Abby Windows and Exteriors Sues Journo and 5 Employees For Exposing Corporate Corruption, Eavesdropping and Other Abuses

July 22, 2024
Re: File No. 153851 -Coltyn VonDeylen Complaint on Abby Windows
Firstly, I have checked around town and people are finding out about the lawsuit with Abby
and those poor salespeople and the reporter. Now they will know that Abby charges more
than twice the going rate for her $600 Square when the rate is really closer to $200-$250
and I can go do the footwork if your oKice needs more proof of yet another unlawful
business practice from Abby Windows.
This is an abusive practice because companies can prey on people when they have their
roofs opened up and price gouge them, which is illegal by statute.
100.305 Prohibited selling practices during periods of abnormal economic disruption.

(2) PROHIBITION. No seller may sell, or o.er to sell, in this state at wholesale or at retail, consumer
goods or services at unreasonably excessive prices if the governor, by executive order, has certified
that the state or a part of the state is in a period of abnormal economic disruption.
Second, the excuse about Rilla does not hold water:
There was no overriding CRM event with Rilla when the staK was at my home and this
requires an evidence investigation because I have spoken with people in the industry who
used Rilla earlier this year and the sales staK turns Rilla on by themselves but under duress
like Mr. King showed in several of his videos:
https://www.youtube.com/watch?v=FQEYliCxC4A&t
Abby Binder Rilla 908 Party Admission: Forcing Reps to Use Rilla by Economic Coercion
I have also seen the New Sales practices book that Mr. King sent you showing how the sales
staK is instructed to twice leave the primary point of sale inside the home, and with no
direction for them to turn oK the Rilla recording. It doesn’t take a rocket scientist to know
that consumer privacy violations are happening here just as Mr. King pointed out in his
videos that showed the November 14, 2023 email where the DA stated that this was a
serious issue.
https://www.youtube.com/watch?v=0EUe7GVsxss&t
Big Easy Waukesha: PD Retreats from its Position on Abby Windows; Now Refuses to Investigate.
To be crystal clear based on my discussions with professional sales staK using Rilla none of
them find this rationale or excuse one bit credible. Either Abby is lying to its lawyers, or both
of them are lying but somebody is lying and it will not be me or the thousands of other
unsuspecting homeowners in Wisconsin and beyond.
Also are you telling me that this Department never looks to BBB reviews when judging how
thorough to be with investigations? Because anyone can see that Abby has horrid reviews
for the past two years and I believe she had ZERO retention of sales staK that started in
early 2023 everyone is gone and openly complaining about Abby’s unethical practices.
https://www.bbb.org/us/wi/waukesha/profile/window-installation/abby-windows-llc-0694-
1000007820/complaints
That being said please notify me in the next calendar week regarding your intentions on my
request for review.
Sincerely,
Coltyn VonDeylen
cc: William F. Sulton, Esq.

Christopher King, JD
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.
NOTICE OF JOINDER IN MOTION TO DISMISS AND COUNTERCLAIM
NOW COMES DEFENDANT Taylor Stepniewski, without waiving any Defenses or

Jurisdictional challenges, to join in the Motion to Dismiss and Counter-Claim of Christopher
King, JD in all of his filings and does state further grounds for Relief at the Declaration as
attached.
Respectfully submitted
___________________________
Taylor Stepniewski
1
WAUKESHA COUNTY
STATE OF WISCONSIN
v. ) CASE NO.2024-CV-000820

)
DECLARATION OF TAYLOR STEPNIEWSKI
NOW COMES DEFENDANT TAYLOR STEPNIEWSKI to solemnly aver to the

following as on Oath and Subject to the Pains and Penalties of Perjury.
1. I stand by each and every word I wrote in this review about Abby and Abby Windows:
2
2. I never received any notice that my allegedly false written comments were Defamatory
prior to receiving a lawsuit; and
3. As Mr. King has stated I agree this is a violation of the Letter and/or Spirit of Wis. Stat
895.05; and
4. Everything I wrote about Plaintiffs is based on my own observations in the workplace;

and
5. Everything I have spoken about Plaintiffs is based on my own perceptions in the

workplace; and
6. I have heard and seen multiple discussions about the Richarz family and using their
sperm to conceive; and
7. I fully understand why people were affected by our owner having an affair with a staffer
and then marrying her and us working under her as a VP; and
8. I know Abby has ads all over Wisconsin TV stations and appears on Rilla and other
YouTube video; and
9. I further believe her to be a Limited Purpose Public Figure; and
10. In my opinion Abby Binder is using her status as a woman, and further GLBTQ woman
(I know a girl”) to insulate herself from public criticism and to gain new customers; and
11. While I cannot locate old messages at this time there was definitely discussion in the
workplace about Riley’ sperm for Abby and Mandy to conceive; and
12. As others have stated, Abby Windows was the most toxic environment I have ever
worked in; and
13. To the best of my recollection she was kicked out of the National Association of the
Remodeling Industy (NARI) because of complaints; and
14. She was not allowed at the spring home show last year 2023 because of the suspension;
and
15. I honestly wanted to file this a long time ago but I’ve been terribly busy with a full time
job, childcare, and a special needs child;
16. This litigation is in my opinion completely frivolous and just like the history of her
history of abusive treatment of staff and customers ad it has greatly affected my life
emotionally, with loss of sleep, despair and anger at her entire way of being as it pertains
to Abby Windows; and
3
17. I completely support the customer who filed to join the case today and I wish him the
best of luck and will be available for him and his family for anything he needs.
WITHOUT WAIVING SUPPLEMENTATION FURTHER DECLARANT SAYETH NAUGHT
______________________
Taylor Stepniewski
CERTIFICATE OF SERVICE
I the undersigned swear that a true copy of this Notice and Declaration was served to
Counsel via CCAP and at:
[email protected]
[email protected]
via email
And to all named Defendants via email
This 11th Day of July, 2024
_____________________________________________
4
WAUKESHA COUNTY
STATE OF WISCONSIN
v. ) CASE NO.2024-CV-000820

)
NOTICE OF JOINDER IN MOTION TO DISMISS AND COUNTERCLAIM
NOW COMES DEFENDANT Riley Richarz, without waiving any Defenses or

Jurisdictional challenges, to join in the Motion to Dismiss and Counter-Claim of Christopher
King, JD in all of his filings and does state further grounds for Relief at the Declaration as
attached and previously-filed, including but not limited to the sexual harassment and unpaid
back-end commissions as noted.
___________________________
Riley Richarz
1
COMPLAINT
1. My name is Riley Richarz.
2. I maintain everything I said in my previous Declaration and I support homeowner Coltyn

VonDeylen and the people in his BBB Exhibit 100%.
3. I maintain that the Abby litigants owe me a bunch of money the same way that Fred
Mayen had going on with them so I am attaching my previous letter to Abby that they
accused Jason Crismond of writing for me in some kind of conspiracy well I guess the
conspiracy now includes an innocent homeowner who didn’t even know any of us.
4. I would anticipate that as more people find out about this case more homeowners will
join and Abby will finally get what she has coming to her.
CLAIMS
1. Material Breach of Contract.
2. Quantum Meruit
3. Unjust Enrichment
4. Fraudulent Inducement
5. Fraud in the Factum
6. Intentional Infliction of Emotional Distress.
DEMANDS FOR RELIEF
1. Declaratory Judgment.
3. Injunctive Relief.
4. Compensatory Damages.
5. Punitive Damages.
6. Any other orders that are appropriate to send a message to Abby and anyone else who
operates a business like this.
Respectfully submitted,
____________________
Riley Richarz
2
I the undersigned swear that a true copy of this Joinder was served to
[email protected]
[email protected]
via email
_____________________________________________
3
January 29, 2024
Attn: Abby Windows & Exteriors HR Department
Re: Undocumented Payroll, Illegal Deductions and Demand for Settlement
Over the years I along with others have questioned this company’s payment structure repeatedly in
group electronic communication and verbally at staff meetings. I write this letter on their behalf and
with their concerted support.
I am just a young alleged 1099 contractor with my whole life ahead of me and I along with others are
suffering a handicap because of the lack of transparency and honesty. For example my Q4 payment of
$2,128.00 against $111K in sales is not fair and that is just one example.
Questions and Holds have been unfairly manipulated to 1099 staff disadvantage. When we demanded
transparency the Company instead published everyone’s purported earnings, which is legally
questionable. To us it is clear that this company has found multiple ways to artificially reduce earnings
of people who have questioned any company practices, and the Human Resource Department is a
completely closed-door operation.
Forensic research will prove, by and through Quickbooks, that I earned $2,663,675.57 for the company
but received in pay approximately $112,000.00. Therefore at a minimum on wages alone the company
owes me ten per cent (10%) of the aforementioned $2,663,675.57 minus the aforementioned
$112,000.00, or $154,367.00.00, not inclusive of Pre or Post Judgment Interest.
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. Further, during a period
of non-employment Mandy did further appear at my home in a drunken manner, thong out and
attempting to seduce me in front of many others after I had called her an Über at her request during a
domestic episode between the two.
My return to this company was predicated on false promises by the owner that things would be better
this time but they most certainly are not.
You have also demanded that 1099 staff put in long hours for unpaid training and that does not strike us
as fair or legal either. In fact, by any reading of the 20-point test we are not 1099 contractors and this
matter will be reported to the appropriate Wisconsin authorities at Workforce Development Office:
https://dwd.wisconsin.gov/worker-classification/report.htm1
https://enterprise.fiverr.com/blog/irs-20-factor-test/#:~:text=missed business opportunities.-,What is

the IRS 20-Factor Test%3F,they have over their work
1
See the Workforce Classification at Appendix B
1
https://www.workyard.com/answers/how-much-can-you-sue-an-employer-for-
misclassification#:~:text=Chelsea Larson&text=If you were misclassified as,%2425%2C000 for each
willful misclassification
How Much Can You Sue an Employer for Misclassification?

Chelsea Larson
May 23, 2023

If you were misclassified as an employee, you are entitled to the full amount of your unpaid wages, plus
that same amount in liquidated damages. Employers who knowingly and voluntarily misclassify
employees could face a fine of $5,000 to $25,000 for each willful misclassification.
With respect to the IRS factors at Appendix C In my case the company among other things:
-required attendance at a central company location

-mandatory training specific to the company in finite detail
-mandated use of potentially illegal eavesdropping devices2
-no autonomy in scheduling, completely setting my schedule and appointments3
-we don’t work for other companies, you basically own us and artificially reduce payments to us
-used the HR Department to effectuate discipline, a known no-no for an Independent Contractor; the
company even issued written discipline for not sending Christmas cards. See Appendix A p.1 for the
“Employee Write up Form.”
-forcing me to change pricing in a way that was not ethically correct by upping the price on a project
from $12,749.00 to $13,749 against an elderly homeowner with no family present to review charges
(Appendix A).
*********
The company has so many unfair practices we can’t even name them all right now but a few more
include:
- Being instructed to make false charges on contracts, double-charging dumpster fees on top of clean up
fees. When asking ownership directly why I am supposed to do this, the response was a threat of
charging me for digital measures for jobs that I don’t sell. It is disingenuous and unconscionable to
knowingly overcharge a customer to pay a bill for somebody else that didn’t do business with our
company. These are company costs of doing business, not a customer’s place to be deceived.
-Being forced to engage in undisclosed audio recording of homeowners without consent, with threat of
termination, removal of schedule and other forms of reprimand if I failed to comply. Appendix A. I and
others, in a concerted way, protested this activity only to comply under duress when my livelihood was
threatened by holding my pay hostage. Moreover, the instruction and training on porchlight closing
required us to leave these recordings on while not physically present.
2
All of us were warned “You have to use Rilla (eavesdropping software) or you will be taken off schedule.”
3
I was even forcefully told “Don’t leave that house if you don’t have a sale.”
2
-The blurred line of personal/professional relationship from my first chapter at Abby where, on more
than one occasion, was asked to provide my ejaculate (by what means, I am still unsure) for the purpose
of the owners of the company conceiving a child. Talking about my family's genetics, looks, and
athleticism as the reasoning provided.
My soon-to-be wife and myself could never speak on how uncomfortable this made us due to the fact
that provisions for my family were at stake. This led to another instance in March of 2023 when the
Mandy, Vice President of the company contacted me late in the evening after a domestic dispute
wanting me to pick her up. She Überred to my house with my Über (Appendix A) where she arrived
heavily inebriated, falling all over my house, underwear revealed with pants falling down. When my
fiancée went to another room, she followed me outside where I smoked a cigarette and she proceeded
to make a sexual advance which I declined. Along with late night promiscuous snapchats of revealed
cleavage, I was put in an extremely uncomfortable position as I perceived this to be unconscionable
economic extortion.
-Inappropriate cleavage images from the Vice President on Snapchat that will be obtained via 18
U.S.C. Chapter 121 §§ 2701–2713).
- The defamation of my father's name in an open company forum throughout your production
department, accounting, and executive level on the claim that he “stole” $250k dollars from your
company and has a negative influence on my life with a “drug” problem. This concerns me a great deal
in how my father’s reputation as an honest, blue-collar man has been smeared not only internally at the
company but also outside of it.
-Overcharging undisclosed dealer fees
-Alteration of sales contracts/items and earnings through measure technician/order

fulfillment/accounting
-Putting me on as Representative 2 on a job that once the other employee was no longer with the
company, became a “house deal”.
-Being pressured by a colleague, who is now acting in a leadership capacity, to change the price after
being disclosed to a customer in a way that was clearly taking advantage of a vulnerable and elderly
person.
- The public humiliation and ridicule of a man with a speech disability who was effectively managed out
of the company with unfair treatment after speaking up in the “money team” chat about concerns with
preferential treatment on opportunities and asking for financial transparency in remittance.
-Discovering that our promises of providing lead-safe, factory trained and certified installers was a willful
misrepresentation upon learning that our window subcontractors were undocumented workers falling
under the umbrella of an LLC owned by no one else but one of your project managers. Concerns of
conflict of interest in an open understanding that said individual is receiving kickbacks for putting the
3
taxes through his name and the very installs that I have been instructed to promise proper qualifications
for are what I believe to be in violation of the law, immigration and EPA alike. Closely related matters
have recently been settled in fines, see a related Home Depot case.
https://www.justice.gov/opa/pr/home-depot-pay-20750000-penalty-nationwide-failure-follow-rules-
conducting-renovations Violation of §402(a); 15 U.S.C. §2682(a).
***********
The minute you forced me to use illegal eavesdropping software and threatened termination and
“los[ing] all nights and weekends” the company has vitiated all of the tenets of any purported
Independent Contractor or Statutory Non-Employee status. The Courts are going to look at the totality
of this situation and all of us will get Justice because what you are doing is completely counter to any
notion of fair and equitable Public Policy directives.4 For example:
https://www.jdsupra.com/legalnews/direct-selling-and-door-to-door-sales-6279805/
June 11, 2021

Direct Selling and Door-to-Door Sales Under Attack: May 2021 IC News Update
Richard Reibstein
Locke Lord LLP
In the Courts (6 cases)
DOOR-TO-DOOR SALES REP FILES CLASS ACTION FOR INDEPENDENT CONTRACTOR

MISCLASSIFICATION. A door-to-door sales representative selling home energy contracts has brought a
proposed class and collective complaint in Pennsylvania federal court against Platinum Advertising LLC
and its related entities alleging minimum wage and overtime violations under the FLSA and state law
due to the alleged misclassification of the sales reps as independent contractors. The company offers
marketing and sales expertise to both telecom and energy service companies. According to the
complaint, the sales representatives typically worked six days per week, a minimum of eight hours per
day and often more than ten, are required to make sales calls on personal time, and are paid solely on a
commission basis, subject to the company’s approval, regardless of how many hours they work. In
support of the misclassification claims, the plaintiff alleges that significant control was exercised by the
company by requiring the sales reps to routinely work in excess of 60 hours per week, wear a company
uniform, and follow a sales script. The plaintiff further asserts that the sales reps are not required to
have any specialized skills to perform their jobs, do not have their own enterprise or separate business
structure, are not permitted by the company to assign or delegate their responsibilities, and have no
opportunity for profit and loss. McWilliams v. Platinum Advertising LLC, No. 2:21-cv-00607 (W.D. Pa.
May 10, 2021).
4
To add to this legal miasma, Bobby Jones has become part of a managerial hierarchy while allegedly an
Independent contractor.
4
Walsh v. Wellfleet Communications, No. 20-16385 (9th Cir. May 12, 2021)
https://law.justia.com/cases/federal/appellate-courts/ca9/20-16385/20-16385-2021-10-
14.html
II
The district court also correctly determined that Wellfleet’s workers were employees under the
FLSA because they were “dependent upon [Wellfleet]” as “a matter of economic
reality.” Donovan v. Sureway Cleaners, 656 F.2d 1368, 1370 (9th Cir. 1981) (enumerating the six
factors of the economic realities test). Wellfleet did not dispute that it controlled its workers’
labor, compensation, and work conditions, it merely justified those approaches as reasonable
and common in the industry. Nor did Wellfleet show that its workers required the “long training
[or] highly developed skills” indicative of independent contractor status, id. at 1372 (no special
skill if training lasted only five days), or dispute whether its call salespersons were integral to its
telemarketing company. Id.
*********
DIRECT SELLING COMPANIES UNDER LITIGATION ATTACK BY THE U.S. DEPARTMENT OF LABOR FOR IC
MISCLASSIFICATION. The publisher of this blog was quoted in a May 9, 2021 article in Law360
Employment Authority by Jon Steingart, commenting on an appellate brief submitted by the U.S.
Department of Labor. The DOL alleges that over 1,500 call center workers are owed $1.5 million in back
wages due to their misclassification as independent contractors and not employees. In its brief, the DOL
stated that the lower court had properly concluded that an Internal Revenue Code provision designating
“direct sellers” as nonemployees did not apply to the FLSA’s exemptions and that, “The IRS provision, by
its terms, plainly limits its applicability to federal tax law.” The publisher commented that the case is a
reminder that independent contractor classification comes into play under a variety of laws that use
different tests to pursue different purposes, noting: “A large number of direct selling companies
mistakenly believe that an IRS rule, which says that direct sellers are not employees if paid on a
commission-only basis, also applies to the federal and state wage and hour laws. Because of this
misconception, direct selling companies often don’t give independent contractor classification the
attention it deserves. Businesses in this industry should do just the opposite — enhance their level of
contractor compliance.” Walsh v. Wellfleet Communications, No. 20-16385 (9th Cir. May 12, 2021). We
first proposed that suggestion for direct selling companies over five years ago in an earlier blog post, and
it remains our view today.
Full docket text for document 29:

