06 July 2011
KingCast final Third Amended Complaint in KingCast v. Ayotte, NH GOP, Nashua PD 2010-CV-501 adds Defamation against Senator Kelly Ayotte.
The first draft is in the Fourth of July post.
As the Good Senator is not too strong on Civil Procedure (having violated NH rules of same in her failed rabid prosecution of me as NAACP Legal Chair) I'm here to help:
Move to Dismiss on failure to add a necessary party, your idiot, lying Chief of Staff John Easton. Looks like you'll be needing those public funds after all. Roll Call gave him a pass, but holy cow, I will give no quarter to this sort of nonsense.
m) Any one or two of the aforementioned issues could constitute an honest mistake, but when viewed over the course of time they represent a design, pattern and practice of illogical activity that a Jury may find predicated on unlawful racial animus. The aforementioned issues go well beyond general incompetence and dereliction of duty and stand as substantial proof that Kelly Ayotte is operating out of an illegal bias against a strong black investigative journalist and Civil Rights activist.
n) To add insult to injury Defendant Ayotte, by and through her Chief of Staff as U.S. Senator, recently sought and current seeks public money to Defend this lawsuit by falsely claiming that Plaintiff has filed “frivolous” actions against her. As Plaintiff explained to the government mouthpiece journalists at Roll Call that is a material misuse of a legal term of art that cannot be sustained. In point of fact, if anyone has engaged in frivolous litigation it is Defendant Ayotte and Martin J. Dunn as referenced, supra.