IN

THE SUPERIOR COURT OF THE STATE OF DELAWARE

IN AND FOR KENT COUNTY


CHRISTOPHER KING, d/b/a KingCast/Mortgage Movies,
)







) CASE NO. K15C-03-028

Plaintiff,





v.







) JUDGE YOUNG

BETTY LOU MCKENNA, HOLLY MALONE


)
and JOHN PARADEE, ESQ.






Defendants.




)


PLAINTIFFS FINAL MOTION TO RECUSE JUDGE ROBERT B. YOUNG
WITH SUPPLEMENTAL LAW AND TYPOGRAPHIC EDITS

I.
The August 5 2015 Payment of Trial Fees for a Trial Scheduled November 14,
2016 Should Not Result in a Draconian Bar to Filing Further Memoranda in
this Case; Judge Young was deceitfully Wrong on the Key Case of Iacobucci v.
Boulter and Ignored Pomykacz v. Village of West Wildwood out of Unlawful
Bias Against Plaintiff.

Plaintiff has via overnight courier retendered the $150 Trial Fee along with a copy
of all documents heretofore rejected by this Court: Plaintiff paid his Trial Fee on or about 5
August, 2015. Prior to that time, he never received any notice from Judge Robert B. Young
that the Trial Fee must be paid on or before 23 July 2015. In point of fact, that Court never
took adverse action until a full week later, and only after Plaintiff filed his Waiver of Jury
Trial, noting that he feels particularly unsafe in Delaware given the five (5) mysterious
lynching deaths/murders of black males that AG Denn claims were suicides. Appendix A.

Meanwhile after mentioning these lynchings in a global email to supporters, State

employees, First Amendment attorneys and several high-powered area attorneys Plaintiff
received an email from Detective Hill in which he declined to provide safety for Plaintiff if
he came to the Forum State whilst simultaneously threatening Plaintiff that he could be
subject to prosecution for the content of the emails that was alarming. Plaintiff, with
notice, taped the entire conversation and put it out for the World to hear on 6 August, 2015.

First Amendment Lawsuits Show Markell, AG Biden, AG Denn Coverup of Black Lynchings

http://mortgagemovies.blogspot.com/2015/08/caught-on-tape-kingcast-and-
mortgage.html
https://www.youtube.com/watch?v=QibeMFiaxgM

Only AFTER production of this video did the Court determine that Plaintiffs filings
were allegedly Out of Rule. These filings mentioned the lynchings, the lies by Judge Young
about a major case (Iacobucci) and the fundamental flaw of logic by the Court and
Defendants in that they used public meeting law to strike Plaintiffs Constitutional claims,
only now to turn around and claim that Tisdale is completely irrelevant because it is based
on public meeting law.
This unlawful pattern trails back to the Court twice returning the SD video card
Offer of Proof previously submitted, showing Plaintiffs true modus operandi when shooting
video in a County Recorders Office, which is NOT to go into private areas and such. But
Judge Young, in light of his bias, simply MUST whitewash the Record to make Plaintiffs
position appear completely untenable, when the Plain Trust is that his conduct is
commonplace in every other Jurisdiction in the Country. In. The. Country.

Only Dirty Deeds Recorders Like Kent County DE's Betty

Lou McKenna Restrict Media Access and Cameras
https://www.youtube.com/watch?v=4uPuF-Z_Ft4

Moreover, also out of unlawful bias and hegemony, Judge Young ignored Pomykacz
v. Village of West Wildwood as well, a case in which a citizen journalist was protected by the
First Amendment after shooting police personnel at the police station at all hours of the day.
Pomykacz was a self-described citizen activist who expressed concern that a
suspected romance between the towns mayor and a police officer were leading to
nepotism, conflicts of interest and preferential treatment. These suspicions led

Pomykacz to monitor the two, which included taking

photographs. Eventually she was arrested on charges of stalking, though the
charges were downgraded to harassment.

Pomykacz ended up filing suit asserting, among other things, that she was arrested in
violation of the First Amendment retaliation for her monitoring activities (emphasis
added so the Defendants, Court and Reviewing Court can see where they have been
completely disingenuous to date).

