IN THE SNOHOMISH SOUTH DIVISION COURT

LYNNWOOD, WASHINGTON

KRISTINA M. ROBINSON, )

Complainant, CASE No. U17-73

)
JUDGE GOODWIN
v.

CHRISTOPHER KING, J.D. )

Respondent.

RESPONDENTS RENEWED MOTION FOR MEDIA COVERAGE

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I. Relevant Background and Failure to Follow the Law on Prior Request.

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. See Attachment
A, Respondents Notice of Media Coverage.
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)

To recap the underlying FACTS: Complaining Party is a woman who killed the most
beautiful dog that Respondent and Livis mother have ever known. She crippled our
family with the biggest hurt one could imagine, then she tried to stop Respondent
from criticizing her.

This is a woman who lied about having a legal and licensed operation at her home,
and who further lied about whether we were paying actual clients and who then
proceeded to leave our dogs alone with her pack of pit bulls in her own home,
completely unsupervised by any human pack leader, for 45 minutes. Whereupon her
dogs summarily murdered Livi the Wonderdog. She failed to provide us any insurance
information as requested by us, never sent a condolences card, never sent any flowers, and
never sent a written formal apology or offered to pay for cremation.

What she did do, however, was to admit to her other clients, in writing, the fact that she had
left dogs alone on prior occasion, resulting in injury. Meanwhile she lied to Mountlake
Terrace City Council about not having prior injuries when she paid out nearly $600 to
owners of a dog named Liko, and her professional pal and friend Bonnie Sands admitted to
another bloody fight in her licensed Edmonds facility.

This Court, in fact by and through His Honor, found that she engaged in unlawful harassing
conduct approximately 16 months ago. Meanwhile many other people clients and
otherwise have publicly commented on her dangerous driving and careless actions in the
course of her dog care responsibilities. Respondent posts his own comments relative to her,
and to other valid concerns he has about her ongoing KittyCatfe and Respondent reposted
the comments of others.

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II. Respondent is a Bona Fide Journalist.

Respondent has worked for daily and weekly newspapers. He has won First Amendment
Criminal Trials as an Attorney. He has been awarded Mayoral Commendation from Nashua
Aldermanic Chamber and the Mayor for his First Amendment activity. He has been
promoted to Team Leader in Seattle for a multi-city media concern for his prowess in
interviewing, shooting and editing.
Only one other Judge in Washington has refused to allow Respondent to run video,
and his name is Stanley J. Rumbaugh. He escaped liability by a Court that deliberately
allowed the Defendants in the Pierce County Prosecutors office to flat out lie, including their
omission of the following colloquy before King County Superior Judge Monica Benton:

I'm going to get to the specifics and substance of the case soon, and it involves a
purportedly lost Note with a date uncertain for when an indorsement was issued on
it, but for now you need to know that my First Amendment Rights as a Citizen, as a
Journalist, and as a Citizen Journalist were somewhat imperiled today when I was
called back into Honorable Monica Benton's Judicial Chambers where the following
colloquy ensued:

"What are your credentials?"

"Well Your Honor I was a reporter for a large daily newspaper, and editor of a
statewide daily before law school.... and I've been shooting these movies in
courtrooms throughout the Country for 4 or 5 years now, and I've been covering this
case already...." (I neglected to tell her I was an escrow attorney who worked for
WAMU but that is noted in my Notice of Media Coverage, as is the fact that Joseph
McIntosh and his buddies unlawfully threatened to have me arrested as seen in this
video, Judges Will Watch as Foreclosure Mill Attorneys Threaten Depo Videographer
with Security and Arrest).

"Well I haven't seen you with a camera in this case."

"Well Your Honor Judge Schubert has (one and two) and we and are on great terms.
He respects what I do and he said as much, I have that on video I recorded on prior
occasion."

"I have some concerns about whether you are media."

"Well Your Honor even if my prior experience and background weren't enough as a
journalist, I am still authorized as a public citizen to video these proceedings."

"Where is your website?"

"It's right there Your Honor," as I handed her my card.

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 You might audio but I'm not certain that entitles you to run video (Googling
Pooley+Mortgage Movies after I had told her to Google Mortgage Movies) I'm at your
website now and I see you have the hear/see/speak no evil monkeys and
skeletons...."

