Professional Documents
Culture Documents
Now come Plaintiffs pursuant to Rule 15(a)(2) to file for Leave as previously-
noted before this Honorable Court. Plaintiffs in no ways concede Jurisdiction of
this case, which obviously chiefly turns on the application of GR 16 that reads,
in Pertinent Part:
At this point we now have more than one isolated incident in which
Defendant has willfully violated carefully crafted State Law in order to chill and
basically eradicate all vestiges of First Amendment and Prior Restraint
protections left in his Courtroom. We have a clearly established pattern,
practice and Policy or Policy-in-Fact that that is material to the entire case,
simple. It is also patently clear that the Washington State Legislature did not
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intend an absurd result in crafting GR 16 so that Judges like Defendant
Rumbaugh could just violate it with impunity in his Individual or Official
Capacities without recompense.
As noted in Plaintiffs First Amended Complaint,
44. His Attorneys are in complicity given that they received this
recent Notice of Media Coverage and obviously advised their
client to ignore it, but sadly this is nothing new as noted by the
Seattle Times and other reputable members of the Fourth Estate:
http://www.seattletimes.com/opinion/editorials/pierce-county-
prosecutor-mark-lindquist-should-resign/
Respectfully submitted,
___________________________________________
Christopher King, J.D.
Page 2 of 40
___________________________________________
Wally Brown
___________________________________________
Chris Nubbe
https://www.youtube.com/watch?v=ZcE0ZiO-deM
CERTIFICATE OF SERVICE
We, the undersigned, solemnly swear that a true and accurate copy of the
foregoing Motion with copy of First Amended Complaint was sent via email and
tracked U.S. Mail
on 6 March 2017 to the following:
Page 3 of 40
___________________________________________
Christopher King, J.D.
___________________________________________
Wally Brown
___________________________________________
Chris Nubbe
IN THE KING COUNTY SUPERIOR COURT
SEATTLE, WASHINGTON
and )
CHRIS NUBBE )
Judicial Oversight Investigator
PMB 377, 1001 Cooper Pt Rd SW STE 140 )
Olympia, WA 98502
)
Plaintiffs,
v. )
Defendant )
Page 5 of 40
7. On information and belief, Defendant Rumbaugh has been, and
continues to be, a Managing Partner of an active law firm, i.e.
Rumbaugh, Rideout, Adkins & Wallace, PLLC some three (3) years
after his ascension to the Bench. This Conduct will be the subject of
an independent Complaint for violation of Canon 3, Rule 3.10:
Practice of Law
(A) A judge shall not practice law. A judge may act pro se or on
behalf of his or her marital community or domestic partnership and
may, without compensation, give legal advice to and draft or review
documents for a member of the judge's family,* but is prohibited
from serving as the family member's lawyer in any adjudicative
forum.
FACTS
8. Plaintiff King and Plaintiff Brown are Western Washington area
journalists who routinely run Courtroom and other video pertaining to
the fallout from Americas 2008 financial/mortgage crisis.
9. The two of them have worked together on several projects since King
moved to Seattle in 2013.
10. Neither of them has been subject to reprimand or sanctions
regarding their in-Court or out-of-Court news coverage.
11. On or about 20 July, 2016 Plaintiff Brown contacted Plaintiff King
regarding a denial of camera coverage of a Friday, 22 July 2016
hearing pending in case number 14-2-12022-8, Federal National
Mortgage Association (FNMA) v. Brenda J. Duzan.
12. King was concerned as he had never been denied access to a
Courtroom in Washington, and in point of fact had only been denied
access to two (2) Mortgage hearing in Courtrooms across America in
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the States of Massachusetts, New Hampshire, California, Maryland,
Minnesota and Washington.
As such, he emailed the Court, by and through Judicial Assistant
Merri Reagan.
*******
As you will see, I've been running Courtroom video since the
mid 1990's.
Please advise.
Respectfully submitted,
CHRISTOPHER KING, J.D.
Page 7 of 40
13. Plaintiff King also submitted via email an original and Amended
Notice of Media Coverage, requesting an immediate response prior to
the 22 July 2016 hearing, noting the Rule GR16 and noting his
concerns for Prospective Relief. See Appendix A, attached.
