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    King v. McKenna Motion For Jury View in Free Press First Amendment Lawsuit

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    Christopher King
    http://mortgagemovies.blogspot.com/2015/07/kingcast-and-mortgage-movies-to-file.html PLAINTIFF’S NOTICE OF JURY FEE AND MOTION FOR JURY VIEW Plaintiff at once notices the Court and Defendants of payment of the requisite $150.00 Jury Fee and further moves the Court to issue a Jury View of the subject area. A Jury view is essential in a case such as this because these cases are based on what is reasonable under the circumstances. The Court has incorrectly referenced cubicles and interior offices in its 29 June 2015 Opinion at p. 15 As an initial matter, Plaintiff makes no argument for the “existence of a tradition of public access to” the interior offices of the Recorder of Deeds.41 Furthermore, the Plaintiff does not contend that the function of the Recorder of Deeds is positively promoted by granting access to its interior offices. Thus, the Court finds that filming the employees of the Recorder of Deeds in their cubicles or at the water cooler fails to create a database of property ownership, among other raisons d’etre. Notwithstanding the fact that the Third Circuit Plaintiff in Pomykacz v. Borough of W. Wildwood, 438 F. Supp. 2d 504 (2006) had no such tradition, nor did Plaintiff in Tisdale v. Gravitt, 51 F. Supp. 3d 1378 (N.D. Georgia 2014), this is at once an incorrect analysis of law and incorrect inference about what areas Plaintiff came to video. Nothing in the pleadings suggests that he came to video interior offices or cubicles. As such, the analysis comes down to what is reasonable and Plaintiff of course cannot show the areas he tried to film because he was THREATENED WITH ARREST and therefore chilled and in effect seized pursuant to the Fourth Amendment. Therefore a Jury is entitled to see what Plaintiff saw and was attempting to film. From Delaware Trial Handbook § 20:11. VIEW OF A SCENE: In certain circumstances, a party may wish to have the jury or other trier of fact view the scene where the event or transaction at issue occurred. Whether or not to allow such a jury view is within the discretion of the trial court.133 The court may deny a request for a jury view if, in the court’s opinion, such a view would serve no useful purpose, for example, where photographs adequately inform the jury as to the scene. As such, there has to be at a minimum photographs and diagrams but the best evidence is of course an actual visit. Thompson v. State, 399 A.2d 194 (Del. 1979). See also State v. Bilinski, Cr. A. No. 1N83-06-l725, slip op. at 6-9, Poppiti, J. (Del. Super. May 25, 1989), aff’d mem., 574 A.2d 262 (Del. 1990) (permitting view where trial court concluded that photographs and diagrams were inadequate). In at least one non-jury case, the trial court accepted into evidence a videotape of the subject premises, thereby bringing the view to the court.136 Fairwinds Shopping Center v. Five Star Video, Inc., C.A. No. 9lC-06-161, Del Pesco, J. (Del. Super. Apr. 2, 1993). If there is available video of the subject scene it should be properly introduced into evidence as it aids the Trier of Fact. See also State v. Restrepo-Duque, 2014 Del. Super. LEXIS 240 (2104) Robert B. Young presiding. While this case is not final and subject to review, the point remains that if there is anything that could help a Jury fairly decide a case, it must be properly introduced or seen by a Jury. As Defendants have of course prevented Plaintiff from gathering any visual evidence, still photographs, a video or a jury view must be made and/or conducted because testimony without visuals is worthless in this context. At this point there is nothing in the record excepting the Court’s incorrect assertion.

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    King v. McKenna Motion For Jury View in Free Press First Amendment Lawsuit

