IN THE SNOHOMISH SOUTH DIVISION COURT

LYNNWOOD, WASHINGTON

KRISTINA M. ROBINSON, )

Complainant, CASE No. STK17-0005

)
JUDGE GOODWIN
v.

CHRISTOPHER KING, J.D. )

Respondent.

RESPONDENTS PRE-HEARING BRIEF

AND DEMAND FOR JUDICIAL NOTICE

1. Judicial Notice.

Now comes Respondent, as a professional photojournalist who

routinely runs video in Snohomish County Court, to note pursuant to ER
201(d) that the Complaining Party (hereinafter, C.P.) Kristina Robinson and
her cohorts have a recent, documented history of vitriolic comments and a
lack of understanding about the boundaries of appropriate use of social
media resulting in an Order of Protection from this very Court last year (Ex
1). The relevance of this fact will become readily apparent in short order.

2. Relevant Background.

This is, first and foremost, a matter of extreme Public Importance.

Major TV is already poised to cover this case and the City of Mountlake
Terrace has issued rulings against CP on several occasions. These rulings are
designed to curb an unlawful use of the Subject Premises in Mountlake
Terrace for a kenneling business.
Respondent and his Partner left their two dogs ostensibly in the care of
CP and her husband Ahadu Amlaktereda beginning December 21, 2016 and
scheduled to conclude on January 4, 2017. Unbeknownst to them, their
animals were being kept at Respondents home under the care of a man that
CP describes as mentally ill and destroyed by drugs.

1
 At approximately 6:45pm CP and her father whom she refers to as Mike
Robinson, decided it would be a good idea to leave the home and to abandon
our dogs Livi and Fang on the turf of their own pack of four dogs, including
one German Shepherd mix and some three Pit Bull/ bully mixes, along with
Duba (a recurring client), and perhaps one other dog.
CP has said she knows scuffles happen and that it is her job to
deescalate them. To do so, CP would have to be present. In our case, she was
not.
When her husband Ahadu arrived home at 7:32pm Livi was dead, most
likely killed by CPs own Pit Bull Nova (as reported by the first responding
officers on December 29th, 2016). CP had been warned on several prior
occasions to terminate unlawful kenneling at her home Premises and a new
ORDER was put forth echoing the prior ORDERS after Livis mauling death.
CPs established pack of dogs was left on their turf, with multiple unfamiliar
dogs for no less than 45 minutes. During which time a fight broke out, and no
pack leaders of the human variety were present to break it up. 1
Respondent and his Partner requested an insurance declaration page but did
not receive any formal apology, flowers, cards or offer to pay for cremation,
and so 4-5 days later they appeared at City Council and retained Attorney
Adam Karp to represent them, after he rejected CP as a client.

1 The City of Mountlake Terrace has not released the final report even though the
purported investigation was completed nearly two weeks ago. In that time span
Respondent and his Partner have discovered financial ties between the house where
Livi was mauled and killed, the Crazy Moose Casino and City Councilor Seaun
Richards. Respondent has substantial experience in criminal investigations stemming
from his job as daily reporter prior to law school, victory in several Criminal Civil
Rights Trials and Appellate work and ongoing murder investigations and film work.

2
 Livi brought life to the entire community.

Since that time Respondent and his Partner have interviewed former
employees, neighboring businesses, submitted public records requests and
pored through endless documents that all point to the money and influence
trial present that is referenced at Fn1, as the city conducts business affairs
with the Crazy Moose Casino, and CP and her former manager both worked
for the Casino and City Councilor Richards stored materials at the subject
Premises.

**************

3. Complaining Party Fails to Meet her Burden to Show by a

Preponderance of the Evidence That Respondent has Engaged in any
Threatening or Otherwise Unlawful Conduct.

The only thing this Court has to consider is whether Respondent who
does not even own a gun -- made a credible threat to shoot a dog in the head
and whether Respondent has unlawfully used his investigative skills to
unlawfully harass someone engaged in commercial activity.

3
 First there is the fact that there are no TRO's against Respondent for
threatening anyone but this Court had one against Kristina after she said she
and her biker friends noted that her neighbors were racist pricks and
motherfuckers who needed some fear put in them. (Ex. 2)
Respondent will now address CPs allegations in seriatim.

A. Her father Mike.

In point of fact, CP has publicly stated that "drugs destroyed my
dad" and that he is "mentally ill." As this man, unbeknownst to us,
was watching our dogs, we are entitled to publicly question these
facts. (Ex 3). Good Karma Tattoo studio echoed Respondents
observations that Mike appears mentally or physically disabled.
https://www.youtube.com/watch?v=MOvOkrYmnCM
Fecal Matters: Issues of Public Concern with Kristina Robinson and
Precious Paws

B. The purported threat to a third party.

Respondent has reproduced the entire conversation between
himself and Patti Angeliz, owner of Valhalla Rescue (Ex. 4). The
conversation speaks for itself and clearly does not include any
threats, and the conversation was terminated the minute that Ms.
Angeliz claimed she felt harassed.

