Academy of Canine Behavior Lawsuit - To Be Filed in Snohomish 3 Aug 2018

IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON
IN AND FOR THE COUNTY OF SNOHOMISH
CHRISTOPHER KING, JD ) CASE NO. 18-2-06974-31

Clerk’s Action Required
Plaintiff,
)
vs.
) JUDGE_________________
ACADEMY OF CANINE BEHAVIOR
4705 240th Street SE )
Bothell, WA 98201
)
Defendant.
NOTICE OF HEARING
MOTION TO COMPEL COMPLETE GOOD FAITH RESPONSE TO
PLAINTIFF’S FIRST REQUESTS FOR ADMISSIONS
AND ALL INTERROGATORIES AND REQUESTS FOR
PRODUCTION OF DOCUMENTS
Now comes Plaintiff, to note the above-captioned matter is hereby set down for Hearing at
10:30 a.m. 12 October 2018 in Department A:
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CERTIFICATE OF SERVICE
I the undersigned, solemnly swear that a true and accurate copy of the foregoing Notice was
served on Defendant, via tracked priority U.S. Mail to:
John S. Feldmann
c/o Mark Miller Law Offices
15500 SE 30th Place
Suite 201
Bellevue, WA 98007
This 3rdh day of October 2018.
Respectfully submitted,
_______________________________
CHRISTOPHER KING, J.D.
2
3

Plaintiff,
)
vs.
) JUDGE_________________
Bothell, WA 98201
)
Defendant.
RULE 26i DECLARATION OF PLAINTIFF, CHRISTOPHER KING
Now comes Plaintiff, subject to the Penalties and Pains of Perjury to note the following
course of conduct:
1. A copy of his First Set of Interrogatories, Request for Production of Documents and
Request for Admissions was served on Defendant by Process Server John Rashleigh
on 10 August, 2018.
2. Plaintiff telephoned Counsel for Defendant on 12 September and told Defendant he

would afford Defendant until the end of the following week – 21 September 2018 –
to respond to all Discovery.
3. Counsel for Defendant indicated that his client would meet such extended deadline
with respect to all Discovery.
4. Plaintiff received Responses to his Request for Admissions within that timeframe,
subject to the concerns noted in his pending Motion to Compel.
5. As of today, 26 September 2018 Plaintiff has not received any Responses to his
Interrogatories or Request for Production of Documents, even though Defendant
told Plaintiff that he would have to go to Court to “Get a Subpoena” in order to
obtain records for his dog Pepper’s stay at AOCB.
6. The attached Motion is brought in absolute Good Faith.
___________________________
Sworn before me and subject to the Pains and Penalties of Perjury

this ____ day of September, 2018
Christopher King did personally appear and provide proof of identity
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_________________________
NOTARY PUBLIC
MY COMMISSION EXPIRES________________
5

Plaintiff,
)
vs.
) JUDGE_________________
Bothell, WA 98201
)
Defendant.
MOTION TO COMPEL COMPLETE GOOD FAITH RESPONSE TO

AND ALL INTERROGATORIES AND REQUESTS FOR
PRODUCTION OF DOCUMENTS
I. Plaintiff’s Request for Admissions.

