Professional Documents
Culture Documents
Jessica Nadelman
Assistant City Attorney
(206) 386-0075
jessica.nadelman@seattle.gov
October 4, 2018
Christopher King
12048 Greenwood Avenue
Seattle, Washington 98133
We are in receipt of your Summons, Complaint and discovery requests in the above
captioned matter. I will be representing the City of Seattle in this litigation.
Based on my review of your pleadings, your communications with the City, and the
videos from the City Council hearings, it appears that you are interested in making a
public records request. At this time, on your behalf, I would be willing to submit a
request for public records from the Legislative Department for communications
exchanged between City Council members and the Seattle City Attorney’s Office
regarding the viability of suing MERS. Please let me know if I have misinterpreted the
records you would like to request.
For efficiency, I would ask that you voluntarily dismiss your lawsuit so that we may
focus on providing the records you would like to request in an expedited manner. In the
alternative, I will move to dismiss your case because you have failed to make a public
records request to which the City has any obligation to respond. The Washington Public
Records Act only imposes requirements on agencies after a public records request is
made. The video and your blog post do not constitute a request for public records, but
rather a statement of intention to make a request. Had you made a request, the City
would have processed it in the same manner has we have processed all of your previous
requests. For your information, the City now uses a web portal for managing its public
records requests. A link to the portal can be found here: https://www.seattle.gov/public-
records/public-records-request-center
Please let me know if you are willing to dismiss this matter and I will proceed with
submitting a records request to the Legislative Department on your behalf. As a courtesy,
all fees associated with responding to your request will be waived. If I do not hear from
you by DATE, I will proceed with a motion to dismiss.
Sincerely,
Jessica Nadelman
Assistant City Attorney
Jessica,
One of the problems with your response is the fact that I submitted the request in the exact same manner as I have done on prior occasion
AND walked a copy upstairs and had it time-stamped in.
The City cannot now require some sort of Talismanic incantation in order to respond to my well-tendered request:
That portal cannot be the only way to file a PRR with the City.
PETER S. HOLMES
Seattle City Attorney
By: ____________________________________
[Attorney Name]
Assistant City Attorney
Plaintiff,
)
vs.
) JUDGE_________________
CITY OF SEATTLE
600 Fourth Avenue )
Seattle, WA 98104
)
Defendant.
NOW COMES PLAINTIFF, CHRISTOPHER KING to bring this Action to help promote
Transparency in Seattle City Government and to help millions of taxpayers and
homeowners understand the true measure of damages that Mortgage Electronic
Registration Services (MERS) and their mortgage and banking partners have foisted
upon this Country.
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6. Venue is proper.
GENERAL ALLEGATIONS
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15. Meanwhile, area homeowners, other attorneys, political candidates and area
mortgage professionals paid to host Ms. McDonnell at their own “Mortgage
Economic Reality Seminar” (MERS).
16. These same people repeatedly petitioned Seattle City Council to allow Ms.
McDonnell to present, all to no avail because of the aforementioned cozy
relationships with banking and mortgage industries.
17. Even Kshama Sawant, the great Socialist Hope, walked away from her
associations with protesters who set protests against the banks, even as former City
Council noted in a KingCast video “what the banks are doing to these homeowners is
criminal.”
https://www.youtube.com/watch?v=3nuPc9XvoOE
Seattle Councilor Identifies Criminal Activity at BoA Jane Mair Fraudclosure
Halloween Rally
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19. As eleven (11) other Oregon Counties sued MERS the Protesters – including
Plaintiff – noted that Seattle and King County should be suing MERS in order to help,
inter alia, provide funding for the homeless in a manner similar to the failed “Head
Tax” that was hastily repealed after an illegal meeting in yet another violation of
RCW §42.56.
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https://www.youtube.com/watch?v=WCg9LXQwXjM
Seattle as War Zone: A MERS Visit with Lanny Breuer, Marie McDonnell and
Seattle City Council
20. Ms. McDonnell noted that suing MERS is a legal, moral, ethical and financial
duty.
https://www.youtube.com/watch?v=iMctjZSK5UY
Multnomah County Shames King County and Seattle City Council on $9M MERS
Lawsuit
21. On or about 29 May, 2018 Plaintiff appeared before City Council with his usual
handouts and stated
“We are going to play the ‘It’s a fact game’…..We have feet of clay here. It is a
fact that I am going to request any and all notes relative to the viability of
suing MERS that you have gathered over the years since I have made this
public to you and the taxpayers deserve a reason.”
http://mortgagemovies.blogspot.com/2018/05/kingcast-says-seattle-is-going-to-
hell.html
Saturday, May 26, 2018
KingCast Says Seattle is Going to Hell in a Hand Basket. Meanwhile, an RCW §42.56
Public Records Request to City Attorney Pete Holmes on Multnomah County et al. v.
