IN THE SUPERIOR COURT

KING COUNTY WASHINGTON

CHRISTOPHER KING, J.D.
A/K/A KINGCAST
AND MORTGAGE MOVIES JOURNAL
No.__________________
17006 11TH Avenue
Shoreline, WA 98155
Plaintiff,

CASE

JURY DEMAND

JUDGE______________________
v.

WRIGHT FINLAY & ZAK

AND
LUKAZ WOZNIAK, Esq.
AND
RENEE PARKER, ESQ.
c/o Ryan Carson
200 Second Avenue W
Seattle, WA 98119

)
)
)

Defendants.

COMPLAINT
PARTIES
1.

In the past thirty (30) years Plaintiff has been a photojournalist and
editor for small and major press, an Assistant State Attorney, an
Escrow Attorney, a Civil Rights Attorney in State and Federal Court,
and a zoning and permitting communications attorney. He was the
first independent journalist to register with the Massachusetts
Supreme Judicial Court in 2012 (Appendix A) and has filmed all
matter of civil and criminal trials in courtrooms across the Country.

2.

He has no criminal history whatsoever, but among other

accomplishments Plaintiff has investigated employment abuse at
American Tower Corporation and initiated an investigation resulting

in a $290,000 ORDER against them by the Department of Labor.

Further, received a First Amendment Mayoral Commendation for his
efforts when he was NAACP Legal Chair in New Hampshire, and he
is the investigative journalist who found Joanna Marinova her
lawyers in Boston and they sued the Boston Herald for a 2015 $.9M
settlement after a 2014 $.5M Jury Verdict.
http://christopher-king.blogspot.com/2014/03/kingcast-cheersjoanna-marinova-and.html
https://www.youtube.com/watch?v=l_kb8JS-Lk0
https://www.youtube.com/watch?v=ZlaHj9QN9yc
3.

Defendant Wozniak is, on information and belief, an Associate

Attorney for the Defendant law firm of Wright, Finlay & Zak. 1

4.

Defendant Parker is, on information and belief, an Associate

Attorney for the Defendant law firm of Wright, Finlay & Zak.

5.

Wright, Finlay & Zak is a California-based law firm that regularly

practices in the forum Jurisdiction in the areas of securities,
mortgages, mortgage servicing and real estate.

JURISDICTION and VENUE

6.

This is a Court of general jurisdiction fully vested with full authority

to hear all Claims mounted herein.

7.

Defendants all either reside in, or conduct substantial business

within the forum State, consonant with any and all Constitutional
concerns involving Long Arm Jurisdiction.

8.

The misconduct giving rise to this Action substantially occurred in

King County, Washington.
FACTS

1 Name Partner Jonathan Zak is, on information and belief published on a corporate
website, no longer a partner with said firm but is now of counsel, as noted
subsequently.

9.

In the fall of 2014 Plaintiff ran video of several Plaintiff Depositions

involving a foreclosure case of Lucero v. Cenlar, Case No. 20130602, in which Cenlar was denied Summary Judgment on the issue
of Outrage.

10.

All Parties and Plaintiff later stipulated that certain Depositions

would not be broadcast. This will become relevant as noted in
paras 11-14, infra.

11.

Later that year Plaintiff attended a Defendant Deposition in the

case of Lucero v. Cenlar as a videographer. There was some
disagreement as to whether he would be permitted to run video but
all Parties and Counsel AGREED that he would permitted to do so.

12.

Defendant Wozniak was present at that Deposition, as were two

other bank/servicer attorneys, Joseph McIntosh and Heidi Buck
Morrison.2

13.

For reasons never articulated to Plaintiff, these three attorneys

reneged on the agreement and Plaintiff promptly began packing up.

14.

