Chief
Civil Judge James Doerty
ROGER W. KNIGHT, )
) No.
plaintiff, )
) MOTION FOR ORDER TO SHOW
v. ) CAUSE WHY STATUTORY WRIT
) OF PROHIBITION SHOULD NOT BE
STATE OF
ROYANNE M. SCHMITZ, NORM )
MALENG, King County Prosecutor, )
KATHLEEN ANN O’BRIEN, Chief of )
Family Support Division of
Prosecutor,
LLOYD PATRICK CORGAN, )
Deputy Prosecuting Attorney, and )
Deputy Prosecuting Attorney, )
)
defendants. )
____________________________________)
MOTION AND
RELIEF REQUESTED
Comes
now ROGER W. KNIGHT, plaintiff, to move for a an order to show cause why a Statutory
Writ of Prohibition, Chapter 7.16 RCW should not be granted for want of in
personam jurisdiction as requested in the
Application for Statutory Writ of
Prohibition, Chapter 7.16 RCW (Application) and for want of an impartial
tribunal not prejudiced by plaintiff’s exercise of his free speech rights, due
process rights, and his previous success in fending off contempt proceedings.
EVIDENCE
AND FACTS IN SUPPORT OF MOTION
Plaintiff
hereby incorporates herein by reference the Introduction and Facts on page 2 of
the Application. These facts are set
forth in the Declaration of Roger W. Knight in Support of Application for
Statutory Writ of Prohibition,
Chapter 7.16 RCW (Knight Declaration I) and its
attached Exhibits. Attached as Exhibit A
to the Supplemental Declaration of Roger W. Knight in Support of Application for
Statutory Writ of Prohibition (Knight Declaration II) is a package of materials
mailed by Deputy Prosecuting Attorney Jacqueline L. Jeske to
John R. Scannell
on or about
Mr.
Bradford confirms the facts set forth in Knight Declaration I, that he was
served in the King County Courthouse when he was required to attend a hearing
in a criminal case to avoid a criminal warrant for his arrest.
Mr.
John Scannell was under strict instructions not to waive service. Because the Application was filed and served,
and because Mr. Scannell appeared on Mr. Knight’s behalf at the hearing
scheduled for May 12, 2004 and informed everyone present of the Application and
that he and his client are challenging service, he obtained a continuance of
the matter and avoided an arrest warrant.
These facts are set forth in the Declaration of
John R. Scannell.
An
attorney’s objectives appropriately include keeping his client out of jail.
Subsequent
to these events, Mr. Scannell received the documents that are attached as
Exhibits A and B to
Knight Declaration II.
As set forth in that Declaration and evidenced by these Exhibits, the
prosecution has changed its approach from Track A to Track B subsequent to May
12, 2004, motivated by Mr. Knight’s bringing the
Application in this case
asserting improper service, and motivated by Mr.
Scannell’s previous success in
obtaining dismissal of a contempt action on the basis of improper service,
Mr.
Knight’s challenge to the validity of the driver’s license suspension for child
support in civil proceedings in this Court and the
Court of Appeals, his
previous exercise of his right to due process of law pursuant to and within
procedure, venue, and jurisdiction statutes and rules of court, and his ongoing
exercise of free speech rights protected by
Article I Section 5 of the
Washington Constitution and the
First Amendment in a public forum,
specifically, the Internet.
Deputy
Prosecutor Jeske is now asking for a bench warrant if Mr. Knight does not
appear at the hearing scheduled for
LEGAL AUTHORITY
STATUTORY WRIT IS THE APPROPRIATE REMEDY
For
the claim that a court lacks in personam jurisdiction due to improper service
and that service upon a person required to attend a criminal hearing while at
the courthouse to attend such hearing is improper service, the plaintiff
incorporates herein by reference the arguments set forth on pages 3-8 of the
Application.
It
follows that where a court is incompetent by reason of bias or personal
interest, including where the prosecution poisoned the well by bringing in irrelevant
materials and asking the court to deal harshly based on such materials, that a
statutory writ of prohibition is the appropriate remedy. In the case of a state tribunal incompetent
by reason of bias,
Gibson
v. Berryhill, (1973)
411
Unlike those situations
where a federal court merely abstains from decision on federal questions until
the resolution of underlying or related state law issues - a subject we shall
consider shortly in the context of the present case -
Younger v. Harris
contemplates the outright dismissal of the federal suit, and the presentation
of all claims, both state and federal, to the state courts. Such a course
naturally presupposes the opportunity to raise and have timely decided by a
competent state tribunal the federal issues involved. Here the predicate for a
Younger
v. Harris dismissal was lacking, for the appellees alleged, and the
District Court concluded, that the State Board of Optometry was incompetent by
reason of bias to adjudicate the issues pending before it. If the District
Court's conclusion was correct in this regard, it was also correct that it need
not defer to the Board.