May it please the Court:
Plaintiff sent Defendant the following set of clearly-articulated Demands for
Admissions. Once the Court reviews the Defendants’ responses to the requests it will be
obvious that they are no more than subterfuge and interposed to delay, vex, harass and
annoy. As such, Sanctions must be issued.
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May the Court recall that central to this case is an allegation of Fraudulent
Inducement as well as Fraud in the Factum relating to how a dog (Moxie the MinPin and
potentially more) died at AOCB and what AOCB told -- or neglected to tell -- Plaintiff about
the deaths.
Plaintiff hereby reproduces the Relevant Requests for Admissions along with
Defendant’s denials and arguments, with a short analysis as to why the responses to at least
two of them are issued in Bad Faith…. Despite a telephone conference with Counsel for
Defendant in which he promised to operate in Good Faith.
REQUEST FOR ADMISSIONS
1. Admit that Moxie the MinPin was in the same kennel run with two other dogs when
she died.
“Objection. This request for admission is for information regarding a dog not owned
by plaintiff and is irrelevant to plaintiff’s suit. Furthermore, plaintiff does not have
standing to request such information. Finally defendant submits any records
regarding A dog owned by another client other than the Plaintiff are privileged and
absent the permission of the dog owner or order of the Court Defendants are not
authorized to release information regarding such animal.”
Brilliant. That is exactly why this Motion to Compel is being filed: To obtain an
Order from this Honorable Court.
First of all, the request is clearly relevant because the theory of the case as far as
Fraudulent Inducement is concerned is that AOCB lied about the circumstances resulting in
Moxie the MinPin’s death. So the matter is patently relevant and Defendant’s assertions to
the contrary are Bad Faith responses.
Second, standing has been waived because Defendant offered up a subset of false
information ab initio as noted in Plaintiff’s Complaint. Defendant cannot open up the rabbit
hole with a series of lies about Moxie the MinPin and then proceed to hide behind
confidentiality. It does not work this way: In American Society for Prevention of Cruelty to
Animals et al. v. Ringling Brothers and Barnum and Bailey Circus et al. (D-Columbia 03-2006)
the Court ruled, over objection and request for Protective Order regarding animals not
owned by the Plaintiffs:
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“I’m going to order that all of these documents be produced. And when I say all, I mean
all, every last record.”
The Principles apply here as well. Amidst admissions of death and potential abusive policies
and practices the Defendants cannot sit on their hands and hide behind confidentiality in
any measure. Should the Court determine that the names and addresses of the owners
are subject to redaction or Protective Order that would be another matter, but the
information itself is hardly subject to protection in a case such as this.
2. Admit that one of the other dogs present with Moxie the MinPin when she died was
not from her same residential household.
“Same as answer to RFA 1.”
Plaintiff restates all the precedes in his Motion to Compel relative to Admission #1.
However, this response is even more specious than the first response because it does not
call for the release of any specific medical or veterinary records whatsoever, and the scope
of the inquiry is not greater than what was set forth by Defendant’s fraudulent inducement
statements, ab initio. It doesn’t get any clearer than this.
*********
Moreover, as to both issues perhaps the Court should be aware of the following new
information, received by Plaintiff on 19 September 2018:
The pattern of abuse continues unabated as Plaintiff has received notice from
another AOCB client that her dog was returned to them in the midst of a long boarding and
training session with a lost voice, a Urinary Tract Infection, kennel cough “and a puncture
wound [our] veterinarian said is consistent with a dog bite.”
The owner continues:
“I would like a copy of all of her records from her stay. Please confirm that you have
received this message and when can expect her records.”
Defendant responds by and through General Manager Becca:

“I apologize for the late response in getting back to you….. [Your dog] should have
never been allowed to be in a situation where she was close enough to a dog to
receive a bite….”
Yet and still Defendant failed to produce any actual documents or records regarding
the pet’s stay at AOCB because of their ongoing unlawful refusal to provide any documents
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that will be testified to from a well-respected area animal attorney as well, increasing the
need for Injunctive Relief in the overall case.
********
The foregoing Motion was hand-delivered by Plaintiff directly to Counsel on 12
September 2018, after reaching out to him in a telephone call in which Plaintiff afforded
Defendant until the end of the following week to respond to Discovery – 21 September.
This was actually extra time given as a courtesy because the Complaint and Initial
Discovery were all served on or about 10 August 2018 after the 6 August 2018 Court filing.
II. Plaintiff’s First Set of Interrogatories and Request for Production of Documents.
Not only are two of their Admissions Responses lacking, they by and through their
attorney reneged on a promise to provide Responses to Plaintiff's First Set of
Interrogatories and Request for Production of Documents. This is completely
unprofessional and at once besmirches the entire legal and dog community.
As noted on Plaintiff’s blog “Chris King’s First Amendment Page,” (online since
2005) Plaintiff telephoned Counsel for Defendant and the essence of the conversation was
as follows:
http://christopher-king.blogspot.com/2018/08/kingcast-and-others-say-expose-
seattle.html
https://www.youtube.com/watch?v=2QqO1uiIOvs
12 September 2018 update:

First off, I am busy with several other people who are helping to sue Seattle City
Council on blatant failure to overturn records involving the MERS sellout. That's too
deep to delve into in this space but here is the link to the RCW §42.56 lawsuit.
Next, I gave Defendants an extra week to respond to Discovery Requests. I'm a nice
guy. I play fair. Leave it at that.
Next, I cannot say too much because there were Settlement negotiations initiated.
What I can say is that I maintain that my Discovery requests are reasonable and that
I will prevail on any Motion to Compel, and my claims for Fraud will be proved
substantial enough to get to a Trier of Fact, which will be a Jury after I add my Jury
Demand. I told them any more questions they have for me I am more than happy to
answer in written Discovery and at my Deposition. I look forward to Deposing them
as well, on video as I shoot Deposition videos of course. That is all for now.
Ciao.
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At this point Plaintiff has not received responses to any of his Interrogatories or his
Request for Production of Documents, even though Plaintiff wrote a note on his Motion
delivered on Thursday the 20th that he would file the Admissions Motion to Compel on
Tuesday the 24th.
That sort of blatant disrespect has become the hallmark of Defendant’s misconduct
that was first noted and thoroughly documented on video by Plaintiff when Defendant, by
and through its owner as well as an alleged third party contractor, told Plaintiff he would
have to file suit to obtain any documents relative to his dog Pepper’s stay at AOCB.
Frankly, that is disgusting behavior and the Court must grant it no quarter and must
enter stern rebuke to Defendant, immediately. The relevant Interrogatories and Requests
for Production of Documents are reprinted below, along with a second set that is being
served today, 26 September 2018. The purpose of the Second Set is to demonstrate the
specious nature of Defendant’s Answer and Affirmative Defenses as well as its general
posture on Discovery as will be seen once the Court reviews them.
___________________________
Christopher King, J.D.
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Plaintiff Pro Se

Plaintiff,
)
vs.
) JUDGE_________________
Bothell, WA 98201
)
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.
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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).
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, in July 2018, you told Plaintiff King he would have to
issue a subpoena to obtain all boarding records for his dog Pepper.
ANSWER:
INTERROGATORY NO. 3: State whether you have administered any drugs to any boarded
dog without express notification to any owner since 1 January 2012 and describe the
process for administering same.
ANSWER:
INTERROGATORY NO. 4: State the names and breeds of dogs that were in the same kennel
run as Moxie the MinPin when she died.
ANSWER:
INTERROGATORY NO. 5: State which dogs present in the same kennel run as Moxie the
MinPin were from her actual household.
ANSWER:
INTERROGATORY NO. 6: State the names, breeds and approximate ages of each and every
dog who has died at AOCB since 1 January, 2012.
ANSWER:
INTERROGATORY NO. 7: For each entry above, provide a brief description of how the
death occurred.
ANSWER:
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INTERROGATORY NO. 8: State the dates of all client interaction, i.e. training and boarding,
with both of Plaintiff’s dogs (Livi and Pepper).
ANSWER:
INTERROGATORY NO. 9: State why, in July 2018, Kenton blocked Plaintiff’s motorcycle in
with his car as seen at Appendix A.
ANSWER:
INTERROGATORY NO. 10: State whether Defendant has been subject to any written
customer complaints since 1 January 2012.
ANSWER:
INTERROGATORY NO. 11: State whether Defendant has been the subject of any
investigations from any law enforcement or regulatory agency since 1 January, 2012 and if
the answer be in the affirmative, provide file numbers relative thereto.
ANSWER:
INTERROGATORY NO. 12: State whether Defendant has been sued by any client or law
enforcement or regulatory agency since 1 January, 2012 and if the answer be in the
affirmative, provide case numbers relative thereto and state the disposition of same.
ANSWER:
INTERROGATORY NO. 13: State the number of times that the whiffle ball bat was used in
training and state why it is no longer used.
ANSWER:
INTERROGATORY NO. 14: State why there is a bottle of 151 proof alcohol on the premises.
ANSWER:
INTERROGATORY NO. 15: State whether any employee has used any alcohol sprays on
any dog on the Premises at any point in time.
ANSWER:
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Plaintiff,
)
vs.
) JUDGE_________________
Bothell, WA 98201
)
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 each and every note, memorandum, letter, email or any other
communication created, maintained or electronically destroyed that contains the
name or any reference to the following:
a. Christopher King
b. Elisa Bronstein
c. Livi (their dog)
d. Pepper (their dog)
e. Moxie (the dead MinPin)
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2. Provide a copy of any and all documents that support Defendant’s position in
Interrogatory #1, supra.
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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:
John S. Feldmann
c/o Mark Miller Law Offices
15500 SE 30th Place
Suite 201
Bellevue, WA 98007
This 20h day of September, 2018.
(Admissions Motion)
and on 26 September 2018

