Senator Kelly Ayotte

Senator Kelly Ayotte

Friday, December 10, 2010

KingCast files Motion for Disclosure on Free Press & 42 U.S.C. §1981 lawsuit on relationship between McLane, Graf, Kelly Ayotte, Jack Middleton, Jennifer Parent, Magistrate McCafferty and Defendant Kelly Ayotte.

It all ties in with this video and this journal entry, the Motion for Disclosure (now properly linked as of 10:32 p. 11 Dec) is the same except for the Local Rule 7.1c Declaration and Request for Oral Argument to "establish and to maintain the integrity of this process."

The nerve of these guys. I caught on to it because in this Ridley Report video where David Ridley noted that the McLane, Graf attorneys were "evasive" with their names.... so I wondered "why would they be evasive with their names????"

I noted in the video comments:

10 seconds ago
4:00 et seq Jennifer Parent and Jack Middleton were "evasive" with names because they didn't want us to figure out that they are all in the same cesspool of Judicial favoritism but I've got their number now. And this issue will go with the file all the way to SCOTUS, the nerve of these people to try to fuck me over like that, I am indefatigable and I will put their business in the goddamn street.


4 minutes ago
2:55 Judge McCafferty is not refreshing at all, her boss at McLane, Graf her boss was Defense Counsel Jack Middleton, who was also Defendant Kelly Ayotte's boss. Meanwhile Middleton's co-counsel Jennifer Parent, worked with Kelly Ayotte.

These people will do whatever is necessary to eliminate the relevance of the "acrimonious relationship" McCafferty noted because it stems from another racial and First Amendment case when I was NAACP Legal Chair and I kicked Kelly Ayotte's ass, that's a FACT.


  1. So the Motion for Sanctions is complete pending final review and filing, here then we start to craft the Memorandum Contra Defendants' Motions to Dismiss:

    A. Service

    Defendant, in an attempt to skirt the issues, has implied that it will mount an argument that Friends of Kelly Ayotte was not properly served because Plaintiff initially served “Kelly Ayotte Senate Campaign” by and through Kelly Ayotte at her home address, and did not waste the time and money to serve her with another Complaint noting the name change to reflect the correct name of the entity being sued. The Court granted Plaintiff the Right to Amend his Complaint to clarify the names of the parties – but not the identities of the parties or to add new parties -- and Plaintiff did so.

    Therefore this case is indistinguishable from Estate of Xue v. Aramark Corp., 2007 U.S. Dist. LEXIS 30918 (2007) and the case must go forward and be heard on the merits.



    The specious nature of Defendant’s argument is best shown by its insouciant attempt at addressing NAACP v. Thompson, 648 F.Supp. 195 D.Md.,(1986) a case clearly on point. Defendant stated:

    “Similarly, reliance on NAACP v. Thompson, 648 F. Supp. 195 (D. Md. 1986), with facts distinguishable from this case, does not save Plaintiff s claim from dismissal.”

    Sadly, Defendants fail to address exactly how NAACP v. Thompson is distinguishable, because the ONLY possible point of distinction is the amount and type of licensing, and that is an issue for Discovery and Summary Judgment, not a Motion to Dismiss. Then Defendant makes a legally dishonest and blanket statement that:

    “The Plaintiff presents no legal authority for his central proposition that any individual has a First Amendment right of unrestricted access to a private event.”

    But that is of course a bald faced lie. First of all Plaintiff – once again – is not asking for unrestricted acces, but NAACP v. Thompson does grant him the amount of access that Plaintiff seeks and in point of fact it went beyond what Plaintiff seeks – attendance at permitted and licensed commercial facilities – to award protection on someone’s private property. Defendants cannot get around the material fact that the subsequent NAACP case of Invisible Empire of the Knights of the Ku Klux Klan, Maryland Chapter v. Town of Thurmont, MD. 700 F.Supp. 281 (1998) (at leagle) held that the NAACP -- much like the Kay Plaintiff -- cannot barge in and command a place on the dais, but that's just common sense. Invisible Empire and Kay are materially different from Thompson, and that is why Defendants failed to distinguish Thompson, hoping that their friends in this court would let it slide. See Plaintiff’s Motion for Disclosure, filed 10 December 2010.

    Defendants’ arguments are pathetic in this regard and thus a Motion for Rule 11 Sanctions is being filed contemporaneously with this Memorandum.