Meanwhile Ms. Angeliz had told Respondents Partner and co-owner

of Livi, that she needed to get over it because dogs dont live
forever, a completely insensitive comment.
Respondent, in addressing such rude comment, stated as a figure of
speech, well if it doesnt matter when a dog dies how about I come
over and shoot one of yours in the head if it doesnt matter?
Respondent unlike Kristinas husband have never had a gun
registered to him in the State of Washington in the 4 years he has
lived here. Respondent has not received information from any Court
of Law that Ms. Angeliz has sought any protection from him,
because it was obviously a figure of speech and unlike Mr.
Amlaktereda Respondent doesnt even own a gun!

C. Cameras and Children

First of all, Respondent is a professional videographer who runs
courtroom video in Snohomish, King and other Superior Courts on
more occasions than he can remember in the past 4 years. As
already addressed in a prior filing with the
Court CP brought her children to a public forum on her own volition,
whereupon Respondent told Ahadu immediately that night that he
would censor children out even though he was under no true legal
obligation to do so and was permitted to shoot stills and video in
Mountlake Terrace City Hall, unlike CP who illegally captured images
in this very Court without Court permission and published them to
YouTube.

4
 As the Court can see, Respondent did indeed edit the child out of
any pictures he posted (Ex. 5). No cameras were ever directly in
anyone's face at any time and if that had been a concern Mountlake
Terrace City officials would have taken appropriate action.

D. Expectation of Privacy: Posting the house address.

This is a matter of legal, public and political concern. The City has
made a finding that there is an illegal business there on several
occasions. CP is running her business via her familys residence, so
there is no real expectation of privacy.
Therefore it is not tantamount to Ms. Robinson setting up a spy cam
on her neighbors residence and placing their private activities up
for public inspection by the entire Free World. That is clearly
abusive conduct. In contrast, the only footage used by Respondent
of the home address

E. Respondents Track Record of Professionalism in Washington vis a

vis CPs Vitriolic Commentary.

i. Respondents Track Record on media.

Suffice it to say Respondent is well-versed in the principles of
First Amendment Law and Prior Restraint and have never
once been removed from a courtroom for inappropriate
conduct nor has any of his courtroom footage been stricken
from my YouTube channel, which has 3,500 subscribers and
1,5M views. In point of fact, Complaining Partys husband
Ahadu Amlaktereda was a YouTube subscriber of
Respondents:

In contrast to the unauthorized courtroom imagery captured and used by

CP, Respondent hereby submits relevant links from prior Snohomish
Courtrooms in which the Court has AFFIRMED his media presence as

5
consonant with any and all State and Federal Statutory and Constitutional
Principles.
https://www.youtube.com/watch?v=IIvdb_p3ftU&t=1s

Washington Foreclosure Attorney Scott Stafne Oral Arguments in Bradburn v

ReconTrust Fraudclosure. 3277 views

https://www.youtube.com/watch?v=V33jTD9Dc94
Frail Elderly Woman Fights Select Portfolio Servicing on Statute of Limitations
1,136 views

https://www.youtube.com/watch?v=9oL_zeSx1Bc

Select Portfolio Looses Summary Judgment on Fraudulent Mortgage in

Snohomish Washington 1,685 views

https://www.youtube.com/watch?v=_r7QDqbW5rQ

Frail Elderly Woman Fights Select Portfolio Servicing on Removal of Wrongful

Foreclosure Lawsuit. 3,325 views

https://www.youtube.com/watch?v=ObmhqFe4QNo

Select Portfolio Lawyer Gets Away with Testifying in Little RICO 9A.82
Washington Foreclosure Case 994 views

And of course the most relevant video to date from Snohomish County,
in which Respondents access was contested. Obviously he prevailed in that
analysis for the same reason he must prevail in shooting video footage in this
one and even more so considering that the case personally involves
Respondent, his Partner and the mauling death of their best friend at the
hands of a reckless CP.
These are matters of compelling governmental and societal interest,
i.e. does a black man whose dog was killed in a reckless kennel suddenly
become a Dangerous Black Man by lawfully exercising his First Amendment

6
Rights in a First Amendment, Anti-SLAPP, Harassment, Stalking or Prior
Restraint context?

https://www.youtube.com/watch?v=bPzKdfb8lGU

Interviews with Attorney and Frail Elderly Pro Se on Little RICO Sustained
Against NWTS 787 views

ii. Continuing Vitriolic Commentary by CP and her Associates.