And thereby created an exception to the abstention
doctrine set forth in
Younger
v. Harris, (1971)
401
MR. KNIGHT CANNOT OBTAIN A
FAIR HEARING BEFORE AN IMPARTIAL JUDICIAL OFFICER IN CONTEMPT ACTION AS A
RESULT OF PROSECUTION’S ACTIONS AND REVEALED MOTIVATIONS AND FOR OTHER REASONS
The
purpose of a contempt proceeding under
chapter 7.21 RCW is to enforce a court
order and to provide an opportunity to an alleged contemnor to provide facts
and argument that such remedy is unnecessary, unwarranted by law,
unconstitutional, or otherwise invalid.
This is the purpose in the case of a child support contempt hearing
under this chapter as well as under
chapter 26.18 RCW.
It is
NOT the purpose of contempt
proceedings to punish the alleged contemnor for activities unrelated to the
court order. It is EXTREMELY IMPROPER to use contempt proceedings to punish a person
subject to a court order for exercising his right to free speech in a public
forum and for exercising his right to due process of law within and pursuant to
procedure, venue, and jurisdiction statutes and rules of court. This is most particularly true if the court
order never prohibited any speech by the party that is otherwise
constitutionally protected. That is the
case here, Mr. Knight’s speech has never been restricted by any court order in
King County
The
rights to free speech and freedom of the press set forth in the
First Amendment
are incorporated upon the states through substantive due process guaranteed by
the
Fourteenth Amendment:
Gitlow v. New
York, (1925) 268 U.S. 652, 663, 69 L. Ed. 1138, 45
Wood v.
Bassett vacated an order restricting the
speech of attorneys representing a criminal defendant awaiting trial on the
grounds that the trial court failed to explore alternative remedies and was not
narrowly tailored to serve the interest of a defendant’s right to a fair trial
and to serve the fair administration of justice. Such concerns, of course, cannot be served
where a prosecution for contempt seeks to punish the allege contemnor for
speech that has never been restricted by a court order.
Gentile struck down a Bar Rule that
imposed a blanket speech restriction on all attorneys practicing in
Wood is a decision most relevant to this
case, in that it involves the committing of a person to jail under a court’s
contempt powers for an out of court utterance.
Wood, at 370
We start with the premise that the
right of courts to conduct their business in an untrammeled way lies at the
foundation of our system of government and that courts necessarily must possess
the means of punishing for contempt when conduct tends directly to prevent the
discharge of their functions. While courts have continuously had the authority
and power to maintain order in their courtrooms and to assure litigants a fair
trial, the exercise of that bare contempt power is not what is questioned in
this case. Here it is asserted that the exercise of the contempt power, to
commit a person to jail for an utterance out of the presence of the court, has
abridged the accused's liberty of free expression. In this situation the burden
upon this Court is to define the limitations upon the contempt power according
to the terms of the Federal Constitution.
In
Bridges v.
California, 314 U.S. 252, 86 L. Ed. 192, 62 S. Ct. 190,
this Court for the
first time had occasion to review a State's exercise of the contempt power
utilized to punish the publisher of an out-of-court statement. The accused
contended that the exercise abridged his right of free speech guaranteed
against state infringement by the
Fourteenth Amendment. To determine the scope of this constitutional
protection, the Court reviewed the history of the contempt power, both in
Thus, if Mr. Knight, in a public forum outside of any
courtroom, makes statements critical of the Child Support Crusade, no sanction
is permissible for such speech, unless there is imminent danger. An example of an imminent danger would be an
"angry mob with pitchforks" ready to tear down the courthouse doors
and lynch the personnel within. A
peaceful protest demonstration or a protester in a costume hanging on a crane
would not constitute such an imminent danger.
Mr. Knight does not advocate a violent solution to the problem, but he
will support peaceful demonstrations.