(Interrogatories and Request for Production of Documents)
_______________________________
16
Plaintiff,
)
vs.
) JUDGE_________________
Bothell, WA 98201
)
Defendant.
PLAINTIFF’S SECOND SET OF INTERROGATORIES
17
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: Defendant claims in its Answer and Affirmative Defenses, by and
through licensed, sworn attorney John S. Feldmann, subject to Rule 11(a)(1):
……. The signature of a party or of an attorney constitutes a certificate by the party or

attorney that the party or attorney has read the pleading, motion, or legal memorandum,
and that to the best of the party's or attorney's knowledge, information, and belief, formed
after an inquiry reasonable under the circumstances:
(1) it is well grounded in fact;
…….that they called the police (Snohomish County Sheriff responding) “because
Plaintiff was being verbally abusive to defendant’s staff and guests.”
With such statement firmly in mind, please state with particularity and using quotations if
possible, exactly what Plaintiff said that was “verbally abusive” and to whom such “verbally
abusive” statements were allegedly made. Feel free to use Plaintiff’s unedited version of the
video covering the time in question from the time he rode up on his motorcycle as seen on
YouTube:
Expose Academy of Canine Behavior for Hiding Records and Lying About Dog Death.
https://www.youtube.com/watch?v=2QqO1uiIOvs
ANSWER:
INTERROGATORY NO. 3: State whether any of the aforementioned “guests” will be called
as witnesses. If the Answer be in the affirmative, provide names and contact information
for such guests, subject to Protective Order if desired.
ANSWER:
INTERROGATORY NO. 4: State exactly how Plaintiff allegedly failed to mitigate his
damages as Defendants allege in their Answer and Affirmative Defenses.
ANSWER:
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INTERROGATORY NO. 5: State whether you have told any other dog owners that the must
get a subpoena to obtain their dog’s records from 1 Jan 2012 to present.
ANSWER:
INTERROGATORY NO.6 : State whether you have told attorneys that they must get a
subpoena to obtain their client’s dog’s records from 1 Jan 2012 to present.
ANSWER:
INTERROGATORY NO.7: Describe your protocol for providing full records to dog owners
and to attorneys prior to the onset of litigation from 1 Jan 2012 to present.
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 September, 2018
Plaintiff
Name:
Address:
___________________________________________
19
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Plaintiff,
)
vs.
) JUDGE_________________
Bothell, WA 98201
)
Defendant.
PLAINTIFF’S SECOND REQUEST FOR PRODUCTION OF DOCUMENTS

1. Provide a copy of any audio-visual records from the Premises or any other type of
documents or paperwork that Defendant believes support its position that they
called the police (Snohomish County Sheriff responding) “because Plaintiff was
being verbally abusive to defendant’s staff and guests.”
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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:
___________________________________________
22
23
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CHRISTOPHER KING, JD ) CASE NO._______________
Plaintiff,
)
vs.
) JUDGE_________________
Bothell, WA 98201
)
Defendant.
ORDER GRANTING PLAINTIFF’S MOTION TO COMPEL