As opposed to Respondents commentary regarding CPs business
practices, CP is hosting comments that refer to Respondent as a Negro
Negro who Lives off of his girlfriend and others and imply that Ms.
Bronstein is in some way living under lock and key i.e. blink twice if you
need to be rescued. Another one writes you are trash and you will always
be trash, and yet another wrote that he wished Livi had bitten Respondents
face off in a video where Respondent and Livi were horsing around on his
couch. One example is attached hereto, with more to follow for introduction
in Court (Ex 6)

CONCLUSION AND PRAYER FOR RELIEF:

REINSTATEMENT OF ALL CONSITTUTIONAL RIGHTS, IMMUNITIES AND
PRIVILEGES

7
 Respondent is going to continue to investigate the reckless death of his
dog. He will continue to post commentary and observations directly relating
to the current and recent business practices of CP. Respondent will neither
encourage or participate in personal diatribes against CP or her family, nor
will be post anything that does not have direct relation to the business
practices of CP. In point of fact, if anyone is owed an harassment TRO it would
be Respondent, rather than CP.
Further, while Respondent does not own a gun that does not inherently
mean that he finds this intrusion into his Constitutional and Statutory Rights,
Privileges and Immunities to be in any ways tolerable. It was yet another
attempt by CP to make herself the victim after her reckless conduct
foreseeably caused the death of Respondent and his Partners Best Friend,
and the Best Dog either of them have ever known. 2
As such, Respondent moves this Honorable Court to summarily dissolve this
Temporary Restraining ORDER and grant any such relief to Respondent as the
Court deems appropriate.

2 Even at that, CP encourages people on her blog to denigrate Respondent and his
Partner for immediately adopting, even as they attend a City-managed Pet Loss
Support Group in which the directors support this move. CP and her associates are
once again engaging in emotionally abusive conduct and demonstrating a"Lack of
understanding about the boundaries of appropriate use of social media."
Despite 12 years of aggressive political and legal blogging Respondent has not once
had a court make any such finding against him, ever. Today should not be any
exception to that Professional Rule.

8
 21 December 2016: The last time we would ever see our baby Livi alive.

Respectfully submitted,

/s/ Christopher King

CHRISTOPHER KING, J.D.
kingcast955@icloud.com
mortgagemovies007@gmail.com
http://affordablevideodepo.com
http://mortgagemovies.blogspot.com
617.543.8085m
206.299.9333f

CERTIFICATE OF SERVICE

I, the undersigned, solemnly swear that a true and accurate copy of the
foregoing

9
Brief was sent via hand delivery to Complaining Party by leaving an extra
courtesy copy with the Court on 7 January 2017 at the scheduled hearing

_____________________________________
CHRISTOPHER KING, J.D.

10
EXHIBIT 1

11
12
EXHIBIT 2

13
EXHIBIT 3

14
EXHIBIT 4

15
16
17
 JAN 17TH, 12:24PM
Christopher
Hi Pattti... did Kristina adopt Nova from you? You know, the dog that killed
Livi?
They accepted your request.

Patti
I have no idea which dog caused the fatal injuries amd will not
speculate..... Nova was adopted from the rescue as a puppy many years
ago and in that time I have seen Nova interact here online thru pictures,
updates which would require from all adopters and at public events, like
the anti vick rally with many other dogs, cats and children and never
once saw her display one drop of aggression. I do not know which dog
caused the Fatal injuries to yours and i am so sorry that it happened, but
cannot speak of things i do not know.
Christopher
Understood. Kristina has publicly stated that Nova was the dog of hers
that was clearly most damaged. Just goes to show that's why you don't
leave dogs alone, particularly bully breeds. As noted, we love all dogs but
extra care must be taken as a professional.

Patti
Well if Nova was most damage that would imply that she was a victim
and not the aggressor
Christopher
Nice try. It indicates that a weaker breed like Livi tried to save her life.
Especially when Kristina admitted a prior act of aggression.

Patti
Pardon me???? You obviously don't know dog behavior very well. When a
fight ensues a pack mentality happens and when more than one dog is
involved many dogs can be injured.
What you just stated implies that Nova could have been a victim that
your dog could have attacked her and that the other dogs when after
your dog to protect her.
I am not going to believe that an anxious hunting dog is submissive or
weaker than any other dog. I have been a vet tech for almost 20 years
and have seen hunting dogs harm other dogs and humans just as easily.
Since none of us were there none of us can insinuate which dog started
the fight. My dog was nearly killed by a dog a quarter of her size. So nice
try on your part.

18
Christopher
Livi has no other acts of violence. I understand how packs work. I wish
Kristina did or she would not have left them alone. None of the other
dogs were injured BTW. So according to your theory attacked Nova, which
is more conjecture than anything especially when we know from Kristina's
own mouth that there were PRIOR ACTS OF VIOLENCE. And you should
have publicly acknowledged that Nova was your rescue.

Patti
You know mr. King we have no idea what happened there your
conjecture, my conjecture, it's all conjecture. There was food involved in
anything could have happened absolutely anything.
And why should she acknowledged which rescue she got Nova from have
you publicly acknowledged which rescue you got your dog from? No vote
was a puppy Less Than 3 months old she has lived peacefully in their
home for many, many years
Nova*
Christopher
What we do know however is that she left them ALONE and that Livi was
not where she was supposed to be. There's not need for me to
acknowledge where we got Livi because it's irrelevant. Obviously we are
biased it's our dog, silly. But you hid your bias shame on you.