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    Christopher King
    937 views20 pages
    http://mortgagemovies.blogspot.com/2015/07/kingcast-and-mortgage-movies-to-file.html PLAINTIFF’S NOTICE OF JURY FEE AND MOTION FOR JURY VIEW Plaintiff at once notices the Court and Defendants of payment of the requisite $150.00 Jury Fee and further moves the Court to issue a Jury View of the subject area. A Jury view is essential in a case such as this because these cases are based on what is reasonable under the circumstances. The Court has incorrectly referenced cubicles and interior offices in its 29 June 2015 Opinion at p. 15 As an initial matter, Plaintiff makes no argument for the “existence of a tradition of public access to” the interior offices of the Recorder of Deeds.41 Furthermore, the Plaintiff does not contend that the function of the Recorder of Deeds is positively promoted by granting access to its interior offices. Thus, the Court finds that filming the employees of the Recorder of Deeds in their cubicles or at the water cooler fails to create a database of property ownership, among other raisons d’etre. Notwithstanding the fact that the Third Circuit Plaintiff in Pomykacz v. Borough of W. Wildwood, 438 F. Supp. 2d 504 (2006) had no such tradition, nor did Plaintiff in Tisdale v. Gravitt, 51 F. Supp. 3d 1378 (N.D. Georgia 2014), this is at once an incorrect analysis of law and incorrect inference about what areas Plaintiff came to video. Nothing in the pleadings suggests that he came to video interior offices or cubicles. As such, the analysis comes down to what is reasonable and Plaintiff of course cannot show the areas he tried to film because he was THREATENED WITH ARREST and therefore chilled and in effect seized pursuant to the Fourth Amendment. Therefore a Jury is entitled to see what Plaintiff saw and was attempting to film. From Delaware Trial Handbook § 20:11. VIEW OF A SCENE: In certain circumstances, a party may wish to have the jury or other trier of fact view the scene where the event or transaction at issue occurred. Whether or not to allow such a jury view is within the discretion of the trial court.133 The court may deny a request for a jury view if, in the court’s opinion, such a view would serve no useful purpose, for example, where photographs adequately inform the jury as to the scene. As such, there has to be at a minimum photographs and diagrams but the best evidence is of course an actual visit. Thompson v. State, 399 A.2d 194 (Del. 1979). See also State v. Bilinski, Cr. A. No. 1N83-06-l725, slip op. at 6-9, Poppiti, J. (Del. Super. May 25, 1989), aff’d mem., 574 A.2d 262 (Del. 1990) (permitting view where trial court concluded that photographs and diagrams were inadequate). In at least one non-jury case, the trial court accepted into evidence a videotape of the subject premises, thereby bringing the view to the court.136 Fairwinds Shopping Center v. Five Star Video, Inc., C.A. No. 9lC-06-161, Del Pesco, J. (Del. Super. Apr. 2, 1993). If there is available video of the subject scene it should be properly introduced into evidence as it aids the Trier of Fact. See also State v. Restrepo-Duque, 2014 Del. Super. LEXIS 240 (2104) Robert B. Young presiding. While this case is not final and subject to review, the point remains that if there is anything that could help a Jury fairly decide a case, it must be properly introduced or seen by a Jury. As Defendants have of course prevented Plaintiff from gathering any visual evidence, still photographs, a video or a jury view must be made and/or conducted because testimony without visuals is worthless in this context. At this point there is nothing in the record excepting the Court’s incorrect assertion.

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    http://mortgagemovies.blogspot.com/2015/07/kingcast-and-mortgage-movies-to-file.html PLAINTIFF’S NOTICE OF JURY FEE AND MOTION FOR JURY VIEW Plaintiff at once notices the Court and Defendants of payment of the requisite $150.00 Jury Fee and further moves the Court to issue a Jury View of the subject area. A Jury view is essential in a case such as this because these cases are based on what is reasonable under the circumstances. The Court has incorrectly referenced cubicles and interior offices in its 29 June 2015 Opinion at p. 15 As an initial matter, Plaintiff makes no argument for the “existence of a tradition of public access to” the interior offices of the Recorder of Deeds.41 Furthermore, the Plaintiff does not contend that the function of the Recorder of Deeds is positively promoted by granting access to its interior offices. Thus, the Court finds that filming the employees of the Recorder of Deeds in their cubicles or at the water cooler fails to create a database of property ownership, among other raisons d’etre. Notwithstanding the fact that the Third Circuit Plaintiff in Pomykacz v. Borough of W. Wildwood, 438 F. Supp. 2d 504 (2006) had no such tradition, nor did Plaintiff in Tisdale v. Gravitt, 51 F. Supp. 3d 1378 (N.D. Georgia 2014), this is at once an incorrect analysis of law and incorrect inference about what areas Plaintiff came to video. Nothing in the pleadings suggests that he came to video interior offices or cubicles. As such, the analysis comes down to what is reasonable and Plaintiff of course cannot show the areas he tried to film because he was THREATENED WITH ARREST and therefore chilled and in effect seized pursuant to the Fourth Amendment. Therefore a Jury is entitled to see what Plaintiff saw and was attempting to film. From Delaware Trial Handbook § 20:11. VIEW OF A SCENE: In certain circumstances, a party may wish to have the jury or other trier of fact view the scene where the event or transaction at issue occurred. Whether or not to allow such a jury view is within the discretion of the trial court.133 The court may deny a request for a jury view if, in the court’s opinion, such a view would serve no useful purpose, for example, where photographs adequately inform the jury as to the scene. As such, there has to be at a minimum photographs and diagrams but the best evidence is of course an actual visit. Thompson v. State, 399 A.2d 194 (Del. 1979). See also State v. Bilinski, Cr. A. No. 1N83-06-l725, slip op. at 6-9, Poppiti, J. (Del. Super. May 25, 1989), aff’d mem., 574 A.2d 262 (Del. 1990) (permitting view where trial court concluded that photographs and diagrams were inadequate). In at least one non-jury case, the trial court accepted into evidence a videotape of the subject premises, thereby bringing the view to the court.136 Fairwinds Shopping Center v. Five Star Video, Inc., C.A. No. 9lC-06-161, Del Pesco, J. (Del. Super. Apr. 2, 1993). If there is available video of the subject scene it should be properly introduced into evidence as it aids the Trier of Fact. See also State v. Restrepo-Duque, 2014 Del. Super. LEXIS 240 (2104) Robert B. Young presiding. While this case is not final and subject to review, the point remains that if there is anything that could help a Jury fairly decide a case, it must be properly introduced or seen by a Jury. As Defendants have of course prevented Plaintiff from gathering any visual evidence, still photographs, a video or a jury view must be made and/or conducted because testimony without visuals is worthless in this context. At this point there is nothing in the record excepting the Court’s incorrect assertion.