Lastly, please note not only the Constitutional issues but the Statutory
Presumptions:
prospective Relief: Open Courts are the best Courts. The case will be posted on
Channel https://www.youtube.com/watch?v=ZcE0ZiO-deM
*********
14. The Court did not respond to Plaintiff King.
15. Plaintiff King did then hand file his Notice of Media Coverage on 2
August 2016 for prospective relief in this case and for precedential
value in other cases before this Honorable Court. See Appendix A.
Page 9 of 40
16. The effect of Plaintiff Kings actions, coupled with the complete non-
response of Defendant, grants King full Standing and Real Party in
Interest authority as to each and every Claim and Demand for
Damages, same as Plaintiff Brown.
17. Plaintiff Brown also submitted his Notice of Media Appearance, filing
it before the hearing, on 21 July 2016. See Appendix B, attached.
18. In open Court on 22 July 2016 the Courtroom assistants refused to
deliver a copy of Mr. Browns Notice to the Defendant.
19. The Defendant scolded Mr. Brown and told him to Get out of here...
get out of here now. A copy of the Transcript will be ordered to
verify the exact quote.
20. The Defendant completely failed to honor any of the provisions of
Rule GR16.
21. The Defendant violated RULE GR 16(c) by his failure to make
particularized findings on record, either written or oral, at the time of
announcing his limitations on open access to news media to video.
22. The Defendant violated RULE GR 16(c)(1) by his failure to give
legitimate or any reasons to limit video open access to news media
which are sufficiently compelling to outweigh the open access
presumption.
23. The Defendant violated RULE GR 16(c)(3) by his failure to give
legitimate or any reasons to limit video open access to news media
which relate to the specific circumstances of the case before the
court.
24. After litigation ensued and a subsequent improvident and
manipulative, evasive Removal to this Court was filed,
25. Plaintiff King placed the Court on Actual Notice by filing a Notice of
Media Coverage prior to Court in the Bozgoz case 16-2-12303-7 on
24 February, 2017.
26. Plaintiffs had also placed the Court on Constructive Notice by
emailing a copy of same to Counsel of Record in this case on or
about 22 February, 2017.
Page 10 of 40
27. Plaintiffs placed the Defendants in the case on Actual Notice by
emailing and mailing a copy of same to Counsel of Record in this
case on or about 22 February, 2017.
28. Nonetheless, at approximately 10:00 a.m. on 24 February 2017 the
Court looked straight at Plaintiff King, yet refused to call him to
conduct a Rule 16 hearing prior to calling the case for a Record
Hearing. Plaintiff was therefore forced into interrupting the Hearing
whereupon the following colloquy ensued, initially between the
litigant and then between Plaintiff King and Defendant Rumbaugh.
The litigant has full Power of Attorney for her cousin, and was
litigating (using her PoA and the ADA) a wrongful death action after a
Pierce County Public Access driver tipped her aunt onto her head in a
reckless driving maneuver, breaking her neck. She died a year later. 1
29. Court: If you are representing another entity like an LLC or an estate
you cannot represent yourself.
30. Family: I had a full power of attorney Court A POA only allows you to
speak on her behalf. The case law in the state is quite clear. She
cannot speak on her behalf. I understand and I don't dispute that you
have a power of attorney. Non-individual entities must be
represented by counsel.2
31. Family: I gave you several examples.. precedents....
32. Court: You cannot file on behalf of an estate unless you are an
attorney.3
33. Family: "I have given you several past precedents where superior
court where I showed you can file a claim and sign it when you have
full representation. She falls under ADA as I told you..... " 4
7 The Plaintiffs have removed their sole Federal Claim in order to obtain Removal in
the exact same manner as contemplated by last years case of KingCast v. Wright,
Finlay & Zack. In the unlikely event that the Court retains Jurisdiction Plaintiffs must be
permitted to Retain the Federal Claim, as Equity and Justice Demand such a result
given that we all know Defendant Rumbaugh only ran off to Federal Court to hide from
Courtroom cameras in the first place instead of facing all claims in State Court like a
Real Man or an Honest Judge.