On the night of October 7, 2002, on her way to Wildwood, Pomykacz drove past
the borough municipal building and observed Officer Ferentz working on
renovations while she was on duty. Later that night, after Pomykacz had returned
from Wildwood, she photographed Officer Ferentz in the police

headquarters. 7 Another police officer and [*508] Mayor Fox were also
present in the police station at the time. According to Pomykacz, Mayor Fox came
out of the building and began yelling at her. Pomykacz walked home without
responding (emphasis added so the Defendants, Court and Reviewing Court can see
where they have been completely disingenuous to date).

U.S. District Judge Joseph E. Irenas noted,

Pomykacz has put forth sufficient evidence that she was a concerned citizen who at
times spoke her mind to Borough [*513] officials and other citizens about her
concerns regarding the official conduct of the police department and the mayor.
Such speech is clearly protected by the First Amendment. 14 See Mills v.
Alabama, 384 U.S. 214, 218, 86 S. Ct. 1434, 16 L. Ed. 2d 484 (1966) HN15 ("a major
purpose of [the First] Amendment was to protect the free discussion of
governmental affairs."); Roth v. United States, 354 U.S. 476, 484, 77 S. Ct. 1304, 1 L.
Ed. 2d 1498 (1957) ("The protection given speech and press was fashioned to
assure unfettered interchange of ideas for the bringing about of political and social
changes desired by the people.").

That is a virtually identical case from the Third Circuit but because of unlawful bias Judge
Young and the Defendants ignored it. It isnt the first time that First and Third Circuit
judges citing Iacobucci have completely disagreed with Judge Youngs findings, because
his findings were clearly UNLAWFUL. Here is the more of the substance of what Plaintiff
stated, and it is all rock solid and it is the real reason why Judge Young has resorted to
striking all Docket entries:
The point is, Defendants and the Court cannot have it both ways: They claim
that Tisdale is not relevant at para 6 of their Memorandum because it involves a public
meeting. But If public body/public meeting analyses are inapplicable now, then they were
inapplicable in the first place -- and theres yet another compelling reason for the Supreme
Court of the United States to give this case a prompt Remand in the name of Justice. Gotcha.
So now Defendants claim that public meeting analysis is not relevant to Plaintiffs
claims well then that conclusively provides proof that the Courts underlying rationale. Is
wrong and Plaintiff thanks Defendants for pointing that out because they and the Court are
so caught up in their lies that they cant keep them straight. In any event, recall that the
Court specifically cited to Whiteland woods as particularly helpful and instructive.

Well come to find out that Plaintiff said this was not a public meeting case, ab initio,
while the Court was busy giving him the bums rush earlier: It is the Pomykacz, Cirelli,
Iacobucci and Glik cases and their progeny, including Third Circuits Montgomery v.
Killingsworth, 2015 U.S. Dist. LEXIS 7152 (January 22, 2015) that are most germane because
they all involve journalists filming public officials in and out of their offices.
Theres the a-ha moment of this entire case and Defendants offered it up on a
platter. That having been said, Plaintiff maintains his public body/public meeting
arguments in the alternative and points to the 11th Circuit Tisdale v. Gravitt, 51 F. Supp. 3d
1378 (N.D. Georgia 2014) case to show that current Courts disagree with the ancient
Whiteland Woods case.
Interestingly, in Defendants Motion for Summary Judgment para 8 they try to
dismiss Peloquin, Tarus and Iacobucci by stating that the Court already analyzed them in the
prior order, but alas that analysis was fundamentally wrong as proved by Iacobucci as well
as the newly-discovered Third Circuit and First Circuit (NY) 2015 First Amendment cases.
As Plaintiff stated in prior Memoranda:
Next, the Courts Patent Misrepresentation (read: lie) -- about Iacobucci v.
Boulter, 1997 U.S. Dist. Lexis 7010, No. CIV.A. 94-10531 (D.Mass, Mar. 26, 1997) is
startling. Iacobucci specifically found that an independent reporter has a protected
right under the First Amendment and state law to videotape public meetings and the
events that occurred in the hallways of a public building.

But read p17 FN 47 of the courts Opinion where Judge Young tries to limit the
holding to Fourth Amendment Grounds he writes:
(holding rested upon whether Officer had probable cause to arrest video reporter
for recording public event, implicating the Fourth Amendment)
.. the problem is, one does not get to the Fourth without the First, as noted by the
Iacobucci Court, again, so simple as other courts concur: From Iacobucci (cited in Glik, infra).
In the next decade, the SJC narrowed this definition of disorderly conduct to
encompass only activities not implicating the lawful exercise of a First Amendment
right. .
and
Boulter's repeated demands that Iacobucci cease recording do not change the
disorderly conduct calculus. A police officer is not a law unto himself; he cannot give
an order that has no colorable legal basis and then arrest a person who defies it. So
it is here: because Iacobucci's activities were peaceful, not performed in derogation
of any law, and done in the exercise of his First Amendment rights (emphasis
added lest the Court and Defendants miss it again) Boulter lacked the
authority to stop them. Id at 678.

