IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON

IN AND FOR THE COUNTY OF SNOHOMISH

CHRISTOPHER KING, JD ) CASE NO._______________

Plaintiff,
)
vs.
) JUDGE_________________
ACADEMY OF CANINE BEHAVIOR
)
Defendant.

COMPLAINT

NOW COMES PLAINTIFF, CHRISTOPHER KING to bring this Action to help

protect the life and well-being of every dog in the State of Washington, and to seek
redress for several violations of contract and public policy.

JURISDICTION, PARTIES, AND VENUE

1. This court has subject-matter jurisdiction over this action.

2. Plaintiff CHRISTOPHER KING resides in Seattle, King County and was the co-
owner/guardian of LIVI The Wonderdog, a spayed female, four-year-old German
Shorthaired Pointer. The Plaintiff regarded Livi as his sentient personalty and
immediate family member.
3. Plaintiff CHRISTOPHER KING resides in Seattle, King County and is the owner-
guardian of PEPPER Underfoot the Australian Cattle Dog, a spayed female, three
year-old Blue Heeler/German Shorthaired Pointer mix. The Plaintiff regards Pepper
as his sentient personalty and immediate family member.
4. Defendant Academy of Canine Behavior (hereinafter, “AOCB”) is, based on
information and belief, a legally-chartered facility in Snohomish County offering
consumer services including dog kenneling and training at all times relevant to this
Action.
5. This court has personal jurisdiction over all named defendants.
6. Venue is proper

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 GENERAL ALLEGATIONS

7. Plaintiff and his former Partner trained and boarded Livi with AOCB on several
occasions in 2014-2016.
8. On December 29, 2016 Livi was killed by another dog after Livi and her family
sibling Fang Weatherwax were left completely unattended with inappropriate dogs
not of their pack.
9. On or about December 31, 2017 Plaintiff and his former Partner adopted Pepper
and notified Defendant that they were desirous to start training and/or occasional
boarding arrangements for Pepper with Defendant.
10. Defendant was well aware of the Livi’s history and successful litigation and
settlement with Attorney Adam P. Karp, through social media and personal contact
with Plaintiff and his former Partner.
11. Plaintiff specifically inquired about a death they had heard about at AOCB.
12. Two individuals responded and told Plaintiff and his former Partner that a dog
was killed in their kennel by his canine household family member.
13. On information and belief culled from several current and/or former AOCB
employees this was and is a materially false account as to the death of the dog
involved, who shall be known as Moxie the MinPin.
14. On information and belief Moxie the MinPin wound up destroyed and partially
eaten by a dog not in Moxie’s household.
15. On information and belief a third dog was kenneled with Moxie and her family
member and that dog was Moxie’s killer.
16. On information and belief the offspring of a lead trainer was responsible for the
placement of Moxie’s killer with Moxie and her household sibling.
17. The apparent material misrepresentation was given to Plaintiff and his then-
Partner because Defendant knew that any other explanation would result in the
termination of any relationship between the Parties and Defendant knowingly
interjected this material falsity into the chain of commerce with the express intent
of retaining a business relationship in spite of the falsity.