MERS.
22. Plaintiff handed a printout of this above-linked Mortgage Movies Journal Entry
to both City Council Chambers as he politely stated
“May it please the Council I have a copy for you and I’ll get one stamped for
my notes and records.”
Plaintiff may be seen presenting the RCW §42.56 request to City Council at such
time, and video surveillance requested in Discovery will also reveal Plaintiff positing
a copy of same at the Office of the Mayor five minutes later.
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22. Plaintiff followed up with an email on 11 July 2018 and was again ignored (see
Appendix A).
23. Plaintiff appeared before Defendant again on 4 September 2018 and reminded
City Council that he had not received any response whatsoever as he stated
If you can show me one scintilla of proof that you responded to me I won’t sue you. I
have better things to do.”
24. No response was forthcoming, so Plaintiff has now been compelled to file this
lawsuit.
25. This is not shocking behavior to Plaintiff as he has rebuffed former Council
President Tim Burgess for cutting him off at exactly two (2) minutes whilst allowing
other speakers more time to briefly conclude their presentations before Council.
This is a First Amendment and Equal Protection violation, however Plaintiff is not
going to plead those Causes of Action lest Defendant remove the Case to Federal
Court to avoid KingCast cameras in Court during the pendency of the case.
26. Defendant’s failure to respond is clearly more than an oversight. The failure
exists because of malice against Plaintiff and others similarly-situated and such
illicit motivation provides grounds for substantial punitive damages for Plaintiff that
he will share with the homeless through his chosen reputable 501 (C)(3) entities.
27. To wit, local Attorney Lincoln Beauregard filed suit over yet another homeless
and public-records related issue: The same City Councilors who refused to respond
to this Public Records Request were ORDERED this week to provide their notes and
documents relative to a secret meeting held on the Head Tax referenced by Plaintiff
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herein, thereby cementing the need for a full measure of damages for repeated
malfeasance.
https://www.seattletimes.com/seattle-news/judge-orders-seattle-to-turn-over-internal-records-on-
head-tax-repeal-ed-murray-by-sept-28/
https://www.documentcloud.org/documents/4887741-Egan-Motion-to-Compel-Discovery.html
See Egan et al. v. City of Seattle et al. King County Superior 18-2-14942-8 SEA
CLAIMS
A. For the production of any and all records as sought, i.e. any and all notes, paper or
electronic, relative to the City and City Attorney’s deliberations on the viability of
suing MERS;
G. For post judgment interest at 12% per annum or the highest rate permitted by
law,
whichever is higher, pursuant to RCW 4.56.110;
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H. For such other and further relief as the Court may deem just and proper.
_________________________________
Christopher King, J.D.
Plaintiff Pro Se
CERTIFICATE OF SERVICE
I the undersigned, solemnly swear that a true and accurate copy of the foregoing
Motion was served on Defendant, by hand at:
Jessica Nadelman
Erica Franklin
c/o Seattle City Attorney Peter S. Holmes
701 Fifth Avenue
Suite 2050
Seattle, WA 98104
This 20th day of September, 2018.
Respectfully submitted,
_______________________________
CHRISTOPHER KING, J.D.
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IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON
IN AND FOR THE COUNTY OF KING
Plaintiff,
)
vs.
) JUDGE_________________
CITY OF SEATTLE
)
Defendant.
The answers are to be signed by the person to whom they are addressed and must be
served on all parties within thirty (30) days after the service of the interrogatories unless
these interrogatories were served upon you along with the service of the summons and
complaint in which case the answers must be served within forty (40) days.
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).
1
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 which you have resided for
the past ten years and the dates you resided at each address.
ANSWER:
INTERROGATORY NO. 2: State why you have not provided the documents sought by
Plaintiff, i.e. the public records as contemplated by Plaintiff’s PRR as follows:
So next week I am going to print this journal entry out and return to City Council
and demand all public records where City Attorney Pete Holmes or any City
Councilors individually or collectively studied the possibility of suing MERS and
the reasons why they have thus far decided not to do so. If they claim that there
are no responsive documents then I want a written explanation from Attorney
Holmes as to why he is not working the the County or others to sue MERS. I like
Pete. In general I think he's a good City Attorney. But I have no sacred cows and
I'm going to ask the difficult questions. It's what I do.
