IN THE SNOHOMISH SOUTH DIVISION COURT

LYNNWOOD, WASHINGTON

KRISTINA M. ROBINSON, )

Complainant, CASE No. CASE No. U17-73

)
JUDGE GOODWIN
v.

CHRISTOPHER KING, J.D. )

Respondent.

MOTION TO RECUSE JEFFREY D. GOODWIN

A. Judge Goodwins Continued Denial of GR 16 Points to Unlawful Bias.

Respondent filed a Renewed Notice of Media Coverage on 25 September documenting his

credentials as a bona fide member of the Press who has shot dozens if not hundreds of
courtroom videos in and around King County since 2013.
Respondent further published a YouTube video and journal entry entitled:

26 September 2017
KingCast Says Snohomish South District Judge Jeffrey D. Goodwin is a Hegemonic Warlord
who Hates Cameras in his Courtroom.
http://christopher-king.blogspot.com/2017/09/kingcast-says-snohomish-south-
district.html

https://www.youtube.com/watch?v=cQG5ieRJxi4

Respondent found that the Court was discourteous to him in an 11 September 2017 hearing
and therefore published the fact that His Honor had been punished for retaliatory,
impatient and discourteous conduct.
http://www.heraldnet.com/news/judge-draws-scrutiny-from-state-conduct-commission/8

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https://www.scribd.com/document/359942985/Snohomish-South-Judge-Jeffrey-D-
Goodwin-is-a-Bigoted-Hegemonic-Warlord-who-Hates-Cameras-in-Court#from_embed8

Immediately thereafter the Court issued its 28 September 2017 pronouncement to hear the
case on Briefs, again circumventing an Open Court process, in willful derogation of GR 16.

Respondent has been openly critical of Judge Goodwin, and of Judge Beth Fraser (Cullen),
who actually represented Complaining Party on prior occasion but who failed to
acknowledge the relationship before discussing aspects of this case on the Record and being
unnecessarily critical of Respondent because he miscalendared a hearing.

At the time of the Renewed Notice of Media Coverage there were four (4) issues for the
Court on that date:
#######

1. Mr. Kings Motion for Nunc Pro Tunc Recusal of Judge Fraser.
2. Mr. Kings Motion for Lost Wages.
3. Ms. Robinson/Amlak Motion for Reconsideration.
4. Mr. Kings Renewed Motion for Media Coverage (containing a Demand for Specific
Findings of Fact and Law) relative to any of Respondents filings that the Court may
deem unduly acrimonious.

By using CRLJ 59(e)(3) to schedule the case to be heard on Briefs, the Court has taken an
unfortunate end-around GR 16 to DENY Mr. Kings Constitutional and Statutory Rights
and Privileges to provide camera access to a legal proceeding.

Respondent pursued Media Coverage in Complaining Partys first attempt to obtain a TRO
and the Court DENIED such coverage without any written ruling whatsoever, and without
any Findings of Fact or Conclusions of Law as required by General Rule 16. Please see
Appendix A, Respondents Notice of Media Coverage and his Renewed Motion of same.
There is audio of that occasion here: https://www.youtube.com/watch?v=pNd1kBqD7kM

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GR 16 that reads, in Pertinent Part:

(b) The judge shall exercise reasonable discretion in

prescribing conditions and limitations with which media
personnel shall comply.

I If the judge finds that sufficient reasons exist to

warrant limitations on courtroom photography or recording,
the judge shall make particularized findings on the records
at the time of announcing the limitations. This may be done
either orally or in a written order.

In determining what, if any, limitations should be imposed, the judge shall be

guided by the following principles:

3. Open access is presumed; limitations on access must be

supported by reasons found by the judge to be sufficiently
compelling to outweigh that presumption; (emphasis added)

The pronouncement to submit the case on Briefs came only after, and immediately after, Mr.
King filed his Renewed Notice of Media Coverage on 25 October, 2017, requiring the Court
to adhere to the above dictates of Law that it also failed to follow in February, 2017. See
Appendix A, supra.

As such, one could reasonably conclude that this Court is attempting to circumvent First
Amendment, Statutory Law and the history of dozens or hundreds of Courtroom videos
filmed by Respondent in 6 different states that all point toward the uncontested assumption
that camera access must be granted.

Moreover, the reactionary decision to order the case heard on Briefs diminished Mr. Kings
right to defend the case in the manner he sees most appropriate, i.e. by and through a video
presentation.

B. Judge Goodwins Referencing to Acrimony as to Respondent Point to Unlawful Bias.

As to the Acrimony concerns posited by this Court as concerning Respondent, he directs the
Courts attention to the following facts and videos:

1. Complaining Party killed Respondents dog in an ILLEGAL KENNEL as a MATTER OF

LAW, opened up an entire blog dedicated to bashing Mr. King and among other things,
allowed postings in which her supporters called him negro negro and said he was an ugly,
mean lazy motherfucker was Living off of his girlfriend. Other than being a negro and
perhaps physically unattractive to some, none of this is true. Significantly, neither is it
necessarily grounds for a Restraining Order. (Appendix B).1

1 While these comments are completely false and merit no further comment, they display the exact
sort of antipathy that the Court disdains, and this acrimony is of a PERSONAL sort, as opposed to
Respondents legitimate concerns about matters of safety that have COMMERCIAL IMPLICATIONS on
the part of Complaining Party. Either way, none of this communication is subject to a Restraining
Order on either side. It may or may not be a matter for a Defamation lawsuit.