ORDER denying [28] the parties' joint Motion for final approval of FLSA collective action
settlement, without prejudice, as follows. The Court agrees that, under appropriate
circumstances, it may finally approve an FLSA settlement without a hearing. The Court's
research, however, has failed to identify a single "hybrid" action (i.e., one addressing both FLSA
collective action claims and state wage-law class action claims) where final approval has been
afforded without a fairness hearing. As to the notion that due process concerns are alleviated
5
because participation is limited to those putative members who "cash the check," serious
questions have been raised regarding this contention. See, e.g., Douglas v. Allied Universal Sec.
Servs., 381 F.Supp.3d 239 (E.D.N.Y. 2019). Here, the parties' Motion for approval may be
capable of resolution without a hearing, except to the extent that putative members
purportedly will release state wage claims through participation in the collective action
settlement. See Doc. [28] at 3 ("I hereby release all claims or causes of action... for unpaid
minimum and overtime wages" that arise under "the Fair Labor Standards Act, Pennsylvania law
and any applicable state, local or municipal law or regulation"). The proposed settlement cannot
be approved as currently proposed, and, thus, the Motion for approval is DENIED. Finally, should
a renewed motion contemplate the settlement/release of state class-action claims, the parties'
proposed procedures must account for the notice-requirements and timeframes in the Class
Action Fairness Act of 2005 ("CAFA"), 28 U.S.C. §§ 1715(b) through (d). Signed by Judge Cathy
Bissoon on 4/5/22. Text-only entry; no PDF document will issue. This text-only entry constitutes
the Order of the Court or Notice on the matter. (dcd)
**********
Please show me how you have dealt with the unfair payroll deductions and the “1099” status legally,
because as you know there are many of us who have demanded this type of information, and who live
and work under this alleged classification, including Fred who was administratively terminated after
asking for remittance documents and reliable accounting proof that we are owed as 1099 Contractors.
We all have communicated our disagreement to management individually and collectively on staff
meetings, but we never really got an answer to these questions and it is important. My integrity is at
stake. The company’s integrity is at stake. Who are the company Attorneys or third party Accounting
firms who have cleared these practices?
***********
Racism.
This company abuses elders and have disdain for black people. They sent me the message seen below
and in Appendix A noting that they “didn’t put [me] in the hood,” a less than oblique reference to
geographic areas more populated by blacks and other People of Color. I am a male, white but I find this
type of condescending racism to be pathetic coming from two Lesbians who hold themselves out as
progressive minorities. While I agree that they have such a status they are clearly abusing it as white
women of means and privilege and they should be ordered to pay into a Constructive Trust Fund held by
the social service agency or church of my choice.
6
7
SPOLIATION OF EVIDENCE
You are hereby put on Actual Notice that you are not to alter, destroy, edit, purge or in any other way
disturb any operations programs or data including but not limited to HR functions, monetary matters of
any kind, and Rilla data.
DEMAND
1. We are all demanding their names and a letter of verification that this activity is lawful.
2. I hereby demand prompt payment of $154,367.00.00, exclusive of any interest.
3. I hereby demand a written private apology.
4. I hereby demand that you work with community leaders to establish a Trust in the amount of
$154,367.00.00.
I want what I am honestly owed as does everyone else. If I do not receive a Good Faith Counter Offer by
Noon, Wednesday January 31, 2024 I will retain Counsel, contact local and federal administrative
agencies and proceed accordingly.
Sincerely,
Riley Richarz
8
APPENDIX A
ASSORTED DOCUMENTATION
9
BLATANT RACISM
10
11
12
13
14
15
APPENDIX B
WORKFORCE CLASSIFICATION
Penalties
If an employer is found to be utilizing misclassified workers, the employer may be liable for additional
tax, interest and penalties. If as a result of an investigation an employer is found to be utilizing
misclassified workers, additional tax, interest and civil penalties, including the issuance of stop work
orders, may result. In addition, an employer may be subject to criminal penalties for intentional
misclassification.
Administrative Penalty for Intentional Misclassification:
Wis. Stat. § 108.221(1) provides that employers engaged in construction as described in Wis. Stat.
§ 108.18 (2)(c), or who are engaged in the painting or drywall finishing of buildings or other structures,
who knowingly and intentionally provide false information to the department for the purpose of
misclassifying or attempting to misclassify an employee, shall for each incident, be assessed a penalty by
the department in the amount of $500 for each employee who is misclassified, not to exceed $7,500 per
incident.
The department shall consider the following factors in determining whether an employer knowingly and
intentionally provided false information to the department: (1) whether the employer was previously
found to have misclassified an employee in the same or substantially similar position; and (2) whether
the employer was the subject of litigation or a government investigation relating to worker
misclassification and the employer, as a result of that litigation or investigation, received an opinion or
decision from a federal or state court or agency that the subject position or a substantially similar
position should be classified as an employee. The statute provides those factors are non-exclusive;
therefore, the department may also consider other factors.
Criminal Penalty for Intentional Misclassification:
Under Wis. Stat. § 108.24 (2m), any employer engaged in construction as described in § 108.18 (2) (c) or
engaged in the painting or drywall finishing of buildings or other structures who, after having previously
been assessed an administrative penalty by the department under § 108.221 (1), knowingly and
intentionally provides false information to the department for the purpose of misclassifying or
attempting to misclassify an individual as a nonemployee shall be fined $1,000 for each employee who is
misclassified, subject to a maximum fine of $25,000 for each violation.
The department may refer violations of this subsection for prosecution by the department of justice or
the district attorney for the county in which the violation occurred.
Administrative Penalty for Coercion:
Under Wis. Stat. § 108.221 (2) (c), any employer described in § 108.18 (2) (c) or engaged in the painting
or drywall finishing of buildings or other structures who, through coercion, requires an individual to
adopt the status of a nonemployee shall be assessed a penalty by the department in the amount of
$1,000 for each individual so coerced, but not to exceed $10,000 per calendar year.
16
APPENDIX C
IRS 20-POINT CLASSIFICATION
1. Level of instruction. If the company directs when, where, and how work is done, this control
indicates an employer-employee relationship.
2. Amount of training. Requesting or requiring workers to undergo company-provided training

suggests an employment relationship since the company is directing the methods by which a
worker performs their duties.
3. Degree of business integration. Workers whose services are central to the business operations
or significantly affect business outcomes are likely to be considered employees.
4. Extent of personal services. Companies that insist or demand that a particular person performs
the work have asserted a high degree of control, which indicates an employment relationship. In
contrast, independent contractors are typically free to assign work to anyone.
5. Control of assistants. If a company hires, supervises, and pays a worker’s assistants, this control
suggests an employment relationship. If the worker gets to control the hiring, supervising, and
paying of assistants, they could be defined as an independent contractor.
6. Continuity of relationship. A continuous relationship between a company and a worker