(emphasis added to protect against the sort of intellectual disingenuity that has
plagued this case, as noted in the following video on Plaintiffs YouTube channel,
which is approaching 2,500 subscribers and 2M views.

And quite frankly, for the coup de gras, the Third Circuit Federal Judges who outrank

Judge Young understand it as well so Judge Young should recognize that the Third Circuit
recetly cited Iacobucci and Glik just this year prior to Plaintiff filing suit. This Court
ignored Glik when Plaintiff raised it. The fact of the matter is, if a citizen in the Third Circuit
is entitled to politely criticize a police officer during the prosecution of his or her duties,
then Plaintiff had dang well better be permitted to ask a couple of polite questions at the
County Recorders Office. See Montgomery v. Killingsworth, 2015 U.S. Dist. LEXIS
7152 (January 22, 2015).
In Iacobucci v. Boulter, the First Circuit concluded that the plaintiff, Iacobucci, had
a First Amendment right to film local government officials who were conducting
public business in a public building. 193 F.3d 14, 25 (1st Cir. 1999). Iacobucci was
arrested after he refused to stop filming several town commissioners while they
were discussing the possible approval of an applicant's building permit. Id. at 18.
Charged with disorderly conduct and disrupting a public assembly, Iacobucci spent
four hours in custody, though the charges were later dismissed. Id. Iacobucci
initiated a 1983 suit in which he claimed false arrest and excessive force. Id. After
losing in the trial court, the arresting officer appealed, contending he was entitled to
qualified immunity on those claims. Id. at 21-22. Rejecting that argument, the First
Circuit held that Iacobucci's "right to act as he did without being arrested for
disorderly conduct" was clearly established at the time of his arrest. Id. at 24. In so
holding, the First Circuit found that "Iacobucci's activities were peaceful, not
performed in derogation of any law, and done in the exercise of his First
Amendment rights." Id. at 25.

Peaceful criticism of a police officer performing his duties in a public place is a
protected activity under the First Amendment. As the Court established in City of
Houston, Texas v. Hill, "the First Amendment protects a significant amount of verbal
criticism and challenge directed at police officers." 482 U.S. 451, 461, 107 S. Ct.
2502, 96 L. Ed. 2d 398 (1987). This type of speech is necessary to protect and
preserve because "[t]he freedom of individuals verbally to oppose or challenge
police action without thereby risking arrest is one of the principal characteristics by
which we distinguish a free nation from a police state." Id. at 462-63.

Accord Gaymon v. Borough of Collingdale, 2015 U.S. Dist. LEXIS 93014 (July 17, 2015).

In contrast, qualified immunity was rejected for the remaining First
Amendment claim because "peaceful criticism of a police officer that neither
obstructs an investigation nor jeopardizes a police officer's safety has strong social
value, serving as a valuable check on state power, and is therefore protected under
the First Amendment." Killingsworth, 2015 U.S. Dist. LEXIS 7152, 2015 WL
289934, at *8 (citing Gentile v. State Bar of Nev., 501 U.S. 1030, 1034, 111 S. Ct.
2720, 115 L. Ed. 2d 888 (1991) ("There is no question that speech critical of the
exercise of the State's power lies at the very center of the First Amendment.").7

There is yet more 2015 Iacobucci Analysis, this time from New York. See Higginbotham v. City
of New York, 2015 U.S. Dist. LEXIS 62227 (May 12 2015)
The Court concludes, however, that the right to record police activity in public, at
least in the case of a journalist who is otherwise unconnected to the events
recorded, was in fact "clearly established" at the time of the events alleged in the
complaint. When neither the Supreme Court nor the Second Circuit has decided an
issue, a court "may nonetheless treat the law as clearly established if decisions from
. . . other circuits [*23] 'clearly foreshadow a particular ruling on the
issue.'" Terebesi v. Torreso, 764 F.3d 217, 231 (2d Cir. 2014) (quoting Scott v.
Fischer, 616 F.3d 100, 105 (2d Cir. 2010)); see also Ashcroft v. al-Kidd, 131 S. Ct.
2074, 2084, 179 L. Ed. 2d 1149 (2011) (requiring, in the absence of controlling
authority, "a robust 'consensus of cases of persuasive authority'" (quoting Wilson v.
Layne, 526 U.S. 603, 617, 119 S. Ct. 1692, 143 L. Ed. 2d 818 (1999))).