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    King v. McKenna Motion For Jury View in Free Press First Amendment Lawsuit

    Uploaded by

    Christopher King
    http://mortgagemovies.blogspot.com/2015/07/kingcast-and-mortgage-movies-to-file.html PLAINTIFF’S NOTICE OF JURY FEE AND MOTION FOR JURY VIEW Plaintiff at once notices the Court and Defendants of payment of the requisite $150.00 Jury Fee and further moves the Court to issue a Jury View of the subject area. A Jury view is essential in a case such as this because these cases are based on what is reasonable under the circumstances. The Court has incorrectly referenced cubicles and interior offices in its 29 June 2015 Opinion at p. 15 As an initial matter, Plaintiff makes no argument for the “existence of a tradition of public access to” the interior offices of the Recorder of Deeds.41 Furthermore, the Plaintiff does not contend that the function of the Recorder of Deeds is positively promoted by granting access to its interior offices. Thus, the Court finds that filming the employees of the Recorder of Deeds in their cubicles or at the water cooler fails to create a database of property ownership, among other raisons d’etre. Notwithstanding the fact that the Third Circuit Plaintiff in Pomykacz v. Borough of W. Wildwood, 438 F. Supp. 2d 504 (2006) had no such tradition, nor did Plaintiff in Tisdale v. Gravitt, 51 F. Supp. 3d 1378 (N.D. Georgia 2014), this is at once an incorrect analysis of law and incorrect inference about what areas Plaintiff came to video. Nothing in the pleadings suggests that he came to video interior offices or cubicles. As such, the analysis comes down to what is reasonable and Plaintiff of course cannot show the areas he tried to film because he was THREATENED WITH ARREST and therefore chilled and in effect seized pursuant to the Fourth Amendment. Therefore a Jury is entitled to see what Plaintiff saw and was attempting to film. From Delaware Trial Handbook § 20:11. VIEW OF A SCENE: In certain circumstances, a party may wish to have the jury or other trier of fact view the scene where the event or transaction at issue occurred. Whether or not to allow such a jury view is within the discretion of the trial court.133 The court may deny a request for a jury view if, in the court’s opinion, such a view would serve no useful purpose, for example, where photographs adequately inform the jury as to the scene. As such, there has to be at a minimum photographs and diagrams but the best evidence is of course an actual visit. Thompson v. State, 399 A.2d 194 (Del. 1979). See also State v. Bilinski, Cr. A. No. 1N83-06-l725, slip op. at 6-9, Poppiti, J. (Del. Super. May 25, 1989), aff’d mem., 574 A.2d 262 (Del. 1990) (permitting view where trial court concluded that photographs and diagrams were inadequate). In at least one non-jury case, the trial court accepted into evidence a videotape of the subject premises, thereby bringing the view to the court.136 Fairwinds Shopping Center v. Five Star Video, Inc., C.A. No. 9lC-06-161, Del Pesco, J. (Del. Super. Apr. 2, 1993). If there is available video of the subject scene it should be properly introduced into evidence as it aids the Trier of Fact. See also State v. Restrepo-Duque, 2014 Del. Super. LEXIS 240 (2104) Robert B. Young presiding. While this case is not final and subject to review, the point remains that if there is anything that could help a Jury fairly decide a case, it must be properly introduced or seen by a Jury. As Defendants have of course prevented Plaintiff from gathering any visual evidence, still photographs, a video or a jury view must be made and/or conducted because testimony without visuals is worthless in this context. At this point there is nothing in the record excepting the Court’s incorrect assertion.

