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.

RESPONDENTS RESPONSE TO BRIEFING ORDER OF 28 SEPTEMBER 2017

A. Motion to Reconsider Briefing Order of 28 September 2017.

Prior to the Courts 28 September 2017 pronouncement to hear the case on Briefs, there
were four (4) issues for the Court on that date:
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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.
The audio is here:

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.

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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 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 diminishes Mr. Kings
right to defend the case in the manner he sees most appropriate, i.e. by and through a video
presentation.

As such the Court must reverse the ORDER of 28 September 2017 eliminating an open Court.

B. The Merits of the Reconsideration and the Underlying Case.

Respondent has thoroughly briefed the underlying matter and refers the Court to his Trial
Brief, filed on or about 31 July, 2017.

As to the Reconsideration of the dismissal, the Complaining Partys history before this Court
is directly relevant. His Honor punished her a year ago and thats a FACT. A local law
enforcement officer recently found her to be a liar, and recommended that everything she
said be taken with a grain of salt. That is not an acrimonious statement, it is a VALID LEGAL
ARGUMENT, as noted hereinbelow.

Anyone can call their doctor and get an excuse, and recall that the Court awarded the wages
to Amlaks husband, who was NOT sick and who DID NOT appear for the 11 September
hearing. So a logical legal and fully permissible argument is that he is also in Bad Faith.
Failure to argue as much could constitute legal malpractice, in point of fact.

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C. Acrimony.

As to the Acrimony concerns posited by this Court, Respondent directs the Courts attention to:

1. Complaining Party, who 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. (Appendix B).1

2. These YouTube videos, as provided to the Court on an SD card for the Record.

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

3. 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:

4. Another example could be the fact that Complaining Party herself stated her father was
brain-damaged and destroyed by drugs. Her comments stating as much are at Appendix
C and see at the YouTube Court Hearing at 0:40 in:

https://www.youtube.com/watch?v=pNd1kBqD7kM
This is precisely the sort of thing that Judge Goodwin is pointing to when he uses the code
word "I warned you about the acrimony" when in point of fact I am airing legitimate
concerns that a community SHOULD be aware of, but he is impliedly holding it against me. I
have a right to be "acrimonious" over these findings.

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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She has no true right to be "acrimonious" to me but I suppose she too is protected by the
First Amendment unless she is truly stalking or threatening me and she is not, nor am I
doing same to her.

As such, the Respondents Pending Demand for Findings of Fact and Conclusions of Law as
to the alleged antipathy of any legal argument is relevant.

D. Conclusion and Prayer for Relief.

This entire scenario is a complete waste of time set in motion, and continued in
motion, by Complaining Party. It is so clearly without merit that were she an attorney
she would have been thoroughly SANCTIONED for Bad Faith pursuant to Rule 11 for
all of the reasons manifest in Respondents Trial Brief and Notices of Bad Faith.

The Respondent is working with friends and Livis attorney to commence fundraising to sue
the Complaining Party and that is the ONLY Legal battlefield on which this war shall rage. As
neither party has truly stalked or harassed the other in a Legal sense, any other ruling
would be antithetical to the First Amendment to the United States Constitution and its
related Washington Statutory scheme.

Further, Respondents Motion to Recuse Judge Fraser Nunc Pro Tunc must be GRANTED.

Further, Respondents Motion for Lost Wages must be GRANTED.

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

CERTIFICATE OF SERVICE

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

5808 218th PL SW
Mountlake, Terrace WA 98043

This 6th day of October, 2017

_____________________________________
CHRISTOPHER KING, J.D.

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