By the way Counselors, it is called EXPEDITED DISCOVERY.

Obviously you feel some sense of urgency to address these matters or you would not be writing me at 10:28pm.

So this is why you shouldn't drag your feet or fail to respond to me when I ask you simple questions, i.e.

1) What day did Facebook notify the offending defamatory user account(s)?
2) What is wrong with providing me the information on Saturday, Sunday or Monday following the last due date of response, i.e. Friday, 23?
3) When will you provide me the User information given that you and your client are both already in possession of it for at least 21 days right?
4) Will you be available for a Meet and Confer on Monday, 26 August 2019 and if not what is your next available day, date and time to do so?

You and your client's niggardly responses in this regard I will not suffer gladly, and may I be so bold as to predict that Judge Orrick will not take too kindly to them either.

#clarity. Do with it what you wish. I look forward to hearing from you as contemplated by our emails Saturday night and this Sunday morning.

UNITED STATES DISTRICT FEDERAL COURT

FOR THE NORTHERN DISTRICT OF CALIFORNIA

CHRISTOPHER KING, JD ) CASE NO. 19-CV-1987

A/K/A KingCast,_
)
Plaintiff,
) JUDGE WILLIAM ORRICK
vs.
)
FACEBOOK, INC.,
)
Defendant.

AFFIDAVIT OF CHRISTOPHER KING, J.D.

IN SUPPORT OF HIS RULE 37 MOTION TO COMPEL

NOW COMES PLAINTIFF Being first duly sworn and subject to the Pains and Penalties of
Perjury to solemnly avers as follows:

1. I have had to inquire of Counsel for Defendant William Hicks 4-5 times over the Course
of 13 days to make him give me a simple date certain as to when his client notified one of
the offending, defamatory User Accounts of the Defamation claim against them;

2. Defense Counsel finally concurred with me on or about 23 August 2019 that the due date
for a Motion to Quash or Objection by the offending defamatory user account was indeed
naturally on a Friday (24 August 2019), thereby stretching the day date and time of
production to the next business day to Monday, 26 August 2019;

3. Defendant and Counsel have had Plaintiff’s Rule 26(f) Expedited Discovery since 28
May 2019 so the specific subject matter is nothing new to them here;

4. However, despite several emails commencing on or about 23 August 2019 asking for
specific timeframes I got nothing;

5. All of my girlfriends who received the defamatory comments contained in my Rule 26f
Discovery Requests are willing to testify against the defamatory agent(s);

6. My girlfriends who received the offending defamatory comments were all adversely
impacted by them even though we eventually worked through it and they ultimately agree
that the content regarding cheating, mental abuse, monetary abuse etc. is FALSE;

7. I have been suffering tangible harms from the malicious, false and defamatory comments
made on multiple occasions over the past 3-4 years and my mental health Counselors
during that period will all provide Expert Testimony relative thereto as previously noted
to Counsel for Defendant when I attempted to schedule a Management Conference
months ago;
8. My mental health Counselors will testify that I felt, and continue to feel slighted by the
type of abuse I have suffered on the Platform in general and in specific, as a black male,
when white people get compensated for single-episodes of Defamation, to wit:
Defamation on the platform is actionable. See generally Zerlie Charles v. Vickie D. Vest,
Indiana Ct. App. No. 72A01-1706-SC-01252 (October 24, 2017) and Dial v. Hammond
15-CV-05383 N. Carolina Buncombe Superior (2015). Case settled for $500,000.00.

9. This summary email reflects the content of the longer email excerpts below:

25 August 2019:

By the way Counselors, it is called EXPEDITED DISCOVERY. Obviously you feel some sense
of urgency to address these matters or you would not be writing me at 10:28pm.

So this is why you shouldn't drag your feet or fail to respond to me when I ask you simple
questions, i.e.

1) What day did Facebook notify the offending defamatory user account(s)?

2) What is wrong with providing me the information on Saturday, Sunday or Monday following
the last due date of response, i.e. Friday, 23?

3) When will you provide me the User information given that you and your client are both
already in possession of it for at least 21 days right?