Wood, at 370
It is with these principles in mind that we consider the
case before us. Initially, however, it should be noted that the
This case differs from
Bridges and
Pennekamp,
first, in that the court below has upheld petitioner's conviction on the basis
that his conduct presented a clear and present danger to the proceedings of the
court and grand jury, a standard this Court has held to warrant punishment for
alleged contemptuous conduct. But state
courts may not preclude us from our responsibility to examine "the
evidence to see whether it furnishes a rational basis for the characterization
put on it" (In re Sawyer, 360
Despite its conclusion that the petitioner's conduct
created a serious evil to the fair administration of justice, the
Court of
Appeals did not cite or discuss the
Bridges,
Pennekamp or
Harney cases, nor
did it display an awareness of the standards enunciated in those cases to
support a finding of clear and present danger. It simply adopted as conclusions of law the
allegations made in the contempt citation. The court did not indicate in any manner how
the publications interfered with the grand jury's investigation, or with the
administration of justice. Unlike those cases in which elaborate findings have
been made to support such a conclusion, this record is barren of such findings.
The prosecution called no witnesses to show that the functioning of the jury
was in any way disturbed; no showing was made that the members of the grand
jury, upon reading the petitioner's comments in the newspapers, felt unable or
unwilling to complete their assigned task because petitioner
"interfered" with its completion. There is nothing in the record to indicate
that the investigation was not ultimately successful or, if it was not, that
the petitioner's conduct was responsible for its failure. And to the extent
that the conviction on the third count was upheld because petitioner's last
statement presented a clear and present danger to the contempt hearing, it is
indeed novel that under the circumstances of this case the petitioner might be
responsible for a substantial interference with his contempt hearing because he
had made public his defense to the charges made against him. What interference
to petitioner's hearing or what harm this assertion might inflict on the
administration of justice is not stated in the opinion. Nor is there any evidence of either in the
record.
Deputy Prosecutor Jeske
likewise does not offer any evidence that publishing a web site critical of the
Child Support Crusade and making public defenses that Mr. Knight has or may
present to the courts and administrative agencies somehow interferes with the
proceedings. Exhibit B to
Knight
Declaration II, State's Reply. After
all, if no one logs on to the web site, it is the tree that falls in the forest
that nobody hears.
Wood, at 370
Thus we have simply been told, as a matter of law without
factual support, that if a State is unable to punish persons for expressing
their views on matters of great public importance when those matters are being
considered in an investigation by the grand jury, a clear and present danger to
the administration of justice will be created. We find no such danger in the
record before us. The type of "danger" evidenced by the record is
precisely one of the types of activity envisioned by the Founders in presenting
the
First Amendment for ratification. "Those who won our independence had
confidence in the power of free and fearless reasoning and communication of
ideas to discover and spread political . . . truth."
Thornhill v.
"to supply the public
need for information and education with respect to the significant issues of
the times. [Footnote omitted.] . . . Freedom of discussion, if it would fulfill
its historic function in this nation, must embrace all issues about which
information is needed or appropriate to enable the members of society to cope
with the exigencies of their period."
Men are entitled to speak as
they please on matters vital to them; errors in judgment or unsubstantiated
opinions may be exposed, of course, but not through punishment for contempt for
the expression. Under our system of government, counterargument and education
are the weapons available to expose these matters, not abridgment of the rights
of free speech and assembly. Cf. Mr. Justice Brandeis, concurring in
Whitney v. California, 274
Child support and the
enforcement of child support is most certainly "a significant issue of the
times". That the prosecution is
attempting to imprison Mr. Knight for failure to pay the amount of child
support demanded, and that the State has suspended his driver's license for
such failure, clearly makes this an issue vital to Mr. Knight. He certainly is entitled to speak as he
pleases on this matter. He chooses
counterargument and education as the weapons to expose these matters. As this State's courts have repeatedly
declared imprisonment for child support to be an exception to the prohibition
of imprisonment for debt set forth in
Article I Section 17,
Article I Section 5
protects Mr. Knight's assertions against the wisdom of such policy and his
right to attempt to persuade the public to cease its tolerance of such
exception to
Article I Section 17.