COMPLETE RESPONSES TO HIS FIRST SET OF
INTERROGATORIES, REQUEST FOR PRODUCTION OF DOCUMENTS
AND REQUEST FOR ADMISSIONS
This Cause came before the Court on 26 September 2018 pursuant to Plaintiff’s Motion to
Compel. Good Cause having been shown, the Court hereby finds in favor of Plaintiff and
issues the following specific ORDER:
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It is so ORDERED this ____ day of __________, 2018
_______________________
JUDGE
26
CHRISTOPHER KING, JD ) CASE NO._____________
Plaintiff,
)
vs.
) JUDGE_________________
Bothell, WA 98201
)
Defendant.
COMPLAINT
NOW COMES PLAINTIFF, CHRISTOPHER KING to bring this Action to help protect the life
and well-being of every dog in the State of Washington, and to seek redress for several
violations of contract and public policy.
JURISDICTION, PARTIES, AND VENUE
1. This court has subject-matter jurisdiction over this action.

2. Plaintiff CHRISTOPHER KING resides in Seattle, King County and was the co-
owner/guardian of LIVI The Wonderdog, a spayed female, four-year-old German
Shorthaired Pointer. The Plaintiff regarded Livi as his sentient personalty and immediate
family member.
3. Plaintiff CHRISTOPHER KING resides in Seattle, King County and is the owner-guardian of
PEPPER Underfoot the Australian Cattle Dog, a spayed female, three year-old Blue
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Heeler/German Shorthaired Pointer mix. The Plaintiff regards Pepper as his sentient
personalty and immediate family member.
4. Defendant Academy of Canine Behavior (hereinafter, “AOCB”) is, based on information
and belief, a legally-chartered facility in Snohomish County offering consumer services
including dog kenneling and training at all times relevant to this Action.
5. This court has personal jurisdiction over all named defendants.
6. Venue is proper
GENERAL ALLEGATIONS
7. Plaintiff and his former Partner trained and boarded Livi with AOCB on several occasions
in 2014-2016.
8. On December 29, 2016 Livi was killed by another dog after Livi and her family sibling
Fang Weatherwax were left completely unattended with inappropriate dogs not of their
pack.
9. On or about December 31, 2017 Plaintiff and his former Partner adopted Pepper and
notified Defendant that they were desirous to start training and/or occasional boarding
arrangements for Pepper with Defendant.
10. Defendant was well aware of the Livi’s history and successful litigation and settlement
with Attorney Adam P. Karp, through social media and personal contact with Plaintiff and
his former Partner.
11. Plaintiff specifically inquired about a death they had heard about at AOCB.
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12. Two individuals responded and told Plaintiff and his former Partner that a dog was
killed in their kennel by his canine household family member.
13. On information and belief culled from several current and/or former AOCB employees
this was and is a materially false account as to the death of the dog involved, who shall be
known as Moxie the MinPin.
14. On information and belief Moxie the MinPin wound up destroyed and partially eaten by
a dog not in Moxie’s household.
15. On information and belief a third dog was kenneled with Moxie and her family member
and that dog was Moxie’s killer.
16. On information and belief the offspring of a person who would become lead trainer was
responsible for the placement of Moxie’s killer with Moxie and her household sibling.
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17. The apparent material misrepresentation was given to Plaintiff and his then-Partner
because Defendant knew that any other explanation would result in the termination of any
relationship between the Parties and Defendant knowingly interjected this material falsity
into the chain of commerce with the express intent of retaining a business relationship in
spite of the falsity.
18. Based on this material and intentional misrepresentation, Plaintiff and his then-Partner
continued a relationship with Defendant, taking Pepper to two types of training at AOCB,
general obedience and Rally, and sending Kenton a high-resolution DSLR photograph for
him to use for marketing purposes.1
19. The Defendant’s statements where issued by and through persons of apparent, actual