By November 2011, the First, Ninth and Eleventh Circuits had all concluded that the
right exists. So had a number of district courts. See Pomykacz v. Borough of West
Wildwood, 438 F. Supp. 2d 504, 512-13 (D.N.J. 2006) (denying summary judgment
in a First Amendment retaliation claim involving a plaintiff who was arrested for
repeatedly photographing a police officer);Robinson v. Fetterman, 378 F. Supp. 2d
534, 541 (E.D. Pa. 2005) (holding that the plaintiff's "recording the activities of
Pennsylvania state troopers as they went about their duties on a public highway"
was protected by the First Amendment);Alliance to End Repression v. City of
Chicago, No. 74 C 3268, 2000 U.S. Dist. LEXIS 6342, 2000 WL 562480, at *21 (N.D. Ill.
May 8, 2000) (holding that "taking photographs of the police" was
"First Amendment conduct"); Connell v. Town of Hudson, 733 F. Supp. 465, 471
(D.N.H. 1990) (holding that the police's interest in securing an accident scene did
not outweigh the plaintiff's right to photograph the scene, and rejecting the
defendants' qualified immunity argument); Channel 10, Inc. v. Gunnarson, 337 F.
Supp. 634, 638 (D. Minn. 1972) (recognizing the right of a newsman to film a crime
scene from any location to which the general public had access, unless he
unreasonably interfered with or endangered the police).

The Court is unaware of any decision holding that the recording of police activity by
a journalist otherwise [*24] unconnected to the events recorded is categorically not
protected (rather than holding merely that the right to record was not "clearly
established"). At the time of Higginbotham's arrest, there was thus a "robust
consensus of persuasive authority" in favor of the right that "clearly foreshadowed"
an analogous ruling by the Second Circuit or the Supreme Court. See Crawford v.
Geiger, 996 F. Supp. 2d 603, 615-17 (N.D. Ohio 2014) (holding that the right to
openly film police officers was clearly established by 2012, despite the absence of
Sixth Circuit authority).
In sum, the point is that while a Judge could argue that Pomykacz shot pictures through a window,
while Plaintiff was in the building, an unbiased Judge could never just truncate Discovery and rule that
there is clearly no possible way that Plaintiffs Constitutional claims had any merit. That is why Judge
Young put specific little items into the Record involving items that were not in the Record to start with, see
Section II, infra.

That is not just a simple case of a Court making an incorrect decision on which a
litigant cries sour grapes: No. Anyone with any Constitutional integrity knows that the Fourth
Amendment is not implicated in a case involving a journalist unless she or he has First
Amendment Rights, ab initio.
***********
II.

Judge Youngs Unlawful Bias: He Assumed Facts Not in the Record and
Intentionally Downplayed Plaintiffs Professional Acumen to Shade the Case in
the Light Most Favorable to Defendants in Violation of Several Judicial Canons.

As dictated by several cases set forth below some of which were ignored or
misrepresented in the dismissal of Plaintiffs Original Complaint (i.e. Pomykacz, Iacobucci
and Glik) -- there is simply no plausible way that this case can be decided on the Pleadings.
First of all it is pretty obvious as noted on prior occasion that Judge Young ignored
all of Plaintiffs professional accomplishments and even the description as set forth on the
Pleadings to malign Plaintiff as a guerrilla journalist. But thats not in the Record. What is
in the Record, is this:
THE PARTIES

2. Plaintiff is a former daily news reporter and escrow attorney who has
closed several dozen commercial real estate purchases and refinances. He has
successfully tried several First Amendment Jury Trials and has operated
several politically and legally-charged online journals over the past decade,
most notably Chris Kings First Amendment Page and Mortgage Movies
Journal.