indicates an employment relationship. However, an independent contractor arrangement can
also be an ongoing relationship that spans multiple, sequential projects.
7. Flexibility of schedule. If a company gets to dictate a worker’s days and hours of work, this
degree of control suggests an employer-employee relationship.
8. Demands for full-time work. Workers who work full-time hours suggests a company has control
over most of their time, which indicates an employment relationship.
9. Need for on-site services. Requiring someone to work on company premises — particularly if
the work could be performed elsewhere — suggest an employer-employee relationship.
10. Sequence of work. If a company requires work to be performed in specific order or sequence,
this type of control suggests an employment relationship.
11. Requirements for reports. If a worker has to regularly provide written or oral reports on project
status, they could be viewed as an employee.
12. Method of payment. If a worker is paid hourly, weekly, or monthly, this could suggest an
employment relationship, unless the payments simply are a convenient way of distributing a
lump-sum fee. It is more characteristic to pay contractors upon project completion or
commission.
17
13. Repayment of business or travel expenses. Independent contractors are typically responsible
for paying for travel or business expenses, and most contractors set their fees high enough to
cover these costs. In contrast, reimbursement of travel and other business expenses by a
company suggests an employment relationship.
14. Provision of tools and materials. Workers who use company-provided equipment, tools, and
materials to perform their work are more likely to be considered employees. Work largely done
using independently obtained supplies or tools supports an independent contractor
classification.
15. Investment in facilities. While independent contractors and freelancers usually pay for their
own work facilities, most employees rely on their employer to provide work facilities.
16. Realization of profit or loss. If a worker’s earnings are predetermined and have little chance to
realize significant profit or loss through their work, they are generally considered to be an
employee.
17. Work for multiple companies. Workers who provide services for multiple companies
concurrently are likely to qualify as independent contractors.
18. Availability to the public. If a worker regularly makes services available to the general public,
they could qualify as an independent contractor.
19. Control over discharge. If a company has the unilateral right to discharge a worker, this suggests
an employment relationship. In contrast, a company’s ability to end an independent contractor
relationship generally depends on the terms specified in the contract.
20. Right of termination. Most employees can terminate their work for a company unilaterally
without liability. Independent contractors cannot quit their work engagements without liability,
except as permitted under their contracts.
18
The service was pretty bad. We made the down payment early March and didn't hear back until
mid April when I called to ask why I hadn't heard anything. They said I hadn't signed the
paperwork and sent it then. After that I waited another two weeks and had to call again. At that
point they told us the colors we chose weren't in their catalog anymore, so not sure why they
were offered to us. We finally chose new colors and scheduled the roofers and they showed up a
week early without telling us and set off our house alarm and started tearing off the roof only to
tell us they they didn't have the materials to fix the roof since they were early. Eventually we got
the roof and gutters replaced and the manager said they would make sure to clean and not leave a
nail and lo and behold there were nails and something like a brace in the front yard. Additionally,
even though the salesman promised the price would never go up from the estimate we were
charged extra because "he estimated wrong." Day after the repair we noticed a bush from the
front yard had been cut down and the gutters that weren't replaced were now dripping. Overall a
pretty bad experience but the roof does look nice so 2 stars.
EDIT: After getting a clearly AI generated response including the words "please contact us at
(your contact information) so we can discuss" I'm lowering the review to 1 star for terrible
customer service.
2
3. I know that Mr. King has filed my correspondence attempts to get my Rilla recordings
from Abby. I am incredibly disturbed and insulted by this. I have lost sleep over it.
4. I know that Mr. King has filed my displeasure about the unlawful request for early
Certificate of Completion.
3
5. Abby’s crews damaged my property as I noted in my Google Complaint.
6. Abby never responded to me in over a week now.
7. I have read pretty much everything Mr. King has filed recently and I have read many
online complaints about Abby Windows and I believe these complaints to be true given
what I am seeing in my own life.
8. This morning I notified Mr. King that Consumer Protection wrote me saying that they
had initiated an investigation but like me they have not heard back from Abby or her
lawyers. Appendix A.
9. I told him, as I told him before, that I want to bring my issues with Abby to light because
I think she is a classic bully who keeps things hidden from public view by the use of
threats and lawyers. When I saw the emails to Amy O’Donnell threatening her with
extortion I was appalled.
10. Mr. King shared with me a comment for a prior Abby staffer he did not who said that the
lawsuit against these innocent people was “death of a thousand cuts to her business.”
11. Mr. King will not reveal who said that but I believe him and he said he will reveal it if the
case continues.
12. Me joining this case will give the Court a true vision of how operating with Abby really
works for a lot of consumers and I want to expose the truth and help the people she has
sued: I read the BBB complaints about her too and it’s the same story. Some of those
complaints are in the appendix B.
4
I the undersigned swear that a true copy of this Joinder was served to
[email protected]
[email protected]
via email
_____________________________________________
6
APPENDIX A
7
APPENDIX B
https://www.bbb.org/us/wi/waukesha/profile/window-installation/abby-windows-llc-0694-
1000007820/complaints
Initial Complaint
04/28/2024
Complaint Type:
Service or Repair Issues
Status:
Answered
More info
Abby Windows did a shoddy job. They broke an awning and light. There is old trim
sticking out from underneath the new trim. They destroyed our tv antenna and threw it
out. There are chunks of wood from the tear-off of the old roof. And the rain pours out of
the new gutter. Every time I try to get things fixed they say they will forward my
information to someone else. No one calls back.
Initial Complaint
04/19/2024
Complaint Type:
Status:
Answered
More info
Had this company install windows. They were supposed to remove and reinstall 11
windows. Removed my bathroom window that was not in scope, agreed to replace with
comparable window (double hung with privacy pane), installed temporary window that
was larger, creating larger hole in wall and bathroom tile. Replaced with window of
original size. I didnt make that hole bigger THEY DID. All trim was replaced on all
windows. Finishing was awful and had craters and excessive chipping. Company said it
was the best they could do. Paid $30k for work that looks like I did it myself, with no
construction experience. A friend of mine went to high school with the owner and is
friends with current saleman for the company I asked her to share with the owner as I
wanted to fix the issue without hurting the reputation of the business. However, I was
told of their multiple complaints and dissatisfied customers and decided that someone
needed to stand up to this absolutely unacceptable workmanship and customer service.
8
Initial Complaint
03/11/2024
Complaint Type:
Order Issues
Status:
Answered
More info
Our original signed contract with **** was 9/18/2023. They came back in December
2023 saying they missed 2 windows the price would be $4000.00 more. Our salesman
also tried to say he didnt charge us for the window wrap, he would consume that cost
himself. As if to justify the additional costs??? It was very odd. Im wishing I would have
backed out then. We were told ***** Weeks for installation on the 9/18/23 contract. It
was 23 weeks from 9/18/23 signing of contract. Before we got our windows, we tried to
be patient, we had no choice but when you hear them constantly advertising you
wonder, why dont you make your current customers happy first. The **********************
were installed late February. One window was the wrong size, so it is boarded up at this
time. Our new patio door handle does not lock. Two of the windows in our master bath
appear to be a little small. The blinds that were in there no longer fit and there are big
gaps around the tile where the original wood was. There is also a bad board on another
of the windows. The glider window in Master bedroom the safely lock is hidden and will
not open the installer took a picture when they were here. Our sales man now says
boinds may not fit, but that is not what he told us. I asked about safety locks and blinds
and and at no time did he say they may not fit, All the others in the house fit, except
those that you can see there is a clear issue in the size. They take no
accountability.They are pressuring us to sign a Letter of completion, saying our
financing is going to run out, well that could be because it took them 23 weeks to get the
job done. They take no accountability.Their communication and accountability have
been terrible. Unless they want something from you, like the up charge on the contract
and the letter of completion signed so they get paid, you will hear from them then.
9
Initial Complaint
02/05/2024
Complaint Type:
Status:
Resolved
More info
October of 2023 we had Abby windows come out and give us a quote. We were happy
with demonstration and thought the company was organized and legit. 2 months later
December of 2023 we werent getting responses on when the down payment was due or
how to pay. Turned out that the associate who gave us the quote was fired or quit and
no one told us. Essentially no one followed up with us at all until I sent an email asking if
we should just go with another company. They finally responded and gave us the dollar
amount, just over 7k. We wrote the check and thought nothing of it until the guy came
out to do a final measurement. When he did everything was wrong, the number of
windows and the style of windows. So now this new guy is telling us its going to be
more expensive. 2 weeks later, in January of **** no new quote has been provided. We
asked for our money back and to cancel since we still have no new dollar amount they
want us to pay and now theyre refusing to refund us the money for a quote that was
wrong to start with. In addition to all of the issues, every time I emailed, the employees
would pass the email off to someone else. Not one person at Abby windows has been
helpful nor do they even care about their customer service.
Initial Complaint
11/08/2023
Complaint Type:
Product Issues
Status:
Answered
More info
We booked a siding job in April 2023 to be completed in August 2023 with an $8,000
deposit. We contacted at the beginning of September and they advised they were
waiting on the city permit. My husband drove to the city and they confirmed that no
permit was applied for. On November 7, ******************************************** our
driveway without contact. We have requested that they pick up the incorrect materials
and refund our money as we will be seeking another company to complete services. No
response. No response and no service since April 2023.
10
Initial Complaint
11/07/2023
Complaint Type:
Status:
Answered
More info
My experience with the siding job provided by *************** leaves a lot to be desired.
We signed a contract 3-13-2023 with *******************************. We gave him a
substantial check. (Cashed 03-15-2023). I was able to print the contract. Then ******
filled out the financing paperwork, electronically signed it and could not ************* 3-
15-23 I called ****** and told him the contract shows Corner Color was the same. I told
him I wanted white on 3-13-23. He assured me the color would be corrected. A few
days later ****** called and said the signature did not go through and I had to sign
another financial contract. I was unable to print that one and called ******. He told me he
would send a copy that I could print. I never received anything from ******. 3-23-23 a
representative came out an measured.No date noted but I called ****** ext. 719 after
trying ****** that went to voicemail. She returned my call and told me she would call
when the materials were there.4-26-23 called ****** ext 719 (in the warehouse) will call
when the materials arrive to set up appointment. 5-3-23 at 3:43 pm I called ****** and
left a message for him to call me. I was sure the return call would not happen until the
next day. Waited 2 days Never received a call. 5-5-23 called ******* extension no one
answered. I hung up and called ****** at 3:10pm. Left message. She called me back at
3:25pm and we set up install date of 6-5-23 or 6-6-23. 5-18-23 I received and email
from ********************************* offering to come sooner. Offered the date of Tuesday
May 23, 24, and 25. I jumped at the chance and postponed the concrete to begin
removing the asphalt until the 25th so the dumpster would not damage new concrete.
The email said it would be a 3 day job.5-19-23 received a conformation via email that
the date was changed to May 23rd. 5-22-23 the dumpster arrived but no materials
came. I called and informed them that no materials arrived. They assured me that they
would be here in the morning. 5-23-23 5 guys here to work and no materials. Called at
7:55 am and left a message on ext 719 that the workers where here and there was no
materials. They set up the scaffolding and removed all the small boards. (I think it was
called ******.) That was done late morning and the 5 guys sat around waiting for the
materials. The materials arrived and after the guys delivered it, I noticed that the corner
boards were not white. I called ****** and he told me the white ones will be there in the
morning. *********** only had time to put the green rap on. They had me cut the internet
cord so they could put the green rap on. They left at 7:00pm. 5-24-23 **** came out
early and spoke with my husband. He assured my husband that window shutters would
be installed on all the windows. He told him the dumpster would be removed that
evening so the asphalt could be removed in time to prep for the concrete to be poured.
*********** only got the boards up on the north and part of the west side of the house. I
talked to ****** the guy supervising the workers and told him the dumpster was going to
be removed and we came up with moving it to in front of the detached garage. He said
11
his guys would be ok with taking the scrapes a little farther.I called Source Dumpster
and they told me that they never received an Order from **** to pick up the dumpster. At
around 3pm I called ******* ext 713 it went to voicemail. I tried ******* ext 719 it went to
voicemail, No messages left. I called back and thought it said ****** was ext 706 and
spoke with ****. I explained the dumpster situation and he said he would relay the
message about moving the dumpster and have someone get ahold of me. I carried the
house phone with me.At 4:50 **** called me back to check if I received a call from ****. I
told him no. He was surprised then informed me that Source Dumpster was called and
would be there tonight or tomorrow morning to move the dumpster. 5-25-23 At noon I
called the asphalt removal company that the dumpster has not been removed yet and
he told me he could not come again until June 1st.At 4:48 I called ext 719 it went to
voicemail and I hung up. At 5:00 Source Dumpster arrived. My husband went out to
show them where to move the dumpster. They said they were there to remove it. The
driver called the office and they informed him that **** told them to remove it. My
understanding was that there would be an additional charge and that **** was not happy
having to call in the first place. 5-26-23 *********** completed the siding on the North,
West and some of the South side of the house. The East side was partially done and
the South side of the house where the deck is was left in only the Green **** They ran
out of materials. They removed the scaffolding on the North side and left it on the grass.
At 2:00pm ****** (only person who spoke my language English) arrived. I blew off s****
with him and he told me they only sent 49 boards, what was he supposed to do. He told
me the guys would come back tomorrow but I asked him what were they going to do
there was no boards for them to work with. 5-31-23 I called ****** and asked him when
they were coming back and he told me I was a special order and that he was waiting for
the materials. He said it would be in Monday June 1. I asked him then if he could come
out and pick up the scaffolding as they were done with it. He told me they would pick it
up Thursday or Friday. No one came to pick up the scaffolding and no one showed up
on Monday to finish the job. I still do not have internet. I used up all my cell phone hot
spot allowance within 2 days. Still do not have completed siding. Needs much
tweaking.No One at **** has attempted to make any kind of contact with me to inform
me what is going on with materials or if I have anything to say. I am paying for what I
think is premium price for a job I thought *********** and siding was going to do. Not a
subcontractor that cant communicate with your English speaking impaired customers.
The new TV ad says you do it right the first time because you dont want to come back. I
wish you would come and finish it, or tell me what the status is. I have not called
because I dont want to fuel the fire of ******* everyone off any more than they are. It is
your job to call me and update me what is going on I should not have to beg for
information. I am paying $41,715.80 for an incomplete job that at first looks nice but
there are gaps between the siding and the soffits. There is no caulking under the
window. There is a cut in at least one of the white corner pieces. A worker took it upon
themselves into putting aluminum around the front door, I am assuming because I have
not painted it yet. They did a nice job but it needs to be removed because it does not
match what I want the door to look like. Most of all - it is not done. On June 4th **** the
project manager came out to review my concerns and started a work order. The deck
12
that was damaged by the workers with paint, the unfinished eves, the unsealed siding
ont he west side of the building and the lack of shutters. He measured all 11 windows
for dark brown shutters. The beginning of August my husband and I went to the ****
offices in ******** and were met by **** and the receptionist. They set up an appointment
where they would send ***** to complete the work. I asked if I could see the shutters
and they told me the receptionist would send me a picture to my email. Again I waited
and never received the pictures or even and explaination as to where they were. *****
never showed to finish the job. October 25th ***** showed up (scheduled appointment)
with 4 sets of black shutters. I told him there should be 11 sets of shutters and the color
is dark brown. (***** corrected me with the dark brown. I said chocolate brown). I
showed him the peaks and we measured the 11 windows again. On October 25th, the
salesman ****** called and started to bulling me to pay before the job was done
because the financing would expire on the following Tuesday. An email demanding
payment was received a short time later. I replied the job was not completed. On
November 6 th I received and email from *** in accounting. Email: Based on what has
been communicated to me by **** **** members, your project is substantially complete,
and we need to fund the project. Please contact me tomorrow at ***************** so we
may close this out. I called ***, Per our phone conversation I told him I did not need
there financing. He told me because they were substantial done I had to take care of
balance. *** said he talked to your crew and they told you I kicked them off the property.
I never kicked anyone off the property. October 25th ***** showed up with 4 sets of
black shutters. I have 11 windows and the color should have been dark brown. I told
him they were not correct and not enough 4 vs 11 sets and not to put them up. ***** and
I went around and took measurements for 11 sets of shutters. We looked at the peaks
and he told me that he thought it just needed caulking. I never kicked him off the
property. *** did not want to hear my side of the story. The fact that **** came June 14th
checked the job and found the bottom was not sealed on the west side of the house and
the the 3 peaks needed to be sealed. He also took measurements of 11 windows for
shutters. He was filling out a work order that I did not get a copy of. I am sure it is not
available to me. This project has had 11 window measured 3 times that I am aware of
and 1 time my husband was aware of. November 7 **** called wanting to get things set
up to finish the job. She told me the shutters were not written in the contract so they
were not going to provide 11 sets reguardless of the fact we had a verbal agreement. It
was not in the contract. She said they would come and seal the peaks and the west side
of the house. She told me she would have them hang the 4 sets of shutters they have
and I told her they were the wrong color so she said she would credit us the shutters.
Then I asked about the deck board that the sub contractors damaged and that **** said
they would credit us. She said she would take to **** and go from there. This was a job
contracted in March and now in November it is still not completed. I am the one treated
poorly and they are bulling me.
13
Initial Complaint
10/31/2023
Complaint Type:
Status:
Answered
More info
The windows I purchased from Abby Windows and installed by Abby Windows do not
correctly fit in the area where the prior windows were installed. This has resulted in my
custom-made blinds not fitting correctly, which caused a lack of privacy, and the window
treatments no longer fit. The salesperson knew the windows would not fit the same as
the windows that were taken out and failed to tell me prior to selling the windows and
having them installed, even though an Abby Windows representative came to my home
twice on separate occasions. I have reached out to Abby Windows, both ******, the
sales person, and ******, Project Manager, with no reasonable resolution. ******
responded that it was an unfortunate situation and that the sales person shouldve
informed me that there would be a problem with the blinds not fitting properly. I have
this voice mail message saved on my phone. I have also searched the Abby Windows
website for information on installation services and guarantees but I was unsuccessful
in finding anything that was relative to a guarantee or customer satisfaction. There were
only references to flow-through manufacturer warranties mentioned. No documents
were included on the website for review. I am asking for one of three options to make
me whole: 1. Detailed steps accompanied by the prompt timeline by which one of the
following sub-steps would be completed: a. Fix current window by cutting into the
drywall to lessen the depth of the window, if this is a possible solution, or b. Replace the
window with one that has more depth, comparable to the previous windows, or 2.
Reimbursement of my blinds in the amount of $2,243.52 so I can replace with blinds
that fit properly 3. A full and immediate refund of $6,473.00 so that I may purchase
windows that fit correctly My last effort to contact Abby Windows was via email on
October 6. I requested a response by EOB October 10. I have heard nothing since.
14
Initial Complaint
10/13/2023
Complaint Type:
Order Issues
Status:
Answered
More info
Contract was signed 6/29/23 for roofing and siding, $32065.50 paid to Abby Windows
(1/2 of total),of this the cost of the roof was $17796.00. Per Sales rep- roofing to be
completed in August and siding in September 2023. We had to change the roof edge
color as we were told the color was discontinued- we have since found out it was a
premium color and the Sale rep would have been responsible for paying the additional
cost. Roof was completed 8/16/23- they also tore off large areas of the existing siding-
exposing the house outer walls9 not replaced), tore off all gutters and downspouts. After
numerous calls and emails, gutters and downspouts were put on 8/19/23- after rain had
leaked into my basement. One section of gutter from an upper roof line was directed to
the lower roof- no downspout at all so the entire upper roof section runoff is directed on
to the lower roof in 1 spot. 'Siding supervisor' finally came out on 8/30/23 to measure for
siding- not sure how we were charged for the siding job if there was record of the
measurements-he stated he would order the siding on 8/30 or 8/31/23 and then 4-6
weeks until install. No info received after many calls and emails- 9/5/23 siding still not
ordered.On 9/12/23 I received an email from the Sales rep that the siding would be
installed sometime in November- I have made it very clear via email and phone
messages that this is not acceptable. There have been many additional calls, emails,
etc. trying to get info on the siding installation- no response with any date, status, etc.
*********** has had $12889.50 of my money (1/2 of total required at contract signing
minus the roof quote) since 6/29/23- we have siding missing, roof edge that is already
coming loose, an upper roof that now drains directly to a lower roof in one concentrated
spot due to the gutter they installed incorrectly, no siding installed, no response from the
company, no date for the siding or even if the siding has been ordered Please help!
15
Customer response
02/20/2024
Hi Stacy
Attached, please find the latest emails- with Abby Windows- still no repairs, areas
exposed, etc.
Thank you
Deanne Harris
From: Harris, Deanne <[email protected]>

Sent: Saturday, February 17, 2024 6:58 PM
To: Catrina McKenzie <[email protected]>
Subject: RE: Service appointment
Importance: High
There have been non stop problems since we signed the contract with Abby Windows
LLC- and were required to pay $30685.50 in June 2023.
The improper installations, issues, damage to our house, etc. have been well noted and
documented many times including photos. Recent emails are attached, there are many
others-
When the siding finally was started, 11/7/23, the first day the “siding installers” were
here- they broke our electric meter- nothing was said… we saw the whole thing happen
and called the We Energies- they had to replace the entire unit.
Adam and Eric were both here on January 18, 2024- again photos were taken, lists
created, same problems and damage recorded- nothing fixed.
Eric was last here on 2/2/24 and additional siding was dropped off at our house at 8pm
that night- since then nothing- no work, no response to emails…but the windows are still
exposed to the elements, vent left totally open, bottom of the house not sealed, siding
not properly fitted or installed, roof edges not covered, we don’t even have the correct
colors for the trim and gutters!
We had a new furnace installed this fall and expected approximately a 25% reduction in
gas usage- instead we have had an increase of 30% with all of the damage and
problems with our house due to the Abby Windows LLC. We also now have rodents
crawling into the walls inside our house- through the unsealed siding bottoms. Plus all
the other internal damage done to ceilings, walls- even a hole in the wall punched from
the outside!
Thank you
Deanne Harris
16
Initial Complaint
07/17/2023
Complaint Type:
Status:
Answered
More info
Had windows installed by Abby Windows in 2018. Noticed a crack in one of them in
April of this year. Have contacted the company numerous times since April regarding
their warranty. There has been no follow through by them.
17
18
WAUKESHA COUNTY
STATE OF WISCONSIN
ABBY WINDOWS et al. LLC., )
Plaintiffs, )
v. ) CASE NO.2024-CV-000820

CHRISTOPHER KING et. al,
)
Defendants.
LITIGANT KING §902.01 REQUEST FOR JUDICIAL NOTICE OF CONSUMER

PROTECTION INVESTIGATION OF ABBY WINDOWS, LLC
NOW COMES DEFENDANT-COUNTER PLAINTIFF CHRISTOPHER KING, J.D., to

note that Consumer Protection has taken action against the Abby litigants. Obviously this is
probative of the validity of Litigant King and any Joinders’ position in this matter. Litigant King
will incorporate this into his Second Amended Counterclaim by tomorrow morning, July 12,
2024.
CONCLUSION
In its short history this case has already seen a) Claims filed in blatant violation of Wis.
Stat §895.05, b) a patently fraudulent process server who celebrates in “skipping court again”
and “running a ponzi scheme” and now, c) the obvious fact that fake reviews violated Consumer
Protection Law in any and every State in this Country, as Litigant King has stated all along.
Therefore the reputation of any dirtbag who engages in this type of conduct can never
demonstrably show any harm to its purported reputation in the community, ipso facto because
once the public knows these proclivities, there is no reputation.1
1
And the underlying case is indeed, frivolous as further briefings will demonstrate.
1
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.”
______________________
2
3
I the undersigned swear that a true copy of this Notice was served to
Counsel and Putative Counsel respectively via CCAP and at:
[email protected]
[email protected]
via email

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

)
Defendants.
LITIGANT KING §902.01 REQUEST FOR JUDICIAL NOTICE OF

NOVEMBER 14, 2024 WAUKESHA PD EMAIL

file this requested Notice.
1. Relevant Background.
Waukesha Police Sergeant Servando Benitez opined that the Abby litigant’s use of
Rilla/Rilla voice may indeed violate Wis. Stat §968.31 and stated that the Department should
consider following Abby staff around to monitor them, and noted that staff could be legally
liable and probably have no idea that they are violating the law. He further indicated that he
would need actual recordings…. Which the Department actually has had for months; it is
related to the files that Litigant King filed under Seal, the John V. Mouldenhauer files. As the
Court is aware from Litigant King’s Opposition to Abby’s Motion to Dismiss Counterclaim,
they also have live complainants. This is what he outright stated “If these allegations are true, it
feels like the people directing them to do this are more responsible than the sales people” and
wrote in pertinent part:
1
This all came up because an allege ex-employee called in saying the company traines
sales people to do this and they often jack the price up of the widows because the more
they sale the more they make in commission. As of now we don’t have any actual victims
but the employee is trying pass on this information because he wants someone to look
into it. The ex-employee is working with a private investigator and they are claiming they
have tried the FCC along with the FBI so take that for what it is. The ex-employee and PI
are bringing up 968.31 as the law that it violates.”
Not sure if the ex-employee has a grudge with the company but he provided a bunch of
documents to E Hendo. At this point I told Hendo to take an I on it and will look into it
further. I reached out to Leslie and this was her answer “I think it is a violation of 968.31,
for the person recording the conversation as well as any person directing that a
conversation be recorded. Wisconsin is a one party consent state, but based on the fact
that the salesperson left the room and recorded a conversation without any of the parties
knowing about it, it would be a violation. The problem is going to be proving it. It sounds
like the person reporting it also violated the statute and therefore, could be subject to
criminal penalties as well as civil penalties under 961.31(2m). I assume the business is
located in the City of Waukesha. We would definitely need more than just his word—I
would want the recorded conversation, statements from the victims that they did not give
consent, that the voices on the recording are theirs, etc. Without any recorded
conversations being turned over, I think you would have to follow the salespeople
around, see if they leave the customers alone and then confront them about their
recording of any conversation. I am sure these salespeople do not have a clue that what
they are doing is illegal. If these allegations are true, it feels like the people directing
them to do this are more responsible than the sales people.” (Appendix A).
The allegations are indeed true and testimony will reveal it to be so. One Hundred Per
Cent. Meanwhile Sergeant Benitez telephoned Litigant King yesterday, July 8, 2024 and flipped
like a pancake, which surprised many people on NextDoor where 4,000 people have read it in
48 hours. https://nextdoor.com/profile/01zn6N-PgSwJ5QfYB/?is=feed_author
2
In a phone call from Benitez he refused to consider anything whatsoever and repeatedly
insulted Litigant King’s intelligence. Litigant King was not prepared to record the call initially
but once he read the negative attitude he ran an immediate video and has demanded the full
audio for use at Trial and during Deposition of this Officer.
https://www.facebook.com/KingCast/videos/455973880619677
https://www.youtube.com/watch?v=0EUe7GVsxss
Big Easy Waukesha: PD Retreats from its Position on Abby Windows; Now Refuses to Investigate.
This parallels the same laissez-faire attitude over a DA Suan Opper’s Office, leading
Litigant King to note:
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.
3
(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.
The ongoing recalcitrance of Wisconsin Law Enforcement to address any of the obvious
violations of law by Abby is astounding, especially when we recall last week’s Judicial Notice
regarding Consumer bullying, fake reviews and more when the Record in replete with
indications that Abby does the exact same thing, recall the Extortion threat against Consumer
Amy O’Donnell over a negative review and many more.
This incalcitrant behavior has indeed caused Litigant King to soundly criticize Waukesha
DA Susan Opper on repeated occasion, and the fact that her assistant told Litigant King they will
no longer respond to his emails nor will she inform him to whom she forwarded his information
in the office is not promotive of any sort of transparency we demand from modern government.
King told the assistant in no uncertain terms on or about July 8, 2024:
From: Christopher King <[email protected]>

