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) JUDGE YOUNG
Defendants.
)
PLAINTIFFS AMENDED MEMORANDUM IN OPPOSITION TO SUMMARY
JUDGMENT1
I.Introduction, View of the Premises and Where the Courts Entire First
Amendment Analysis is Completely Off-Point, Public Meeting Laws and
Cases are Inapplicable and the Law of the Case Doctrine Does Not
Apply.
The Court cannot ignore relevant case law and then point and say well
thats the law of the case and thats that. Well it can do that, but Plaintiff will
of course bring his claim again, make the record, make his valid Rule 59
argument and prepare for Appellate review.
Note the hypocrisy evident in Defendants arguments: They used the
public body/public meeting case Whiteland Woods, L.P., v. Township of West
Whiteland, 193 F.3d 177 [3d Cir 1999] to get Plaintiffs Constitutional claims
bumped, yet they now turn around and consistently argue in Plaintiffs First
Amended Complaint that public body law and access to public meetings is
inapplicable. (Defendants Joint Motion para 14-18, 21 et seq.)
Well that is precisely what Plaintiff said, ab initio, while the Court was
busy giving him the bums rush earlier: It is the Pomykacz, Cirelli, Iacobucci
and Glik cases and their progeny, including Third Circuits Montgomery v.
Killingsworth, 2015 U.S. Dist. LEXIS 7152 (January 22, 2015) that are most
germane because they all involve journalists filming public officials in and out
of their offices. Theres the a-ha moment of this entire case. That having
been said, Plaintiff maintains his public body/public meeting arguments in the
alternative and points to the 11th Circuit Tisdale v. Gravitt, 51 F. Supp. 3d
1 Per Plaintiffs Rule 59 Motion this is a Summary Judgment case , albeit with
truncated discovery.
1378 (N.D. Georgia 2014) case to show that current Courts disagree with the
ancient Whiteland Woods case.
The point is, Defendants and the Court cannot have it both
ways: If public body/public meeting analyses are inapplicable now, then they
were inapplicable in the first place -- and theres yet another compelling
reason for the Supreme Court of the United States to give this case a prompt
Remand in the name of Justice. Gotcha.
As dictated by several cases set forth below some of which were
ignored or misrepresented in the dismissal of Plaintiffs Original Complaint
(i.e. Pomykacz, Iacobucci and Glik) -- there is simply no plausible way that
this case can be decided on the Pleadings. This time around if the Court and
Defendants actually respond to what Plaintiff wrote, we may be able to create
a record that is actually usable by a reviewing Court. Let us commence then,
in light of the below drawing evincing the fact that Plaintiffs attempted
conduct in no ways threatened employee privacy or the function of the office:
That is because the only items downstairs in the public area is a public
foyer, a guard desk, a service desk at which Defendant Malone stood alone,
and a public hallway leading to the back room where several public kiosks are
situated. As such, if the Court is at all interested in Truth and Justice, it would
stop hiding behind facts not alluded to in the Pleadings. To wit: Plaintiff was
not seeking access to Interior offices or to film employees of the Recorder
of Deeds in their cubicles. The Review of Plaintiffs initial and Amended
Complaint will reveal that Plaintiff never sought nor implied such access. (29
June Opinion pp. 14-15, Fn 42).
At this point then it is incumbent of Defendants to use photographs,
video or blueprints to disprove Plaintiff on this point. That is how the burdens
of persuasion and proof work, the last time Plaintiff checked when he was
busy winning First Amendment trials and changing First Amendment Law and
receiving Mayoral Commendations in Senator Kelly Ayottes home state of
New Hampshire, where he routinely photographs Ayottes Office, which is not
a public body or public meeting either. See Appendices A and B and a
picture of Plaintiff in the office of the elected official, just like Betty Lou
McKenna except with a lot more power, prestige, pomp and circumstance! 2
https://www.youtube.com/watch?v=rl4tS0W7RcQ
2 For the Record, Plaintiff reminds Defendants and the Court as to how Defendants
raised Kelly Ayotte in Defense until he published these video captures. Yep. The
Worlds biggest backpedal.
entire notion that Plaintiff somehow needs to prove or find historical access
is wrong because Plaintiff was not present to engage in expressive conduct.