Page 13 of 40
45. Further, while the exclusion of the Media is not criminal per se,
Defendants reckless conduct mirrors the language in the Criminal
Statute, to wit:
(c) RECKLESSNESS. A person is reckless or acts recklessly when
he or she knows of and disregards a substantial risk that a
wrongful act may occur and his or her disregard of such
substantial risk is a gross deviation from conduct that a
reasonable person would exercise in the same situation.
Both news media personnel as Plaintiffs in this case gave timely and
proper notice of intent regarding media coverage for the hearing and for
subsequent hearings, as indicated herein, in harmony with GR16.
Page 14 of 40
CLAIMS
The Right to Speech is part of the same rubric that provides Freedom of
the Press and the Publics Derivative Right to Know. The Defendants conduct
in this case is violative of these Principles.
DEMANDS
1. Immediate Declaratory Judgment.
2. Temporary Injunctive Relief against further or repeated
transgressions.
3. Permanent Injunctive Relief against further or repeated
transgressions.
4. Compensatory Damages in Excess of $25,000.00.
5. Punitive Damages in an amount to be determined by Jury.
________________________
Christopher King, J.D.
A/K/A KingCast/Mortgage Movies
________________________
Wally Brown
________________________
Chris Nubbe
Page 16 of 40
APPENDIX A
The only things uncertain will be the number of Plaintiffs and whether it
will be filed in the next week or two.
Thank you.
To All:
Page 17 of 40
Please be advised that I seek a response to my Notice of Media
Coverage by the Close of Business today.
Thank you.
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.
As you will see, I've been running Courtroom video since the mid 1990's.
Please advise.
Respectfully submitted,
Plaintiffs,
Defendants.
Now comes Christopher King, J.D., KingCast.net and Mortgage Movies Journal,
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
I am a former Assistant Attorney General who has also managed a title insurance company as
a title insurance producer. I have also practiced First Amendment and Civil Rights Law throughout
Page 19 of 40
the 1990s, routinely running video of said trials in an age before broadband. Prior to those
activities I was an editor and reporter for mid-sized and large daily press.
Page 20 of 40
I have run video since 2010 in courtrooms throughout the Country and in western Washington
on murder trials, civil litigation and foreclosure without incident including countless King County
KingCast Mortgage Movies employs Mr. Kings legal background and experience as a
licensed title insurance producer and escrow attorney to analyse legal matters relative to
foreclosure; all footage shall be made available for media pooling orders or requests in this regard.
In this particular case I have grave concerns that there is a pending First Amendment violation
of law. To wit, in email exchanges between Court personnel and the homeowner I emailed Ms.
As I understand it, you have denied my colleague Wally Brown camera access
to a foreclosure hearing this Friday.
I have run courtroom video throughout the County on this and other issues and
I believe the denial runs counter to Constitutional and Statutory and Common
Law in the State of Washington and if it is not rescinded, I will sue.
I am not here to be popular or liked. Judge Monica Benton can't stand the very
sight of me, in spite of the fact that I was a Civil Rights lawyer and she has
Malcolm X and Martin Luther King on her wall. But she still granted access and
that is all... I repeat ALL.... that I care about.
http://christopher-king.blogspot.com/2015/05/kingcast-mortgage-movies-malcolm-x-
and.html
https://www.youtube.com/watch?v=zVNVyijeQKU
Page 21 of 40
Page 22 of 40
As you will see, I've been running Courtroom video since the mid 1990's.
Please advise.
Respectfully submitted,
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
There was nothing unclear about the Courts earlier order to Ms. Duzan to
desist ex parte contact with the court, yet she persists in doing so. Sanctions
to be imposed on defendant for this repeated violation of the Courts Rules will
be taken up at the time of hearing on Friday, July 22 nd.