Subject: Re: DA Case # 2024WK004117
Date: July 8, 2024 at 11:01:08 PM PDT
To: Waukesha County DA <[email protected]>
Cc: coltyn vondeylen <[email protected]>
Dear Ms. Moelter,
Please allow me explain a few things to you lest you be confused here are ten (10) points of
light:
1. I did not ask for Abby Windows to be an abusive company.
2. I did not ask for her abusive lawyers to sue 5 innocent staff and me on a patently bogus case
for "Defamation" against a Limited Purpose Public Figure.
3. I did not ask your boss to ignore, and to continue to ignore likely violations of Wis. Stat
§968.31 that the Wauskesha PD noted.
4. I did not ask for Consumer Protection and Pat Studenec to fail to provide that thumb drive to
Waukesha PD.
5. I did not ask for Abby Windows to unlawfully request early Certificates of Completion at
Coltyn Vondeylen's home.
6. I did not ask for Abby Windows to run Rilla/Rilla Voice and to have staff walk away from the
recording device at Coltyn Vondeylen's home which they most assuredly did.
4
7. I did not ask for Abby and her happy little Window company to refuse to answer his inquiries
about Rilla/Rilla Voice, equipment buyback or early Completion Cetificates.
8. I did not ask for Abby to refuse to answer 6 or 7 reach-outs prior to publication.
9. I did not ask for Abby to refuse to reach back to Coltyn Vondeylen; I just spoke with him again
at 6:15pm Central and bupkis from Abby.
10. I did not ask for Abby to use economic coercion to make her staff use Rilla/RillaVoice.
https://youtu.be/FQEYliCxC4A
All I asked for, is for your boss to protect these five (5) innocent staffers and homeowners from
unlawful consumer abuse, the type again witnessed almost verbatim in Washington, or the type
that Waukesha PD noted is quite likely here:
https://www.koin.com/news/health/ap-health/ap-seattle-plastic-surgery-provider-accused-of-
posting-fake-positive-reviews-must-pay-5m/
https://www.atg.wa.gov/news/news-releases/ag-ferguson-files-lawsuit-against-seattle-based-
plastic-surgery-clinic-bribing1
*******
At this moment let us drill back down on what innocent homeowner Coltyn VonDeylen is
going through, and Abby and the State refuse to address him whatsoever about his legal concerns
on Rilla Eavesdropping and Premature demands for Certificates of Completion, issues that
Defendants in the primary case are being sued over.
1
Litigant King believes this hostility with His Honor’s chosen appointee to succeed him at the Waukesha DA’s
Office mandates Recusal, regardless of Litigant King’s affinity with His Honor’s First Amendment Amicus
Briefings in McAdams: Offensive or unpopular speech is not inherently Defamation or otherwise unlawful, a lesson
that the Abby litigants need taught in the most serious way.
5
6
For some reason Litigant King (and all non-Abby litigants) believe this information to be
relevant to this discussion.
II. Law and Argument.
We all know the standards for Judicial Notice. Litigant King will be blunt: If Wisconsin
Law Enforcement decides to continue with its head in the sand and to harm innocent
homeowners and staff, and refuses to investigate and act in a dismissive and hostile manner
when receiving information (Benitez) then they are free to do so with the following caveat:
The Trial will be on video and then the taxpayers and constituents will review the matter and
make their decision, and an informed public is the best public is it not? Is that not what our
Founding Fathers fought for? Is that not why we celebrate the Fourth of July, Veteran’s Day and
Memorial Day?
Whatever the case none of the Abby5 or Litigant King is going to sit here and suffer this
gaslight-scapegoating narrative offered by Abby. The Court does not sit as a Super Legislature to
set policy on these matters but the Court most assuredly does sit as a conduit of meaningful
information on which it reflects and shares relevant information with the Jury. The Jury in turn
renders its decision, and then the Legislature can and must take note of it.
7
If this Court does not honor these principles and declines to consider these documents and
information or at Trial refuses to allow its introduction it will be doing a grave disservice to
innocent Consumers and working stiffs, and once they hear about it they will not be happy.
Those who know about it now are not happy, but it is tough to reach people because Abby makes
things disappear from the Internet as previously noted. Unfortunately for the Abby litigants the
facts will prove that there is not one single thing they can or will do to stop Litigant King’s
enjoyment of the Free Press, or the Abby5’s exercise of their Certain Inalienable First
Amendment Rights.
III. Conclusion.
Pickering, again:
______________________
8
[email protected]
[email protected]
via email

_____________________________________________
9
Waukesha PD Judicial Notice
Appendix A
From: Servando Benitez
To: _PD Detective Supervisors
Subject: FW: Complaint to District Attorney on Abby Windows and Exteriors for Illegal Oral Interceptions in the
Commission of Consumer Fraud
Date: Tuesday, May 14, 2024 8:45:08 PM
Ill let you guys read below if you want, long story short “A window company has sales reps
going around providing quotes to individuals. When they go inside to meet with the
homeowners to discuss quotes they leave a recording device and step out so the homeowners
can discuss the quote. The homeowners obviously don’t know the device was left behind and
the conversation is recorded. The sales person will listen to the people talk and then use the
information to work the deal further. This all came up because an allege ex-employee called in
saying the company traines sales people to do this and they often jack the price up of the
widows because the more they sale the more they make in commission. As of now we don’t
have any actual victims but the employee is trying pass on this information because he wants
someone to look into it. The ex-employee is working with a private investigator and they are
claiming they have tried the FCC along with the FBI so take that for what it is. The ex-employee
and PI are bringing up 968.31 as the law that it violates.”
documents to E Hendo. At this point I told Hendo to take an I on it and will look into it further. I
reached out to Leslie and this was her answer “I think it is a violation of 968.31, for the person
recording the conversation as well as any person directing that a conversation be recorded.
Wisconsin is a one party consent state, but based on the fact that the salesperson left the
room and recorded a conversation without any of the parties knowing about it, it would be a
violation. The problem is going to be proving it. It sounds like the person reporting it also
violated the statute and therefore, could be subject to criminal penalties as well as civil
penalties under 961.31(2m). I assume the business is located in the City of Waukesha. We
would definitely need more than just his word—I would want the recorded conversation,
statements from the victims that they did not give consent, that the voices on the recording are
theirs, etc. Without any recorded conversations being turned over, I think you would have to
follow the salespeople around, see if they leave the customers alone and then confront them
about their recording of any conversation. I am sure these salespeople do not have a clue that
what they are doing is illegal. If these allegations are true, it feels like the people directing
them to do this are more responsible than the sales people.”
The company has an office on Pilot Ct in our city and one in Brookfield. They reached out to the
DA’s office and were told to file a report with us. We don’t have any victims and just an ex-
employee who is passing this information on. The question is who gets it assigned? This might
be a big nothing and I don’t know how much we can do with no victims. Do we hit up DCI and
see if they have an interest?
From: Patrick Kenealy <[email protected]>

Sent: Tuesday, May 14, 2024 5:26 PM
WAUKESHA COUNTY
STATE OF WISCONSIN
Defendant Counter-Plaintiff, )
v. ) CASE NO.2024-CV-000820

)
Plaintiff Counter-Defendants.
MEMORANDUM IN OPPOSITION TO ABBY LITIGANTS’ MOTION TO DISMISS

FIRST AMENDED RULE §2620 ABUSE OF PROCESS COUNTERCLAIM
OF DEFENDANT CHRISTOPHER KING, J.D
NOW COMES LITIGANT CHRISTOPHER KING, J.D., without waiving any Defenses
or Jurisdictional challenges, to file this Memorandum. A Second Amended Counterclaim shall
follow within forty-eight (48) hours. This will be brief.
I. Law and Argument
Abby litigantss’ cited case is inapposite here because no Counterclaim against Counsel
exists, which is the sine qua non of the cited case, to wit: Badger Cab v. Soule 171 Wis. 2d 754
(1992) read, in pertinent part:
Allowing counterclaims against opposing counsel could create a conflict of interest

which would require a substitution of counsel. Babb v. Superior Court of Sonoma
County, 479 P.2d 379, 382 (Cal. 1971); Lyddon v. Shaw, 372 N.E.2d 685, 688 (Ill. App.
Ct. 1978). This has occurred in the case at bar as the drivers' attorneys recused
themselves and sought their own counsel to defend the counterclaims. We are concerned
that such counterclaims could become potent "dilatory and harassing devices" which
could "deter poor plaintiffs from asserting bona fide claims" due to the additional risk and
expense. Babb, 479 P.2d at 382-83.
1
We are also seriously concerned about the negative effect of these counterclaims on the
attorney-client privilege and work product immunity, both critical to effective advocacy.
The company and Melms, the respondents, argue that sec. 901.04(1), Stats., under which
preliminary questions, including the existence of a privilege, are determined by the trial
judge, sufficiently protects the attorney-client privilege. Work product is similarly *761
shielded by a motion for a protective order under sec. 804.01(3), Stats. While these
safeguards exist, resorting to them could significantly delay the discovery process and the
resolution of the principal action. See Realco Services, Inc. v. Holt, 479 F. Supp.
880, 886 (E.D. Pa. 1979). We view such delays as undesirable, especially when they
could be avoided by simply requiring the claims against opposing counsel to be brought
after termination of the principal lawsuit.
There being absolutely no such issues at bar, the Counterclaim moves forward. Cornell
law notes:
If the defendants’ counterclaims address the same basic issues as the plaintiff’s claims,
courts usually address the claims and counterclaims at the same time. If the counterclaims
involve distinctly different issues or facts, the court may choose to address them separately.
As to Brownsell v.. Klawitter, 102 Wis. 2d 108, 115 (1981) that case is as stale as last
week’s bread. See Spaulding v. Tri-State 18-CV-377, 18-CV-826 (WD Wisconsin, 2019)
I. Defendant’s Motion to Amend the Counterclaim
Defendant seeks to amend its counterclaim to seek fees and costs incurred in
litigating these cases, as well as damages for “loss of potential business”
through a claim for abuse of process.
The Spauldings brought suit against Tri-State Adjustments alleging

violations of the Fair Debt Collection Practices Act (the “FDCPA”), 15
U.S.C. § 1692.1 The court previously concluded that § 1692k(a)(3) of the
FDCPA did not provide an avenue for a counterclaim, but permitted Tri-State
to seek leave of court to expressly set forth the state-law bases for an award of
fees and costs in responding to plaintiff’s lawsuit. (18-cv-377, dkt. #34 at 6-
8, n.3.) Presently before the court is defendant’s request for leave to amend
its counterclaims (dkt. #19), as well as plaintiffs’ motion for judgment on the
pleadings as to defendants’ unclean hands affirmative defense (dkt. #32).2
For the reasons set forth below, both motions will be granted.1
1
In case the Abby litigants and Counsel missed it, there are not one but two case numbers there, one denoting the
Counterclaim in action at the same time. So the Abby litigants have engaged the Court in yet another frolic and
detour at taxpayer expense while wasting valuable Judicial resources, just like their entire lawsuit, ab inito.
Seriously all they had to do was request a More Definite Statement, which could have been done via simple email
correspondence but they are far too arrogant to even respond to King, even in the face of a clearly fraudulent process
server as previously-noted. See https://www.youtube.com/watch?v=QraYXNhS2BY&t
Hoosier Process Service Hires a Dirtbag to do Abby Binder's Dirtywork
2
As to Abusing the Process may the Court remember that it is patently evident that no
written notice was given to anyone as clearly mandated by Wis. Stat §895.05 which read in
pertinent part:
895.05 Damages in actions for libel.
(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….2
So then, at a minimum any reasonable Trier of Fact could find an Abuse of Process so the
Abby litigants are achieving nothing more than the rearrangement of deck chairs on the Titanic;
their time is coming. And it is coming hard given the fact that they had about six (6) or seven (7)
opportunities to even talk with King before his second video; all of this has been noted in the
Court.
King reminds the Abby litigants that even if they were able to prove that they had
justifiable grounds to initiate this case on some issues they clearly do not have such grounds to
continue with much of it, such as any claims subject to Wis. Stat §895.05 or claims about not
making a sale to Ms. Bertha or asking for premature Certificates of Completion as the record is
not replete with examples of the Certificate abuse including one Coltyn VonDeylen. Mr.
VonDeylan demanded to know if Abby had surreptitiously Rilla/Rilla Voice recorded him and
demanded an early Certificate a week ago and Abby – as per her usual – refuses to even respond.
As to Ms. Bertha the Court has already seen that the Abby litigants own materials proudly
proclaim “SOLD!!” for example.
2
The Court is already well aware of Abby litigants’ penchant for always threatening people without Probable Cause,
including but not limited to threatening innocent homeowners with Extortion prosecution over a negative review.
Recall the Universal Equity Maxim “Those who seek equity must come with Clean Hands.”
3
4
5
II. Corrective Measures.
Litigant King and any Joinders will correct the format of the Counterclaim within forty-
eight (48) hours and move this case on down the road towards a Jury.
___________________________
Christopher King, J.D.
I the undersigned swear that a true copy of this First Amended Counterclaim was served to
[email protected]
[email protected]
via email
_____________________________________________
6
Grievance Form
To file a grievance: Complete this form, sign and date it, and submit it via email or mail.
[email protected] Office of Lawyer Regulation
P.O. Box 1648
Madison, WI 53701-1648
Your Information
Name Christopher King, J.D. Email [email protected]
Street Address 515 E. Fulton Street Daytime Phone Number 617.543.8085m
City Mt. Vernon ■ Phone

Preferred method for intake
staff to contact you ■ Email
State WA Zip 98273 Mail
Lawyer Information
Only list one lawyer per form. We can’t accept a grievance against a law firm, only individual lawyers.
Lawyer Name Timothy J. Andringa, Esq.
Was this your lawyer? Yes No
Street Address 1601 E. Racine Ave Ste 200 If yes, date hired:
City Waukesha, WI 53186 If no, what connection do you have to the lawyer?
Opposing Counsel
State WI Zip 53186
If a court case is involved, provide the case number and county or court. If your issue does not involve a
court case, please describe the services the lawyer was to provide.
Abby Windows, LLC et al. v. Christopher King, J.D. et al., Waukesha 2024-CV-00820
STATEMENT OF FACTS – Attach a brief summary (no more than 2 pages) of what the lawyer did
or did not do that you are concerned about. Please include dates on which events occurred.
DOCUMENTS – Provide any documents that support your grievance with this form.
Please be advised that a copy of this grievance and all attached documents will be provided to the lawyer
who you are filing the grievance against.
Signature Date 8 July 2024
Questions?
email [email protected] or call toll-free (877) 315-6971 or (608) 267-7274 and press “1”
Grievance Form
To file a grievance: Complete this form, sign and date it, and submit it via email or mail.
[email protected] Office of Lawyer Regulation
P.O. Box 1648
Madison, WI 53701-1648
Your Information
Name Christopher King, J.D. Email [email protected]
Street Address 515 E. Fulton Street Daytime Phone Number 617.543.8085m
City Mt. Vernon ■ Phone

Preferred method for intake
staff to contact you ■ Email
State WA Zip 98273 Mail
Lawyer Information
Only list one lawyer per form. We can’t accept a grievance against a law firm, only individual lawyers.
Lawyer Name Steven M. Couch Esq.
Was this your lawyer? Yes No
Street Address 123 N. Wacker Drive If yes, date hired:
City Chicago If no, what connection do you have to the lawyer?