Wood, at 370
The administration of the law is not the problem of the
judge or prosecuting attorney alone, but necessitates the active cooperation of
an enlightened public. Nothing is to be gained by an attitude on the part of
the citizenry of civic irresponsibility and apathy in voicing their sentiments
on community problems. The petitioner's attack on the charge to the grand jury
would have been likely to have an impeding influence on the outcome of the
investigation only if the charge was so manifestly unjust that it could not
stand inspection. In this sense
discussion serves as a corrective force to political, economic and other
influences which are inevitably present in matters of grave importance. The
charge given to the jury indicated that the motivation for it was founded on
rumor, but that the situation had existed for several years. Yet the charge was
directed primarily against one group in the community and was given at the
height of the highly important Democratic primary, in which, because of their
elected positions, both the judges and the petitioner were interested
personally and apart from their official status. The
First Amendment envisions
that persons be given the opportunity to inform the community of both sides of
the issue under such circumstances. That this privilege should not lightly be
curtailed is ably expressed in a passage from Judge Cooley's 2 Constitutional
Limitations (8th ed. 1927) 885, where he stated that the purpose of the
First
Amendment includes the need:
". . . to protect
parties in the free publication of matters of public concern, to secure their
right to a free discussion of public events and public measures, and to enable
every citizen at any time to bring the government and any person in authority
to the bar of public opinion by any just criticism upon their conduct in the
exercise of the authority which the people have conferred upon them."
Moreover, it is difficult to imagine how the voting
problem may be alleviated by an abridgment of talk and comment regarding its
solution. This problem is important not only to an individual or some isolated
group or to individual litigants in a particular lawsuit, but affects the
entire Nation. When the grand jury is performing its investigatory function
into a general problem area, without specific regard to indicting a particular
individual, society's interest is best served by a thorough and extensive
investigation, and a greater degree of disinterestedness and impartiality is
assured by allowing free expression of contrary opinion. Consistent suppression
of discussion likely to affect pending investigations would mean that some
continuing public grievances could never be discussed at all, or at least not
at the moment when public discussion is most needed. The conviction here
produces its "restrictive results at the precise time when public interest
in the matters discussed would naturally be at its height," and "[n]o
suggestion can be found in the Constitution that the freedom there guaranteed
for speech and the press bears an inverse ratio to the timeliness and
importance of the ideas seeking expression."
Bridges v.
. . .
Our examination of the content of petitioner's statements
and the circumstances under which they were published leads us to conclude that
they did not present a danger to the administration of justice that should
vitiate his freedom to express his opinions in the manner chosen.
The
prosecution in the contempt action at issue specifically cites Mr. Knight's web
sites. In the Exhibit 7 to the State's
Response, Exhibit B to
Knight Declaration II, the state includes posters
advertising the URL of one of the web sites:
www.antipeonage.0catch.com.
The
Internet is a public forum where speech is protected by the
First Amendment on
the basis that it is a public forum.
Reno v. ACLU, (1997) 521
Finally, unlike the conditions that prevailed when Congress
first authorized regulation of the broadcast spectrum, the Internet can hardly
be considered a "scarce" expressive commodity. It provides relatively
unlimited, low cost capacity for communication of all kinds. The Government
estimates that "[a]s many as 40 million people use the Internet today, and
that figure is expected to grow to 200 million by 1999." This
dynamic, multifaceted category of communication includes not only traditional
print and news services, but also audio, video, and still images, as well as
interactive, real time dialogue. Through the use of chat rooms, any person with
a phone line can become a town crier with a voice that resonates farther than
it could from any soapbox. Through the use of Web pages, mail exploders, and
newsgroups, the same individual can become a pamphleteer. As the
District Court
found, "the content on the Internet is as diverse as human thought." .
. . We agree with its conclusion that our cases provide no basis for qualifying
the level of
First Amendment scrutiny that should be applied to this medium.
Mighty
Movers, supra, at 112
The amount of government regulation
of speech allowed by the federal and state constitutions depends, in part, on
the location and the method used for communicating. The government's ability to
regulate speech in a public forum is much more restricted. The test, however,
for regulating speech in a nonpublic forum is less
stringent. "The Government's decision to restrict access to a nonpublic
forum need only be reasonable; it need not be the most reasonable or the only
reasonable limitation."
Cornelius v. NAACP Legal Defense & Educ.
Fund, Inc., 473
Public forums are (1) those places
which "by long tradition or by government fiat have been devoted to
assembly and debate," . . . or (2) channels of communication used by the
public at large for assembly and speech, used by certain speakers, or the
discussion of certain topics.