Once again, he was there to ask a few questions of high-ranking officials
regarding Defendant McKennas conduct while sitting as Recorder of Deeds
and to video Candidate La Mar Gunn pulling up arguably fraudulent
documents. This is specifically what he said he was there to do:
15.Plaintiff was compelled to leave without that which he came to get,
i.e. video inside of the building, including a requested interview with
Defendant Malone in lieu of the other Defendants.
16.Plaintiff made it clear to Defendants that he was there to question
Malone or McKenna about false campaign allegations, to obtain BRoll footage of Candidate Gunn using the electronic county fiche
machines to pull up questionable or fraudulent documents, as
admitted by Defendant McKenna in her own Affidavit.
Recall of course that it is a FACT that Mr. Gunn was instrumental in
getting notary Nikole Shelton permanently decommissioned for misconduct in
the Jurisdiction so Plaintiff was not out on a lark.
While the Court at p. 16-17 opines that Plaintiff could get by with a
notepad, the only Court in recent history that arrived at such a conclusion
was Whiteland Woods, and again that was the wrong context according to
Defendants because it is a public meeting argument and therefore
inapplicable.3 Other Courts have specifically held otherwise, including but
not limited to the color quote that appears below. May Plaintiff repeat it lest
the Court and Defendants fail to address it:
3 And further of course the point is that a pen and pad without a Fine Art degree in
drawing does not portray what Plaintiff wants to portray with three-time successful
Candidate Gunn pulling up dirty documents. Unless such portrayal disrupts the office
then by golly Plaintiff has a Constitutional, Statutory and Common Law Right to shoot
it. Period. SCOTUS will agree once we get out of Delaware.
Suppose, for example, that the [local public body] had attempted to
prohibit the use of pen, or pencil and paper, at the sessions held by
them; such a measure would at once strike anyone as being an
improper means of exerting official power, and the surprise and
dissatisfaction generated by such an arbitrary rule would undoubtedly
lead to a prohibition by the courts of such a foolish attempt to exercise
governmental power. [Id. at 154, 348 A.2d 216 (quoting Nevens v.
Chino, 233 Cal. App. 2d 775, 44 Cal. Rptr. 50, 52 (Dist.Ct.App.1965)).]
Thus, over time, quill and parchment gave way to pen and pad; audio
recording devices supplanted stenography.
Who are they fooling? Not Plaintiff not anyone else reading closely, but
for good measure to the extent that the public body/public meeting analysis
is relevant, heres just a little bit more for the Record:
Indeed as Plaintiff has been saying now buttressed by the AGs office 4
-- Courts are increasingly holding that there is no difference between a pen &
paper and a video camera if used in an unobtrusive manner. See Peloquin,
infra. Even though Peloquin was decided on statutory ground the analysis is
still the same: Is the equipment unduly obtrusive or not?
Defendants arguments initially were all predicated on an analysis of
public meeting video. As such, Plaintiffs case is most analogous to
Pomykacz, which was noted by Plaintiff in various Memoranda to date and
hereinbelow. But as the Court and Defendants have hung their hat on the
relatively ancient 1997 case of Whiteland Woods, L.P. v. Township of West
Whiteland, 1997 U.S. Dist. LEXIS 16313 (1997) then Plaintiff will first address
the most recent East Coast case In the recent case of Tisdale v. Gravitt, 51 F.
Supp. 3d 1378 (N.D. Georgia 2014). From Tisdale:
As an initial matter, the Court agrees that Plaintiff has a First
Amendment interest in filming public officials at a public
meeting. Smith v. City of Cumming, 212 F.3d 1332, 1333 (11th Cir.
2000) ("The First Amendment protects the right to gather information
about what public officials do on public property, and specifically, a
right to record matters of public interest.").
Prohibiting Plaintiff from video recording the meetingeven while
permitting her to attend the meeting, take notes, or make audio
recordingsimpacted how she was able to obtain access to and
present information about the City Council and its proceedings.
See Blackston v. State of Ala., 30 F.3d 117, 120 (11th Cir. 1994).
