IN

THE SNOHOMISH SOUTH DIVISION COURT

LYNNWOOD, WASHINGTON


KRISTINA M. ROBINSON,


)

Complainant,


CASE No. STK17-0005






)











JUDGE __________________
v.







CHRISTOPHER KING, J.D.


)




Respondent.







MOTION IN LIMINE OF RESPONDENT KING

Respondent files this Motion in Limine regarding a conversation in which he

allegedly threatened to shoot a third partys dog in the head. As an initial matter,
Respondent hereby submits more of the entire conversation with said third party for
context such that the Court may see that there was no credible threat.
Further, Complaining Party lacks Standing to assert an interest allegedly belonging
to a third party. This is clearly a trumped-up attack and attempt to chill the exercise of
Inalienable First Amendment Rights. Unlike Complaining Party, Respondent has no
criminal record whatsoever, whereas Complaining Partys pattern and practice is to
delay and to shirk her responsibilities, witness her two-year long stall tactics relative to
her conviction for a crime of moral turpitude involving deceit, i.e. a plea bargain to
Attempted forgery in this very County. She never completed her Community Service
and had not one, not two, but THREE bail revocations. See Case No. 1878A-04F Ex. 1 as
attached to Respondents Motion to Compel.
In point of fact, the purported threat occurred over a week ago and in point of fact
Respondent immediately ceased communications with the third party Patti Angelize the
minute she requested, so Respondent is well aware of his legal obligations in this
respect.

Moreover, Patti Angeliz and Kristina Robinson are completely untrustworthy and fabricate
lies: They publicly claim that Respondent and his Partner are not clients, apparently
forgetting that there is an E-Track Record that distinctly proves otherwise, with some of the
payment history and Ms. Robinsons own statement that we were indeed our kind of
clients.


And there it is, all paid up.

CONCLUSION

There is simply no credible threat involved here, and even if there were, it is not

directed at Complaining Party. As such, the purported threat should not even be considered
by the Court in its analysis.

Respectfully submitted,
/s/Christopher King
____________________________
Christopher King, J.D.

CERTIFICATE OF SERVICE

I, the undersigned, solemnly swear that a true and accurate copy of the foregoing
Motion in Limine was sent via tracked Priority U.S. Mail to Complaining Party
on _____ January 2017 at the following address:


Kristina M. Robinson
5808 218th Pl SW
Mountlake Terrace, WA 98403



_____________________________________
On behalf of:
Law Office of Scott Stafne
239 N. Olympic Ave.,
Arlington, WA 98223

Member of Washington Animal Rescue Resources

12:24PM

Hi Pattti... did Kristina adopt Nova from you? You know, the dog that killed Livi?
They accepted your request.

I have no idea which dog caused the fatal injuries amd will not speculate..... Nova was adopted from the
rescue as a puppy many years ago and in that time I have seen Nova interact here online thru pictures,
updates which would require from all adopters and at public events, like the anti vick rally with many other
dogs, cats and children and never once saw her display one drop of aggression. I do not know which dog
caused the Fatal injuries to yours and i am so sorry that it happened, but cannot speak of things i do not
know.

Understood. Kristina has publicly stated that Nova was the dog of hers that was clearly most damaged. Just
goes to show that's why you don't leave dogs alone, particularly bully breeds. As noted, we love all dogs
but extra care must be taken as a professional.

Well if Nova was most damage that would imply that she was a victim and not the aggressor
Nice try. It indicates that a weaker breed like Livi tried to save her life. Especially when Kristina admitted a
prior act of aggression.

Pardon me???? You obviously don't know dog behavior very well. When a fight ensues a pack mentality
happens and when more than one dog is involved many dogs can be injured.
What you just stated implies that Nova could have been a victim that your dog could have attacked her and
that the other dogs when after your dog to protect her.
I am not going to believe that an anxious hunting dog is submissive or weaker than any other dog. I have
been a vet tech for almost 20 years and have seen hunting dogs harm other dogs and humans just as easily.
Since none of us were there none of us can insinuate which dog started the fight. My dog was nearly killed
by a dog a quarter of her size. So nice try on your part.
Livi has no other acts of violence. I understand how packs work. I wish Kristina did or she would not have
left them alone. None of the other dogs were injured BTW. So according to your theory attacked Nova,
which is more conjecture than anything especially when we know from Kristina's own mouth that there
were PRIOR ACTS OF VIOLENCE. And you should have publicly acknowledged that Nova was your
rescue.

