Now that I have twice prevailed the DOC asks for in-

camera inspection of the sought video of its staff

indiscriminately gassing inmates.

This is sheer madness. See my response letter below:

In all of this I now see a request for in-camera inspection.

This last-ditch attempt to avoid production and Eighth
Amendment liability must fail when the DOC exploits
cameras to its own advantage according to whimsy.
 CHRISTOPHER KING, J.D.
c/o Stafne Law Advocacy and Consulting
239 N. Olympic Ave.
Arlington, WA 98223
617.543.8085
kingcast955@icloud.com
http://darrelljonesinnocent.blogspot.com/
https://christopher-king.blogspot.com/

16 March 2020 VIA EMAIL TRANSMITTAL

Re: Demand for Production of Video for Demond Hicks, Inmate Number W107908.

Dear Manager Silvia and/or Public Records Officer:

I write you as a former law enforcement attorney and independent journalist to inform you of my ongoing
concern regarding the safety of Demond Hicks and/or the protection of his property and/or his right to
Procedural and Substantive Due Process given your Department’s continued unauthorized gassing of his
Cell Area.

Based on information I have reviewed from Pacer, Mr. Hicks and other prison sources, I hereby demand,
pursuant to MGL §66 – 10:

1. Any and all documents pertaining to grievance #106603.

2. Any and all documents pertaining to item # 17679 that was conducted by the superintendent’s
special investigator with regards to the incident on 13 Nov. 2019.

3. And of course I am still awaiting:

a. Production of the videos that I am owed;

b. An actual response to my second request or video.

In all of this I now see a request for in-camera inspection. This last-ditch attempt to avoid
production and Eighth Amendment liability must fail when the DOC exploits cameras to its
own advantage according to whimsy. This is how it’s done, again from DOC’s own
Facebook page:

At approximately 10:45am today, our brave staff encounter a dangerous situation that
occurred at a moment’s notice. This video shows the resilience and training of the officers
involved. Due to the quick efforts by responding officers, life-threatening injuries were
prevented in this incident. We wish a speedy recovery for the officers involved.

Due to CORI regulations the video has been blurred.

The Trend is toward greater disclosure, not less. See generally the unanimous SJC Decision in Boston
Globe v. Mass Dep’t of Health, SJC-12622 (June 17, 2019). See overleaf:
https://www.bostonglobe.com/metro/2019/06/17/sjc-says-state-agencies-should-more-open-
records-requests-that-are-public-interest/0lYVi3xylxhB62V212sqLL/story.html

SJC says state agencies should be more open to

records requests that are in the public interest

By John R. Ellement Globe Staff,June 17, 2019, 2:40 p.m.

At the risk of sounding factious I would assume that the DOC concurs that the safe and lawful housing of
prisoners is, ipso facto a matter of public interest right, given that the Department hosts videos of the same
areas that I am seeking. Surely it shouldn’t take a legal education to advance this argument and to see the
fallacy of the DOC’s purported defense.

Also there is yet another matter of concern:

I sent Mr. Hicks a draft copy of the lawsuit via Corrlinks +30 days ago. He still has not received it.
Can someone speak to that as well? Or should we just fold that into the litigation as well then?

Very Truly Yours,

______________________________
Christopher King, J.D.

cc: Demond Hicks (if he ever receives it)

Blind Copies
 KingCast wins again. Because I never lose PRR cases. I’ve lost 1 out of 6 and even legal scholars agreed that the Court
did not properly analyse whether individual emails to State Reps are ipso facto not subject to PRR.
KingCast v. Mcleod is the ONLY PRR case in which I have not prevailed. I’ve defeated the DOC before too in Darrell Jones’ case.

Google: KingCast + Demond Hicks

to see videos, documents, updates.