Sincerely,
Page 23 of 40
Merri Reagan for Judge Stanley J. Rumbaugh
Merri Reagan| Judicial Assistant to Judge Stanley J. Rumbaugh | Pierce County Superior Court | Dept. #18 | 930 Tacoma
Avenue South, Room 334, Tacoma, WA 98402 | Phone: (253) 798-6650 | Email: mreagan@co.pierce.wa.us
IMPORTANT: In order to avoid inappropriate ex parte contact, you are hereby directed to forward this communication to all
other counsel/parties not already copied on this email.
Think Green. Before printing this e-mail ask yourself: "Do I need a hard copy?"
*********
************
Lastly, please note not only the Constitutional issues but the Statutory Presumptions:
Page 24 of 40
either orally or in a written order.
I specifically note that even if this matter is not addressed for any reason by tomorrows
hearing, it must be addressed immediately owing to future, prospective Relief: Open Courts are the
best Courts.
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,
Page 25 of 40
CERTIFICATE OF SERVICE
The undersigned certifies that a true and correct copy of the foregoing was delivered via
email on 21 July 2016 and 3 August 2016 and mailed via USPS mail on 3 August 2016 to the
following:
Plaintiff Duzan
and
Page 26 of 40
Dated: 21 July 2016
_____________________________
Christopher King, J.D.
http://KingCast.net
http://MortgageMovies.blogspot.com
http://affordablevideodepo.com
617.543.8085/m
206.299.9333/f
27
APPENDIX B
The official Court Reporter will be making the stenographical court record, which
can be transcribed and provided to any person, litigant or otherwise, upon payment
of the usual and customary fee for that service. Video recording of the proceedings,
or use of cameras in the court room is prohibited.
Sincerely,
Merri Reagan| 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?"
Hi Merri,
I am Wally Brown and I have been contracted by Brenda Duzan to be
added to her defense team in the court proceeding for Friday July 22nd. I am
giving the normal 3 day notice to the judge that is presiding over her
case: FNMA v Brenda J. Duzan Case No. 14-2-12022-8
28
Unless I hear back from you to the contrary, I will be driving up there to
Tacoma to record this hearing. I am a professional court room reporter and
will stand by the normal procedures for courtroom recording, staying out of
the way of all that is going on.
Wally Brown
16717 Vail Loop, SE
Rainier, Wa 98576
(360) 446-1015
Hi Merri,
I am Brenda the defendant in the noted case in the subject line. The
opposing counsel has a motion scheduled for this Friday, July 22nd.
I have retained a videographer to record the hearing on my behalf as part of
my defense. He will be there on Friday to tape the hearing unless the hearing
is cancelled or I do not hear from you stating otherwise.
I have cc'd him as well.
Thank-you,
Brenda J. Duzan
No virus found in this message.
Checked by AVG - www.avg.com
Version: 2016.0.7688 / Virus Database: 4627/12648 - Release Date: 07/20/16
29
IN THE KING COUNTY SUPERIOR COURT
SEATTLE, WASHINGTON
CHRIS NUBBE )
Plaintiffs,
v. )
Defendant )
NOTE: Answers must be in compliance with the Civil Rules, Local Rules, and
Washington State case law, including the duty set forth in CR 26(e).
INTERROGATORIES
INTERROGATORY NO. 1: State your full name and any other names you have
been known by during the last ten years, your present address, date of birth, and
place of birth. In addition to your present address, state all other addresses at
30
which you have resided for the past ten years and the dates you resided at each
address.
ANSWER:
INTERROGATORY NO. 2: State why Plaintiff King did not receive a response from
Defendant allowing him to run video at the Duzan hearing conducted on Friday, 22
July 2016.
31
ANSWER:
INTERROGATORY NO. 3: State why Plaintiff Brown was not permitted to run video
at the Duzan hearing conducted on Friday, 22 July 2016.
ANSWER:
ANSWER:
32
SUBMITTING PARTYS CERTIFICATION
The undersigned pro se plaintiff, or attorney for the plaintiff, certifies
pursuant to KCLR 33(b) and (c) that these interrogatories are appropriate to the
Plaintiff
Name:
Address:
Respectfully submitted,
___________________________________________
Christopher King, J.D.