Patti
Just like it's irrelevant where she got Nova from. Nova was a puppy when
she left our care and we have followed her through the required updates
that we ask all our doctors to do and never once has Nova been involved
in any other issues. If your dog attacked Nova first over this food that it
would make sense that her dogs would jump in to protect a member of
their family.
Christopher
It's not irrelevant to your bias. Have a nice day.
I'll make sure that city hall receives your thoughts on the matter.

Patti
My bias is towards the dogs and the dogs only. I prefer to wait for a judge
and not City Hall.. if I am subpoenaed then I will bring my thoughts to
court gladly
Christopher
Good. We look forward to you explaining why it's ok to leave dogs
unattended and not do what was promised in terms of daily exercise with
a high-anxiety dog, and why it's ok not to tell clients that your dogs have
a prior violent history. Good Luck with that.

19
Patti
I never want implied it was okay to leave the dogs alone, so do not put
words in my mouth. It can easily be asked why you would leave a high-
anxiety dog in a daycare. And not find someone privately to care for
them in your home
Christopher
Livi is only high anxiety when not exercised as promised. We have had
many other people watch her with NO PROBLEM. Unfortunately we
believed Kristina when she promised she was fully licensed and would
exercise Livi daily at the shop. Get it? Good.

Patti
You too have just admitted that you knew your dog was very anxious and
high anxiety. I would never place a dog with those kind of emotional
issues in a daycare situation. The dog would only be with highly trained
private individuals or in a boarding facility where it did not have to
interact with other animals.

Patti
And yes I get your opinion, do not be rude to me and speak to me like a
human being an adult. I am not on either side of this fence and only
defending the dogs. To me you both are wrong and you both accept
50/50 responsibility for Livi's death. You know your dog has special
requirements and you chose to not Place her in a place with someone
that had the certifications. It was your job to ensure the safety of your
dog. If you wanted to believe somebody without checking further into
their qualifications then that is on you
Christopher
I didn't admit any of that. She's a sporting breed who needs exercised.
Top professionals in the city have worked with her and pronounced her a
kind soul with no documented issues of high anxiety or violence, unlike
Kristina's dogs. You are impliedly trying to blame Livi . And you can blame
us for believing Kristina's lies all you want to but it still doesn't make it
right

Patti
I personally never leave my dogs with anybody that is not hoghly trained.
In fact I had traveled around the country with my dogs so there is no
reason to have not taken them with you no matter what the excuse

20
Once and for all I am deeply sorry for the loss of your dog but this could
have been prevented had you done more homework and not placed her
there in the first place.
Christopher
Oh so now it's our fault for not taking our dogs with us. Wow. Livi has
trained here and we will cac call them if necessary. http://www.aocb.com/

Patti
It is 50-50 but you were never going to see that so there was nothing I
can do to have you accept responsibility. I am glad that your beloved
companion was so easily replaced and I would hope that you would move
on

Note: This is crazy talk, abusive talk from Patti: Its somehow our
fault 50-50% because Kristina left our dog unattended with her pack of
pit bulls? Shameful blame game. And yet another abusive comment
beloved companion so easily replaced, I would hope that you move on.
How rude two weeks after Livi was mauled to death by the dog she dealt
to Kristina in the first place, according to Kristinas own commentary. This
woman has no business in the dog industry.
Patti
I don't know what you hope to accomplish with this, but I am sure that
they will close down their business if the judge instructs them to. But you
handing them and coming after me is not helping the situation and
definitely does not make you look like the victim anymore. You are
harassing me at this point and I feel you need to stop
Christopher
The only asshole bigger than the asshole who believes a lie is the asshole
who tells it and runs an illegal operation. Livi was not "easily replaced"
but we have a beautiful new baby girl to ease the pain. Nothing will
replace Livi I've been around dogs 51 years and NEVER met a dog like
her. We will move on healing and move on legally on all fronts. You can
count on that.
Christopher
Ok I see your request now. Goodbye.

Patti
Are yoy calling me an asshole????

Christopher
Nope.

21
 EXHIBIT 5
Interview with Good Karma Tattoo owners:

Kristina Robinsons father had an accident per Kristina the night that
they found feces smeared over their storefront and door handle.

I have compassion for his situation but that doesnt mean I want him
watching our dogs, feeding our dogs, protecting our dogs WITHOUT MY
KNOWLEDGE.

22
 EXHIBIT 6
More vitriol from Kristina Robinsons quarter, same as last year:

Negro Negro, You are Trash

23
Lowlife Scumbag Nice talk

24
 IN THE SNOHOMISH SOUTH DIVISION COURT
LYNNWOOD, WASHINGTON

KRISTINA M. ROBINSON, )

Complainant, CASE No. STK17-0005

)
JUDGE __________________
v.