Based on this record, the Court finds that a reasonable jury could
conclude that Mayor Gravitt's restrictive policy announced at the April
17, 2012 meeting was [**12] a total ban on filming in City
Council meetings. If the restriction was a total ban, it burdens more
speech than necessary to further the City's interest in maintaining
4 Plaintiff respects the State AGs offices: He was one. In fact, he was the go-to guy
for Appellate issues in the employment section. That ability is clearly borne out in this
document.
10
affairs."); Roth v. United States, 354 U.S. 476, 484, 77 S. Ct. 1304, 1 L.
Ed. 2d 1498 (1957) ("The protection given speech and press was
fashioned to assure unfettered interchange of ideas for the bringing
about of political and social changes desired by the people.").
So lets review the bold text then, to see the Defendants lies
shall we?
A citizen journalist took pictures, repeatedly, at a police building that
definitely was NOT tied to a public body and that is completely akin to the
Recorder of Deeds office. She repeatedly photographed officers in the police
headquarters, which is undoubtedly more private than the Recorder of Deeds
Office. So to this the Defendants claim there is no precedential relevance?
Lets let the Supreme Court of the United States sort that out along with
Montgomery v. Killingsworth, 2015 U.S. Dist. LEXIS 7152 (January 22, 2015),
and Gaymon v. Borough of Collingdale, 2015 U.S. Dist. LEXIS 93014 (July 17,
2015), after the Delaware juggernaut finishes running Plaintiff into the ground
in this happy little anti-First Amendment State. 5
5As a relatively militant black man I feel good though even though the Court clearly
has it in for me: Unlike La Mar Gunn I havent had an election stolen from me, I
havent been lynched and I never have to set foot in Delaware again, nor will I. The
remainder of this case will be heard on paper. Now thats saying a lot for Delaware,
even though AG Denn swears up and down that those five (5) black men all
committed suicide, some by hanging by a belt. I have notified Douglas Beatty, Ohio
Federal Prosecutor Steven J. Dettlebach and several other groups of people about my
concerns in that regard after Detective Jeff Hill telephoned me because some
unidentified folks were apparently concerned about my emails. See generally First
Amendment Lawsuits Show Markell, AG Biden, AG Denn Coverup of Black Lynchings
https://www.youtube.com/watch?v=QibeMFiaxgM
11
12
***********
In this go around the Defendants could only offer up a lame excuse that the
Recorder of Deeds is not a Public Body (Defendants Motion to Dismiss para
14-18 et seq.).
Thats terrific to Plaintiff, because Plaintiff has already long since
argued on deaf ears that this is not actually a Public Body/Public Meeting
case, so Defendants cant be using Whiteland Woods in the first place! Its
most definitely in the Record folks. What they CAN use, is Plaintiffs cited
cases of Pomykacz, Iacobucci, Cirelli and Glik, even though the Court ignored
Glik in its 29 June 2015 Opinion. We will now finish with Pomykacz and
Iacobucci and move on to Cirelli and Glik momentarily.
Further, Pomykacz effectively trumps Whiteland Woods because it DID
find a Constitutional Right and it did so in a context that is clearly much more
akin to Plaintiffs case: An independent journalist takes camera images of
public officials in their building, is threatened with arrest (and actually
arrested as Plaintiff would have been had he continued shooting based on his
Complaint and two witnesses present as alleged), and wins on Constitutional
grounds. Again, so simple it hurts.
13
14
15
https://www.youtube.com/watch?v=Emq8pn6O34w
6 Plaintiff from time to time cites to the Court and Defendants as one, because thus
far thats pretty much how they have operated, in complete lockstep.
7 Focus on the word electorate. This is a nice word because Defendants try to
distinguish McKenna by stating that she is not a public body but an elected official.
Again, who do they think they are fooling?
16
17
18
Lastly, in Glik v. Cuniffe, (1st Cir Ct. App 2011) in South Boston where
Plaintiff was living and running video of police and various Court Trials at the
time, the Court indeed cited Cirelli v. Town of Johnston Sch. Dist., 897 F.
Supp. 663 (D.R.I. 1995) (holding that teacher had a right under the First
Amendment to videotape potentially hazardous working conditions at school,
which were a matter of public concern).
So here we have a Federal Court of Appeals applying Cirelli exactly as Plaintiff
applied it, with no mention of the bogus limiting factor that Judge Young tried
to impose by stating that Cirellis rationale applies only to public employees,
ahem.