4) Will you be available for a Meet and Confer on Monday, 26 August 2019 and if not what is
your next available day, date and time to do so?

You and your client's niggardly responses in this regard I will not suffer gladly, and may I be so
bold as to predict that Judge Orrick will not take too kindly to them either.

#clarity. Do with it what you wish. I look forward to hearing from you as contemplated by our
emails Saturday night and this Sunday morning.

10. Keker, Van Nest is a well-monied boutique law firm that prides itself as follows as noted
on their web page: https://www.keker.com/

We take the tough cases— The make or break cases where companies, careers,
and reputations are riding on the result. True to our roots as trial lawyers, we
relish the courtroom battles. Still, whether we go to trial, settle, or just make the
problem go away, what matters is obtaining the best result for our clients.

11. Plaintiff has won a few trials too – Civil Rights Trials – and is equally resolute and states
that Facebook is never going to “just make the problem go away,” because I will be on
them like white on rice until Justice is served. This is certainly a “tough case,” and I
believe this is why Counsel writes me back at 10:28pm at night on a Saturday night when
I am coincidentally out with one of the girlfriends I allegedly cheated on who is going to
be a material fact witness for me on this aspect of the Case.
12. This is a summary of relevant emails between Plaintiff and Counsel for Defendant, sent
to all four (4) of them at Keker, Van Nest who are opposing me in this case.

7 August
OK so the identified User has an active account?

On what day was Notice sent so I have my calendaring straight?

Thank you.
C

**********

8 August
Also, I had asked on what day was the Notice sent?

Thanks,
C
**********

9 August:

Dear Attorney Hicks:

OK so I remind you that I had asked what day the Notice was sent and I still need to know that. I
believe I am entitled to know that. Please advise if you disagree.

**********
9 August
I believe it was on or about August 2, but I’ll need to confirm.

*********

With all due respect y’all have now had thirteen (13) days to confirm even the notice on the one
account, not to mention the pending possibility of my filing a Motion to Compel on the others.

So I am going to ask you one last time before I approach the Court:
What day did Facebook send the notice and are you holding firm that Facebook cannot obtain the
information on the other two accounts?

Thank you.
C
 ***********
24 August

I suggest that you review the local rules and the Court's standing orders.

Best,
Bill

***********

Don’t you worry about that. I’ll be reviewing all of that first.

I suggest you and your client concern yourselves with producing what you owe me by Law.

Ciao.
C

So I hereby request a meet and confer on Monday. Right now I’m just showing you what is
coming down the pike so you are completely aware of what will happen as a professional
courtesy prior to such meeting.

If you cannot do Monday then I need to know your next available day date and time.
In the interest of complete clarity.
C

I told you a long time ago if your client can’t produce the data on Facebook User that I would put
them on blast for not having safety backup provisions so that is exactly what I am going to do.

You are bringing part of this on yourselves.

At this point you have no reason to fail to tell me at least when you will produce the User
Information for Lisa Marie but you have failed to do even that.

In case you forgot you made me ask 4-5 times for a date certain as to notification in the first place
don’t you dare try to bust my chops here Counselor I will clip your wings on this.

So when are we meeting and conferring.

Let’s stay clear. Or at least get clear despite your best attempts to avoid being so.

Ciao.
C

**********
25 August 2019

By the way Counselors, it is called EXPEDITED DISCOVERY. Obviously you feel some sense
of urgency to address these matters or you would not be writing me at 10:28pm.

So this is why you shouldn't drag your feet or fail to respond to me when I ask you simple
questions, i.e.
1) What day did Facebook notify the offending defamatory user account(s)?

2) What is wrong with providing me the information on Saturday, Sunday or Monday following
the last due date of response, i.e. Friday, 23?

3) When will you provide me the User information given that you and your client are both
already in possession of it for at least 21 days right?

4) Will you be available for a Meet and Confer on Monday, 26 August 2019 and if not what is
your next available day, date and time to do so?

You and your client's niggardly responses in this regard I will not suffer gladly, and may I be so
bold as to predict that Judge Orrick will not take too kindly to them either.

#clarity. Do with it what you wish. I look forward to hearing from you as contemplated by our
emails Saturday night and this Sunday morning.