Opposing Counsel
State IL Zip 60606
If a court case is involved, provide the case number and county or court. If your issue does not involve a
court case, please describe the services the lawyer was to provide.
Abby Windows, LLC et al. v. Christopher King, J.D. et al., Waukesha 2024-CV-00820
STATEMENT OF FACTS – Attach a brief summary (no more than 2 pages) of what the lawyer did
or did not do that you are concerned about. Please include dates on which events occurred.
DOCUMENTS – Provide any documents that support your grievance with this form.
Please be advised that a copy of this grievance and all attached documents will be provided to the lawyer
who you are filing the grievance against.
Signature Date 8 July 2024
Questions?
email [email protected] or call toll-free (877) 315-6971 or (608) 267-7274 and press “1”
8 July 2024
Good Day,
Attached please find an intake sheet, complaint and attachments relative to these two Attorneys for their
conduct in Abby Windows, LLC et al. v. Christopher King, JD et al., Waukesha 2024-CV-000820
Note that Attorney Couch is participating pro hac vice in this venue.
The complained of conduct relates to the following in a Defamation lawsuit against five (5) innocent
former staffers and me as a professional Journalist.
SCR 20:1.2 (d)

(d) A lawyer shall not counsel a client to engage, or assist a client, in conduct that the lawyer knows is
criminal or fraudulent, but a lawyer may discuss the legal consequences of any proposed course of
conduct with a client and may counsel or assist a client to make a good faith effort to determine the
validity, scope, meaning or application of the law.
ABA Rule 1:2 (d) A lawyer shall not counsel a client to engage, or assist a client, in conduct that the
lawyer knows is criminal or fraudulent, but a lawyer may discuss the legal consequences of any proposed
course of conduct with a client and may counsel or assist a client to make a good faith effort to determine
the validity, scope, meaning or application of the law.
Attorney Andringa filed, and is maintaining a lawsuit that is frivolous in general but specifically in this
instance is being used as a misguided sword to accuse me and five innocent former Abby Windows
staffers of Defamation for claiming that Abby Windows management forces staff to use Rilla/RillaVoice
software in a way that violates Wisconsin Privacy Rights in the home. Specifically there are concerns that
the surreptitious recordings are in violation of 18 USC §2511, and further in violation of Wis. Stat.
§968.31 because they are instructed in the training manual to leave the interior of the home and to go
outside. There is not one single warning or indication that the recording device (typically on a laptop or
tablet) is turned off. I have personally listened to the audio of one John V. Mouldenhauer's family that
was recorded while they were in private discussions.
Attorney Andringa appeared as Pro Hac Vice several weeks ago (without the Administrative procedure of
notifying litigants I might add) and is also maintaining this train wreck lawsuit.
In any event, I have repeatedly warned these lawyers that I had this information, and now also have the
live complaint from one Coldyn VonDeylen in which he specifically inquired of Abby directly whether
he was recorded without his knowledge, in addition to Abby's all-too-typical request for early Certificates
of Completion (another Statutory violation), but neither Abby nor these lawyers have said "Boo!" to this
poor abused homeowner. Worse yet is the fact they they tried to claim us calling Abby out for it is
Defamatory even in the face of all of these facts. Sadly, this is how Abby empirically operates as she
previously told another abused homeowner she was calling the Waukesha PD and filing an Extortion
complaint against her because of a bad review. When you run your investigation of this company and its
practices as it relates to these two Attorneys you too will be appalled. In fact, on the fake reviews and
threatening conduct towards homeowners just prior to my initial coverage of these matters Washington
AG Bob Ferguson nailed a plastic surgeon for $5M for virtually identical conduct as you will see in the
attached documentation.
*********
That being said, the relevant background also includes the fact that Attorney Andringa filed the Primary
Action in Abby Windows v. Christopher King, JD et al. Waukesha 2024-CV-000820 with nary a concern
as to the mandatory and jurisdictional requirements of Wis. Stat §895.05 requiring written notice prior to
initiating any Defamation claims based on traditional libelous (written) comments. This is completely
inexcusable behavior, especially given the fact that I had written his client and called them no less than
six (6) or seven (7) times prior to publication of anything.
This sort of Bad Faith informs the reviewing Counsel of the nature of this case and it is a very ugly
harbinger. As goes the client so goes the Counsel.
617.543.8085m
PS: It bears noting that I do not file grievances without substantial care, consideration and concern: The
only grievance I can recall filing since the 1990's was sustained by the OLR in the matter of one Mark
Rattan in which he "approached me in an angry and threatening manner in violation of a Standing Order"
that [King] and his cameras were engaged in lawful protected activity. It is perhaps telling to note that all
three (3) of these lawyers have a verifiable contempt for my Courtroom video, with Respondents in this
instance attempting to object to video coverage of any hearings. The Court shut that down summarily
with the obvious caveat that I cannot run the video myself but I had already clarified that in my Notice of
Media Coverage anyway. Obviously outside of a zoom hearing I would be a bit too busy to smoothly
handle that operation anyway.
The police email was written before they received
actual audio from the John V. Moldenhauer file
or the live complaint of Coltyn VonDeylen
They are now in receipt of both.
From: Servando Benitez
To: _PD Detective Supervisors
Subject: FW: Complaint to District Attorney on Abby Windows and Exteriors for Illegal Oral Interceptions in the
Commission of Consumer Fraud
Date: Tuesday, May 14, 2024 8:45:08 PM
Ill let you guys read below if you want, long story short “A window company has sales reps
going around providing quotes to individuals. When they go inside to meet with the
homeowners to discuss quotes they leave a recording device and step out so the homeowners
can discuss the quote. The homeowners obviously don’t know the device was left behind and
the conversation is recorded. The sales person will listen to the people talk and then use the
information to work the deal further. This all came up because an allege ex-employee called in
saying the company traines sales people to do this and they often jack the price up of the
widows because the more they sale the more they make in commission. As of now we don’t
have any actual victims but the employee is trying pass on this information because he wants
someone to look into it. The ex-employee is working with a private investigator and they are
claiming they have tried the FCC along with the FBI so take that for what it is. The ex-employee
and PI are bringing up 968.31 as the law that it violates.”
documents to E Hendo. At this point I told Hendo to take an I on it and will look into it further. I
reached out to Leslie and this was her answer “I think it is a violation of 968.31, for the person
recording the conversation as well as any person directing that a conversation be recorded.
Wisconsin is a one party consent state, but based on the fact that the salesperson left the
room and recorded a conversation without any of the parties knowing about it, it would be a
violation. The problem is going to be proving it. It sounds like the person reporting it also
violated the statute and therefore, could be subject to criminal penalties as well as civil
penalties under 961.31(2m). I assume the business is located in the City of Waukesha. We
would definitely need more than just his word—I would want the recorded conversation,
statements from the victims that they did not give consent, that the voices on the recording are
theirs, etc. Without any recorded conversations being turned over, I think you would have to
follow the salespeople around, see if they leave the customers alone and then confront them
about their recording of any conversation. I am sure these salespeople do not have a clue that
what they are doing is illegal. If these allegations are true, it feels like the people directing
them to do this are more responsible than the sales people.”
The company has an office on Pilot Ct in our city and one in Brookfield. They reached out to the
DA’s office and were told to file a report with us. We don’t have any victims and just an ex-
employee who is passing this information on. The question is who gets it assigned? This might
be a big nothing and I don’t know how much we can do with no victims. Do we hit up DCI and
see if they have an interest?
From: Patrick Kenealy <[email protected]>

Sent: Tuesday, May 14, 2024 5:26 PM
FROM THE DESK OF CHRISTOPHER KING, JD
[email protected]
617.543.8085m
8 July 2024
Re: Ethical Violations of Abby Windows, LLC Counsel Timothy Andringa and Steven M. Couch;
Ongoing Consumer Abuse and Fraud and Potential Legal Exposure to Staff.
SCR 20:1.2 (d)

(d) A lawyer shall not counsel a client to engage, or assist a client, in conduct that the lawyer knows is criminal or
fraudulent, but a lawyer may discuss the legal consequences of any proposed course of conduct with a client and
may counsel or assist a client to make a good faith effort to determine the validity, scope, meaning or application of
the law.
ABA Rule 1:2 (d) A lawyer shall not counsel a client to engage, or assist a client, in conduct that the lawyer knows is
criminal or fraudulent, but a lawyer may discuss the legal consequences of any proposed course of conduct with a
client and may counsel or assist a client to make a good faith effort to determine the validity, scope, meaning or
application of the law.
I. Willful Violation of Wis. Stat §895.05.
First we face the fact that you filed this Primary Action in Abby Windows v. Christopher King, JD et al.
Waukesha 2024-CV-000820 with nary a concern as to the mandatory and jurisdictional requirements of
Wis. Stat §895.05 requiring written notice prior to initiating any Defamation claims based on traditional
libelous (written) comments. Completely inexcusable behavior, especially given the fact that I had written
your client and called them no less than six (6) or seven (7) times prior to publication of anything. This
sort of Bad Faith informs the reviewing Counsel of the nature of this case and it is a very ugly harbinger.
II. Class H Felony Misprision/SCR 20:1.1(d)/ABA Rule 1:2(d) Wis. Stat §968.31 Violation.
Next we face the inevitable conclusion that your client is in blatant violation of Federal (and State) laws
that DA Susan Opper, Consumer Protection and Waukesha PD have all chosen to ignore. As a former
AAG myself I am with this letter also approaching AG Kaul about this because the record in the
underlying case is replete with absolute facts that show Abby Binder had to force her sales staff to use
Rilla/Rilla Voice surreptitiously in violation of 18 USC §2511 and Wis. Stat §968.31 because they are
specifically instructed by Abby’s own training materials to twice leave the primary sale locus to go
outside. There is no instruction to turn off the recording device either time, and I have directly heard a
surreptitious conversation at a homeowner’s house when the sales staff had gone outside.
I will provide all the accompanying materials when you contact me for further investigation, something
that no other Wisconsin Law Enforcement Agent nor Agency has yet done for some reason.1 A call to
Waukesha PD left us running in circles between them and the Waukesha DA’s office, which had the nerve
to even tell me that they were not going to answer any more emails from me. I told her: “You can dodge
my emails but you will not dodge my Subpoena.”2
1
My PI will locate that homeowner and they will be subpoenaed in the underlying case.
2
I have renewed my Motion to Recuse Judge Brad D. Schimel much as I agreed with his position on other First
Amendment matters these optics are not sustainable at this point with her becoming my Witness.
https://youtu.be/brZb6yyPHM8
I publicly criticized DA Opper and she is my lead yet Hostile Witness because the Plaintiff raised her
name as someone that received Defamatory communications to her when I was merely asking her to
investigate.
https://youtu.be/e2K40tCNBts
These lawyers are violating SCR 20:1.2 (d) and ABA Rule 1:2 (d) for their attempts to turn this around
into being a Defamatory allegation against their client, which is absolute nonsense; they are involved in
Misprision of a Class H Felony. Here is their perverse spin on it, claiming that they don’t direct its sales
personnel to leave any device to record the private conversations of prospective customers. That is a lie
because as noted above in the file there is proof of such a recording that I attempted to file under Seal, a
request which was denied so it is public record. From para 19 a bald-faced lie appears:
First let’s review the salient portions of Abby’s own training manual that clearly directs staff not once but
TWICE to leave the primary sales locus.
1
Significantly, Rilla Partner Grosso University Sales Academy has a nearly exact process in its “Sales
Academy Workbook” that a Good Samaritan forwarded to me shortly after this litigation commenced.1
1
This is a National Issue; thousands of homeowners every day are being violated so Abby and her lawyers
thought it would be neat to try to flip the narrative. I feel confident that neither AG Kraul nor the Bar Reviewers
fall for this attempted coverup. This is particularly true when they review the Abby Binder Rule 908 Party
Admission on “The Wealthy Contractor” about how she had to use economic coercion to compel Rilla
compliance, a fact supported today yet again by top salesman Dylan Helfnstein who was Employee of the
Week more than anyone else, infra.
2
3
The Abby process dictates two (2) leaves of absence. Note that even if the
homeowner comes outside the first time, they do not the second time, by
design. The entire manual is completely bereft of any Privacy or 18 USC
§2511 or Wis. Stat §968.31 references whatsoever.2
In practice, this is how it works and there is sworn testimony already filed
in Court over it and Dylan Helfenstein yet again confirmed it on July 6,
2024:
2
I had been waiting for Binder and her duly-licensed Counsel to double-down on this lie as I had been in
possession of the training materials shortly after I ran my first video but I’ve seen enough of this abuse that it
simply cannot wait any longer: You as AG and the respective Bar Association disciplinary committees must
step in now.
4
5
Here are just a few items now for your edification where a homeowner noted that sales staff left the room
with electronic devices left behind. Coltyn VonDeylen, who ALSO noted – as have others – that this
company makes premature requests for Certificates of Completion, which is yet another patent violation
of Wisconsin Law, specifically as told to Waukesha DA Susan Opper:
26 June 2024
it:
……..but let’s remain focused on the unauthorized Eavesdropping, a Class H Felony as Abby even noted
in her own Sworn Complaint in claiming that the staffers and I had wrongly accused her of practicing it.
Here is a live customer, one of several we have spoken with directly who affirmed similar business
practices:
The aforesaid Abby customer did inquire of the Abby litigants if they had Rilla recorded him; and despite
the serious nature of the questions there has been absolutely zero response from Abby:
6
The aforesaid Abby customer did further write Consumer Protection’s Patrick Studenec and the
Abby litigants after they did not respond to him on Monday, at close of business Tuesday with the
following:
From: coltyn vondeylen
Date: July 2, 2024 at 5:14:38 PM CDT
To: [email protected], [email protected]
Subject: Supplement to my complaint #31c2ff06302024233137
Dear consumer protection staff and abby windows:
To expand on my complaint and concerns I have seen the owner of the company on public video
sites discussing how rilla is used for quality control Since there was a pricing discrepancy in my
case I would like to hear the recording of the sales presentation at my home so that I can
a) be aware of what is being recorded without my knowledge, and
b) help the owner find out how to hone any communication issues.
Furthermore, I am voicing my concern that I was asked to sign a certificate of completion before
the work was done.
Thank you for your time,

Coltyn VonDeylen
7
I have placed these Counsel on Actual Knowledge of the valid concerns on the non-response:
Let's see how your client volleys this ball. It's a sharp crosscourt BH for sure; with Abby's
unsteady legal footing she is certain to fail. She either provides the recording -- to which he is
entitled -- or she commits Perjury and says she doesn't have a recording when we all know Rilla
just made her a Crown Princess of the franchise 2 weeks ago right after my first Rule 908 Video so
I'm sure Rilla will be ecstatic to know that she doesn't have the recording or wasn't using it.
Abby has spun enough lies already but hey let's keep on going it's only going to get worse.
https://www.youtube.com/watch?v=FQEYliCxC4A
**********
8
III. Browbeating Customers and Posting and Manipulating Fake Ads. 3
Finally, I am approaching AG Kaul to see if he will follow the lead of Washington AG Ferguson who
actually took disciplinary action against a company that is engaged in the exact same conduct employed
by Abby Windows with the fake reviews, forced NDAs and outright threats of “Extortion” relating to an
honest and negative review by Amy O’Donnell. Here then is what Washington AG Bob Ferguson did,
followed by what an innocent homeowner suffered through with Abby Binder:
3
Lest the reviewing Counsel get too in the weeds on these items suffice to say in reviewing Appendix A – the base
instructions for the Consumer Fraud with complete knowledge and agreement from Abby – also know that I have
put Opposing Counsel and all relevant Wisconsin LE on Actual Notice that a woman in one of the fake testimonials
is actually Defendant Fred Mayen’s wife. Mayen also admitted in writing that Abby and/or her wife and VP Mandy
made him forge a signature for a change order after a $10,000.00 overcharge in order to cook the books.
9
Dear Attorney Kaul you may reach Ms. O’Donnell at [email protected]. I can’t
technically talk to her but you can.4
“Writing a truthful review about a business should not subject you to threats or intimidation,”
Ferguson said in a statement. “Consumers rely on reviews when determining who to trust,
especially services that affect their health and safety. This resolution holds Allure accountable for
brazenly violating that trust — and the law — and ensures the clinic stops its harmful conduct.”
The complaint accused Allure of illegal business practices including artificially inflating its
ratings on Yelp and Google by posting fake positive reviews and suppressing negative ones that
were real.
The details of the lawsuit and $5M Consent Decree -- issued prior to my involvement with Abby
mind you -- are linked here:
4
Actually the forced NDA with her is basically a legal nullity for Bad Faith/Public Policy reasons contemplated by
Washington v. Alderwood but for now let’s play along with Abby and her Arbitrary and Capricious misconduct.
10
https://www.koin.com/news/health/ap-health/ap-seattle-plastic-surgery-provider-accused-of-
posting-fake-positive-reviews-must-pay-5m/
plastic-surgery-clinic-bribing Washington v. Alderwood Surgical 22-CV-01835-RSM (April 12,
2024)
A copy of a set of instructions directly from Abby Binder is attached at Appendix A. Note the
specific instruction “This is not a contest for REAL reviews….” (emphasis in original).
***********
This, from Appendix A, is how Abby goes about her business as a matter of Law and Fact, and she has
had previous Attorneys bully people as well, as noted by Ms. O’Donnell, supra, and Deanne Harris who
told me Abby was extremely rude to her when she complained. Many others have complained as well, but
I know for fact that Abby had her staff flag known honest reviews so that the evaporated from public
view.5
5
This fact in and of itself renders a lawsuit for Defamation a legal impossibility because we can never truly know
the true reputation of the entity, ipso facto. That much is simple and it also renders the underlying lawsuit frivolous,
ab initio.
11
Only a fool comes to Court with hands this dirty. A fool or someone who can operate out of manifest
insouciance, feeling secure that their power, position and privilege will still net them a positive result
regardless of the facts. I put Opposing Counsel on Actual Notice that I won’t be tolerating any of that nor
should the reviewing bodies in this instance:
Counselors,
Your client, on substantial information and belief, is a Class H Felon.
Your misguided attempts to turn this on the Defendants or anyone else will find no quarter here. I
am going to do what I need to do, and then you can answer to it because I am not going to suffer
this nonsense.
SCR 20:1.2 (d)