and ostensible authority and Plaintiff and his then-Partner placed reasonable reliance on
the statements in continuing their relationship with Defendant.
20. Meanwhile, Plaintiff authored a draft bill entitled “Livi’s Law,” designed to penalize
kenneling with dogs not known to each other without express written consent.
21. Plaintiff raised the proposal to Defendant and was met with a complete lack of interest,
a fact he found odd.
21. Plaintiff boarded Pepper for approximately four (4) days in spring, 2018.
1 Rally, on information and belief, was taught by an independent contractor.
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22. On returning from the East Coast and retrieving Pepper he questioned AOCB staff
because they had told him Pepper was doing great with no problems at one point, but then
subsequently told him that she was not eating well and had diarrhea.
23. Plaintiff contemporaneously wrote Livi’s lawyer and his former Partner and advised
them that there were conflicting stories and he stated that he felt Pepper had been drugged.
24. Plaintiff’s former Partner advised him to trust his intuition.
25. Plaintiff expressly stated that he had no intention of suing over it, but added that he was
concerned and that he would be interested in seeing the full records.
26. Defendant provided what Plaintiff believes to be partial records.
27. Plaintiff was informed that AOCB has a pattern and practice of drugging dogs without
prior consent and without post-hoc acknowledgement.
28. In July, 2018 Plaintiff became aware of a viral video in which a trainer beats an allegedly
belligerent dog with a thin-walled whiffle bat.
29. Plaintiff also began to see other allegations of abuse as intimated above, including in-
line chaining of dogs and use of alcohol sprays with 151-proof alcohol and he therefore
demanded all of Pepper’s records, on video.
30. Livi’s former trainer Kenton and AOCB co-owner Jack McDaniel brought Plaintiff inside
into a back room under the pretense that they would talk openly about all of Plaintiff’s
questions. Instead they kicked Plaintiff out of the room as soon as he mentioned Moxie the
MinPin, denying his request for Pepper’s records.
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31. Incensed and shocked, Plaintiff returned the following day to narrow the issues. He
sought only Pepper’s records, whereupon both Kenton and Jack ended up making physical
contact with him in threatening manner.
32. Kenton and Jack also ordered the maintenance man to run a loud, gas-powered two-
stroke leaf-blower in and around Plaintiff to attempt to jar him and to drown out his video.
33. Speaking of two-strokes, Kenton then actually ran and got his car, a recent Subaru
sport-ute/station wagon, and attempted to block in Plaintiff’s motorcycle.
34. Instead of simply providing the records that are owed, Defendant called in a 911 to the
County Sheriff, asking that Plaintiff’s motorcycle be towed.
35. Plaintiff calmly met the Sheriff Deputies and explained what was really going on,
whereupon said Deputies had a cordial conversation with Plaintiff and informed Defendant
that Plaintiff’s motorcycle was actually on an easement and that it could not be towed and
that they would lose that battle. As the Deputies escorted Plaintiff back to retrieve his
motorcycle to illustrate the complete lack of tension coming from Plaintiff, one of them
stated “Nice motorcycle!” whereupon a short discussion was had about the particular
machine.
36. On information and belief, the Academy is willed to Kenton the Trainer.
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37. The Plaintiff is suffering, and continues to suffer severe emotional distress and loss of
enjoyment of life, among other general damages, as a direct result of Defendants’ acts and
omissions.
CLAIMS
Per CR 8(e)(2), the Plaintiff pleads the following as to Defendants:
37. Claim I: Fraudulent Inducement/Fraud in the Factum.

38. Claim II: RCW 19.86.090 (Consumer Protection Act)
39. Claim III: Outrage
40. Claim IV: Negligence (including negligent misrepresentation)
41. Claim V Breach of Contract
42. Claim VI: Breach of Bailment
43. Claim VII: Strict Common Law Liability
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PRAYER FOR RELIEF
WHEREFORE the Plaintiff seeks judgment against the Defendants as follows:

A. For the production of any and all records pertaining to Christopher King, Elisa
Brownstein, Livi or Pepper and the return of any and all monies spent with AOCB after Livi’s
death.
B. For noneconomic damages;
C. For prejudgment interest on liquidated sums;
D. For treble damages under RCW 19.86.090 for each Plaintiff;
E. For costs of suit;
G. For post judgment interest at 12% per annum or the highest rate permitted by law,
whichever is higher, pursuant to RCW 4.56.110;
H. For such other and further relief as the Court may deem just and proper.
Dated July 31, 2018
_________________________________
Plaintiff Pro Se
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APPENDIX A – FACES OF HATE
35
36
APPENDIX B – PLAINTIFF WAS NOT PREDISPOSED TO SUE ACOB
DSLR PICTURE OF KENTON SENT TO HIM FOR PROMOTIONAL PURPOSES
37
Plaintiff,
)
vs.
) JUDGE_________________
Bothell, WA 98201
)
Defendant.
PLAINTIFF’S FIRST SET OF INTERROGATORIES
38
INTERROGATORIES
INTERROGATORY NO. 16: 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. 17: State why, in July 2018, you told Plaintiff King he would have to
issue a subpoena to obtain all boarding records for his dog Pepper.
ANSWER:
39
INTERROGATORY NO. 18: State whether you have administered any drugs to any boarded
dog without express notification to any owner since 1 January 2012 and describe the
process for administering any drug to a boarded dog.
ANSWER:
INTERROGATORY NO. 19: State the names and breeds of dogs that were in the same
kennel run as Moxie the MinPin when she died.
ANSWER:
INTERROGATORY NO. 20: State which dogs present in the same kennel run as Moxie the
MinPin were from her actual household.
ANSWER:
INTERROGATORY NO. 21: State the names, breeds and approximate ages of each and
every dog who has died at AOCB since 1 January, 2012.
ANSWER:
INTERROGATORY NO. 22: For each entry above, provide a brief description of how the
death occurred.
ANSWER:
INTERROGATORY NO. 23: State the dates of all client interaction, i.e. training and
boarding, with both of Plaintiff’s dogs (Livi and Pepper).
ANSWER:
40
INTERROGATORY NO. 24: State why, in July 2018, Kenton blocked Plaintiff’s motorcycle
in with his car as seen at Appendix A.
ANSWER:
INTERROGATORY NO. 25: State whether Defendant has been subject to any written
customer complaints since 1 January 2012.
ANSWER:
INTERROGATORY NO. 26: State whether Defendant has been the subject of any
investigations from any law enforcement or regulatory agency since 1 January, 2012 and if
the answer be in the affirmative, provide file numbers relative thereto.
ANSWER:
INTERROGATORY NO. 27: State whether Defendant has been sued by any client or law
enforcement or regulatory agency since 1 January, 2012 and if the answer be in the
affirmative, provide case numbers relative thereto and state the disposition of same.
ANSWER:
INTERROGATORY NO. 28: State the number of times that the whiffle ball bat was used in
training and state why it is no longer used.
ANSWER:
INTERROGATORY NO. 29: State why there is a bottle of 151 proof alcohol on the premises.
ANSWER:
INTERROGATORY NO. 30: State whether any employee has used any alcohol sprays on
any dog on the Premises at any point in time.
ANSWER:
41
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 July 2018
Plaintiff
Name:
Address:
___________________________________________
42
Plaintiff,
)
vs.
) JUDGE_________________
Bothell, WA 98201
)
Defendant.
PLAINTIFF’S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS

8. Provide a copy of each and every note, memorandum, letter, email or any other
communication created, maintained or electronically destroyed that contains the
name or any reference to the following:
f. Christopher King
g. Elisa Bronstein
h. Livi (their dog)
i. Pepper (their dog)
j. Moxie (the dead MinPin)
43
44
these document requests are appropriate to the facts of this case
Dated this _______ day of July, 2018
Plaintiff
Name:
Address:
___________________________________________
45
Plaintiff,
)
vs.
) JUDGE_________________
Bothell, WA 98201
)
Defendant.

