IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON

1 IN AND FOR THE COUNTY OF KING

2
CHRISTOPHER KING, JD ) CASE NO. 18-2-28075-3SEA
3 A/K/A KingCast,
)
4 Plaintiff,
)
5 vs.
) JUDGE_________________
6 FACEBOOK, INC.,
) CLERK’S ACTION REQUIRED
7 Defendant.
8 NOTICE OF ERRATA AND PLAINTIFF’S RENEWED SHOW CAUSE MOTION
TO FIND DEFENDANT IN CONTEMPT OF COURT
9
NOW COMES PLAINTIFF to note the fact that he had attached a copy of his Proof of
10
Service to his Motion in response to the Court’s DENIAL of a requested Show Cause hearing: The
11
Court held that there was no proof that the Defendant in this matter has been formally put on notice of
12 the existence of this case. However as noted by the email sent to the Process Server there was indeed

13
notification of the initial TRO ORDER in this matter – it is the document on the far right of the
screenshot labeled Facebook ORDER and the Process Server has verified that he delivered it, and
14
Service of Process on a registered agent is sufficient to invoke Jurisdiction for a Show Cause
15 Contempt Hearing; Plaintiff has never seen any case law to the contrary.
16

17

18

19

20

21

Additional support in favor of the Public Interest on a TRO/Contempt/Injunction:

22
Time Magazine today reports that Facebook is scrambling to create an independent commission to
23
deal with content regulation. Plaintiff submits that he would like to be a panelist on a contract basis
24 with Defendant, after they pay him for the wrongs they have committed in the face of a valid Court
25 Order that they and their Counsel have been on Virtual and Actual Notice of for quite some “time”
now: http://time.com/5456421/mark-zuckerberg-facebook-russia-definers-conference-call/
26

1
 1

3
The call was originally designed to reveal how the company is changing its approach
4 to content moderation. On Thursday, Facebook also released a reportshowing how
much “bad content” — ranging from hate speech and bullying to nudity and terrorist
5 propaganda — it is taking down each quarter because it violates the platform’s terms
of service. (The short answer: billions of items, and growing.)
6
Zuckerberg announced a bevy of related initiatives, such as Facebook’s yet-to-unfold
7
plan for stopping the spread of sensational and provocative content that doesn’t
technically violate its terms. The most significant may be the creation of an
8
independent board that will act as a check on the decisions the company makes about
9
“what stays up and what comes down” among the billions of posts that Facebook’s 2
billion-plus users share every day. Zuckerberg also promised to start holding quarterly
10 calls to provide updates on how this massive, thorny effort is proceeding — further
proof that Facebook is hoping that more openness will help solve its many problems.
11
**********
12
On 8 November, 2018 this Honorable Court issued a specific Order with carefully-crafted language
13
towards Defendant. Appendix A The Order told Defendant in no uncertain terms to [reinstate]
14 Plaintiff’s Facebook privileges to permit Plaintiff to publish posts regarding the loss of his mother,

15 with the remaining request for relief reserved pending the return hearing scheduled to 30 November
2018.1
16
Meanwhile Plaintiff swears as on Oath that he posited a copy of the Order with the only
17
known local Counsel for Defendant: John Robertson, Cooley, LLC Managing Partner refused to
18 accept it and Plaintiff was compelled to leave it on the front lobby desk. See the YouTube video of

19
the incident here: https://www.youtube.com/watch?v=RKAJ88PVLLo
Robertson’s conduct mirrors his conduct a day or two prior to the Order’s issuance when
20
Plaintiff attempted to resolve the matter through extrajudicial means. Robertson wrote in a patently
21 insouciant and patronizing email:
22 "I would like to remind you that we are a private business and people are here working to
get their jobs done. Access to our office is for our employees and clients. You do not have
23 permission to enter our offices. Please do not contact our employees any further. It is
interfering with our business."
24
1
25 Because of a scheduling anomaly the case could not be heard until 30 November, 2018. There is yet another
scheduling issue because the Celebration of Life for Plaintifff’s mother is on 1 December 2018 and Plaintiff
26
was not be available between 27 December 2018 and 7 December because of that event and a previously-
scheduled event in Vancouver, 4-6 December, 2018.