Defendant Wozniak, for no lawful reason, spoke down to Plaintiff

and told him in a very mean-spirited manner to Get out. When
Plaintiff admonished him to Watch your tone to me, Counselor, I
am clearly packing up, the male attorneys threatened to have him
arrested by calling security for no lawful reason. Much of the
exchange was captured on audio and Plaintiffs camera was still
running. Plaintiff contemplated reporting the conduct to the Bar
Association but decided to give the Defendants the benefit of the
doubt. See:
Judges Will Watch as Foreclosure Mill Attorneys Threaten Depo
Videographer with Security and Arrest.

2 Attorney Morrison has apparently left the Jurisdiction and resides in Idaho as of this
writing.

https://www.youtube.com/watch?v=mFTCVXNaisY

15.

However, in September or early October of 2015 Plaintiff became

aware that Defendant Wozniak was reprimanded on Record by
Judge Lasnik for failing to treat a witness with compassion.

16.

On hearing this, Plaintiff became concerned about a pattern and

practice on the part of Defendant Wozniak, and he did then issue a
complaint to the Court on 2 October 2015 with a copy to Defendant
Wozniak. The subject line read:
Dear Judge Lasnik: I want you to know how Luke Wozniak
comports himself in general.

17.

In so doing, Plaintiff scolded Attorney Wozniak and used language

remarkably similar to that of Wright, Finlay Partner Jonathan Zak
(see para 18, infra) as Plaintiff admonished Defendants that they
should get good with Jesus, who might in fact, be a brown man.

18.

For the record, pro se Plaintiffs in a Ventura County, California case

allege that Attorney Zak threatened them with malicious
prosecution on a Quiet Title Action involving Bank of New York

3 Significantly, Plaintiff hid nothing and in fact implored Defendant Wozniak to tell
the Court:
Feel free to show this to Judge Lasnik. If you don't, I will.
A full copy of the email is attached hereto as Appendix B.

Mellon, while telling them that he was The Terminator and that
they were Going to have a come-to-Jesus moment. The conduct
was memorialized in a Transcript provided to Plaintiff that reads, in
pertinent part, as noted in the below thumbnail where the litigants
complain that he had told them they had better get on their knees
and have a Come to Jesus Moment because he was the terminator.
19.

As noted by the transcript, and in the near future by way of Affidavit

and live testimony at Trial, the WFZ associate laughed at the notion
that such words could be unreasonably threatening coming from a
name partner to pro se litigants (Appendix B).

20.

Plaintiff asserts that if those words are not threatening from a name
partner to pro se litigants then they are not threatening between
seasoned attorneys, either, and Plaintiff and all Defendants in this
case are indeed seasoned attorneys.

21.

Such conduct hardly constitutes a death threat, but it is certainly

abusive conduct when coming from a 30-year litigator to pro se
litigants, particularly when there is no basis for a malicious
prosecution action, as Plaintiff has publicly noted. On SCRIBD. 4
https://www.scribd.com/doc/289136279/Former-Wright-Finlay-ZakWFZ-Partner-Jonathan-Zak-Issues-a-Come-to-Jesus-Death-Threat-inVentura-Case-No-56-2013-00445950-CU-Or-VTA

22.

In open Court, on or about 27 October, 2015 Defendants, by and

through Defendant Parker, point blank stated that Plaintiff had
issued a Death Threat to Wozniak and to Parker because Plaintiff
knew she would read the email. See Appendix D, attached.

23.

This was a complete lie and cover up and was all part of an unlawful
civil conspiracy because Parker had to be aware that Plaintiff had
previously challenged the professional ethics and demeanor of
Defendant Wozniak -- simply because he had to have told her and
the Corporate entity about it -- and it had been on YouTube for a
year prior to the Death Threat.

24.

On information and belief, at no time did any of the Defendants

report any alleged death threat to the Seattle Police.

25.

On information and belief, at no time did any of the Defendants

report any alleged death threat to the FBI.

26.

On information and belief, at no time did any of the Defendants

report any alleged death threat to any law enforcement official
other than Judge Lasnik immediately prior to the hearing on 27
October nearly an entire month after the purported threat was
issued.

4 A copy of the relevant passage from Plaintiffs Court filing complaining of the
conduct toward them is attached at Appendix C.