The First Circuit relied on its earlier opinion in Iacobucci, as well as a
plethora of decisions from other courts, in holding that the First Amendment
right to record public officials in public spaces had been well established. The
Court also dismissed the suggestion that the discussion of the First
Amendment right to record in Iacobucci was too cursory to clearly establish
the right. To the contrary, the Court stated that
What is particularly notable about Iacobucci is the brevity of the First
Amendment discussion, a characteristic found in other circuit opinions
that have recognized
a right to film government officials or matters of public interest in
public space.
See Smith, 212 F.3d at 1333; Fordyce, 55 F.3d at 439. "[t]he terseness
implicitly
speaks to the fundamental and virtually self-evident nature of the First
Amendment's protections in this area."
So the key in Pomykacz and Glik is whether or not the reporter
engaged in unnecessary discussion or unprofessionalism, not whether they
were allowed to have a camera at all. And remember that those cases dealt
with police, so of course it is more important that they not be seeking
interviews with officers who are on duty; but other employees may certainly
be subject to REASONABLE inquiry, which is a case specific inquiry but this
Court is not to threw the baby out with the bathwater and prohibit ALL inquiry
because that is simply Draconian. Plaintiff understands this being a former
law enforcement attorney and so to do 99% of all independent or mainstream
journalists,
19
And quite frankly, for the coup de gras, the Third Circuit understands it
as well so Judge Young should recognize that it cited Iacobucci and Glik just
this year prior to Plaintiff filing suit. The fact of the matter is, if a citizen in
the Third Circuit is entitled to politely criticize a police officer during the
prosecution of his or her duties, then Plaintiff had dang well better be
permitted to ask a couple of polite questions at the County Recorders Office.
See Montgomery v. Killingsworth, 2015 U.S. Dist. LEXIS 7152 (January 22,
2015).
In Iacobucci v. Boulter, the First Circuit concluded that the plaintiff,
Iacobucci, had a First Amendment right to film local government
officials who were conducting public business in a public building. 193
F.3d 14, 25 (1st Cir. 1999). Iacobucci was arrested after he refused to
stop filming several town commissioners while they were discussing
the possible approval of an applicant's building permit. Id. at 18.
Charged with disorderly conduct and disrupting a public assembly,
Iacobucci spent four hours in custody, though the charges were later
dismissed. Id. Iacobucci initiated a 1983 suit in which he claimed
false arrest and excessive force. Id. After losing in the trial court, the
arresting officer appealed, contending he was entitled to qualified
immunity on those claims. Id. at 21-22. Rejecting that argument, the
First Circuit held that Iacobucci's "right to act as he did without being
arrested for disorderly conduct" was clearly established at the time of
his arrest. Id. at 24. In so holding, the First Circuit found that
"Iacobucci's activities were peaceful, not performed in derogation of
any law, and done in the exercise of hisFirst Amendment rights." Id. at
25.
Peaceful criticism of a police officer performing his duties in a public
place is a protected activity under the First Amendment. As the Court
established in City of Houston, Texas v. Hill, "the First
Amendment protects a significant amount of verbal criticism and
challenge directed at police officers." 482 U.S. 451, 461, 107 S. Ct.
2502, 96 L. Ed. 2d 398 (1987). This type of speech is necessary to
protect and preserve because "[t]he freedom of individuals verbally to
oppose or challenge police action without thereby risking arrest is one
of the principal characteristics by which we distinguish a free nation
from a police state." Id. at 462-63.
Accord Gaymon v. Borough of Collingdale, 2015 U.S. Dist. LEXIS 93014 (July
17, 2015).
In contrast, qualified immunity was rejected for the remaining First
Amendment claim because "peaceful criticism of a police officer that
neither obstructs an investigation nor jeopardizes a police officer's
safety has strong social value, serving as a valuable check on state
power, and is therefore protected under the First
20
further, a Department of Justice Memo was likewise in the books for 2 years.
Thats probably why the Court ignored Glik just as surely as it ignored
Pomykacz but were here now so lets not miss it again. From Montgomery:
Existing precedent is not limited to Third Circuit case law; case law
from other circuits is relevant in analyzing whether a reasonable officer
would have known that his conduct violated the Constitution. See
Kopec v. Tate, 361 F.3d 772, 77778 (3d Cir. 2004) (discussing other
circuit case law in determining a right was clearly established).
