Monday, February 7, 2011
KingCast tells Nixon Peabody's W. Scott O'Connell: "You better learn the difference between a principle and a principal before you think you can scare me on Rule 11 Sanctions against Gordon MacDonald."
I read your letter but have only limited access to Internet. When I return tomorrow I will explain to you and your co-worker once again that a Complaint includes all filed materials, such as CDs that were embedded, linked and attached in hard copy. Therefore your attempts to skirt the fact that Officer Hargreaves' statements made to me at the Joe Arpaio rally were included by reference in Plaintiff's First Amended Complaint are principally wrong. You wrote, "Efforts to mask deficiencies in your Amended Complaint with personal attacks against others is wholly improper. Your legal training should have equipped you with this important principal."
As to your inability to grasp basic tenets of the English language, I will share that with the Free World and the Court tomorrow when I file my Motion for Sanctions and in my NENPA panel discussion this weekend. More. And yet more, with Liko Kenney and film producer Dorothy Aufiero, it's all going in. Your letter will be of substantial interest and documented in my forthcoming NENPA video. I can mail you a DVD if you like. The fact that I misspoke at one point regarding which event was which is of no moment, Sir. So you go on ahead and prepare to file your Motion for Attorney Fees because you don't scare me one bit. I am filing my Motion for Sanctions tomorrow afternoon, including this footnote regarding my unintentional misstatement as opposed to Attorney MacDonald's intentional attempted act of deception:
 Note: Plaintiff was in error and misspoke, as this event at VFW was indeed the same event identified by Defendant Counsel in the Rule 11 Response letter at Appendix A. Plaintiff gets confused at times given the number of times he has been unlawfully threatened with arrest. This in no way decreases the merit of Plaintiff’s argument because Defendant (again) ignored the same exact statement coming from Officer Hargreaves at the Joe Arpaio rally as he threw him out of the entire building without any lawful justification whatsoever. This is documented at para. 16 of Plaintiff’s First Amended Complaint with video incorporated by reference. Defendant disrespects the Order of the Court admitting such evidence into the Record. Defendant argues that such statement is “entirely legal” but that of course puts the cart before the proverbial horse because that is the entire point of this litigation. Moreover, the letter contains an obvious lie regarding the content of Plaintiff’s Amended Complaint at item E, 42 U.S.C. §1985, see Exhibit 1, Plaintiff’s Open Reply to Defendant’s Rule 11 Response attached herein.