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    of 20

    IN THE SUPERIOR COURT OF THE STATE OF DELAWARE

    IN AND FOR KENT COUNTY


    CHRISTOPHER KING, d/b/a KingCast/Mortgage Movies,

    ) CASE NO. K15C-03-028


    Plaintiff,
    )
    v.

    ) JUDGE YOUNG

    BETTY LOU MCKENNA, HOLLY MALONE


    and JOHN PARADEE, ESQ.

    Defendants.

    )
    PLAINTIFFS WAIVER OF JURY TRIAL

    Plaintiff hereby removes his Jury Demand as he simply does not feel
    safe in Delaware, legally in this Courtroom and definitely not free from
    lynchings as noted in an email chain repeated in its entirety below:
    On Aug 04, 2015, at 10:57 AM, Christopher King <[email protected]>
    wrote:
    I get it now.
    If the AG's Office won't investigate the Delaware lynchings then they sure as
    hell won't investigate a First Amendment Free Press Complaint.
    http://waronthehorizon.com/site/?p=3836
    How shameful. I recall the video I did a couple of weeks ago showing how Joe
    Biden blew off the information I provided about multiple felon Gregory Floyd,
    who continued on a rampage and criminally threatened his neighbor.
    https://www.youtube.com/watch?v=UPWTqNrzZ5U
    So my next video will go to an altogether different place, and don't expect me
    to appear at any more kangaroo Court hearings and I may withdraw my Jury
    Demand because as a former Civil Rights litigator I know my history and I
    know I love living more than the alternative.

    Because none of these motherfuckers would investigate my death, I'll tell you
    that much. Nope, time to submit it on paper, get on up to the Supreme Court
    and then on to SCOTUS once Delaware finishes its Dirty Work. And I do mean
    Dirty.
    This nigger stays at home:

    Ciao.

    Begin forwarded message:


    From: Christopher King <[email protected]>
    Date: August 04, 2015 12:02:29 PM
    To: [email protected],[email protected],msilow@foxrothsc
    hild.com,[email protected],[email protected],lbandlow@f
    oxrothschild.com,[email protected],[email protected]
    Cc: [email protected],[email protected],delawaregrapevine@comcas
    t.net,[email protected],[email protected],Amy.Quinlan@state
    .de.us,[email protected],[email protected],Attorney.Gener
    [email protected],[email protected],[email protected],lspolto
    [email protected],[email protected],gweber@constitutional
    litigation.com,[email protected],[email protected].
    us,[email protected],[email protected],[email protected],r
    [email protected],[email protected],[email protected],jahii
    [email protected],[email protected],[email protected],nancyvwilling
    @yahoo.com,[email protected],[email protected],Kia.evans@
    co.kent.de.us
    Subject: Re: Delaware The First Amendment Denials are Nothing
    Compared to the Lynchings.
    Yep, now I see why Delaware hates cameras in its public meetings.
    https://www.youtube.com/watch?v=ucmIj_hzYbI&feature=youtu.be
    https://www.youtube.com/watch?v=mTpm8fEcyI0&feature=youtu.be
    https://www.youtube.com/watch?v=oDYc0Y6T22Q&feature=youtu.be
    I've already got these videos downloaded.
    May the Defendants enjoy whatever pyrrhic victories they may have in my
    case, because I am opening up a whole 'nother can of whupass on the entire
    state of Delaware, and any and all of the house negroes who sit there and
    take it. If you are offended by this then you are part of the problem so fuck
    you too.
    And I mean that with all of my heart.
    A copy of this email chain will be submitted to Court with my withdrawal of
    Jury Demand.