"Well I believe it does, and if this Court cannot take any step that would infringe on
my right to portray what I see as I see it, because that would be inimical to the First
Amendment."

"We'll see about that. Have a seat in the Courtroom."

Upon which First Amendment access as a reporter was GRANTED.

^+^+^+^+^+^+^+^+

In this case Complaining Party has caused King County Sheriff John Urquhart to alter
his scheduling in setting up his interview with Respondent on or about 29 August, 2017. See
the sample thumbnails from the interview and email from Media Liason Cindi West on the
following page. She is interfering with Respondents right to earn a living when no such
intrusion is warranted.

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III: Demand for Specific Findings of Fact and Conclusions of Law Regarding Antipathy.

This Court has 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:

As such, there was no need for any rebuke from this Honorable Court.

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C. Respondent previously provided a picture of the $300.00 that the Court ORDERED
as payment for lost time or wages for Ahaudu Amlaktereda. The Court should be on
Actual Notice, however, that Respondent lobbied in favor of Mr. Amlaktereda
receiving a variance for his illegally-parked work truck at the residence because
that line of work does not place him or Complaining Party within harms way
of any animals. There is absolutely no unwarranted antipathy. See Exhibit A:
(PREVIOUSLY SUBMITTED).

D. Judge Goodwins Retaliatory Record is a Cause of Substantial Concern:

Respondent is not comfortable with Judge Goodwin presiding over his case without
cameras. He has already recently been punished for retaliatory and uncivil conduct against
someone questioning his integrity, and Respondent resolutely questions that integrity
because of, inter alia, the issues countenanced in Section III, supra.
http://www.heraldnet.com/news/judge-draws-scrutiny-from-state-conduct-commission/

As such, Respondent respectfully demands that this Court specifically identify any
and all passages from any filings in this Court that it finds to be unreasonably tainted by
antipathy. That will be crucial in the event that the Court again rejects a request for Media
coverage.

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IV. The Unlawful Failure of Recusal with Judge Fraser Signals Unlawful Bias.

As previously submitted:

After Respondent miscalandared a TRO hearing (9:30 instead of 10:30 a.m.) and appeared
late on 31 July 2017 Judge Goodwin directed him to file for Reconsideration immediately:
The Court had DENIED most of the sought relief. The Complaining Party was still on the
Courthouse grounds and His Honor was still on the bench. Respondent did as instructed.
The case came on for recall yesterday before Judge Fraser in spite of the fact that
Respondent has requested recall before Judge Goodwin as clearly seen in Appendix A
(previously submitted).

The problem is that yesterday the Court issued stern rebuke to Respondent as was
unreasonably hostile to him, which caused Respondent to start thinking as to why that could
be the case.. and he recalled that Judge Fraser actually represented Complaining Party
during some of her criminal and otherwise unsavory past, including multiple driving
infractions that point to a lack of care and concern for safety in a safety related industry.

The transcript has been ordered such that one may hear the tone and inflection but before
we even countenance any of that, it must be noted that the Court, while busy scolding me for
what is clearly excusable neglect that happens in courtrooms every day, should have been
busy recusing itself immediately.

Both of these women knew that the Complaining Party was a former client and they both sat
there on their hands and said and did NOTHING, which amounts to a clear cut ethical
violation because of the appearance of impropriety:

From State v. Tathum No. 300854III.

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Decided: August 14, 2012: 30 Beginning with State v. Post, 118 Wn.2d 596, 826 P .2d 172,
837 P.2d 599 (1992), the Supreme Court has characterized a judge's failure to recuse himself
or herself when required to do so by the judicial canons as a violation of the appearance of
fairness doctrine.4 The court also narrowed the scope of the appearance of fairness doctrine
from one under which a party could challenge whether decision-making procedures created
an appearance of unfairness to a reformulated threshold: whether there is evidence of a
judge's or decisionmaker's actual or potential bias. 118 Wash.2d at 619 n. 9, 837 P.2d 599.