___________________________________________
Wally Brown
___________________________________________
Chris Nubbe
33
IN THE KING COUNTY SUPERIOR COURT
SEATTLE, WASHINGTON
CHRIS NUBBE )
Plaintiffs,
v. )
Defendant )
1. Provide a copy of any and all correspondence received from Brenda J. Duzan
or any named Plaintiff relative to video coverage of the underlying case
identified as 14-2-12022-8, Federal National Mortgage Association (FNMA) v.
Brenda J. Duzan.
2. Provide a copy of any and all responses issued by Defendant to any and all
correspondence identified in Document Request #1, supra.
34
4. Provide any documentation showing, or tending to show, that Defendant
made Particularized findings on the Record per Rule GR 16 that would
explain why any or all Plaintiffs were denied video access to the Duzan
hearing conducted on Friday, 22 July 2016.
5. Provide any and all documents that explain, or tend to explain, they Plaintiff
Duzan received a Record Reprimand for Ex Parte Communications relative
to her attempts to secure video coverage of the proceedings in her case.
that these document requests are appropriate to the facts of this case
Plaintiff
Name:
Address:
Respectfully submitted,
___________________________________________
Christopher King, J.D.
___________________________________________
Wally Brown
___________________________________________
35
Chris Nubbe
36
IN THE KING COUNTY SUPERIOR COURT
SEATTLE, WASHINGTON
CHRIS NUBBE )
Plaintiffs,
v. )
Defendant )
1. If you fail to respond to these Requests for Admissions within the time allowed
each matter set forth in these Requests may be deemed admitted and conclusively
established against you for purposes of this action.
2. If you fail to admit to the truth of a Request, and if Plaintiffs prove the truth of the
matter contained within that Request, the Court may order that you pay Plaintiffs
reasonable expenses, including attorneys fees, incurred in making that proof.
3. If, in responding to these Requests, you encounter any ambiguities when
construing a request or definition, your response should set forth the matter
deemed ambiguous and the construction used in responding.
4. If you cannot respond in full to any of these requests, to the fullest extent
possible, specify the reason(s) for your inability to respond in full.
37
5. If you contend that you do not have to respond to any of these Requests under
the attorney-client privilege, the work product doctrine, or any other basis, you
should (1) describe the information with particularity sufficient to allow the matter
to be brought before the Court; and (2) explain the nature and basis for each claim
of privilege or immunity.
6. To the extent any of the following requests are considered objectionable, respond
to as much of each request as is not objectionable and identify the part of each
request to which you object and the ground(s) for your objection.
7. If any of the requests for admissions are denied, please provide the basis for
such denial.
1. Admit that Plaintiff King has not been granted video access to any Duzan
hearing as of 15 August, 2016.
2. Admit that the Defendant has reviewed the Notice of Media Coverage filed by
Plaintiff King on or about 4 August, 2016 (Appendix A).
3. Admit that Defendant received and reviewed a Notice of Media Coverage filed
by Plaintiff Brown prior to 22 July 2015 (Appendix B).
4. Admit that Defendant does not have had a reasonable fear or concern that
that any Plaintiff might, by their appearance or conduct, distract participants
in the proceedings or otherwise adversely affect the dignity and fairness of
the proceedings relative to the Duzan hearing conducted on Friday, 22 July
2016.
5. Admit that Defendant does not have had a reasonable fear or concern that
that any Plaintiff might, by their appearance or conduct, distract participants
in the proceedings or otherwise adversely affect the dignity and fairness of
the proceedings relative to the Duzan hearing conducted on Friday, 22 July
2016.
38
6. Admit that Defendant did not make Particularized findings on the Record
per Rule GR 16 that would explain why any or all Plaintiffs were denied video
access to the Duzan hearing conducted on Friday, 22 July 2016.
39
SUBMITTING PARTYS CERTIFICATION
The undersigned pro se plaintiff, or attorney for the plaintiff, certifies
that these Admission Requests are appropriate to the facts of this case
Plaintiff
Name:
Address:
Respectfully submitted,
______________________
Christopher King, J.D.
___________________________________________
Wally Brown
___________________________________________
Chris Nubbe
40