actions are initially
consistent with the goals of the group. Next, Mike Hailwood joins the group and is a sig-
11
nificant and valued contributor. He even makes videos with the group and has history as a
12
journalist and practicing Attorney.
13
A year or two later Mr. Weishar professes that European bikes are trash and starts
14
espousing Harley-Davidson motorcycles and lifestyles. Moreover, he even takes the name
15
of “Big Twin Motorcycle Group” and licenses a corporate entity with it. Significantly, he
16
does this without any notification to King or Hailwood or others who maintain that he is
17
perverting the goals of the group with his newfound allegiance to noisy, slow and poorly-
18 assembled American machinery.
19 King and Hailwood are incensed, and King appoints Hailwood as a group representa-
20 tive given his dedication to purpose and experience as a professional journalist and trial
21 Attorney. Hailwood sues on behalf of the group to stop the unlawful use of the name, with
22 a Declaration from the founder. . What result?
23
24
25 1
This subject was raised during one of the prior Public Court hearings and at the time, the es-
26 sence of the discussion was that we had not crossed that bridge yet as Aaron Barfield had not
weighed in. Well we are now most assuredly on the far side of that bridge today given the Sworn
27 Declaration of one Aaron Barfield as seen at Appendix B.
28
9
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 1 A Jury is the result, because only a Jury can hear all of the relevant evidence to
2 determine what is Truth, what is worth knowing and how the value judgment should be
3 made given King, Hailwood and Weishar’s contributions over the years and the proven
4 mission of the group.

5 There are no sanctions. There are no costs assessed. There is just a Jury hearing all

6 of the evidence and making its lawful findings. Period.

7
CONCLUSION
8
9 You can’t just take peoples’ ideas, their hard work and their brain trust and then at

10 once subvert the mission of the underlying group and attempt to financially capitalize on

11 the Goodwill of the group, yet that is precisely what Defendants-Appellees have done. Even
if no money has yet changed hands, the likelihood that it will – given that it is a registered
12
corporation for a reason – provides this Honorable Court all of the ripeness that it needs to
13
do the right thing and remand so that Plaintiff may continue his case toward Trial on the
14
Merits. For that matter even if a Jury decides that King is wrong, the point here we must
15
focus on is whether King’s stated facts and claims in his FAC tie him in as a valued Member
16
of BEiC and ipso facto grant him Standing to sue. The face of King’s FAC – not to mention
17
the Declaration of founder Aaron Barfield – indeed clearly provide grounds for reversal and
18 Remand.
19
20 Respectfully submitted,
_________________________
21 CHRISTOPHER KING, J.D.
22
APPELLANT
23
24
25
Date: July 28, 2023
26
515 E. Fulton Street
27
Mt. Vernon, WA 98273
28
10
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31
 1 CERTIFICATE OF COMPLIANCE
2
Pursuant to Fed. R. App. P. 32(a)(7)(C), I certify that:
3
This brief complies with the type-volume limitation of Fed. R. App. P. 32(a)(7)(B)
4
5 because this brief contains 6002
2,671 words, excluding the parts of the brief exempted by Fed.

6 R. App. P. 32(a)(7)(B)(iii).
7
This brief complies with the typeface requirements of Fed. R. App. P. 32(a)(5) and
8
the type style requirements of Fed. R. App. P. 32(a)(6) because this brief has been prepared
9
10 in a proportionately spaced typeface using MS Word 16.76 using Times New Roman 14-

11 point font.
12
13
14 _________________________
15 CHRISTOPHER KING, J.D.

16 APPELLANT
17
18

19
20
Date: July 28, 2023
21
515 E. Fulton Street
22
Mt. Vernon, WA 98273
23
24
25
26
27
28
11
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 1 CERTIFICATE OF SERVICE
2
I hereby certify that on July 28, 2023 I electronically filed the foregoing with the
3
Clerk of the Court by and through the electronic portal designed to effectuate Service on
4
5 Counsel for Appellees. Further, an emailed copy was sent on this Day as well to:

6 Ryan Agnew ATTORNEY FOR APPELLEES

P.O. Box 601 BLACK EXCELLENCE IN CANNABIS
7
Milton, WA 98354-0601 AND PETER MANNING
8 agnew.rr@gmail.com
9
10 _________________________
CHRISTOPHER KING, J.D.
11
APPELLANT
12
13
14 Date: July 28, 2023
15
515 E. Fulton Street
16 Mt. Vernon, WA 98273
17
18

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 1 APPENDIX A
2
3
4
5

6
7
8
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16

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18

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APPENDIX B