31 Under the version of the CJC in effect at the time of the trial below, [j]udges should
disqualify themselves in a proceeding in which their impartiality might reasonably be
questioned, including but not limited to instances in which the judge has a personal bias or
prejudice concerning a party. Former CJC Canon 3(D)(1)(a) (2002). While the CJC in effect at
the time of trial did not extend the judge's duty of disqualification to proceedings where the
judge has a personal bias or prejudice concerning a party's lawyer, as it does now,5 an
advisory ethics opinion issued in 1990, which Mr. Rogers submitted in support of his motion
for relief from the judgment, required that a judge disclose past associations that might
reasonably suggest or create a conflict of interest. The 1990 ethics opinion provides, in
pertinent part;

A judge is required to disclose to the parties on the record any known past association with a
law firm or attorney which would lead a reasonable person to infer that the judge is partial or
that there is a potential for a conflict of interest. Absent such circumstances, the fact that at
some earlier time the judge was affiliated with the law firm or office, or that a member of the
firm is or was affiliated with a law firm or office in which the judge formerly practiced, does
not require disclosure on the record. The judge is required to disclose on the record when an
attorney appearing in court or who has signed pleadings worked directly with the judge
before the judge assumed the bench.

Wash. Ethics Advisory Coram., Op. 9014 (1990).

32 Like the protections of due process, Washington's appearance of fairness doctrine seeks
to prevent the problem of a biased or potentially interested judge. State v. Carter, 77
Wash.App. 8, 12, 888 P.2d 1230 (1995). Under this doctrine, evidence of a judge's actual bias is
not required; it is enough to present evidence of a judge's actual or potential bias. Post, 118
Wash.2d at 619 n. 9, 826 P.2d 172. The CJC recognizes that where a trial judge's decisions are
tainted by even a mere suspicion of partiality, the effect on the public's confidence in our
judicial system can be debilitating. Sherman v. State, 128 Wash.2d 164, 205, 905 P.2d 355
(1995).

Please note that I have crossed this bridge before in Federal Court and compelled a Judge to
recuse herself as well. Landya B. McCafferty. Watch it on YouTube:
https://www.youtube.com/watch?v=2vT7_uhnElQ
Judge McCafferty Backdoor Recusal Taints NH Bar Ass'n & Courts in Free Press Racial
case.

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V. Summation of Salient Factual Points.

Respondent does not trust this Court. Respondent does not particularly like this
Court. It is also evident that this Court does not care for Respondent too much either. But
when Respondent walks into this Court and places a box of ashes on His Honors bench and
demands the right to video to protect the integrity of the system he must not be refused.
Any other response is to devalue the life of Livi the Wonderdog, and that is one thing
that Respondent will simply never allow. Open Courts are the ONLY Courts. Respondent is
certain that Complaining Party would favor open and full exposition of all relevant issues as
well

Respectfully submitted,

__________________________________________
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 served to the Complaining Party
via Overnight U.S. Mail at:

5808 218th PL SW
Mountlake Terrace, WA 98043

This 25th day of September, 2017

_____________________________________
CHRISTOPHER KING, J.D.

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Variance for Ahadu Amlaktereda
June 19, 2017 at 2:22 PM

From Christopher King

To mltnewseditor@gmail.com Moreno, Joel

gschrag@mltcityattorney.com bronzy22@gmail.com EMcKee

@ci.mlt.wa.us CElrod@ci.mlt.wa.us mortgagemovies007@gm

ail.com adam@animal-lawyer.com tips@q13fox.com

prr@edm
To All,

I do know know exactly where this issues stands.

What I do know, is that I am going to communicate the following:

Elisa and I both support the variance.

We have no problem with Kristina or her husband earning a

legitimate living but unethical conduct merits the full court press
that we are going to give them. The neighbors and I have reported
him parking a commercial work vehicle without zoning approval at
their home where Livi was mauled and killed. For the record, I
support their application for a proper variance to park his work truck
there but these people need to know that there are RULES and
LAWS they need to follow.

It saves lives and provides the public with information necessary to

make an informed judgment. Mountlake Terrace AC Officer Elena
McKee told the truth about her (i.e. "doesn't hesitate to lie if it
serves her purpose") until she sold out later. And for the record, this
is hardly my first foray into politics and law when it comes to
improper zoning issues that claim lives. Ask the family of Robert
Taylor RIP. Or Senator Bruce Tarr back in MA. -- where they actually
investigate and punish dangerous kennels dammit. I've sent you
THAT information before, but here's my testimony on Robert Taylor's

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Law. My brainchild. We didn't get it enacted but at least we tried to
do the right thing.....
CHRISTOPHER KING, J.D.

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