(d) A lawyer shall not counsel a client to engage, or assist a client, in conduct that the lawyer
knows is criminal or fraudulent, but a lawyer may discuss the legal consequences of any proposed
course of conduct with a client and may counsel or assist a client to make a good faith effort to
determine the validity, scope, meaning or application of the law.
ABA Rule 1:2 (d)
A lawyer shall not counsel a client to engage, or assist a client, in conduct that the lawyer knows
is criminal or fraudulent, but a lawyer may discuss the legal consequences of any proposed course
of conduct with a client and may counsel or assist a client to make a good faith effort to
determine the validity, scope, meaning or application of the law.
<<By now you should have surmised that I have had a copy of your client's "New Abby
Sales Process" for quite some time.>>
The Abby process dictates two (2) leaves of absence. Note that even if the homeowner comes
outside the first time, they do not the second time, by design. The entire manual is completely
bereft of any Privacy or 18 USC §2511 or Wis. Stat §968.31 references whatsoever.[1]
[1]
I had been waiting for Binder and her duly-licensed Counsel to double-down on this lie as I had been in
possession of the training materials shortly after I ran my first video but I’ve seen enough of this abuse
that it simply cannot wait any longer: You as AG and the respective Bar Association disciplinary
committees must step in now.
12
***************
By the way, it appears that the cat still has your client's proverbial tongue on Mr. Vondeylen's
reasonable inquiries, repeated in their entirety below for your edification…..
……In sum, your client cannot just keep creating lies and hiring more lawyers to try to browbeat
people and abuse processes, such as your filing the primary action with absolutely no adherence
to Wis. Stat §895.05 for starters. Enjoy the balance of your weekend.
Warm regards,
617.543.8085m
I look forward to your respective investigations on these matters. I know the Defendants and
several homeowners would look forward to participating and I/we can identify them for you now and
further in Court.
_________________________
617.543.8085m
PS: I don’t take these situations lightly. I have helped my friend recover her money in Washington against
Attorney Scott and here in Wisconsin my complaint against Mark Rattan was sustained after he
“approached me in an angry and threatening manner in violation of a Standing Order” because he hated
my KingCast cameras. Note in the underlying case these Attorneys tried to fight video of substantive
hearings. They too, lost. I have found since running video of my own trials in the 90’s dishonest people
hate my cameras. See overleaf.
13
14
Abby Windows had 4 Solid Days to Reach Out
After my Initial Video to the Second
I remember I wrote April Broughton, whose hubby appears to be one of those faithful
Abby Reviewers....who include the rest of Abby Staff. So where exactly is their
credibility you ask? A Jury will ask the same question if they ever get there.
4
5
6
7
8
9
10
11
12
13
WAUKESHA COUNTY
STATE OF WISCONSIN
Plaintiffs, )
v. ) CASE NO.2024-CV-000820
) JUDGE BRAD D. SCHIMEL

)
Defendants.
NOTICE OF MOTION AND MOTION TO TAKE REMOTE COUNTERCLAIM DEPOSITION

OF PLAINTIFF ABBY BINDER1
NOW COMES COUNTERCLAIMANT KING et al., to move the Court for an order to take the
remote Deposition of Plaintiff Abby Binder as contemplated below. As Defendants are in various places
of the Great Lakes area and the State of Washington, such request is completely reasonable and the
reduces the time, expense and complexity of an in-person Deposition.
____________________________________
1
This document includes a corrected Notice of Counterclaim Deposition (Dkt. 83)..
1
WAUKESHA COUNTY
STATE OF WISCONSIN
Plaintiffs, )
v. ) CASE NO.2024-CV-000820

)
Defendants.
NOTICE OF RULE 804.05 COUNTERCLAIM DEPOSITION OF PLAINTIFF ABBY BINDER
PLEASE TAKE NOTICE that, pursuant to Wis. Stat §804.05, that Christopher King and all
Counterclaimants as applicable, will on Friday, 26 July, 2024 take the Deposition of Plaintiff Abby
Binder upon oral examination, to be recorded by stenographic means and videotape, at the virtual
offices of:
Seattle Deposition Reporters 600 University Street

Suite 320
Seattle, WA 98101
800.557.1110
206.622.6661
A link will be provided no less than forty-eight (48) hours prior to the scheduled Deposition.
All video will be held in abeyance and not publicly released unless filed and approved by the Court
as a valid Court Exhibit.
WHEREFORE YOU ARE HEREBY COMMANDED to provide the following documents:
1. A copy of any and all correspondence between Plaintiffs and the National Association of
the Remodeling Industry (NARI) from 1 January 2021 to present.
2. A copy of any and all Rilla or RillaVoice training manuals used from inception to date.
3. A copy of the entire file for Coltyn Vondeylen (a release will be provided).
2
4. A complete and unabridged copy of Dylan Helfenstein’s personnel file (a HIPAA release
will be provided).
5. A copy of any and all employee handbooks in place from 1 January 2021 to present.
6. A copy of any and all 3508 employee handbooks in place from 1 January 2021 to
present if different from item 5.
7. A copy of any and all sales process training manuals in place from 1 January, 2021 to
present.
8. A copy of any documents in your possession, date-referenced, that instructs sales staff
to stop Rilla or RillaVoice recordings when they leave the interior of a sales locus to go
outside.
9. A copy of any and all research or training materials in place prior to May 1, 2024
production that includes a reference to 18 USC §2511.
10. A copy of any and all research or training materials in place prior to May 1, 2024
production that includes a reference to Wis. Stat 968.31.
11. A copy of any and all BBB complaints issued since 1 January, 2021 to present.
12. A copy of any and all Cease and Desist/NDA Demands issued against former staff based
on their public comments from 1 January, 2021 to present.
13. A copy of any and all Cease and Desist/NDA Demands issued against customers based
on their public comments from 1 January, 2021 to present.
14. Any correspondence from the Abby litigants to any public official relating to this case.
The Deposition will commence at 1:00 p.m. on Friday, 26 July, 2024 and will continue day-to-day
until adjourned.
____________________________________
3
I the undersigned swear that a true copy of this Motion and Notice was served to
[email protected]
[email protected]
via email

This 5th day of July, 2024
_____________________________________________
4
WAUKESHA COUNTY
STATE OF WISCONSIN
Plaintiffs, )
v. ) CASE NO.2024-CV-000820
) JUDGE__________________
)
Defendants.
NOTICE OF RENEWED MOTION AND RENEWED MOTION

TO RECUSE JUDGE BRAD SCHIMEL
NOW COMES LITIGANT KING to provide crucial updates to his first Request for Recusal
which was denied without hearing. A Declaration in Support is affixed as Appendix A.
I. Relevant Background.
The original document is affixed hereto as Appendix B. Since that time the complexion of this
case has changed markedly, first with Washington AG taking Decisive Action against a predatory
merchant engaging in the exact same business practices that Waukesha DA Susan Opper, Consumer
Protection and Waukesha PD refuse to address out of home-town favoritism and no legal reason
whatsoever. https://www.atg.wa.gov/news/news-releases/ag-ferguson-files-lawsuit-against-seattle-based-
plastic-surgery-clinic-bribing Washington v. Alderwood Surgical 22-CV-01835-RSM (April 12,
2024)(Prior to Litigant King’s production of any media)(Appendix D).
AG Ferguson files lawsuit against Seattle-based plastic surgery clinic for bribing, threatening patients to
falsely inflate its online ratings.
News coverage – Judicial Notice has been requested.
https://www.koin.com/news/health/ap-health/ap-seattle-plastic-surgery-provider-accused-of-posting-fake-
positive-reviews-must-pay-5m/
“Writing a truthful review about a business should not subject you to threats or intimidation,”
Ferguson said in a statement. “Consumers rely on reviews when determining who to trust,
especially services that affect their health and safety. This resolution holds Allure accountable for
brazenly violating that trust — and the law — and ensures the clinic stops its harmful conduct.”
1
The complaint accused Allure of illegal business practices including artificially inflating its
ratings on Yelp and Google by posting fake positive reviews and suppressing negative ones that
were real.
Suffice to say the record is replete with references to the exact same conduct in this case, yet no
one in Wisconsin seems to care, no Law Enforcement nor Journalist dare touch this even though noted
consumer advocate Jason Brown directly wrote WISN staff and told them to contact litigant King, as
previously-noted repeatedly in filings.
Next, Litigant King and another sued Abby staffer have spoken directly with several local
homeowners who complained to him of the very core issues that were allegedly Defamatory as alleged in
the Verified Complaint para 32:
2
On information and belief two of the homeowners already have Counsel against the Abby litigants so they
declined to directly engage, however the one who is not represented has indeed engaged, and as the Court
will see his sentiments dovetail with other irate Abby customers online.
This customer wrote Abby twice and has waited 48 hours

now regarding his inquiry as to whether Rilla or
RillaVoice was used in his home, and also he has voiced
concerns about the premature requests for Certificates of
Completion, all of which goes to the core of what
Defendant Taylor Stepniewski stated online that litigant
King republished.
See the below email to Counsel incorporating same:
**********

Subject: Re: Abby Windows v. King et al. Rilla
Date: July 2, 2024 at 3:40:17 PM PDT
To: Timothy Andringa <[email protected]>,
[email protected]
Oh and he's not done yet:

To expand on my complaint and concerns I have seen the owner of the company on public video sites
discussing how rilla is used for quality control Since there was a pricing discrepancy in my case I would
like to hear the recording of the sales presentation at my home so that I can

Furthermore, I am voicing my concern that I was asked to sign a certificate of completion before the work
was done.
Coltyn VonDeylen
3
Let's see how your client volleys this ball. It's a sharp crosscourt BH for sure; with Abby's unsteady legal
footing she is certain to fail. She either provides the recording -- to which he is entitled -- or she commits
Perjury and says she doesn't have a recording when we all know Rilla just made her a Crown Princess of
the franchise 2 weeks ago right after my first Rule 908 Video so I'm sure Rilla will be ecstatic to know
that she doesn't have the recording or wasn't using it.
Abby has spun enough lies already but hey let's keep on going it's only going to get worse.
https://www.youtube.com/watch?v=FQEYliCxC4A
Warm regards,
617.543.8085m
**********
Anyone can clearly see Abby’s legal bind here: She was using Rilla and did not tell the
homeowner, now in order to provide him what he seeks she simultaneously commits another Rule 908
Admission because there’s an 18 USC §2511 violation *AND* an attendant Wis. Stat §968.31 violation.
Litigant King is entitled to address these matters with Witness Opper on the witness stand strictly because
the Abby litigants brought her into this.1
1
It is a fact that litigant King had no reason to call Witness Opper without Abby crying and trying to make a case
for Defamation based on said communications. Witness Opper must testify as to her initial impressions on receiving
the email and whether or not she perceived it as Defamatory or potentially alarming in terms of any Class H Felony
terms on the underlying case. Moreover, as to the pending Counterclaims she must provide information as to her
CURRENT perceptions given what she has seen since the lawsuit was filed. That’s how the Legal system works and
it is very straightforward.
4
Naturally, Litigant King put Counsel for Actual Notice that he intends to call Waukesha DA
Susan Opper as a Material Witness. The following analysis reveals exactly why Litigant King is acting in
the manner of any prudent and seasoned Attorney (Appendix C).
June 26, 2024 Email to Attorney Andringa with copy of email sent to DA Opper:
From: Christopher King

Subject: Re: Abby Windows v. King et al. Dispositive Motion/Case in Chief
Witnesses
Date: June 26, 2024 at 11:33:03 AM PDT
To: Timothy Andringa <[email protected]>, [email protected]
I'll be calling Attorney Opper if your client gets that far because you brought her into
this, ab initio.
The minute your client filed a Defamation case against Taylor Stepniewski and me
based on republishing her truthful statements and some sort of grand conspiracy
against Abby, she gave her the right to defend herself, and by golly that is exactly what
she and I are going to do.
26 June 2024
Re: Blatant ATCP Violations, a Bogus Defamation Case and Your Ethical
Responsibilities
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:
(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.
contract before the home improvement is completed in accordance with the terms of the
contract.
********
5
It is more than clear that homeowners are reporting these problems yet Opper and the rest
of the area Law Enforcement fail to take action and subject Wisconsin homeowners to all matter
of abuse for no lawful reason whatsoever. Two relevant images from King’s Declaration:
This Abby customer did further write Consumer Protection’s Patrick Studenec and the Abby
litigants after they did not respond to him on Monday, at close of business Tuesday with the
following:
6
Subject: Supplement to my complaint #31c2:06302024233137
Dear consumer protection staL and abby windows:
To expand on my complaint and concerns I have seen the owner of the company on public
video sites discussing how rilla is used for quality control Since there was a pricing
discrepancy in my case I would like to hear the recording of the sales presentation at my
home so that I can
b) help the owner find out how to hone any communication issues.
Furthermore, I am voicing my concern that I was asked to sign a certificate of completion

before the work was done.
Coltyn VonDeylen
The Consumer informed as of CoB last night, forty-eight (48) hours had passed fron his first
request with no response from the Abby litigants because they are indeed running a dirty
operation.2
Lastly, if the air between Witness Opper and litigant King could be any thicker, it all
became clear in this video celebrating the fact that the live customer complaint and the
Washington AG action obviously renders jurisdiction for Opper, Consumer Protection and
Waukesha PD to investigate instead of protecting the home-town gal with bags of money, ill-
gained as some of it is.
https://www.youtube.com/watch?v=wDnJxwjPQbA
2
Litigant King will suffer absolutely no criticism for illuminating the Truth about this company.
7
II. Law and Argument.
In addition to the prior citations litigant King adds this ABA article, “When must a judge recuse
over a personal relationship? ABA issues ethics guidance” by Dennis Rendleman, September 5,
2019.
https://www.abajournal.com/web/article/judges-personal-relationships-formal-opinion-488
In essence, Rule 2.11(C) concludes that despite a situation where a judge’s impartiality
might reasonably be questioned, the judge may preside with permission of the lawyers
and parties if the judge does not have a personal bias or prejudice or personal knowledge
of facts in proceeding.
Opinion 488 opines that a close personal relationship is covered by Rule 2.11(A)(2)
quoted above, requiring disqualification, while acquaintances do not. As for friendships?
That depends on the specific facts.
The specific facts here reveal a decades-long relationship between His Honor and
someone that litigant King is calling as a hostile witness. That says it all and it is definitive.
https://archive.jsonline.com/news/waukesha/brad-schimel-names-sussan-opper-as-acting-da-in-
waukesha-county-b99419149z1-287367911.html
8
Given the facts of this particular situation, Litigant King does not consent, nor should the
Court or Opposing Counsel because the sheer optics of this matter do not bode well for the
Record, and that is precisely the point that Litigant King made on his morning drive to see
SCOTUS-Licensed Attorney Scott Stafne, Esq., a man with whom King has shared mutual
respect for more than a decade.
To be clear: If King were a Judge and Stafne a witness King would immediately recuse
himself sua sponte, as should Judge Schimel in this case. Landya B. McCafferty did not in King
v. Ayotte 860 F. Supp. 2d 118 (D.N.H. 2012) and it remains a source of embarrassment and a
stain on the Bench when litigant King caught her and all of them engaged in conspiratorial bliss,
taking him for a fool and abusing the legal process to shut down independent media. While
Litigant King is aware of His Honor’s track record in preserving safety for unpopular opinions
that simply cannot outweigh the nature of his relationship with a Material Witness whose
integrity is being squarely challenged at the moment of her retirement:
https://www.scribd.com/document/741642775/Actual-Consumer-Complaint-Puts-Waukesha-
DA-Susan-Opper-on-ATCP-Duty-to-Investigate-Abby-Binder-and-Abby-Windows
1K views242 pages
Actual Consumer Complaint Puts Waukesha DA Susan Opper On ATCP Duty To
Investigate Abby Binder and Abby Windows
9
Just as Nixon rhetorically did with Checkers, KingCast joins his pup for a ride and
explains his successful recusal of Landya B. McCafferty and compares it to the present situation:
https://youtu.be/UFR0jbDy1x8
KingCast Explains His Politics and Recusal of Landya B. McCafferty and Brad D. Schimel.
10
CONCLUSION
There is really nothing more to say here. When homeowners and little people trying to
gain good housing get abused, the Undersigned has always been there for them, in this instance
Judge Schimel’s friend and Hostile Witness Susan Opper… is not. As such, the clear optics of
this situation dictate that he can no longer preside on this case.
11
Litigant King is a seasoned Journalist and Attorney. He does not walk into this battle
without substantial experience, law and particular facts in this case that are irrefutable. In this
instance, the logical presence of Attorney Opper as Material Hostile Witness, the lack of
transparency on Judge Maxwell’s recusal despite phone calls and filings, coupled with the
decades-long relationship between Judge Schimel and DA Opper all clearly militate in favor of
immediate Recusal.3
________________________
617.543.8085m
3
At this point it does not matter whether or not Attorney Opper actually testifies; the level of obvious friction and
controversy between litigant King and her, in addition to her role in this thanks to the Abby litigants, has led to the
obvious conclusion that Judge Schimel cannot hear this case going forward and no further rulings on anything shall
be had until this matter is completely resolved. Moreover, the file needs a notation as to the reason for Judge
Maxwell’s recusal as that rule is indeed codified. Litigant King is not looking for trouble here. He is looking for
logical help for homeowners and adherence to established principles of Law.
12
I the undersigned swear that a true copy of this Renewed Motion and Declaration was served to
[email protected]
[email protected]
via email