FURTHER AFFIANT SAYETH NAUGHT

____________________________________
CHRISTOPHER KING, J.D.

STATE OF WASHINGTON

COUNTY OF KING

SWORN BEFORE ME THIS ____ DAY OF AUGUST, 2019

____________________________________
NOTARY PUBLIC
 UNITED STATES DISTRICT FEDERAL COURT
FOR THE NORTHERN DISTRICT OF CALIFORNIA

CHRISTOPHER KING, JD ) CASE NO. 19-CV-1987

A/K/A KingCast,_
)
Plaintiff,
) JUDGE WILLIAM ORRICK
vs.
)
FACEBOOK, INC.,
)
Defendant.

FRCP RULE 37 MOTION TO COMPEL MEMORANDUM IN SUPPORT

OF PLAINTIFF, CHRISTOPHER KING, J.D. A/KA/ KINGCAST

NOW COMES PLAINTIFF to file this Motion seeking full information on his Rule 26f
Expedited Discover Requests for user information regarding several Facebook user accounts that
have been being used to actively defame Plaintiff for years.
Sadly, it contemplates a history of Facebook abuse that goes back to the corporate
behemoth ignoring Plaintiff’s request for review on his last Facebook Jail term: They sat on it for
two solid weeks a few month ago, so by the time they did get to it most of Plaintiff’s 30-day
Facebook Jail sentence had expired!
In this case, at present time, Facebook – by and through Counsel for Facebook at Keker,
Van Nest – refused to provide a date Certain for two solid weeks when Plaintiff posed the simple
question as to what day, date and time Facebook gave Notice to the offending Defamatory agent
“Lisa Marie” after they pulled the user information as requested.
Even now, Counsel for Defendant has refused to tell Plaintiff when they will release the
Lisa Marie information even though it has been available for at least twenty-one (21) days:
Facebook finally admitted that they served a Notice of records subpoena to Lisa Marie
back on 2 August 2019
As we shall see by way of the accompanying Memorandum, there are ongoing issues
with respect to the other two Defamatory accounts “Troy Frasier” and “Facebook User” as well.
Be that as it may, the following email sent on 25 August, 2019 is a brief summary of the
agony that Plaintiff goes through trying to get a simple straight answer on these issues:
25 August 2019:

By the way Counselors, it is called EXPEDITED DISCOVERY. Obviously you feel some sense
of urgency to address these matters or you would not be writing me at 10:28pm.

So this is why you shouldn't drag your feet or fail to respond to me when I ask you simple
questions, i.e.

1) What day did Facebook notify the offending defamatory user account(s)?

2) What is wrong with providing me the information on Saturday, Sunday or Monday following
the last due date of response, i.e. Friday, 23?

3) When will you provide me the User information given that you and your client are both
already in possession of it for at least 21 days right?

4) Will you be available for a Meet and Confer on Monday, 26 August 2019 and if not what is
your next available day, date and time to do so?

You and your client's niggardly responses in this regard I will not suffer gladly, and may I be so
bold as to predict that Judge Orrick will not take too kindly to them either.

******
Please see the attached Memorandum and Rule 26(f) Discovery Requests as

Appendix A to this filing, all because Plaintiff dared to ask a few simple questions of
lawyers for the massive, and massively abusive corporate godhead.

Respectfully submitted,

_____________________
Christopher King, J.D.
 CERTIFICATE OF SERVICE

I the undersigned swear that a true and accurate copy of this Motion
was submitted to ECF
And was delivered via email to Counsel for Defendant at:

Keker Van Nest & Peters,

PAVEN MALHOTRA - # 258429

pmalhotra@keker.com

MATAN SHACHAM - # 262348

mshacham@keker.com

WILLIAM S. HICKS - # 256095

whicks@keker.com

this _______ Day of August 2019

_______________________________
CHRISTOPHER KING, J.D.
 UNITED STATES DISTRICT FEDERAL COURT
FOR THE NORTHERN DISTRICT OF CALIFORNIA

CHRISTOPHER KING, JD ) CASE NO. 19-CV-1987

A/K/A KingCast,_
)
Plaintiff,
) JUDGE WILLIAM ORRICK
vs.
)
FACEBOOK, INC.,
and )
DOES UNKNOWN,
)
Defendants.

