Actual Consumer Complaint Puts Waukesha DA Susan Opper on ATCP Duty to Investigate Abby Binder and Abby Windows

IN THE CIRCUIT COURT
WAUKESHA COUNTY
STATE OF WISCONSIN
CHRISTOPHER KING, J.D. )
Defendant Cross-Plaintiff, )
v. ) CASE NO.2024-CV-000820
) JUDGE BRAD SCHIMEL

ABBY WINDOWS et al. LLC.,
)
Plaintiff Cross-Defendants.
RULE §785.01 NOTICE OF FRAUD ON THE COURT AND

NOTICE OF MOTION AND MOTION TO STRIKE BAD FAITH AFFIDAVIT OF SERVICE
SHOW CAUSE HEARING REQUESTED
NOW COMES LITIGANT KING., to solemnly aver to the following as on Oath and Subject to
the Pains and Penalties of Perjury.
1. Jason Crismond told an unknown representative of Hoosier Process Service that he was not
directly contacted by anyone on June 7, 2024 regarding Service of any Summons, Complaint,
Request for Waiver of Summons or any other documents related to this case (Appendix A); and
2. He further stated that he had never been directly contacted by anyone regarding Service of any
Summons, Complaint, Request for Waiver of Summons or any other documents related to this
case; and
3. Isiah Lowe is the apparent “CEO” of “Deluxe Legal Services” of Muncie, IN; and
https://www.linkedin.com/in/isiah-lowe-a7b414208/
4. The purported Affidavit as filed contains absolutely no narrative description whatsoever as noted
at Appendix A; and
5. I asked Plaintiff Attorney Andringa if he thought he could provide such a narrative; he did not
respond whatsoever as seen at para. 8, infra and Appendix B with Proposed Joint Motion and
Proposed Order regarding a proper Show Cause Hearing, and
1
6. The purported e-signature affixed to the document appears to be flipped, upside down and/or
backwards; and
7. Another contemporaneously-filed Affidavit by Lowe – a Licensed Notary for the time being –
contains the typical language:
2
8. I inquired of Attorney Andringa of the situation; and
On Jun 18, 2024, at 2:53 PM, Christopher King <kingcast955@icloud.com> wrote:
Good Day Attorney Andringa,
Do you by chance have any narrative to attend your client's Crismond Affidavit of Service filed at
Dkt. 54?
The reason I ask is because I believe it to be Sewer Service, which of course dovetails with the
pending Counterclaim for Bad Faith litigation.
So yes, another 'deadline' that you don't like: If I don't see a narrative by CoB Thursday 20 June,
2024 I will add this issue to my pending Counterclaim.
However, if you could please assuage my concerns in this regard it would be greatly appreciated
so we can keep the litigation moving forward.
Warm regards and Happy Juneteenth!
Christopher King, JD
617.543.8085m
***************
From: Christopher King <kingcast955@icloud.com>

Subject: Re: Abby Windows v. King et al. Crismond Service of Process
Date: June 19, 2024 at 7:19:53 AM PDT
To: Timothy Andringa <tja@cmlawgroup.com>, smc@berensonllp.com
Cc: XXXXXX
See as I'm sure you know, a typical Service Attempt is accompanied by a Narrative, like this one
that just came back today on another case I'm covering.
Do you think you can get one of those in this case?
I'll bet not.
Warm regards,
617.5433.8085m
3
************
9. I did further draft a proposed Joint Motion and Proposed Order for signature by Abby Attorneys
Andringa and Couch, however neither Attorney dignified my concerns; prompting this Notice and
Motion; and
10. I know for fact that the backwards upside down is not his real signature because Defendant my
Private Investigator Adam Winquist at Summit Investigations pulled his real signature from his
mortgage docs as seen below; and
11. Isiah Paul Lowe verified with Defendants King and Crismond, that the real estate signature is
indeed his signature “when I bought my house”; and
4
12. I had become suspicious of Lowe because of an online obituary indicating a June 10, 2023
suicide, which would have predated the June 12, 2023 backwards upside-down, flipped signature;
and https://www.legacy.com/us/obituaries/legacyremembers/isiah-lowe-obituary?id=55326762
13. In point of fact he does appear to be alive as a staffer at Hoosier indicated, although he believed
Lowe to be a female; and
14. Lowe identified as male to Defendants; and
15. He has several social media sites in which he presents as female so that might explain the
confusion there at Candy Kay Winters (Izzy Deluxe) https://www.facebook.com/isiah.lowe.16;
and
16. It does not explain the confusion regarding a consistent pattern of conduct not becoming a Notary,
starting with a podcast in which he exalts in “skipping court again” “running a ponzi scheme” and
“getting away with not going to Court” on this podcast “The Deluxe Edition”
https://podcasts.apple.com/us/podcast/the-deluxe-edition/id1587480300?i=1000548435631
; and
17. On information and belief he was busy working as a process server while dodging Court for his
own evictions, see below
https://public.courts.in.gov/mycase/#/vw/CaseSummary/eyJ2Ijp7IkNhc2VUb2tlbiI6IlphcGxfSnp
UTTJNOUJlOWJNTjZWNzFiUmF0NWtTSGFjd0VDa3RTQTVsMm8xIn19
; and
5
6
7
8
9
18. To make a long story somewhat shorter Defendants King and Crismond engaged in several phone
calls with Hoosier Process Servers and Mr. Lowe, lawfully-recorded. Both men indicated they
would get back in touch with us; and
19. Defendant Crismond emphatically told Lowe “You did not serve me that day. It did not happen.
You have never served me and you would remember what you did if you just drove four hours
from your house to mine two Fridays ago”; and
20. Lowe stated something about his associates but never directly addressed Mr. Crismond’s
statement; and
21. Both men promised to return phone calls but alas neither of them actually did so, and when
telephoned on or about Monday, June 24, 2024 Lowe did not answer and the unidentified person
at Hoosier immediately stated “Gentlemen I have to disengage with both of you” and hung up the
phone within eight (8) seconds; and
22. I have been involved in the issuance or receipt of dozens of Process Service attempts since 1993
on passing the bar and I have never seen anything like this, prompting me to document it on
video, with the opening quote being verbatim “My day was pretty decent, I skipped Court
again….” “Are you SERIOUS??” (not from John McEnroe but from his co-host at “The Deluxe
Edition,” January 19, 2022.
https://www.facebook.com/KingCast/videos/7573157186145902
10
MOTION FOR SHOW CAUSE HEARING
The integrity of these proceedings must be restored and maintained. The judge presiding in an
action or proceeding may impose a punitive sanction upon a person who commits a contempt of court in
the actual presence of the court. The judge shall impose the punitive sanction immediately after the
contempt of court and only for the purpose of preserving order in the court and protecting the authority
and dignity of the court.
Litigant King – who has been lied to by Abby’s chosen Process Server and his contracted Server -
- believes that the need for an actual zoom hearing on this matter is essential, as contemplated by Local
Rule: The contumacious conduct of this young person clearly evinces a complete disregard for the Law,
flaunting the system at every opportunity, i.e. “My day was pretty decent, I skipped Court again….” “Are
you SERIOUS??” (not from John McEnroe but from his co-host at “The Deluxe Edition,” January 19,
2022.
Significantly this is not a case of mistaken identity or whether the Service Documents were
delivered to a visiting relative or anything of the sort. No. This is about a completely fabricated story such
that Litigant King did leave a phone message
imploring Lowe to provide any information
whatsoever that would indicate he had driven for hours
to and from Crismond’s abode “stopped for gas,
receipts from a candy store…anything, show me
something.” Naturally nothing has been shown, and
Counsel for the Abby litigants have not lifted a finger
to assist in ferreting out the Truth.
It is imperative to note that Mr. Crismond is not dodging Service. To the contrary the Undersigned has
seen his information, including previous attempts by another Abby lawyer to threaten him with divulging
trade secrets or some kind of confidential information, however when asked for further description the
lawyer at Michael Best had nothing say except “you know what you did” or words of similar import.
Litigant King respectfully asserts that such a statement is wholly inadequate to put anyone on Legal
Notice of an alleged violation.
12
Much more on this later should this case survive Motions to Dismiss and in any event on the
Counterclaims, which have a much more substantial chance of getting to Jury as the Court has already
seen. 1
Wis. Stat §785.01 reads, in pertinent part:
785.01 Definitions. In this chapter:
(1) “Contempt of court" means intentional:
(a) Misconduct in the presence of the court which interferes with a court proceeding or with the
administration of justice, or which impairs the respect due the court;
With all the respect that is due (not much in this instance) the definition was tailor-made for
Abby’s selected process server(s). Note that both Hoosier and Deluxe Legal Services/Isiah Paul
Lowe/Candy Kay Winters are responsible for this, if not in the original Fraud then in the continuation of
same without any attempts to address it, lying about return phone calls and/or outright handing up on
Crismond and Litigant King.2
________________________
Christopher King, J.D.
CERTIFICATE OF SERVICE
I the undersigned swear that a true copy of this Notice and Motion was served to
Counsel via CCAP and at:
tja@cmlawgroup.com
smc@berensonllp.com
via email
And to all named Defendants via email

This 28th Day of June, 2024
_____________________________________________
1
Yesterday, June 28, 2024 Litigant King filed the Mikki Campbell Joinder in his Motion to Dismiss and
Counterclaim with supporting Declaration; more are anticipated but we are dealing with for example Litigant
Stepniewski’s special needs child who has hours-long medical treatments and evaluations, and Riley Richarz’
expanding family; apparently his sperm does count. Putting people like this through litigation on a patently baseless
case will have repercussions. For his part Mr. Crismond is busy working long weeks trying to bridge the financial
divide that resulted from the Abby Litigants breaches of contract and abuse. This is the Abby Way.
2
Litigant King respectfully reminds the Abby Litigants and Counsel that Mr. Crismond is not actually a litigant until
he is properly served.
13
Appendix A
DECLARATION OF JASON CRISMOND
NOW COMES JASON CRISMOND to solemnly aver to the following as on Oath and
Subject to the Pains and Penalties of Perjury.
To whom it may concern,
1. It was brought to my attention via SMS/MMS message on June 18th, 2024 at

approximately 16:48 that some type of legal affidavit was submitted to the Wisconsin Court
claiming that I was served legal documents by a process server named Isiah Lowe on June 7th,
2024 at 19:31 EDT.
2. In an effort to be mindful of the perception of tonality of this letter, I will attempt to be

concise and state only the facts as I know them to be true.
3. Firstly, I can say and swear under the penalty of perjury in whatever jurisdiction this
matter is of concern, that at no time on June 7th, 2024, or any other time for that matter, was I
ever served legal documents.
4. I work 80-hour work weeks, and on June 7th, 2024, I was onsite at a construction project
approximately 40 miles away from the alleged service address.
5. I have photos of the project where I was, timestamped at approximately 16:30 on the
above-mentioned date. I did not return with my work vehicle to retrieve my personal vehicle
until shortly after 17:00.
6. With routine close-of-business tasks, I left my office at approximately 17:30.
7. I traveled to a local restaurant where I am known by staff and local residents alike,
located approximately 30 minutes away from my office, where I'm quite certain I was during the
time this alleged service is claimed to have occurred.
8. My phone records will indicate outbound phone calls being placed around the alleged
time of service.
9. I was never contacted by, approached by, or encountered any person regarding the
alleged "service" or party/witness to any of the events included in the vague descriptions within
the reviewed affidavit of service.
10. My response to this information being received on June 18th, 2024 resulted in
immediate frustration and curiosity to pursue an independent investigation on who was making
a false claim upon my name.
1
11. My first observation was the illegibility of the "signature" on the submitted affidavit. As
people can make their signature whatever they so wish, this one seemed to be remarkably
peculiar. The date accompanying the signature said June 12th, 2024. The description stated
that I was served at 1741 Harrison Spring Rd. NW, Corydon, IN 47112, and that my physical
person was the recipient of allegedly contained documents by a process server named as Isiah
Lowe who acted as an agent for an entity listed on the affidavit as Hoosier Process Service,
LLC.
12. Appalled by the falsehood and impossibility of the statement, I began to research who
this individual was to try to understand better what was being purported and the potential
motivation in making such an outlandish and untrue claim.
13. A simple Google search of "Isiah Lowe Process Server Indiana" resulted in a LinkedIn
page for a company called Deluxe Legal Services. The description on the page stated that the
individual was a notary public and worked in the domain of legal service matters. The
company's headquarters was listed as Muncie, IN.
14. As the world is large and it was very possible that this individual may have shared a
common name, I could not unfix my eyes from the uncommon spelling of the name Isiah. I have
only known the Old Testament spelling of Isaiah.
15. After seeing the LinkedIn page for Isiah Lowe, CEO of Deluxe Legal Services in Muncie,
Indiana, I continued searching online for more information.
16. Where my heart stopped in fear and confusion was when I typed "Isiah Lowe Muncie
Indiana" and found an online obituary for a 24/25 year-old young man who according
to Legacy.com had committed suicide on June 10th, 2024, two days before the signature date
on the affidavit of service, after "struggling with heartbreak and inner-demons" (paraphrased). I
had no idea what I just stumbled into and began to call family to explain what was happening.
17. I contacted Mr. King and explained what I had found. Immediately after began scouring
what open-source information was available publicly to get some peace of mind or resolution as
this was a particularly emotional experience after reading online of Isiah Lowe's sister who was
an elder of two years dying a few years back after a long battle with terminal illness. I was
crying in empathy, living through a channel of vicarious suffering in what this poor young man
must have been going through internally, completely separate from the underlying matter of how
all of this started with a false claim of meeting me and serving me papers.
18. Obsessively over the next 24 hours, I needed answers. Was this intentional? Should I
be concerned for my safety? How does someone sign a document on June 12th, 2024 who by
information and belief committed suicide on June 10th, 2024?
19. Continuing research through public information and with the help of a private
investigator, court records in Indiana on the State's website showed a long list of different
docket numbers for an individual named Isiah Lowe or in some cases, Isiah Paul Lowe.
2
20. The dockets showed a pattern of return to sender service, and failed attempts of being
contacted or reached through effective service of process. Within these documents contained a
bill of sale for what appears to be an active foreclosure docket number with the original
purchase agreement of a home that went delinquent with the original copy of Mr. Lowe's
signature.
21. The signature did not resemble that which was contained on the court-submitted affidavit
of service, allegedly signed by a Mr. Lowe on June 12th, 2024.
22. After many hours consumed in research to make sense of this, I finally found some rest.
23. The following day, distracted at work with unresolved tension and unanswered
questions, I reached out to Mr. King explaining how distraught I was and how peculiar this whole
thing was.
24. Mr. King called Hoosier Process Service, LLC, the party who contracted Mr. Lowe and/or
Deluxe Legal Services by telephone, a call which I was a party of on three-way calling and
disclosed to the gentleman at Hoosier Process Service who was on the phone and that the
phone call was being recorded and that there were many questions regarding this matter.
25. The representative (possibly owner?) of Hoosier Process Service, LLC was moderately
hostile, defensive and reluctant to speak demanding personal information from myself.
26. I explained that I was a bit reluctant to share any personal information with any stranger
on the phone as some agent of or on the behalf of the company he represented made an untrue
statement against my name, submitted it to the court, and by all public information and belief
could not have possibly been the one who signed the affidavit.
27. I can only speculate on what the life of a process serving company representative might
be in terms of sifting through claims of truth and falsehoods but this circumstance was so
undeniably peculiar that I had to explain to the gentleman on the phone my concern, and that
after I shared the specifics of my concern that I felt the matter irrefutably warranted some type of
consideration or assistance in figuring out what was going on.
28. I guided the gentleman on the phone, after the reluctance subsided and my sincerity
became evident, to do the same google searches I did and compare the information to the dates
written on the affidavit.
29. The gentleman's tone of voice changed immediately and for a moment it began to seem
like I had an ally in finding the truth.
30. The gentleman from Hoosier Process Service, LLC then stated that this was "very
alarming" and "he apologizes for not giving the benefit of the doubt" but also had a hard time
digesting this as he "had been in contact with her through text messages since June 10th and
she was very professional".
3
31. At this moment I began thinking that this name was a victim of identity theft and that
someone was acting as Isiah Lowe after he had been published as deceased, or this is all one
big coincidence and it was actually a female process server with a name spelled the same who
lied on this affidavit. The gentleman then confirmed it was indeed Deluxe Legal Services who
was contracted for the service of process in question. He stated he would reach out to the
woman he was in contact with via SMS message and we could reconvene to figure out what
was going on the day following.
32. After this call, a three-way call was placed with Mr. King and myself reaching out to the
published number of Deluxe Legal Service. Someone answered with a company greeting, and
we asked if this was Isiah Lowe. To which to representative responded "Yes, this is
he". Perplexed by what was happening, with a stuttered inquiry, I asked
"Is...this....Isiah..Paul..Lowe?" To which the person on the phone responded "Yes".
33. At this point I began asking questions about the events that were purported to have
happened in the affidavit of service, regarding the specifics of the address and the time and
descriptors of my physical persons and the circumstances surrounding the alleged service.
34. Stammering and stating "I have to go through my reports, I won’t attest to anything on
the phone" the person who identified themselves as Isiah Lowe, Isiah Paul Lowe continued to
say he would have to communicate with his team and go through records as the job number
provided that was listed on the affidavit of service provided no aid in him remembering the facts
he stated to be true. I asked the individual on the phone, "How can I be talking to you when
there are public obituaries of your death over a week ago?"
35. His response was a passive and nonchalant dismissal stating that "law enforcement is
already made aware, it’s an ongoing thing with a person in Michigan".
36. At this time, upon request during the call, Isiah Lowe provided an email address to
receive documents to confirm his identity. The public record signature from his Indiana Court
Case with bill of sale signature was sent and he confirmed that it was indeed his signature.
Upon affirmation, I asked "is the signature on this affidavit your signature?". No direct answer
was given, and a promise to consult with his team and reports and to follow up in an hour with a
phone call resulted in none of those actions or promises being fulfilled.
37. My inner monologue at this point is screaming "What is this?". I remember this
conversation vividly as I was pacing around a Dr. Pepper cooler in a gas station in a surreal
state of disbelief. "So this person is alive? The process service company believes him to be a
woman, and has never physically met him? Who is this?"
38. In suspense of a follow-up call for some explanation as to who was responsible for the
signature and false statement of events, I continued to research public information on this
person. As mentioned earlier in this writing, whoever Isiah Lowe is, they appear to be avoiding
service of process or receipt of summons in active court dockets, see Delaware County, IN
18C05-2304-PL-000044.
39. To this day, no response was ever given from Isiah Lowe or Hoosier Process Service,
LLC again. A phone attempt reached a half-ring to voicemail which conventionally indicates a
number being blocked.
4
40. After seeing the court records, I began to search Facebook for any information that could
provide answers. What I found was multiple Facebook accounts for Isiah Lowe of Muncie,
Indiana which included one of a female alternate gender identity known as Candy Kaye Winters
(aka Izzy Deluxe). Within these Facebook profiles, I found a post regarding a podcast hosted
by none other than Isiah Lowe themselves called "The Deluxe Edition".
41. With a podcast broadcasted on January 19th, 2022 titled "Would You Rather?", Isiah's
co-host asks the question and the following is transcribed verbatim
Isiah Lowe: "Uhh, yeahh, my day....was pretty decent...I actually, um...I skipped court again,
um...(long boisterous laughter)
Co-host: "Are you serious?!"
Isiah Lowe: (Continued Laughter) I, didn't really have to go to this hearing, um, it was only if I
was going to have to attest to something which I di...uhhh, .thats a separate case..
Co-host: "What, wait...so what do you mean? Were you like a witness?
Isiah Lowe: (deep inhalation) Uhm, no, so like, um basically...if I was going to argue what I was
(guttural stammering and filler noise) going to court for, like what somebody was (stammering)
um saying, um uhh
*At this point, the tonality shift begins to feel like some type of non-verbal communication was
used to signal to the co-host to change the subject due to being actively recorded for broadcast*
Co-host: Oh okay
Isiah: "But! I wasn't arguing it, I know what I did, blah blah blah, kiss my ass, um BUT! I did take
the day off of work to get some things done, I cleaned my guest room, um if you ever...
Co-host: Good for you!
Isiah: Yeah so if you ever, whenever you fall asleep in my house I can lift you into the guest bed
and stare over you like a creep"
42. I will spare the reader of this writing the remainder of transcribing this podcast for
reasons not only due to the inappropriate nature of it but also due to it lacking any relevance in
this writing or the matters of concern. It is important to note, that this recorded statement of
Isiah Lowe's actual voice on his own podcast, broadcasted on January 19th, 2022 does not
match any dates in Indiana Courts Public Records where Isiah Lowe is a Plaintiff or
Defendant. I am not a lawyer, but find myself asking the question "Attest is such a specific
word to use, why that word? What was he supposed to appear for?"
43. As the facts stand, the person misrepresented themselves to Hoosier Process Service,
LLC. This person beyond any doubt has committed fraud or contracted some agent to
knowingly perpetrate fraud in the name of Isiah Lowe and their signature.
5
Appendix B
WAUKESHA COUNTY
STATE OF WISCONSIN
ABBY WINDOWS et al. LLC., )
Plaintiffs, )
v. ) CASE NO.2024-CV-000820

CHRISTOPHER KING et. al,
)
Defendants.
NOTICE OF MOTION AND JOINT MOTION OF DEFENDANT COUNTER-

PLAINTIFF KING AND PLAINTIFFS COUNTER-DEFENDANTS ABBY WINDOWS
LLC FOR SHOW CAUSE HEARING ON SERVICE OF PROCESS FRAUD1
NOW COME DEFENDANT COUNTER-PLAINTIFF CHRISTOPHER KING, J.D.,

AND PLAINTIFFS ABBY WINDOWS et al., LLC to note that litigant King provided
information sufficient to place Counsel for the Abby litigants on Actual Notice of potential Fraud
involving Service of Process in this case.
All Parties and Counsel would like to fully evaluate this matter as Service of Process on
any litigant is of paramount importance, and the integrity of same must be maintained.
WHEREFORE Counsel for litigant King (proceeding Pro Per) and Counsel for the Abby
litigants hereby affix their signatures hereto in joint support of an immediate hearing on this
matter. The Court must exercise its inherent authority to Order an Evidentiary Show Cause
Hearing to be attended by the following:
Isiah Lowe and/or Deluxe Legal Services or authorized representative

Hoosier Process Service or authorized representative
Timothy Andringa, Esq.
Steven Couch, Esq.
1
The Parties acknowledge that a Motion to Recuse Judge Schimel is pending and will await further instruction from
the Court on that matter.
1
Respectfully submitted and agreed,
________________________
_________________________
_________________________
Steven Couch, Esq.
2
WAUKESHA COUNTY
STATE OF WISCONSIN
Plaintiffs, )
v. ) CASE NO.2024-CV-000820

)
Defendants.
[PROPOSED] ORDER GRANTING SHOW CAUSE HEARING

ON SERVICE OF PROCESS FRAUD
THIS MATTER COMES BEFORE THE COURT on a Joint Motion of these Parties
relative to matters they have agreed to brief for review. The Court defers to their judgment at to
the materiality of the matter and hereby ORDERS a live video Evidentiary Hearing on the matter
to be held with live witnesses present as follows:
Hoosier Process Service, LLC or authorized representative
Steven Couch, Esq.
The parties are advised as to the following schedule:
IT IS SO ORDERED THIS ___ DAY OF JUNE, 2024
__________________________
JUDGE
1
27th June
27 June 2024
Good Day Counselors Doyle, Knott and Starnes:
I took the time to find you as Attorneys who represent Waukesha County/Susan Opper’s Office.
I write you as a concerned former AAG myself because I would like to receive a meaningful
response to my public inquiry about known and provable consumer abuse as noted below in my
most recent communication to DA Opper yesterday.
Here is what you need to know:
Abby Windows, LLC actually sued five innocent staff at Abby Windows, LLC and I as a journalist
were actually sued for Defamation for reporting things about the company that are actually
100% true (Waukesha Abby Windows v. Christopher King, JD et al 2004-CV-000820). I have a
LOT of First Amendment and Defamation experience as litigant, consultant and Attorney. I
seldom lose.
The lawsuit stems largely from the facts exposed in a video basically similar to this one:
https://www.youtube.com/watch?v=9_E-48JGPjo&t
…..along with some claims against written statements where Abby and her lawyer Timothy
Andringa failed to follow basic law requiring Notice pursuant to Wis. Stat §895.05(2).
The issue is that unwitting homeowners are being surreptitiously recorded in violation of 18 USC
§2511 and Wis. Stat §968.31 and they are also, inter alia, subject to premature demands for
Certificates of Completion, an ATCP violation on several fronts. Read the Wisconsin
Contractors Handbook right here:
https://wicontractorinstitute.com/wp-content/uploads/coursebooks/contractors/Home-
Improvement-Trade-Practices-Book1.pdf
(6) PRICE AND FINANCING.

(a) Misrepresent to a prospective buyer that an introductory, confidential, close-out, going out of
business, factory, wholesale, or any other special price or discount is being given, or that any
other concession is made because of materials left over from another job, a market survey, or
test, or any other reason.
(e) Request the buyer to sign a completion slip or certificate, or make final payment on the
contract before the home improvement is completed in accordance with the terms of the
contract.
1
I have verified this now with former staff and homeowners but Susan Opper has refused to give
the matter the light of day, and her staffer won’t even identify the “appropriate person” to whom
she forwarded my inquiry.1
As you will see by this video we got the runaround from Waukesha PD and her.
https://www.youtube.com/watch?v=brZb6yyPHM8&t
To be clear I’ve both sued and repped LE personnel and for the life of me, along with other
former Abby staff who are not Defendants in this case nobody can understand why there is no
protection here. There is no pulse from anyone and it’s as if the DA, Consumer Protection and
Waukesha PD have all phoned it in, and these entities are actually allowing harm to consumers,
which I am certain the Waukesha DA’s Office would not condone.
As such, I am concerned that DA Opper is not actually getting my correspondence and it is

being intercepted by someone with bad intentions to set her up for when this case might get to
Trial and it’s all on video where the staff explain these violations with intimate detail.
I have informed Opposing Counsel and DA Opper that I intend to call her because her opinion
as to whether there are valid legal claims or issues given the fact pattern with respect to Taylor
Stepniewski’s comments and my re-broadcast of same. Because if there is, obviously it tends to
moot any Actual Malice concerns regarding Binder, a Limited Purpose Public Figure.
If they fight this I told them they cannot use the legal system as a sword, battering ram and then
shield.
There is another disturbing component to this matter:
Judge Michael P. Maxwell recused himself without any explanation as required by Statute.
When when I called in and also filed a request for same, I was ignored, and the next thing I
knew the Honorable Brad Schimel appeared as Judge and the problem with that is obvious
here:
No Reasonable Person would feel comfortable coming before a Jurist who is a career friend and
co-worker (read: Supervisor) of a person I intend to call as a witness to prove that our
contentions are reasonable. My Motion has not been addressed by anyone nor is it scheduled
for Briefing as of yet; it’s sort of like it fell into a Black Abyss.
1
Sta% are also subject to Draconian and pointedly vague employment contracts that make them virtual
Indentured Servants but that matter is not squarely before us but I’ll attach Riley Richarz’ contract for your
review. It’s horrible. He can’t even dispute anything given the timing schedule, they sued him even though it
clearly contains a Mandatory Arbitration Clause, and they owe him back-end money the same way they owed
Fred Mayen money. They paid Mr. Mayen when he wrote a nasty review online but they owe Riley much more
money according to both men.
2
As you know, a Judge must recuse himself or herself whenever the facts and circumstances the
judge knows or reasonably should know raise reasonable question of the judge's ability to act
impartially, regardless of whether any of the specific rules in SCR 60.04 (4) applies.
*********
For her part Attorney Opper has never denied that our concerns have merit; which makes the
pronouncement from her office nonsensical because she clearly has authority to act, as
thoroughly explained below. It’s odd but then again odd things happen to me in Wisconsin, it
being the only time in my life that someone actually assaulted me and got away with it in a
professional capacity, and I got thrown out for simply asking why the man (Mark Rattan) was not
reprimanded. Sure there was a finding that he violated ethical principles by “approaching [me] in
an angry and threatening manner in violation of a standing order on cameras” but nothing really
came of it; it was like it was basically my fault which seems to be the emerging trend in this case
here as well.
https://www.youtube.com/watch?v=xmYatdpIlSU
So I write to you all to see if you can reach out to Attorney Opper directly to make sure she is
actually getting this information and still refusing to protect homeowners, and lastly to ask her if
our concerns regarding State and Federal Eavesdropping and Certificate of Completion
demands are reasonable.
I thank you in advance for your time and consideration.
617.543.8085m
3
26 June 2024
Re: Blatant ATCP Violations, a Bogus Defamation Case and Your Ethical Responsibilities
Dear Attorney Opper,
I write you as a former LE Attorney to remind you and Pat Studenec and Waukesha PD that you
do indeed have authority to protect homeowners. Here is the relevant ATCP in case you missed
it:
(6) PRICE AND FINANCING.

