IN THE SNOHOMISH SOUTH DIVISION COURT

LYNNWOOD, WASHINGTON

KRISTINA M. ROBINSON, )

Complainant, CASE No. U17-73

)
JUDGE GOODWIN
v.
CHRISTOPHER KING, J.D. )

Respondent.

RULE 60(b)(1) and (5) MOTION TO VACATE MEMORANDUM AND OPINION

OF 17 OCTOBER 2017 AB INITIO; ETHICS COMPLAINT

A. The Memorandum and Opinion was Issued in the Absence of Jurisdiction.

i. Relevant Immediate Background.

The Courts Memorandum references the fact that the underlying case was dismissed (on 11
September 2017) but neglects to mention that the Court directed the Parties to submit
briefs instead of attending a Scheduled hearing on 9 October, 2017. Appendix A p.2. As such,
the Court was actively engaged in Jurisdiction of this case and as such, Respondents Motion
to Recuse and Motion for Lost Wages were ripe for consideration, period.

So to was Respondents Motion for Nunc Pro Tunc Recusal of Judge Fraser but the Court
handily ignored that, among other things as we shall see below.

Prior to the Courts issuance of the Memorandum in Question there were five (5) 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.
5. Mr. Kings Motion to Recuse Judge Goodwin.

1. The ruling ignored item #1.

Recall that Judge Fraser took Legal Action on a case and berated Respondent for a simple
misate without divulging her prior relationship with Complaining Party as noted in the
thumbnail below. Apparently Mr. King is supposed to just forget about that, even though he
has caused a Federal Magistrate (Landya B. McCafferty) to recuse herself for virtually
identical reasons. That information is on file with the Court.

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2. The ruling incorrectly labeled item #2 as a Motion for Reconsideration.

In so doing the Court tied the Motion to a Defining Event of 29 August when in point of fact
the Defining Event occurred when the Court issued a Final Order dismissing the case on 11
September, 2017. It was at that point that Complaining Party failed to appear and SHE then
filed the only true Reconsideration in this case. A Reconsideration on the Default
Dismissal. This is a mistake or error per 60(b)(1) that must be addressed forthwith.

Mr. Kings Motion, however, while springing from that Event, ultimately stands completely
independent of that and could be brought at any reasonable time as it merely echoes the
procedure employed by the Court when it sua sponte awarded Lost Wages to Complaining
Party in the exact same circumstances.. even though she is a white girl who already lost to
Respondent on these issues in February, 2017 and who carries with her a penchant for lying,
as noted by Mountlake Terrace Animal Control Officer Elena McKee in her OFFICIAL
CAPACITY.

Speaking of which, the Court showed completely unlawful bias and an impatient lack of
courtesy by cutting Respondent off and bellowing stop talking when he logically
referenced that statement as noted on YouTube.

From Respondents Motion to Recuse:

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.

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 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. The ruling did not address the Amlak Default Judgment Reconsideration.

Presumably His Honor will Recuse himself from that matter, according to a recorded
statement from the Director of Courts. Or he will not. Whatever he does, the simple
fact remains that he should not have issued the 17 October Ruling prior to taking a
stance on Recusal.

Unbelievable.

4. The Court Retaliated Against Respondent and has Twice Violated the Law by
Removing a Publicly-Scheduled Hearing and Reducing it to Pleadings.

Moreover, 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

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:

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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.(included in original).

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. It was unprincipled retaliation that was imposed three
(3) days after Respondent issued his second Notice of Media Coverage and two (2)
days after Respondent published a story critical of Judge Goodwin,

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

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

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What is sad is the fact that Judge Goodwin was of course recently warned about Retaliation
against people who may be critical of him when he received a written admonishment but
the behavior has continued.

In fact, it has been a modus operandi for him for years according to a source who contacted
Respondent:

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.

