UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF WISCONSIN

CHRISTOPHER KING, JD., ) CASE NO. 3:19-CV-000063

)
Plaintiff,
)
vs.
) JUDGE WILLIAM CONLEY
STATE OF WISCONSIN ET AL.,
)
Defendants.

PLAINTIFF KING’S RESPONSE TO DEFENDANT’S REQUEST FOR

201(e) HEARING ON PLAINTIFF’S DEMAND FOR JUDICIAL NOTICE

I. Defendant’s Request is a Waste of Judicial Resources and the Parties’ Time.

First of all we are all fully aware the no document Plaintiff provided in this matter was
“photoshopped” at all. Second, we are aware that Counsel for Defendant (Terry L. Johnson) was
already fully aware of everything because of the OLR letter granting his extension of time in
which to respond to the findings that his client (Defendant Rattan) inter alia, “Confront[ed] King
in an angry and threatening manner in the course of a public disciplinary hearing…

Third, we are aware that Attorney Johnson has been proceeding hysterically in a parallel
Universe in which Plaintiff somehow altered the video/audio of the Hearing, and in which
Plaintiff allegedly traveled State to State looking for people to sue when in point of fact he was
running a Title Company, managing Zoning and other Property and Leasing matters for this
Country’s wireless infrastructure & earning Mayoral Commendation for First Amendment work.

1
 Lastly, it may be a bit much to understand in Plaintiff’s little Negro mind how his
suspension from Practice 18 years ago is purportedly relevant to this proceeding yet what
Attorney Johnson and his client did 18 months ago is purportedly not. Perhaps Attorney Johnson
can elucidate on this point. Plaintiff King awaits such an attempt poised on the edge of his seat,
with bated breath.1

Plaintiff King will nonetheless stay tuned for any direction from this Honorable Court as
to when such a Hearing may take place, at which point we can all get together and waste yet more
time and Judicial Resources to indulge Attorney Johnson in his hysterical machinations: He must
continue to attempt to prove that Plaintiff King is the proverbial “Bad Guy” just because he is an
intelligent Black Man capturing unsavory misconduct of Attorney Johnson’s clients and other
Mortgage industry representatives in Attorney Nora’s case and in scores of others.
Respectfully submitted,

_______________________
Christopher King, J.D.
Plaintiff Pro Se

1
In the event that Counsel for Defendants missed it, the matters from 18 years ago were actually found to
be irrelevant and “unrelated” by the OLR as clearly seen in paras 25-27 of their Report. And at least one
highly respected Disciplinary Panelist expressly stated that “racism, ignorance and reactionary politics”
played a role in said suspension anyway. Meanwhile Plaintiff King anticipates full payment to the Ohio Bar
in the calendar year 2019 and return to Practice – should he so choose – after a year of CLE requirements.

2
 UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WISCONSIN

CHRISTOPHER KING, JD., ) CASE NO. 3:19-CV-000063

)
Plaintiff,
)
vs.
) JUDGE WILLIAM CONLEY
STATE OF WISCONSIN ET AL.,
)
Defendants.

PLAINTIFF KING’S MEMORANDUM CONTRA

DEFENDANT’S MOTION TO STRIKE
PLAINTIFF’S DEMAND FOR JUDICIAL NOTICE

I. Plaintiff King Provides a Clean Copy of the OLR Report on Defendant Rattan.1

First of all, Counsel for Defendants would do well to understand the fundamental
difference between a photoshopped image and an annotated Administrative Finding. To assist in
that endeavor Plaintiff provides an example of a photoshopped image relative to another case that
will soon be filed in Federal Court. Note how Facebook CEO Mark Zuckerberg is not really the
cartoon monopoly man but his face appears as if he is. In other words, the original content has
been modified or changed in a way that bears no verisimilitude to the original. So this image then
is both photoshopped AND annotated:

1
See Appendix A.

1
In marked contrast, the previously-filed OLR imagery was ANNOTIZED ONLY. Take a look:

Therefore, once we remove the ANNOTATION the underlying document reads the same,
i.e. “By confronting King in an angry and threatening manner in the course of a public
disciplinary hearing….”