This 3rd day of July, 2024
_____________________________________________
13
APPENDIX A
WAUKESHA COUNTY
STATE OF WISCONSIN
Plaintiffs, )
v. ) CASE NO.2024-CV-000820

)
Defendants.
RENEWED RECUSAL DECLARATION OF LITIGANT CHRISTOPHER KING, J.D.
NOW COMES LITIGANT CHRISTOPHER KING, J.D. to solemnly aver to the

following as on Oath and Subject to the Pains and Penalties of Perjury:
1. Over the weekend of June 29-30 I had occasion to discuss an Abby Windows roof
installation with a current customer; and
2. Said current customer did inform me that Abby sales staff left the room while leaving an
electronic device behind; and
1
3. I have substantial reason by training and study to believe that Abby’s conduct using
Rilla/Rilla Voice software is in violation of 18 USC §2511 and Wis. Stat §968.31; and
4. Said current customer did inform me that Abby sales staff requested a Certificate of
Completion well before any punch list had been drafted and addressed (id); and
5. I have substantial reason to believe that such request violated ATCP as noted to Counsel
for the Abby Litigants and to DA Susan Opper:
The minute your client filed a Defamation case against Taylor Stepniewski and me based on
republishing her truthful statements and some sort of grand conspiracy against Abby, she gave
her the right to defend herself, and by golly that is exactly what she and I are going to do.
26 June 2024
it:

(e) Request the buyer to sign a completion slip or certificate, or make final payment on the
6. The Abby litigants and their Counsel are the ones who brought Susan Opper into this
case by way of para. 32 because these were “false and defamatory statements” as Sworn
Under Oath; and
2
7. Because the Abby litigants brought Attorney Opper into this matter I most certainly have
the right to call her as a Material Witness because to ask her if the underlying assertions
would point to valid legal concerns if reasonably believed true;
8. I believe it would be a blatant Substantive Due Process violation if I am not allowed to
call Attorney Opper as a witness and I have already informed Opposing Counsel of my
intentions as noted in the accompanying Motion Attachments.
Returning to the current Abby Customer then:
9. The aforesaid Abby customer did file a consumer complaint # #31c2ff06302024233137;
and
10. The aforesaid Abby customer did inquire of the Abby litigants if they had Rilla recorded
him; and
3
11. The aforesaid Abby customer did further write Consumer Protection’s Patrick Studenec and the
following:
the work was done.

Coltyn VonDeylen
4
APPENDIX C
June 14, 2024:
Good Day Counsel,
So you got away with violating the Administrative Rule, whatever.
Do you intend to call Attorney Opper as a witness at any point in this litigation?
Please advise by CoB Tuesday, 18 June 2024. The absence of a reply will constitute a Yes for briefing purposes.
Warm regards,
617.543.8085m
************
June 17, 2024
Mr. King,
First, who the Plaintiff intends to call as witnesses in this case is work product. Second, if the court
requires disclosure via a scheduling order of the Plaintiff’s witnesses, the Plaintiff will comply with the
court’s scheduling order. Third, setting aside 1 and 2 above, at this time I do not have any reason to call
Sue Opper as a witness on behalf of the Plaintiff but reserve the right to call her if for unknown reasons
her testimony were to be relevant and admissible. At this time I cannot fathom any reason Sue Opper’s
testimony would be relevant or admissible.
Finally, discontinue giving demands in your emails that ‘absence’ of a reply to a fake deadline constitutes
a yes or no response. You should infer nothing from my decision not to response to your emails. I will
timely respond to all pleadings filed in this case as required by court order or statute.
Respectfully,
Tim.
Timothy J. Andringa
Managing Partner
*********
June 17, 2024
Attorney Andringa:
Yes of course it is work product AT THIS TIME. However, as a matter of courtesy it is relevant to my pending Motion
to Recuse for obvious reasons, so no it is not unreasonable for me to ask you, just as it was neither unreasonable nor
unlawful for me to ask your client a direct question and yet you responded in a most uncivil tone.
The 'deadline' you speak of was simply so that I could get a feel for what I need to do in the Motion for Recusal, and
again given that your client directly mentioned my discourse with Attorney Opper as Defamatory it is hardly
unreasonable to believe you may call her as a witness, and given her decades-long relationship with the current
Judge and the lack of any reason for Recusal given by the outgoing Jurist in violation of Rule provides reasonable
justifications for my position.
I look forward to you and your client's next sworn statement that Abby does not instruct staff to Rilla record when they
are not in the room.
Warm regards,
617.543.8085m
*************
June 26, 2024 Email to Attorney Andringa with copy of email sent to DA Opper:

Subject: Re: Abby Windows v. King et al. Dispositive Motion/Case in Chief Witnesses
To: Timothy Andringa <[email protected]>, [email protected]
Cc: Amy Charpentier <[email protected]>, Taylor Stepniewski <[email protected]>, Riley Rich
<[email protected]>, Riley Richarz <[email protected]>, Mikki Campbell <[email protected]>,
[email protected], [email protected]
I'll be calling Attorney Opper if your client gets that far because you brought her into this, ab initio.
The minute your client filed a Defamation case against Taylor Stepniewski and me based on republishing her
truthful statements and some sort of grand conspiracy against Abby, she gave her the right to defend
herself, and by golly that is exactly what she and I are going to do.
26 June 2024
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:

(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.”
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. (All matters in red = emphasis added for clarity).
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.
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
APPENDIX D
Case 2:22-cv-01835 Document 1 Filed 12/29/22 Page 1 of 48
8 UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF WASHINGTON
9 AT SEATTLE
10 STATE OF WASHINGTON, NO.
11 Plaintiff, COMPLAINT FOR DECLARATORY,

INJUNCTIVE, AND OTHER RELIEF
12 v.
13 ALDERWOOD SURGICAL CENTER,

LLC, a Washington limited liability
14 company; NORTHWEST NASAL SINUS
CENTER P.S., a Washington professional
15 service corporation; and JAVAD A. SAJAN,
M.D.,
16
Defendants.
17
18 Plaintiff State of Washington, by and through its attorneys Robert W. Ferguson,
19 Attorney General, and Matt Geyman, Camille McDorman, and Zorba Leslie, Assistant Attorneys
20 General, brings this action against Defendant Alderwood Surgical Center, LLC, d/b/a Allure
21 Esthetic, d/b/a Gallery of Cosmetic Surgery, d/b/a Seattle Plastic Surgery, and Defendant
22 Northwest Nasal Sinus Center P.S., d/b/a Northwest Face & Body (collectively, “Allure
23 Esthetic”), and their owner, Defendant Javad A. Sajan, M.D. The State alleges that Defendants
24 have engaged, and continue to engage, in a pattern of unlawful, unfair, and deceptive acts or
25 practices in violation of the Consumer Review Fairness Act, 15 U.S.C. § 45b (CRFA), the Health
26 Insurance Portability and Accountability Act, 42 U.S.C. § 1320d-5(d) and
COMPLAINT FOR DECLARATORY, ATTORNEY GENERAL OF WASHINGTON

Consumer Protection Division
INJUNCTIVE, AND OTHER RELIEF - 1 800 Fifth Avenue, Suite 2000
Seattle, WA 98104-3188
(206) 464-7744
1 45 C.F.R. § 164.508(b)(4) (HIPAA), and the Washington Consumer Protection Act,
2 Wash. Rev. Code § 19.86 (CPA). The State alleges the following on information and belief:
3 I. INTRODUCTION
4 1. With the ever-increasing reliance on online marketing, ensuring that online reviews
5 are truthful and that consumers can freely share accurate information about businesses is essential
6 to protecting Washington consumers and maintaining fair business competition.
7 2. This is even more crucial in certain industries, such as the plastic and cosmetic
8 surgery business, where online reviews are often a consumer’s primary or only source of third-party
9 information about a healthcare provider before trusting that provider with sensitive, and in some
10 cases life-altering, procedures.
11 3. State and federal consumer protection laws prohibit businesses from unfairly or
12 deceptively manipulating consumer reviews. For instance, Congress, recognizing a need for further
13 protections in this increasingly important area, passed the Consumer Review Fairness Act,
14 15 U.S.C. § 45b, which prohibits the use of “gag clauses” in form contracts that prevent, restrict,
15 or suppress truthful consumer reviews.
16 4. Allure Esthetic is a large, highly profitable Seattle-area plastic and cosmetic surgery
17 business with offices in Lynnwood, Kirkland, and Seattle. Allure Esthetic does business under
18 several names, including Allure Esthetic, Alderwood Surgical Center, Gallery of Cosmetic
19 Surgery, Seattle Plastic Surgery, Northwest Nasal Sinus Center, and Northwest Face & Body.
20 5. Allure Esthetic is owned and controlled by Defendant Javad A. Sajan, M.D., a
21 plastic surgeon who advertises online, including on Instagram, Facebook, YouTube, Snapchat,
22 and other social media, as @realdrseattle or “Real Dr. Seattle.”
23 6. Defendants systematically suppressed negative patient reviews by requiring their
24 patients, before they received services (and in some cases before even having a consultation), to
25 sign a form nondisclosure agreement (the pre-service NDA) that purported to restrict the patient’s
26 right to post truthful information about their experience with Defendants’ services.

(206) 464-7744
1 7. Specifically, from August 15, 2017 to March 24, 2022, Defendants used a pre-
2 service form NDA to restrict patients from posting negative online reviews of Defendants’ plastic
3 and cosmetic surgery services in violation of the CRFA, 15 U.S.C. § 45b, and the CPA,
4 Wash. Rev. Code § 19.86. Defendants required over 10,000 patients to sign these illegal NDAs
5 over that period.
6 8. A version of the pre-service NDA Defendants used from August 15, 2017 to
7 January 11, 2019 also required Defendants’ patients to agree that if they left a negative review
8 in violation of the agreement, Defendants could unilaterally reveal their personal health
9 information (“PHI”) when responding to the review, in violation of HIPAA,
10 45 C.F.R. § 164.508(b)(4).
11 9. When patients posted negative reviews despite the pre-service NDA, Defendants
12 contacted them and used the pre-service NDA—and the threat, or implied threat, of taking legal
13 action to enforce it—to coerce them into taking down the negative reviews.
14 10. Beginning in September 2017, Defendants also used a second, post-service NDA
15 that prohibited patients from posting negative reviews after they received services. When a
16 patient posted a negative review despite the pre-service NDA, Defendants offered the patient
17 cash, free services, and/or free products “to make things right.”
18 11. After a patient accepted Defendants’ offer of cash or other inducement “to make
19 things right,” Defendants then required the patient to sign the post-service NDA to receive the
20 inducement payment—an additional condition not previously disclosed.
21 12. This post-service NDA illegally forced consumers to remove their reviews and
22 purported to prohibit them in perpetuity from posting reviews of any kind or ever discussing
23 Defendants’ business with anyone. Defendants required hundreds of patients to sign these illegal
24 post-service NDAs.
25 13. Defendants’ illegal NDAs restricted their patients from sharing truthful
26 information about Defendants’ services with the public and prevented other Washington

(206) 464-7744
WAUKESHA COUNTY
STATE OF WISCONSIN
Plaintiffs, )
v. ) CASE NO.2024-CV-000820

)
Defendants.
LITIGANT KING §902.01 REQUEST FOR JUDICIAL NOTICE OF WASHINGTON V.

ALDERWOOD SURGICAL 22-CV-01835-RSM (APRIL 12, 2024)1

note that the Abby litigants would be subject to severe penalties in any forward-thinking County
or State because they are clearly involved in illicit conduct, to wit: Washington v. Alderwood
Surgical 22-CV-01835-RSM (April 12, 2024)(Prior to Litigant King’s production of any media).
plastic-surgery-clinic-bribing
AG Ferguson files lawsuit against Seattle-based plastic surgery clinic for
bribing, threatening patients to falsely inflate its online ratings
FOR IMMEDIATE RELEASE:
Dec 29 2022
1
This filing further informs Litigants King and Campbell’s outrage at the resolute failure of DA Susan Opper and
other Wisconsin LE to investigate anything at any point in time. In fact Waukesha PD even refused to take physical
evidence because in the (in)finite wisdom there was nothing to see here. Ridiculous. And shameful. Wisconsin
residents deserve better than this. See generally https://www.youtube.com/watch?v=brZb6yyPHM8&t
“Waukesha PD Pushback on Journalist to Protect Abby Windows and Exteriors and Imperil Consumers”
KingCast, May 22, 2024.
1
The company intimidated consumers into removing negative reviews, ordered employees to post
fake 5-star reviews
OLYMPIA — Attorney General Bob Ferguson today filed a federal lawsuit against Allure Esthetic, a
major plastic surgery provider in Seattle, and its owner, Dr. Javad Sajan, for falsely and illegally
inflating its ratings on online rating platforms such as Yelp and Google. The company intimidated
patients into removing negative reviews, and ordered its employees to post fake positive reviews.
Ferguson’s lawsuit asserts Allure and its owner broke the law in numerous ways, including by:
• Requiring paLents to sign unlawful non-disclosure agreements, before receiving any

treatment, that restrict them from posLng truthful reviews about their experiences with
Allure. Over 10,000 people signed these NDAs.
• Threatening to take legal acLon against paLents, telling some paLents it would sue them for
monetary damages if they refused to delete their negaLve reviews.
• Offering paLents cash and free services or products for taking down their negaLve reviews.
• Requiring paLents who accepted these bribes to sign a second non-disclosure agreement
staLng they could face a $250,000 lawsuit if they conLnue to post negaLve reviews.
• EdiLng “before and aVer” photos to make the results of its procedures look beXer than they
actually were.
• Applying for rebates on behalf of its paLents without their consent and keeping those
rebates. Allure used hundreds of fake email accounts to register for rebate programs
intended for real paLents. Allure received thousands of dollars every month from these
rebates — rebates that should have gone to paLents.
Ferguson filed the lawsuit in the U.S. District Court for the Western District of Washington.
“Threatening and bribing customers to prevent them from sharing the truth about their experience
isn’t just wrong — it’s illegal,” Ferguson said. “Patients rely on reviews to determine if a healthcare
provider is right for them, and using legal threats and bribes to manipulate those reviews is
deceptive and harms Washingtonians. We are taking action to stop these unethical and illegal
practices."
A copy of the lawsuit and the Consent Decree are affixed at Appendix A; the relevance
here need to be repeated in light of the multiple notifications of willfully-falsified reviews and
unlawful strikes against known honest reviews, recall most glaringly Abby’s threat of Extortion
against Amy O’Donnell:
2
This is again what Reporter Jason Brown told King would result in Abby losing her BBB
Accreditation and more; he wrote local press WISN who never contacted King. Whatever the
case we are all here now and the clearly relevant modern persuasive law on an identical subject
matter militates in favor of Partial Summary Judgment for King or any Counter Plaintiff who
spoke on similar issues: The theory of the Counterclaim is that Abby litigants are stifiling
consumers and press in order to keep these horrid facts from light, and their stooge media friends
are all involved. There no other reason a case like this or the stories about Abby never get
published and Litigant King is not afraid to call a spade a spade on this. Today’s story just drives
it home like a giant Nordic Thunderbolt of Truth.
******
3
CONCLUSION
In its short history this case has already seen a) Claims filed in blatant violation of Wis.
Stat §895.05, b) a patently fraudulent process server who celebrates in “skipping court again”
and “running a ponzi scheme” and now, c) the obvious fact that fake reviews violated Consumer
Protection Law in any and every State in this Country, as Litigant King has stated all along.
Therefore the reputation of any dirtbag who engages in this type of conduct can never
demonstrably show any harm to its purported reputation in the community, ipso facto because
once the public knows these proclivities, there is no reputation.2
Pickering, again:
______________________
2
And the underlying case is indeed, frivolous as further briefings will demonstrate.
4
[email protected]
[email protected]
via email

This 3rd Day of July, 2024
_____________________________________________
5
WAUKESHA COUNTY
STATE OF WISCONSIN
Plaintiffs, )
v. ) CASE NO.2024-CV-000820

)
Defendants.
RENEWED RECUSAL DECLARATION OF LITIGANT CHRISTOPHER KING, J.D.
NOW COMES LITIGANT CHRISTOPHER KING, J.D. to solemnly aver to the

following as on Oath and Subject to the Pains and Penalties of Perjury:
1. Over the weekend of June 29-30 I had occasion to discuss an Abby Windows roof
installation with a current customer; and
2. Said current customer did inform me that Abby sales staff left the room while leaving an
electronic device behind; and
1
3. I have substantial reason by training and study to believe that Abby’s conduct using
Rilla/Rilla Voice software is in violation of 18 USC §2511 and Wis. Stat §968.31; and
4. Said current customer did inform me that Abby sales staff requested a Certificate of
Completion well before any punch list had been drafted and addressed (id); and
5. I have substantial reason to believe that such request violated ATCP as noted to Counsel
for the Abby Litigants and to DA Susan Opper:
The minute your client filed a Defamation case against Taylor Stepniewski and me based on
republishing her truthful statements and some sort of grand conspiracy against Abby, she gave
her the right to defend herself, and by golly that is exactly what she and I are going to do.
26 June 2024
it:

(e) Request the buyer to sign a completion slip or certificate, or make final payment on the
6. The Abby litigants and their Counsel are the ones who brought Susan Opper into this
case by way of para. 32 because these were “false and defamatory statements” as Sworn
Under Oath; and
2
7. Because the Abby litigants brought Attorney Opper into this matter I most certainly have
the right to call her as a Material Witness because to ask her if the underlying assertions
would point to valid legal concerns if reasonably believed true;
8. I believe it would be a blatant Substantive Due Process violation if I am not allowed to
call Attorney Opper as a witness and I have already informed Opposing Counsel of my
intentions as noted in the accompanying Motion Attachments.
Returning to the current Abby Customer then:
9. The aforesaid Abby customer did file a consumer complaint # #31c2ff06302024233137;
and
10. The aforesaid Abby customer did inquire of the Abby litigants if they had Rilla recorded
him; and
3
11. The aforesaid Abby customer did further write Consumer Protection’s Patrick Studenec and the
following:
the work was done.