Importantly, this inquiry focuses only on the state of the law at the
time of the arrests: January 23, 2011, for Montgomery, and July 14,
2011, for Loeb.5 See Kelly v. Borough of Carlisle, 622 F.3d 248, 253 (3d
Cir. 2010) ([T]o decide whether a right was clearly established, a court
must consider the state of the existing law at the time of the alleged
violation and the circumstances confronting the officer to determine
whether a reasonable state actor could have believed his conduct was
lawful.).
5 Montgomery claims in his response that his arrest occurred on
January 23, 2012, even though he admits in the defendants
undisputed statement of facts that it occurred on January 23, 2011,
alleges in his complaint that it occurred on January 23, 2011, and every
other reference in the record to his arrest reflects the 2011 date. Based
on this incorrect 2012 date, he relies on Glik v. Cunniffe, 655 F.3d 78
(1st Cir. 2011), as well as a 2012 Department of Justice memorandum,
in arguing that this right was clearly established. Because Glik and the
Department of Justice memorandum came after Montgomerys arrest,
the court disregards any reference to them he makes in support of his
qualified immunity argument.
Furthermore, in publicly-filed documents that were circulated throughout the
entire country, and right next door in Maryland, the Department of Justice
Attorneys laid down the Law: In U.S. Dist. Court MD Garcia v. Montgomery
County, Civil No. 8:12-cv-03592-JFM:
21
The United States addressed the central questions raised in this case
whether individuals have a First Amendment right to record police
officers in the public discharge of their duties, and whether officers
violate individuals Fourth and Fourteenth Amendment rights when
they seize such recordings without a warrant or due process in a
Statement of Interest filed in Sharp v. Baltimore City Police Dept., et
al., No. 1:11-cv-02888 (D. Md.), attached here as Exhibit A.1 Here, as
there, the United States urges the Court to answer both of those
questions in the affirmative.
http://www.rcfp.org/sites/default/files/docs/20130307_135451_garcia.p
df
So Glik and the DOJ Memorandum were all present and accounted for
when Plaintiff
approached the venue in fall, 2014. As such, the memo written by Defense
Counsels Marshall Dennehey brethren Donald Carmelite is old news and no
longer valid, relevant or on point when he claimed, in March 2011:
There is no clearly established right to videotape police officers during
traffic stops.
http://www.marshalldennehey.com/defense-digest-articles/thumbs-qualifiedimmunity
And, further, even if all of that were not in place and Defendants argue
that the law is not established until January, 2015 Plaintiff has sought
Injunctive Relief going forward and so that would have to be heard, but in
reality, Glik and the DOJ Memo were and are clear enough. More than clear
enough. See Fn.5 from Montgomery, supra.
22
Plaintiff will now exercise his First Amendment Right to send a copy of this to
U.S. Attorney Dettlebach to let him know how things are being handled down
on the Delaware Plantation:
Plaintiff grew up with and around people of honor and integrity, unlike the
sort of unprincipled rogue backwater Justice he has seen in Delaware on
this case and relative to the five (5) black male lynchings (suicides)
according to AG Denn. Who has yet to substantively respond to my Civil
Rights Public Trust Complaint filed weeks ago.
III.
23
24
So then for the Court to hold that Plaintiff does not have a
Constitutional Right to ask a question or two of a high-ranking public official
with a camera is the same as saying he does not have a Constitutional Right
to do the same with a pen and a notepad. That proposition is of course
completely untenable. As that finding would be patently Unconstitutional this
Court must allow all Claims to proceed to Trial. 8
IV.Defendants Parade of Horribles is a Completely Implausible Defense.
Defendants cry at or around para. 28 that what if every citizen would
start running videos and asking questions of public officers, etc etc. This is
ridiculous. Surely Defendants would have to agree that every citizen clearly
already has the right to point a camera at a public official on a sidewalk for
example. But do we see scores of people descending upon the Recorder of
Deeds or any other Office to shoot public officials before or after they enter
work?
Moreover, it is lawful to run video of Police officers wherever they may
be, and politely criticize them in the Third Circuit; see Montgomery v.