    Vulgar?
    Yep. Apparently it's the Delaware Way
    CHRISTOPHER KING, J.D.
    [email protected]
    [email protected]
    http://affordablevideodepo.com
    http://mortgagemovies.blogspot.com
    617.543.8085m
    206.299.9333f
    The following information remains valid and true and is incorporated
    herein merely so the the Record remains complete in showing that Plaintiff
    clearly has enough law and facts on his side to obtain a Jury View were he
    ever to return to the State of Delaware, but owing to his concerns of public
    safety in a State that has actually covered up several recent lynchings of
    black men, he will definitely not be setting foot into that crooked, racist --and criminally dangerous State. Please return the $150.00 to the __006
    address in the file.
    **************
    Plaintiff at once notices the Court and Defendants of payment of the
    requisite $150.00 Jury Fee and further moves the Court to issue a Jury View of
    the subject area. A Jury view is essential in a case such as this because these
    cases are based on what is reasonable under the circumstances.
    The Court has incorrectly referenced cubicles and interior offices in its
    29 June 2015 Opinion at p. 15
    As an initial matter, Plaintiff makes no argument for the
    existence of a tradition of public access to the interior offices of the
    Recorder of
    Deeds.41 Furthermore, the Plaintiff does not contend that the function
    of the Recorder of Deeds is positively promoted by granting access to
    its interior offices. Thus, the Court finds that filming the employees of
    the Recorder of Deeds in their cubicles or at the water cooler fails to
    create a database of property ownership, among other raisons detre.
    Notwithstanding the fact that the Third Circuit Plaintiff in Pomykacz v.
    Borough of W. Wildwood, 438 F. Supp. 2d 504 (2006) had no such tradition,
    nor did Plaintiff in Tisdale v. Gravitt, 51 F. Supp. 3d 1378 (N.D. Georgia 2014),
    this is at once an incorrect analysis of law and incorrect inference about what

    areas Plaintiff came to video. Nothing in the pleadings suggests that he came
    to video interior offices or cubicles.
    As such, the analysis comes down to what is reasonable and Plaintiff of
    course cannot show the areas he tried to film because he was THREATENED
    WITH ARREST and therefore chilled and in effect seized pursuant to the
    Fourth Amendment.1 Therefore a Jury is entitled to see what Plaintiff saw and
    was attempting to film. From Delaware Trial Handbook 20:11. VIEW OF
    A SCENE:
    In certain circumstances, a party may wish to have the jury or other
    trier of fact view the scene where the event or transaction at issue occurred.
    Whether or not to allow such a jury view is within the discretion of the trial
    court.133 The court may deny a request for a jury view if, in the courts
    opinion, such a view would serve no useful purpose, for example, where
    photographs adequately inform the jury as to the scene.
    As such, there has to be at a minimum photographs and diagrams but the
    best evidence is of course an actual visit. Thompson v. State, 399 A.2d 194
    (Del. 1979). See also State v. Bilinski, Cr. A. No. 1N83-06-l725, slip op. at 6-9,
    Poppiti, J. (Del. Super. May 25, 1989), affd mem., 574 A.2d 262 (Del. 1990)
    (permitting view where trial court concluded that photographs and diagrams
    were inadequate).
    In at least one non-jury case, the trial court accepted into evidence a
    videotape of the subject premises, thereby bringing the view to the court..
    Fairwinds Shopping Center v. Five Star Video, Inc., C.A. No. 9lC-06-161, Del
    Pesco, J. (Del. Super. Apr. 2, 1993).
    If there is available video of the subject scene it should be properly
    introduced into evidence as it aids the Trier of Fact. See also State v.
    Restrepo-Duque, 2014 Del. Super. LEXIS 240 (2104) Robert B. Young
    presiding. While this case is not final and subject to review, the point remains
    that if there is anything that could help a Jury fairly decide a case, it must be
    properly introduced or seen by a Jury. As Defendants have of course
    prevented Plaintiff from gathering any visual evidence, still photographs, a

    1 And even if he were not seized there still remains the issue of prospective relief for
    the next time Plaintiff appears at the Recorder of Deeds so he needs to know if it is
    permissible for Defendants to arrest him.

    video or a jury view must be made and/or conducted because testimony


    without visuals is worthless in this context.
    At this point there is nothing in the record excepting the Courts
    incorrect assertion.
    Lastly, note that while Delaware is apparently teeming with unlawful
    First Amendment conduct, not all of it requires a Jury View. For example while
    some of Newcastle County allows cameras as noted in Plaintiffs First
    Amended Complaint, the Board of Adjustment apparently needs a mental
    adjustment:

    Delaware Coalition for Open Government


    PO Box 493
    Montchanin, DE 19710

    Mr. David H. Burt, Chair


    New Castle County Board of Adjustment
    87 Read's Way
    New Castle, DE 19720

    August 2, 2015

    Dear Mr. Burt:


    The Delaware Coalition for Open Government is a non-profit organization committed to
    promoting and defending the people's right to transparency and accountability in government.
    We serve as a resource through education and advocacy, and we work to strengthen Delaware's
    Freedom of Information Act, its application and its enforcement.
    I am writing to express our concern over the New Castle County Board of Adjustment failure to
    post over 20 meeting minutes on your web-site as well as your prohibiting bona-fide journalists
    from video/audio recording the June 11th meeting, as well as future meetings of the Board.
    As you are aware, Delawares Freedom of Information Act was enacted, in part, to provide the
    public the opportunity to observe the performance of public officials and to monitor their
    decisions in formulating and executing public policy.
    This opportunity for the public to observe and monitor your performance as public officials is
    thwarted by not posting your meeting minutes in a timely manner and prohibiting bona-fide
    journalists from video recording your meetings.

    Delaware Code Title 29, 10004 Open Meetings (f) states that, Each public body shall maintain
    minutes of all meetings, including executive sessions, conducted pursuant to this section, and
    shall make such minutes available for public inspection and copying as a public record.
    Our perusal of the Board of Adjustments web-site found that the last Board of adjustment
    meeting minutes were posted on June 26, 2014. Since then, over 20 meeting minutes have yet to
    be posted.
    In addition to the timely posting of meeting minutes, there are no prohibitions under Delawares
    Freedom of Information Act, 29 Del. C. ch. 100 that exclude bona-fide members of the news
    media from video recording the proceedings of public bodies.
    I have attached a legal memo dated April 1, 2011 from Lawrence W. Lewis, then Delaware
    Attorney General Solicitor that speaks to the issue of the right of the public to record open
    meetings of public bodies.
    Solicitor Lewis ends his memo by stating; the Department of Justice should advise its client
    public bodies that to prohibit any recording of public meetings is highly risky. The law is
    evolving in a more permissive direction.
    We agree with the solicitor and urge the Board to make reasonable accommodations for bona-fide
    journalists to video-record future meetings of the Board of Adjustment as well as timely posting
    of meeting minutes.
    We thank you for your time in this matter.
    John D. Flaherty
    John D. Flaherty, President
    Delaware Coalition for Open Government
    bcc: David Grimaldi, DelCOG
    ***********
    As such, a camera view is not ipso facto necessary in that case even
    though the wrong is equally heinous.
    In any event, Plaintiff who is not a self-proclaimed web video
    journalist (29 June 2015 Opinion p.3) but rather a former AAG, Daily
    Reporter/Editor, Escrow attorney and successful First Amendment litigator as
    attorney and private citizen has some experience on this matter.
    To wit, in 2013 he shot the Jury view in State v. Cody Eller, a road rage
    situation in which a conviction was ultimately overturned because of a dirty
    cop. As a former law enforcement attorney I blanche at this result but it was
    the only fair thing to do.

    https://www.youtube.com/watch?v=Tou_-05kW7E
    Motorcycle Road Rage? Cody Eller Trial Day One.

    Note Judge Jacalyn Coburn, green coat front and center. She has no problems
    with KingCast cameras in the Courtroom, on the road or anywhere else in
    public. So apparently Delaware now firmly behind East Coast states like
    Georgia, New Jersey and New Hampshire, likes its Justice cloaked with an
    aura of invisibility. That is because it is a rogue State. See also :
    http://mortgagemovies.blogspot.com/2015/07/kingcast-and-mortgagemovies-observe.html
    Tuesday, July 21, 2015
    KingCast and Mortgage Movies Observe an East Coast First Amendment
    Battle Over Right to Film Public Officials: Pomykacz v. Borough of W.
    Wildwood, 438 F. Supp. 2d 504 (2006), Tisdale v. Gravitt, 51 F. Supp. 3d 1378
    (2014), Gravitt v. Olens, 2015 Ga. App. LEXIS 490 (2015), Tarus v. Borough of
    Pine Hill, 189 N.J. 497 (2007), King v. McKenna, 2015 Del. Super. LEXIS 323
    (2015).
    ***************