City of Seattle v. Huff, 111 Wn.2d 923,
927, 767 P.2d 572 (1989) (quoting
Perry Educ. Ass'n v. Perry Local
Educators' Ass'n, 460
There is no question and can be no question that the
Internet is a "channel of communication used by the public at large for
assembly and speech".
Ashcroft v. ACLU, (2002) 535
"The Internet ... offer[s] a forum for a
true diversity of political discourse, unique opportunities for cultural
development, and myriad avenues for intellectual activity . . . individuals can access material about topics
ranging from aardvarks to Zoroastrianism. One can use the Web to read thousands
of newspapers published around the globe, purchase tickets for a matinee at the
neighborhood movie theater, or follow the progress of any Major League Baseball
team on a pitch-by-pitch basis.
When
a person posts a website on his own server or upon the server of a hosting
service such as Geocities or
Zero Catch, that website becomes immediately
available to any user of any computer attached to the Internet and its World
Wide Web wherever such technology is available on the Planet Earth. When an American posts material on the
Internet under the protection of the
First Amendment, it is possible that other
nations and their courts might try to hold him to a different standard. In
Dow
Jones & Co. v. Gutnick, [2002] HCA 56 the
High Court of Australia found
that an American webmaster can be held to answer an action for libel in the
Australian State of Victoria under Victoria's libel principles for the harm
allegedly due to persons viewing the content within Victoria and not under
American
First Amendment principles. However,
American webmasters can be protected from enforcement of such foreign judgments
in the United States where such proceedings offer less protection than provided
by the
First Amendment,
Yahoo!,
Inc. v. La Ligue contre le Racisme et l'Antisemitisme, (N.D. Cal. 2001) 145
F. Supp. 2d. 1168 and
169 F. Supp. 2d. 1181.
Exhibit B to
Knight Declaration II
is the State's Reply in the contempt action.
Its Exhibit 7 includes a number of posters Mr. Knight has published on
his Web Site, at www.antipeonage.0catch.com/warposters.htm as jpeg images that
can be downloaded and readily printed out on 8.5 X 11 inch paper. The captions on these posters read as
follows:
Given
In re Cave, (1901) 26
Let Me Get This
Straight. We Can Deny Noncustodial
Parents Equal Protection of State Constitutions that Prohibit Imprisonment for
Debt.
And Deny Them the Protections From
Involuntary Servitude, Excessive Bails And Bills of Attainder. And Still Expect the Constitution to Protect
You and Me. RIGHT.
The
slippery slope argument is valid and commonly asserted in public debate.
It
turns out to not be exactly true. The
Social Security Administration provides
benefits for the children of disabled
and dead parents. If Mr. Knight really
wanted to provide for his ex-wife and his children, he need only commit
suicide. Or fake his death and
disappear.
Then the federal treasury
would provide over $2,000 per month, considerably more than he was ordered to
pay and could ever possibly pay short of a windfall. One reason we owe over $6 trillion to such
lovely creditors as the Saudi Royal Family.
However, it is also true that the widows of soldiers killed in battle do
not always get the benefits provided by the law.
I Need My Mom More Than I
Need Her Money The
For
further details, please see
Case v.
Kitsap County, (9th Cir. 2001)
It is one thing for the prosecutors
to attempt to punish Mr. Knight for constitutionally protected activities with
contempt proceedings, it is another thing for the prosecutor to attempt to
prejudice the judicial officers involved with Mr. Knight's speech that, while
protected, can seriously prejudice the judicial officers against him and make
them more likely to impose sanctions.
This poster included by the State in its submission in the contempt
action shows a World War II drawing of Uncle Sam with his finger over his mouth
indicating his wish for silence. The
original caption on war propaganda posters with this image usually had a
message to the effect: "Loose lips sink ships." During a war, information that could help the
enemy should be kept quiet. No need to
allow the U-boats to know when a convoy was scheduled to leave
In this version, the image is
accompanied by the callouts "18 U.S.C. §1581" and "42 U.S.C.
§1994"
with the word "CENSORED' superimposed at a slant. The caption reads:
This statement is constitutionally
protected as a comment on public policy.
It is reasonable to submit to the "marketplace of ideas" because
the Antipeonage Act addresses enslavement for debt or obligation, declaring the
use of state law, including orders, that impose or enforce peonage to be null
and void, and that such practice is a crime against the United States each
count of which is punishable by not more than 20 years of imprisonment. Child support orders are routinely based on
some formulae or tables based on the admitted or proved monthly income of each
parent, or such income as can be imputed by a judge or commissioner.