27.

Judge Lasnik a former prosecutor on his own right -- did not find
cause to publicly take any action against Plaintiff for the allegedly
threatening email.

28.

Plaintiff was never notified of any cause for alarm by any Law
Enforcement Officials at any time.

29.

On information and belief, the individual Defendants had notified

senior corporate staff to alert them of the purported Death Threat,
and they all conspired to fabricate a death threat, to muzzle a
vigorous journalist, knowing full well that the words used are fairly
commonplace and do not denote or connote any such threat.

30.

Judge Lasnik declined the requested relief to expel Plaintiff from the
Courtroom, and at no point in time did he lend any credence to
Defendants claims, nor did he at any point in time take any sua
sponte action against Plaintiff for any alleged threat.

31.

The false statements about a crime of moral turpitude were made

with malice aforethought, with complete knowledge of their falsity
and were broadcast to the World Public by way of communication in
a public federal courtroom.

32.

The malicious, false and Defamatory statements were made with

the direct intent to provoke a Federal Judge and former prosecutor
to take action against Plaintiff, when any Court reprimand or arrest
of his person would at once prevent him from being a licensed
attorney again and ruin his credibility as an online journalist.

33.

The malicious, false and Defamatory statements were steeped in

racism, as there is no way that these attorneys would have
attempted to say that a white male in Plaintiffs position had issued
a Death Threat. We know this because a white male Senior Partner
of the Corporate Defendant did indeed issues those words and they
were not considered as a Death Threat.

34.

The malicious, false and Defamatory statements were made in an

attempt to limit scrutiny of the underlying case, which ended in a
$214,000.00 bench Judgment against Wright, Finlay & Zak client
Cenlar, FSB, for the Tort of Outrage.

35.

As goes the client as goes the law firm, two peas in a pod.

36.

Plaintiff has a history of other racist, mean-spirited people attacking

him for being A Dangerous Black Man and Plaintiff was and is
foreseeably damaged by these actions. Defendants were aware of
this fact prior to publication as Plaintiff had written all parties in
2014:
Re: Lucero v. Bayview, August 11, 2014
August 12, 2014 at 8:35 AM
FromChristopher King
To"Ha Dao"
Cc"Vicente Omar Barraza"
"Joseph McIntosh"
Production"

"Heidi Buck Morrison"

"Lukasz I. Wozniak"
"Virginia Parsons"

"Michelle Darnell"

"Steve Morberg"

"Julia Paris"

production@centralreporting.com
m

"YOM

info@mccarthyholthus.co

"ha dao"

Bcc"Scott Stafne"

"Terri Conklin"

Dear Attorney Dao:

It is most certainly unfortunate that Defense Counsel used the
situation yesterday to somehow imply that there were security
issues of any kind. You don't have to go to Court for anything I'll
handle it myself if they chose to go there. That sort of conduct

smacks of the "dangerous black man" mentality that American

Tower Corporation used when they called the police on me and the
police also asked them WTF is going on. We made a movie about
that too and they settled. Two of us -- myself and a Caucasian
female successfully sued them for Defamation and wrongful
termination as we had been stellar employees in the land use
acquisition department until they asked us to commit illegal acts.
Moreover, because of my complaint written with my trainee
Michael Mae the DOL fined ATC $290K
http://www.dol.gov/whd/media/press/whdpressVB2.asp?
pressdoc=Northeast/NEarchive/20041020.xml
I am sick and tired of people with ill intentions trying to make me
into the Bad Guy when review of the audio clearly reveals
otherwise. The only thing they are scared about.... is my camera
putting the Truth to Light.
Sincerely,
CHRISTOPHER KING, J.D.
37.

The Defendants were again reminded a year ago that Plaintiff was
not violent, in an email to Heidi Buck et al. noting the RCO was
observing the situation.