MEMORANDUM IN SUPPORT OF FRCP RULE 37 MOTION TO COMPEL

OF PLAINTIFF, CHRISTOPHER KING, J.D. A/KA/ KINGCAST

I. Factual Backdrop.

On or about 23 May 2019 Plaintiff filed a Second Amended Complaint for the sole
specific reason that he needed to identify the holder of several user accounts to determine who
has been targeting him for years by issuing racially-tinged, defamatory diatribe to his girlfriends
on multiple occasions.1 As noted in the Complaint, then:

62. Defamation on the platform is actionable. See generally Zerlie Charles v. Vickie D. Vest,
Indiana Ct. App. No. 72A01-1706-SC-01252 (October 24, 2017) and Dial v. Hammond
15-CV-05383 N. Carolina Buncombe Superior (2015). Case settled for $500,000.00.
63. Plaintiff has notified Facebook Counsel that he will be filing a First Amended Complaint
Monday, 22 April 2019 and a Motion for Limited Injunctive Relief this week for
Defamation and Invasion of Privacy.
64. From Vest Plaintiff Counsel:
“I’m glad the Court of Appeals recognized that” and chose to reclassify its
memorandum decision as a published opinion, Spencer said in a phone interview.
While Spencer said he doesn’t use Facebook, he said he believes “defamations
occur on Facebook all the time.”

1
Plaintiff, on prior occasion, noted the USA today story that is referenced in the Oral Argument Transcript
at Docket ____. That story discusses issues of racism against blacks that Facebook Diversity Director Mark
Luckie said BEFORE HE RESIGNED, thus rendering them to be Party Admissions.

1
 He said he hopes the COA’s ruling and the subsequent award of damages in
Charles’ favor sends a message that “you can’t just say anything you want on
Facebook and get personal and make statements about other people that aren’t
true without running the possibility of getting sued. “A lay person probably feels
they have a First Amendment right to say whatever they want to, but that’s
definitely not the case if you’re harming people with what you’re saying,”
Spencer said. Even though the case was tried before a small claims court where
pleading standards are less stringent, Dattilo said he believes he had a winning
case in any forum. He said the circumstances of this case made small claims the
proper venue. “I still think the facts of this case could have held up anywhere,”
he said. “When you get a reversal and a remand for … a damages hearing,
you’ve got something on all fours. … You really appreciate having a fact pattern
like this that becomes precedent and will probably help the middle class
substantially.”

65. Coincidentally perhaps, prior to the dawn of the Internet, Plaintiff wrote for the
Indianapolis Star immediately prior to admission to, and graduation from, a then top-50
law school, i.e. Case Western Reserve University, where he earned an "A" in
Constitutional Law when he studied, under, and clerked for, one Professor Edward
Mearns, (RIPower)
66. In spite of all of this, Defendant allowed Defamatory remarks to be published to
Plaintiff’s last girlfriend “MH” in 2018 without recourse from Facebook User “Troy.”
When Plaintiff asked Defendant for the identity of the poster Facebook directed the
attention away to Plaintiff’s girlfriend.
67. In 2019 Defendant and Counsel in this case again allowed such Defamatory remarks to
be leveled against Plaintiff towards his current girlfriend “SW” by two Facebook
accounts “Facebook User” and “Lisa Marie”2

2
Plaintiff has since discovered that his girlfriend “MM” -- prior to “MH” – received similar
correspondence, however she had deleted it not knowing it would be an ongoing pattern of abuse, Internet
bullying, stalking and Invasion of Privacy. She will testify to it if necessary.

2
68. The comments in 2018 and in 2019 all indicate, with certainty devoid of any speculation,
that Plaintiff “cheats on all of his women” and "Every single woman that he as dated he
has used and mentally abused."…. and goes on to state that Plaintiff seeks out white
women as gullible, to use for money etc. etc. ad nauseam, basically every negative racist
stereotype of black men in this Fine Country. (See Appendix D).
69. Plaintiff and “SW” attempted to exhaust all administrative appeals within the Platform
structure and Facebook continued to ignore Plaintiff’s Defamation issue and offered a
link for “SW” to use that was, and is, nonfunctional.
70. As such, Plaintiff responded:
You are playing stupid.