You know mr. King we have no idea what happened there your conjecture, my conjecture, it's all
conjecture. There was food involved in anything could have happened absolutely anything.
And why should she acknowledged which rescue she got Nova from have you publicly acknowledged
which rescue you got your dog from? No vote was a puppy Less Than 3 months old she has lived
peacefully in their home for many, many years
Nova*

What we do know however is that she left them ALONE and that Livi was not where she was supposed to
be. There's not need for me to acknowledge where we got Livi because it's irrelevant. Obviously we are
biased it's our dog, silly. But you hid your bias shame on you.

Just like it's irrelevant where she got Nova from. Nova was a puppy when she left our care and we have
followed her through the required updates that we ask all our doctors to do and never once has Nova been
involved in any other issues. If your dog attacked Nova first over this food that it would make sense that
her dogs would jump in to protect a member of their family.
It's not irrelevant to your bias. Have a nice day.
I'll make sure that city hall receives your thoughts on the matter.

My bias is towards the dogs and the dogs only. I prefer to wait for a judge and not City Hall.. if I am
subpoenaed then I will bring my thoughts to court gladly
Good. We look forward to you explaining why it's ok to leave dogs unattended and not do what was
promised in terms of daily exercise with a high-anxiety dog, and why it's ok not to tell clients that your
dogs have a prior violent history. Good Luck with that.

I never want implied it was okay to leave the dogs alone, so do not put words in my mouth. It can easily be
asked why you would leave a high-anxiety dog in a daycare. And not find someone privately to care for
them in your home
Livi is only high anxiety when not exercised as promised. We have had many other people watch her with
NO PROBLEM. Unfortunately we believed Kristina when she promised she was fully licensed and would
exercise Livi daily at the shop. Get it? Good.

You too have just admitted that you knew your dog was very anxious and high anxiety. I would never place
a dog with those kind of emotional issues in a daycare situation. The dog would only be with highly trained
private individuals or in a boarding facility where it did not have to interact with other animals.

And yes I get your opinion, do not be rude to me and speak to me like a human being an adult. I am not on
either side of this fence and only defending the dogs. To me you both are wrong and you both accept 50/50
responsibility for Livi's death. You know your dog has special requirements and you chose to not Place her
in a place with someone that had the certifications. It was your job to ensure the safety of your dog. If you
wanted to believe somebody without checking further into their qualifications then that is on you
I didn't admit any of that. She's a sporting breed who needs exercised. Top professionals in the city have
worked with her and pronounced her a kind soul with no documented issues of high anxiety or violence,
unlike Kristina's dogs. You are impliedly trying to blame Livi . And you can blame us for believing
Kristina's lies all you want to but it still doesn't make it right

I personally never leave my dogs with anybody that is not hoghly trained. In fact I had traveled around the
country with my dogs so there is no reason to have not taken them with you no matter what the excuse
Once and for all I am deeply sorry for the loss of your dog but this could have been prevented had you done
more homework and not placed her there in the first place.
Oh so now it's our fault for not taking our dogs with us. Wow. Livi has trained here and we will call them if
necessary. http://www.aocb.com/

It is 50-50 but you were never going to see that so there was nothing I can do to have you accept
responsibility. I am glad that your beloved companion was so easily replaced and I would hope that you
would move on

I don't know what you hope to accomplish with this, but I am sure that they will close down their business
if the judge instructs them to. But you handing them and coming after me is not helping the situation and
definitely does not make you look like the victim anymore. You are harassing me at this point and I feel
you need to stop
The only asshole bigger than the asshole who believes a lie is the asshole who tells it and runs an illegal
operation. Livi was not "easily replaced" but we have a beautiful new baby girl to ease the pain. Nothing
will replace Livi I've been around dogs 51 years and NEVER met a dog like her. We will move on healing
and move on legally on all fronts. You can count on that.

Ok I see your request now. Goodbye.

Are yoy calling me an asshole????

Nope.
Chat Conversation End


IN THE SNOHOMISH SOUTH DISTRICT COURT
LYNNWOOD, WASHINGTON


KRISTINA M. ROBINSON,

Complainant,








v.




CHRISTOPHER KING, J.D.



Respondent.

CASE No. STK17-0005

JUDGE __________________

ORDER GRANTING PLAINTIFFS MOTION IN LIMINE

This matter came before the Court pursuant to Respondents Motion in Limine
relative to a communication with a third party. The Court finds that the Motion is welltaken and hereby GRANTS the Motion in Limine. The purported threat shall not be
admitted to Court relative to the Complaining Partys allegations.

IT IS SO ORDERED THIS ____ Day of _____________, 2017

____________________________
JUDGE

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