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Peter S.

Holmes, City Attorney

Jessica Nadelman
Assistant City Attorney
(206) 386-0075
jessica.nadelman@seattle.gov

October 4, 2018

Christopher King
12048 Greenwood Avenue
Seattle, Washington 98133

Via electronic mail to: kingcast955@icloud.com

RE: King v. City of Seattle, KCSC No. 18-2-22718-6 SEA

Dear Mr. King:

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,

SEATTLE CITY ATTORNEY’S OFFICE


701 FIFTH AVENUE, SUITE 2050, SEATTLE, WASHINGTON 98104-7097
(206) 684-8200 FAX (206) 684-8284 TTY (206) 233-7206
an equal employment opportunity employer
October 2, 2018
Page 2

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,

/s/ Jessica Nadelman

Jessica Nadelman
Assistant City Attorney

Re: King v. City of Seattle


13 minutes ago at 2:42 PM
From Christopher King
To Nadelman, Jessica"

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.

File your Motion.

Sent from my iPhone

PETER S. HOLMES
Seattle City Attorney

By: ____________________________________
[Attorney Name]
Assistant City Attorney

SEATTLE CITY ATTORNEY’S OFFICE


701 FIFTH AVENUE, SUITE 2050, SEATTLE, WASHINGTON 98104-7097
(206) 684-8200 FAX (206) 684-8284 TTY (206) 233-7206
an equal employment opportunity employer
IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON
IN AND FOR THE COUNTY OF KING

CHRISTOPHER KING, JD ) CASE NO. ______________

Plaintiff,
)
vs.
) JUDGE_________________
CITY OF SEATTLE
600 Fourth Avenue )
Seattle, WA 98104
)
Defendant.

FIRST AMENDED COMPLAINT

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.

JURISDICTION, PARTIES, AND VENUE

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


2. Plaintiff CHRISTOPHER KING, JD resides in Seattle, King County and is a mortgage
industry professional who has managed a title company as a title insurance
producer (residential closing attorney). A former daily news reporter, he hosts
several blogs, most notably “Chris King’s First Amendment Page” and “Mortgage
Movies Journal” and a TV show “Corruption Meets Camera” on ROKU TV, hosted by
VH2 Networks. His general alter ego is known as “KingCast.”
3. Defendant CITY OF SEATTLE is a duly-chartered municipal entity located in King
County subject to suit.
5. This court has personal jurisdiction over all named defendants.

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6. Venue is proper.
GENERAL ALLEGATIONS

7. In 2013 Plaintiff led a mortgage/underwater home/foreclosure forum attended


by current and past members of, and candidates for, Seattle City Council.
8. In 2013 Plaintiff made several videos for successful City Hall Candidate Kshama
Sawant.
9. In or about 2014 Defendant, at taxpayer expense, hired Forensic Auditor Marie
McDonnell to research the implications and impact of Mortgage Electronic
Registration Services (MERS) on King County area mortgages.
10. The Washington Department of Financial Institutions (DFI) has found MERS to
be a fraudulent business practice in DFI v. Planet Home Lending (C-16-1936-16-
CO01) and other cases.
http://dfi.wa.gov/sites/default/files/consumer-services/enforcement-actions/C-
16-1936-16-CO01.pdf
11. Former Washington Attorney General Robert M. McKenna has condemned
MERS in an Amicus Brief for the precedent-setting case of Bain.
12. Ms. McDonnell has testified in many trials, most notably a successful $5M trial in
Texas involving Wells Fargo and MERS. In Seattle she issued a review that noted
false documents and legal infractions that have led to unlawful foreclosure and
which, in her opinion, should have resulted in assessment of fines and penalties
running into the tens or hundreds of millions.
13. Seattle City Council sat on the review or audit, prompting Plaintiff to leak it, as
his sources had provided him a version of the document, as noted by award-winning
writer David Dayen in The 18 September 2015 Intercept story “Leaked Seattle Audit
Concludes Many Mortgage Documents are Void.”
https://theintercept.com/2015/09/18/leaked-seattle-audit-concludes-many-
mortgage-documents-void/
14. Meanwhile, because of outright malice and because of cozy relationships with
the banking industry, Defendant refused to allow Ms. McDonnell to come to publicly
present her findings.

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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

18. Meanwhile many protesters and mortgage professionals and attorneys


implored Seattle City Council to sue MERS because Oregon’s Multnomah County had
sued MERS and settled for $9M. Ms. McDonnell was reduced to being a two-minute
public speaker. From 14 December, 2014:
https://www.youtube.com/watch?v=nqXIIO_o6RU
Seattle City Council Confronted on Public Speakers Transparency and $9M
Multnomah County MERS Lawsuit

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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

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

Claim I: Bad Faith, Willful Violation of RCW §42.56

PRAYER FOR RELIEF

WHEREFORE the Plaintiff seeks judgment against the Defendants as follows:

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;

B. For noneconomic damages;

C. For prejudgment interest;

D. For Bad Faith treble damages and/or substantial Punitive Damages;

E. For costs of suit;

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.