2
 1 Plaintiff further swears on Oath that he forwarded Actual Notice of the Order to Facebook via
2 its purported Appellate procedure. He received responses from Facebook after such submissions yet
Facebook continued to ignore the Court Order.
3
Then, on Tuesday 13 November 2018 Plaintiff engaged his process server to serve
4
Defendant’s registered corporate agent. Service was effected before noon, and Plaintiff notified the
5 Court and local Facebook Counsel Robertson prior to Close of Business 13 November, 2018 yet and
6 still as of Close of Business 14 November 2018 Defendant continues to flaunt the valid Court Order.
Plaintiff cannot speculate as to the ultimate reason for the intransigence but perhaps it is
7
because their Chief Legal Counsel is preparing to take a powder: After eight (8) years at the helm,
8
Colin Stretch will resign his post at the Internet juggernaut for greener pastures. Plaintiff tweeted him
9 as well so perhaps he is too consumed to review a notice about possible Contempt of Court. See

10 overleaf. https://www.cnbc.com/2018/07/25/facebooks-top-lawyer-colin-stretch-is-leaving-the-company.html
Plaintiff has done all that he can do, and Defendant has had ample time in such an
11
exigent situation to respond, either through local Counsel, the corporate Defendant on the end of
12
Plaintiff’s help requests, via Process of Service at the registered agent and even by and through
13 the still current General Counsel. All of the predicate factors are in play to GRANT Plaintiff’s

14
sought relief immediately. 2
May the Court keep in mind that the underlying “Hate Speech” offense, as noted at Plaintiff’s
15
current blog on the matter (https://howtosuefacebook.blogspot.com/) was that he redlined a Sheriff’s
16 report noting the races of people involved and noted that he believed the report was “biased” because
17 the white Sheriff ignored a white man at a Defendant’s corporate address who had dropped five – 5 –
F-Bombs in Plaintiff’s face. The identifying information has been removed from the document
18
pursuant to settlement of that case and Plaintiff presents copy of that document so that the Court and
19
the Entire Free World can clearly see that there is simply no Hate Speech involved, even by
20 Defendant’s own Hate Speech policy that was attached to the Complaint and Demand for Injunctive
21 Relief and presented again, herein with the edited report image at Appendix B.

22

23

24
2
25 If the Court should find otherwise, Plaintiff shall again incur an expense by engaging the labor of his process
server for Friday, 16 November 2018 to serve a copy of this Motion noting a hearing at King County
26
Courthouse Room 325 at 2:00 p.m. Plaintiff will even agree to telephonic appearance if Defendant claims
that it does not have anyone to appear in person.

3
 1

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

4
 Against that backdrop note that Plaintiff continues to suffer palpable harms. His sister comments
1
on their mom on Facebook noting her undergraduate degree at 50.
2

10

11

12

13

14

15

16

Meanwhile Plaintiff’s friend since 1973, Dr. Joshua A. Breslau lost his mother as well, in addition to
17

18 living 2 blocks away from the Squirrel Hill massacre in Pittsburgh. He can post his mother’s obituary

19 and Plaintiff can’t even share in that relate it to his own mother’s obituary in blatant contravention of a

20 Court ORDER. Each respective mother were personal favorites for each man. That’s Dr. Breslau

21 losing his grip from Plaintiff’s clubhouse in 1973 while Plaintiff’s mother took pictures and made tea

22 sandwiches for us, and then again that is Dr. Breslau with Plaintiff last month at their 35th Hawken

23 School reunion.

24

25

26

5
 1

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

6
 1

10

11 CONCLUSION

12 You only lose your mother once. And you should never lose what is essentially your First

13 Amendment Rights, ever. As noted by today’s Time Magazine feature Facebook is in deep trouble
over this contractual issue with its subscribers and this case is going to address it, in Open Court and
14
on video. Momma would have it no other way because she told Plaintiff to get a blog twenty (20)
15
years ago in point of fact. Defendant’s blatant disregard of a valid Court Order has rendered this
16 moment much more painful for Plaintiff than it already needed to be, as his mother died of a

17 protracted battle with dementia. The Court must not allow for such abusive conduct that tends to set a
bad tone for the balance of the litigation.
18
Plaintiff apologizes on behalf of Defendant for wasting taxpayer monies and using Judicial
19
Resources to address this matter that was caused purely by Defendant’s contumacious misconduct. As
20 the facts of this case and the facts of the Contempt of a clearly-established Court Order can only be

21
interpreted in favor of the Moving Party, Plaintiff hereby requests that the Court issue an ORDER
finding Defendant in Criminal Contempt of Court and to issue any and all appropriate sanctions
22
including costs assessed against Defendant and Punitive Damages as well.
23 REPECTFULLY SUBMITTED AND DATED this 16th Day of November, 2018.
24
_________________________________
ChristopherKingJD .
25

26

7
 IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON
1 IN AND FOR THE COUNTY OF KING
2

3 CHRISTOPHER KING, JD ) CASE NO. 18-2-28075-3SEA

A/K/A KingCast,
4 )
Plaintiff,
5 )
vs.
6 ) JUDGE_________________
FACEBOOK, INC.,
7 )
Defendant.
8