That is what Plaintiff holds himself out to be as noted in the Complaint and thats all
the Court claimed to be reviewing, so the pejorative guerrilla nomenclature is reflective of
the short shrift that this Plaintiff ultimately received from the Court. Further, Plaintiff did
provide the Court with excerpts and materials from his website and such description
comports with the information on his website -- which was not once mentioned by the
Court. The Mortgage Movies Journal description has read this way for several years now:

Mortgage Movies Journal

Christopher King has worked in residential and corporate
real estate in various capacities for the past fifteen
years, clearing title, filing zoning applications and
reviewing wireless tower contracts. He and his
associates are now teaming to provide video coverage
of America's imploding Mortgage market. All images
video and text subject to copyright.

Mortgage Movies Journal

Christopher King has worked in residential and corporate real estate in various
capacities for the past fifteen years, clearing title, filing zoning applications and
reviewing wireless tower contracts. He and his associates are now teaming to provide
video coverage of America's imploding Mortgage market. All images video and text
subject to copyright.

So in the first instance, Plaintiff is not a guerrilla; he is a professional journalist as
well as a mortgage industry professional who has made hundreds of thousands (if not
millions) of dollars for the banking/mortgage industry. Higginbotham v. City of New
York, 2015 U.S. Dist. LEXIS 62227 (May 12 2015) explains why Judge Young did what he did
by
i.

Whitewashing the professional acumen.

ii.

Putting Plaintiff in an interior office near employee cubicles when he was

nowhere near either such place.

From Higginbotham (in addition to prior citation noting the proper analysis of Pomykacz):
Certainly, the right to record police activity in a public space is not without limits,
and some uncertainty may exist on its outer bounds. For instance, it may not apply
in particularly dangerous situations, if the recording interferes with the police
activity, if it [*26] is surreptitious, if it is done by the subject of the police activity, or
if the police activity is part of an undercover investigation. As alleged, however,
Higginbotham's conduct falls comfortably within the zone protected by
the First Amendment.

The complaint alleges that he was a professional journalist present to record a
public demonstration for broadcast and not a participant in the events leading up to
the arrest he was filming. There is nothing in the complaint suggesting that his
filming interfered with the arrest. Accordingly, and in light of the case law consensus
described above, a reasonable police officer would have been on notice that
retaliating against a non-participant, professional journalist for filming an arrest
under the circumstances alleged would violate the First Amendment.

......This is why Judge Young had to fashion Plaintiff as a "guerrilla journalist" and completely
ignore the professional acumen specifically stated in the complaint. And that is unlawful,
hegemonic and potentially racist bias.

***********
But going into the substance, there is more. Much more. As dictated by several cases
set forth below some of which were ignored or misrepresented in the dismissal of
Plaintiffs Original Complaint (i.e. Pomykacz, Iacobucci and Glik) -- there is simply no
plausible way that this case can be decided on the Pleadings. This time around if the Court
and Defendants actually respond to what Plaintiff wrote, we may be able to create a record
that is actually usable by a reviewing Court. Let us commence then, in light of the below
drawing evincing the fact that Plaintiffs attempted conduct in no ways threatened
employee privacy or the function of the office:
That is because the only items downstairs in the public area is a public foyer, a
guard desk, a service desk at which Defendant Malone stood alone, and a public hallway
leading to the back room where several public kiosks are situated.
As such, if the Court is at all interested in Truth and Justice, it would stop hiding
behind facts not alluded to in the Pleadings. To wit: Plaintiff was not seeking access to
Interior offices or to film employees of the Recorder of Deeds in their cubicles. SEE
Plaintiffs drawing on page 12.

10

The Review of Plaintiffs initial and Amended Complaint will reveal that Plaintiff
never sought nor implied such access. (29 June Opinion pp. 14-15, Fn 42). The Court
assumed facts not in the Record in order to help Defendants squash this case, and
Plaintiff is most certainly entitled to point that out to this Court and to the Reviewing
Courts.
At this point then it is incumbent of Defendants to use photographs, video or
blueprints to disprove Plaintiff on this point. That is how the burdens of persuasion and
proof work, the last time Plaintiff checked when he was busy winning First Amendment
trials and changing First Amendment Law and receiving Mayoral Commendations in
Senator Kelly Ayottes home state of New Hampshire, where he routinely photographs
Ayottes Office, which is not a public body or public meeting either. See Plaintiff in the
U.S. Senate building below. And see Appendices B and C and a picture of Plaintiff in the
office of the elected official, just like Betty Lou McKenna except with a lot more power,
prestige, pomp and circumstance!1

https://www.youtube.com/watch?v=rl4tS0W7RcQ

1 For the Record, Plaintiff reminds Defendants and the Court as to how Defendants raised Kelly
Ayotte in Defense until he published these video captures. Yep. The Worlds biggest backpedal.