RCO sniffing around my websites and FB but their counsel won't speak to me.
August 18, 2014 at 9:26 PM
From Christopher King
To"Ha Dao"
Cc" " "Vicente Omar Barraza" ""
McIntosh"
Parsons"

"Heidi Buck Morrison"

"Lukasz I. Wozniak"
"Steve Morberg"

"YOM Production"
"Michelle Darnell"

production@centralreporting.com

"Joseph
"Virginia
"Julia Paris"

info@mccarthyholthus.com

"ha dao"

10

Bcc" " "Scott Stafne" ""

"Terri Conklin"

Heidi,
I told you before -- as noted below -- that I am a reasonable man and I pose
absolutely no threat to you that should make you justifiably refuse my
presence at video depositions. But apparently there is something threatening
about me, enough so that your co-counsel completely disrespected me last
week. And you are continuing in that vein by not answering my wellreasoned question.
Please advise because obviously I can see you and your people are reading
and so can anyone else for that matter because I am posting these three
screen captures -- showing RCO, NWTS and FEI process servers at IP
address 97.65.96.138 reading assiduously -- on my journal page.
The issue isn't exactly going to go away Heidi because other lawyers will be
using my services, and they will be much more likely to force your hand on
this. And when they do, and if you fight, the evidentiary trail is right here in
these emails, and in that audio from last week.
Don't forget that for one minute.
Sincerely,
CHRISTOPHER KING, J.D.
kingcast955@icloud.com
mortgagemovies007@gmail.com
http://affordablevideodepo.com
http://mortgagemovies.blogspot.com
617.543.8085m
206.299.9333f

11

38.

Some of the heinous current actions of Defendants may be seen in

the following YouTube video. https://www.youtube.com/watch?
v=5dVPEy7Pygo

12

CLAIMS
1.

Defamation/Defamation per se The Defendants knowingly

and intentionally broadcast the false assertion regarding a
crime of moral turpitude, i.e. murder, in claiming that Plaintiff
had indeed issued a colorable death threat with an intent to
cause harm to Plaintiff, and indeed harm was caused as
these false accusations exposed a living person to hatred,
contempt, ridicule or obloquy, and, if successful, would have
deprived him of the benefit of public confidence or social
intercourse, and (2) injured him in his business, trade,
profession or office." Caruso v. Local Union No. 690, 100
Wn.2d 343, 353, 670 P .2d 240 (1983). Defendants jointly
and severally engaged in Defamation and Defamation per se.

2.

False Light Per Eastwood v. Cascade Broad. Co., 106 Wn.2d

466,469,722 P.2d 1295 (1986) A false light claim arises when
someone publicizes a matter that places another in a false
light if (a) the false light would be highly offensive to a
reasonable person and (b) the actor knew of or recklessly
disregarded the falsity of the publication and the false light in
which the other would be placed.

3.

Outrage -- The elements of the tort of outrage are

(1) extreme and outrageous conduct,(2) intentional or
reckless infliction of emotional distress, and (3) severe
emotional distress on the part of plaintiff. Rice v. Janovich,
109 Wn.2d 48, 61 (1987). Defendants jointly and severally
engaged in Outrageous conduct.

4.

Intentional Infliction of Emotional Distress Defendants

jointly and severally engaged in intentional infliction of
emotional distress by engaging in conduct that would shock
the conscience of a reasonable person by publicly lying about
an attempted crime of moral turpitude.

13

5.

Tortious Interference with Business Expectancy Defendants

attempted to ruin the legal and journalistic career of Plaintiff
and to ruin his chances of obtaining Court access by labeling
him as a violent Felon. Defendants jointly and severally
engaged in Tortious Interference with Business Expectancy.
Prior to Defendants lies Plaintiff had a business relationship
with the law office representing Plaintiff with respect to
Deposition videos. As the tensions raised regarding this
issue said counsel reasonably became concerned about her
first priority, which is naturally to her client. The relations
between Plaintiff and the law firm were essentially soured
and severed unnecessarily because of Defendants
orchestrated lies.

14

6.

