10 February 2011

KingCast sees Judge Barbadoro order Amended Pleadings in KingCast v. Friends of Kelly Ayotte, GOP, Nashua PD NH Dist. 2010-CV-501.

Hard to tell from my Galaxy S but it appears from the ECF tag that everyone's motions were denied.

Update: His Honor had some choice words to say about everyone's Motions and Memoranda (The Defendants' Motions are at once particularly dilatory and obfuscatory) but the bottom line is that I got exactly what I wanted, the chance to file a Second Amended Complaint including the newfound footage of Nashua PD driving me out of the entire Crowne Plaza Hotel at the Joe Arpaio "Steak Out." Read the passage from this morning's pleading in the thumbnail at right. It will make an interesting addition to my presentation this weekend at the Annual NENPA Trade Show (para. 2).

And now here's The Thing Of It: I know Judge Barbadoro is one of the more conservative judges I'll ever practice before. But at the same time I believe he is going to take a good hard look at this case and at Oral Argument on the Motion to Dismiss he could very well look up at Defendants and say "What's the problem here..... why can't Mr. King be present to attend and gather information at these publicly advertised events that are held on commercial property subject to substantial state and local licensing and permitting.....?"

And I have one question for Counsel for Defendants: "Will you accept service and Waiver of Summons on behalf of the Defendants as most lawyers do in this circumstance, or are you going to hardball me and make me pay for Sheriff Process servers?"


SHE said...

Is he your new judge? Or just happens to be the judge reviewing today?

An ethics law prof told me today that he sees the judge having come from the same law firm as Defendant and all Defendants lawyers as a major ethical problem.

Christopher King said...

He is the Judge, period. The Magistrate is Judge McCafferty.

At one point Judge DiClerico (His Honor ruled against Ayotte for $300K Planned Parenthood fees that Ayotte publicly misrepresented) had it, I have no idea why it was transferred.


SHE said...

I'll chip in if they decide to be jerks about service.

Anonymous said...

You're an idiot. Your brief looks as if it was written by a five year old. Why don't you stop wasting your time on a goal that you will never achieve and actually use your legal degree to help people. You appear to be more content acting like a dog chasing a car that he will never catch then acting like an actual practicing attorney. Clearly you're upset at your own insignificance and thus are trying to waste taxpayer time and money on frivolous suits with no merit. No one is oppressing you, no one is out to get you, you have created all of your own problems with this bullshit. I am a liberal and absolutely no fan of Kelly Ayotte but your obsession is downright scary. Place your energy and resources towards an issue you can actually tackle instead of doing idiotic publicity stunts and then crying about the reaction you receive.

Christopher King said...


You must be one of those liberals over at Daily Kos who kicked me off the board for saying I was correct the last time I defeated Kelly Ayotte on First Amendment and racial claims when I was NAACP Legal Chair of Southern NH.

They said I couldn't tackle it, "take a plea."

You offer no substantive analysis of the brief and you ignored the fact that the Defendants have repeatedly lied and misrepresented key issues to the Court.

I will discuss idiots like you this weekend at the NENPA conference.



Christopher King said...


At least this five year old knows the difference between a principle and a principal.


And FWIW I don't care about labels, I am liberal on some things and conservative on others. You can call yourself whatever you want to but you're still a tool.

Just calling a spade a spade.


Christopher King said...


Here's something else I take on that I allegedly can't handle:

Mortgage Fraud, the same sort of thing that Kelly Ayotte ignored when someone forged my name to a mortgage when I was a licensed Title Insurance Producer. Watch the movie jackass the signatures don't lie.

I guess you're right I can't handle it myself, I need a responsible AG or State Senator to step in and help, hahahahaaa.....

Got any easy answers on that, you dumb ass?

Christopher King said...

Okay jackass I'll give you a chance. Go through this and point out exactly what isn't professional or accurate:

This is a crucial issue that requires edification on two fronts, as noted in the accompanying Reply Memorandum.

I. A Jury May Find Unlawful Racial Animus by the GOP Directive to Unlawfully Drive Plaintiff out of the Entire Crown Plaza Building.

In short, the Nashua PD Defendants had absolutely no lawful right to drive Plaintiff out of the entire Crowne Plaza Hotel. The video footage as admitted by this Honorable Court proves that they did it at the behest of the Political GOP Defendants who were admittedly running the event (“The people here are asking you to leave are you going to take your stuff or do you want me to take it”) and if they didn’t do it at GOP behest then they are liable in ultra vires or otherwise individually, that of course is a matter for discovery.

As such, it is clear that Defendant Nashua PD and the others by association have donned their collective and individual waders and set out on a fishing expedition in an attempt to get this highly damaging footage excised from the record, because it goes to show the extent to which the Defendants unlawfully directed the Police to drive Plaintiff from the entire building.

Remember that Defendants tried to write Officer Hargreaves’ malicious conduct and admission of collusion with GOP Defendants “The people here are asking you to leave,” out of the record by their grammatically and factually improper Rule 11 letter to Plaintiff. See Plaintiff’s pending Rule 11 Motion in that regard. As such, Justice demands that they fail.

Christopher King said...

Then go through this, and since you're so flippin' smart go ahead and identify yourself and be proud, you've got your chance to show the World how bright you really are!

II. The Separate and Distinct Cause of Action for Unlawful Interference with Plaintiff’s Right to Enjoy a Place of Public Accommodation.

Plaintiff may well move the Court to Amend the Complaint because driving Plaintiff out of the entire Hotel is not only indicative of the possible racial animus, it is also its own separate and distinct Civil Rights violation.

In Black History Month in the last State to acknowledge and to respect Martin Luther King Day as a Holiday it is important to remember that in Plaintiff’s lifetime Negroes were not permitted to gather and to eat at their chosen venues, yet this is precisely what the Defendants, individually and collectively did to Plaintiff.

In light of the above, if the Court deems it appropriate to order Plaintiff to file a Second Amended Complaint to countenance the newfound footage that would be the appropriate remedy, not to disregard the facts. Courts grant liberal leave to Amend a Complaint to include facts and they develop for this very reason.

Christopher King said...

Besides, you appear to be a Seton Hall law student, I've won First Amendment Criminal Trials WTF have you done, you can't even pee straight yet.

Seton Hall Law Sch ( [Label IP Address]

10th February 2011 18:39:31 Exit Link https://www.blogger.com/comment.g?blogID=13439084&postID=5150586912135146032

10th February 2011 18:43:52 Exit Link https://www.blogger.com/comment.g?blogID=13439084&postID=5150586912135146032


Christopher King said...

.....And last but not least, Kelly Ayotte attended Seton Hall, so I'm more apt to believe you're a piece of shit COINTELRO jackass.

In the words (and license plate of) Bruce Mckay....


But thanks for proving me some material for a quick post tonight.

-The KingCaster.

SHE said...

If it's a frivolous suit with no merit (which is a little like a brainless comment with no intelligence), then why did all three branches of the federal government suddenly begin to follow this blog just as this lawsuit began? Why do three branches continue to follow this blog?

Christopher King said...

Well I can't say for sure why some of them are reading but I am fairly certain why SCOTUS Justice Elena Kagan's folks are watching, ahem.

Kelly publicly said Her Honor wasn't fit to sit on the Bench.

And I publicly say Kelly is not fit to be a U.S. Senator.

-The KingCaster.