Again: I have a VALID CLAIM FOR DEFAMATION ON MY OWN. So you need to

give me that goddamn information right now.

Further: As I told you, the offending Party -- who will be sued -- removed the content so
it is no longer available [to my girlfriend to follow their instructions]

And the link that you just sent me it not available, see attached.
https://www.facebook.com/help/contact/597132477126770/?ref=cr

So really there is no channel for either my past or current girlfriend to complain anyway.
Please advise. And I have sent this content directly to your lawyers too.

71. Plaintiff notified Counsel for Facebook thusly, and received no response so he wrote FB
Counsel:

72. 18 April 2019

Re: Ongoing Issues of Defamation on the Facebook “Platform.”

Vis a vis Christopher King A/K/A KingCast v. Facebook, Inc. 19-CV-1987

Dear Attorneys Hicks and Thole:

For reasons noted in today’s communication with the Facebook “Help Desk” I will be
adding this information to the pending Federal Complaint against your client, who
previously IGNORED my concerns about the exact same sort of Defamation last year.

This year [I] can promise you that any and all of the last three (3) girlfriends in my life
who were allegedly warned about me by this poster will come forward to state that they
were alarmed by this Defamatory Rhetoric and that it did initially have the intended
impact:

3
 It made them leery of me and more accurately feeling vulnerable for prior breaches of
trust by OTHER MEN for periods of time ranging from weeks to days to hours.

The Rhetoric employed continually references my purportedly predatory acts toward

white women, so that is completely racist as well as Defamatory. If you do not deliver to
me by Close of Business tomorrow 19 April, 2019 a promise to divulge the identifying
information on the perpetrators by month’s end I will be folding this matter into the Case
at Bar and moving for immediate Injunctive Relief.

No one should have to live under this type of racist, defamatory abuse and I will not…
nor will any of my past girlfriends or present girlfriend It’s complete shit. In fact, she
will send a complaint to Facebook within the next 24 hours and will reply on this email
chain immediately to confirm her complete agreement that she is harassed and finds the
communication to be Defamatory towards me. And you will note that I am not holding
your client responsible for the Defamation as that would of course be outside the purview
of 47 USC §230, unlike my pending Claims in the case.

Now that I have made myself clear, I look forward to hearing from you in the next 24
hours.

Very Truly Yours,

__________________________
Christopher King, J.D.

73. Defendant Counsel has now agreed to Permissive Joinder to allow Plaintiff to pursue his
Defamation Claims within this litigation while clearly delineating any potential liability for such
claims lies with Defendant(s) Doe.

4
II. The Value of this Claim Cannot be Underestimated.
Plaintiff has written Davyne Dial about this matter. And who is Davyne Dial? From Plaintiff’s
Blogs:
https://howtosuefacebook.blogspot.com/2019/08/facebook-lawyers-at-keker-van-nest.html

Thursday, August 22, 2019

Facebook Lawyers at Keker Van Nest Cannot Answer a Simple Question on Defamation
Abusers.

http://christopher-king.blogspot.com/2019/08/facebook-lawyers-at-keker-van-nest.html
22 August 2019
Facebook Lawyers at Keker Van Nest Cannot Answer a Simple Question on Defamation

Abusers.

5
 Davyne Dial3 is another victim of Defamation on the Facebook platform who needs to
know this. Ms. Dial -- general manager of VPVM 103.7 Asheville -- was awarded $.5M
for a single episode of Defamation on the Platform. She now needs to know about how
Keker, Van Nest can't even answer simple questions for 13 days running about the
Defamation I sustained over the course of YEARS.... ....and further:

Despite knowing the gravity of this situation and the impact it has had on Plaintiff over
the course of YEARS with ALL of his recent girlfriends, it took Defendant thirteen (13) days to
answer a simple question:
When did you notify the User Account to commence the twenty-one (21) day
Notice Requirement? Let’s review the email chain with multiple, repeated reasonable attempts
by Plaintiff to discover some modicum of Truth shall we? From Plaintiff’s blog:

That's enough bullshit in and of itself, but then to have the same lawyers who couldn't give me an
answer as to the date of notification then fail to promise me the information by Monday after I
asked them what the holdup is, constitutes bullshit on top of bullshit and I am not going to stand
for it. If I don't have my information by Monday close of business I will serve them a Motion to
Compel and have them in front of Judge Orrick so fast it will make their heads spin.
**********
Counselors:

Tuesday morning 20 August at 9:10 a.m. I asked you a simple question:

Also,

It is no secret that I feel getting information from you client regarding my defamer(s) has been
tantamount to drawing blood from a stone.

Wherefore, let's get a few things straight:

1. Did your client send out information to the defamer Lisa Marie on 2 August, 2019 as indicated
by Attorney HICKS and if so can we agree then that the time for production of User Information
(or a Motion to Quash, etc) would be no later than Friday, 23 August as the expiration of the 21st
day?

2. Does your client maintain its position that it cannot or will not locate information on
"Facebook User" or "Troy Frasier?"

That is all for now.

3
Ms. Dial is a female, white.

6
………. I asked this in light of what my app developer shared with me. Again to be crystal clear
what he said:

“That’s bullshit. If you delete an account they can go right back and activate it. That’s because
they keep records.”

“They can identify any of their users from their IP Addresses. Even if the abuser bought a VPN
they could probably track it.”

I then corrected a name typo yesterday (HICKS) as noted above.

Guys: There are three of you working the Federal Case at Keker. Surely one of you has some
answers for me given that tomorrow appears to be the deadline on the Lisa Marie issue, and I say
appears to be because the firmest answer I have received on the matter from Attorney Hicks
despite numerous inquiry was

“….on or about August 2.”

Please allow me to run through the timeline on this for absolute clarity:

7
6 August
G'Day Counselor,

I would appreciate an update sometime this week as to:

*Notification of the first ass-clown.

*Identification of the second ass-clown.

Thank you in advance,

**********

8
7 August
OK so the identified User has an active account?
On what day was Notice sent so I have my calendaring straight?

Thank you.
C
**********

8 August
Also, I had asked on what day was the Notice sent?

Thanks,
C
**********

9 August:

Dear Attorney Hicks:

OK so I remind you that I had asked what day the Notice was sent and I still need to know that. I
believe I am entitled to know that. Please advise if you disagree.

**********
9 August
I believe it was on or about August 2, but I’ll need to confirm.

**********

With all due respect y’all have now had thirteen (13) days to confirm even the notice on the one
account, not to mention the pending possibility of my filing a Motion to Compel on the others.

So I am going to ask you one last time before I approach the Court:
What day did Facebook send the notice and are you holding firm that Facebook cannot obtain the
information on the other two accounts?

Thank you.
C

9
Notice was provided to the account associated with Lisa Marie on August 2. Absent an objection
from the user, Facebook will promptly produce the available BSI. I do not anticipate making a
production tomorrow, which is the last day of the notice period.

As to the other accounts, I do not know how I could be more clear. As I’ve said multiple times,
Facebook was unable to identify a user account associated with the display name “Facebook
User.” The third account was deleted by the user; therefore, there is no BSI to produce for that
account.

****************************

Sue Facebook <suefacebook007@gmail.com>

9:49 AM (3 minutes ago)
to William, Gavin, Matan, Paven

I am going to return your clarity with more of my own then.

1. Since you have finally confirmed 2 August as notification day then what is the holdup getting
that information to me immediately and when exactly do you intend to get it to me?

If tomorrow is the last day of the notification period then what’s wrong with Saturday, Sunday or
Monday?

2. I will get back to you on any potential Motion on receipt of the User information.

C
So at this point, then, Plaintiff noted on 22 August, 2019:
I mean, you know one would logically think you would want to get that much off of your plate as
soon as possible, right?

C
******
Again,
Your client had the same set of information for "facebook user" as for "Lisa Marie" as noted in
the attached Rule 26(f) Discovery request.