Chapter 26.19 RCW. If the noncustodial parent is not wealthy,
does not have substantial resources additional to his or her income, and is not
able to cover the child support obligation with such resources, than the only
way that he or she can comply with a child support order is to maintain
employment at least at the wage level on which the support order is based. If he or she quits his or her job or refuses
employment, he or she can be prosecuted for contempt for failure to comply with
a child support order. RCW 26.18.050(4)
actually requires that if a support obligor asserts inability to comply with
the support order, "the obligor shall establish that he or she exercised
due diligence in seeking employment".
Therefore, at first glance, a child
support order enforceable by this means looks as much like the thing addressed
by the Antipeonage Act as the
Cathlamet
looks like a Washington State Ferry.
Upon closer inspection it looks even more like enslavement for
debt: In State v. Dominique Allen Davis,
Orders like this are easy to
find. An investigator can go to the
SCOMIS computers in the Clerk's Office on the Sixth Floor of the Seattle
Courthouse and scan for -3- cases using such common names as Smith, Johnson,
Jones, Williams, and Nguyen, while limiting the search to cases starting in
2000. Those cases listed
"MISCELLANEOUS" are usually original actions for contempt brought by
the King County Prosecutor's
Family Support Division headed by defendant
Kathleen Ann O'Brien. The investigator
can write down the cause numbers of these cases and then look them up on the
row of computers that have these files scanned in. If he is a gamer, he can then scan for names
such as King, Queen, Bishop, and Knight.
A high energy search can be made for
By conducting such a search, the
investigator can find, for each and every person who has served as a family
court commissioner or family court commissioner pro tempore in King County: at
least one order signed by such commissioner requiring the noncustodial parent
to make at least 3, 5, or 10 job contacts each week until success, and to bring
proof of such contacts or success in finding employment to the next scheduled
hearing.
This Court can take judicial notice
under
Evidence Rule 201 of its own records.
Mr. Knight is saying, on the
Internet, throughout the website www.antipeonage.0catch.com, that this is the
crime defined by 18 U.S.C. §1581.
Evidence for this constitutionally protected speech was presented by one
of defendant O'Brien's deputy prosecuting attorneys in the contempt action
scheduled to be heard by one of these commissioners or commissioners pro
tempore on
Therefore poisoning the well and preventing
Mr. Knight from being able to have a fair hearing before an impartial judicial
officer.
Suppose a web master were to assert
on his web site, that
Judge Grant Anderson of
Pierce County Superior Court was
allowing someone else to pay for his Cadillac in violation of the Canons of
Judicial Conduct.
Constitutionally
protected if true, defamatory if false.
But Judge Anderson would readily recuse himself from any case involving
the web master whether the accusation was true or false. Or any decision in such a case could be
overturned on appeal if adverse to the web master.
If the situation in Pierce County
was even worse, where the web master can assert that every judge and
commissioner of the
Superior Court was receiving free car payments in violation
of the Canons, and provide evidence gleaned from public records to support such
factual allegations, such web master absolutely cannot receive a fair hearing
before an impartial judicial officer in Pierce County until the court personnel
was completely changed.
As to the makeup of King County's
court commissioners this court is presently tolerating the service as
commissioners pro tempore of
Georgina Sierra who is receiving child support,
Janet Watson who was frustrated in receiving child support by the disappearance
of her husband, and
David Kontos, who has been
disciplined by the
Washington
State Bar Association for negligent misrepresentation. Knight Declaration II pages 9-12.
Commissioner Bonnie Canada-Thurston served as
a deputy prosecuting attorney in the
Family Support Division of the
King County
Prosecutor. Many other family court
commissioners can be determined to have practice divorce law, served as
guardian ad litems, and otherwise served in domestic relations law wherein they
were tolerant of the practice Mr. Knight asserts is the crime of peonage.
It also appears that the prosecution
wants to punish Mr. Knight for having exercised his right to due process of law
in addition to his right to free speech in a public forum, and for his attorney's
previous success in obtaining dismissal of a contempt action for improper
service.
Not appropriate uses for the
contempt powers provided by chapters
26.18 RCW and
7.21 RCW.
PROPOSED
ORDER
A copy of the proposed Order is provided hereto.
Respectfully
submitted this 6th day of July, 2004.
__________________________
Roger W. Knight, pro se
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