(a) Misrepresent to a prospective buyer that an introductory, confidential, close-out, going out of
business, factory, wholesale, or any other special price or discount is being given, or that any
other concession is made because of materials left over from another job, a market survey, or
test, or any other reason.
(e) Request the buyer to sign a completion slip or certificate, or make final payment on the
contract before the home improvement is completed in accordance with the terms of the
contract.
https://docs.legis.wisconsin.gov/code/admin_code/atcp/090/110/02
For starters, Abby Binder is suing Taylor Stepniewski for Defamation for stating that Abby
unlawfully requests Certificates of Completion at an inappropriate time. This is what Taylor
wrote, inter alia “DO NOT SIGN THE CERTIFICATE OF COMPLETION UNTIL YOUR
PROJECT IS 10000000% DONE. I don’t care if they tell you “this is just the part we completed
today” it’s all a lie. That’s how they process your financing. Once they have your money, WHO
CARES IF YOU STILL HAVE WORK TO BE DONE, they have your money and have been
instructed BY THE OWNER to focus on the people that still owe money. If you have a service,
you’re put on the back burner until you start threatening and reporting to the BBB. Best of luck.”
4
Abby customers Gale Bautch and Deanne Harris, clearly identifiable people whom my PI can
locate for subpoenas both directly told us that they requested Certificates of Completion too
early just as Taylor Stepaniewski publicly stated.
Let me make this simple:
Abby and her lawyers opened the window (no pun intended) by suing Taylor Stepniewski and
she has a right to subpoena all of those customers who will indeed verify this patently unlawful
practice and others just as Discovery records will prove no efforts to address 18 USC §2511
and Wis. Stat §968.31, matters that your office chose to ignore and to funnel us back to
Waukesha PD, who in turn funneled back to YOU. If we go to Trial all of this is going on the
Record and this means on video and subsequently broadcast and shared AT MY SOLE
DISCRETION.
To be clear Injunctive Relief and Civil Forfeiture is contemplated:
1. Rule Enforcement
Private Remedy
A person who suffers a monetary loss because of a seller’s violation of ATCP 110 may
sue the seller under Wisconsin Statutes section 100.20(5), and may recover twice the
amount of the loss, together with costs and attorneys fees.
Injunction and Restitution
DATCP may seek a court order under Wisconsin Statutes section 100.20(6), enjoining
violations of ATCP 110 and ordering a seller to pay restitution to consumers. The
Department of Justice or a district attorney may represent DATCP in court.
Civil Forfeiture
DATCP or any district attorney may start a court action under Wisconsin Statutes section
100.26(6), to recover a civil forfeiture from a seller who violates ATCP 110. The court
may impose a civil forfeiture of up to $10,000 per violation. The Department of Justice or
a district attorney may represent DATCP in court.
Criminal
A district attorney may start a criminal prosecution, under Wisconsin Statutes section
100.26(3), against a seller who violates ATCP 110. A seller may be fined up to $5,000 or
sentenced to as much as a year in jail, or both.
Furthermore: Any adversarial attempt at preventing these truths from entering the court are not
only violations of Bar Oath of Wisconsin under SCR 40.15 but will involve two or more parties
conspiring to deprive American citizens of constitutional rights under §18 USC 24.
5
Attorney Opper you have an Oath of Office that you are not following at present, and at Trial I
plan to call you to demonstrate our Good Faith Attempts to bring this matter forward as we have
a right to do, and on top of that Taylor Stepniewski has a right to Subpoena all Abby customers
to determine if and when Abby sought premature Certificates of Completion.
And as clearly shown here you do indeed have authority to protect homeowners and I will
make that known not only to you but to every single homeowner I can find in Wisconsin. I
respectfully demand that you quit protecting Abby Binder and Abby Windows and start
protecting innocent homeowners on ATCP and the Eavesdropping violations and Pat Studenec
that goes for you too and your division has refused to respond to me IN WRITING so you are
part of the problem as well.
Taylor Stepniewski is entitled to subpoena any and all homeowner clients of Abby Windows and
I am entitled to subpoena you as Hostile Witness because after all it was Abby and her lawyers
who brought you into this in the first place by crying about the fact that I wrote you. If you want
to file a Motion to Quash be my guest because remember, I’m not the one who brought you into
this lawsuit in the first place; you can thank Abby and Timothy Andringa for that; they also filed
this suit with nary a concern in the World for Wis. Stat §895.05 and that’s a fact.
I remind you that I tried to tell you this before:
https://www.youtube.com/watch?v=e2K40tCNBts&t
Warm regards,
617.543.8085m
6
26 June 2024
Re: Blatant ATCP Violations, a Bogus Defamation Case and Your Ethical Responsibilities
And I'm calling Pat as well, because here is the focal point for both of you:
Did I have a valid legal concern in your opinion when I wrote you, yes or no. As you are both
experts in your field I believe you are qualified to answer that question. After all Waukesha PD
already said it's a bad business practice, need to call him too and I will. "I agree it's a bad
business practice...."
https://www.youtube.com/watch?v=brZb6yyPHM8
Look: They don't get to roll up in here with a clearly bogus Defamation case, not even properly
filed with respect to written allegations, and then deny Discovery.
Anyway, survey says yes. it goes to negate any potential inference of Actual Malice all day it
does and you both know it and no Jurist is going to say that's not probative.
Even one with a pending Motion to Recuse based on his decades-long professional and
personal friendship with Attorney Opper.
Again, I look forward to prompt and timely production of my Public Records Demand. I have
been known to successfully sue over those in the event there are delays.
You can try to ignore my emails all you like but you will *NOT* ignore my Subpoena.
Warm regards,
617.543.8085m
7
WAUKESHA COUNTY
STATE OF WISCONSIN
Defendant Counter-Plaintiff, )
v. ) CASE NO.2024-CV-000820

)
Plaintiff Counter-Defendants.
COUNTER-PLAINTIFF KING SECOND RULE 804.09 REQUEST FOR PRODUCTION OF

DOCUMENTS TO COUNTER-DEFENDANT ABBY DEFENDANTS
AND RILLA CEO SEBASTIAN JIMENEZ1
Document Request #1 (Rilla and Abby litigants)
Provide under Seal or pursuant to Stipulated Protective Order subject to ultimate Decision by the Court
on sealability, a copy of the Rilla rollout meeting with Abby litigants where any alleged consent was
given pursuant to the Verified Complaint, para 13:
Response
1
Mr. Jiminez will be served appropriately at RillaVoice: 824 Lexington Avenue, Apt. 51, Brooklyn, NY 11221.
1
I the undersigned swear that a true copy of this request was served to
Counsel and Putative Counsel respectively via CCAP and at:
tja@cmlawgroup.com
smc@berensonllp.com
via email

_____________________________________________
2
WAUKESHA COUNTY
STATE OF WISCONSIN
v. ) CASE NO.2024-CV-000820

)
COUNTER-PLAINTIFF KING REVISED FIRST RULE 804.11 DEMAND FOR ADMISSIONS

TO ABBY LITIGANTS AND NATIONAL ASSOCIATION
OF THE REMODELING INDUSTRY, INC. (NARI)1
Admission #1:
Abby litigants have training manual(s) that direct sales staff to leave the primary sales locus (i.e. the
interior of the home) during a sale. (Rilla and Abby litigants)
Response.
Admission #2:
As of the day date and time of King’s initial video production Abby litigants did not have any language in
any training manual directly staff to turn off their Rilla software at any point in time during a customer
sales meeting. (Rilla and Abby litigants)
Response.
1
Mr. Jimenez will be served appropriately at RillaVoice: 824 Lexington Avenue, Apt. 51, Brooklyn, NY 11221;
NARI will be served at: Elsie Iturralde, 700 Astor Lane, Wheeling, IL 60090-6256.
1
Admission #3:
Admit that prior to King’s initial video production Abby Binder publicly discussed the company’s use of
Rilla software with “The Wealthy Contractor,” Know the System Like the Back of Your Hand,
approximately ten (10) months ago.
Response
Admission #4:
Admit that the Abby corporate entity was at some point in time, a member of NARI
(NARI and Abby litigants).
Response
Admission #5:
Admit that the Abby corporate entity is no longer a member of NARI as of June 23, 2024.
(NARI and Abby litigants).
Response
Admission #5:
Admit that the Abby litigants did not respond in writing to any of King’s emails before filing the
underlying Verified Complaint. (Abby litigants).
Response
Admission #6:
Admit that the Abby litigants did not request a retraction of any alleged written Defamatory statements
issued by King prior to filing the underlying Verified Complaint. (Abby litigants).
Response
2
Admission #7:
Admit that the Abby litigants left company as a listed partner entity with NARI because of Ethical
concerns (NARI and Abby litigants)
Response
Admission #8:
Admit that the Abby litigants did not sue for Defamation for any public statement that they were kicked
out of NARI (Abby litigants)
Response
3
I the undersigned swear that a true copy of these requests was served to
tja@cmlawgroup.com
smc@berensonllp.com
via email

_____________________________________________
4
WAUKESHA COUNTY
STATE OF WISCONSIN
v. ) CASE NO.2024-CV-000820

)
COUNTER-PLAINTIFF KING REVISED FIRST RULE 804.09 REQUEST FOR PRODUCTION OF

DOCUMENTS TO COUNTER-DEFENDANT ABBY DEFENDANTS, RILLA CEO SEBASTIAN JIMENEZ
& NATIONAL ASSOCIATION OF THE REMODELING INDUSTRY, INC. (NARI).1
Document Request #1 (Rilla and Abby litigants)
https://www.youtube.com/watch?v=o82uNVuvLgI
Provide a copy of all correspondence between Rilla and the Abby Defendants between June 1, 2023 and
day, date and time of production that relate to the production of this video.
Response
1
NARI will be served at: Elsie Iturralde, 700 Astor Lane, Wheeling, IL 60090-6256
1
Document Request #2: (Rilla and Abby litigants)
Provide a copy of each and every training or policy document that references porch light sales.
Response
Provide a copy of each and every training or policy document that references eavesdropping or privacy.
Response
Provide a copy of each and every training or policy document that references Wis. Stat §968.31
Response
Provide a copy of each and every training or policy document that references 18 U.S. Code § 2511.
Response
Document Request #6: (Abby litigants)
Provide a copy of each and every training or policy document used by Abby Windows from the date of
the alleged staff consent on Rilla to present.
Response
Provide a copy of each and every document between the Abby litigants and Rilla that references any
litigation relative to the case number on this Caption.
Response
2
Provide a copy of each and every document between the Abby litigants and Rilla that contains the name
of any named Defendant in the underlying Verified Complaint
Response
Provide a copy of all correspondence between the Abby Defendants and the Waukesha PD concerning
recording of potential Abby customers.
Response
Provide a copy of all correspondence between the Abby Defendants and the Waukesha District Attorney
concerning recording of potential Abby customers.
Response
Provide a copy of all correspondence between the Abby Defendants and the Pat Studenec or any other
Wisconsin Agriculture/Consumer Protection staffer concerning recording of potential Abby customers.
Response
Under Stipulated Protective Order provide a complete copy of all personnel files for each named
Defendant in the underlying Verified Complaint.
Response
3
Under Stipulated Protective Order provide a complete copy of all personnel files for each named
Defendant in the underlying Verified Complaint.
Response
Under Stipulated Protective Order provide a complete copy of the personnel files for female sales staff
who “Just kinda washed out” as contemplated by Abby Binder’s own words on “The Wealthy Contractor”
https://www.youtube.com/watch?v=9PH3qgQQOms&t
The Wealthy Contractor
190. Know the System Like the Back of Your Hand | Abby Binder
https://www.youtube.com/watch?v=FQEYliCxC4A
Abby was asked about female sales staff:
Q: Do you have any women now that are salespeople?
A: I don't. No they kinda’ all just washed out.....Mandy, my Vice President has been doing most of
the training and came from a sales background so she did most of that.”
Response
4
Under Stipulated Protective Order provide a complete copy of the personnel file for Dylan Helfenstein,
who has been publicly critical of Abby Defendants.
Response
Under Stipulated Protective Order provide a complete copy of the personnel file for James Rosso.
Response
Under Stipulated Protective Order provide a complete copy of the personnel file for Sarah Huber.
Response
To follow up on the email from King to Abby Binder that resulted in a threat from Counsel, provide a
copy of any and all correspondence between the Abby Defendants and the National Association the
Remodeling Industry (NARI) from January 1, 2022 to present.
Response
5
Provide a copy of any and all correspondence between the Abby Defendants and the National Association
the Remodeling Industry (NARI) concerning any complaints or disciplinary action sought by NARI
against the Abby Defendants.
Response
Document Request #20: (Rilla)
Provide a copy of each and every one of your landing pages, indexed by date, that address the legality of
home recording. (Rilla)
Response
Provide a copy of any and all documents that demonstrate how Rilla establishes customer compliance
with 18 U.S. Code § 2511.
Response
Provide a copy of any and all documents that demonstrate how Rilla monitors customer compliance with
18 U.S. Code § 2511.
Response
6
Provide a copy of any and all documents that advise Abby Staff to turn off their Rilla recording when they
exit the primary sales locus inside the home.
Response
Defendant Fred Mayen claims that Abby forced him to forge a signature on the Haumschild file when he
was out of state in order to create a false true-up on a $10K overbilling
WHEREFORE Under Seal or pursuant to Stipulated Protective Order subject to ultimate Decision by the
Court on sealability, provide a complete and unabridged file for the Haumschild client, including any and
all correspondence between Defendant Mayen and the Abby litigants, all billing and each and every
signature that appears in the file.
Response
Provide, indexed by date, a copy of any and all documents that advise Abby Staff to turn off their Rilla
recording when they exit the primary sales locus inside the home.
Response
7
Provide under Seal or pursuant to Stipulated Protective Order subject to ultimate Decision by the Court
on sealability, a copy the entire client and correspondence file with customer Amy O’Donnell.
Response
8
tja@cmlawgroup.com
smc@berensonllp.com
via email

_____________________________________________
9
WAUKESHA COUNTY
STATE OF WISCONSIN
v. ) CASE NO.2024-CV-000820

)
COUNTER-PLAINTIFF KING REVISED FIRST SET OF RULE 804.08 INTERROGATORIES

TO COUNTER-DEFENDANT ABBY DEFENDANTS, RILLA CEO SEBASTIAN JIMENEZ AND
NATIONAL ASSOCIATION OF THE REMODELING INDUSTRY, INC. (NARI).1
Interrogatory #1 (Abby litigants)
In this video:
https://www.youtube.com/watch?v=HNvcTrctAXY
Abby Binder states that the company is struggling with sales staff, to wit:
Q: “What are you worried about the most… what has the most attention of yours this year….”
A: We've been able to get the leads that we need...Getting sales people has been our challenge so
that's kind of my focus right now."
1
NARI will be served at: Elsie Iturralde, 700 Astor Lane, Wheeling, IL 60090-6256
1
As such, under Stipulated Protective Order provide the names, service dates and reason for termination of
employment for all Abby sales staff between January 1, 2021 to present.
Response
Interrogatory #2 (Abby litigants)
In this video
Abby was asked about female sales staff:
Q: Do you have any women now that are salespeople?
A: I don't. No they kinda’ all just washed out.....Mandy, my Vice President has been doing most of
the training and came from a sales background so she did most of that.”
As such, please provide an explanation by what is meant by “washed out.”
Response
Interrogatory #3: (Rilla and Abby litigants)
State the date on which the Abby litigants entered into contract with Rilla.
Response
2
In a Verified Complaint the Abby litigants claim that “Abby Windows’ sales associates sign a consent
agreement upon their first use of the Rilla software..”
As such, please describe how the alleged consent was given, i.e.
a) Was there a consultation with individual staffers and a written signature on paper;
b) Were the alleged consents done via electronic signature?
c) Was Rilla staff present in the room when the alleged consent was given?
Response
State whether Abby litigants and Rilla discussed any privacy or wiretapping concerns pursuant to Wis.
Stat §968.31 or 18 U.S. Code § 2511 in the company’s planning and Rilla rollout.
Response
3
State the date that Rilla published the landing page on its website as it appears on June 23, 2024:
https://www.rilla.com/reports/is-it-legal-to-record-conversations-with-customers-in-the-home
Is it Legal to Record Conversations with Customers in the Home?

(Appendix A)
Interrogatory #7 (Abby litigants).
State whose initial idea it was to produce the following video:
https://www.youtube.com/watch?v=o82uNVuvLgI&t
Response
4
Interrogatory #8: (Abby litigants)
Citing to applicable State or Federal Code that was reviewed prior to filing their Verified Complaint,
identify the nature of each and every alleged Trade Secret or Confidential Disclosure violation that the
Abby litigants contend occurred in any KingCast video.
Response
In light of Abby Binder’s public statement "We finally got them to buy into it...I also told them they
weren't getting any more leads unless they hit record” and given that Riley Richarz “is his own
business” (p. 5 Section 3.4) please cite to the paragraph and sentence of any provision in Riley Richarz’
Contract (Attached as Appendix A) that you could make him incur loss of wage or continuity of
employment opportunity (i.e. “more leads”) if he objected to the mandatory use of Rilla.
Response
Please describe the scenario where Binder read, agreed, signed and witnessed the 3508 Agreement of Mr.
Richarz and what date she witnessed his signature (p. 13).
Response
Identify by Office (and name if possible) every public regulatory or legal Agencies that you contacted
prior to launching Rilla with respect to 18 U.S. Code § 2511 or Wis. Stat §968.31 and the dates of any and
all such communications.
Response
5
Interrogatory #12: (NARI)
State the dates of NARI membership for the Abby litigants.
Response
Interrogatory #13: (NARI)
State whether there were any official hearings conducted before any NARI Tribunals and
a) if the Answer be in the Affirmative provide the dates of any and all such hearings.
Response
State why the Abby litigants did not request a retraction of any alleged written Defamatory
statements issued by King prior to filing the underlying Verified Complaint
Response
State whether the Abby litigants had reviewed any Defamation Law Statutes in Wisconsin prior to
filing the underlying Verified Complaint.
Response
State the date on which April Broughton first notified Abby Binder or Mandy Binder of any
KingCast communications.
Response
6
tja@cmlawgroup.com
smc@berensonllp.com
via email

_____________________________________________
7
Appendix A
Is it Legal to Record Conversations with

Customers in the Home?
Coach your team on how to properly get homeowner consent to record conversations in
the home.
Rilla Team
10
min read
Share
8
You’re a home improvement contractor who wants to track and improve your sales rep
performance.
Luckily for your business, physical ridealongs are no longer the only way to measure and
evaluate performance. Now, you have the option to record their conversations with
customers and ensure they’re following your process and, ultimately, providing the best
customer experience.
Maybe you’re even thinking about getting started with Rilla and hopping on the virtual
ridealong bandwagon.
But there’s one question that inevitably comes up: “Is it legal to record conversations with
homeowners in their home?”
The answer is yes. As long as you do it properly.
One-Party vs All-Party Consent

When it comes to audio recording laws, it’s important to know which states require “one-
party consent” or “all-party consent” to be recorded.
9
One-party consent means that you can record a conversation without the other person’s
consent. This means it’s perfectly legal for your technicians and design consultants to
record their conversations with homeowners. Just keep in mind that there are some
nuances to the individual laws between states.
In all-party consent states, sometimes referred to as two-party consent, you need

the consent of all parties involved in the conversation to record it. In this case, your team
must explicitly obtain consent before recording a conversation.
Most states in the US are one-party consent states. However, for conversations that
happen face-to-face, there are 13 all-party consent states. They include:
• Connecticut
• California
• Delaware
• Florida
• Illinois
• Maryland
• Massachusetts
• Michigan
• Montana
• New Hampshire
• Oregon
• Pennsylvania
• Washington
How to Seamlessly Get Recording Consent from the

Homeowner
Getting recording consent from a homeowner is similar to that of agents at a call center;
there are just a few more steps in the process to cover all your bases.
1. Display a Disclaimer on Your Website
Displaying a disclaimer on your website is one of the first places your customers can learn
about this aspect of your service. Key areas to display the disclaimer on your website
include the privacy policy page, the fine print of a contact page or form, or the confirmation
page after requesting a quote.
If your customers have the option to book in-person appointments directly with your reps
online, add a consent box to your scheduling form.
The text should read: “By clicking here, I understand and agree that my in-person
appointment will be recorded for quality and training purposes.”
10
2. Share the Disclaimer Upon Booking
When the homeowner calls to book their appointment, members of your call center should
be coached to say the disclaimer. This is an opportunity to give the customer a heads up
that both the call and in-person visits are typically recorded.
• Don’t say: “Thank you for calling. This call will be recorded for quality and training
purposes.”
• Say: “Thank you for calling. All of our calls and in-person appointments will be
recorded for quality and training purposes."
Customers are used to hearing that phone calls are recorded, and most are fine with it. But
it’s important to make sure it’s clear that it isn’t just the phone call that will be recorded.
3. Include the Disclaimer in Dispatch Appointment Reminders
In your automated dispatch system, make sure text message and email reminders to
customers include the disclaimer. This is just another step to reassure and reconfirm that
you have consent. You can also use it as an opportunity to let them know you’d be happy
to share the recording after the meeting, if that’s something you want to provide your
customers.
Here are a couple examples to send in dispatch reminders:
• “As a reminder, all of our in-person appointments are recorded to ensure we provide
our customers with the best service.”
• “This meeting will be recorded so we can provide better follow-up service and
coaching to our team. By meeting with our technician, you consent to such
recording. If you do not consent to being recorded, please ask our service rep not to
record.”
4. Have Reps Remind the Homeowner Upon Arrival
After taking the above steps to inform the homeowner, you’re technically safe to record in
the eyes of the law. But, to make sure you’re totally covered–and to win some
transparency/loyalty points with the customer–have your rep repeat the disclaimer to the
homeowner right after they enter the customer’s home.
Here’s what they can say: “Hey Ms. Homeowner, I’m Jake with X Company. Just to remind
you, I’m on a recorded conversation for quality and training purposes. How are you doing
today?”
With Rilla, our users actually track when their reps say the recording disclaimer.
11
Based on our data, more than 99% of homeowners respond positively to the in-person
disclaimer. In fact, we have a large, private equity customer in California, one of the most
privacy-aware states in the US, and they observed that less than 0.2% of appointments
declined being recorded.
As you’ll hear below, homeowners are more than happy for you to record the meetings.
This is especially true when your reps explain the value of recording for security as well as
their own growth and development in the trade.
Your reps also have the option for asking for a signature of consent. This is an extra step,
which isn’t necessary to legally have you covered, but might give your reps and the
customer peace of mind.
And you might even find some like-minded customers who believe in the importance of
recording too. After a funny misunderstanding, the customer in the recording below lets the
rep know that he was also being recorded!
Delighting Customers with Transparency

Many of our customers in one-party consent states still opt to inform the home-owner about
the recording as a way to differentiate their brand.
It sounds something like this: “Hey, here at [company name], we care deeply about the
experience you receive from our team and making sure we stand by our word. While other
shops might try to pull a fast one on you, we record and share our conversations with you
to keep us accountable and deliver the best service.”
Remember, transparency around recordings is good for your business and for the
customer. Think about it, with a recording, the customer knows the sales rep will be held
accountable by their manager. It also keeps everyone on the same page about what was
said during the visit so that there’s no confusion or misleading information.
That’s why most customers see audio recordings as a positive. Plus, increasing
transparency between you and your customers helps increase trust and loyalty, leading to
repeat customers and awesome referrals.
So whether you need one-party or all-party consent, the data is clear: recording your calls
is beneficial for all parties involved.
If you want to learn more about Rilla and take your business to the next level, book a demo
here.
Copied!
12
WAUKESHA COUNTY
STATE OF WISCONSIN
v. ) CASE NO.2024-CV-000820

)
DEFENDANT AND COUNTER-PLAINTIFF KING RULE 908.03 JUDICIAL NOTICE FILING

OF LEARNED TREATISE BY INDUSTRY PROFESSIONAL
THE PRO MODELER
NOW COMES COUNTER-PLAINTIFF KING., to note that some time ago a Good Samaritan
passed a copy of a number of internal training memoranda, policies and training manuals that will come
to play later, but at this point it is crucial for the Court to take Judicial Notice of what a porch light sale is.
This is a seminal understanding that the Court will need as it runs an analysis of facts yet to appear, and
related Discovery Demands will be posited with the Abby Defendants and Rilla to determine what
industry standards and protections are in place relative to Wis. Stat §968.31 or 18 U.S. Code § 2511.
Pro Remodeler: https://www.proremodeler.com/contact-us
https://www.proremodeler.com/blog/porch-light-close
Everyone I know did it, but everyone seemed to call it something different. You may know it, for
instance, as the “porch-light close.” Or maybe the “cigarette close.”
1
It had different names but they all stood for the same thing: a ruse designed to force homeowners
to make up their minds.
Here’s how it works. You’ve been in the house for going on three hours. You’re winding up your
roofing/siding/window presentation. You’ve worn the homeowners down with the heat lamp (to
show how the low-E coating stops ultraviolet light from getting in or heat from getting out) and
the mallet (to demonstrate how shatter-proof the glass is). All that stuff. You sense that they’re on
the fence.
You come up with a final offer and asked for the business. They’re squirming. If they say, “We’ll
think about it,” you can kiss the deal goodbye. If they say, “We’ll be getting back to you,” that’s a
death sentence. You’ve run through six or seven mini-closes, to test the waters. (“So John and
Mary, wouldn’t you agree that this new siding would not only look great on this house, but it’ll
help you sell this house three years from now, when you’re planning to retire?”) They’re on the
hook but they just can’t bring themselves to make a decision.
If You’ll Excuse Me
This is where the porch-light close—or whatever you call it—comes in. I say: “Look, folks, I
know this is a big decision. I’m not a high-pressure guy. If it was me and my wife in your shoes, I
know we’d need some time. We’d absolutely have to think it over. So if you’ll excuse me, I’m
going to go out to put these samples in my car. I’ll just be sitting out on the front porch, so
whenever you’re done, just come and get me.”
I go outside, rummage around in the trunk, play with the radio. This works most of the time. Do
you think they’re going to come running out to tell me no? If after 15 minutes goes by, and
nothing’s happened, I knock on the door. I got so good at it I could tell by whoever answered
whether or not I could just pull out the pen for contract signing or if I was going to go back into
the sale.(Appendix A in full).
********
I. Relevant Background.
Recall that the Abby litigants have specifically advised that Porch Lighting “is still a thing.”
2
********
This becomes relevant for obvious reasons, because on information and belief this is the process
in play with the Abby litigants, as they dropped a YouTube video right after the Counterclaim was filed
and the same day after Counter-Claimant King posted his YouTube video noting that Abby Binder used
Economic Coercion and smiled about it with “Wealthy Contractor” host Brian Kaskavalciyan
Abby Windows & Exteriors | Rilla
3
This was again posted after King posted this video:
As such, any reasonable Trier of Fact could find that Abby and Rilla are running Damage
Control, even as they use expensive SEO/SBO programs to mute people like King and anyone who gets
in their way. Recall that Defendant Riley Richarz has repeatedly stated he objected to Rilla in his
Declaration filed yesterday, June 21, 2024, to wit:
30. When i started selling for her again learning from my mistakes a little bit last time I realized
within 6 months it was even worse than it was when I came back. Not only was the same thing happening
but they had now demanded the use of Rilla or you will not be getting anymore leads; and
31. Just yesterday I saw Defendant/Counterclaim Plaintiff King’s video where she directly admitted
this and there she is laughing about it on “WealthyContractor” with Brian Kaskavalciyan who does not
permit anyone to post negatively about Abby on his YouTube channel; and
32. This is why people like Mr. King as a trained journalist and lawyer are crucial in our society
because he fights for the little people like us against a $12M company. None of us are lying and nobody
has defamed Abby Binder she is reaping what she has sown; and
33. We were definitely trained to leave our electronic devices in the home while we intentionally left
the home and porch lighted. We never were trained to obtain knowing consent from the homeowners
prior to running Rilla; and
34. I argued this multiple times and have proof of them forcing me to use Rilla or I would be fired
and not receive any of my money I was rightfully owed. Any job I ever sold never got takin care of within
a month. I never seen anything as to expenses and certain things pertaining to any of my jobs; and
Counterclaimant King notified Opposing Counsel of his concerns regarding Perjury because the Abby
Clients wrote:
4
On information and belief, industry training manuals do not contain one single admonition about
turning off the Rilla software on exit from the primary sales locus or concern about State or Federal laws
regarding Eavesdropping but King is aware that Rilla changed their landing page recently to address this
matter as we will see in subsequent filings but for now, given this week’s official sponsorship King has
decided to release this information that he was formerly holding in abeyance. Obviously King will be
issuing Discovery/Third Party Discovery/Subpoena Duces Tecum to Rilla CEO Sebastian Jimenez in
short order as it is a seminal issue in the case and King is obviously entitled to it given the Sworn,
Verified Complaint so the World can see what precautions are taken such that Abby can truly claim:
“Abby Windows did not direct its sales personnel to leave any device to record the private
conversations of prospective customers. Any claim to the contrary is false and defamatory.”
5
*******
First of all, given that King has had this information in his possession prior to all of the videos he
clearly had a Good Faith basis to believe that the recordings occur in the absence of the non-consenting
staffers because only a fool would believe that the staffer would pick up the tablet or laptop and take it
outside with them to the car or porch. This Jurist is no fool, nor will he have his intelligence insulted by
Abby litigants or Counsel, enough said.1
May it Please the Court: Rilla is fine as long as there is true consent. With Abby Windows there
is no true consent as clearly noted in Abby Binder’s material 908 Party Admission, so Rilla now has a
video with Abby because they know she's in hot water and they posted a video with her right after
KingCast posted one showing how she had to threaten economic coercion to make staff use it. Further,
the way they employed Rilla was in violation of Federal and State Law as will be proved by Clear and
Convincing Evidence. Further, litigant King knows for fact that Rilla was used inappropriately in two-
party states and the history of modifications to its landing pages will prove rather interesting as well as the
Abby litigants and their industry associates scurry to provide the appearance of propriety, however there
is simply no empirical proof of any attention paid to Federal and State Law. In this more than
Postmodern Day Era we can date ink and papers and Metadata cannot be intrinsically faked so the results
of all of this will set us free.
II. A Special Primer on Defamation.