Civil Conspiracy -- In this case we have Defendants Wozniak

and Parker, and potentially other members or associates of
the Corporate entity, joining together to posit a known lie to
a Federal Court, in open Federal Court. We therefore have
two or more people gathering to accomplish an unlawful
purpose of threatening First Amendment conduct, and (2)
entering into an agreement to accomplish said conspiracy.
Corbit v. JI Case Co., 70 Wn.2d 522, 528-29, 424 P.2d 290
(1967). The existence of a civil conspiracy must be
established by clear, cogent, and convincing evidence. Id.
The existence of a conspiracy may be based on
circumstantial evidence but mere suspicion is insufficient. Id.
Defendants engaged in conduct amounting to a civil
conspiracy when, including but not limited to: engaging in
conduct that would shock the conscience of a reasonable
person by publicly lying about an attempted crime of moral
turpitude, particularly after having been warned of Defendant
Wozniaks unprofessional conduct one year prior. Defendants
jointly and severally engaged in Civil Conspiracy with full
knowledge by the Corporate Entity.
DEMANDS

1.

Immediate Declaratory Judgment that the Defendants individually

and collectively are responsible for all Claims.

2.

Injunctive relief against any and all further such failures

3.

Assessment of all Costs against Defendants for willful derogation of

Law.

4.

Punitive Damages in an amount and degree commensurate with the

wrong.
CERTIFICATION

The foregoing Complaint is true and accurate to the best of Plaintiffs

recollection and belief.
____________________________________________________
NOTARY PUBLIC
My Commission Expires_________________________

15

Respectfully submitted
___________________________________________
Christopher King, J.D.
a/k/a KingCast/Mortgage Movies Journal
APPENDIX A

16

APPENDIX B

From: Christopher King <kingcast955@icloud.com>

Date: October 2, 2015 at 11:42:02 AM PDT
To: lwozniak@wrightlegal.net, lasnikorders@wawd.uscourts.gov
Cc: mortgagemovies007@gmail.com
Subject: Dear Judge Lasnik: I want you to know how Luke
Wozniak comports himself in general.
This is what I wrote him, Your Honor. And he deserves every bit of it.
I will never suffer any indignities from a jerk like him or anyone else
for that matter. Watch the video.
Respectfully submitted,
Christopher King, J.D.
On Oct 02, 2015, at 11:15 AM, Christopher King
<kingcast955@icloud.com> wrote:
Treat the witness with compassion.... you were warned in Lucero v.
Bayview 2013-CV-0062 the other day. Good thing for you that
Federal Court is not on video but that Transcript is available and it
will show that you seem to have a difficult time bringing up a Veep
to testify on your client's behalf.
If I see you later this month my friend, outside the courtroom, on a
public street.... you can't flip me from Invitee or Licensee to
Trespasser in a hot second.
Perhaps Judge Lasnik knew you were an abusive person from
watching KingCast media LOL dude one way or another you will
learn your place, Counselor. I'm just getting started with you.
http://mortgagemovies.blogspot.com/2014/08/kingcast-andmortgage-movies-see-judges.html
https://www.youtube.com/watch?v=mFTCVXNaisY
You have a friend in Ferguson and all the other pricks who are trying
to run homeowner attorneys out of business but you can't touch a
journalist because I'm going to say whatever the hell I want to about
you, to your face and on my journals, subject to Defamation of
course. But thankfully your prior actions have given me plenty of
latitude there because you were such a complete asshole toward

17

me, and that's a fact. On record. I don't know who the fuck you
think you are, but you will not run that game with me, kid.
Feel free to show this to Judge Lasnik. If you don't, I will.
Ciao.
CHRISTOPHER KING, J.D.
kingcast955@icloud.com
mortgagemovies007@gmail.com
http://affordablevideodepo.com
http://mortgagemovies.blogspot.com
617.543.8085m
206.299.9333f
PS. I haven't been to Europe in a decade but my Croatian pals just came
back..... They tell me they have confirmed proof that Jesus was black. So you
better get good with him.

18

APPENDIX C

19

20