CHRISTOPHER KING, J.D. )

Respondent.

NOTICE OF MEDIA COVERAGE

Now comes Christopher King, J.D., and http://christopher-

king.blogspot.com/ and http://mortgagemovies.blogspot.com/, pursuant to

the First Amendment of the Constitution of the United States:

Amendment I
Congress shall make no law respecting an establishment of religion, or
prohibiting the free exercise thereof; or abridging the freedom of speech, or
of the press; or the right of the people peaceably to assemble, and to petition
the government for a redress of grievances.

May it please the Tribunal:

I am a former Assistant Attorney General who has also managed a title

insurance company as a title insurance producer. I have prevailed as an
attorney on several criminal trials involving First Amendment matters. I
began running courtroom video of said trials 19 years ago and have since
covered murder trials, mortgages and intellectual property trials with my
courtroom cameras, including multiple videos in the Snohomish County
Courthouse. Prior to those activities I was an editor and reporter for mid-sized
and large daily press. Suffice it to say I am well-versed in the principles of
First Amendment Law and Prior Restraint and have never once been removed
from a courtroom for inappropriate conduct nor has any of my courtroom
footage been stricken from my YouTube channel, which has 3,500 subscribers

25
and 1,5M views. In point of fact, Complaining Partys husband Ahadu
Amlaktereda was a YouTube subscriber of mine:

I have submitted relevant links from prior Snohomish Courtrooms in

which the Court has AFFIRMED my media presence as consonant with any
and all State and Federal Statutory and Constitutional Principles.
https://www.youtube.com/watch?v=IIvdb_p3ftU&t=1s

Washington Foreclosure Attorney Scott Stafne Oral Arguments in Bradburn v

ReconTrust Fraudclosure. 3277 views

https://www.youtube.com/watch?v=V33jTD9Dc94
Frail Elderly Woman Fights Select Portfolio Servicing on Statute of Limitations
1,136 views

https://www.youtube.com/watch?v=9oL_zeSx1Bc

Select Portfolio Looses Summary Judgment on Fraudulent Mortgage in

Snohomish Washington 1,685 views

https://www.youtube.com/watch?v=_r7QDqbW5rQ

Frail Elderly Woman Fights Select Portfolio Servicing on Removal of Wrongful

Foreclosure Lawsuit. 3,325 views

26
https://www.youtube.com/watch?v=ObmhqFe4QNo

Select Portfolio Lawyer Gets Away with Testifying in Little RICO 9A.82
Washington Foreclosure Case 994 views

And of course the most relevant video to date from Snohomish County, in
which my access was contested. Obviously I prevailed in that analysis for the
same reason I must prevail in this one, and even more so considering that the
case personally involves me and these are matters of compelling
governmental and societal interest, i.e. does a black man whose dog was
killed in a reckless kennel suddenly become a Dangerous Black Man by
lawfully exercising his First Amendment Rights in a First Amendment, Anti-
SLAPP, Harassment, Stalking or Prior Restraint context?

https://www.youtube.com/watch?v=bPzKdfb8lGU

Interviews with Attorney and Frail Elderly Pro Se on Little RICO Sustained
Against NWTS 787 views

Lastly, should there be any question as to publication of pictures or videos

involving the Complaining Partys children, I have never published their
images even though it is likely lawful for me to do so when they are in a

27
public space. In point of fact I even told them directly that this is not about
the children and I would NEVER publish them. I have not, and will not. In
point of fact I edited a child out of the arms of its mentally ill grandfather 3 in
one picture.

The father was included because unbeknownst to me, he was watching our
dog when our dog was mauled and killed at CPs unlicensed home.

Respectfully submitted,
/s/ Christopher King
CHRISTOPHER KING, J.D.
kingcast955@icloud.com
mortgagemovies007@gmail.com
http://affordablevideodepo.com
http://mortgagemovies.blogspot.com
617.543.8085m
206.299.9333f

IN THE SNOHOMISH SOUTH DIVISION COURT

LYNNWOOD, WASHINGTON

KRISTINA M. ROBINSON, )

Complainant, CASE No. STK17-0005

)
JUDGE __________________
v.

CHRISTOPHER KING, J.D. )

Respondent.

ORDER GRANTING PLAINTIFFS NOTICE OF MEDIA COVERAGE

This matter came before the Court pursuant to Plaintiffs Notice of

Media Coverage. As the Court finds this this Notice to be well-grounded in

3 CP has publicly stated that her father is mentally ill. The fact that she never
informed my partner of that illness, or that he would be watching our dogs and their
children at the same time is a matter for another Court.

28
existing law, Respondent shall be permitted to record and to publish video
subject to any and all constraints of the law as it exists at the day, date
and time of this Ruling.