First of all litigant King actually has successfully sued for Defamation but cannot say
anything more than this other than the fact that it pertained to his Consumer Advocacy. In addition to
several years of successful First Amendment defense cases as seen on KingCast video from time to time.
Next, litigant King, as a Journalist with a First Amendment legal career behind him, convinced
Joanna Marinova’s Attorneys to actually take her case after they had rejected it. King hosted her on his
radio show in Boston as other Journos covered the matter in which the Mass DOC said she was “having
sex with inmates” when coming to visit Darrell Jones. She went on to sue the Boston Herald and a
$570,000.00 Jury Award and $.9M Settlement happened.
1
Well not exactly. There is more to say: The maintenance of this claim in the underlying case clearly gives rise to an
Abuse of Process Claim each and every day of the week. Further, whether Judge Schimel or another Judge hears the
matter pursuant to litigant King’s pending Motion to Recuse, no Jurist on this Bench is a fool, and therefore they
will see that maintenance of this “Claim” at this point in the underlying case is fodder for a legitimate Abuse of
Process Counter-Claim.
6
https://www.youtube.com/watch?v=ZlaHj9QN9yc
https://www.bostonglobe.com/metro/2014/03/19/boston-herald-loses-defamation-suit-boston-woman-
wins-award/jkAUG7qML7IbijdG9tb1UO/story.html
Naturally KingCast ran video of both of these cases with no issue.2
2
Again making the Abby litigants failed attack on Free Press all the more indicative of a completely frivolous
position.
7
https://www.youtube.com/watch?v=l_kb8JS-Lk0
Jones would later be released after 32 years of wrongful imprisonment likely being a patsy for a
bunch of corrupt LE who stole cocaine out of the Evidence Room. King demonstrated that the DA did not
care about the proven fact that the video used in his initial case had been materially altered in a crash edit,
fact.
https://www.youtube.com/watch?v=y8B_vUpmhM4
8
WHEREFORE, pursuant to Rule §908.03 and any and all other Plenary and Penumbral Authority of this
Court, Counter-Claimant King provides this information from an Industry professional as it is essential to
this case in evaluating Actual Malice towards a Limited Purpose Public Figure, to establish whether:
a) The Abby litigants are committing Perjury; and
b) Litigant King had a Good Faith basis in his reporting that Federal and State
Eavesdropping standards were being violated; and
c) Defendant staff had a Good Faith basis for believing that Federal and State
Eavesdropping standards were being violated.3
Respectfully submitted,
______________________
I the undersigned swear that a true copy of this Request was served to
tja@cmlawgroup.com
smc@berensonllp.com
via email

This 23rd Day of June, 2024
_____________________________________________
3
The matter is the subject of vigorous discourse all over the Internet in the past year or so since Rilla came to town.
It is not truly “AI” as they claim, it is simply a recording device backed by millions if not billions of dollars. See
Appendix B.
9
APPENDIX A
This article first appeared in the March 2017 issue of Pro Remodeler.
Everyone I know did it, but everyone seemed to call it something different. You may know it, for
instance, as the “porch-light close.” Or maybe the “cigarette close.”
It had different names but they all stood for the same thing: a ruse designed to force
homeowners to make up their minds.
Here’s how it works. You’ve been in the house for going on three hours. You’re winding up your
roofing/siding/window presentation. You’ve worn the homeowners down with the heat lamp (to
show how the low-E coating stops ultraviolet light from getting in or heat from getting out) and
the mallet (to demonstrate how shatter-proof the glass is). All that stuff. You sense that they’re
on the fence.
You come up with a final offer and asked for the business. They’re squirming. If they say, “We’ll
think about it,” you can kiss the deal goodbye. If they say, “We’ll be getting back to you,” that’s a
death sentence. You’ve run through six or seven mini-closes, to test the waters. (“So John and
Mary, wouldn’t you agree that this new siding would not only look great on this house, but it’ll
help you sell this house three years from now, when you’re planning to retire?”) They’re on the
hook but they just can’t bring themselves to make a decision.
If You’ll Excuse Me
This is where the porch-light close—or whatever you call it—comes in. I say: “Look, folks, I know
this is a big decision. I’m not a high-pressure guy. If it was me and my wife in your shoes, I know
we’d need some time. We’d absolutely have to think it over. So if you’ll excuse me, I’m going to
go out to put these samples in my car. I’ll just be sitting out on the front porch, so whenever
you’re done, just come and get me.”
10
I go outside, rummage around in the trunk, play with the radio. This works most of the time. Do
you think they’re going to come running out to tell me no? If after 15 minutes goes by, and
nothing’s happened, I knock on the door. I got so good at it I could tell by whoever answered
whether or not I could just pull out the pen for contract signing or if I was going to go back into
the sale.
Us or Them
My sales career started in a car lot. The manager there had seen it all and then some. This was in
the days when pricing the car meant you had to work your way up from a base price and
everything else was an upcharge—radio, air conditioning, windshield wipers, the works.
One day a couple came in. We had incredible rapport. I showed them a car and spent time
pricing it out. They said: We’re going to go to a few more places and see what other dealers
have, but we’ll be back. We really want to buy from you, Mike.
The manager watched them driving away.
He says: “Well, that’s the end of them.”
I say: “No, they’re coming back.”
He shook his head.
I said: “I’m telling you, they’re coming back.”
He says: “Kid, they’re not coming back.” He let that sink in for a minute or so and then he said:
“Either you’re selling them, or they’re selling you.”
But then they came back.
We’re there when they appear again in the lot. We’re watching them get out of their car.
He says: “You must’ve forgotten to price something.”
Sure enough, he was dead right.
Facts and a Price
A few years ago, I got to thinking: What if everything I was taught about selling was wrong?
“You want to eat, you’ve got to close.”
“You’ve got to keep them from procrastinating and keep them from shopping.”
Etc.
And all the smoke and mirrors stuff. The lies. The six-hour sales calls. (As a sales manager, my
guys weren’t allowed to leave the house unless they called me.) The way anything they said
became a product benefit: “And what this means to you, John and Mary, is that instead of being
up on a ladder washing windows, you could be out on the golf course ...”
Here’s how I justified it. We just made it emotional. We made it juicy. And we did it the way we
were taught to. They got what they paid for, right? I showed them a banana and described the
banana. They bought it, peeled it, ate it, and it tasted good. The homeowner got a remodeling
job. That’s not theft, it’s commerce.
11
But whatever label you want to put on it, the number of people willing to buy that way is
becoming fewer and fewer, and older and older. The young don’t fall for any of this. The
information revolution has inoculated them against it.
Today, homeowners want a price. They want facts and they want a reliable company to do their
job. If you can walk in and provide those things, you have a chance of selling a job.
The old way? Forget it. Especially if those homeowners are under 40. Try telling them you need
to put some stuff in the car while they come to an agreement. The agreement they’re most likely
to reach is that that under no circumstances are you getting back in their house.
12
13
14
Case 2024CV000820 Document 72 Filed 06-21-2024 Page 1 of 1
FILED
06-21-2024
Clerk of Circuit Court
BY THE COURT:
Waukesha County
DATE SIGNED: June 21, 2024 2024CV000820
Electronically signed by Brad D. Schimel

Circuit Court Judge
STATE OF WISCONSIN CIRCUIT COURT WAUKESHA COUNTY

BRANCH 6
Abby Windows, LLC, COURT ORDER

Plaintiffs,
vs.
Case No. 24CV820
Christopher King et al
Defendants.
WHEREAS The Defendant, Christopher King, submitted a letter regarding media coverage on
06/19/2024. Upon review of the letter by the Honorable Brad Schimel on 06/21/2024, the Court orders the
following:
IT IS HEREBY ORDERED
All media personnel who wish to cover any present and future scheduled hearings in the above case
must contact the Waukesha County Media Coordinator before each hearing.
Any parties to the case are not permitted to record the proceedings themselves.
The Court reminds the parties that under Local Rules, all substantive hearings are to be held in person at
the Waukesha County Courthouse.

WAUKESHA COUNTY
STATE OF WISCONSIN
Plaintiffs, )
v. ) CASE NO.2024-CV-000820

)
Defendants.
DECLARATION OF RILEY RICHARZ IN SUPPORT OF COUNTER-COMPLAINT

OF CHRISTOPHER KING, J.D.
NOW COMES DEFENDANT COUNTER-PLAINTIFF CHRISTOPHER KING, J.D., to

provide a copy of the Declaration of Riley Richarz, accompanied by an email from his father
Jack Richarz as former staffer to the Abby litigants some time ago. The documents speak for
themselves.
________________________
1
I the undersigned swear that a true copy of this Declaration was served to
tja@cmlawgroup.com
smc@berensonllp.com
via email

This 21st Day of June, 2024
_____________________________________________
2
---------- Forwarded message ---------
From: Jack Richarz <jack@abbywindows.com>
Date: Mon, Jan 10, 2022 at 4:09 PM
Subject: 2022
To: Abby Windows and Exteriors <abby@abbywindows.com>
Hi Abby, after a long and struggling time with what is going on and how I was valued with you, I have no desire to be
a project manager or accept either proposals. I was your roofing department, handling your sales team, ordering,
scheduling, taking all phone calls, selling, meeting customers, handling customers, being a runner when needed, and
cleaning job sites. Oh yes, I also handled all repairs, skylights, rubber roofs, metal roofing, and scheduling for 1 to 2
workers for the small jobs or repairs. Even helped on siding jobs when needed. Pretty much all gutter jobs were also
handled by me. I have brought 20 plus years of experience in this last year and basically gave you a full roofing
department. I know pretty much everything and anything that comes up in the industry, and if I don't have the
answer, I have the right connections that can give me the answer we are looking for. I also bring all the crews and
working relationships that are required to do any of these jobs. It doesn't matter if you are a 1 million dollar company
or a 10 million dollar company. I have given your company my full attention, ran, and treated it like it was my
own. You went from maybe 200k in Roofing a year ago to almost 1.1 million in 8 months. Your advertising just
started and will take time to be known as having a roofing company. I would say most people think of you as a
Window Company and have no idea that you can do roofs. You keep saying you are paying me $3,800 per roof
which makes no sense. We did 54 roofs with Warranties, we did roughly 65 to 70 total roofs, as well as all the other
jobs that I managed so to keep saying this is not even close to being fair on what I did all year. Everything on your
JOB Description Sheet is exactly what I did except for the new information that we didn't have in place such as the
entire first line. I would also like to know when I missed any scheduled appointments with you, and if I did I am
guessing I was in God's country starting or finishing a job? Anyways, I feel that I earned exactly what I was paid and
as I said long before I am not looking to go backwards. I do understand all the risk you are taking however, we now
have a base number where the roofing department needs to be. I don't think after 1 year of a full roofing department
you can say you should be making X amount of money? At the very minimum you can say 1 million is a break even
point for you. Fyi additional money not included in these totals is all the returns as well or the inventory that is still in
the shop. For the matter of jobs being sold at $385 per square I believe is ridiculous and no idea what job that was
and how that job was broken down? I believe at some point throughout the year either you, mandy, or tj would have
gone through a breakdown process of each job or what you might be adding in the breakdown and would have
included me? As shown in every breakdown that is on the drive that I did and inputting all numbers on the
spreadsheet shared with you, are the numbers real numbers?
My request for pay is a base pay of $??????? for 1.1 million dollars in work completed and collected. This is
obviously a $50,000.00 risk for me to get to 1.5 million so I can get paid in full. I believe now that we both have skin
in the game. This would include any jobs, roofing, gutters, soffit and fascia, attic insulation, rubber roofs,
basically everything I am managing. If I manage anything more than 1.5 million, I receive a 4% bonus of the total
amount installed. This job is not an 8 to 4 job, I don't believe sales personnel will ever stop calling or asking
questions nor should they, and I don't believe tj knows all or knows more then me to answer all questions. Example,
Grasshopper's phone has been answered by me the last 2 weeks, numerous sales phone calls have been answered
and all while I am not getting paid. As I stated 14 months ago, I want to be a part of growing your roofing department,
into a multi million dollar department and something that I treat as my own. With that being said, I also expect to be
paid fairly.
Also after talking to all kinds of people about what is fair, position, connections, your hands on, and life in general,
your bonus structure is unachievable and would never be reached by 1 project manager. The most jobs a project
manager can handle with great relationships and with building a long lasting relationship that should be done is from
150 to 200. This is from 2 of the largest roofing companies in our area.
I guess the bottom line is, am I worth ???? for bringing in 1.5 Million and having a quality roofing department that you
are hands free from or as much hands on you want to put on, except for advertising? Not to mention having
someone in your corner that is more than capable of doing it all and treats your company like his own. Either way I
am good with your decision. Please take your time to make your decision as I will not start back up until January 24th
as I am in Hawaii all next week.
Thank you
Jack
WAUKESHA COUNTY
STATE OF WISCONSIN
Plaintiffs, )
v. ) CASE NO.2024-CV-000820

)
Defendants.

Steven Couch, Esq.
__________________________
JUDGE
1
WAUKESHA COUNTY
STATE OF WISCONSIN
Plaintiffs, )
v. ) CASE NO.2024-CV-000820

)
Defendants.
NOTICE OF MOTION AND JOINT MOTION OF DEFENDANT COUNTER-

PLAINTIFF KING AND PLAINTIFFS COUNTER-DEFENDANTS ABBY WINDOWS
LLC FOR SHOW CAUSE HEARING ON SERVICE OF PROCESS FRAUD1
NOW COME DEFENDANT COUNTER-PLAINTIFF CHRISTOPHER KING, J.D.,

AND PLAINTIFFS ABBY WINDOWS et al., LLC to note that litigant King provided
information sufficient to place Counsel for the Abby litigants on Actual Notice of potential Fraud
involving Service of Process in this case.
All Parties and Counsel would like to fully evaluate this matter as Service of Process on
any litigant is of paramount importance, and the integrity of same must be maintained.
WHEREFORE Counsel for litigant King (proceeding Pro Per) and Counsel for the Abby
litigants hereby affix their signatures hereto in joint support of an immediate hearing on this
matter. The Court must exercise its inherent authority to Order an Evidentiary Show Cause
Hearing to be attended by the following:

Hoosier Process Service or authorized representative
Steven Couch, Esq.
1
The Parties acknowledge that a Motion to Recuse Judge Schimel is pending and will await further instruction from
the Court on that matter.
1
Respectfully submitted and agreed,
________________________
_________________________
_________________________
Steven Couch, Esq.
2
WAUKESHA COUNTY
STATE OF WISCONSIN
Plaintiffs, )
v. ) CASE NO.2024-CV-000820

)
Defendants.

Steven Couch, Esq.
__________________________
JUDGE
1
"We finally got them to buy into it...I also told them they weren't getting any more leads unless they hit
record."
The forced compliance with Rilla, and the method in which it is employed is obviously a seminal
issue in this case. As such, Abby Binder’s statement is clearly a Party Admission. The Rule
reads, in pertinent part:
908.01 Definitions. The following definitions apply under this chapter:

(1) STATEMENT. A “statement" is (a) an oral or written assertion or (b) nonverbal conduct of a
person, if it is intended by the person as an assertion.
(2) DECLARANT. A “declarant" is a person who makes a statement.
(4) STATEMENTS WHICH ARE NOT HEARSAY. A statement is not hearsay if:
(b) Admission by party opponent. The statement is offered against a party and is:
1. The party's own statement, in either the party's individual or a representative capacity, or
2. A statement of which the party has manifested the party's adoption or belief in its truth, or
3. A statement by a person authorized by the party to make a statement concerning the subject, or
4. A statement by the party's agent or servant concerning a matter within the scope of the agent's
or servant's agency or employment, made during the existence of the relationship, or…..
2
Just to make it clear that consent is a material issue recall Riley Richarz’ communications to
Abby, “As far as Rilla goes I never consented to use it – you all forced me to use it with threat of
termination.”1
The Statement uttered online by someone who is obviously Abby Binder, is noticeable.
Judicial Notice of Facts on the Internet. Appellate courts have increasingly cited information
found on the Internet, often with less care than they should. As with hard-copy publications,
courts are most willing to take judicial notice of information found on government Web sites,
such as the time of sunrise found on the Web site of the U.S. Naval Observatory [U.S. v.
Bervaldi, 226 F.3d 1256, 1266 n.9 [11th Cir. 2000]]; the prime interest rate on the Federal
Reserve Board Web site [Levan v. Capital Cities/ABC Inc., 190 F.3d 1230, 1235 n.12 [11th Cir.
1999]]; and records of retired military personnel on a federal Web site [Denius, 330 F.3d at 926].
Courts have, however, also been willing to take judicial notice of information on arguably less
reliable commercial Internet sites, including mileage information on Mapquest [In re Extradition
of Gonzalez, 52 F. Supp. 2d 725, 731 n.12 [W.D. La. 1999]]; historical information on Liberia on
1
Litigant King will soon provide the Court with Sworn Statements from Riley Richarz and from Jack Richarz, also
a former employee with Abby who took extreme exception to the way he was treated.
3
the “Geocities” Web site [Bridgeway Corp. v. Citibank, 45 F. Supp. 2d 276, 278 n.2 [S.D.N.Y.
1999]]; and information regarding a bank’s ownership from the bank’s Web site [see Laborers’
Pension Fund v. Blackmore Sewer Constr. Inc., 298 F.3d 600, 607 [7th Cir. 2002]]
This is also crucial for staff because they could be held liable for violating Federal
Wiretap and State laws as previously noted. See FTC v. Amy Travel, 875 F.2d 564 (7th Cir.
1989)(Holding individuals liable under the FTC Act for deceptive practices of a corporation
where those individuals had knowledge of the deceptive practices and participated directly in
those practices or had authority to control them).
******
This case chiefly involves a set of allegedly progressive owners of Abby Windows ad their
abusive actions, including surreptitious recording of unwitting homeowners. Again, we are here
before the Court so that the public can have attendance at a case that involves matters of extreme
public interest, i.e. the surreptitious recording in their own homes, and predatory business
practices. In so doing there will be an analysis set forward by Hawken School’s Professor
Pickering, again “What is truth… What is worth knowing…. How do we go about making value
judgments.”
______________________
4
I the undersigned swear that a true copy of this Notice was served to
tja@cmlawgroup.com
smc@berensonllp.com
via email

_____________________________________________
5
FILED
06-19-2024
BY THE COURT:
Waukesha County
Electronically signed by Brad D. Schimel

Circuit Court Judge

BRANCH 6
Abby Windows, LLC et al BRIEFING SCHEDULE

Plaintiffs, ORDER
vs.
Case No. 2024CV820
Christopher King et al
Defendant.
This matter is set for a Motion Hearing on 08/21/2024 at 8:30am, to address the Notice of Media
Coverage before the Honorable Brad D. Schimel.
IT IS HEREBY ORDERED
Responding Party has until (07/22/2024) (30 calendar days prior to the Motion Hearing) to serve and
file a responsive brief and supporting documents, or waiver in writing to the Notice of Media Coverage.
Movant has 10 calendar days from service of a responsive brief and supporting documents to serve and
file a reply brief limited to matters in reply to the responsive brief to the Notice of Media Coverage.**
WAUKESHA COUNTY
STATE OF WISCONSIN
Plaintiffs, )
v. ) CASE NO.2024-CV-000820

)
Defendants.
REQUEST FOR CLARIFICATION ON COURT ORDER

REGARDING SCR §61 MEDIA COVERAGE
NOW COMES DEFENDANT CHRISTOPHER KING, J.D., to seek clarification on

whether the scheduled hearing on the Notice of Media coverage will be covered on KingCast
video as well. By this Reporter’s experience a denial of such coverage of the hearing itself could
constitute unlawful Prior Restraint on a Free Press. At a minimum Defendant Counter-Claimant
King would hope that he be permitted to run the video of the hearing pending a ruling. This way
the recording could be held in abeyance pending any Appeals.
As publicly noted litigant King is no stranger to these matters, see pp. 4-6, infra.
Court orders briefing.
https://www.scribd.com/document/741642775/Abby-Windows-gets-hit-with-Abuse-of-
Process-Counterclaim-by-Journalist-in-5-Staffer-Defamation-Case
I don't know what wabbit they intend to pull out of their hats to prevent video coverage
of a case involving surreptitious audio recordings of homeowners against someone who
has already professionally run video in Wisconsin but we shall see... Fortunately I have
some precedent on my side. Another Lawyer of the Year (who also secured a huge verdict
in an infrastructure collapse) fought me and a friend of mine on related issues right, a
Gag Order right, and guess who won. You already know:
https://dennerlaw.blogspot.com/2008/12/unconstitutional-court-order-that-tries.html
Abby has to learn -- with assistance from the Court -- that you can't ban speech just
because you don't like it.
1
In a First Amendment/Academic/Free Press context the fact that people may be offended
by speech or news coverage is completely irrelevant to the discourse as His Honor aptly noted in
his Amicus Brief in McAdams v. Marquette, 2018 WI 88 (2018).
The principle of academic freedom—that teachers and scholars should be “protect[ed] . . .
from hazards that tend to prevent [them] from meeting [their] obligations in the pursuit of
truth”—is fundamental to the Western and American tradition. Russell Kirk, Academic
Freedom: An Essay in Definition 1, 139 (1955) (quotation marks omitted). Martin Luther
King, Jr., traced its history back to Socrates. Martin Luther King, Jr., “Letter from
Birmingham Jail” (Apr. 16, 1963), in Martin Luther King, Jr., The Autobiography of
Martin Luther King, Jr. 194 (1998).
….[C]ourts and respected jurists across the country agree that the core of constitutional
academic freedom is the right of faculty “to disseminate publicly [their] views as . . .
teacher[s] or scholar[s].” Omosegbon v. Wells, 335 F.3d 668, 677 (7th Cir. 2003); see
Wagner v. Jones, 664 F.3d 259, 269 (8th Cir. 2011); Urofsky v. Gilmore, 216 F.3d 401,
435 (4th Cir. 2000) (Wilkinson, C.J., concurring in the judgment); cf. Emergency Coal. to
Defend Educ. Travel v. U.S. Dep’t of the Treasury, 545 F.3d 4, 15 (D.C. Cir. 2008)
(Edwards, J., concurring). The defense of this right is especially urgent when such views
“fall outside the mainstream.” Rodriguez v. Maricopa Cnty. Cmty. Coll. Dist., 605 F.3d
703, 708 (9th Cir. 2010). After all, “intellectual advancement has traditionally progressed
through disc[ord and dissent, as a diversity of views ensures that ideas survive because
they are correct, not because they are popular.” Id. Universities— “sheltered from the
currents of popular opinion by tradition, geography, tenure and monetary endowments—
have historically fostered that exchange. But that role in our society will not survive if
certain points of view may be declared beyond the pale.”
More on this during the formal briefing process but the analysis is the same for the Free
Press as it is with Academia, any distinction is a distinction without difference.1
The Supreme Court concurred and sided with Dr. McAdams:
Dr. McAdams commented that Instructor Abbate employed "a tactic typical among
liberals now," namely that "[o]pinions with which they disagree are not merely wrong,
and are not to be argued against on their merits, but are deemed 'offensive' and need to be
shut up."
1
Coincidentally Litigant King authored his Undergraduate Thesis using “Letter from a Birmingham Jail.”
2
That is precisely the modus operandi of the Abby litigants as seen time and time again; it
is not even up for debate. Everything they disagree with, call the lawyers, threaten and SUE.
This case chiefly involves a set of allegedly progressive owners of Abby Windows ad their
abusive actions, including surreptitious recording of unwitting homeowners. Again, we are here
before the Court so that the public can have attendance at a case that involves matters of extreme
public interest, i.e. the surreptitious recording in their own homes, and predatory business
practices. In so doing there will be an analysis set forward by Hawken School’s Professor
Pickering, again “What is truth… What is worth knowing…. How do we go about making value
judgments.
https://www.youtube.com/watch?v=FC9R86Wd840
3
4
5
6
______________________
I the undersigned swear that a true copy of this Request for Clarification was served to
tja@cmlawgroup.com
smc@berensonllp.com
via email

_____________________________________________
7
WAUKESHA COUNTY
STATE OF WISCONSIN
Plaintiffs, )
v. ) CASE NO.2024-CV-000820

)
Defendants.
RESPONSE TO ABBY LITIGANTS’ INFORMAL LETTER TO COURT
REGARDING SCR §61 MEDIA COVERAGE
NOW COMES DEFENDANT CHRISTOPHER KING, J.D., to note that he is in receipt
of an informal letter from Abby Counsel (Dkt. 59) in which he seeks a hearing on the Notice of
Media Coverage. See Appendix A. There is no specific area of concern noted in the letter
whatsoever. Litigant King has provided a media CV and Notice1 well beyond that of most
videographers who come before this Court and has even afforded the Abby litigants disclosure of
Expert Witness Evan Wright as a courtesy in the event that the case proceeds into Discovery.2
There being no stated reason for a requested hearing litigant King finds no reason for any
such hearing; he and his crew as selected will simply follow the Court directives given at any
live hearing as he has done for the past thirty (30)+ years, no different than any other media that
comes before this Honorable Court.
We are here before the Court so that the public can have attendance at a case that involves
matters of extreme public interest, i.e. the surreptitious recording in their own homes, and
predatory business practices. In so doing there will be an analysis set forward by Hawken
School’s Professor Pickering, again “What is truth… What is worth knowing…. How do we go
about making value judgments.”
1
Abby litigants refer to the Notice as a Motion. It is only a Motion if other Media have to file a Motion. Otherwise it
is what it is called, a Notice.
2
Naturally the Notice of Media Coverage also contemplates the pending First Amended Counterclaim as well.
1
Jack Pickering, circa 1967ish
KingCast, 2018
______________________
2
FILED
06-18-2024
Waukesha County
2024CV000820
1601 EAST RACINE AVENUE STE 200

APPENDIX A POST OFFICE BOX 558
WAUKESHA, WISCONSIN 53187-0558
Timothy J. Andringa TELEPHONE (262) 542-4278
FACSIMILE (262) 542-4270
tja@cmlawgroup.com
www.cmlawgroup.com
June 18, 2024
VIA ELECTRONIC FILING
Honorable Brad D. Schimel

Waukesha County Courthouse
515 W. Moreland Blvd.
Waukesha, WI53188
Re: Abby Windows, LLC et al v. Christopher King, et al.

Waukesha Count Case No. 2024CV0820
Dear Judge Schimel:
The Plaintiffs are in receipt of Defendant, Christopher King’s “Notice of SER § 61 Media
Coverage” apparent motion (Dkt. 51) and additional supplements filed thereafter.
Plaintiffs, if necessary, wish to be heard on this motion. We ask that if the Court is going to
entertain this motion, that the matter be heard and briefed prior to the Motion to Dismiss hearing
set for August 21, 2024 at 8:30 a.m.
Thank you for your anticipated prompt response with respect to this matter.
Respectfully,
/s/ Timothy J. Andringa
Timothy J. Andringa
Managing Partner
TJA:ac
cc: Christopher King (via efiling)

Taylor Stepniewski (via email: taylorstepniewski@icloud.com)
Michaele Campbell (via email: memikkic123@gmail.com)
Riley Richarz (via email: riley_rich@aol.com; riley@sportslipgrip.com)
Fred Mayen (via email: fmayen00@gmail.com)
Jason Crismond (via US Mail)
I the undersigned swear that a true copy of this Supplemental Notice was served to
tja@cmlawgroup.com
smc@berensonllp.com
via email

_____________________________________________
3
WAUKESHA COUNTY
STATE OF WISCONSIN
v. ) CASE NO.2024-CV-000820

)
FIRST AMENDED RULE §2620 ABUSE OF PROCESS COUNTERCLAIM

OF DEFENDANT CHRISTOPHER KING, J.D WITH JURY DEMAND1
NOW COMES DEFENDANT CHRISTOPHER KING, J.D., without waiving any

Defenses or Jurisdictional challenges, to file this Counterclaim.
Plaintiff Abby Binder owns Abby Windows, LLC. She is a Limited Purpose Public
Figure with scores of YouTube videos and other online publications and with substantial
advertising on various news stations including Fox6, which to date has refused to run any stories
about Abby Windows in spite of the fact that Defendant King knows former staff and customers
have written Fox 6 with distinct valid issues. See generally Ben Bagdikian “The Media
Monopoly” and “The New Media Monopoly,” and Robert McChesney “Rich Media, Poor
Democracy.”
Defendant King is a professional Journalist. He studied newswriting and rhetoric in
undergrad under Steven Depoe, whose background includes teaching courses in Environmental
Communication, Communication and Sport, Rhetoric of Social Movements, Rhetorical Research
Methods, and Advanced Rhetorical Theory. From that point he edited the Cincinnati Edition of
1
This Amended Document chiefly corrects a scrivenor’s error re: “counter” vs. “cross” Plaintiff with other minor
edits. Defendant King is using limited evidence in this Motion to stick to items that Plaintiff was aware of prior to
publication of the second and subsequent videos to which Plaintiff takes exception.
1
the statewide Ohio Call & Post and wrote as general beat reporter for the Indianapolis Star prior
to law school. In law school he studied First Amendment and Journalism under William P.
Marshall, who served as Deputy Communications Counsel to President Clinton. After law school
he was the first non-corporate entity to receive a formal press pass from the Massachusetts
Supreme Judicial Court and he received Mayoral Commendation from the City of Nashua for
many reasons, including changing First Amendment policy at the School Board. He has a
dedicated history of helping homeowners, including registration as a homeowner advocate in the
Washington State Foreclosure Fairness Program. He broadcast online videos prior to the
existence of YouTube and his YouTube channel has 1,700 videos and 7,780 subscribers. He has
shot courtroom video in six (6) states without any admonishment whatsoever except the time he
inquired of Wisconsin Hearing Officer James Winiarski why he did not reprimand Attorney
Mark Rattan for “approaching [me] in an angry and threatening manner in violation of a standing
Order.” https://www.youtube.com/watch?v=xmYatdpIlSU2
In spring, 2024 Defendant King was approached by several former staff at Abby
Windows. They informed him of their own allegations of abusive employment practices and
false, deceptive and abusive consumer practices including but not limited to the ordered
fabrication of fake online reviews, inflated prices and price gouging, mean-spirited treatment of
customers who filed complaints, unlawful delays in production and more.
2
Rattan is not technically a Wells Fargo Attorney I believe he was an affiliate for individual representation of a
Wells Fargo staffer, whatever the guy basically assaulted me and got away with it.
2
The first things to know is that Record Evidence can be provided that will show that
Officers of this company encourages surreptitious recording of unsuspecting home owners in the
absence of sales staff, commits contract fraud with fake customer signatures to change quantity
to true up accounts, pays staff to provide fake online customer reviews using Abby Staff and
families (never disputed), and threatens extortion and/or uses economic incentives to convince
customers to take down negative reviews. The threat to customer Amy O’Donnell – who along
with Abby Staff has reached out to Fox6 News – alone is enough to get Abby’s BBB
Accreditation revoked according to SEO and online consumer expert Jason Brown. See also the
National Association of the Remodeling Industry (NARI) reference at p. 11 because Defendant
King has reason to believe that Plaintiff lost its membership there for False and Deceptive
Business Practices, all of which weighs heavily on this case:
Discovery will reveal that Counter-Defendants intentionally direct staff to leave a Rilla
software recording device running while they leave the interior of the home, thereby rendering
any purported consent nugatory. Appendix A, forthcoming.3 That’s not all: Many staffers have
told Counter-Plaintiff King that they do not want to use Rilla software, and that they are forced
to do so out of economic coercion, an issue that an industry expert finds highly questionable, see
Appendix B.
Here is what we do know: Online advertising expert Jason Brown, who has worked with
the State of Wisconsin on prior occasion in a directly-related case:
https://www.tmj4.com/news/i-team/fake-online-reviews-may-be-fooling-wisconsin-consumers
Fake online reviews may be fooling Wisconsin consumers
………..concurs with Defendants that it is a questionable practice; this is why he wrote WISN
Reporter Erica Finke just as Defendant King wrote other “news” stations. Brown said, he said:
From: Jason Brown
Subject: Abby Windows and Exteriors
Date: May 29, 2024 at 6:01:15 PM PDT
To: Erica.Finke@hearst.com
Cc: kingcast955@icloud.com
Erica,
3
Defendant Counter-Plaintiff will provide the materials in a few weeks as soon as Abby Windows and Counsel
double down on their Verified Complaint in this regard. As soon as that happens Defendant Counter-Plaintiff King
will prove the Abby Plaintiffs Counter-Defendants are lying to the Court. The only question that will remain at such
point is plausible deniability on the part of Abby Counsel, who have been put on Actual Notice of their Candor to
the Tribunal responsibilities.
3
Please meet Mr. Christopher King. He emailed about issues with Abby Windows and
Exteriors in Waukesha. He created this video on YouTube. This is a smaller version of
Landmark Recovery. Mr. King highlights how the company hired a law firm to
request customers to delete negative social media posts to receive a refund. The company
emailed in January 2023 asking employees to create and post fake reviews. They also
recorded customer conversations without them knowing. Sadly, Wisconsin is a one-part
state, meaning that as long as one party in the conversation knows the call is
being recorded, the other party doesn't need to know.
Mr. King brings up an interesting legal argument: Is this consent if the employee is
forced to turn on the recording feature? (emphasis added for clarity)
Mr. King also highlighted issues with employees not being paid properly or being
informed of their pay structure while consumers were overcharged and ripped off.
I hope you can look into this matter.

