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IN THE UNITED STATES DISTRICT COURT NEW HAMPSHIRE CHRISTOPHER KING, J.D. a/k/a KINGCAST.NET, Plaintiff-Petitioner, v.

FRIENDS OF KELLY AYOTTE, et al., Defendants. ) ) ) )

CASE NO. 2010-CV-501 JJM JUDGE JOHN J. MCCONNELL, JR. MAGISTRATE _________________

PLAINTIFFS OBJECTION TO DEFENDANTS 11TH HOUR ATTEMPT TO RECUSE JUDGE JOHN J. MCCONNELL, JR. AFTER THEY SAT ON THEIR HANDS AND WATCHED HIM ISSUE TWO PRIOR ORDERS WITH FULL KNOWLEDGE OF THE ALLEGED CONFLICT
Now comes Plaintiff, on less than one hours Notice, to provide his response, which is his email response to Defendants. Plaintiff notes that unlike Defendants he has been providing his view of the issues for more than a week now, whereas Defendants have attempted to sandbag Plaintiff as they were well aware of the Senate vote against His Honor from Day One.

I'll get back to you shortly. The fact that you all waited until the 11th hour to send this to me smacks of gamesmanship. As if none of you were aware of this Party-line Partisan vote from the get go. You guys think you're playing with an amateur don't you? I will respond to you in an hour, or by 4:15 pm. Do not, under any circumstances file anything with the Court until you hear back from me.

I am reviewing United States v. Evans, 262 F. Supp. 2d 1292 (2003) and other cases in the interim. Also attached I have provided a Second Supplemental Hearing Memorandum that I will be filing later today, and a comment-free YouTube link to a 50-second video in which Defendant Ayotte admits that her office should have taken action on my forgery complaint will be provided, along with a hard copy DVD for you immediately.
http://www.youtube.com/watch?v=9AcU6l3wkJc That is all.

Counsel: It is now 4:19 I apologize so sincerely for being 4 minutes "late." I have read enough to see that I am not in accord with your Motion not only because of United States v. Evans, but because you are estopped from arguing this point after you sat back on your hands and allowed the Court to issue two decisions in your favor.... now that you are worried that the Court has given you everything it is going to give you [you] go Judge shopping. I'm not down with that. I had much more to go on with Magistrate Judge Landya B. McCafferty working for McLane Graf and working next to and under NH Bar President Jennifer Parent and Jack Middleton and not even mentioning it, as if I was some hayseed who never practiced in Federal (or any other) court. From Evans, infra, in which a Defense Counsel himself -- once removed from Defendant Ayotte's Position as litigant -- wrote a letter in opposition to confirmation of a Jurist: Even assuming (contrary to prevailing law) that an appearance of bias against an attorney is a sufficient basis for recusal, the grounds alleged in the motion would fall well short of the appropriate showing. Defense counsel has a First Amendment right to petition members of Congress and to suggest how they should vote on judicial nominees. But such communications "are probative of [an attorney's] dislike for [a judicial nominee], not the other way around." 17 Defense counsel's communications "may very well establish [his] feelings toward [the court], but they have "no tendency to show [the [*1296] court's] feelings towards" defense counsel. 18 The undersigned bears no animosity towards defense counsel for expressing his views. File your motion and I shall file my Memorandum Contra the minute I see it posted on ECF and yes I will basically just use this email chain as my response.

See also Cheney v. United States Dist. Court, 541 U.S. 913 (2004).

Respectfully submitted, /s/ Christopher King, J.D. _____________________________ Christopher King, J.D. http://KingCast.net -- Reel News for Real People 617.543.8085

CERTIFICATE OF SERVICE I the undersigned, solemnly swear that a true copy of this Opposition was electronically delivered on 26 October 2010 to: Jennifer Parent and Jack Middleton, Esq. City Hall Plaza 900 Elm Street Manchester, NH 03101 Gordon MacDonald, Esq. Nixon Peabody LLP 900 Elm Street Manchester, NH 03101 Brian Cullen, Esq. 10 East Pearl Street Nashua, NH 03060 /s/Christopher King, J.D. __________________________________ KingCast.net By and through Christopher King, J.D.

617.543.8085m

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