IT IS SO ORDERED THIS ____ Day of _____________, 2017

____________________________

JUDGE

29
 CERTIFICATE OF SERVICE

I, the undersigned, solemnly swear that a true and accurate copy of the
foregoing
Motion to Compel was sent via tracked Priority U.S. Mail to Complaining Party
on _____ January 2017 at the following address:

Kristina M. Robinson
5808 218th Pl SW
Mountlake Terrace, WA 98403

_____________________________________
On behalf of:
Law Office of Scott Stafne
239 N. Olympic Ave.,
Arlington, WA 98223

30
 IN THE SNOHOMISH SOUTH DIVISION COURT
LYNNWOOD, WASHINGTON

KRISTINA M. ROBINSON, )

Complainant, CASE No. STK17-0005

)
JUDGE __________________
v.

CHRISTOPHER KING, J.D. )

Respondent.

MOTION IN LIMINE OF RESPONDENT KING

Respondent files this Motion in Limine regarding a conversation in

which he allegedly threatened to shoot a third partys dog in the head. As
an initial matter, Respondent hereby submits more of the entire
conversation with said third party for context such that the Court may see
that there was no credible threat.
Further, Complaining Party lacks Standing to assert an interest
allegedly belonging to a third party. This is clearly a trumped-up attack
and attempt to chill the exercise of Inalienable First Amendment Rights.
Unlike Complaining Party, Respondent has no criminal record whatsoever,
whereas Complaining Partys pattern and practice is to delay and to shirk
her responsibilities, witness her two-year long stall tactics relative to her
conviction for a crime of moral turpitude involving deceit, i.e. a plea
bargain to Attempted forgery in this very County. She never completed
her Community Service and had not one, not two, but THREE bail
revocations. See Case No. 1878A-04F Ex. 1 as attached to Respondents
Motion to Compel.
In point of fact, the purported threat occurred over a week ago and in
point of fact Respondent immediately ceased communications with the

31
third party Patti Angelize the minute she requested, so Respondent is well
aware of his legal obligations in this respect.

32
Moreover, Patti Angeliz and Kristina Robinson are completely untrustworthy
and fabricate lies: They publicly claim that Respondent and his Partner are
not clients, apparently forgetting that there is an E-Track Record that
distinctly proves otherwise, with some of the payment history and Ms.
Robinsons own statement that we were indeed our kind of clients.

33
34
35
36
 And there it is, all paid up.

CONCLUSION
There is simply no credible threat involved here, and even if there
were, it is not directed at Complaining Party. As such, the purported threat
should not even be considered by the Court in its analysis.

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

CERTIFICATE OF SERVICE

I, the undersigned, solemnly swear that a true and accurate copy of the
foregoing
Motion in Limine was sent via tracked Priority U.S. Mail to Complaining Party
on _____ January 2017 at the following address:

Kristina M. Robinson
5808 218th Pl SW
Mountlake Terrace, WA 98403

_____________________________________
On behalf of:
Law Office of Scott Stafne
239 N. Olympic Ave.,
Arlington, WA 98223

37
Member of Washington Animal Rescue Resources
12:24PM
Hi Pattti... did Kristina adopt Nova from you? You know, the dog that killed
Livi?
They accepted your request.

I have no idea which dog caused the fatal injuries amd will not speculate.....
Nova was adopted from the rescue as a puppy many years ago and in that
time I have seen Nova interact here online thru pictures, updates which
would require from all adopters and at public events, like the anti vick rally
with many other dogs, cats and children and never once saw her display one
drop of aggression. I do not know which dog caused the Fatal injuries to yours
and i am so sorry that it happened, but cannot speak of things i do not know.

Understood. Kristina has publicly stated that Nova was the dog of hers that
was clearly most damaged. Just goes to show that's why you don't leave dogs
alone, particularly bully breeds. As noted, we love all dogs but extra care
must be taken as a professional.

Well if Nova was most damage that would imply that she was a victim and
not the aggressor
Nice try. It indicates that a weaker breed like Livi tried to save her life.
Especially when Kristina admitted a prior act of aggression.

Pardon me???? You obviously don't know dog behavior very well. When a fight
ensues a pack mentality happens and when more than one dog is involved
many dogs can be injured.
What you just stated implies that Nova could have been a victim that your
dog could have attacked her and that the other dogs when after your dog to
protect her.
I am not going to believe that an anxious hunting dog is submissive or
weaker than any other dog. I have been a vet tech for almost 20 years and
have seen hunting dogs harm other dogs and humans just as easily.
Since none of us were there none of us can insinuate which dog started the
fight. My dog was nearly killed by a dog a quarter of her size. So nice try on
your part.

38
Livi has no other acts of violence. I understand how packs work. I wish
Kristina did or she would not have left them alone. None of the other dogs
were injured BTW. So according to your theory attacked Nova, which is more
conjecture than anything especially when we know from Kristina's own mouth
that there were PRIOR ACTS OF VIOLENCE. And you should have publicly
acknowledged that Nova was your rescue.