Jason Brown
http://reviewfraud.org
Plaintiff Counter-Defendant is a company that employes false and deceptive practices

seen at Appendix C with more to follow. It is these facts that Counter-Defendants are seeking to
suppress, which is an impermissible reason for litigation, and criminal acts are indeed involved
pursuant to Wis. Stat §968.31. Defendant Counter-Plaintiff King has studied related matters for
the past thirty four (34) years since he wrote a related feature below in the 1990 Indianapolis
Star:
4
II. The Actual Motivation for the Underlying Case is an Impermissible Motive.
In her professional life Abby Binder is an abusive and threatening person, at least in the
last several years of it according to those closest to her. For proof of this look no further than
Appendix C, supra “Play Hard Play Dirty” and her response to an innocent homeowner who can
no longer talk (subject to subpoena for which she will gladly comply):
The real reason for this litigation – suing five (5) former staffers and a Journalist – is not
to address Defamatory statements, of which none were made. The real reason is to crush dissent,
by a company that actually has sales contracts that forbid staff to earn their back-end checks if
they were no longer employed with the company. The company then keeps this money, making
it Unjustly-Enriched. Staffers will explain Under Oath about underhanded pricing schemes,
5
illegal customer authorizations, overpriced low-quality materials, management refusing to
address customer complaints and more. The following are a few examples that demonstrate the
truth abusive nature of this litigation, which is based largely on a video substantially identical to
this one:
A. Abby Litigants’ Rule of Completeness Violation is Indicative of Improper Intent and

Misuse of Process .
Plaintiffs intentionally left off the entire email chain from Litigant King not once but twice in
their Verified Complaint, a violation of Statute. Wis. Stat §901.07.
https://docs.legis.wisconsin.gov/statutes/statutes/901/07
i. On one occasion this was done with the intent to mislead the Court as to the
opportunity that Defendant truly gave Abby to respond to his reasonable inquiries.
There were seven (7) emails and two (2) or more phone calls made to them that went
without response, a common knowledge that former staff (some subject to suit and
some not) told Defendant King that Abby never responds to anything negative, and
when she does there is a record of her threatening an innocent homeowner with
Extortion because she would not [retract her negative online review].
ii. The second time Defendant King accused them of tampering with my online privacy;
spamming and missing folders. Defendant King received about 80 emails involving
identity theft and trader online car sales. It is still not clear that no one from Abby did
this, but more importantly Defendant King wrote back that day in the same
email without a request for retraction where he qualified the statement by stating that
he would apologize if someone from Abby was not responsible. Given Plaintiff's
Penchant for fake Internet schemes and other abusive tactics it's hardly a reach to
think that they might have been involved. Appendix D.
6
B. All Claims Concerning any Written Materials Were Filed in Direct Violation
Of Wis. Stat §895.05(2) and are Indicative of Improper Intent and Misuse of Process.
Plaintiffs attempt to base several claims on written purported Defamation without seeking
Retraction. This is a patent violation of Statute. Wis. Stat §895.05(2) and shows that the true
motive for this case is nothing more than retaliatory abuse for exposing the dirt on the Abby
litigants. See https://docs.legis.wisconsin.gov/statutes/statutes/895/i/05
Plaintiffs identified the following alleged issues in their Verified Complaint.
i.. The Written Sperm Incidents.4
Defendant King republished a portion of Defendant Richarz’ Demand Letter.
In addition to forcing me and others to illegally record homeowners under threat of

termination (coercion according to State regulations below) there were requests made of
me for my semen for Abby to have a child with her partner Mandy while I was employed
by the company.
ii. The Allegations of Tampering with Equipment.
Defendant King issued the following written statement after he was spammed and folders
went missing on his computer:
To All,
Yeahh.... I'm missing about 9 folders and things out of other folders.... can't communicate
on my macbook with Taylor.... Riley Richarz' folder had but two (2) items in it this
morning until I downloaded the Demand Letter he sent to
the "snake in the grass" Abby: https://www.scribd.com/document/727945642/KingCast-
Fields-Allegations-of- Widespread-Elder-Abuse-and-Illegal-Eavesdropping-by-Window-
Companies- AbbyWindows
I will get you dirty PoS (Princesses of Slime).
And oh yeah... I've got backups of my zoom with him anyway you motherfuckers. Video
coming later today so to hell with you and your dirty-assed company. You took working
files and a bunch of stuff all because I am telling the truth about your company.
4
The Abby litigants have been in possession of a written statement from the fiancée of a former staffer who directly
specified some of the occasions she specifically witnessed in which the Abby litigants (and wife) raised the issue of
sperm from Riley Richarz and/or his father, yet they maintain their position that none of this happened, which is
ridiculous. Nobody makes that up and puts themselves in the line of fire against a $12M company. Appendix B.
7
Next video title: Cruel Abusive Women Demand Cum from Male Worker Bee
You do indeed "Play Hard and Play Dirty" as you say but I got something for ya. And not
it's not a physical threat from a Dangerous Black Man. I'm on dangerous because I'm
adept at exposing your bullshit.
iii. The Elder Black Matriarch.
Defendant King wrote:
An Elder Matriarch is in love with these people even as they silently rob her blind
with already inflated charges and another $1K bump for no lawful reason
whatsoever. In this dirty industry it is known as face punching. “I punched that old lady
right in the face” was heard at another company for example.
[* * *]
They would not know the truth if it walked up and slapped them in the face.
iv. Public Participation Emails to State Staff:
Dear Attorney Opper and State Representative Callahan;
I write you as a former AAG and lifetime Journalist to inform you of some patently False
and Deceptive Consumer practices by Abby Windows and Exteriors.
https://www.scribd.com/document/727945642/KingCast-Fields-Allegations-of-
Widespread-Elder-Abuse-and-Illegal-Eavesdropping-by-Window-Companies-
AbbyWindows
Multiple staffers have directly informed me that they price gouge, issue materially false
customer reviews, misclassify employees and illegally record customers while in the
commission of overcharging them to boot, which arguably wobbles this into Felony
status as I note in my commentary in the Abby video below.
[* * *]
Somewhere in all of this I am certain that your office has jurisdiction to commence a
thorough investigation, working with IRS/Department of Treasury, Agriculture and other
agencies seeing as the IRS/Treasure Department has already dinged them on
misclassification. [...]
8
I can put you in touch with many former employees who will take a polygraph and offer
other verifiable information for your office. They will no doubt try to blame me or the
many staffers who dare to speak the truth but none of us are having one scintilla of
THAT. They did the actions, they suffer the consequences and sadly their customers are
suffering as well.
Warm regards, Christopher King, JD
[* * *]
PS: I have spoken with Patrick Studenec on this and he felt in large part that his hands
were tied but in reality I have just given you proof that these people surreptitiously record
homeowners and when they leave the room there is a clear cut violation there even in a
one party state. IMO the legislators have to get busy to modify the law when it comes to
commercial recordings at a consumer home, where they have a complete expectation of
privacy right. Contrast State v. Riley, 2005 WI App 203, 287 (2005). His agency has
recently noted for example that Home Improvement is the #3 claim in his office right
now and this is certainly part of it.
Plaintiffs’ claim i, ii and iii to be Defamatory and that iv is essentially defamatory as it

is based on allegedly Defamatory statements. It is ultimately doubtful that any of these
statements are actually Defamatory for numerous reasons but we need not even analyze this
frivolous and failed claim because there was no adherence to Statute, period and end of story.
See Hucko v. Jos. Schlitz Brewing Co., 302 NW 2d 68 - Wis: Court of Appeals 1981
and Schultz v. Sykes, 638 NW 2d 604 - Wis: Court of Appeals 2001:
We agree with ALI that it was not required to request a retraction from Sykes because his
statements were not made in print. See It's in the Cards, Inc. v. Fuschetto, 193 Wis. 2d
429, 436, 535 N.W.2d 11 (Ct. App. 1995) (holding that notice requirement of WIS.
STAT. § 895.05(2) applies only to libel made in print). We do not agree, however, that
we are precluded from considering ALI's failure to make the request with respect to the
Journal Sentinel because the Journal Sentinel failed to raise the issue in the circuit court.
Failure to request a retraction under WIS. STAT. § 895.05(2) is not an affirmative
defense. Rather, the notice requirement of 790*790 the statute is a condition precedent to
the existence of a cause of action for libel where the statute applies, and a circuit court is
not competent to hear the claim until the condition is met. Cf. Elm Park Iowa, Inc. v.
Denniston, 92 Wis. 2d 723, 728-29, 286 N.W.2d 5 (Ct. App. 1979) ("[N]o civil action for
damages can be brought or maintained unless the condition precedent of required notice
is given."); see also Hucko v. Jos. Schlitz Brewing Co., 100 Wis. 2d 372, 380-81, 302
N.W.2d 68 (Ct. App. 1981) (holding that failure to request retraction under § 895.05(2)
requires that claim be dismissed). The Journal denied in its answer that ALI had
demanded a retraction, and that was all it was required to do. Therefore, because ALI
never demanded a retraction from the Journal Sentinel, its claim against the Journal
Sentinel must be dismissed.
9
Further,
Once a claimant has been found to not meet the notice requirements, the action cannot be
revived by again attempting to comply with the notice provisions. DeBraska v. Quad Graphics,
Inc., 2009 WI App 23, 316 Wis. 2d 386, 763 N.W.2d 219, 07-2931. So those "Claims," specious
as they were in the first place, are now completely TOAST and Abby's Counsel should have
known this but instead valuable Judicial and Defendant resources have been squandered. Yet and
still Abby has not withdrawn these complaints, more indicia of scorched-Earth litigation abuse.
C. The Abby Litigants are Attempting to Cover up Surreptitious Recordings in a Space

Consonant with a Reasonable Expectation of Privacy.
Counter-Defendants not only lie about directives to record in the absence of the
homeowner, they try to skirt their violation of Federal Law. Counter-Plaintiff King has publicly-
stated:
And eventually people are going to have to stop looking the other way to avoid an
unpleasant reality.
It's going to be interesting to watch as more homeowners become aware that they are
being illegally recorded in two different ways. It's a fact.
People have a reasonable expectation of privacy in their homes and if you can't do it at a
car dealership you sure as heck aren't going to do it in my house.
See West v. Pressman 2:16-CV-00075-DN (Utah 2017).

https://www.govinfo.gov/content/pkg/USCOURTS-utd-2_16-cv-
00075/pdf/USCOURTS-utd-2_16-cv-00075-0.pdf
Good Day U.S. Attorneys and Smith:
I'll be (somewhat) brief.
I am a former LE Attorney, Journalist and First Amendment scholar. I have written

successful Appellate Briefs on First Amendment issues and won First Amendment Jury
Trials. Also, I have a long history of investigating fraud against homeowners and served
as homeowner advocate with the Washington Foreclosure Fairness Program. At present,
I have been investigating a Milwaukee company that like many, employs a software
product named Rilla to surreptitiously record homeowners. The data and recordings are
shared on multiple platforms post sale to persons with absolutely zero privity to the sale
whatsoever.5 The Statute provides, in pertinent part:
5
Discovery will show that the Abby litigants failed to meet any industry standards in their use of Rilla.
10
§2510. Definitions
As used in this chapter—

(2) "oral communication" means any oral communication uttered by a person exhibiting
an expectation that such communication is not subject to interception under
circumstances justifying such expectation, but such term does not include any electronic
communication;
(1) Except as otherwise specifically provided in this chapter any person who—
(C) intentionally discloses, or endeavors to disclose, to any other person the contents of
any wire, oral, or electronic communication, knowing or having reason to know that the
information was obtained through the interception of a wire, oral, or electronic
communication in violation of this subsection;
…..shall be punished as provided in subsection (4) or shall be subject to suit as provided
in subsection (5).
1. That is undoubtedly a violation of Common Law Right to Privacy.

2. It is likewise a violation of 18 USC §2511/Omnibus Safe Streets Act/1986 ECPA, etc.
3. The sales staff do not like to use Rilla and I have proof that many of them objected,
and proof that Abby Windows threatens economic sanction for failure to use Rilla. See
Attached……..
***********
As to Rilla recording and surreptitious eavesdropping on April 30, 2024 or May 1, 2024 –
well before the purportedly Verified Complaint was issued -- Defendant King issued the
following clarification that Plaintiffs don’t fully address because of Bad Faith: The fact that
former Staffer and co-Defendant Riley Richarz would subsequently indicate that monitoring was
possible ["if you have another device from another person, like, listening to your appointment”]
is his story to tell and no liability could attach to Defendant King who has already stated that the
matter is in some dispute.
That is all that Defendant Counter-Plaintiff King is required to say, and Counter-
Defendant’s maintenance of this claim is specious and put there solely to intimidate, again a
hallmark of Abby and her Counselors.6
6
Recall the referral to other Abby Counsel for “Extortion” supra. In point of fact Counter-Plaintiff King had to warn
Attorney Andringa “don’t ever threaten me again” when he had written exactly one (1) email to his client to clarify
whether she was still listed with National Association of Remodeling (NARI) because several staff have indicated
Abby was forcibly removed from NARI owing to consumer abuse. The rule permitting represented Parties to speak
amongst themselves is sacrosanct and well-known, but instead of simply requesting that King not have further
contact (to which King would have simply agreed), Andinga instead bellowed “Any further contact will result in a
Motion for Protective Order and for costs…” etc. etc. needlessly inflaming relations between Counsel in a manner
cautioned against by the Wisconsin Bar Ethics: Maintaining Decorum in Court Candor and Civility
https://www.wisbar.org/NewsPublications/WisconsinLawyer/Pages/Article.aspx?Volume=77&Issue=10&ArticleID
=672
11
Note further that during a client meeting Plaintiff Binder wrote Mr. Richarz to tell him to
turn his Rilla on for porchlight sales, which involve leaving the recording device in the room
while a salesperson walks out of the home.
These sales staff, on video and otherwise, told Defendant King that they were coerced
into recording or lose their jobs. Moreover, in addition to staffers not wanting to use Rilla it is
clear that Abby Management staff told them to use it and to issue reports. See Appendix B. It
remains a question of Employment Law whether this is true consent as Abby alleges but in any
event it is well beyond the purview of any Defamation claim that much is certain, yet the Abby
litigants press onward.
Abby wrote in its Verified Complaint:
Abby Windows’ sales associates sign a consent agreement upon their first use of the Rilla
software and, in a one-party consent state like Wisconsin, such recordings are legal so
long as the salesperson remains a party to the discussion.
Plaintiffs thereby tacitly admit to violating U.S. Code and acknowledge that it would be
illegal for a salesperson to leave the recording running while absent. In fact, they acknowledge
that it is in an attempt to pin a bogus Defamation claim against King and other Defendants:
On May 7, 2024, Defendant King posted a third video to YouTube entitled, “Interview
with Abby Windows Staffer on Payroll and Rilla Eavesdropping,” in which he
interviewed a former Abby Windows Account Associate, Fred Mayen. This video
contained numerous false statements about Abby Windows’ business practices. Most
notably, Defendants Mayen and King falsely claimed that Abby Windows engaged in
illegal eavesdropping on customers during sales calls. In effect, Defendants Mayen and
King accused Abby Windows and/or Binder of criminal activity because the
unauthorized recording of private conversations is a Class H felony in the State of
Wisconsin.
That’s right it is. That is part of why Defendant King and staff find Rilla to be
unconscionable, ab initio. Unfortunately for Plaintiffs, Defendant King has concrete proof that
Abby used recorded calls outside the presence of the salesperson as a customer was recorded
precisely this way. In any event the question of economic coercion is real as seen above and in
the Appendices as it clearly has Defendant Richarz telling Abby he never wanted to use Rilla,
the same way that both he and Defendant Mayen told Defendant King on video while indicating
12
that the company encouraged staff to leave the negotiation space for unattended Rilla recording.
It is now proved by sealed Motion to Dismiss Appendix B-1 Under Seal and further soon by the
pending Appendix A in this Counter Claim. Note further that Defendant King had asked Abby
about Rilla and nobody responded back on May 1, 2024 and any reasonable Trier of Fact can
find that Abby’s conduct is indicative of someone with illicit intent in litigation.
Among other things this quote was striking to me:
"We play by street rules....scour your house, make fake accounts, bribe middle-
schoolers and walk into a bank shouting "everybody listen up!" Play hard, play dirty
and the winner will be announced...."
Please confirm whether this is a true message or whether Taylor Stepaniewski contrived
it.
Also does your company employ "Rilla" software and does it surreptitiously record
customers?
Are customers ever told they are being recorded? Please advise.
********
After Plaintiff failed to appear or even call or write or provide any communication
whatsoever in response to the two (2) phone calls and seven (7) emails because they would rather
not discuss any of these things but would rather try to sue and to intimidate.
D. All Claims Concerning any Spoken Allegations Fail on their Face as to Defendant
Counter-Plaintiff King and Highlight Improper Intent and Misuse of Process.
Plaintiffs allege the following areas of broadcast Defamation:
i. The Riley Richarz’ Comments Provide no Claim.

ii. The Elder Black Matriarch Issues Provide no Claim
iii. Allegations of Willful Surreptitious Recording on the Absence of Sales Staff.
iv. Claims Involving Fred Mayen are Completely Baseless.
v. Claims Involving Defendant Mikki Campbell are Completely Baseless
vi. Claims Involving Taylor Stepniewski are Completely Baseless
vii Claims Involving Jason Crismond are Completely Baseless
Addressing these in seriatim:
13
i). The Sperm Incidents and Riley Richarz Jurisdictional Matters Precluded the Case
from Even Being Filed and Shows Further Indicia of Illicit Motive in the Underlying
Case..
First of all, anything to do with Defendant Richarz’ alleged actions belong in

Mandatory Arbitration. But given Plaintiff Counter-Defendants’ push to threaten people
with litigation they once again jumped the procedural gun and tried to sue in this
Honorable Court. It must further be noted that Defendant Richarz’ employment contract reads
like an indentured servitude arrangement. Read carefully it shows that he had no real opportunity
to contest a payment dispute because of the 30 day rule. He also waives basically everything,
including any discrimination or harassment claims. Litigant King obviously questions the
unconscionable nature of this adhesion Clause contract as well as the fact that it purports to be
binding on all parties with respect to the Boilerplate Adhesion Clause Arbitration Clause that is
all-encompassing, to wit:
Section 20. LEGAL PROCEEDINGS AND ARBITRATION. COMPANY AND ACCOUNT
ASSOCIATE AGREE THAT ANY AND ALL DISPUTES, CLAIMS, OR CONTROVERSIES
HEREAFTER REFERRED TO AS A "CLAIM") ARISING UNDER OR RELATING TO THIS
AGREEMENT, INCLUDING BY WAY OF EXAMPLE AND NOT AS A LIMITATION: (I)
THE RELATIONSHIPS RESULTING FROM THIS AGREEMENT; ( I ) THE BREACH OR
ALLEGED BREACH OF THIS AGREEMENT BY EITHER PARTY; (III) MATTERS
ARISING FROM ACCOUNT ASSOCIATE'S WORK AT COMPANY, INCLUDING, BUT
NOT LIMITED TO, TERMINATION, CLAIMS OF AGE, GENDER, O R DISABILITY
DISCRIMINATION, SEXUAL HARASSMENT, OR CIVIL RIGHTS VIOLATIONS; OR (IV)
THE VALIDITY OF THIS AGREEMENT OR THE VALIDITY OR ENFORCEABILITY OF
THIS ARBITRATION PROVISION, SHALL NOT BE INITIATED OR OTHERWISE
COMMENCED BY EITHER PARTY MORE THAN SIX (6) MONTHS AFTER THE DATE
THAT THE RELATIONSHIP UNDER THIS AGREEMENT SI TERMINATED,
REGARDLESS OF THE REASON FOR THE TERMINATION, AND THAT ACCOUNT
ASSOCIATE AND COMPANY AGREE TO WAIVE ANY STATUTE OF LIMITATIONS TO
THE CONTRARY THAT MIGHT OTHERWISE ALLOW FOR SUCH CLAIMS TO BE
BROUGHT AFTER THIS SIX (6) MONTH PERIOD.
BOTH COMPANY AND ACCOUNT ASSOCIATE ARE HEREBY AGREEING TO CHOOSE

ARBITRATION, RATHER THAN LITIGATION OR SOME OTHER MEANS OF DISPUTE
RESOLUTION TO ADDRESS THEIR GRIEVANCES OR ALLEGED GRIEVANCES WITH
THE EXPECTATION THAT THIS RESOLUTION PROCESS MAY BE MORE COST-
EFFECTIVE AND EXPEDIENT FOR THE PARTIES THAN LITIGATION. BY ENTERING
INTO THIS AGREEMENT AND THIS ARBITRATION PROVISION, BOTH PARTIES ARE
GIVING UP THEIR CONSTITUTIONAL RIGHT TO HAVE ANY DISPUTE DECIDED IN A
COURT OF LAW BEFORE A JURY, AND INSTEAD ARE ACCEPTING THE USE OF
ARBITRATION, OTHER THAN AS SET FORTH IMMEDIATELY BELOW.
14
1. The parties agree that due to the possible immediate and irreparable harm from a violation of
the restrictive covenant sections of this Agreement, these arbitration requirements shall not apply
to any restrictive covenant provisions, rights, and legal remedies contained elsewhere in this
Agreement.
2.If there is a small claims court (or an equivalent type of court) located within the county and
state in which Account Associate resided during Account Associate's work with Company,
Account Associate may, in accordance with the rules of that small claims court, choose to bring
(and must then keep) Account Associate's own claim in that small claims court.7
The only avenue in here is the subsection 1 clause dealing with irreparable harm, but had
Plaintiff and Counsel done their homework they would have known that Defamation is in the
irreparable harm category, ab initio. It will be interesting to see how that plays out for those
Parties because this case was not filed against him in Arbitration but that entire hornets’ nest has
to be sorted before anything moves forward in this venue. Litigant King will wait for that to be
litigated in the underlying case and will of course Petition the Court to file an Amicus or
supporting co-Defendant Richarz’ full briefing on the matter.
First however let us review William & May Law Rev v. 55 (2013) Issue 1, Article 2
because the reason Riley Richarz is involved here is…. Defamation. But Defamation is not an
irreparable harm so Riley Richarz should probably file for Arbitration and share his spreadsheet
and see what happens but whatever the case one thing for certain it’s not happening in the
companion case.
Significantly Plaintiff did not call out Mr. Richarz for stating that there were breast shots
from snapchat, or that Mandy arrived at his house drunk and disheveled, clothes hanging off of
her and “tried to make a move on [him]” so those allegations, taken in tandem with the rideshare
proof, render all of that quite probable. It’s hardly a jump of any consequence to believe that
other opprobrious behavior occurred as well, and if this cause is not dismissed the other staff and
friends who witness all of this will be called to testify, and to find their electronic devices, same
as Plaintiff Binder and then we will see who’s lying.
7
Note that the Abby litigants have now pending before this Court in 2024-CV-000073 Ark Contracting v. Abby
Windows a Motion Compel Arbitration and Stay Proceedings Pending Outcome of Arbitration with Affidavit in
Support filed by Attorney Triebenbach, the lawyer cc’d on the abusive email to innocent homeowner Amy
O’Donnell.
15
Meanwhile also note the written statement of Defendant Richarz’ Fiancée regarding
multiple discussions about him (and his father, another Abby staffer they accused of something
nefarious, wait for it) being a sperm donor.
We were all talking about wanting children one day, and the topic got brought up if either
Abby or Mandy would carry their future children due to them being a Lesbian couple.
Both Abby and Mandy mentioned they would want their future children to have Abby’s
athletic ability and stature. Abby then made a reference to wanting Riley’s father, Jack
Richarz, who was also employed by Abby at the time, to be the sperm donor for their
future child/children due to his athletic ability, and handsome looks. Abby then said that
she knows Riley’s mother Sheila, would never approve of that happening. Abby then
stated that Riley would be a perfect second choice to being the biological father of Abby
and Mandy’s future child/children. Abby and Mandy have both made multiple remarks
about both Jack and Riley’s desirable genetic traits, and how they would be ideal semen
donors.
These are requests coming from the owner of a $12M company who, according to
multiple staffers, abuses her staff like it’s going out of style and who basically owns all of the
media where she advertises. Where the Defamation appears in all of this for telling the Truth
remains to be seen and on the face of these facts and allegations no Action against Defendant
King shall lie for the mere reporting of a dispute; if that happens we might as well just hand the
keys to all media over to high-dollar businesses.8
When several people verify that a comment was stated there is no liability to befall a
Journalist as Plaintiff and Counsel should well be aware of, given the landmark Verdict just last
year in Tomczyk v. Wausau Pilot & Review when they reported that he called someone “a
faggot.”
https://www.wpr.org/justice/wausau-news-site-raises-money-legal-fees-after-politician-sues-
defamation
‘Even if we win, we lose’: Wisconsin news site raises money for legal fees after politician
sues for defamation
A Marathon County judge dismissed a suit against the Wausau Pilot & Review, but the
outlet says legal costs put it in danger of shutting down
BY SARAH LEHR
AUGUST 17, 2023
8
Oh, wait. Bagdikian enters the room again.
16
Note further that the Defendant in Mathewson v. Roberts was not liable for Defamation
even though he made false statements about a public figure as is Plaintiff(s).
https://wisconsinexaminer.com/2023/07/14/jury-rejects-defamation-claim-made-by-kenosha-
blogger-kevin-
mathewson/#:~:text=KENOSHA%20%E2%80%94%20A%20Kenosha%20jury%20determined,i
n%20Kenosha%20County%20Circuit%20Court.
• POLITICS & GOVERNMENT
Jury rejects defamation claim made by Kenosha blogger Kevin Mathewson

