FROM

THE DESK OF CHRISTOPHER KING, J.D.

kingcast955@icloud.com
617.543.8085m

27 December 2023

Re: Complaint for Violation of Rules 3.3 and 4.1 by Ryan Agnew, WSBA # 43668

Dear Reviewing Authority,

This is a simple matter:

I. Introduction.

At an open Hearing in King v. Peter Manning and Black Excellence in Cannabis 22-2-17896-5 SEA
broadcast to third parties, a Defendant in my case (Peter Manning) against an entity he calls “Black
Excellence in Cannabis” stated that he was conversing with Attorney Agnew and stated on the
Record that Attorney Agnew had reviewed some files from New Hampshire or somewhere and that
I was *DISBARRED.*

None of this is accurate; there was no finding against me in New Hampshire and I am not, nor have I
ever been, disbarred. In point of fact I have awards and accolades in New Hampshire from the
Mayor and Aldermanic chamber as noted in local press the City Attorney agreed with Alderman
Teeboom and me, so Peter Manning was just talking out the side of his neck, but apparently he did
so based on false statements made to him by Attorney Agnew, simple. Here are the facts and video:

King County:
https://www.facebook.com/KingCast/videos/861127488257161
Black Excellence in Cannabis Intellectual Property theft hearing.…

https://www.scribd.com/document/603961051/Taxpayer-Christopher-King-JD-v-Black-
Excellence-in-Cannabis-as-Thieves-of-Aaron-Barfield-Goodwill-and-Intellectual-Property

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FROM THE DESK OF CHRISTOPHER KING, J.D.
kingcast955@icloud.com
617.543.8085m

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kingcast955@icloud.com
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kingcast955@icloud.com
617.543.8085m

Next, let Record be Clear that Peter Manning also falsely stated that my friend Aaron Barfield – the
True owner of Black Excellence in Cannabis – was a Felon; a person who had been “convicted” for
stealing, embezzling or otherwise pilfering $80,000.00 from his business partners when in point of
fact it was Jim Buchanan, a longtime paramour and friend of Washington State Liquor and Cannabis
Board member Ollie Garrett, who financially imperiled the Emerald Haze cannabis entities. There
are $400K in Judgments against him from another partner on record in King County Court by the
way, just the facts please. In re Receivership of Pacific Cannabis Development, LLC, and James W.
Buchanan, King County Nos. 20-2-15352-4 ($100,366.92 and $300,000.00).

Also to make the Record yet more transparent, Buchanan apparently likes to play around and get in
trouble in Hawaii; this is odd to me because when I go to Hawaii I just hang out with my coffee
plantation friends in Kona and I never seem to come home with any charges:

https://www.youtube.com/watch?v=NzodRQcbHg4

JIM BUCHANAN
Address: 1275 MAIN AVE, CLEVELAND, OH 44113-2329 (CUYAHOGA COUNTY) Filing Type:
CIVIL JUDGMENT
Plaintiff: BALER SALES CO
Court Case Number: 04CVF13219
Total Judgment Amount: $2,284
Court: HAWAII COUNTY DISTRICT COURT(HIHAWM1)
Court Address: 75 AUPUNI ST, HILO, HI 96720 (HAWAII COUNTY)
Court Phone: (808) 933-1241
Filing Date: 11/22/2004

Curiously, certain people seem to have carte blanche around the WSLCB and its cronies:

Buchanan is also a criminal here on the Mainland too…. Passing bad checks and all of that…

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kingcast955@icloud.com
617.543.8085m

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kingcast955@icloud.com
617.543.8085m

………..so with the money he is slated to help manage in the Community Reinvestment Act/Cannabis
programs he has a broad spread of manure with which to fertilize the filthy Washington cannabis
market with the highest tax rate of any in the Country, at 37% but I digress1:

II. Applicable Law.

Rules 3.3 and 4.1 Govern, as noted per one of several emails to Attorney Agnew:

Subject: Dear Attorney Agnew: Where is Your NoA; Where is Your Apology?
Date: Dec 19, 2022 at 5:03 PM
To: agnew.rr@gmail.com, "serviceATG@atg.wa.gov" <serviceATG@atg.wa.gov>, James s
<jameskshelton@yahoo.com>, Leah.Harris@atg.Wa.Gov
Cc: "dustin.dickson@lcb.wa.gov" <dustin.dickson@lcb.wa.gov>,

Great Day to All,

Counselor: Contrary to the musings of Peter Manning you have not yet entered an Appearance, and if
you're smart you probably won't for a number of reasons.

Whatever. I don't care if you appear or not. I don't care if Clarence Darrow summonses himself from the
grave and appears; I'm ready for whomever and whatever. What I *DO* care about is the apparent fact
that you told your client (Peter Manning) that I am disbarred. That is defamatory Sir, especially coming
from a practicing Attorney charged with the moral and ethical duty to know the difference.

I don't have to tolerate this and I won't. So as such I am going to call you and leave a message for you right
now at the below number, and then if I don't hear back from you I am going to file a Complaint with the
Bar.

Happy Holidays!
Christopher King, J.D.

RPC 4.1 TRUTHFULNESS IN STATEMENTS TO OTHERS In the course of representing a client a
lawyer shall not knowingly: (a) make a false statement of material fact or law to a third person; or
(b) fail to disclose a material fact to a third person when disclosure is necessary to avoid assisting a
criminal or fraudulent act by a client, unless disclosure is prohibited by Rule 1.6.