And of course the portions about Defendant Rattan remain as damning as they ever were, i.e.
“expressing no remorse” and prattling on about “unrelated matters” and finding that Defendant
Rattan – by and through Attorney Johnson mind you – falsely claimed that video had been
altered. The highly astute observer might see a pattern here:

2
 The same stale bag of ad hominem hot air is continually set forth toward this Court in
hopes that it will reify the hateful bigotry that Plaintiff King experienced. It shall not, however,
and that is precisely what has set Defendants scrambling. (Findings Paras 25-27).

Again, the only doctored video that Plaintiff has ever been involved in relates to the
release of wrongly-convicted 32-year prisoner Darrell Jones back in Brockton, Massachusetts. As
it turns out, Plaintiff is working on a documentary with film makers who are still there because
Plaintiff was Mr. Jones’ courtroom videographer before and during WBUR’s tenure on the case
with the Innocence Project et al.
http://darrelljonesinnocent.blogspot.com/
https://www.youtube.com/watch?v=y8B_vUpmhM4
The Sheer Madness of Plymouth County DA in the Darrell Jones Retrial
The video segment that appears in screen shot right here on the following page has been illegally
ALTERED and the Chief Detective committed PERJURY. When Plaintiff caught up with the
area prosecutor in Court he was not thrilled, as seen above. Sorry not sorry.

II. The Document is Self-Authenticating.

Now that Plaintiff King has submitted the entire document in clean fashion devoid of
annotation, complete with cover letter from OLR to Attorney Johnson dated 2 January 2018
granting an extension of time and that is all the authentication that is required. Unless of Course
Attorney Johnson wants to go off on another hysterical and unfounded, racist and hegemonic rant
about how Plaintiff King must have falsified something else. It gets rather tiresome. Especially
from a guy who sits on an OLR Review Panel. Perhaps he has a reading comprehension problem
and that is why it is “incomprehensible” to him and that is why he needed an extension of time.

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III. Judicial Notice May be Taken at any Time.
Should the Court deny the other aspects of Plaintiff King’s Memorandum then Plaintiff
King Respectfully requests that the Court consider solely the OLR document in and of itself. In
point of fact, Wisconsin Law provides that Judicial Notice may be taken at any time and is in fact
MANADATORY in this instance:
902.01 (4) WHEN MANDATORY. A judge or court shall take judicial notice if requested
by a party and supplied with the necessary information.2

IV. Defendant’s Conclusion should be Stricken.

Again, Defendant is attempting to bring in other matters that are as the OLR determined
to be “unrelated.” Even if Defendant were taking aim at Plaintiff, Plaintiff has provided the Court
with many other examples of successful litigation undertaken by Plaintiff King so we are not here
to take an assessment of Plaintiff King’s wins and losses. There is no “Disbarment” or
“Permanent Suspension.”
He is making payments on his Ohio fines and will eventually be in Good Standing again
whether or not he chooses to practice or take other avenues. None of that is before the Court right
now. What is before the Court – if Attorney Johnson can comprehend it – is the conduct of the
Defendants, pure and simple.
Furthermore, where is this litigation history of Defendant Rinaldi that Attorney Johnson
prattles on about, to wit:
“King and his companion litigants in the other two cases that the Court severed from the
instant case, Wendy Allison Nora and Roger Rinaldi, have a litigation history under
which they observe no rules but their own….”

Such are the ramblings of a bigoted mind full of hate and hubris and not much else. The
Court must disregard same and Strike form the Record.
Respectfully submitted,

_______________________
Christopher King, J.D.
Plaintiff Pro Se

2
At some point Attorney Johnson’s unbridled hubris must take a back seat to Justice and Common Sense.
Plaintiff respectfully submits that such moment has now arrived, via the lowly “permanently suspended”
nigger attorney who has suffered enough abuse at the hands of these Defendants to last a lifetime.