Dated 10 September, 2018

_________________________________
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

CHRISTOPHER KING, JD ) CASE NO. 18-2-22718-6 SEA

Plaintiff,
)
vs.
) JUDGE_________________
CITY OF SEATTLE
)
Defendant.

PLAINTIFF’S REVISED FIRST SET OF INTERROGATORIES

TO EACH NAMED DEFENDANT: The following interrogatories are in compliance


with King County Local Rule 33. In accordance with Washington Superior Court Rules
26 and 33, please answer each of the following interrogatories separately, fully, in writing
and under oath. Each answer must be as complete and straightforward as the information
reasonably available to you permits after reasonable inquiry, including the information
possessed by your attorneys or agents. If an interrogatory cannot be answered
completely, answer it to the extent possible.

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:

INTERROGATORY NO. 3: State the date on which Defendant’s Public Information


Portal was opened for use for:

a) The Seattle Police Department.


b) Seattle City Council.

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:

a) The Seattle Police Department.


b) Seattle City Council.
c) Any City entity.

ANSWER:

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 facts of
this case
Dated this _______ day of October 2018

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

CHRISTOPHER KING, JD ) CASE NO. 18-2-22718-6 SEA

Plaintiff,
)
vs.
) JUDGE_________________
CITY OF SEATTLE
)
Defendant.

PLAINTIFF’S REVISED FIRST REQUEST


FOR PRODUCTION OF DOCUMENTS

TO EACH NAMED DEFENDANT: The following interrogatories are in compliance


with King County Local Rule 34. In accordance with Washington Superior Court Rules
26 and 34, please respond within the time allotted by Rule.

DEMAND FOR PRODUCTION OF DOCUMENTS

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.

2. Provide a copy of all documents responsive to Plaintiff’s initial request as


contemplated by Interrogatory #2, supra.

3. Provide a copy of all documents responsive to Plaintiff’s initial request as


contemplated by Interrogatory #3, supra.

4
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

CHRISTOPHER KING, JD ) CASE NO. 18-2-22718-6 SEA

Plaintiff,
)
vs.
) JUDGE_________________
CITY OF SEATTLE
)
Defendant.

PLAINTIFF’S FIRST REQUESTS FOR ADMISSIONS

TO EACH NAMED DEFENDANT: The following interrogatories are in compliance


with King County Local Rule 36. In accordance with Washington Superior Court Rules
26 and 36, please answer each of the following queries separately, fully, in writing and
under oath.

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.

REQUEST FOR ADMISSIONS

1. Admit that Defendant has never -- as of 16 October 2018 -- published any


writings of any kind that expressly limit the Portal identified by Defendant’s 4
October 2018 letter to Plaintiff as the exclusive manner in which to file a Request
for Public Records pursuant to RCW §42.56.

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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

CHRISTOPHER KING, JD ) CASE NO. ______________

Plaintiff,
)
vs.
) JUDGE_________________
CITY OF SEATTLE
600 Fourth Avenue )
Seattle, WA 98104,
)
Defendant.

PLAINTIFF’S FIRST SET OF INTERROGATORIES

TO EACH NAMED DEFENDANT: The following interrogatories are in compliance


with King County Local Rule 33. In accordance with Washington Superior Court
Rules 26 and 33, please answer each of the following interrogatories separately,
fully, in writing and under oath. Each answer must be as complete and
straightforward as the information reasonably available to you permits after
reasonable inquiry, including the information possessed by your attorneys or
agents. If an interrogatory cannot be answered completely, answer it to the extent
possible.

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

facts of this case

Dated this _______ day of September 2018

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

CHRISTOPHER KING, JD ) CASE NO. ______________

Plaintiff,
)
vs.
) JUDGE_________________
CITY OF SEATTLE
600 Fourth Avenue )
Seattle, WA 98104
)
Defendant.

PLAINTIFF’S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS

TO EACH NAMED DEFENDANT: The following interrogatories are in


compliance with King County Local Rule 34. In accordance with Washington
Superior Court Rules 26 and 34, please respond within the time allotted by Rule.

DEMAND FOR PRODUCTION OF DOCUMENTS

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.

2. Provide a copy of all documents responsive to Plaintiff’s initial request as


contemplated by para._____ to the Complaint.

12
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 September, 2018

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

CHRISTOPHER KING, JD ) CASE NO. ______________

Plaintiff,
)
vs.
) JUDGE_________________
CITY OF SEATTLE
600 Fourth Avenue )
Seattle, WA 98104
)
Defendant.

PLAINTIFF’S FIRST REQUESTS FOR ADMISSIONS

TO EACH NAMED DEFENDANT: The following interrogatories are in


compliance with King County Local Rule 36. In accordance with Washington
Superior Court Rules 26 and 36, please answer each of the following queries
separately, fully, in writing and under oath.

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.

14
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.

REQUEST FOR ADMISSIONS

1. Admit that prior to initiation of this lawsuit Defendant never provided any
documents responsive to this request tendered on _____, i.e.

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 September, 2018

Plaintiff

Name:
Address:

Respectfully submitted,

______________________
Christopher King, J.D.

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