BY: DEE HÖLZEL - JULY 14, 2023 5:45 AM
KENOSHA — A Kenosha jury determined comments made about former alder and
controversial blogger Kevin Mathewson did not rise to the level of defamation following
a four-day trial in Kenosha County Circuit Court.
The jury delivered the verdict on Thursday after approximately six hours of deliberation
in Mathewson’s defamation suit against Raymond Roberts, who used social media to
repeatedly describe Mathewson as a racist with white nationalist connections. Mathewson
had claimed his reputation and standing in the community were damaged by the posts
Roberts had made about him.
Mathewson also claimed Roberts endangered his family by publishing his address,
though no actual threat materialized, and further injured his standing at his children’s
school by claiming Mathewson was training his children to be suicide bombers.
The case went to the jury Wednesday after Roberts testified in the lawsuit, telling the jury
that he believed what he said about Mathewson to be true. Roberts also said it was his
opinion Mathewson’s reputation was not damaged because “he has no reputation, in my
opinion.”9
9
Here is the nugget of Truth: While Defendant is not basing this Motion on the public reputation of Abby Binder
and her company (as it sits today not 4 years ago) the facts are going to show that Plaintiff’s long time associates
echo Mr. Roberts’ sentiments there’s not even a pyrrhic victory to be had for Plaintiffs here, just a long and
embarrassing “Come to Jesus Moment” as one interviewee stated to Defendant King.
17
ii). The Elder Black Matriarch.
Plaintiff claims that the sale was never consummated, and that Riley Richarz was wrong
about the sale amount and was corrected by senior staff present at the sale, etc. etc. That doesn’t
work anyway because prior to publication Defendant King had seen the below screen shot that
was circulated throughout the hallowed halls of Abby Windows, clearly indicating a sale.10
Furthermore, even if the sale was not consummated Defendant’s statement that Plaintiff
was robbing her blind would apply to attempted robbery anyway in the eyes of any listener the
attempt and the final success is a distinction without difference.11
10
There are other reasons why Defendant King knows that Defendant is lying about what truly happened in that
house but it’s not necessary to delve into that in this Motion for obvious reasons.
11
On matters such as these Defendant Counter-Plaintiff King has notified Abby and Counsel that he anticipates one
Evan Wright “Generation Kill” will enter an appearance as Expert Witness on the applicable Due Diligence
requirements incumbent of any professional Journalist prior and post publication. King has clearly met them.
18
iii. Allegations of Willful Surreptitious Recording on the Absence of Sales Staff: Perjury.
Defendant King specifically warned Counsel about this on one context earlier but they
did not listen even though another staffer heard it herself:
And I’ve witnessed her talk about Riley and his sperm. Multiple times……..
Not only could that point to Perjury folks.....and so based on that statement alone (much
less Riley Richarz's statements to me) I have zero liability whatsoever for my position
posting staff stating that it did in fact happen and no Jury instruction is going to read
otherwise should it ever even come to that. That is a valid report from a former staffer. If
it's s more an issue for a 12(b)(6) or Rule 56, whatever. Riley wasn't lying about the
rideshare nightmare so why would he lie about this?
Perjury is a Class H Felony Wis. Stat §946.31.
https://docs.legis.wisconsin.gov/statutes/statutes/946/iii/31
But that is not the Perjury we are discussing today. The Perjury we are discussing
today is the fact that Plaintiff wrote in the purportedly Verified Complaint:
17……..[M]ost notably, Defendants Mayen and King falsely claimed that Abby
Windows engaged in illegal eavesdropping on customers during sales calls. In effect,
Defendants Mayen and King accused Abby Windows and/or Binder of criminal activity
because the unauthorized recording of private conversations is a Class H felony in the
State of Wisconsin.
19. In fact, Abby Windows did encourage salespersons to give prospective customers
space to discuss the proposed deal, Abby Windows did not direct its sales personnel to
leave any device to record the private conversations of prospective customers. Any claim
to the contrary is false and defamatory.
Plaintiff’s problem – and it is a huge problem that Defendant King tried to warm them about – is
the fact that Plaintiff King, as noted above, has absolute proof as noted above, that Abby
Managerial staff took copious training notes and such on this file while the sales rep was not
present in the home, and this type of review happens repeatedly and the data from the
surreptitious recording is used in subsequent transactions with persons and entities have no
privity with the original contract whatsoever.
19
PERJURY AND FALSE SWEARING
946.31 Perjury.
(1) Whoever under oath or affirmation orally makes a false material statement which the person does
not believe to be true, in any matter, cause, action or proceeding, before any of the following,
whether legally constituted or exercising powers as if legally constituted, is guilty of a Class H
felony:
(a) A court;
(2) It is not a defense to a prosecution under this section that the perjured testimony was corrected or
retracted.
Perjury consists of a false statement that the defendant knew was false, was made under
oath in a proceeding before a judge, and was material to the proceeding. Materiality is
determined by whether the trial court could have relied on the testimony in making a decision,
not on whether it actually did. State v. Munz, 198 Wis. 2d 379, 541 N.W.2d 821 (Ct. App.
1995), 95-0635.
Now that is patently clear that Plaintiffs have lied in what is arguably the biggest issue in
this entire case, the Court must grant the requested Show Cause Hearing to bring this case
forward to where it needs to be and to potentially save innocent Wisconsin taxpayers from
shouldering the cost of Abby Binder’s historical vituperative largesse. Naturally should any
claims actually remain in this case when the Motion is argued and should any such claims further
survive Summary Judgment then Defendant(s) are all entitled to a somewhat limiting Jury
Instruction that the Plaintiff has already Perjured herself in a Sworn and Verified Complaint.
This is obviously another seminal point in the litigation as a core issue and Abby Binder
completely lied and it is right here on the page (and in the audio) to prove it. And now her
lawyers (Timothy Andringa and putative Counsel Steven Mark Couch) are on Actual Notice of it
as well, with all of the Ethical implications involved, i.e. SCR §20:3.3:
(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;
(3) offer evidence that the lawyer knows to be false. If a lawyer, the lawyer's client, or a witness
called by the lawyer, has offered material evidence and the lawyer comes to know of its falsity,
the lawyer shall take reasonable remedial measures, including, if necessary, disclosure to the
20
tribunal. A lawyer may refuse to offer evidence, other than the testimony of a defendant in a
criminal matter that the lawyer reasonably believes is false.
(b) A lawyer who represents a client in an adjudicative proceeding and who knows that a person
intends to engage, is engaging, or has engaged in criminal or fraudulent conduct related to the
proceeding shall take reasonable remedial measures, including, if necessary, disclosure to the
tribunal. (c) The duties stated in pars. (a) and (b) apply even if compliance requires disclosure of
information otherwise protected by SCR 20:1.6.
….and potentially SCR §20:3.4
A lawyer shall not:
(a) unlawfully obstruct another party's access to evidence or unlawfully alter, destroy or conceal
a document or other material having potential evidentiary value. A lawyer shall not counsel or
assist another person to do any such act;
(b) falsify evidence, counsel or assist a witness to testify falsely, or offer an inducement to a
witness that is prohibited by law;
(d) in pretrial procedure, make a frivolous discovery request or fail to make reasonably diligent
effort to comply with a legally proper discovery request by an opposing party;
(e) in trial, allude to any matter that the lawyer does not reasonably believe is relevant or that
will not be supported by admissible evidence, assert personal knowledge of facts in issue except
when testifying as a witness, or state a personal opinion as to the justness of a cause, the
credibility of a witness, the culpability of a civil litigant or the guilt or innocence of an accused;
or….
iv. Defendant Fred Mayen is Another Innocent Victim of Plaintiff.
Defendant King has already told Counsel for Plaintiff the Truth about Fred Mayen and
that Truth is that he was entitled to his money and he didn’t get it. When he wrote a nasty review
seen below discussing the price gouging and the unlawful construction delays and the CCAP
activity they gave him his money, but the manner in which it was conducted was completely
nefarious, with nothing in writing and a hushed call from the personal phone of the COO who
never had any time for anyone. The bottom line here is the Plaintiff Counter-Defendant is in
possession of items that render their claims against Mayen to be completely baseless; the only
issue when the dust settles is whether Abby shared this information with their Counsel with
respect to THEIR Ethical duties. Time will tell, and it will tell soon.
21
22
23
v. Statements made by Defendant Mikki Campbell on Workplace Manifestations
of the Relationship Between Abby Binder and Mandy, her Former Co-Worker are
clearly not Actionable.
These allegations lack specificity sufficient enough to put any Defendant on Actual
Knowledge of the allegedly Defamatory statements but suffice to say first that Defendant King
has notified Counsel for Plaintiff that the situation with Mandy being abruptly promoted from
rank and file to Vice President has repercussions that directly impacted her at work because
Mandy came to her in the workplace. Defendant told them on June 7, 2024:
They claim that Mikki's comments about how Abby swooped up a rank-and-file staffer
and married her and threw her then-wife/soon-to-be former out of the house is not truly a
private matter because Wife #2 became Mikki's and everyone's boss and by all accounts
is ineffective and just an Alter Ego manifestation of Abby. Mikki wrote an email about
this earlier this week and has confirmed to me that the personal side also spilled over into
the business side because Wife #2/VP Mandy came running to her IN THE
WORKPLACE in some drama moment not dissimilar to the drama when Riley called
Mandy a rideshare to his house, all of which is shown in screenshots.
Hello Mr. King,

Let me say again, everything that past employees have said is the truth. If you listen to
Abby, she would have everyone believe we are all lies and she is the only one telling the
truth which is not so. I stand by everything I said about Abby and the way she runs her
business and treats people. Hell, I have no reason to lie. The day she or lets say she had
someone left me go, was the best day I had at Abby Windows plus I got unemployment on
top of it.
And let me add to the statement about Mandy becoming VP just after they got engaged.
Now not only did all the employees have to answer to her, she was never there. She and
Abby spent weeks at a time gone. Then they would come in and hold your fingers over the
flames sort of speak for anything that did not meet their expectations. Mandy could not
find her own ass in the dark let alone be a VP.
Now if they want to try and sue me for my little social security check for speaking the
truth. Let them come.
Sincerely,
Mikki Campbell
As such, there is a clear-cut nexus between Mandy’s ascent to her VP position has clearly
manifest workplace manifestations so there’s no Cause of Action here. In fact, this kind of
activity is indeed questionable again just last year:
24
https://www.cbs58.com/news/gov-evers-defends-not-having-policy-against-supervisors-dating-
staffers
https://wisconsinwatch.org/2023/09/tony-evers-spokesperson-raise-promotion/
Did a spokesperson for Wisconsin Gov. Tony Evers who lives with Evers’ chief of staff get a
raise and promotion to a position that reports to the chief of staff?
YES.
The Milwaukee Journal Sentinel reported Aug. 31, 2023, that Maggie Gau, Wisconsin Gov.
Tony Evers’ chief of staff, has lived for at least a couple of years with a staff member who
directly reports to her.
The staffer was appointed in January 2019 to a position at $62,000 that did not report directly to
Gau but was under her chain of command, the Journal Sentinel reported, citing a statement from
Evers’ office.
On Nov. 8, 2020, Evers promoted the staffer to a top-level position that reports to Gau at a salary
of $100,006. The newspaper said the statement from Evers’ office was not clear on Gau’s role in
the promotion.
The staffer got a raise to $112,008 in January 2023, the Journal Sentinel reported.
Milwaukee radio talk show host Mark Belling identified the staffer as Britt Cudaback, Evers’
communications director.
https://www.news8000.com/news/politics/local-politics/gov-evers-defends-chief-of-staff-being-
in-relationship-with-staffer-she-supervises/article_60f1cd14-4c6c-11ee-bce8-eb42e2f63bfd.html
Gov. Evers defends chief of staff being in relationship with staffer she
supervises
Sep 5, 2023 Updated Mar 21, 2024
MADISON (WDJT) -- Supervisors dating staffers.
It's a policy banned in the Wisconsin State Legislature and countless employers, but the
governor's office doesn't have a similar ban in place.
25
That's drawing criticism now that Tony Evers' chief of staff is reportedly dating a staffer
she directly supervises….
…..Many other employees who work at the Capitol are subject to strict guidelines. The
Assembly and Senate's policy says, "any relationship between supervisors and
subordinates are not allowed."
It goes on to state these relationships "may give rise to legal and ethical concerns."
Of course it does, in a private or public employment context but Abby never met a
detractor she didn’t want to sue, so here we sit, burning substantial taxpayer dollars and Judicial
resources. What is particularly offensive is Plaintiff’s attempts to downplay this obvious ethical
question when Defendant King is sitting here as a former Employment Law Attorney (State and
Private) with a mother who retired as a HR Specialist at General Electric. Who do they think
they are fooling here? Just, wow. Wow.
vi) Taylor Stepniewski’s Comments are Not Actionable.
Ms. Stepniewski wrote:
****EDITED TO ADD SINCE THEY’RE STILL GETTING TRUTHFUL REVIEWS

REMOVED AND GETTING THEIR EMPLOYEES, FRIENDS, AND FAMILY TO
ADD FAKE ONES**** (proof attached)
This company is hands down the WORST company you could ever have the displeasure
of working with. For the love of god, go anywhere else. Save your money, your sanity,
and your time and effort. If you do happen to still go with this company for whatever
reason they slime-balled you with, please do not be fooled by her twist of words when it
comes time to sign the certificate of completion. DO NOT SIGN THE CERTIFICATE
OF COMPLETION UNTIL YOUR PROJECT IS 10000000% DONE. I don’t care if they
tell you “this is just the part we completed today” it’s all a lie. That’s how they process
your financing. Once they have your money, WHO CARES IF YOU STILL HAVE
WORK TO BE DONE, they have your money and have been instructed BY THE
OWNER to focus on the people that still owe money. If you have a service, you’re put on
the back burner until you start threatening and reporting to the bbb. Best of luck.
Oh and Abby, take your useless cease and desist letters and shove them where the sun
don’t shine. !12
12
True to form, that is exactly what this “lawsuit” is all about: Plaintiff Binder’s rogue vanity. She lives in a World
where she believes she is beyond reproach, and that she can just hire lawyers to smash people like the six of us with
far less financial resources. It’s disgusting. We will all say as much in that Jury Box if the case ever goes that far,
26
Yikes...stay away. They pay for positive fake reviews and flag the negative ones so
potential customers can’t see the real deal. They will flag this and it will be removed in
no time. If you have a problem that escalates, the only way to get a response is to go to
the BBB and only then will she try to “fix” the problem with a weak, unfair, offer of
resolution. STAY AWAY!!!! The more I find out the more shocked I get that IT STILL
GETS WORSE. STAY FAR FAR AWAY AND SAVE YOUR SANITY.
It is clear that her factual comments actually have merit based even on the preliminary
level of documentation that has been put into the work by the date of the Verified Complaint and
her opinion comments are certainly not actionable either, unless Abby is now the employer and
the Thought Police…. Which might actually be the case in her mind because recall she told Riley
Richarz he could no longer talk to Dan Tarpey when the IRS/Department of Treasury issued a
finding in his favor that he had been misclassified as an Independent Contractor. “You can’t talk
to him if you want to work at Abby Windows” is exactly what he said in the video.
vii. Miscellany: Proprietary Information; Claw Back Clauses and Threats of Arson.
The claims pertaining to Defendant Crismond in the underlying case provide yet more
indicia of disingenuous conduct before the Court: Abby claims that proprietary information has
been leaked. This too fails for vagueness and requires a More Definite Statement but Defendant
King has been informed that Abby staff was typically compelled to purchase their own electronic
devices; these devices were then used to record unwitting customers. This begs the question as to
who owns the Intellectual Property involved: To this observer the only people who have a claim
to that discussion are the homeowner and the sales agent.
Also when reading the Crismond contract it will be clear that it is so poorly written that it
contains a dangling modifier that goes to…. Nothing. More on this at a subsequent time.
Lastly, there was no threat of arson or “burning the place down” that was an implied
threat in the Abby Complaint, and this is readily proved by the fact that Crismond was involved
in several communications with other Abby lawyers at this time and there was absolutely no
mention of this. Given Abby’s penchant for threatening legal action she would never have
and the Jury will agree with us, and it will all happen on KingCast cameras. I’ll put in my Notice of Media Coverage
if we go that far, and nobody in Wisconsin is going to come and tackle my cameras this time either.
27
missed a chance to throw that sort of thing in Mr. Crismond’s face. It never happened and in fact
Defendant King told Counsel for Plaintiff in this case that it was a lie when he sent an email
containing a salient part of Mr. Crismond’s letter to them that read:
From: Jay C
Date: Fri, Jan 19, 2024 at 5:13 PM
Subject: Follow Up
To: Abby Binder <abby@abbywindows.com>
Abby,
I am writing this letter to express my concerns regarding the lack of communication,

collaboration, and support in the tasks outlined in our written and verbal agreement. As
discussed in multiple meetings with you, I found it a bit concerning that during a
multiphase interview process before receiving an offer, I was under the impression that
during my meeting with the executive team, all necessary discovery conversations were
complete. One thing that was said during our very first conversations was your desire not
to have a "yes man" in the position I was contracted to fulfill, however, the statement of
needing "A brass cop, not a cops cop", I found to be quite alarming.....
..... During this time, I attempted to build a formative relationship with leadership on the
operations side of the company to have a better understanding of pipeline concerns that
were affecting timeliness and responsiveness for customer orders. On December 17th, I
was sent a Jobs by Status report that listed jobs not moved to measure or fulfill in a status
in CRM called Questions/Hold. What was determined while analyzing said report was
that the company was currently sitting on nearly three-quarters of a million dollars of jobs
not nettable due to some procedural compliance issues. I made contact with your CFO to
obtain login credentials for your current lenders so I could remotely solve any job that
was held up in the aforementioned report for financing document completion. During this
time I also reached out to build relationships and collaborate with your internal order
fulfillment team to get a better understanding of your organization's intake process so that
I could be integral in maintaining the compliance necessary to deliver and fulfill the
promises made to customers through installation contracts. It was during this time that
information was coming to me from operations desiring the punishment and termination
of several individuals on your salesforce who were consistently found on jobs noted in
the previously mentioned Questions/Hold report.
.....I requested numerous times the outlined curriculum and any testing that was necessary
to graduate your trainees. There was no response or information regarding those
requests. I began to receive text messages and phone communication requesting a
timeline on when the people I was not training would be prepared for the field and
leaving a training environment. Only 2 days before your vacation with your Vice
President, on 1/18/2024 you agreed to sit with me and review your own company's
training material. During this time, I was shocked to find out that you had never
looked at it. (emphasis added). I continued to utilize voice analytics to aid in identifying
the patterns and gaps in training while arriving at the company's office early each day to
28
address these issues. It is my professional opinion that my input in lack of standardization
and effective training was perceived as a personal threat and an attempt to expose one's
incompetence and have since observed a pattern of triangulation of communication,
rumor, and overtly passive-aggressive behavior. Rumors of complaints about my training
information surfaced through a conversation I had with you after business hours.....
Moreover, the Crismond Contract is also a product of abuse: It was materially changed
after initial agreement to include a claw back clause to the five thousand dollar ($5,000) forward
to Crismond for relocation, and he was told that it was in cause he quit. In reality they fired him
when he pushed back on abusive practices and his successor was already groomed before
Crismond even made his exit! It is Bobby Jones, the staffer who jacked up the price against the
Black Elder homeowner noted previously.
In sum, Plaintiffs Counter-Defendants are not making the underlying litigation in Good
Faith, just as their prior threats to an innocent homeowner were not in Good Faith, nor are many
of their contracts as we shall see in Discovery. Under Wisconsin common law “‘[e]very
contract’”—not only contracts that are subject to the Act—“‘implies good faith and fair dealing
between the parties to it.’” See WIS. STAT. § 421.108 and Beidel v. Sideline Software, Inc.,
2013 WI 56, ¶27, 348 Wis. 2d 360, 842 N.W.2d 240 (quoting Chayka v. Santini, 47 Wis. 2d 102,
107 n.7, 176 N.W.2d 561 (1970)). Abby litigants have failed this threshold repeatedly.
29
PRAYERS FOR RELIEF
1. Declaratory Judgment.
2. Preliminary and Permanent Injunctive Relief.
3. Any attendant costs.
4. Punitive Sanctions against Abby litigants.
5. Punitive Sanctions against Counsel for Abby litigants.
6. Any and all other Relief as the Court deems appropriate.
JURY DEMAND
Defendant Counter-Plaintiff hereby demands this Cause be heard before a Duly-Empaneled Jury
of Appropriate Composition and Size
____________________
Respectfully submitted
___________________________
30
I the undersigned swear that a true copy of this First Amended Counterclaim was served to
tja@cmlawgroup.com
smc@berensonllp.com
via email
_____________________________________________
31
WAUKESHA COUNTY
STATE OF WISCONSIN
Plaintiffs, )
v. ) CASE NO.2024-CV-000820

)
Defendants.
SUPPLEMENTAL NOTICE OF SCR §61 MEDIA COVERAGE

ON SUSPECT HOME PAGE “REVIEW” AND EXPERT WITNESS EVAN WRIGHT
NOW COMES DEFENDANT CHRISTOPHER KING, J.D., to reasonably supplement
yesterday’s filing with two short yet crucial developments:
I. False Review Hosted on Plaintiff’s Own Website.
First is the fact that Defendant King has discovered a very questionable “review” on
Plaintiff’s website that is internally inconsistent. This Journalist is aware that the Court Record
already contains specific directives from Plaintiff Binder to create fake reviews, bribe middle
schoolers, play hard, play dirty, etc. see Appendix A. In addition to external pages however, this
particular review purports to be a five (5) star review yet the following text appears:
CONSUMER BEWARE!
***** Ted V. 7 months ago
Be sure to get comparison bids on your project before selecting Abbey(sic), their bid on
our project was double the highest bid we received from reputable professional services.
Note that the 5-star rating is completely incongruous to the review. As such, it is
quite possible that manipulation occurred by April Broughton or other Abby staff and a forensic
review is required as it goes to the entire integrity as alleged by Sworn Complaint by Plaintiff,
i.e. “Abby is Ethical…” Defendant King has represented with specific emails that Ms.
Broughton never answered his inquiry as to fake reviews despite multiple requests.
1
2
The apparent conduct involved here is clearly in violation of all matter of Local, State and
Federal Laws and Principles too many to enumerate in this space.
II. The Emergence of Evan Wright as Expert Witness for Defendant King.
Defendant King and Reporter King now move
to introduce International Journalist Evan
Wright as future Expert Witness. While
Defendant King is not at this point formally
introducing Mr. Wright as Expert Witness, he
will be there should the case proceed past a
pending Motion to Dismiss.
Defendant and Evan Wright have known
each other for fifty (50) years now and the two
of them have always shared immense respect
for the other’s work in early journalism as far
back as 1978 and State Debate Finals in 1981.
Defendant King was to join Witness Wright at
Vassar College in 1984 but owing to a glitch in
King’s transfer application it was not timely
processed. The pair recently caught up in
October, 2023 at Hawken School’s 40th
Reunion Class of 1983.
Wright holds the highest U.S. non-military
security clearance in the World, running with “The Killer Elite.” The Court may be familiar with
his work on “Generation Kill” book and video series; Generation Kill: Devil Dogs, Ice Man,
Captain America, and the New Face of American War.
Suffice to say he passes any test as Expert witness on journalistic principles.
https://www.amazon.com/Generation-Kill-Captain-America-American/dp/0425224740
https://x.com/evanscribe
https://en.wikipedia.org/wiki/Generation_Kill_(miniseries)
3
https://www.npr.org/2004/10/23/4123158/evan-wright-reporting-on-the-killer-elite
States Wright:
Evan Wright:
Say you’re my previous partner in journalism, too, if it helps . (I think your critiques of the
school, stupidity of culture, Mr. Wiemer, and the Seed count as incisive journalistic
commentary.)
MacBook:
True.
Evan Wright:
“Truth shall set us free — and then they will charge us a fee!” That’s my slogan. You can use it!
4
Reporter King tends to stay more local in his coverage of course, which only increases
his level of respect for Mr. Wright. Naturally he will be available any morning, mid-morning,
afternoon, dusk, evening or night that Plaintiffs would like to speak with him should this case
move into Summary Judgment posture but for now the point is that there are two other bona fide
Journalists of International repute supporting Defendant King’s propositions of law here. Their
Alma Mater has recognized both men for their accomplishments, see generally “Working for Fair
Play” Hawken Review 2007.
5
For his part, having reviewed much of the salient matters involved, Journalist Wright
stated “Whoa! That shit is ridiculous man.” Obviously a Judge will determine his credibility
down the road at Summary Judgment and potentially a Jury will do so later, but at this point the
fact that he has expressed severe concerns with Plaintiff’s conduct dovetails neatly with similar
observations from Jason Brown, who has worked with the State of Wisconsin on prior occasion
in a directly-related case:
From: Jason Brown

Date: May 29, 2024 at 6:01:15 PM PDT
Erica,
Jason Brown
http://reviewfraud.org1
1
Wait: We know. Jason Brown is also part of the vast cosmos of people who just up and decided to beat up on poor
innocent Abby Binder. It’s all clear now. Mr. Brown had some other things to say as well.
6
In the event that the main body of Defendant King’s Notice of Media Coverage was not
sufficient he submits that sufficiency has been met and exceeded by any measure on the face of
this Earth with now two Internationally-known Journalist issuing statements in support. At this
point King asks, as did Hawken Professor Jack Pickering many years ago:
What is truth?
What is worth knowing?
How shall we go about making value judgments?
7
______________________
I the undersigned swear that a true copy of this Supplemental Notice was served to
tja@cmlawgroup.com
smc@berensonllp.com
via email

_____________________________________________
8
WAUKESHA COUNTY
STATE OF WISCONSIN
Plaintiffs, )
v. ) CASE NO.2024-CV-000820
) JUDGE BRAD SCHIMEL1

)
Defendants.
NOTICE OF SCR §61 MEDIA COVERAGE

NOW COMES DEFENDANT CHRISTOPHER KING, J.D., to note his presence as
professional Journalist in the above-captioned matter. While such briefing is certainly not
required by any Press, he provides it here for the Record to be crystal clear.
Factual Background and Qualifications.
1. Defendant King has been a professional journalist more than half the span of his life,
since 1989, prior to and after the corporate entity “KingCast” was officially registered in
Georgia.2
2. King was a journalist even as an Attorney, running video of his successful First
Amendment Trials twenty-eight (28) years ago.
https://www.youtube.com/watch?v=PP0AhTuKJWg&t
1
There is a pending Motion to Recuse His Honor owing to his decades-long direct supervisory capacity over current
DA Susan Opper, a public figure that Defendants have criticized for failing to protect Wisconsin homeowners.
Defendants are aware of several homeowners who will be subpoenaed to show unethical conduct. Obviously
Defendant King will respect the fact that he is still the Jurist of Record as of this filing.
2
As will become clear the underlying case is frivolous anyway in part because Plaintiffs failed to provide Safe
Harbor warning under Wis. Stat 895.05(2) New York Times Co. v. United States, 403 U. S. 713 and more.
1
3. As noted previously in his pending Rule 802.06 Motion to Dismiss, he has studied
newswriting and rhetoric in undergrad under Steven Depoe, whose background includes
teaching courses in Environmental Communication, Communication and Sport, Rhetoric
of Social Movements, Rhetorical Research Methods, and Advanced Rhetorical Theory.
From that point he edited the Cincinnati Edition of the statewide Ohio Call & Post and
wrote as general beat reporter for the Indianapolis Star prior to law school. In law school
he studied First Amendment and Journalism under William P. Marshall, who served as
Deputy Communications Counsel to President Clinton. After law school he was the first
non-corporate entity to receive a formal press pass from the Massachusetts Supreme
Judicial Court:
…….and he received Mayoral Commendation from the City of Nashua for many reasons,
including changing First Amendment policy at the School Board.
2
3
He broadcast online videos prior to the existence of YouTube and his YouTube channel
has 1,700 videos and 7,780 subscribers.
4
He has shot murder trials, Products Liability Trials, Foreclosure Hearings and Trials,
Traffic Trials, Wrongful Imprisonment Trials and more.
He has shot courtroom video in six (6) states without any admonishment whatsoever
except the time he inquired of Wisconsin Hearing Officer James Winiarski why he did
not reprimand Attorney Mark Rattan for “approaching [me] in an angry and threatening
manner in violation of a standing Order.”
https://www.youtube.com/watch?v=xmYatdpIlSU3
3
5
4. Since Defendant King has never been subject to reprimand in any court proceeding other
than the one noted above he does not anticipate any problems in these hearings.
See for example “Foreclsoure; Union Federal Ban puts Single Mom in the Streets, Steals
Rent Money.”
https://www.youtube.com/watch?v=E--NfIyPBtw&t
5. Defendant King has routinely focused on matters pertaining to fraud and vulnerable
homeowners, see generally “Leaked Seattle Audit Concludes Many Mortgage Documents
are Void” David Dayen, The Intercept, Sept. 18, 2015.
6. Defendant King has of course also recorded Zoom videos of cases in which he was
involved as a litigant, and in some where he was not. While it is not essential to the issue
most Jurists enjoy Defendant King in their Courtrooms. Defendant King cannot share the
link to the top video owing to settlement but the remainder are linked for proof.
6
https://www.youtube.com/watch?v=1RJ0jSHPoqs&t
https://www.youtube.com/watch?v=xxPuLhWjU1I&t
7
https://www.youtube.com/watch?app=desktop&v=4I9zWlvgQ-o
https://www.youtube.com/watch?v=yGtOq4q15Tc4
Permitted coverage in WSLCB Matters
4
As a side note the Parties in that case are now unified in their opposition to the Washington State Liquor and
Cannabis Board (WSLCB).
8
II. Law and Argument.
A. Wisconsin Bar News Reporters’ Legal Handbook Provides for Recording.
For more than 30 years, Wisconsin courts have permitted cameras and recording devices
in most proceedings.
4) The news media has a constitutional and statutory right (subject only to rare exceptions)
to report judicial proceedings. However, all concerned should cooperate with the court to
ensure jury deliberations are based only on evidence presented to the jury in court. The news
media should use care in reporting portions of jury trials that take place in the jury’s absence.
Publicizing court rulings made or evidence rejected in the absence of a jury may cause
prejudice. A finding of prejudice may result in a mistrial.5
Here is the only limitation:

SCR 61.11 Prohibition of photographing at request of participant.
(1) A trial judge may for cause prohibit the audio recording and the photographing of a
participant with a film, videotape or still camera on the judge's own motion or on the
request of a participant in a court proceeding. In cases involving the victims of crimes,
including sex crimes, police informants, undercover agents, relocated witnesses and
juveniles, and in evidentiary suppression hearings, divorce proceedings and cases
involving trade secrets, a presumption of validity attends the requests; the trial judge shall
exercise a broad discretion in deciding whether there is cause for prohibition. This list of
requests which enjoy the presumption is not exclusive; the judge may in his or her
discretion find cause in comparable situations.
Defendant King will address any potential arguments as to purported trade secrets (i.e. the
surreptitious audio recording of unwilling staffers and unwitting homeowners, and violation of
trade acts) in due course should they arise. Apple tried this argument and ipso facto did not
prevail, supra. Defendants state that on review, the Court will in fact determine that the only
matters that could be claimed as trade secrets are instead used to show that
a) a sale for the purposes of this litigation did in fact happen with respect to the Ms. Bertha
audio and
b) private conversations outside the presence of a sales person did in fact occur, and
c) that a pattern of prohibited Wisconsin Home Improvement Sales Statutory Trade Act
violations occurred within the scope of consumer protection matters that should be investigated
by Law Enforcement. See Fn 1, supra.
5
Again, Defendant King has not had one single instance of running afoul of these principles in hundreds of
courtroom and administrative hearings. Not. Once.
9
B. Non-Institutional Press is Entitled to the Same Protections as Institutional
or Mainstream Press.
See Mortgage Specialists v. Implode-Explode Heavy Industries, NH Supreme Court Case

No. 2009-262, (May 6, 2010)
https://www.courts.state.nh.us/supreme/opinions/2010/2010041mortg.pdf
The fact that Implode operates a website makes it no less a member of the press. In light of
the trial court’s implicit findings, we conclude that Implode’s website serves an informative
function and contributes to the flow of information to the public. Thus, Implode is a reporter
for purposes of the newsgathering privilege.
See also Obsidian Finance Group v. Crystal Cox 740 F.3d 1284 (9th Cir. 2014).
https://caselaw.findlaw.com/us-9th-circuit/1655069.html
https://www.theatlantic.com/technology/archive/2014/01/us-court-bloggers-are-
journalists/283225/
Like the Supreme Court, the Ninth Circuit has not directly addressed whether First
Amendment defamation rules apply equally to both the institutional press and individual
speakers.2 But every other circuit to consider the issue has held that the First Amendment
defamation rules in Sullivan and its progeny apply equally to the institutional press and
individual speakers. See, e.g., Snyder v. Phelps, 580 F.3d 206, 219 n.13 (4th Cir.2009),
aff'd, 131 S.Ct. 1207 (2011)
We agree with our sister circuits. The protections of the First Amendment do not turn on
whether the defendant was a trained journalist, formally affiliated with traditional news
entities, engaged in conflict-of-interest disclosure, went beyond just assembling others'
writings, or tried to get both sides of a story.
C. Decisional Law and SCR 61 Support Access.
SCR §61 Provides in Pertinent Part:
See Mortgage Specialists v. Implode-Explode Heavy Industries, NH Supreme Court Case

No. 2009-262, (May 6, 2010), supra, and Chandler v. Florida, 449 U.S. 560 (1981) and Petition
of WMUR Channel 9 and Another, NH Supreme Court No. 2002-0181 (2002).
Moreover, the Supreme Court of Kentucky said in support of media access to court
proceedings: “The principle that justice cannot survive behind walls of silence is so deeply
imbedded in our Anglo-American judicial system as to give our people in today’s modern society
a deep distrust of secret trials ...
10
One of the strongest demands of a democratic system is that the public should know what
goes on in their courts. This demand can only be met by permitting them to be present in person
and by permitting the press, who have the facilities to properly inform them, to be present upon
their behalf.” Johnson v. Simpson, Ky., 433 S.W.2d 644, 646 (1968).
I/we warrant we will not compile footage or still images of any juror(s) as applicable and
I/we will comply with any and all Court directives as to placement and use of equipment. All
footage shall be maintained, and unedited for content and made available for any and all media
pooling orders or requests in this regard.6
Defendant King anticipates pushback from Plaintiffs. However, for all of the
aforementioned reasons it is incumbent on the integrity of this Court to allow facts to surface for
public view about matters of public concern, that contradict their Sworn Complaint, thereby
triggering a Class H Felony Wis. Stat § 968.31 as Defendant King already told Wisconsin Law
Enforcement, including DA Susan Opper, Consumer Protection and Waukesha PD:
https://www.youtube.com/watch?v=brZb6yyPHM8
Be that as it may, any such protestation would result in an unlawful form or Prior
Restraint. See generally Near v. Minnesota, 283 U.S. 697 (1931); Nebraska Press Assn. v. Stuart,
427 U.S. 539 (1976), and Depp/Heard (2023):7
https://www.youtube.com/watch?v=sYv9D8CIDJQ&list=PLoW1SIeAWaWb1IDY_WuLKvZygi
JudUBSd
6
Reporter King will handle video production himself on zoom calls; obviously he will retain a professional crew for
any in-court proceedings and anyone working this Courtroom will be under strict orders by King to conduct
themselves in a professional manner at all times, and not to fight back if assaulted.
7
While a former staffer has indeed opined in writing that Plaintiff Binder fancies herself “a celebrity” she is not a
celebrity in the sense of a Hollywood actor but she clearly is a Limited Purpose Public Figure with scores of
YouTube videos and tens of thousands of dollars if not more in public advertising on the same media platforms that
continue to ignore staff and consumer complaints. This is called Yellow Journalism and Defendant King does not
practice it.
11
CONCLUSION
First of all this case involves matters of EXTREME public importance and setting bright
line standards involved when homeowners are being surreptitiously recorded, and it will come
out that Rilla information from homeowners obtained both in the presence and absence of sales
staff was shared across the Country to all matter of people not even directly connected to the
sale. And it happens in one and two-party states as well, and not only that, staff may be liable for
violations.
Defendants take the position that staff did not truly consent to the use of Rilla at all, this
might not be enough to keep them out of any potential Civil or Criminal or Administrative
liability: See FTC v. Amy Travel Service, Inc., 875 F.2d 564 (7th Cir. 1989).
This is a simple matter. Either Plaintiffs will prove Defendants wrong, or Defendants will
prove Plaintiffs wrong. Either way these matters will be heard in a public Courtroom involving
matters of substantial public importance. Time will tell, and Defendants and the Undersigned
look forward to Plaintiffs’ position statement on this matter concerning Fundamental Rights of a
Free Press.
______________________
12
tja@cmlawgroup.com
smc@berensonllp.com
via email

_____________________________________________
13
WAUKESHA COUNTY
STATE OF WISCONSIN
Plaintiffs, )
v. ) CASE NO.2024-CV-000820
) JUDGE__________________
)
Defendants.
NOTICE OF MOTION AND MOTION TO RECUSE JUDGE BRAD SCHIMEL
NOW COMES DEFENDANT KING to note that based on prior experience it is

generally not good policy to have the sitting Judge have a decades-long relationship with
someone (Susan Opper) who is being soundly criticized by Defendants for failure to protect
innocent homeowners. This is all the more true when the Plaintiffs in the case have specifically
mentioned that person in their briefings as someone that Defendants should not have the nerve to
be speaking to. That’s right. While Defendant previously cited a prior case in which he admired a
correct First Amendment position that His Honor took on a touchy First Amendment case, that
does not override the obvious implications here, and accordingly it is in everyone’s best interests
that Judge Schimel immediately recuse himself from this case.
I. Relevant Background and Facts.

Presiding Judge Michael P. Maxwell recused himself under §757.19 but did not provide a
reason even as same is required by Statute sub (5).
(5) When a judge is disqualified, the judge shall file in writing the reasons and the assignment of
another judge shall be requested under s. 751.03. Docket 28. Appendix A.
1
Defendant King inquired on a recorded call and he inquired in Docket 32 with a Motion
for Compliance but instead of an answer, he gets a new career DA in the vacuum of the
unexplained sua sponte recusal of the first assigned Jurist. The new career Jurist was for decades
current DA Susan Opper’s boss, who Defendant King cited to as a lame duck staffer who is not
protecting elders and other homeowners. Here for example, is the recorded call to the DA and to
Waukesha PD -- who actually refused to even take in materials offered by Defendant Jason
Chrisman -- in relevant part in today’s video feature:
https://youtu.be/FyTfnFqyyUA
And here is a recent email detailing Defendant King’s concerns that Wisconsin Law
Enforcement has been derelict in their duties to protect innocent homeowners from multiple
facets of illegality by Abby Windows locally, although such practices are too prevalent
throughout the country with respect to the use of surreptitious Rilla recordings.
From: Christopher King

Subject: Re: Anatomy of a Lawsuit Part Eighteen(b): Are Wisconsin Consumer Protection
and Waukesha DA to Investigate Abby Windows?
Date: June 3, 2024 at 2:37:38 PM PDT
Two things:
1. Please have Consumer Protection put the reason for any declines in writing.
2. Please add something in your newsletter about these practices. This is particularly important
because again, most consumers do not realize they have been violated in the sense of the
recordings, but also not aware that they could avail themselves of the office. That is precisely
what Deanne Harris told me today.
2
Query, how many other skeletons are hiding out as we continue to investigate Abby
Windows. These complaints dovetail with all of the issues that Abby takes exception to in her
Unsworn Complaint, yessir1. I can't wait to see her actually swear back against my Declaration
when I file my Motion to Dismiss. She expects a Judge or a Jury is going to find that all of these
staffers and customers are just ganging up on poor Abby? Doubtful.
Anyway yes you should at a minimum post something here, and also the DA has to take steps to
protect innocent staffers who are breaking the law at the behest of their employers as noted in
this morning's video, with reference to established case law.
https://www.facebook.com/story.php/?story_fbid=837193935114640&id=100064721227022&pa
ipv=0&eav=AfaFErbKnb8wobo2VzjVd2LUMIcAkphsENha_oTIONcmjbB9C9kyUt-
GCmRtoJi4kRA&_rdr
Somehow these ideas make sense to Defendant King and the five (5) sued worker bees
but not to Law Enforcement, odd that.
**********
Defendant King, himself a former Law Enforcement Attorney, has an adverse posture
with the Waukesha DA’s Office as does Defendant Crismond and derivatively all Defendants
because neither that office, the office of Consumer Protection nor the Office of the Waukesha
Police Department lift a single finger to investigate Abby Windows.
Defendant King has been quite vocal about this and demanded written responses from these
departments as to why they claim no one has Subpoena powers to investigate, or that they cannot
investigate criminal offenses when reported by staff and consumers with direct knowledge even
when those complaints have been lodged on reputable consumer websites such as BBB and
Google.
1
Defendant King is pleased to discover that the Complaint actually was Verified, for reasons that will become clear
the moment that Plaintiff and duly-licensed Counsel file their next Sworn document.
3
https://www.youtube.com/watch?v=e2K40tCNBts
https://www.youtube.com/watch?v=brZb6yyPHM8&t
4
Defendant King cannot surmise why these people are not doing their jobs in this space, but
suffice to say they are not and as the litigation proceeds there will soon be yet more documented
proof that shows these agencies need to step up to protect Wisconsin homeowners. But with the
current Judge having been a lifelong DA who handed the reigns over
to Susan Opper – who Defendants are actively criticizing for failure
to act – this creates a thoroughly untenable situation, one that Plaintiff
has encountered before on a successful Recusal Motion in Federal
Court as noted in the first linked video of this Motion, hot off the
presses.
_________
These are clearly serious issues that prompted SEO and Online
Review guru Jason Brown to contact local press (at WISN where of course Plaintiff has a lavish
advertising budget) and to opine that Plaintiff should lose her BBB Accreditation yet mum’s the
word, See Hear Speak No Evil at all three of these agencies that stand in conspiracy to imperil
innocent homeowners, often elders, by marketing design.
Here is what we do know: Online advertising expert Jason Brown, who has worked with the
State of Wisconsin on prior occasion in a directly-related case:
From: Jason Brown

Date: May 29, 2024 at 6:01:15 PM PDT
Erica,
5
Jason Brown
He did then further opine that Abby should lose her BBB Accreditation for the stunt
where she threatened a customer with Extortion for refusing to take down a bad review but that’s
still no reason for any LE in Wisconsin to do anything, fascinating. For its part the DA continues
to put its head in the stand and issues curt dismissive comments, i.e. “the matter has been
referred to the appropriate party.”
2
6
These are indeed serious issues but nobody in Law Enforcement is doing anything to
protect homeowners, and not even putting their reasons in writing for failure to do so, which
makes the appointment of a life long DA who anointed the current DA a non-starter on anyone’s
Optic Scale. The problem does not end with homeowners because while Defendants take the
position that staff did not truly consent to the use of Rilla at all, this might not be enough to keep
them out of any potential Civil or Criminal or Administrative liability: See FTC v. Amy Travel
Service, Inc., 875 F.2d 564 (7th Cir. 1989).
In this case we’ve got a siting Judge disappearing with no adherence to process, Plaintiff
Attorneys violating all matter of procedural rules and basic tenets of civility and respect as noted
elsewhere in this Court, and now we have a Jurist who is a lifer DA appearing in a case where
the wealthy and influential Plaintiff is crying about the fact that Defendant King and others
approached his former office with a Consumer Complaint. Is that a crime now to file a
legitimate Consumer Complaint? Defendant King has a life-long pursuit of such matters,
including work as a certified homeowner advocate in the Washington Fairness in Foreclosure
program in the fallout of the 2008 Mortgage Fraud Crisis.3
As noted, Defendant King has made a Federal Jurist recuse herself in a similar situation
several years ago but it was after she had already issued an adverse ruling. For some reason
Defendant King would like to avoid a similar outcome in this instance and of course the
appearance of bias or impropriety would lead any reasonable fact finder to rule in favor of
Recusal.
3
Defendant King previously managed a title company as Residential Closing Attorney.
7
Who knows, he could have been a great Judge for Defendants but the optics here and the
complete lack of Transparency have ruined this moment, and that again, is not Defendant’s
fault. It is Plaintiff Binder’s fault for even filing this patently abusive Action in a attempt to
cover up her own willful malfeasance, some of which is in fact, criminal. Just wait for Defendant
King’s Reply Brief in favor of Rule 802.06 Dismissal. It is all going to come out.
https://www.youtube.com/watch?v=2vT7_uhnElQ&t
II. Law and Argument.
There are clearly compelling Consumer Protection and Criminal matters involved in the
conduct of Plaintiff Abby Binder, Waukesha LE have done nothing about it, Defendant King has
soundly criticized the current AG who the current Jurist appointed when he left office, and the
current Jurist arrived in his position through some nebulous and unstated recusal from the initial
Judge in the case. That is admittedly one heck of a run-on sentence but it highlights the
incredulity of the situation that could have been avoided with a bit of transparency, but the
cumulative effect of all of this operates to end Judge Schimel’s tenure on this case by any
measure.
Wisconsin Legislative Council Memorandum (Sept. 9, 2010);
According to Wisconsin courts, the due process guarantee of a fair trial can be achieved
by disqualification or recusal where objective facts reveal an actual bias on the part of a
judge (such as a direct, personal, substantial pecuniary interest in an outcome) or where a
reasonable person, taking into consideration human psychological tendencies and
weaknesses, would conclude that the average judge cannot be trusted to, using a phrase
frequently quoted in judicial opinions, “hold the balance nice, clear and true” under all
the circumstances.
8
[See State v. O’Neill, 2003 WI App 73, 261 Wis. 2d 534, 663 N.W.2d 292; State v.
Carprue, 2004 WI 111, 274 Wis. 2d 656, 683 N.W.2d 31; and State v. Gudgeon, 2006 WI
App 143, 295 Wis. 2d 189, 720 N.W. 2d 114, rev. den. 297 Wis. 2d 320, 724 N.W.2d
204.]
CONCLUSION
There is really nothing more to say here. The lack of transparency despite phone calls and
filings, coupled with the decades-long relationship between Judge Shimel and DA Opper clearly
militates in favor of immediate Recusal.
________________________
617.543.8085m
I the undersigned swear that a true copy of this Motion was served to
tja@cmlawgroup.com
smc@berensonllp.com
via email
And to all named Defendants

Text via email
_____________________________________________
9
FILED
06-11-2024
APPENDIX A Waukesha County
Electronically signed by Michael P. Maxwell

Circuit Court Judge
Abby Windows, LLC et al vs. Christopher King et al Application and Order for Specific
Judicial Assignment
Case No. 2024CV000820
Case Information
Current Court Official Code Branch No. District No.
Michael P. Maxwell 2639 8 3
Date Case Filed Case Type Class Code and Description
05-16-2024 Civil 30106 - Intentional Tort
Case Status Information

Last Activity in Case Date
Next Scheduled (or to be scheduled) Activity in Case Date

Check Case 08-14-2024
Jury Trial Bench Trial Post-Judgment Case
Additional information that will be helpful to the Chief Judge and the Judge to be assigned (e.g., time limits waived or not waived, defendant in custody, speedy
trial demand, prior judicial substitutions or disqualifications, other attorneys, etc.):
GF-168S(CCAP), 04/2009 Application and Order for Specific Judicial Assignment SCR 70, §§757.19, 801.58, Wisconsin Statutes
This form shall not be modified. It may be supplemented with additional material.
Page 1 of 3
Attorney/Party Information
Timothy J Andringa
Attorney for Plaintiff
1601 East Racine Avenue, Suite 200, P.O. Box 558
Waukesha WI 53187-0558
262-542-4278
Timothy J Andringa
Attorney for Plaintiff
1601 East Racine Avenue, Suite 200, P.O. Box 558
Waukesha WI 53187-0558
262-542-4278
Christopher King
Defendant
721 E. 5th Street, Suite B
Arlington WA 98223 US
Riley Richarz
Defendant
5812 W. Plainfield Avenue
Milwaukee WI 53220 US
Taylor Stepniewski
Defendant
10190 W. Plum Tree Circle
Hales Corners WI 53130 US
Fred Mayen
Defendant
W192S7863 Overlook Bay Road, Apt. E
Muskego WI 53150 US
Michaele Campbell
Defendant
4333 S. Pine Avenue
Milwaukee WI 53207 US
Jason Crismond
Defendant
1741 Harrison Spring Road NW
Corydon IN 47112 US
Other Attorney(s) (and role: e.g., GAL, Adversary Counsel, etc.):
Reason for Assignment Application

Reason
Disqualification per Statute 757.19:
Page 2 of 3
Current Court Official Approval Application Order and Order of Assignment

Application Prepared by: It is Ordered the judge named below is assigned this case.
Michelle G. This assignment is denied.
X Approved
Denied
Explain:
By:
Chief Judge/Deputy Chief Judge/DCA/Director/Chief Justice
Date
Name of Judge Assigned:
DISTRIBUTION: Address Service Type

Court
Page 3 of 3
APPENDIX B
10
WAUKESHA COUNTY
STATE OF WISCONSIN
Plaintiffs, )
v. ) CASE NO.2024-CV-000820
) JUDGE__________________
)
Defendants.
NOTICE OF UNETHICAL CONDUCT
NOW COMES DEFENDANT CHRISTOPHER KING, J.D. to first recall the fact that putative
pro hac vice Counsel did not notify any Defendant of his presence and Application, but now in addition to
this, Stateside Counsel has inappropriately threatened Defendant King, to wit:
I sent exactly one (1) email directly to Plaintiff Binder since the time that Opposing Counsel
entered his appearance, seeking an answer to the question as to whether Abby Windows was still a
member of the National Association of the Remodeling Industry, NARI. The query was informed by
multiple public postings that NARI has removed the company owing to Ethical breaches.
Attorney Andringa then threatened to come to this Court to apply for a Protective Order when the
law on the matter is quite clear. He can ask, and I can agree – which I did – but for him to set off on the
same abusive tack popularized by Plaintiff Binder does not sit well with the Undersigned nor should it
curry any favor before this Honorable Court. See Appendix A, attached.
_______________________
1
tja@cmlawgroup.com
smc@berensonllp.com
via email

_____________________________________________
2
APPENDIX A
On Jun 12, 2024, at 7:02 AM, Timothy Andringa <tja@cmlawgroup.com> wrote:
Mr. King,
Please cease any further communication with Abby Binder of any kind. All communication
must be addressed to my attention only. If you continue contacting Abby Binder I will seek a
protective order and request the recover[sic] of fees.
Respectfully,
Tim Andringa.
Timothy J. Andringa
Managing Partner
*************
From: Christopher King <kingcast955@icloud.com>

Subject: Re: Anatomy of a Lawsuit Part Thirty-Two: The NARI Chronicles and a Baseless Threat
To: Timothy Andringa <tja@cmlawgroup.com>
Attorney Andringa,
Do not ever threaten me again.
I will refrain from further contact as a matter of my choice but you and your client will not
continue to threaten innocent people. We've had enough of that.
Research the ABA and Wisconsin positions next time please before you shoot your mouth off at
me.
Wisconsin Informal Ethics Opinion EI-17-04:
https://www.wisbar.org/formembers/ethics/Ethics Opinions/EI-17-04 Contact with Persons

Represented in Unrelated Matters.pdf
https://www.americanbar.org/groups/professional_responsibility/publications/model_rules_of
_professional_conduct/rule_4_2_communication_with_person_represented_by_counsel/com
ment_on_rule_4_2/#:~:text
3
[4] This Rule does not prohibit communication with a represented person, or an employee or
agent of such a person, concerning matters outside the representation. For example, the
existence of a controversy between a government agency and a private party, or between two
organizations, does not prohibit a lawyer for either from communicating with nonlawyer
representatives of the other regarding a separate matter. Nor does this Rule preclude
communication with a represented person who is seeking advice from a lawyer who is not
otherwise representing a client in the matter. A lawyer may not make a communication
prohibited by this Rule through the acts of another. See Rule 8.4(a). Parties to a matter may
communicate directly with each other, and a lawyer is not prohibited from advising a client
concerning a communication that the client is legally entitled to make. Also, a lawyer having
independent justification or legal authorization for communicating with a represented person is
permitted to do so. (emphasis added).
Instead of issuing more baseless threats how about acknowledging the apparent fact that NARI
did indeed boot your client for unethical conduct, how about THAT instead.
Warm regards,
617.543.8085m
4
5
FILED
06-13-2024
Waukesha County
2024CV000820
ABBY WINDOWS, LLC

and ABBY BINDER,
Plaintiffs,
v. Case No. 2024CV0820
CHRISTOPHER KING
RILEY RICHARZ
TAYLOR STEPNIEWSKI
FRED MAYEN
MICHAELE CAMPBELL
and JASON CRISMOND,
Defendants.
NOTICE OF MOTION AND MOTION TO STRIKE

DEFENDANT, CHRISTOPHER KING’S
“NOTICE OF UNETHICAL CONDUCT” (DKT. 34)
PLEASE TAKE NOTICE that the Plaintiffs, by Cramer Multhauf LLP, by Timothy J.
Andringa, on a date and time set by this Court, will seek an Order to Strike Defendant, Christopher
King’s (King) “Notice of Unethical Conduct” (Dkt. 34) pursuant to Wis. Stat. § 802.06(6) on
grounds that the same is immaterial and not pertinent to this matter.
The grounds for said Motion is that the Circuit Courts of Wisconsin are not to engage in
such matters: “Violations of the Code of Professional Conduct are determined only by means of
disciplinary action.” Foley-Ciccantelli v. Bishop’s Grove Condominium Ass’n, Inc., 211 WI 36,
¶2, 333 Wis. 2d 402, 409, 797 N.W.2d 789, 793.
1
Defendant King’s “Notice of Unethical Conduct,” Dkt. 34, is immaterial and impertinent
pursuant to Wis. Stat. § 802.06(6) to this action and for that reason should be stricken.
Dated this 13th day of June, 2024.
CRAMER MULTHAUF LLP

Attorneys for Plaintiffs
By: Electronically signed by Timothy J. Andringa

Timothy J. Andringa
State Bar No. 1001279
CRAMER MULTHAUF LLP
1601 East Racine Avenue • Suite 200
Waukesha, WI 53187-0558
(262) 542-4278
tja@cmlawgroup.com
2
WAUKESHA COUNTY
STATE OF WISCONSIN
Plaintiffs, )
v. ) CASE NO.2024-CV-000820
) JUDGE__________________
)
Defendants.
REPLY MEMORANDUM IN OPPOSITION TO PLAINTIFF’S MOTION TO STRIKE

NOW COMES DEFENDANT CHRISTOPHER KING, J.D. to note remind the Court
that it maintains the right to control the decorum of its litigants and Counsel regardless of any
specific Ethical Rules that are the province of the OLR. See Appendix A.
https://www.wisbar.org/NewsPublications/WisconsinLawyer/Pages/Article.aspx?Volume
=77&Issue=10&ArticleID=672
OCTOBER 01, 2004
Ethics: Maintaining Decorum in Court Candor and

Civility
Lawyers owe a duty of candor and civility to courts and colleagues.
DEAN DIETRICH
1
And in this case we have seen Counsel/Putative Counsel for Plaintiff already attempt to
appear in this case without notice to any Defendants and improperly threatened Defendant King.
This in addition to filing a case without basic research of Defamation Law in their haste to beat
down five (5) innocent staffers and a Journalist they ignored Wis. Stat §895.02(2) that clearly
mandates, in pertinent part:
(2) Before any civil action shall be commenced on account of any libelous
publication in any newspaper, magazine or periodical, the libeled person shall
first give those alleged to be responsible or liable for the publication a reasonable
opportunity to correct the libelous matter. Such opportunity shall be given by
notice in writing specifying the article and the statements therein which are
claimed to be false and defamatory and a statement of what are claimed to be the
true facts.
This in addition to the fact that Counsel for Plaintiffs also violated Wis. Stat §908.02
Rule of Completeness in the filing, ab initio:
The rule of completeness requires that a statement, including otherwise inadmissible
evidence including hearsay, be admitted in its entirety when necessary to explain an
admissible portion of the statement. The rule is not restricted to writings or recorded
statements. State v. Sharp, 180 Wis. 2d 640, 511 N.W.2d 316 (Ct. App. 1993).
Counsel for Plaintiff twice violated this Rule in Plaintiff’s Verified Complaint and it
materially changed the essence of the communications, conduct that the Court is fully authorized
to address. Typically Defendant King would wait until further briefings to address these matters
but given the ongoing pattern of reckless disregard for the law in this case alone, and Plaintiff’s
history of abusive threats to staff and customers (i.e. threatening Extortion against Amy
O’Donnell unless she removed her negative review) it is imperative that this Court be fully
aware of what is really going on here in this abusive, retaliatory litigation that is about to
backfire against Plaintiff and Counsel as soon as they submit their next Sworn filings.
As such, Defendant King is well within his rights to inform the Court that he told
Attorney Andringa:
From: Christopher King

Subject: Re: Anatomy of a Lawsuit Part Thirty-Two: The NARI Chronicles and a
Baseless Threat
To: Timothy Andringa
So for future reference all you had to do was say:
2
"Hey King, she's not going to respond and you will have to seek that information later or
in a different manner,"
...then I say "Fine Counselor we will get there if your case survives my Motion. I will
honor your request."
But instead you come in here hot -- just like your client -- and try to threaten me. Do you
realize I have been threatened by people larger than you and your client many times in
my 59 years - about the same as you -- and it has never worked out well for those who
take that path.
But hey, as your client says "Play Hard, Play Dirty."
Warm regards,
617.543.8085m
CONCLUSION
Defendant King is not to blame for the behavior of Plaintiff’s Counsel. No. Plaintiff’s
Counsel is to blame for the behavior of Plaintiff’s Counsel. Said behavior on the part of both
established Counsel and Putative Pro Hac Vice Counsel leaves much to be desired and the Court
must demand better moving forward and caution such Counsel accordingly.
_______________________
3
tja@cmlawgroup.com
smc@berensonllp.com
via email

_____________________________________________
4
APPENDIX A
Vol. 77, No. 10, October 2004

Maintaining Decorum in Court Candor and Civility
As officers of the court, lawyers are expected to act with decorum

and civility in all their dealings with tribunals and opposing parties.
by Dean R. Dietrich
Dean R. Dietrich, Marquette 1977, of Ruder, Ware