Killingsworth, 2015 U.S. Dist. LEXIS 7152 (January 22, 2015), and Gaymon v.
Borough of Collingdale, 2015 U.S. Dist. LEXIS 93014 (July 17, 2015), supra.
Does that mean that every citizen is going to start bombarding police at
every street corner or in their squad cars with cameras and questions?
Lastly, surely Defendants would agree in most states that media is
allowed in Courts (actually it is allowed in Delaware too by Rule 155), but
somehow theres never any problem because of a thing they call media
pools. Heres how it works: Whenever there are too many media participants
at any individual event, one or two are chosen by agreement or lottery who
then share the footage. Plaintiff has routinely participated on these as
8 Defendants will argue that one of the cases involves video at Plaintiffs own home
but it is truly a distinction without difference when viewed in light of all of the other
cases that occurred at police stations, in public parks, etc. etc.. everywhere except
interior offices, which is again NOT where Plaintiff was trying to be, despite Judge
Young trying his best to place him there. The charade is over.
25
26
V.
27
modify
mdf/
verb
1.
make partial or minor changes to (something), typically so as to
improve it or to make it less extreme.
"she may be prepared to modify her views"
synonyms: alter, change, adjust, adapt, amend, revise, reshape,
refashion, restyle, revamp, rework, remodel, refine; More (emphasis
added)
So that was yet another feckless attempt by Defendants to avoid
liability. Whether this Court allows it or not, Plaintiff is thoroughly
satisfied with the Record in this case.
VI.
28
held that Rule 155 did not apply to trial courts. See 11 June 2015 Oral
Argument (TR.5-6, 11-12)9
As Plaintiff has noted on prior occasion he worked for Constitutional
Scholar Edward L. (Ted) Mearns (RIP) so he already knew that purportedly
private parties could be found liable under 42 U.S.C. 1983 so he is not
certain as to how the Court could overlook this crucial fact of Law.
Further, consider the Learned Treatise of Professor of Law Jack M.
Beerman and Richard L. Godfrey Faculty Research Scholar, Boston University
School of Law in "Why do Plaintiffs Sue Private Parties Under Section 1983
Cardozo Law Review V. 26 (10/9/2005).
CONCLUSION:
PROSPECTS FOR SUCCESS IN SECTION 1983 LITIGATION AGAINST PRIVATE
DEFENDANTS
29
Conclusion.
There is a whole New World beyond Delaware, whether Judge Young
and the Defendants appreciate it or not. And it is Plaintiffs Job to expose it,
which he will be doing with alacrity in the coming days, months and years.
And in Sum, Thomas Paine is still rolling in his grave, abated ever so slightly
with the promise that Plaintiff will stir some Common Sense into the Delaware
Way.10
Motion for Judgment on the Pleadings the Defendants state Just because Plaintiff can
run video in many other jurisdictions doesnt mean that he can do it here. Perhaps it
never occurred to them that in those jurisdictions including the U.S. Senate
buildings LOL Plaintiff can shoot video because that is how they view the First
Amendment to the United States Constitution, same as the Third Circuit Courts in
Montgomery v. Killingsworth, 2015 U.S. Dist. LEXIS 7152 (January 22, 2015), and
Gaymon v. Borough of Collingdale, 2015 U.S. Dist. LEXIS 93014 (July 17, 2015),
supra. But apparently the Defendants and Judge Young are too deep into their rogue
approach to back away now, so we are headed to SCOTUS while Plaintiff commences
classroom discussions about this case in Seattle and beyond.
30
Respectfully Submitted,
_____________________________________________
CHRISTOPHER KING, J.D.
kingcast955@icloud.com
mortgagemovies007@gmail.com
http://affordablevideodepo.com
http://mortgagemovies.blogspot.com
617.543.8085m
206.299.9333f
31
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 12th Day of August, 2015
________________________________
CHRISTOPHER KING, J.D.
32
APPENDIX A
33
34
35
36
37
APPENDIX B
https://www.youtube.com/watch?v=rl4tS0W7RcQ
https://www.youtube.com/watch?v=jLS0N_hH-cc
Here one of her constituents said that Ayotte Is pleasant and sweet and full
of shit.
38
https://www.youtube.com/watch?v=lXlHu2002Vc
APPENDIX C
39
40