You know mr. King we have no idea what happened there your conjecture, my
conjecture, it's all conjecture. There was food involved in anything could have
happened absolutely anything.
And why should she acknowledged which rescue she got Nova from have you
publicly acknowledged which rescue you got your dog from? No vote was a
puppy Less Than 3 months old she has lived peacefully in their home for
many, many years
Nova*
What we do know however is that she left them ALONE and that Livi was not
where she was supposed to be. There's not need for me to acknowledge
where we got Livi because it's irrelevant. Obviously we are biased it's our
dog, silly. But you hid your bias shame on you.

Just like it's irrelevant where she got Nova from. Nova was a puppy when she
left our care and we have followed her through the required updates that we
ask all our doctors to do and never once has Nova been involved in any other
issues. If your dog attacked Nova first over this food that it would make sense
that her dogs would jump in to protect a member of their family.
It's not irrelevant to your bias. Have a nice day.
I'll make sure that city hall receives your thoughts on the matter.

My bias is towards the dogs and the dogs only. I prefer to wait for a judge and
not City Hall.. if I am subpoenaed then I will bring my thoughts to court gladly
Good. We look forward to you explaining why it's ok to leave dogs unattended
and not do what was promised in terms of daily exercise with a high-anxiety
dog, and why it's ok not to tell clients that your dogs have a prior violent
history. Good Luck with that.

I never want implied it was okay to leave the dogs alone, so do not put words
in my mouth. It can easily be asked why you would leave a high-anxiety dog
in a daycare. And not find someone privately to care for them in your home
Livi is only high anxiety when not exercised as promised. We have had many
other people watch her with NO PROBLEM. Unfortunately we believed Kristina
when she promised she was fully licensed and would exercise Livi daily at the
shop. Get it? Good.

39
You too have just admitted that you knew your dog was very anxious and
high anxiety. I would never place a dog with those kind of emotional issues in
a daycare situation. The dog would only be with highly trained private
individuals or in a boarding facility where it did not have to interact with other
animals.

And yes I get your opinion, do not be rude to me and speak to me like a
human being an adult. I am not on either side of this fence and only
defending the dogs. To me you both are wrong and you both accept 50/50
responsibility for Livi's death. You know your dog has special requirements
and you chose to not Place her in a place with someone that had the
certifications. It was your job to ensure the safety of your dog. If you wanted
to believe somebody without checking further into their qualifications then
that is on you
I didn't admit any of that. She's a sporting breed who needs exercised. Top
professionals in the city have worked with her and pronounced her a kind soul
with no documented issues of high anxiety or violence, unlike Kristina's dogs.
You are impliedly trying to blame Livi . And you can blame us for believing
Kristina's lies all you want to but it still doesn't make it right

I personally never leave my dogs with anybody that is not hoghly trained. In
fact I had traveled around the country with my dogs so there is no reason to
have not taken them with you no matter what the excuse
Once and for all I am deeply sorry for the loss of your dog but this could have
been prevented had you done more homework and not placed her there in
the first place.
Oh so now it's our fault for not taking our dogs with us. Wow. Livi has trained
here and we will call them if necessary. http://www.aocb.com/

It is 50-50 but you were never going to see that so there was nothing I can do
to have you accept responsibility. I am glad that your beloved companion was
so easily replaced and I would hope that you would move on

I don't know what you hope to accomplish with this, but I am sure that they
will close down their business if the judge instructs them to. But you handing
them and coming after me is not helping the situation and definitely does not
make you look like the victim anymore. You are harassing me at this point
and I feel you need to stop
The only asshole bigger than the asshole who believes a lie is the asshole
who tells it and runs an illegal operation. Livi was not "easily replaced" but we
have a beautiful new baby girl to ease the pain. Nothing will replace Livi I've
been around dogs 51 years and NEVER met a dog like her. We will move on
healing and move on legally on all fronts. You can count on that.

40
Ok I see your request now. Goodbye.

Are yoy calling me an asshole????

Nope.
Chat Conversation End

IN THE SNOHOMISH SOUTH DISTRICT COURT

LYNNWOOD, WASHINGTON

KRISTINA M. ROBINSON, )

Complainant, CASE No. STK17-0005

)
JUDGE __________________
v.

CHRISTOPHER KING, J.D. )

41
 Respondent.

ORDER GRANTING PLAINTIFFS MOTION IN LIMINE

This matter came before the Court pursuant to Respondents Motion

in Limine relative to a communication with a third party. The Court finds
that the Motion is well-taken and hereby GRANTS the Motion in Limine.
The purported threat shall not be admitted to Court relative to the
Complaining Partys allegations.

IT IS SO ORDERED THIS ____ Day of _____________, 2017

____________________________

JUDGE

42
 IN THE SNOHOMISH SOUTH DIVISION COURT
LYNNWOOD, WASHINGTON

KRISTINA M. ROBINSON, )

Complainant, CASE No. STK17-0005

)
JUDGE __________________
v.

CHRISTOPHER KING, J.D. )

Respondent.