& Michler L.L.S.C., Wausau, is chair of the State
Bar Professional Ethics Committee.
Question
I have experienced many instances in which
opposing counsel has gone out of her way to make inflammatory
statements when communicating with the trial court. Isn't this
prohibited by the Rules of Professional Conduct?
Answer
Lawyers often walk a delicate line between advocating for their
client and maintaining a proper level of decorum when interacting
with the court or with an opposing party. Many people say that the
5
legal profession has lost touch with the professionalism and civility
that existed in the past between lawyers. Others say that lawyers
owe it to their clients to aggressively advocate their positions.
Whether or not you agree that civility has been lost, it is always
important to remember that lawyers owe a special duty of candor
to the tribunal and this duty should guide lawyers when they
advocate to the court.
The Professional Ethics Committee opinions are available

in Wisconsin Ethics Opinions, published by State Bar of Wisconsin
CLE Books, which includes the complete text of all formal,
informal, and memorandum opinions issued by the Professional
Ethics Committee since 1954, including opinions that have been
withdrawn; and the full text of the Rules of Professional Conduct
for Attorneys (SCR 20). To order Wisconsin Ethics Opinions, call
(800) 728-7788 or visit Marketplace online.
SCR 20:3.3, entitled "Candor Toward the Tribunal," provides the

basic guidance to lawyers in their communications with the court
and with opposing parties. A lawyer may not "knowingly (1) make a
false statement of fact or law to a tribunal; (2) fail to disclose a fact
to a tribunal when disclosure is necessary to avoid assisting a
criminal or fraudulent act by the client; (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 opposing counsel; or (4) offer evidence that the lawyer
knows to be false." These general rules govern the duty of a lawyer
when interacting with a tribunal such as a trial court or other court
6
of jurisdiction. These rules do not, however, address the common
situations in which a lawyer may be communicating with the court
and opposing counsel about a pending matter and offer both
editorial comment and sometimes even inflammatory statements
that do nothing to further the cause before the tribunal. These
types of inflammatory statements, such as blaming opposing
counsel for failing to accept a settlement or for causing a delay in
the court proceedings, often stretch beyond the realm of
reasonableness but do not constitute a false statement of fact or
law.
SCR 20:3.1, entitled "Meritorious Claims and Contentions," offers

further guidance for lawyers. Under this rule, a lawyer shall not,
when representing a client, "file a suit, assert a position, conduct a
defense, delay a trial, or take other action on behalf of the client
when the lawyer knows or when it is obvious that such an action
would serve merely to harass or maliciously injure another." This
rule can, of course, be interpreted many different ways and to
many different degrees. On its face, the rule is intended to prevent
an attorney from participating in a course of action the goal of
which is only to harass another, whether it be the opposing party or
the opposing counsel.
Defining whether a lawyer has acted in such a way is very difficult

and subject to a great deal of interpretation. A recent decision from
the U.S. District Court for the District of Minnesota shows one view
of the type of bad faith conduct of an advocate that is subject to
sanctions. In this case, Schaffhausen v. Bank of America, No.
7
033492, the plaintiff's counsel was ordered to reimburse the
defendant for reasonable costs and fees for making a motion for
enlargement of time after the plaintiff's counsel refused to agree to
an extension of time to answer a complaint unless the defendant
stopped pursuing a particular course of action. In ordering
sanctions against the plaintiff's counsel, the magistrate judge
determined that the counsel's conduct was unreasonable. The
district court judge upheld the finding, concluding that the plaintiff
had no reasonable opposition to the request for an extension of
time to answer the complaint, particularly because counsel did not
oppose the motion seeking the extension. The court found that the
conduct of the plaintiff's counsel "created unnecessary work for
the court's staff and unnecessary expense for opposing counsel."
Monetary sanctions were levied against the plaintiff's counsel for
his conduct. This is but one example of how a lawyer can
overreach for the sake of advocacy and act contrary to the lawyer's
duty to the tribunal.
Even though attorneys are always expected to avoid harassing

types of behavior, we sometimes run into an advocate who
continues to act inappropriately. Lawyers need to be patient when
dealing with the unruly opposing counsel. An off-the-record
conversation with the offending attorney is the first step to
addressing the conflict between counsel. A letter to the opposing
counsel registering a formal objection to the offending behavior
may have to follow. Finally, lawyers may have to report the
continuing offensive conduct to the Office of Lawyer Regulation.
8
Several Supreme Court Rules speak to the conduct of lawyers and
set expectations for lawyer conduct. It is important for every
Wisconsin lawyer to remember that the Rules of Professional
Conduct apply to their behavior in virtually every situation. As
officers of the court, lawyers are expected to exercise the
appropriate level of decorum and civility in all their dealings with
the tribunal and opposing parties.
Opinions and advice of the Professional Ethics Committee, its

members, and assistants are issued pursuant to State Bar Bylaws,
Article IV, Section 5. Opinions and advice are limited to the facts
presented, are advisory only, and are not binding on any court, the
Office of Lawyer Regulation, or State Bar members. Attorneys with
questions on professional ethics issues may contact the Ethics
Hotline at (800) 444-9404, ext. 6168; or (608) 250-6168 (all day
Wednesday); and (608) 629-5721 on Monday, Tuesday, Thursday,
and Friday mornings. Send written requests for Professional Ethics
Committee opinions to the Professional Ethics Committee,
c/o Keith Kaap, State Bar of Wisconsin, P.O. Box 7158, Madison,
WI 53707-7158.
Wisconsin Lawyer
9
WAUKESHA COUNTY
STATE OF WISCONSIN
Plaintiffs, )
v. ) CASE NO.2024-CV-000820
) JUDGE__________________
)
Defendants.
SUPPLEMENT TO
REPLY MEMORANDUM IN OPPOSITION TO PLAINTIFF’S MOTION TO STRIKE
NOW COMES DEFENDANT CHRISTOPHER KING, J.D. to provide notice of the

actual Administrative Rule that Counsel for Plaintiff willfully violated. But as their client says,
“Play Hard, Play Dirty.”
“The filing party is responsible for serving a copy of the document upon all parties to the matter
or their attorneys of record….”
As noted, Counsel were well aware that Defendant King had not yet opted in, and of
course the other Defendants had not yet done so either. These Attorneys are just like their client,
abusing people, abusing processes and threatening financial punishments. This Defendant is not
having any of it. Nor will the others.
1
_______________________
2
I the undersigned swear that a true copy of this Supplement was served to
tja@cmlawgroup.com
smc@berensonllp.com
via email

_____________________________________________
3
WAUKESHA COUNTY
STATE OF WISCONSIN
Plaintiffs, )
v. ) CASE NO.2024-CV-000820
) JUDGE__________________
)
Defendants.
RULE 802.06 MOTION TO DISMISS OF DEFENDANT CHRISTOPHER KING, J.D1.
NOW COMES DEFENDANT CHRISTOPHER KING, J.D., without waiving any

Defenses or Jurisdictional challenges, to file this Motion to Dismiss Plaintiffs’ Complaint in its
entirety with respect to King. The first things to know is that Record Evidence can be provided
that will show that Officers of this company encourages surreptitious recording of unsuspecting
home owners in the absence of sales staff, commits contract fraud with fake customer signatures
to change quantity to true up accounts, pays staff to provide fake online customer reviews using
Abby Staff and families (never disputed), and threatens extortion and/or uses economic
incentives to convince customers to take down negative reviews. The threat to customer Amy
O’Donnell – who along with Abby Staff has reached out to Fox6 News – alone is enough to get
Abby’s BBB Accreditation revoked according to SEO and online consumer expert Jason Brown.
See also the National Association of the Remodeling Industry (NARI) reference at p. 28 because
Defendant King has reason to believe that Plaintiff lost its membership there for False and
Deceptive Business Practices, all of which weighs heavily on this case.
1
Defendant King is using limited evidence in this Motion to stick to items that Plaintiff was aware of prior to
publication of the second and subsequent videos to which Plaintiff takes exception.
1
Some of these false and deceptive practices appear in Appendix C and some will wait for
the Reply Brief. In Section II C below Defendant King clearly demonstrates why a Show Cause
Hearing on Perjury is required: Abby senior staff clearly analyzed a porchlight visit of a
customer for a time period when the sales rep was not present.
Plaintiff Abby Binder owns Abby Windows, LLC. She is a Limited Purpose Public
Figure with scores of YouTube videos and other online publications and with substantial
advertising on various news stations including Fox6, which to date has refused to run any stories
about Abby Windows in spite of the fact that Defendant King knows former staff and customers
have written Fox 6 with distinct valid issues. See generally Ben Bagdikian “The Media
Monopoly” and “The New Media Monopoly,” and Robert McChesney “Rich Media, Poor
Democracy.”
Defendant King is a professional Journalist. He studied newswriting and rhetoric in
undergrad under Steven Depoe, whose background includes teaching courses in Environmental
Communication, Communication and Sport, Rhetoric of Social Movements, Rhetorical Research
Methods, and Advanced Rhetorical Theory. From that point he edited the Cincinnati Edition of
the statewide Ohio Call & Post and wrote as general beat reporter for the Indianapolis Star prior
to law school. In law school he studied First Amendment and Journalism under William P.
Marshall, who served as Deputy Communications Counsel to President Clinton. After law school
he was the first non-corporate entity to receive a formal press pass from the Massachusetts
Supreme Judicial Court and he received Mayoral Commendation from the City of Nashua for
many reasons, including changing First Amendment policy at the School Board. He broadcast
online videos prior to the existence of YouTube and his YouTube channel has 1,700 videos and
7,780 subscribers. He has shot courtroom video in six (6) states without any admonishment
whatsoever except the time he inquired of Wisconsin Hearing Officer James Winiarski why he
did not reprimand Attorney Mark Rattan for “approaching [me] in an angry and threatening
manner in violation of a standing Order.” https://www.youtube.com/watch?v=xmYatdpIlSU2
2
2
In spring, 2024 Defendant King was approached by several former staff at Abby
Windows. They informed him of their own allegations of abusive employment practices and
false, deceptive and abusive consumer practices including but not limited to the ordered
fabrication of fake online reviews, inflated prices and price gouging, mean-spirited treatment of
customers who filed complaints, unlawful delays in production and more.
3
II. Relevant Facts and Law.
Defendant King broadcast his initial coverage on April 30, 2024:
https://www.youtube.com/watch?v=-jIls-6tRjI&t
KingCast Fields Allegations of Widespread #ElderAbuse
and Illegal Eavesdropping by Window Companies.
…..and followed that with several emails and phone calls and an invite to a zoom meeting with
staff, all of which were rebuffed without comment. Appendix A.
Significantly as one can see from reviewing Appendix A Plaintiffs intentionally left off
the entire email chain not once but twice in their Verified Complaint, a violation of Statute. Wis.
Stat §895.05(2).
https://docs.legis.wisconsin.gov/statutes/statutes/901/07
a) On one occasion this was done with the intent to mislead the Court as to the opportunity that
Defendant truly gave Abby to respond to his reasonable inquiries. There were seven (7) emails
and two (2) or more phone calls made to them that went without response, a common knowledge
that former staff (some subject to suit and some not) told Defendant King that
Abby never responds to anything negative, and when she does there is a record of her
threatening an innocent homeowner with Extortion because she would not [retract her negative
online review].
4
b) The second time Defendant King accused them of tampering with my online privacy;
spamming and missing folders. Defendant King received about 80 emails involving identity
theft and trader online car sales. It is still not clear that no one from Abby did this, but more
importantly Defendant King wrote back that day in the same email without a request for
retraction where he qualified the statement by stating that he would apologize if someone from
Abby was not responsible. Given Plaintiff's Penchant for fake Internet schemes and other
abusive tactics it's hardly a reach to think that they might have been involved. Appendix A-1.3
3
As we shall see in Section 2, infra the issues in subsection II b) are mooted for failure to adhere to basic
Defamation Law in Wisconsin in Plaintiff’s rabid attempts to shift the optics of these willful consumer violations
against Defendants. As the old adage goes, “when you point a finger at someone you have several pointed back at
yourself…” Which is exactly what Abby’s old friends have stated to Defendant King. We will get there if any aspect
of this case survives this Motion.
5
As to Rilla recording and surreptitious eavesdropping on April 30, 2024 or May 1, 2024 –
well before the purportedly Verified Complaint was issued -- Defendant King issued the
following clarification that Plaintiffs don’t fully address because of Bad Faith: The fact that
former Staffer and co-Defendant Riley Richarz would subsequently indicate that monitoring was
possible ["if you have another device from another person, like, listening to your appointment”]
is his story to tell and no liability could attach to Defendant King who has already stated that the
matter is in some dispute. That is all that Defendant King is required to say.
Note further that during a client meeting Plaintiff Binder wrote Mr. Richarz to tell him to
turn his Rilla on for porchlight sales, which involve leaving the recording device in the room
while a salesperson walks out of the home. These sales staff, on video and otherwise, told
Defendant King that they were coerced into recording or lose their jobs. Moreover, in addition to
staffers not wanting to use Rilla it is clear that Abby Management staff told them to use it and to
issue reports. See Appendix B.. It remains a question of Employment Law whether this is true
consent as Abby alleges but in any event it is well beyond the purview of any Defamation claim
that much is certain.
Abby wrote in its Verified Complaint:
Abby Windows’ sales associates sign a consent agreement upon their first use of the Rilla
software and, in a one-party consent state like Wisconsin, such recordings are legal so
long as the salesperson remains a party to the discussion.
Plaintiffs thereby tacitly acknowledge that it would be illegal for a salesperson to leave
the recording running while absent. In fact, they acknowledge that it is in an attempt to pin a
bogus Defamation claim against King and other Defendants:
On May 7, 2024, Defendant King posted a third video to YouTube entitled, “Interview
with Abby Windows Staffer on Payroll and Rilla Eavesdropping,” in which he
interviewed a former Abby Windows Account Associate, Fred Mayen. This video
contained numerous false statements about Abby Windows’ business practices. Most
notably, Defendants Mayen and King falsely claimed that Abby Windows engaged in
illegal eavesdropping on customers during sales calls. In effect, Defendants Mayen and
King accused Abby Windows and/or Binder of criminal activity because the
unauthorized recording of private conversations is a Class H felony in the State of
Wisconsin.
6
That’s right it is. That is part of why Defendant King and staff find Rilla to be
unconscionable, ab initio. Unfortunately for Plaintiffs, Defendant King has concrete proof that
Abby used recorded calls outside the presence of the salesperson as a customer was recorded
precisely this way as salesperson Matthew Collier left the room, and the Court can clearly see on
the right side where Abby Staff are grading the performance at a time no sales agent is even in
the room. Appendix B. Those materials have been forwarded to Law Enforcement and
Regulatory Agencies and if Abby’s pet media stations would actually like to know more I might
be able to do that but need to discuss with my Attorney first.
Here is what we do know: Online advertising expert Jason Brown, who has worked with
the State of Wisconsin on prior occasion in a directly-related case:
From: Jason Brown
Date: May 29, 2024 at 6:01:15 PM PDT
Erica,

Jason Brown
4
7
[On information and belief Reporter Finke has not lifted a finger to investigate anything, par for
the course so as not to bite the hand that feeds as staff and customers have claimed].
In any event the question of economic coercion is real as seen at Appendix D and right here as
well because it clearly has Defendant Richarz telling Abby he never wanted to use Rilla, the
same way that both he and Defendant Mayen told Defendant King on video. It is now proved by
sealed Appendix B-1 with senior Abby staff willfully reviewing customer deliberations in the
absence of a sales agent.
Note further that Defendant King had asked Abby about Rilla and nobody responded back on
May 1, 2024!!!
8
Among other things this quote was striking to me:
"We play by street rules....scour your house, make fake accounts, bribe middle-
schoolers and walk into a bank shouting "everybody listen up!" Play hard, play dirty
and the winner will be announced...."
Please confirm whether this is a true message or whether Taylor Stepaniewski contrived
it.
Also does your company employ "Rilla" software and does it surreptitiously record
customers?
Are customers ever told they are being recorded? Please advise.
********
After Plaintiff failed to appear or even call or write or provide any communication
whatsoever in response to the two (2) phone calls and seven (7) emails Defendant King
published his second video and then subsequent videos involving other former Abby staff. Abby
would later of course take exception to not being allowed to comment in the last and final
instance, which is patently ridiculous: They had more than enough opportunity to respond to
Defendant King’s inquiry and this will become yet more clear if the case even survives this
Motion; all former staffers and several homeowners have indicated to Defendant King that Abby
Binder intentionally avoids customers and is rude to them when she does respond; prior to
publication of the second and subsequent videos Defendant King was well aware that Plaintiff
Binder threatened a criminal Extortion case against an innocent homeowner and refused to
discuss long-uncompleted work with them unless they removed a negative post in complete
derogation of ATCP §110.027 Delay in contract performance and FTC/Google guidelines.
Plaintiffs filed this purportedly Verified Action on or about May 16, 2024, citing
allegations of online/broadcast and written Defamation. They failed to provide any written or
oral requests for retraction from Defendant King prior to filing. Defendant King immediately
demanded that Plaintiff and Counsel provide a copy of the Complain to him with a Summons
Waiver. Several days later Defendant King received the Complaint and accepted Service of
Process via email.
Putative pro hac vice Counsel Steven Couch filed for inclusion on May 31, 2024. No
notice was given to any Defendant. On June 7, 2024 Defendant King objected to the Couch
Application.
9
2. All Claims Concerning any Written Materials Must be Dismissed Out of Hand.
Plaintiffs attempt to base several claims on written purported Defamation without seeking
Retraction. This is a patent violation of Statute. Wis. Stat §895.05(2) and shows that the true
motive for this case is nothing more than retaliatory
https://docs.legis.wisconsin.gov/statutes/statutes/895/i/05
Plaintiffs identified the following items in their Verified Complaint.
a. The Written Sperm Incidents.
Defendant King republished a portion of Defendant Richarz’ Demand Letter.
In addition to forcing me and others to illegally record homeowners under threat of

termination (coercion according to State regulations below) there were requests made of
me for my semen for Abby to have a child with her partner Mandy while I was employed
by the company.
b. The Allegations of Tampering with Equipment.
Defendant King issued the following written statement after he was spammed and folders
went missing on his computer:
To All,
Yeahh.... I'm missing about 9 folders and things out of other folders.... can't communicate
on my macbook with Taylor.... Riley Richarz' folder had but two (2) items in it this
morning until I downloaded the Demand Letter he sent to
the "snake in the grass" Abby: https://www.scribd.com/document/727945642/KingCast-
Fields-Allegations-of- Widespread-Elder-Abuse-and-Illegal-Eavesdropping-by-Window-
Companies- AbbyWindows
I will get you dirty PoS (Princesses of Slime).
And oh yeah... I've got backups of my zoom with him anyway you motherfuckers. Video
coming later today so to hell with you and your dirty-assed company. You took working
files and a bunch of stuff all because I am telling the truth about your company.
Next video title: Cruel Abusive Women Demand Cum from Male Worker Bee
You do indeed "Play Hard and Play Dirty" as you say but I got something for ya. And not
it's not a physical threat from a Dangerous Black Man. I'm on dangerous because I'm
adept at exposing your bullshit.
10
c. The Elder Black Matriarch.
An Elder Matriarch is in love with these people even as they silently rob her blind
with already inflated charges and another $1K bump for no lawful reason
whatsoever. In this dirty industry it is known as face punching. “I punched that old lady
right in the face” was heard at another company for example.
[* * *]
They would not know the truth if it walked up and slapped them in the face.
d. Public Participation Emails to State Staff:
Dear Attorney Opper and State Representative Callahan;
I write you as a former AAG and lifetime Journalist to inform you of some patently False
and Deceptive Consumer practices by Abby Windows and Exteriors.
https://www.scribd.com/document/727945642/KingCast-Fields-Allegations-of-
Widespread-Elder-Abuse-and-Illegal-Eavesdropping-by-Window-Companies-
AbbyWindows
Multiple staffers have directly informed me that they price gouge, issue materially false
customer reviews, misclassify employees and illegally record customers while in the
commission of overcharging them to boot, which arguably wobbles this into Felony
status as I note in my commentary in the Abby video below.
[* * *]
Somewhere in all of this I am certain that your office has jurisdiction to commence a
thorough investigation, working with IRS/Department of Treasury, Agriculture and other
agencies seeing as the IRS/Treasure Department has already dinged them on
misclassification. [...]
I can put you in touch with many former employees who will take a polygraph and offer
other verifiable information for your office. They will no doubt try to blame me or the
many staffers who dare to speak the truth but none of us are having one scintilla of
THAT. They did the actions, they suffer the consequences and sadly their customers are
suffering as well.
Warm regards, Christopher King, JD
[* * *]
11
PS: I have spoken with Patrick Studenec on this and he felt in large part that his hands
were tied but in reality I have just given you proof that these people surreptitiously record
homeowners and when they leave the room there is a clear cut violation there even in a
one party state. IMO the legislators have to get busy to modify the law when it comes to
commercial recordings at a consumer home, where they have a complete expectation of
privacy right. Contrast State v. Riley, 2005 WI App 203, 287 (2005). His agency has
recently noted for example that Home Improvement is the #3 claim in his office right
now and this is certainly part of it.
Plaintiffs’ claim a, b and c to be Defamatory and that d is essentially defamatory as it

is based on allegedly Defamatory statements. It is ultimately doubtful that any of these
statements are actually Defamatory for numerous reasons but we need to even analyze this
frivolous claim because there was no adherence to Statute, period and end of story.
See Hucko v. Jos. Schlitz Brewing Co., 302 NW 2d 68 - Wis: Court of Appeals 1981
and Schultz v. Sykes, 638 NW 2d 604 - Wis: Court of Appeals 2001:
We agree with ALI that it was not required to request a retraction from Sykes because his
statements were not made in print. See It's in the Cards, Inc. v. Fuschetto, 193 Wis. 2d
429, 436, 535 N.W.2d 11 (Ct. App. 1995) (holding that notice requirement of WIS.
STAT. § 895.05(2) applies only to libel made in print). We do not agree, however, that
we are precluded from considering ALI's failure to make the request with respect to the
Journal Sentinel because the Journal Sentinel failed to raise the issue in the circuit court.
Failure to request a retraction under WIS. STAT. § 895.05(2) is not an affirmative
defense. Rather, the notice requirement of 790*790 the statute is a condition precedent to
the existence of a cause of action for libel where the statute applies, and a circuit court is
not competent to hear the claim until the condition is met. Cf. Elm Park Iowa, Inc. v.
Denniston, 92 Wis. 2d 723, 728-29, 286 N.W.2d 5 (Ct. App. 1979) ("[N]o civil action for
damages can be brought or maintained unless the condition precedent of required notice
is given."); see also Hucko v. Jos. Schlitz Brewing Co., 100 Wis. 2d 372, 380-81, 302
N.W.2d 68 (Ct. App. 1981) (holding that failure to request retraction under § 895.05(2)
requires that claim be dismissed). The Journal denied in its answer that ALI had
demanded a retraction, and that was all it was required to do. Therefore, because ALI
never demanded a retraction from the Journal Sentinel, its claim against the Journal
Sentinel must be dismissed.
Further,
Once a claimant has been found to not meet the notice requirements, the action cannot be
revived by again attempting to comply with the notice provisions. DeBraska v. Quad Graphics,
Inc., 2009 WI App 23, 316 Wis. 2d 386, 763 N.W.2d 219, 07-2931. So those "Claims," specious
as they were in the first place, are now completely TOAST and Abby's Counsel should have
known this but instead valuable Judicial and Defendant resources have been squandered.
12
3. All Claims Concerning any Spoken Allegations Fail on their Face.
Plaintiffs allege the following areas of broadcast Defamation:
a). The Sperm Incidents

b). The Elder Black Matriarch
c). Allegations of Willful Surreptitious Recording on the Absence of Sales Staff.
d). Statements made by Defendant Mikki Campbell.
f) Taylor Stepniewski’s Comments.
Addressing these in seriatim:
a). The Sperm Incidents and Riley Richarz Jurisdictional Matters.
First of all anything to do with Defendant Richarz’ alleged actions belong in

Mandatory Arbitration. It must be noted that Defendant Richarz’ employment contract reads
like an indentured servitude arrangement. He waives basically everything, including any
discrimination or harassment claims. Defendant King obviously questions the unconscionable
nature of this adhesion Clause contract as well as the fact that it purports to be binding on all
parties with respect to the Boilerplate Adhesion Clause Arbitration Clause that is all-
encompassing, to wit:
Section 20. LEGAL PROCEEDINGS AND ARBITRATION. COMPANY AND ACCOUNT

ASSOCIATE AGREE THAT ANY AND ALL DISPUTES, CLAIMS, OR CONTROVERSIES
HEREAFTER REFERRED TO AS A "CLAIM") ARISING UNDER OR RELATING TO THIS
AGREEMENT, INCLUDING BY WAY OF EXAMPLE AND NOT AS A LIMITATION: (I)
THE RELATIONSHIPS RESULTING FROM THIS AGREEMENT; ( I ) THE BREACH OR
ALLEGED BREACH OF THIS AGREEMENT BY EITHER PARTY; (III) MATTERS
ARISING FROM ACCOUNT ASSOCIATE'S WORK AT COMPANY, INCLUDING, BUT
NOT LIMITED TO, TERMINATION, CLAIMS OF AGE, GENDER, O R DISABILITY
DISCRIMINATION, SEXUAL HARASSMENT, OR CIVIL RIGHTS VIOLATIONS; OR (IV)
THE VALIDITY OF THIS AGREEMENT OR THE VALIDITY OR ENFORCEABILITY OF
THIS ARBITRATION PROVISION, SHALL NOT BE INITIATED OR OTHERWISE
COMMENCED BY EITHER PARTY MORE THAN SIX (6) MONTHS AFTER THE DATE
THAT THE RELATIONSHIP UNDER THIS AGREEMENT SI TERMINATED,
REGARDLESS OF THE REASON FOR THE TERMINATION, AND THAT ACCOUNT
13
ASSOCIATE AND COMPANY AGREE TO WAIVE ANY STATUTE OF LIMITATIONS TO
THE CONTRARY THAT MIGHT OTHERWISE ALLOW FOR SUCH CLAIMS TO BE
BROUGHT AFTER THIS SIX (6) MONTH PERIOD.
BOTH COMPANY AND ACCOUNT ASSOCIATE ARE HEREBY AGREEING TO CHOOSE

ARBITRATION, RATHER THAN LITIGATION OR SOME OTHER MEANS OF DISPUTE
RESOLUTION TO ADDRESS THEIR GRIEVANCES OR ALLEGED GRIEVANCES WITH
THE EXPECTATION THAT THIS RESOLUTION PROCESS MAY BE MORE COST-
EFFECTIVE AND EXPEDIENT FOR THE PARTIES THAN LITIGATION. BY ENTERING
INTO THIS AGREEMENT AND THIS ARBITRATION PROVISION, BOTH PARTIES ARE
GIVING UP THEIR CONSTITUTIONAL RIGHT TO HAVE ANY DISPUTE DECIDED IN A
COURT OF LAW BEFORE A JURY, AND INSTEAD ARE ACCEPTING THE USE OF
ARBITRATION, OTHER THAN AS SET FORTH IMMEDIATELY BELOW.
1. The parties agree that due to the possible immediate and irreparable harm from a violation of
the restrictive covenant sections of this Agreement, these arbitration requirements shall not apply
to any restrictive covenant provisions, rights, and legal remedies contained elsewhere in this
Agreement.
2.If there is a small claims court (or an equivalent type of court) located within the county and
state in which Account Associate resided during Account Associate's work with Company,
Account Associate may, in accordance with the rules of that small claims court, choose to bring
(and must then keep) Account Associate's own claim in that small claims court.
The only avenue in here is the subsection 1 clause dealing with irreparable harm, but had
Plaintiff and Counsel done their homework they would have known that Defamation is in the
irreparable harm category, ab initio. It will be interesting to see how that plays out for those
Parties because this case was not filed against him in Arbitration but that entire hornets’ nest has
to be sorted before anything moves forward in this venue. Defendant King will wait for that to be
litigated and will of course Petition the Court to file an Amicus or supporting co-Defendant full
briefing on the matter.
First however let us review William & May Law Rev v. 55 (2013) Issue 1, Article 2
because the reason Riley Richarz is involved here is…. Defamation. But Defamation is not an
irreparable harm so Riley Richarz should probably file for Arbitration and share his spreadsheet
and see what happens but whatever the case one thing for certain it’s not happening here.
2. A Preference for Legal over Equitable Remedies
The law’s antipathy toward injunctions in defamation cases is also rooted in the
longstanding view that legal remedies are preferable over equitable remedies.98 This
principle is so ingrained in our legal system that the Supreme Court has stated, “[I]t is
axiomatic that a court should determine the adequacy of a remedy in law before resorting
14
to equitable relief.”99 Although this view is attributable, at least in part, to the historical
division between courts of law and courts of equity, the preference for legal remedies
persists today.100
By the mid-twentieth century, fewer courts were interposing a lack of equity jurisdiction as
a reason for denying injunctive relief. Instead, they began to rely on the more general
equitable principle that a plaintiff is not entitled to injunctive relief if she has an adequate
remedy at law.101 In Texas, for example, courts assume that money damages are an
adequate remedy for defamation unless the speech sought to be enjoined includes a threat
of harm to another.102
Some judges also describe this reason for denying injunctive relief in terms of a plaintiff’s
failure to demonstrate “irreparable injury,”103 which is simply another way of saying that
a plaintiff has an adequate remedy at law.104 Both approaches ultimately function as a
means of channeling plaintiffs toward monetary relief and away from equitable remedies,
such as injunctions.
A review of the cases reveals that courts have denied injunctions in a wide variety of
circumstances, including cases in which the defendant police department was continuing to
display the plaintiff’s photograph in its “rogues’ gallery” after criminal charges were
dropped;107 the defendant was publishing a circular that falsely stated that the plaintiff
attorney was a “[s]hyster egomaniac ... [who had made] deliberately false statements” in
legal proceedings;108 and the plaintiff’s mother-in-law was slandering her to the plaintiff’s
husband so as to alienate his affections.109
Next, there is no Actual Malice involved here: There are two types of malice: “Express
malice” is that malice described in the jury instruction used in this case, that is “ill will,
envy, spite, revenge,” etc.; the supreme court in Rosenbloom also referred to this type of
malice as “common law malice.” “Actual malice” (referred to in the New York Times
case) is not malice at all, rather it is knowledge that a statement was false or published with
reckless disregard of whether it was false or not. “Actual malice” is what is required for a
constitutional determination of libel under New York Times.
“Express” and “actual” malice are very different concepts.
The term “actual malice” arises when there has been an abuse of a constitutional
conditional privilege, i.e., where one makes a defamatory statement “with knowledge that
it was false or with reckless disregard of whether it was false or not.” New York Times Co.
v. Sullivan (1964), 376 U.S. 254, 279, 280 84 Sup. Ct. 710, 11 L.Ed.2d 686; 95 A.L.R.2d
1412.
The problem of actual malice arises in the cases involving first amendment protections
afforded to the media, such as newspapers, television and radio, or comments made about
public officers or public figures. See 2500 Wis. JI-Civil Defamation: Law Note for Trial
Judges.
15
Abby Binder is clearly a Limited Purpose Public Figure and *ALL* of the matters
pertaining to her in this case involve the actions of her, her rank-and-file partner cum VP Mandy,
other Abby managerial staff and Abby worker bees. As such any prior restraint against this
Journalist, should the Court be leaning towards that, simply cannot issue because from the basic
preliminary evidence present it is clear that preservation of a Free Press must be sustained in the
absence of any willful patently false or Defamatory statements and we can clearly see that there
is substantial basis to believe everything that was published or rebroadcast by everyone in this
case. See generally Near v. Minnesota, 238 U.S. 697 (1931).
Plaintiffs believe that the broadcast of Riley Richarz’ allegations that Abby Binder and/or
VP Mandy constitutes Defamation. Obviously truth is a Defense, and based on the record before
us that included the items of drunken frolicking and a late-night ride share called by Defendant
Richarz.
Significantly Plaintiff did not call out Mr. Richarz for stating that there were breast shots
from snapchat, or that Mandy arrived at his house drunk and disheveled, clothes hanging off of
her and “tried to make a move on [him]” so those allegations, taken in tandem with the rideshare
proof, render all of that quite probable. Appendix D. It’s hardly a jump of any consequence to
believe that other opprobrious behavior occurred as well, and if this cause is not dismissed the
other staff and friends who witness all of this will be called to testify, and to find their electronic
devices, same as Plaintiff Binder and then we will see who’s lying.
Meanwhile at Appendix D also note the written statement of Defendant Richarz’ Fiancée
regarding multiple discussions about him (and his father, another Abby staffer they accused of
something nefarious, wait for it) being a sperm donor.
We were all talking about wanting children one day, and the topic got brought up if either
Abby or Mandy would carry their future children due to them being a Lesbian couple.
Both Abby and Mandy mentioned they would want their future children to have Abby’s
athletic ability and stature. Abby then made a reference to wanting Riley’s father, Jack
Richarz, who was also employed by Abby at the time, to be the sperm donor for their
future child/children due to his athletic ability, and handsome looks. Abby then said that
she knows Riley’s mother Sheila, would never approve of that happening. Abby then
stated that Riley would be a perfect second choice to being the biological father of Abby
and Mandy’s future child/children. Abby and Mandy have both made multiple remarks
about both Jack and Riley’s desirable genetic traits, and how they would be ideal semen
donors.
16
These are requests coming from the owner of a $12M company who, according to
multiple staffers, abuses her staff like it’s going out of style and who basically owns all of the
media where she advertises. Where the Defamation appears in all of this for telling the Truth
remains to be seen and on the face of these facts and allegations no Action against Defendant
King shall lie for the mere reporting of a dispute; if that happens we might as well just hand the
keys to all media over to high-dollar businesses.5
The law is clear again from 2500:
In cases involving a public official or a public figure versus a media defendant or
private individual, the plaintiff has the middle burden of proof, i.e.; by evidence that
is clear, satisfactory, and convincing to a reasonable certainty. Polzin, supra at 586;
Calero, supra at 500.
Would Plaintiff Binder go for two Perjury findings in one case? Only time will tell but
here’s the nugget: Based on the statements that Defendant King had, and what he has shown
here, there is no clear and convincing evidence that the statements aired on his broadcast were
indeed Defamatory when other staff have verified them. When several people verify that a
comment was stated there is no liability to befall a Journalist as Plaintiff and Counsel should well
be aware of, given the landmark Verdict just last year in Tomczyk v. Wausau Pilot & Review
when they reported that he called someone “a faggot.”
https://www.wpr.org/justice/wausau-news-site-raises-money-legal-fees-after-politician-sues-
defamation
‘Even if we win, we lose’: Wisconsin news site raises money for legal fees after politician
sues for defamation
A Marathon County judge dismissed a suit against the Wausau Pilot & Review, but the
outlet says legal costs put it in danger of shutting down
BY SARAH LEHR
AUGUST 17, 2023
Note further that the Defendant in Mathewson v. Roberts was not liable for Defamation
even though he made false statements about a public figure as is Plaintiff(s).
https://wisconsinexaminer.com/2023/07/14/jury-rejects-defamation-claim-made-by-kenosha-
blogger-kevin-
mathewson/#:~:text=KENOSHA%20%E2%80%94%20A%20Kenosha%20jury%20determined,i
n%20Kenosha%20County%20Circuit%20Court.
5
Oh, wait. Bagdikian enters the room again.
17
• POLITICS & GOVERNMENT
Jury rejects defamation claim made by Kenosha blogger Kevin Mathewson