10
C
*******

OK so when you hit the door later this morning you best know my full intentions here:

This is serious shit guys. If you continue to treat it as if it is not you will wind up defending a
Motion come Monday night.

That is my contribution to our ongoing resolution of clarity.

https://howtosuefacebook.blogspot.com/2019/08/facebook-lawyers-at-keker-van-nest.html

C
********

Your client is in such a hurry to shut down my speech that is not even in violation of ToS but yet
y'all want to take your own sweet time getting information to me about someone who is actually
putting out Defamatory posts that *ARE* in violation of ToS. You should have already agreed to
production on Monday. The information is already gathered and all you have to do is hit the
keyboard.
https://howtosuefacebook.blogspot.com/2019/08/facebook-lawyers-at-keker-van-nest.html

It sucks to be an activist nigger on your client's platform.

Got me?

Good.

Now get me my documents by Monday or I will file.

Defendant failed to produce the documents on Monday, 26 August 2019.

11
III. Law and Argument.

The Court will grant a Motion to Compel if and when abuses occur. As noted in
Plaintiff’s Post-Hearing Memorandum of Newly-Discovered Law, this very Bench issued a
Decision in Wadler et al v. Custard Insurance Adjusters, Inc, 17-CV-05840 (11 April 2018), Fees
awarded five (5) days after Oral Argument in the case at bar, or 22 July 2019. The case involved
clickwrap or adhesion-clause abuse in an unequal arms-length situation. Mark Zuckerberg alone
is worth $85B. Plaintiff is worth approximately $30,000.00 at the moment, or .0000003529% of
that. From Wadler:
Procedural unconscionability occurs where a contract or clause involves oppression,
consisting of a lack of negotiation and meaningful choice, or surprise, such as where the
term at issue is hidden within a wordy document. Id. “California law treats contracts of
adhesion, or at least terms over which a party of lesser bargaining power had no
opportunity to negotiate, as procedurally unconscionable to at least some degree.” Bridge
Fund Capital Corp. v. Fastbucks Franchise Corp., 622 F.3d 996, 1004 (9th Cir. 2010).

Substantive unconscionability occurs where the provision at issue “reallocates risks in an

objectively unreasonable or unexpected manner.” Lhotka, 181 Cal. App. 4th at 821
(citation omitted). “Substantive unconscionability focuses on the one-sidedness or overly
harsh effect of the contract term or clause.” Id. at 824–25 (citation omitted).

This is crucial to the case at Bar because His Honor inquired of Plaintiff in the closing moments
of the Argument whether he could couch his arguments in a manner that would cut against rote
application of 47 §USC 230(1):

IV. Demands.
Defendant must be ORDERED to provide the user information for “Troy Frasier” as the
Defendant cannot provide any distinguishing rationale as to how it can provide the user
information for “Lisa Marie” but not for “Troy Frasier” when Plaintiff provided them the same
data inputs and facts and timeframe information. Defendant must then further provide the Court
a detailed Affidavit as to Best Practices and Good Faith Due Diligence on the matter,
Defendant must be ORDERED to provide the user information for “Facebook User” as
well, because Defendant had all of the same information as in the other two examples. In the
event the Defendant maintains that it cannot find any information they must then provide the
Court a detailed Affidavit as to Best Practices and Good Faith Due Diligence on the matter, and
admit to the Court, to the FCC and to the entire Free World that anybody can open a Facebook
account, defame someone, shut down their account and walk away without a trace or any
accountability whatsoever.

12
Respectfully submitted,

_____________________
Christopher King, J.D.

CERTIFICATE OF SERVICE

I the undersigned swear that a true and accurate copy of this Update
was submitted to ECF
And was delivered via email to Counsel for Defendant at:

Keker Van Nest & Peters,

PAVEN MALHOTRA - # 258429

pmalhotra@keker.com

MATAN SHACHAM - # 262348

mshacham@keker.com

WILLIAM S. HICKS - # 256095

whicks@keker.com

this _______ Day of August 2019

_______________________________
CHRISTOPHER KING, J.D.

13
 UNITED STATES DISTRICT FEDERAL COURT
FOR THE NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO DIVISION

CHRISTOPHER KING, JD ) CASE NO. 19-CV-1987

A/K/A KingCast,
)
Plaintiff,
)
vs.
) JUDGE WILLIAM H. ORRICK
FACEBOOK, INC.,
)
Defendant.