ANSWER:
INTERROGATORY NO. 2: Identify by case caption any and all lawsuits brought
against the City from a reasonable time ago until present -- let’s call it 1 January 2012 --
for RCW §42.56 violations regardless of outcome.
ANSWER:
ANSWER:
2
INTERROGATORY NO. 3: State the date(s) on which Defendant notified the Free
World that Defendant’s Public Information Portal was the exclusive way to file an RCW
§42.56 Request for:
ANSWER:
Plaintiff
Name:
Address:
Respectfully submitted,
___________________________________________
Christopher King, J.D.
3
IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON
IN AND FOR THE COUNTY OF KING
Plaintiff,
)
vs.
) JUDGE_________________
CITY OF SEATTLE
)
Defendant.
1. Provide a copy of any audio-visual records from the day of 29 May, 2018 in
which Plaintiff appears, i.e. approximately 13:00 in to this video:
http://www.seattlechannel.org/FullCouncil/?videoid=x91764
This includes the Full City Council meeting as well as Plaintiff filing his stamped
request at the Office of the Mayor and/or City Council immediately after he
alighted from Council Chambers.
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SUBMITTING PARTY’S CERTIFICATION
The undersigned pro se plaintiff, or attorney for the plaintiff, certifies that these
document requests are appropriate to the facts of this case
Dated this _______ day of October, 2018
Plaintiff
Name:
Address:
Respectfully submitted,
___________________________________________
Christopher King, J.D.
5
IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON
IN AND FOR THE COUNTY OF KING
Plaintiff,
)
vs.
) JUDGE_________________
CITY OF SEATTLE
)
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.
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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.
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SUBMITTING PARTY’S CERTIFICATION
The undersigned pro se plaintiff, or attorney for the plaintiff, certifies that
these Admission Requests are appropriate to the facts of this case
Dated this _______ day of October, 2018
Plaintiff
Name:
Address:
Respectfully submitted,
______________________
Christopher King, J.D.
8
IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON
IN AND FOR THE COUNTY OF KING
Plaintiff,
)
vs.
) JUDGE_________________
CITY OF SEATTLE
600 Fourth Avenue )
Seattle, WA 98104,
)
Defendant.
The answers are to be signed by the person to whom they are addressed and must
be served on all parties within thirty (30) days after the service of the
interrogatories unless these interrogatories were served upon you along with the
service of the summons and complaint in which case the answers must be served
within forty (40) days.
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).
9
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 which you
have resided for the past ten years and the dates you resided at each address.
ANSWER:
INTERROGATORY NO. 2: State why you have not provided the documents sought
by Plaintiff, i.e. the ___________ as contemplated by
ANSWER:
INTERROGATORY NO. 2: Identify by case caption any and all lawsuits brought
against the City from a reasonable time ago until present -- let’s call it 1 January
2012 -- for RCW §42.56 violations regardless of outcome.
ANSWER:
10
SUBMITTING PARTY’S 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.
11
IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON
IN AND FOR THE COUNTY OF KING
Plaintiff,
)
vs.
) JUDGE_________________
CITY OF SEATTLE
600 Fourth Avenue )
Seattle, WA 98104
)
Defendant.
1. Provide a copy of any audio-visual records from the day of ____, 2018 in
which Plaintiff appears. This includes the Full City Council meeting as well as
Plaintiff filing his stamped request at the Office of the Mayor.
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SUBMITTING PARTY’S CERTIFICATION
The undersigned pro se plaintiff, or attorney for the plaintiff, certifies
that these document requests are appropriate to the facts of this case
Plaintiff
Name:
Address:
Respectfully submitted,
___________________________________________
Christopher King, J.D.
13
IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON
IN AND FOR THE COUNTY OF KING
Plaintiff,
)
vs.
) JUDGE_________________
CITY OF SEATTLE
600 Fourth Avenue )
Seattle, WA 98104
)
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.
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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 prior to initiation of this lawsuit Defendant never provided any
documents responsive to this request tendered on _____, i.e.
that these Admission Requests are appropriate to the facts of this case
Plaintiff
Name:
Address:
Respectfully submitted,
______________________
Christopher King, J.D.
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