BY: DEE HÖLZEL - JULY 14, 2023 5:45 AM
KENOSHA — A Kenosha jury determined comments made about former alder and
controversial blogger Kevin Mathewson did not rise to the level of defamation following
a four-day trial in Kenosha County Circuit Court.
The jury delivered the verdict on Thursday after approximately six hours of deliberation
in Mathewson’s defamation suit against Raymond Roberts, who used social media to
repeatedly describe Mathewson as a racist with white nationalist connections. Mathewson
had claimed his reputation and standing in the community were damaged by the posts
Roberts had made about him.
Mathewson also claimed Roberts endangered his family by publishing his address,
though no actual threat materialized, and further injured his standing at his children’s
school by claiming Mathewson was training his children to be suicide bombers.
The case went to the jury Wednesday after Roberts testified in the lawsuit, telling the jury
that he believed what he said about Mathewson to be true. Roberts also said it was his
opinion Mathewson’s reputation was not damaged because “he has no reputation, in my
opinion.”6
6
Here is the nugget of Truth: While Defendant is not basing this Motion on the public reputation of Abby Binder
and her company (as it sits today not 4 years ago) the facts are going to show that Plaintiff’s long time associates
echo Mr. Roberts’ sentiments there’s not even a pyrrhic victory to be had for Plaintiffs here, just a long and
embarrassing “Come to Jesus Moment” as one interviewee stated to Defendant King.
18
b). The Elder Black Matriarch.
Plaintiff claims that the sale was never consummated, and that Riley Richarz was wrong
about the sale amount and was corrected by senior staff present at the sale, etc. etc. That doesn’t
work anyway because prior to publication Defendant King had seen the below screen shot that
was circulated throughout the hallowed halls of Abby Windows, clearly indicating a sale.7
Furthermore, even if the sale was not consummated Defendant’s statement that Plaintiff
was robbing her blind would apply to attempted robbery anyway in the eyes of any listener the
attempt and the final success is a distinction without difference.
c. Allegations of Willful Surreptitious Recording on the Absence of Sales Staff: Perjury.
Defendant King specifically warned Counsel about this on one context earlier but they
did not listen even though another staffer heard it herself:
And I’ve witnessed her talk about Riley and his sperm. Multiple times……..
7
There are other reasons why Defendant King knows that Defendant is lying about what truly happened in that
house but it’s not necessary to delve into that in this Motion for obvious reasons.
19
Not only could that point to Perjury folks.....and so based on that statement alone (much
less Riley Richarz's statements to me) I have zero liability whatsoever for my position
posting staff stating that it did in fact happen and no Jury instruction is going to read
otherwise should it ever even come to that. That is a valid report from a former staffer. If
it's s more an issue for a 12(b)(6) or Rule 56, whatever. Riley wasn't lying about the
rideshare nightmare so why would he lie about this?
Perjury is a Class H Felony Wis. Stat §946.31.
https://docs.legis.wisconsin.gov/statutes/statutes/946/iii/31
But that is not the Perjury we are discussing today. The Perjury we are discussing
today is the fact that Plaintiff wrote in the purportedly Verified Complaint:
17……..[M]ost notably, Defendants Mayen and King falsely claimed that Abby
Windows engaged in illegal eavesdropping on customers during sales calls. In effect,
Defendants Mayen and King accused Abby Windows and/or Binder of criminal activity
because the unauthorized recording of private conversations is a Class H felony in the
State of Wisconsin.
19. In fact, Abby Windows did encourage salespersons to give prospective customers
space to discuss the proposed deal, Abby Windows did not direct its sales personnel to
leave any device to record the private conversations of prospective customers. Any claim
to the contrary is false and defamatory.
Plaintiff’s problem – and it is a huge problem that Defendant King tried to warm them about – is
the fact that Plaintiff King, as noted above, has absolute proof as noted above, that Abby
Managerial staff took copious training notes and such on this file while the sales rep was not
present in the home at Appendix B-1. In the sealed document Here are the screenshots from
Appendix B-1 with the notes on the far right side as they listen post hoc and evaluate.
[Appendix B-1 filed Under Seal]
PERJURY AND FALSE SWEARING

946.31 Perjury.
(1) Whoever under oath or affirmation orally makes a false material statement which the person does
not believe to be true, in any matter, cause, action or proceeding, before any of the following,
whether legally constituted or exercising powers as if legally constituted, is guilty of a Class H
felony:
(a) A court;
(2) It is not a defense to a prosecution under this section that the perjured testimony was corrected or
retracted.
20
Perjury consists of a false statement that the defendant knew was false, was made under
oath in a proceeding before a judge, and was material to the proceeding. Materiality is
determined by whether the trial court could have relied on the testimony in making a decision,
not on whether it actually did. State v. Munz, 198 Wis. 2d 379, 541 N.W.2d 821 (Ct. App.
1995), 95-0635.
Now that is patently clear that Plaintiffs have lied in what is arguably the biggest issue in
this entire case, the Court must grant the requested Show Cause Hearing to bring this case
forward to where it needs to be and to potentially save innocent Wisconsin taxpayers from
shouldering the cost of Abby Binder’s historical vituperative largesse. Naturally should any
claims actually remain in this case when the Motion is argued and should any such claims further
survive Summary Judgment then Defendant(s) are all entitled to a somewhat limiting Jury
Instruction that the Plaintiff has already Perjured herself in a Sworn and Verified Complaint.
This is obviously another seminal point in the litigation as a core issue and Abby Binder
completely lied and it is right here on the page (and in the audio) to prove it. And now her
lawyers (Timothy Andringa and putative Counsel Steven Mark Couch) are on Actual Notice of it
as well, with all of the Ethical implications involved, i.e. SCR §20:3.3:
(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;
(3) offer evidence that the lawyer knows to be false. If a lawyer, the lawyer's client, or a witness
called by the lawyer, has offered material evidence and the lawyer comes to know of its falsity,
the lawyer shall take reasonable remedial measures, including, if necessary, disclosure to the
tribunal. A lawyer may refuse to offer evidence, other than the testimony of a defendant in a
criminal matter that the lawyer reasonably believes is false.
(b) A lawyer who represents a client in an adjudicative proceeding and who knows that a person
intends to engage, is engaging, or has engaged in criminal or fraudulent conduct related to the
proceeding shall take reasonable remedial measures, including, if necessary, disclosure to the
tribunal. (c) The duties stated in pars. (a) and (b) apply even if compliance requires disclosure of
information otherwise protected by SCR 20:1.6.
….and potentially SCR §20:3.4
A lawyer shall not:
21
(a) unlawfully obstruct another party's access to evidence or unlawfully alter, destroy or conceal
a document or other material having potential evidentiary value. A lawyer shall not counsel or
assist another person to do any such act;
(b) falsify evidence, counsel or assist a witness to testify falsely, or offer an inducement to a
witness that is prohibited by law;
(d) in pretrial procedure, make a frivolous discovery request or fail to make reasonably diligent
effort to comply with a legally proper discovery request by an opposing party;
(e) in trial, allude to any matter that the lawyer does not reasonably believe is relevant or that
will not be supported by admissible evidence, assert personal knowledge of facts in issue except
when testifying as a witness, or state a personal opinion as to the justness of a cause, the
credibility of a witness, the culpability of a civil litigant or the guilt or innocence of an accused;
or….
d). Defendant Fred Mayen is Another Innocent Victim of Plaintiff.
Defendant King has already told Counsel for Plaintiff the Truth about Fred Mayen and
that Truth is that he was entitled to his money and he didn’t get it. When he wrote a nasty review
seen below discussing the price gouging and the unlawful construction delays and the CCAP
activity they gave him his money, but the manner in which it was conducted was completely
nefarious, with nothing in writing and a hushed call from the personal phone of the COO who
never had any time for anyone. This and more will all come out if we keep going here. Much
more.
22
Abby: All the work, none of the pay: It’s what she’s about and her paid in full press pals have
thus far sidelined any and all journalistic integrity to avoid any public discussion of Abby
because folks are going to come out of the woodwork against her. That is what’s going on here
and Defendant King will bear no compunction to call a spade a spade.
23
e). Statements made by Defendant Mikki Campbell on Workplace Manifestations
of the Relationship Between Abby Binder and Mandy, her Former Co-Worker.
These allegations lack specificity sufficient enough to put any Defendant on Actual
Knowledge of the allegedly Defamatory statements but suffice to say first that Defendant King
has notified Counsel for Plaintiff that the situation with Mandy being abruptly promoted from
rank and file to Vice President has repercussions that directly impacted her at work because
Mandy came to her in the workplace. Defendant told them on June 7, 2024:
9. They claim that Mikki's comments about how Abby swooped up a rank-and-file staffer
and married her and threw her then-wife/soon-to-be former out of the house is not truly a
private matter because Wife #2 became Mikki's and everyone's boss and by all accounts
is ineffective and just an Alter Ego manifestation of Abby. Mikki wrote an email about
this earlier this week and has confirmed to me that the personal side also spilled over into
the business side because Wife #2/VP Mandy came running to her IN THE
WORKPLACE in some drama moment not dissimilar to the drama when Riley called
Mandy a rideshare to his house, all of which is shown in screenshots.
Hello Mr. King,

Let me say again, everything that past employees have said is the truth. If you listen to
Abby, she would have everyone believe we are all lies and she is the only one telling the
truth which is not so. I stand by everything I said about Abby and the way she runs her
business and treats people. Hell, I have no reason to lie. The day she or lets say she had
someone left me go, was the best day I had at Abby Windows plus I got unemployment on
top of it.
And let me add to the statement about Mandy becoming VP just after they got engaged.
Now not only did all the employees have to answer to her, she was never there. She and
Abby spent weeks at a time gone. Then they would come in and hold your fingers over the
flames sort of speak for anything that did not meet their expectations. Mandy could not
find her own ass in the dark let alone be a VP.
Now if they want to try and sue me for my little social security check for speaking the
truth. Let them come.
Sincerely,
Mikki Campbell
As such, there is a clear-cut nexus between Mandy’s ascent to her VP position has clearly
manifest workplace manifestations so there’s no Cause of Action here. In fact, this kind of
activity is indeed questionable again just last year:
24
https://www.cbs58.com/news/gov-evers-defends-not-having-policy-against-supervisors-dating-
staffers
https://wisconsinwatch.org/2023/09/tony-evers-spokesperson-raise-promotion/
Did a spokesperson for Wisconsin Gov. Tony Evers who lives with Evers’ chief of staff get a
raise and promotion to a position that reports to the chief of staff?
YES.
The Milwaukee Journal Sentinel reported Aug. 31, 2023, that Maggie Gau, Wisconsin Gov.
Tony Evers’ chief of staff, has lived for at least a couple of years with a staff member who
directly reports to her.
The staffer was appointed in January 2019 to a position at $62,000 that did not report directly to
Gau but was under her chain of command, the Journal Sentinel reported, citing a statement from
Evers’ office.
On Nov. 8, 2020, Evers promoted the staffer to a top-level position that reports to Gau at a salary
of $100,006. The newspaper said the statement from Evers’ office was not clear on Gau’s role in
the promotion.
The staffer got a raise to $112,008 in January 2023, the Journal Sentinel reported.
Milwaukee radio talk show host Mark Belling identified the staffer as Britt Cudaback, Evers’
communications director.
https://www.news8000.com/news/politics/local-politics/gov-evers-defends-chief-of-staff-being-
in-relationship-with-staffer-she-supervises/article_60f1cd14-4c6c-11ee-bce8-eb42e2f63bfd.html
Gov. Evers defends chief of staff being in relationship with staffer she
supervises
Sep 5, 2023 Updated Mar 21, 2024
MADISON (WDJT) -- Supervisors dating staffers.
25
It's a policy banned in the Wisconsin State Legislature and countless employers, but the
governor's office doesn't have a similar ban in place.
That's drawing criticism now that Tony Evers' chief of staff is reportedly dating a staffer
she directly supervises….
…..Many other employees who work at the Capitol are subject to strict guidelines. The
Assembly and Senate's policy says, "any relationship between supervisors and
subordinates are not allowed."
It goes on to state these relationships "may give rise to legal and ethical concerns."
Of course it does, in a private or public employment context but Abby never met a
detractor she didn’t want to sue, so here we sit, burning substantial taxpayer dollars and Judicial
resources. What is particularly offensive is Plaintiff’s attempts to downplay this obvious ethical
question when Defendant King is sitting here as a former Employment Law Attorney (State and
Private) with a mother who retired as a HR Specialist at General Electric. Who do they think
they are fooling here? Just, wow. Wow.
f) Taylor Stepniewski’s Comments are Not Actionable.
Ms. Stepniewski wrote:
****EDITED TO ADD SINCE THEY’RE STILL GETTING TRUTHFUL REVIEWS

REMOVED AND GETTING THEIR EMPLOYEES, FRIENDS, AND FAMILY TO
ADD FAKE ONES**** (proof attached)
This company is hands down the WORST company you could ever have the displeasure
of working with. For the love of god, go anywhere else. Save your money, your sanity,
and your time and effort. If you do happen to still go with this company for whatever
reason they slime-balled you with, please do not be fooled by her twist of words when it
comes time to sign the certificate of completion. DO NOT SIGN THE CERTIFICATE
OF COMPLETION UNTIL YOUR PROJECT IS 10000000% DONE. I don’t care if they
tell you “this is just the part we completed today” it’s all a lie. That’s how they process
your financing. Once they have your money, WHO CARES IF YOU STILL HAVE
WORK TO BE DONE, they have your money and have been instructed BY THE
OWNER to focus on the people that still owe money. If you have a service, you’re put on
the back burner until you start threatening and reporting to the bbb. Best of luck.
26
Oh and Abby, take your useless cease and desist letters and shove them where the sun
don’t shine. !8
Yikes...stay away. They pay for positive fake reviews and flag the negative ones so
potential customers can’t see the real deal. They will flag this and it will be removed in
no time. If you have a problem that escalates, the only way to get a response is to go to
the BBB and only then will she try to “fix” the problem with a weak, unfair, offer of
resolution. STAY AWAY!!!! The more I find out the more shocked I get that IT STILL
GETS WORSE. STAY FAR FAR AWAY AND SAVE YOUR SANITY.
It is clear that her factual comments actually have merit based even on the preliminary
level of documentation that has been put into the work by the date of the Verified Complaint and
her opinion comments are certainly not actionable either, unless Abby is now the employer and
the Thought Police…. Which might actually be the case in her mind because recall she told Riley
Richarz he could no longer talk to Dan Tarpey when the IRS/Department of Treasury issued a
finding in his favor that he had been misclassified as an Independent Contractor. “You can’t talk
to him if you want to work at Abby Windows” is exactly what he said in the video.
4. Miscellany: Proprietary Information; Claw Back Clauses and Threats of Arson.
Abby claims that proprietary information has been leaked. This too fails for vagueness
and requires a More Definite Statement but Defendant King has been informed that Abby staff
was typically compelled to purchase their own electronic devices; these devices were then used
to record unwitting customers. This begs the question as to who owns the Intellectual Property
involved: To this observer the only people who have a claim to that discussion are the
homeowner and the sales agent.
8
True to form, that is exactly what this “lawsuit” is all about: Plaintiff Binder’s rogue vanity. She lives in a World
where she believes she is beyond reproach, and that she can just hire lawyers to smash people like the six of us with
far less financial resources. It’s disgusting. We will all say as much in that Jury Box if the case ever goes that far,
and the Jury will agree with us, and it will all happen on KingCast cameras. I’ll put in my Notice of Media Coverage
if we go that far, and nobody in Wisconsin is going to come and tackle my cameras this time either.
27
Also when reading the Crismond contract note that it is so poorly written that it contains
a dangling modifier that goes to…. Nothing. More on this if the case proceeds but it is a FACT.
Lastly, there was no threat of arson or “burning the place down” and this is readily
proved by the fact that Crismond was involved in several communications with other Abby
lawyers at this time and there was absolutely no mention of this. Given Abby’s penchant for
threatening legal action she would never have missed a chance to throw that sort of thing in Mr.
Crismond’s face. It never happened and in fact Defendant King told Counsel for Plaintiff in this
case that it was a lie when he sent an email containing a salient part of Mr. Crismond’s letter to
them that read:
From: Jay C
Date: Fri, Jan 19, 2024 at 5:13 PM
Subject: Follow Up
To: Abby Binder <abby@abbywindows.com>
Abby,
I am writing this letter to express my concerns regarding the lack of communication,

collaboration, and support in the tasks outlined in our written and verbal agreement. As
discussed in multiple meetings with you, I found it a bit concerning that during a
multiphase interview process before receiving an offer, I was under the impression that
during my meeting with the executive team, all necessary discovery conversations were
complete. One thing that was said during our very first conversations was your desire not
to have a "yes man" in the position I was contracted to fulfill, however, the statement of
needing "A brass cop, not a cops cop", I found to be quite alarming.....
..... During this time, I attempted to build a formative relationship with leadership on the
operations side of the company to have a better understanding of pipeline concerns that
were affecting timeliness and responsiveness for customer orders. On December 17th, I
was sent a Jobs by Status report that listed jobs not moved to measure or fulfill in a status
in CRM called Questions/Hold. What was determined while analyzing said report was
that the company was currently sitting on nearly three-quarters of a million dollars of jobs
not nettable due to some procedural compliance issues. I made contact with your CFO to
obtain login credentials for your current lenders so I could remotely solve any job that
was held up in the aforementioned report for financing document completion. During this
time I also reached out to build relationships and collaborate with your internal order
fulfillment team to get a better understanding of your organization's intake process so that
I could be integral in maintaining the compliance necessary to deliver and fulfill the
promises made to customers through installation contracts. It was during this time that
information was coming to me from operations desiring the punishment and termination
of several individuals on your salesforce who were consistently found on jobs noted in
the previously mentioned Questions/Hold report.
28
.....I requested numerous times the outlined curriculum and any testing that was necessary
to graduate your trainees. There was no response or information regarding those
requests. I began to receive text messages and phone communication requesting a
timeline on when the people I was not training would be prepared for the field and
leaving a training environment. Only 2 days before your vacation with your Vice
President, on 1/18/2024 you agreed to sit with me and review your own company's
training material. During this time, I was shocked to find out that you had never
looked at it. (emphasis added). I continued to utilize voice analytics to aid in identifying
the patterns and gaps in training while arriving at the company's office early each day to
address these issues. It is my professional opinion that my input in lack of standardization
and effective training was perceived as a personal threat and an attempt to expose one's
incompetence and have since observed a pattern of triangulation of communication,
rumor, and overtly passive-aggressive behavior. Rumors of complaints about my training
information surfaced through a conversation I had with you after business hours.....
Moreover, the Crismond Contract is also a product of abuse: It was materially changed
after initial agreement to include a claw back clause to the five thousand dollar ($5,000) forward
to Crismond for relocation, and he was told that it was in cause he quit. In reality they fired him
when he pushed back on abusive practices and his successor was already groomed before
Crismond even made his exit! It is Bobby Jones, the staffer who jacked up the price against the
Black Elder homeowner noted previously.
5. Epilogue: Clean Hands and Abby Managerial Conspiracy to Create Fake Reviews.
It is notable that Plaintiffs did not take exception to the fake reviews noted in this case,
even as they claim in the Sworn and Verified Complaint Plaintiffs actually have the nerve to
Swear “We practice Ethical Conduct” or words of virtually identical import. The laughter
quotient of such a statement is simply right off the Richter scale. The hubris to make that
statement -- whilst making fake reviews and commanding staff to “play hard and play dirty” and
that “this is NOT a contest for real reviews” (emphasis in original) -- is simply right out of this
World and the Court must issue stern rebuke to Plaintiff and Counsel for even going there.
29
It is axiomatic that a litigant seeking Equity must come with Clean Hands. See Dekker v.
Wergin, Wis. Ct. App No. 96-3258 (1997); Wis. Stat §103.57 (2023).
103.57 Clean hands doctrine. No restraining order or injunctive relief may be granted to
any complainant who has failed to comply with any legal obligation which is involved in
the labor dispute in question, or who has failed to make every reasonable effort to settle
the dispute either by negotiation or with the aid of any available machinery of
governmental mediation or voluntary arbitration, but nothing in this section requires a
court to await the action of any such tribunal if irreparable injury is threatened.9
These hands are so foul as to defy description, but yet Abby soldiers on, hiring more lawyers and
suing more people. If the case proceeds Defendant will bring more examples of Abby’s abusive
conduct but it really shouldn’t be necessary seeing what we already see here. Not one single
thing in this video is actionable. And if it is actionable the action that needs taken is investigation
of Abby Binder and good Anti-SLAPP legislation. Just ask the National Association of the
Remodeling Industry (NARI) if we cross that bridge in this litigation.
9
Again, Defamation does not constitute irreparable injury and the larger point here is that a pattern of contumacious
misconduct on Plaintiffs’ part has been shown on many levels even at this stage of preliminary documentation used
early on in this project. Threaten everybody, sue everybody. Customers, staff, everyone. “Play Hard Play Dirty.”
Perhaps more apropos this time it is “You mess with the Bull, you get the horns.”
30
CONCLUSION
As to any comments about Abby or Mandy being “Princesses of Slime” etc. are also
protected. “Loose, figurative, or hyperbolic language,” even “vigorous epithet[s],” do not count.
Milkovich v. Lorain Journal, 497 U.S. at 1; Greenbelt Co-op. Pub. Ass’n v. Bresler, 398 U.S. 6,
14 (1970). Indeed, “[t]he common law has always differentiated sharply between genuinely
defamatory communications as opposed to obscenities, vulgarities, insults, epithets, name-
calling, and other verbal abuse.” Rodney A. Smolla, Law of Defamation, § 4:7 (2d ed. 1999).
“Such statements may be hurtful to the listener and are to be discouraged, but … are not
actionable … no matter how obnoxious, insulting, or tasteless.” Id. If a statement “is expressing
a subjective view, an interpretation, a theory, conjecture, or surmise, rather than claiming to be in
possession of objectively verifiable facts, the statement is not actionable.” L. Offs. of David
Freydin, 24 F.4th at 1129–30.
This entire lawsuit is nothing more than a continuation of Abby Binder’s abusive
business practices. Each and every alleged element of the offenses has been thoroughly
discredited and moreover the Plaintiffs are clearly engaging in False and Deceptive businesses
practices but they think if they hire enough lawyers and throw enough trash at the wall that
something will stick, like the wayward fast food ketchup packet that flies out and hits the wall
when you’re taking the trash out running after the weekly pickup in the morning and you’re late
to work. Unfortunately for Plaintiffs, there was a backdraft in this case such that everything they
have thrown at Defendants has come right back to bite them just as so many of Abby’s former
friends and colleagues told Defendant King they expressly hoped would happen.
Respectfully submitted
___________________________
31
I the undersigned swear that a true copy of this Motion and Declaration was served to
tja@cmlawgroup.com
smc@berensonllp.com
via email

_____________________________________________
32

Actual Consumer Complaint Puts Waukesha DA Susan Opper on ATCP Duty to Investigate Abby Binder and Abby Windows

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Actual Consumer Complaint Puts Waukesha DA Susan Opper on ATCP Duty to Investigate Abby Binder and Abby Windows

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IN THE CIRCUIT COURT

CHRISTOPHER KING, J.D. )

) JUDGE BRAD SCHIMEL

RULE §785.01 NOTICE OF FRAUD ON THE COURT AND

Good Day Attorney Andringa,

Warm regards and Happy Juneteenth!

From: Christopher King <kingcast955@icloud.com>

Do you think you can get one of those in this case?

I'll bet not.

Counsel via CCAP and at:

And to all named Defendants via email

To whom it may concern,

1. It was brought to my attention via SMS/MMS message on June 18th, 2024 at

2. In an effort to be mindful of the perception of tonality of this letter, I will attempt to be

6. With routine close-of-business tasks, I left my office at approximately 17:30.

Co-host: "Are you serious?!"

Co-host: Good for you!

) JUDGE BRAD SCHIMEL

NOTICE OF MOTION AND JOINT MOTION OF DEFENDANT COUNTER-

NOW COME DEFENDANT COUNTER-PLAINTIFF CHRISTOPHER KING, J.D.,

Isiah Lowe and/or Deluxe Legal Services or authorized representative

) JUDGE BRAD SCHIMEL

[PROPOSED] ORDER GRANTING SHOW CAUSE HEARING

The parties are advised as to the following schedule:

IT IS SO ORDERED THIS ___ DAY OF JUNE, 2024

Good Day Counselors Doyle, Knott and Starnes:

Here is what you need to know:

(6) PRICE AND FINANCING.

As such, I am concerned that DA Opper is not actually getting my correspondence and it is

There is another disturbing component to this matter:

I thank you in advance for your time and consideration.

Dear Attorney Opper,

(6) PRICE AND FINANCING.

Let me make this simple:

To be clear Injunctive Relief and Civil Forfeiture is contemplated:

Injunction and Restitution

I remind you that I tried to tell you this before:

CHRISTOPHER KING, J.D. )

) JUDGE BRAD SCHIMEL

COUNTER-PLAINTIFF KING SECOND RULE 804.09 REQUEST FOR PRODUCTION OF

Document Request #1 (Rilla and Abby litigants)

Counsel and Putative Counsel respectively via CCAP and at:

And to all named Defendants via email

CHRISTOPHER KING, J.D. )

) JUDGE BRAD SCHIMEL

COUNTER-PLAINTIFF KING REVISED FIRST RULE 804.11 DEMAND FOR ADMISSIONS

Counsel and Putative Counsel respectively via CCAP and at:

And to all named Defendants via email

CHRISTOPHER KING, J.D. )

) JUDGE BRAD SCHIMEL

COUNTER-PLAINTIFF KING REVISED FIRST RULE 804.09 REQUEST FOR PRODUCTION OF

Document Request #3: (Rilla and Abby litigants)

Document Request #4: (Rilla and Abby litigants)

Document Request #5: (Rilla and Abby litigants)

Document Request #6: (Abby litigants)

Document Request #7: (Rilla and Abby litigants)

Document Request #9: (Abby litigants)

Document Request #10: (Abby litigants)

Document Request #11: (Abby litigants)

Document Request #12: (Abby litigants)

Document Request #14: (Abby litigants)

Abby was asked about female sales staff:

Q: Do you have any women now that are salespeople?

Document Request #16: (Abby litigants)