RESPONDENTS MOTION FOR LEAVE OF COURT

TO COMPEL RELEVANT ELECTRONIC EVIDENCE: VIDEO

As an initial point of Interest, Respondent has only photographed

Complaining Party at public fora, i.e. Mountlake Terrace City Hall, as
consonant with his inalienable First Amendment Rights. He shoots video in
Snohomish County Court as a matter of Course:

https://www.youtube.com/watch?v=IIvdb_p3ftU&t=1s

Washington Foreclosure Attorney Scott Stafne Oral Arguments in Bradburn v

ReconTrust Fraudclosure. 3277 views

https://www.youtube.com/watch?v=V33jTD9Dc94
Frail Elderly Woman Fights Select Portfolio Servicing on Statute of Limitations
1,136 views

https://www.youtube.com/watch?v=9oL_zeSx1Bc

Select Portfolio Looses Summary Judgment on Fraudulent Mortgage in

Snohomish Washington 1,685 views

https://www.youtube.com/watch?v=_r7QDqbW5rQ

43
Frail Elderly Woman Fights Select Portfolio Servicing on Removal of Wrongful
Foreclosure Lawsuit. 3,325 views

https://www.youtube.com/watch?v=ObmhqFe4QNo

Select Portfolio Lawyer Gets Away with Testifying in Little RICO 9A.82
Washington Foreclosure Case 994 views

https://www.youtube.com/watch?v=bPzKdfb8lGU

Interviews with Attorney and Frail Elderly Pro Se on Little RICO Sustained
Against NWTS 787 views

He has never published any pictures of Complaining Partys children

and has expressly told Complaining Party he would never do so.
On 24 January, 2017 Respondent was driving on 218 th Pl SW to deliver a
box of information to Complaining Partys (hereinafter, CP) neighbor at
5803 218th Pl SW. The box contains, inter alia, documents from a case in
which a neighbor of Complaining Party obtained a TRO against Complainant
for video stalking/harassment/voyeurism.
As Respondent missed the desired house, he proceeded to the end of
the road, passing Complaining Partys home and turning around in the cul-de-
sac. Forensic evidence will show that he looked up Google Maps again to see
exactly where the desired house was. At the precise moment CP and her
husband Ahadu Amlaktereda, descended upon him with phone cameras
blazing and the following colloquy ensued:
Im not here for you. Im here for your neighbor.
Youre harassing me.
No, I am not, Im just driving down a public street.
The cops are coming.
Good. Im not doing anything wrong.
Youre . (indescifrable)
Tell it to your nonexistent lawyer.

44
 Respondent believes that the video demonstrates his general
demeanor and complete lack of intent to threaten anyone with physical
violence. Plaintiff has direct knowledge that CP has falsely indicated that she
was represented by Jim Johanson, Esq. in the pending Civil case against her
when in point of fact he DOES NOT represent her.
As such, she bought more time through dishonesty to produce
information regarding her homeowners policy which she has failed to
produce for Attorney Adam Karp for several weeks now. In point of fact, she
failed to produce insurance information to Respondent when he asked for it to
avoid having to obtain a lawyer ab initio.
CPs pattern and practice is to delay and to shirk her responsibilities,
witness her two-year long stall tactics relative to her conviction for a crime of
moral turpitude involving deceit, i.e. a plea bargain to Attempted forgery in
this very County. She never completed her Community Service and had not
one, not two, but THREE bail revocations. See Case No. 1878A-04F Ex. 1.

45
 CONCLUSION
The sought materials are not requested to vex, annoy or to harass but
are clearly relevant and probative to all claims and defenses in this case.
They must be preserved and produced. In the civil matter CP has still not
guaranteed or produced E-Discovery sought by Attorney Karp.

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

46
 IN THE SNOHOMISH SOUTH DIVISION COURT
LYNNWOOD, WASHINGTON

KRISTINA M. ROBINSON, )

Complainant, CASE No. STK17-0005

)
JUDGE __________________
v.

CHRISTOPHER KING, J.D. )

Respondent.

ORDER GRANTING PLAINTIFFS MOTION TO COMPEL

This matter came before the Court pursuant to Plaintiffs Motion to

Compel relevant video evidence of an exchange between the Parties. As
the Court finds this material may be probative the Court hereby GRANTS
said Motion. Complaining party shall make her cell phone available for
review at the scheduled hearing on February 7, 2017.

IT IS SO ORDERED THIS ____ Day of _____________, 2017

____________________________

JUDGE

47
 CERTIFICATE OF SERVICE

I, the undersigned, solemnly swear that a true and accurate copy of the
foregoing
Motion to Compel was sent via tracked Priority U.S. Mail to Complaining Party
on _____ January 2017 at the following address:

Kristina M. Robinson
5808 218th Pl SW
Mountlake Terrace, WA 98403

_____________________________________
On behalf of:
Law Office of Scott Stafne
239 N. Olympic Ave.,
Arlington, WA 98223

48