PLAINTIFF RULE 26(d)(1) LIMITED EXPEDITED DISCOVERY

REQUEST FOR PRODUCTION OF DOCUMENTS

THE FOLLOWING DOCUMENT REQUEST CONCERNS THE FOLLOWING

PASSAGE FROM PLAINTIFF’S FIRST AMENDED COMPLAINT AND HIS
NOW WITHDRAWN MOTION FOR INJUNCTIVE RELIEF

65. In spite of all of this, Defendant allowed Defamatory remarks to be published to

Plaintiff’s last girlfriend “MH” in 2018 without recourse from Facebook User “Troy
Frasier.” When Plaintiff asked Defendant for the identity of the poster Facebook directed
the attention away to Plaintiff’s girlfriend.
https://www.facebook.com/maggie.henehan.12

66. In 2019 Defendant and Counsel in this case again allowed such Defamatory remarks to
be leveled against Plaintiff towards his current girlfriend “SW” by two Facebook
accounts “Facebook User” and “Lisa Marie”1
https://www.facebook.com/shae.watson.75

67. The comments in 2018 and in 2019 all indicate, with certainty devoid of any speculation,
that Plaintiff “cheats on all of his women” and "Every single woman that he as dated he
has used and mentally abused."…. and goes on to state that Plaintiff seeks out white
women as gullible, to use for money etc. etc. ad nauseam, basically every negative racist
stereotype of black men in this Fine Country. (See Appendix A).

1
Plaintiff has since discovered that his girlfriend “MM” -- prior to “MH” – received similar
correspondence, however she had deleted it not knowing it would be an ongoing pattern of abuse, Internet
bullying, stalking and Invasion of Privacy. She will testify to it if necessary.
TO EACH NAMED DEFENDANT: Please respond within the time allotted by Rule.
Pursuant to 18 USC § 2703(c), provide a copy of the information files on Facebook User
Accounts of:

a. Troy Frasier.
b. Facebook User.
c. Lisa Marie.

This includes,

(A) name;

(B) address;

(C) local and long distance telephone connection records, or records of session times and
durations;

(D) length of service (including start date) and types of service utilized;

(E) telephone or instrument number or other subscriber number or identity, including any
temporarily assigned network address; and

(F) means and source of payment for such service (including any credit card or bank account
number),

Applicable time period for “Troy Frazier.”

Please note further the relevant time periods for the Defamatory actions from “Troy” would be in
the neighborhood of 1 August, 2018 to 18 September, 2018 as noted in prior correspondence
between Plaintiff and Defendant Facebook.
https://www.facebook.com/maggie.henehan.12

Applicable time period for “Facebook User” and “Lisa Marie.”

Please note further the relevant time periods for the Defamatory actions from “Facebook User”
would be approximately 5 March 2019 and “Lisa Marie” approximately 17 April, 2019.
https://www.facebook.com/shae.watson.75

Response:
SUBMITTING PARTY’S CERTIFICATION

The undersigned pro se plaintiff, or attorney for the plaintiff, certifies that these

document requests are appropriate to the facts of this case

nd
Dated this 22
23rd day of May 2019

Christopher King, J.D.

Plaintiff

Address: 12048 Greenwood Avenue N.

Seattle, WA 98133

Respectfully submitted,

___________________________________________
Christopher King, J.D.
 CERTIFICATE OF SERVICE

I the undersigned, solemnly swear that a true and accurate copy of the foregoing
Document Request was served via email to:

Keker, Van Nest & Peters LLP

633 Battery Street
San Francisco, CA 94111-1809

William Hicks, Esq.

whicks@keker.com

Gavin Thole, Esq.

gthole@keker.com

This 23rd
22nd day of May, 2019.

And via Tracked Priority US Mail the 23rd day of May, 2019.

_____________________________
CHRISTOPHER KING, J.D.
APPENDIX A