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.
46
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
24. Admit that Moxie the MinPin was in the same kennel run with two other dogs when
she died.
25. Admit that one of the other dogs present with Moxie the MinPin when she died was
not from her same residential household.
26. Admit that in July, 2018 Defendant twice refused to provide Plaintiff King with any
documents relative to his dog Pepper’s boarding at AOCB.
27. Admit that in July, 2018, Defendant by and through trainer Kenton, blocked Plaintiff
King’s motorcycle on a day when he was asking for Pepper’s documents.
28. Admit that in July, 2018, Defendant called the Snohomish County Sheriff on a 911
call and requested that Plaintiff King’s motorcycle be towed.
29. Admit that the Snohomish County Sheriff told Defendant that they would likely lose
the battle if they towed Plaintiff King’s motorcycle.
47
these Admission Requests are appropriate to the facts of this case
Dated this _______ day of July, 2018
Plaintiff
Name:
Address:
______________________
48

Academy of Canine Behavior Lawsuit - To Be Filed in Snohomish 3 Aug 2018

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IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON

IN AND FOR THE COUNTY OF SNOHOMISH

CHRISTOPHER KING, JD ) CASE NO. 18-2-06974-31

CHRISTOPHER KING, JD ) CASE NO. 18-2-06974-31

RULE 26i DECLARATION OF PLAINTIFF, CHRISTOPHER KING

2. Plaintiff telephoned Counsel for Defendant on 12 September and told Defendant he

6. The attached Motion is brought in absolute Good Faith.

Sworn before me and subject to the Pains and Penalties of Perjury

CHRISTOPHER KING, JD ) CASE NO. 18-2-06974-31

MOTION TO COMPEL COMPLETE GOOD FAITH RESPONSE TO

I. Plaintiff’s Request for Admissions.

REQUEST FOR ADMISSIONS

“Same as answer to RFA 1.”

Defendant responds by and through General Manager Becca:

12 September 2018 update:

IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON

CHRISTOPHER KING, JD ) CASE NO. 18-2-06974-31

PLAINTIFF’S FIRST SET OF INTERROGATORIES

CHRISTOPHER KING, JD ) CASE NO. 18-2-06974-31

PLAINTIFF’S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS

TO EACH NAMED DEFENDANT: The following interrogatories are in compliance

DEMAND FOR PRODUCTION OF DOCUMENTS

and on 26 September 2018

CHRISTOPHER KING, JD ) CASE NO. 18-2-06974-31

PLAINTIFF’S SECOND SET OF INTERROGATORIES

……. The signature of a party or of an attorney constitutes a certificate by the party or

(1) it is well grounded in fact;

SUBMITTING PARTY’S CERTIFICATION

Dated this _______ day of September, 2018

CHRISTOPHER KING, JD ) CASE NO. 18-2-06974-31

PLAINTIFF’S SECOND REQUEST FOR PRODUCTION OF DOCUMENTS

TO EACH NAMED DEFENDANT: The following interrogatories are in compliance

DEMAND FOR PRODUCTION OF DOCUMENTS

SUBMITTING PARTY’S CERTIFICATION

these document requests are appropriate to the facts of this case

Dated this _______ day of September, 2018

CHRISTOPHER KING, JD ) CASE NO._______________

ORDER GRANTING PLAINTIFF’S MOTION TO COMPEL

CHRISTOPHER KING, JD ) CASE NO._____________

JURISDICTION, PARTIES, AND VENUE

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

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

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

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

WHEREFORE the Plaintiff seeks judgment against the Defendants as follows:

B. For noneconomic damages;

C. For prejudgment interest on liquidated sums;

D. For treble damages under RCW 19.86.090 for each Plaintiff;

E. For costs of suit;

Dated July 31, 2018

CHRISTOPHER KING, JD ) CASE NO._______________

PLAINTIFF’S FIRST SET OF INTERROGATORIES

Dated this _______ day of July 2018

CHRISTOPHER KING, JD ) CASE NO._______________

PLAINTIFF’S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS

TO EACH NAMED DEFENDANT: The following interrogatories are in compliance

DEMAND FOR PRODUCTION OF DOCUMENTS

these document requests are appropriate to the facts of this case

Dated this _______ day of July, 2018

CHRISTOPHER KING, JD ) CASE NO._______________

PLAINTIFF’S FIRST REQUESTS FOR ADMISSIONS

TO EACH NAMED DEFENDANT: The following interrogatories are in compliance

REQUEST FOR ADMISSIONS