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18. Based on this material and intentional misrepresentation, Plaintiff and his then-
Partner continued a relationship with Defendant, taking Pepper to two types of
training at AOCB, general obedience and Rally, and sending Kenton a high-resolution
DSLR photograph for him to use for marketing purposes.1
19. The Defendant’s statements where issued by and through persons of apparent,
actual and ostensible authority and Plaintiff and his then-Partner placed reasonable
reliance on the statements in continuing their relationship with Defendant.
20. Meanwhile, Plaintiff authored a draft bill entitled “Livi’s Law,” designed to
penalize kenneling with dogs not known to each other without express written
consent.
21. Plaintiff raised the proposal to Defendant and was met with a complete lack of
interest, a fact he found odd.
21. Plaintiff boarded Pepper for approximately four (4) days in spring, 2018.
22. On returning from the East Coast and retrieving Pepper he questioned AOCB
staff because they had told him Pepper was doing great with no problems at one
point, but then subsequently told him that she was not eating well and had diarrhea.
23. Plaintiff contemporaneously wrote Livi’s lawyer and his former Partner and
advised them that there were conflicting stories and he stated that he felt Pepper
had been drugged.
24. Plaintiff’s former Partner advised him to trust his intuition.
25. Plaintiff expressly stated that he had no intention of suing over it, but added that
he was concerned and that he would be interested in seeing the full records.
26. Defendant provided what Plaintiff believes to be partial records.
27. Plaintiff was informed that AOCB has a pattern and practice of drugging dogs
without prior consent and without post-hoc acknowledgement.
28. In July, 2018 Plaintiff became aware of a viral video in which a trainer beats an
allegedly belligerent dog with a thin-walled whiffle bat.
29. Plaintiff also began to see other allegations of abuse as intimated above, and he
therefore demanded all of Pepper’s records, on video.

1 Rally, on information and belief, was taught by an independent contractor.

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30. Livi’s former trainer Kenton and AOCB owner “Jack” brought Plaintiff inside into
a back room under the pretense that they would talk openly about all of Plaintiff’s
questions. Instead they kicked Plaintiff out of the room as soon as he mentioned
Moxie the MinPin, denying his request for Pepper’s records.
31. Incensed and shocked, Plaintiff returned the following day to narrow the issues.
He sought only Pepper’s records, whereupon both Kenton and Jack ended up
making physical contact with him in threatening manner.
32. Kenton and Jack also ordered the maintenance man to run a loud, gas-powered
two-stroke leaf-blower in and around Plaintiff to attempt to jar him and to drown
out his video.
33. Speaking of two-strokes, Kenton then actually ran and got his car, a recent
Subaru sport-ute/station wagon, and attempted to block in Plaintiff’s motorcycle.
34. Instead of simply providing the records that are owed, Defendant called in a 911
to the County Sheriff, asking that Plaintiff’s motorcycle be towed.
35. Plaintiff calmly met the Sheriff Deputies and explained what was really going on,
whereupon said Deputies had a cordial conversation with Plaintiff and informed
Defendant that Plaintiff’s motorcycle was actually on an easement and that it could
not be towed and that they would lose that battle. As the Deputies escorted Plaintiff
back to retrieve his motorcycle to illustrate the complete lack of tension coming
from Plaintiff, one of them stated “Nice motorcycle!” whereupon a short discussion
was had about the particular machine.
36. The Plaintiff is suffering, and continues to suffer severe emotional distress and
loss of enjoyment of life, among other general damages, as a direct result of
Defendants’ acts and omissions.

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CLAIMS
Per CR 8(e)(2), the Plaintiff pleads the following as to Defendants:

37. Claim I: Fraudulent Inducement/Fraud in the Factum.

38. Claim II: RCW 19.86.090 (Consumer Protection Act)
39. Claim III: Outrage
49. Claim IV: Negligence (including negligent misrepresentation)
50. Claim V Breach of Contract
51. Claim VI: Breach of Bailment
52. Claim VII: Strict Common Law Liability

PRAYER

WHEREFORE, the Plaintiffs seek judgment against the Defendants as follows:

A. For the production of any and all records pertaining to Christopher King, Elisa
Brownstein, Livi or Pepper and the return of any and all monies spent with AOCB
after Livi’s death.
B. For noneconomic damages;
C. For prejudgment interest on liquidated sums;
D. For treble damages under RCW 19.86.090 for each Plaintiff;
E. For costs of suit;
G. For postjudgment interest at 12% per annum or the highest rate permitted by
law,
whichever is higher, pursuant to RCW 4.56.110;
H. For such other and further relief as the Court may deem just and proper.

Dated July 31, 2018

_________________________________
Christopher King, J.D.
Attorney Pro Se