5. The Ruling was Issued Without Jurisdiction and is Void Ab Initio and
Otherwise.

As noted, and contrary to the implication of the Court in the Ruling, the Court had retained
Jurisdiction over this case and had ordered Briefings on Amlaks Motion to Reconsider.
Therefore when Respondent filed his Motion to Recuse that meant the Court should have
immediately halted proceedings instead of attempting to rationalize and to cover up its
Constitutional transgressions and antipathy for Respondent as highlighted below in the
Conclusion Section.

Respondent referse the Court to the April 9-11 ABA Forum, Dealing with Difficult Judges:
What They Dont Teach You in Law School.

It is difficult to express tone, but the tone in cutting Respondent off during logical
arguments is instructive given Judge Goodwins history:

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3. How do you preserve tone for the record?

Appellate courts do consider the tone of interruptions when considering whether

the trial judge has overstepped his bounds and committed reversible error.
McMillan v. Castro, 405 F.3d 405, 410 (6th Cir. 2005). Whilethe Sixth Circuit called
the court's tone and interrogation of the plaintiff "troubling," it did not find grounds
for reversal in McMillan v. Castro. The trial court's conduct in question included
cutting the plaintiff's answers to his questions short, stating that he was asking "a
simple question," questioning whether he and plaintiff were "speaking the same
language," ending a line of questioning by saying "[t]hat's it? That's your case?," and
suggesting that the plaintiff's attorney had keyed her in on an answer. Id. at 409.

3. Where the judge has a personal bias against counsel, recusal may be
the only option. The Supreme Court of Mississippi ordered a trial judge's recusal for
seven pending cases in which counsel was enrolled because of apparent bias in In re
Blake, 912 So. 2d 907, 917 (Miss. 2005). The court found that "the record before us
clearly demonstrates that [the judge] entertained a high degree of hostility toward
Robinson and that her conduct during the exchange regarding [one witness']
availability to testify was not an isolated loss of temper." Id.

Finding nothing justifying the judge's conduct, the court held that the judge's hostility
toward counsel denied his clients a fair hearing in court and recused her from currently
pending cases, though not future cases.

Such is the case here, in which the Courts continued pattern of conduct toward Respondent
indicates an unfair and unprincipled bias that is so large that the Court would issue a
Decision while ignoring a pending Motion to Recuse.

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 CONCLUSION AND PRAYER FOR RELIEF

The Order Supports Unlawful Due Process and Equal Protection Violations and Must
be Voided Pending Full Review of ALL Pending Matters.

This Court has bent over backwards to help a white female under the age of 40
whilst punishing a black man over the age of 40. The Court sua sponte awarded Lost Wages
to the white Party whilst arbitrarily and capriciously denying the black Partys ask for Lost
Wages. The Court made the black Party stop stalking and admonished him for making what
is clearly a basic, sound legal argument after the white Party refused to accept legal service
of a document right in front of Judge Goodwin and after she was identified as a liar by a
public official. The Court twice refused Notice of Media Coverage by the black Party and
Retaliated against the black Party by moving a scheduled public hearing to Briefings. The
Court has done all of these things despite knowing that the white girl has brought virtually
identical issues before the Court in February 2017 after she killed Respondents dog, and
she lost then. Instead of admonishing the black Party this Court, if anything, should have
been cautioning the white girl about bringing frivolous filings before the Court.
Any and all of these actions comprise concrete violations of Substantive and
Procedural Due Process Rights and a Violation of the Equal Protection Principles as defined
and contemplated by the 5th and 14th Amendments, and for those reasons this Motion is
being filed with a Reviewing Authority i.e. the Commission on Judicial Ethics.
The Order of 17 October 2017 must be stricken from the Record and a Judge other
than Fraser or Goodwin must review and act on the Pending Motion for Lost Wages and all
other matters in order to prevent forestall the presence of any further unprincipled bigotry,
retaliation or contempt for the First Amendment by Judge Goodwin.

Respectfully submitted,

__________________________________________
Christopher King, J.D.

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 20th day of October, 2017

_____________________________________
CHRISTOPHER KING, J.D.

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