11


While playing lip service to deciding the case on the Pleadings lets review what the
Court actually did:
First he put the Plaintiff physically in an interior office near employees cubicles
in order to make it appear that Plaintiffs case and arguments are unreasonable.
That is because in reality -- the only items downstairs in the public area is a public
foyer, a guard desk, a service desk at which Defendant Malone stood alone, and a public
hallway leading to the back room where several public kiosks are situated. As such, if the
Court is at all interested in Truth and Justice, it would stop hiding behind facts not alluded
to in the Pleadings. To wit: Plaintiff was not seeking access to Interior offices or to film
employees of the Recorder of Deeds in their cubicles. SEE Plaintiffs drawing, supra. The
Review of Plaintiffs initial and Amended Complaint will reveal that Plaintiff never sought
nor implied such access. (29 June Opinion pp. 14-15, Fn 42).

12

III.

Judge Youngs Latest Maneuver of Blocking Filings Results in Part from

Plaintiffs Constitutionally-Protected Online Activity.

Plaintiff has been quite vocal in pointing out facts relating to Judge Youngs
handling of this case. A reasonable person could conclude that Judge Youngs latest attack is
because of videos such as this one:

Former Trial Attorney Rips Judge Robert B. Young
in Delaware Free Press First Amendment case.
https://www.youtube.com/watch?v=Emq8pn6O34w

Even if Judge Young claims that this particular decision was not of his making, there
is enough before us to clearly demonstrate that he has not maintained any air of neutrality
in this case, and as such, he must recuse himself.

13

IV.

Summary and Conclusion.

The Delaware Supreme Court has established the following two-part test for

determining whether a judge should recuse himself or herself where a party has alleged
personal bias or prejudice under Del. Judges' Code Jud. Conduct Canon 2.11(A)(1): First, the
judge must, as a matter of subjective belief, be satisfied that she or he can proceed to hear
the cause free of bias or prejudice concerning the party. Second, even if the judge believes
that she or he has no bias, situations may arise where, actual bias aside, there is the
appearance of bias sufficient to cast doubt as to the judge's impartiality. BAC Home Loans
Servicing v. Brooks, 2012 Del. Super. LEXIS 51 (Newcastle Superior 2012).

In this case it is not merely the remarks, it is the willful ignorance of the law, the

falsification of the Record and assuming facts not in the Record, while erasing facts that
should have been in the record, even going down to Plaintiffs identification of himself vis a
vis what the Court said about a black journalist, i.e. guerrilla. An extremely poor choice of
words from a racist, hegemonic judge, and conduct clearly evincing unlawful bias when
viewed by any objective person. The Truth hurs, but we have to call a spade, a spade.
There is a whole New World beyond Delaware, whether Judge Young and the
Defendants appreciate it or not. And it is Plaintiffs Job to expose it, which he will be doing
with alacrity in the coming days, months and years. And in Sum, Thomas Paine is still rolling
in his grave, abated ever so slightly with the promise that Plaintiff will stir some Common
Sense into the Delaware Way.

14

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

CERTIFICATE OF SERVICE

I, the undersigned, swear that a true and accurate Courtesy copy of this document
was sent via email and via Tracked U.S. Mail to:

Joseph Scott Shannon, Esq.
Art C. Arnilla, Esq.
1220 North Market Street
5th Floor
P.O. Box 8888
Wilmington, DE 19899-8888

and to:

John A. Elzufon, Esq.
Peter McGivney, Esq.
300 Delaware Avenue,
Suite 1700
P.O. Box 1630
Wilmington, DE 19899

This 18th Day of August, 2015

________________________________
CHRISTOPHER KING, J.D.

15

APPENDIX A

16

17

APPENDIX B

18

19

20

APPENDIX C
https://www.youtube.com/watch?v=rl4tS0W7RcQ

https://www.youtube.com/watch?v=jLS0N_hH-cc
Here one of her constituents said that Ayotte Is pleasant and sweet and full of shit.

https://www.youtube.com/watch?v=lXlHu2002Vc

21

APPENDIX D

22