9
FINAL PROOF OF SERVICE
10

11 I, the undersigned, being over the age of 18, solemnly swear that I today served upon the
12
following person or corporate entity:
13
Recipient: CSC Lawyers Incorporating Service, Inc.
14

15
Description of Recipient: Becky Degeorge
Service Address
16 2710 Gateway Oaks Dr Ste 150N, Sacramento, CA 95833

17 GPS Data
Mobile Device: Android 7.0
18 GPS Coordinates: 38.6163642, -121.515948
GPS Timestamp: Tue Nov 13 2018 11:52:21 GMT-0800 (Pacific Standard Time)
19

20 The set of documents enumerated herein:

21 Documents:
1.Instructions
22 2. Summons
3. Complaint (Motion for Injunctive Relief)
23
4. Discovery (Plaintiff’s First Interrogatories, Request for Documents and Admissions)
24 5. Discovery signature pages (attached separately)
6. Revised Motion for Temporary Restraining Order
25 7. Stipulation of Damages and Dismissal of Sole Federal Claim
8. Order of 8 November 2018 Compelling Defendant to all provisional posting by Plaintiff
26 as to his mother’s passing from this Earth

Stipulation
 Said Documents pertaining to the
case
I

2
Case: 1B-2-28A1 5-3 SE'A
ftui.rtittt Christopher King, JD alkla Kingcast
J Defendant: Facebook, Inc'

DATED this [ 3 DaY of November' 2018

5

o 5 Star Leeal SuoPort Services. Inc

serviceofproces s9 1 6(&gmatleom
10 800.683.4769

11

12

13

14

15

16

17

18 cc: Christopher King, J.D.

't9

2A

21

22

23

24

25

26

Stipulation
Plaintiff is still waiting……

6
12. Hate Speech
We do not allow hate speech on Facebook because it creates an environment of
intimidation and exclusion and in some cases may promote real-world violence.
We define hate speech as a direct attack on people based on what we call
protected characteristics — race, ethnicity, national origin, religious affiliation,
sexual orientation, caste, sex, gender, gender identity, and serious disease or
disability. We also provide some protections for immigration status. We define
attack as violent or dehumanizing speech, statements of inferiority, or calls for
exclusion or segregation. We separate attacks into three tiers of severity, as
described below.

Sometimes people share content containing someone else’s hate speech for the
purpose of raising awareness or educating others. Similarly, in some cases,
words or terms that might otherwise violate our standards are used self-
referentially or in an empowering way. When this is the case, we allow the
content, but we expect people to clearly indicate their intent, which helps us
better understand why they shared it. Where the intention is unclear, we may
remove the content.

We allow humor and social commentary related to these topics. In addition, we

believe that people are more responsible when they share this kind of
commentary using their authentic identity.

Plaintiff submits that Facebook is clearly breaching its own drafted contract right
here. “words or terms are used self-refentially or in an empowering way….”
Bingo. Plaintiff was directly referring to himself during two of his 2018 bans, and
stating how racist treatments made him feel, and noting that he was not going to suffer it
and that he was going to rise above it… until Facebook put him down, that is. And that is
why we are in Court today, because Facebook is not to be trusted.

13
 1 IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON
IN AND FOR THE COUNTY OF KING
2

3
CHRISTOPHER KING, JD ) CASE NO. 18-2-28075-3SEA
4 A/K/A KingCast,
)
5 Plaintiff,
)
6 vs.
) JUDGE_________________
7 FACEBOOK, INC.,
)
8 Defendant.
9
ORDER GRANTING PLAINTIFF’S REQUEST FOR SHOW CAUSE HEARING
10 FOR CONTEMPT OF COURT
11 This matter comes before the Court pursuant to Plaintiff’s Show Cause Motion for Contempt
12 of a Court ORDER drafted and filed by this Court on 8 November, 2018. The Order specifically
13
restrained Defendant from forbidding Plaintiff the privilege to discuss the loss of his mother. Plaintiff
14
has demonstrated that he contacted Defendant directly via Facebook prior to and after issuance of the
15
order. Plaintiff has demonstrated that he notified local unofficial Counsel for Defendant by email prior
16
to the Order and by direct hand delivery after issuance of the Order. Plaintiff further provided Actual
17
Notice to the Defendant’s registered agent by Licensed Process Server as well.
18
As such, the Court finds Plaintiff’s motion to be well-taken and hereby ORDERS:
19
________________________________________________________________
20
_________________________________________________________________________
21
_________________________________________________________________________
22
________________________________________________________________________
23

SO ORDERED this _____ Day of November, 2018

24

25
_________________________________
26
DUTY JUDGE