    10

    To wit, in 1998 this footage of Plaintiff in Hamilton, Ohio references a


    Jury View in which his client Michael Isreal was exonerated of Criminal
    charges and went on to settle his Civil claims for $57,500.00 against
    Hamilton, Ohio officers Hensley and Rodes. Come now to discover years later
    that Plaintiff was correct again, ab initio, as Defendants are aware, Hensley
    (as a married man) continued to terrorize the community and disciplinary
    action finally was taken after several women reported stalking issues.
    http://enquirer.com/editions/2003/01/28/loc_hamcop28.html
    Tuesday, January 28, 2003
    Police uncover officer's dark side
    Investigation finds threats, complaints
    By Janice Morse
    The Cincinnati Enquirer
    HAMILTON - Some of William R. Hensley's fellow officers had raised concerns
    about him years ago, after they saw him "bully" suspects as early as 1996, a
    2002 internal probe reveals.
    The 100-page document, released Monday in response to
    the Enquirer's public records request, also shows that the now-suspended
    detective, though married, has twice been ordered to stay away from women
    identified as his "girlfriends" - and he allegedly threatened "to get physical"
    with colleagues who were being questioned about him last year.
    The document about the internal police probe released Monday depicted a
    different picture of Mr. Hensley's record than the mostly glowing city
    personnel files released last week.
    One officer said he saw then-officer Hensley grab a handcuffed suspect in
    1996 and slam him into a wall. "I think Bill hit him with his flashlight. The guy
    fell to the ground," the officer said.
    During another 1996 incident, an officer said, "I was handcuffing (a suspect),
    when Billy hit him in the face. After that, I took Billy off to the side and told
    him not to be hitting people in the face. I told him I did not want to be around
    when he's hitting people like that. Billy's famous comment to me was, `I like
    to see my work.'" (On information and belief this was Plaintiffs client Michael
    Isreal, who went on to prove himself as victim of violent crime as noted by
    the Ohio Court of Claims with Plaintiff as Counsel, Case no. V96-61481).

    11

    In June 1997, another officer said he saw Officer Hensley punch a handcuffed
    burglary suspect at least twice.
    In the summer of 2000, another officer reported seeing Detective Hensley
    "chuck" a boy in the face with his forearm.
    See:
    KingCast vintage trial footage shows how to protect First Amendment
    Rights.
    Published to YouTube in on 17 January 2010.
    https://www.youtube.com/watch?v=pnOYQRafnWY

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    Lastly, Plaintiff recalls that this is hardly the first time he has had to
    sue a government to do the right thing. In 2007 he was awarded a First
    Amendment Commendation by Nashua NH Mayor Bernard Streeter, the
    longest-sitting member of the Governors Council, who agreed with the
    Aldermen that Kelly Ayottes investigation of the double-homicide in
    Franconia, NH was bogus. He also agreed with Plaintiff as did the City
    Attorney that the School Board had enacted an unlawful First Amendment
    policy.

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    This is good background for the Court to understand, as Defendants


    have on prior occasion cited to a Free Press lawsuit that Plaintiff lost to
    Ayotte, albeit when she was NOT and ELECTED OFFICAL, and when she was
    held to be participating in a PRIVATE event. None of which is present in this
    case, as noted herein: https://www.youtube.com/watch?v=Emq8pn6O34w
    Former Trial Atty Rips Judge Robert B Young in Delaware Free Press
    First Amendment case.

    17

    In Sum, Thomas Paine is still rolling in his grave.

    18

    Respectfully Submitted,
    _____________________________________________
    CHRISTOPHER KING, J.D.
    [email protected]
    [email protected]
    http://affordablevideodepo.com
    http://mortgagemovies.blogspot.com
    617.543.8085m
    206.299.9333f

    CERTIFICATE OF SERVICE
    I, the undersigned, swear that a true and accurate Courtesy copy of this
    document was sent via email and via Tracked U.S. Mail to:
    Joseph Scott Shannon, Esq.
    Art C. Arnilla, Esq.
    1220 North Market Street
    5th Floor
    P.O. Box 8888
    Wilmington, DE 19899-8888
    and to:
    John A. Elzufon, Esq.
    Peter McGivney, Esq.
    300 Delaware Avenue,
    Suite 1700
    P.O. Box 1630
    Wilmington, DE 19899
    This 4th day of August, 2015
    ________________________________
    CHRISTOPHER KING, J.D.

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