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2. This Court has unreasonably admonished Respondent for making the following two
valid legal arguments when Respondent has reviewed such arguments with several local
licensed attorneys who found the arguments 100% reasonable:

A. Next, as noted on the Record, at the close of the Hearing on 29 August, 2017 the
Complaining Party flat out refused to accept service of a legal document, i.e. the
first Notice of Bad Faith as tendered directly in front of the Bench. She left it on
the Plaintiffs table after Respondent served it, and she then refused the Deputy
Sheriff or other uniformed Law Enforcement Officer who attempted to hand it to her,
and she smirked and laughed at Respondent. This is the same sort of patent
insouciance she exhibited when Attorney Fraser represented her before she came to
sit on this very Bench.

B. Furthermore, Respondent cited to a public document issued by a public official in

her official capacity when noting that Complaining Party is not trustworthy because
drama follows her everywhere and she will not hesitate to lie when it serves her
purposes:

3. These YouTube videos, as provided to the Court on an SD card for the Record. The
first video is submitted to the Record as an Offer of Proof that would have been aired in
Open Court on a video screen had the Court not eliminated the live hearing in an arbitrary,
capricious and abusive retaliatory manner as noted throughout this filing.

https://www.youtube.com/watch?v=cQG5ieRJxi4
Snohomish South Court Bias in Deadly Dog Mauling Case Offer of Proof

https://www.youtube.com/watch?v=QMy9nLz8G5s
The Life and Murder of Livi the Wonderdog by Kristina Amlak and Precious Paws

C. Judge Goodwins Prior Record for Acrimony and Retaliation Informs this Demand.

We have seen Judge Goodwin punished for retaliatory conduct against someone
who is critical of him. Respondent was critical of him and he in turn eliminated a public
Court hearing to avoid compliance with clear-cut Statutory Law in Washington.
At this point it is safe to say that no litigant in their Right Mind would allow such a
Jurist to preside over the balance of their case. Unfortunately, the attitude has stayed with
His Honor from his days as a Prosecutor when he harassed someone who declined to offer a
name for fear of more retaliation. This individual writes:

Yes, I saw him when he was a prosecuting attorney for Edmonds. My lawyer sent me
in to court with some paperwork so my attorney didnt need to be there. He started
lecturing me saying what do you do for work? I said metal fabrication. He said if i
came into your work would i make a very good fabricator, so dont come into my
court and try to play lawyer. He's arrogant and an egoist. I met him as a judge too..
He likes to try to use his loud voice to intimidate. I hope everything works out for
you Chris. Keep on him.

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D. Judge Goodwins Sua Sponte Award of Lost Wages Points to Unlawful Bias.

The Court was well aware that Respondent has always been well-briefed and well-
prepared for Court and was aware that Complaining Party was still on the grounds when
Respondent arrived at Court. Yet and still he awarded lost wages to Complaining Partys
husband and refuses to hold a public hearing on Respondents pending Motion for Lost
Wages for Complaining Partys failure to appear on 11 September 2017. She was allegedly
sick, but she was not in need of hospitalization and her husband. was not sick at all. Yet
instead of a sua sponte award of lost wages, Respondent was compelled to file a Motion.
Query, is that because Complaining Party enjoys white skin privilege?

E. Conclusion and Prayer for Relief.

The Courts present and prior conduct, again acting in retaliatory fashion to
criticism and inquiry, militate strongly in favor of Recusal. Respondent has compelled
Recusal on prior occasion relative to a Federal Magistrate so he is well aware of the
threshold. See App C., in which Federal Magistrate Landya B. McCafferty properly Recused
after Respondent discovered that she worked in the same law firm as Respondents
opposing Counsel in KingCast v. Ayotte et al. Moreover, she worked in a similar capacity as
Senator Ayotte, i.e. junior attorney under Respondents opposing Counsel. Those are the
same grounds to recuse Judge Fraser, of course. And that is yet another Motion that Judge
Goodwin has moved to hide from public scrutiny by moving it to a Briefing only review.
The Truth is a powerful disinfectant, and cameras and diligent litigants and cameras
expose that Truth in a way that transcends lawless conduct. As noted on a recent ABA
Journal page:

Reporters and cameras in the court: Judges sound off

https://www.americanbar.org/news/abanews/aba-news-archives/2017/08/reporters_and_camera.html

Moderator Benjamin Holden, a former reporter who teaches at the University of Illinois, asked
the panel two judges, a retired judge and a Supreme Court reporter if Americas free press
and independent judiciary are under attack today in an unprecedented way.

I think all of us would say yes, replied Jonathan Lippman, former chief judge of the New
York Court of Appeals. I dont think theres any doubt about that. Its hard to say the
independence of the judiciary is not at risk and the free press is not at risk.

By and large, I think its been a positive for our court to have the openness that we have with
the cameras, Rawlinson said. And Im hopeful the experiment will become the norm
throughout the country, including the Supreme Court.
-Ninth Circuit Judge Johnnie Rawlinson

But this Courts truncation of the Free Press Right is indicative of a much larger bias that
must be eliminated in this case. Judge Goodwin must step down and a neutral, fair Judge
must take the helm and allow this process to be as public as it is supposed to be, pursuant to
GR 16.

Respectfully submitted,
/s/ Christopher King, J.D.
__________________________________________
Christopher King, J.D.

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 CERTIFICATE OF SERVICE

I, the undersigned, solemnly swear that a true and accurate copy of the foregoing
Motion was provided to Complaining Party via Regular U.S. Mail

5808 218th PL SW
Mountlake, Terrace WA 98043

This 12th day of October, 2017

_____________________________________
CHRISTOPHER KING, J.D.

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