May it please the Court:
Plaintiff responded by noting that racism was always integral to the case and noted that in Open Court he directly told Magistrate McCafferty two things:
 There was simply no way that a reasonable person, objectively, in Plaintiff’s shoes, could feel safe in remaining on the premises so he left under the continued threat of arrest. While Defendants may argue that the Civil Rights violation of driving Plaintiff all the way out was de minimis, Plaintiff asserts that there is no such thing as a de minimis violation of his Civil Rights.
Note that Defendants are deriving substantial benefit of discovery from Plaintiff while Plaintiff has derived none from them, and that is crucial because it will show them in many lies, including any notion that the other media at the Joe Arpaio rally was “invited.” Video provided by KingCast has shown that all one need do as a journalist was sign in, at least until Ryan Williams assumed that Plaintiff would write a negative story as he made an assumption using race as proxy for ideology. Plaintiff has in fact praised Kelly Ayotte on several occasions. That what journalists do in a Free Country, praise and criticize. And get arrested, apparently.