Misrepresentation [1] A lawyer is required to be truthful when dealing with others on a client’s
behalf, but generally has no affirmative duty to inform an opposing party of relevant facts. A
misrepresentation can occur if the lawyer incorporates or affirms a statement of another person
that the lawyer knows is false. Misrepresentations can also occur by partially true but
misleading statements or omissions that are the equivalent of affirmative false statements.

1 Actually it’s more than a digression; it’s the sine qua non of what the WSLCB and its cronies is all about: Say

and do anything with impunity and don’t even think twice about the Ethics of it all. But that’s why we are here
before you – an Ethics Panel – to help review the matter appropriately. Why would Jay Inslee support this
mayhem is the $64,000.00 – or 37% -- Question.

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kingcast955@icloud.com
617.543.8085m

RPC 3.3 CANDOR TOWARD THE TRIBUNAL

(a) A lawyer shall not knowingly:

(1) make a false statement of fact or law to a tribunal or fail to correct a false statement of material
fact or law previously made to the tribunal by the lawyer;

(2) fail to disclose a material fact to a tribunal when disclosure is necessary to avoid assisting a
criminal or fraudulent act by the client unless such disclosure is prohibited by Rule 1.6;

(3) fail to disclose to the tribunal legal authority in the controlling jurisdiction known to the lawyer
to be directly adverse to the position of the client and not disclosed by the opposing party; or

(4) offer evidence that the lawyer knows to be false.
(b) The duties stated in paragraph (a) continue to the conclusion of the proceeding.
(c) If the lawyer has offered material evidence and comes to know of its falsity, the lawyer shall
promptly disclose this fact to the tribunal unless such disclosure is prohibited by Rule 1.6.
(d) If the lawyer has offered material evidence and comes to know of its falsity, and disclosure of
this fact is prohibited by Rule 1.6, the lawyer shall promptly make reasonable efforts to convince
the client to consent to disclosure. If the client refuses to consent to disclosure, the lawyer may seek
to withdraw from the representation in accordance with Rule 1.16.

***********

Respondent Agnew apparently made false statements and allowed his client to make known,
materially false statements about me, and about Aaron Barfield so at this point he has but two (2)
options:

1. Disavow ever telling Peter Manning any of it, or;

2. Apologize for telling Peter Manning false information.2

2 I also telephoned Respondent and professionally asked him for a comment or apology; he ignored me.

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kingcast955@icloud.com
617.543.8085m

III. Attorney Agnew Must Address These Rule 36 Admission Demands.

These were Served on 29 November 2022 to the Corporate and Manning Defendants, so
chop-chop:

The following Request is in compliance with Civil Rule 36.

1. Admit that you never notified Aaron Barfield that you were going to open a corporate entity
bearing the name “Black Excellence in Cannabis.”

ANSWER


2. Admit that you saw an email and text messages dated 28 October, 2022 from Aaron Barfield
demanding that you CEASE AND DESIST using the name “Black Excellence in Cannabis” as
seen below.

ANSWER


3. Admit you were on the phone in a conversation between Sami Saad and another cannabis
activist without Mr. Saad’s knowledge.

ANSWER:




4. Admit you came to be on the phone in a conversation between Sami Saad and another
cannabis activist without Mr. Saad’s knowledge.

ANSWER:



5. Admit you telephoned Kevin Shelton and told him you could help get a recreational license
for him if he disassociated himself from Plaintiff and withdrew comments he made about
Ollie Garrett and Nate Miles.

ANSWER:



6. Admit you telephoned Plaintiff King in or about April, 2022 and, inter alia, asked him why
he posted pictures in his litigation.

ANSWER:

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kingcast955@icloud.com
617.543.8085m

7. Admit you have spoken with Libby Haines-Marchel prior to 2022 about her situation with
the WSLCB as someone who won the lottery but who never obtained a license.

ANSWER:



8. Admit you have never publicly mentioned Libby Haines’ name in connection with Equity
Cannabis.

ANSWER:



9. Admit you wrote Plaintiff King in October, 2022 and asked him or his phone number.

ANSWER:

IV. Conclusion and Demand for Relief.

At a minimum Attorney Agnew must disavow making any representations to Peter Manning that I
am disbarred. He must also disavow making any representations to Peter Manning that Aaron
Barfield is a criminal in any way, shape or form.

We have had enough of this bullshit. And if you were sitting in our shoes you would be saying worse
than that, I guarantee you. And you know I’m right, so let’s see what you are going to do about it.
Keep in mind I have forced a United States Federal Judge to Recuse herself so if I can do that, I
reckon I can be heard by this Tribunal about a cooking variety cannabis Attorney. See Recusal of
Landya B. McCafferty at Appendix A in King vs. Friends of Kelly Ayotte, NH Dist. 1:10-CV-00501-PB
for more of what really happened in New Hampshire.

Respectfully submitted,

__________________________________
Christopher King, J.D.
617.543.8085m




cc: Aaron Barfield
World Wide Web

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 FROM THE DESK OF CHRISTOPHER KING, J.D.
kingcast955@icloud.com
617.543.8085m

APPENDIX A

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