Coltyn VonDeylen
4
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.
I. Relevant Background.
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
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
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:
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: [email protected]
Cc: [email protected]
Erica,
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.org4
4
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.
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.
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.
d. Public Participation Emails to State Staff:
Defendant King wrote:
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.
https://www.youtube.com/watch?v=9_E-48JGPjo&t
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 <[email protected]>
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.
https://www.youtube.com/watch?v=9_E-48JGPjo&t
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.
___________________________
31
I the undersigned swear that a true copy of this Motion and Declaration was served to
[email protected]
[email protected]
via email

This 11th Day of June, 2024
_____________________________________________
32
WAUKESHA COUNTY
STATE OF WISCONSIN
Plaintiffs, )
v. ) CASE NO.2024-CV-000820
) JUDGE__________________
)
Defendants.
____________________________________________________________________________
[PROPOSED] ORDER DENYING

PRO HAC VICE APPLICATION OF STEVEN COUCH
______________________________________________________________________________
THIS MATTER COMES BEFORE THE COURT pursuant to Defendant King’s

Objection to Application of Attorney Steven Couch for Pro Hac Vice for the above-captioned
matter. Good Cause having been shown, the Application is hereby DENIED.
IT IS SO ORDERED this ___ Day of _________, 2024.
__________________________
JUDGE
WAUKESHA COUNTY
STATE OF WISCONSIN
Plaintiffs, )
v. ) CASE NO.2024-CV-000820
) JUDGE__________________
)
Defendants.
OBJECTION TO PRO HAC VICE ADMISSION OF STEVEN COUCH
NOW COMES DEFENDANT CHRISTOPHER KING, J.D. to object to the request for
pro hac vice admission as the Applicant has already failed to conduct himself in an appropriate
manner in this Court, to wit:
He never served Notice on Defendant King or anyone else of his request. The Motion
was filed on May 31, 2024 and today is June 6, 2024 an entire week later and the only reason
Defendant King is aware is because he signed up for CCAP. From an email sent today:
I just registered with CCAP. They went to Detroit for backup... the same Attorney
repping them on various other cases.
He says he is a problem solver. I am too. I am going to solve the problem of Abby Binder
abusing staff and employees and engaging in unethical business practices.
Funny how time and time again I allegedly don't know what I'm talking about then they
go and grab a top-shelf Attorney to try to shut me down.
I'm just like Mikki and many others: I'm not having it.
Warm regards,
617.543.8085m
1
Also since I distinctly agreed to electronic service it would have been professional
Courtesy to send me a copy of the Motion, email or snail mail.
I ran a search in my inbox and did not have a copy of it although it was filed on May 31,
2024, an entire week ago. I did not receive a paper copy either.
Warm regards,
617.543.8085m
The rules governing Pro Hac Vice in Wisconsin are not expressly clear, whereas Kansas
for example concretely state that Notice must be provided to Parties. In this instance however in-
State Counsel Timothy Andinga was on Actual Notice of the fact that the undersigned had not
been granted CCAP access the whole time that Attorney Couch’s Motion was pending, yet
neither of these men deemed it appropriate to say a word about it.
Subject: Anatomy of a Lawsuit Part Twelve: QBIQ Corp. v. Echarte (Florida
Contractor Defamation case)
Date: May 28, 2024 at 4:09:43 PM PDT
“……I told Opposing Counsel today that I have to wait for CCAP to send a confirmation
code IN THE SNAIL MAIL before I can e-file my Motion to Dismiss.
Welcome to the 21st Century in communications.

Subject: Anatomy of a Lawsuit Part 23: Consumer Protection Denial, Updates on
NARI, Channels 4 and 6; KingCast Classroom Series
Prologue: I see my access code for CCAP filing is coming in the mail today,
yippee!!!! I'll be filing a rather interesting Motion on Monday designed to cut right to the
chase as Abby's lawyer refused to respond to my direct question if Abby maintains that
this ex-staffer and Riley Richarz are lying about Abby and Mandy asking for Riley's
sperm:
Obviously any pending Motions should be provided to every Defendant, particularly any
Defendant who has stood up and accepted Service of Process via email as soon as the case was
filed, as did Defendant King. The failure to do so demonstrates a marked indifference to respect
for the law, also nothing new for Defendants as the Court will soon seen in a Motion to Dismiss
and for Sanctions:
2
2. They filed complaining about written purported Defamation without seeking retraction, a
violation of Statute. Wis. Stat §895.05(2).
4. They left off the entire email chain not once but twice in their Verified Complaint, a violation
of Statute. Wis. Stat §895.05(2).
a) On one occasion this was done with the intent to mislead the Court as to the opportunity that I
truly gave Abby to respond to my inquiries. There were several 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 me 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].
b) The second time I accused them of tampering with my online privacy; spamming and missing
folders. I got like 80 emails involving identity theft and traderonline car sales. It is still not clear
that no one from Abby did this, but more importantly I wrote back that day in the same
email without a request for retraction where I qualified the statement by stating that I 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.
The disrespect does not stop there. Defendant King sent clear succinct simply emails to
Counsel last week seeking clarification on a matter when he realized the underlying Complaint
was indeed Verified. King wrote:
On Jun 3, 2024, at 9:04 PM, Christopher King wrote:
Good Evening Counselor,
Does your client maintain the position that Riley's sperm was never discussed?
Please advise.
Good Evening to All,
I correct any potential errors in my statements. As I did before when I clarified my position on
the cyber attack foisted on me last month... only to have Abby's Counsel leave it out in the
Verified Complaint.
Yes indeed it is a Verified Complaint, and that my friends is going to be interesting because we
all know that MetaData cannot be destroyed. This what I'm working with:
3
And I’ve witnessed her talk about Riley and his sperm. Multiple times. Lying sack of shit.
Unfortunately for her, I also have all of my texts on my old phone that I miraculously forgot to
send back into Att in time when I upgraded. Somehow they didn’t all transfer to my new phone,
but good thing I still have it.
!
All the group texts, personal texts, production texts. Let’s go baybeeeee
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 for someone who threatens innocent homeowners with Extortion charges, Perjury is just the
cost of doing business apparently.
The whole lawsuit is garbage, just like the company.
Warm regards,
617.543.8085m
**********
From: Christopher King

Subject: Re: Abby v. King et al. - Perjury 2024-CV-000820
To: Timothy Andringa <[email protected]>
Cc: Christopher King <[email protected]>
Good Day Counselor,
Your and your client have had a full day to digest the question below. Was it clear enough? Did I
stammer?
At close of business today your continued nonresponse will be reasonably converted into
maintenance of the stated position in the Verified Complaint, which is basically that everyone is
ganging up to lie about Abby Binder.
Warm regards,
617.543.8085m
https://www.arlingtoncompliance.com/
4
************
In sum, the appearance of this Counsel is already off to a rough start. In fact it is rough
enough to warrant denial because both of these Counsel are attempting to run roughshod over the
Rights of all Defendants to object. With respect to Defendant King the violated the Rule of
Completeness and the Fair Warning on written Defamation prior to suit, which is Jurisdictional
and cannot be revived.
(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. (emphasis added). 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. The notice may
also state the sources, if any, from which the true facts may be ascertained with
definiteness and certainty.
From Schultz v. Sykes, 638 NW 2d 604 - Wis: Court of Appeals 2001: 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.
CONCLUSION
Counsel for Plaintiffs have turned what could have been a mere formality into something
much larger than that, and much like their client they would clearly rather try to skirt their legal
obligations and responsibilities than face the terribly discordant music that their client has
orchestrated in this case and for the past several years of her life as many of her long-term
friends have specifically stated to the Undersigned litigant. I look forward to sharing that with
the Court when it comes down to reputation in the Community should this case proceed that far.
The Application must be denied out of hand.
_____________________
617.543.8085m
Defendant pro se
5
I the undersigned swear that a true copy of this Objection was served to
[email protected]
[email protected]
via email
This 7th Day of June, 2024
_____________________________________________
6
Open Online Chat with Prior Customer – Abby’s Real Reputation in the Community???
She thinks she is a celebrity and above everyone. These past 3 years have changed her and
created a selfish person.”
[Not the only person to share this sentiment with KingCast]
“She would much rather pay her lawyer $500 an hour instead of taking a $100 loss. When I
left, she had 6 customers that she was paying her lawyer to deal with instead of just making
things right.”
“So instead of making a bad review into a happy ending and closing out the job, the review
is still out there, and she is paying who knows how much to try to have her lawyer strong
arm her.”
“She accused me of theft… she has cameras on every inch of the building and has no
proof…. Held a meeting and told employees no one is allowed to speak to me.”
[Just as Riley Richarz noted in his zoom chat remember]
“Most hateful and disrespectful thing that ever happened to me… trust me the list of upset
employees is endless. Taylor and I were the longest employees by far there. We almost
made it 2 years. LOL, most will not make it past 1 month.”
Funny how Wisconsin has gone after fake reviews before but sitting there stuck on stupid now.
So I primed the pump for them with a fresh complaint to Consumer Protection:
General Consumer Complaint
Complaint PIN: 83ffc905312024102038
The company, under order of Abby Binder, holds compensated drives to knowingly manufacture
fake online reviews, refuses to discuss pending customer complaints unless negative reviews are
removed and does further threaten Extortion criminal complaints against homeowners who refuse
to remove negative reviews.
This and other unsavory (read: unethical) practices have been alleged and/or documented by many
former staCers in this video:
https://www.youtube.com/watch?v=9_E-48JGPjo
Abby Windows Owners Seek Sperm, Eavesdrop on Customers and Abuse StaC_2: The Coalmine
Mix.
.....five (5) of whom have been sued by Abby for Defamation, along with me as a journalist. I might
add that I have sued for Defamation successfully, helped someone else sue for Defamation
successfully and have never been found to have been in violation of any journalistic principles my
entire life at 59 this year.
1
Pat Studenec is in actual receipt of many many fake reviews and the corresponding company
profiles of the oCenders and has been for weeks now.
This conduct not only violates Federal Trade Commission Act—Section 5 it violates Wisconsin's
Deceptive Trade Practices Act (DTPA) Wis. Stat. §100.18:
100.18 Fraudulent representations
Pat Studenec is on Actual Notice of these violations yet to my knowledge none of the five (5) former
staCers who have interviewed with me have been contacted by anyone to initiate an investigation
even though Wisconsin took the lead on fake reviews just a few short years ago as noted in this four
(4) minute news broadcast:
https://www.tmj4.com/news/i-team/fake-online-reviews-may-be-fooling-wisconsin-consumers
Fake online reviews may be fooling Wisconsin consumers
Moreover, I have reason to believe that the company is price gouging and that it surreptitiously
records homeowners against the will of the staCers so there's no consent there on either party
involved plus the staCers are potentially subject to criminal Class H Felony because they are
ordered to leave the recording device in situ while they go outside to allow the customer to
deliberate amongst themselves about their most private financial and life-planning details. Except
they are not amongst themselves, hence the problem.
I have concrete proof that this is being done yet no one has reached out to me about any of this.
Well let me be clear no one from Wisconsin has reached out to me about any of this.
Please advise.
617.543.8085m
What happened when you contacted the business?
Nothing happened when I called the company and wrote them several times, nobody reached back
except to sue. Even when they sued they violated the law on the allegations regarding written
materials because they failed to provide a retraction request and that is statutory Wis. Stat §895.05.
Anyway, Evelyn put the call in to April Broughton, who on information and belief is the wife of one of
the fake reviewers in the first place.
How do you feel this complaint should be resolved?
Abby needs to be sanctioned for knowingly violating FTC, Google and other principles of law
including Wis. Stat §100.18 and be under Consent Order and monitoring. Further, a public apology
must ensue and there should be a further audit of all sales for price gouging and the use of illegal
recording practices.
2
Yeah so as I said we clearly see Plaintiffs are abusive people and we clearly see that despite at
least a couple reach-outs from me, they never once said "Boo" except to file their specious
lawsuit as I sat back in disbelief at the vile attitudes and bogus Criminal Threats the company
put out to innocent homeowners such as the Extortion threat seen here:
So now here comes the question: Why didn't Plaintiff offer me -- or anyone else for that
matter -- opportunity to cure the alleged Defects pursuant to Wis. Stat §895.05?
Because either they don't know the law or in the alternative because they are scum, that's why.

(1) The proprietor, publisher, editor, writer or reporter upon any newspaper published in this state
shall not be liable in any civil action for libel for the publication in such newspaper of a true and
fair report of any judicial, legislative or other public official proceeding authorized by law or of
any public statement, speech, argument or debate in the course of such proceeding. This
section shall not be construed to exempt any such proprietor, publisher, editor, writer or
reporter from liability for any libelous matter contained in any headline or headings to any such
report, or to libelous remarks or comments added or interpolated in any such report or made
and published concerning the same, which remarks or comments were not uttered by the
person libeled or spoken concerning the person libeled in the course of such proceeding by
some other person.
(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. The notice may also state the sources, if any, from which the
true facts may be ascertained with definiteness and certainty. The first issue published after the
expiration of one week from the receipt of such notice shall be within a reasonable time for
correction. To the extent that the true facts are, with reasonable diligence, ascertainable with
definiteness and certainty, only a retraction shall constitute a correction; otherwise the
publication of the libeled person's statement of the true facts, or so much thereof as shall not
be libelous of another, scurrilous, or otherwise improper for publication, published as the
libeled person's statement, shall constitute a correction within the meaning of this section. A
correction, timely published, without comment, in a position and type as prominent as the
alleged libel, shall constitute a defense against the recovery of any damages except actual
damages, as well as being competent and material in mitigation of actual damages to the
extent the correction published does so mitigate them.
So yeah you're goddamn right I'm filing for sanctions. You guys "play hard and play dirty." I play
hard too, just lawfully, something Abby knows little about in the opinion of many staffers and this
Journalist. Also I'll look forward to the timely production of the full audio from the police call as
noted in my pending Public Records Request pursuant to Wis. Stat §19.31.
And remember, I've got Plaintiffs hemmed up nicely on the valid Journo issue having twice been
recognized by State Tribunals here and elsewhere as noted.
WHEREFORE: Plaintiff and all Counsel are on Actual Notice that I will be filing for Rule 11 Sanctions
on all allegations concerning any written materials with the argument for extension to video in the
modern era when I file my Motion to Dismiss, subject to occur at any point in time thereafter. See
generally 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. I knew it intrinsically just couldn't find the right Statute until today.
So there you go.
Warm regards,
Is that right?
And we take them at their word when we see below
how all of their employees write the Google Reviews
and how Abby threatens a homeowner with an Extortion Complaint.
1
On Jul 24, 2023, at 1:35 PM, Amy O'Donnell <[email protected]> wrote:
So, to be clear you’re refusing to speak with me about a resolution unless a social
media post is removed?
********
On Mon, Jul 24, 2023 at 1:46 PM Abby Binder <[email protected]> wrote:
Yes that is correct. I will have a conversation when you’re prepared to be professional
and respectful about it offline. I’m confident we can come to an agreement that works
for us both.
Abby Binder
President and CEO
Abby Windows & Exteriors
********
From: Abby Binder <[email protected]>

Date: Mon, Jul 24, 2023 at 4:04 PM
Subject: Re: Your job
To: Amy O'Donnell
CC: Lauren Triebenbach <[email protected]>
I will be contacting the police regarding extortion.

Do not contact me again.
You can speak to my lawyer from here on out:

Lauren Triebenbach
[email protected]
I tried to have a discussion and you were not willing to so please have your attorney
contact mine.
Sincerely,
Abby Binder
President and CEO
Abby Windows & Exteriors
2
No Juror, No Judge, nobody but a complete idiot believes that Abby would pass on an
opportunity to lay waste to this employee had he actually stated anything like it.
This, along with the blatantly false reviews below is EXACTLY why I said
Plaintiff’s would not know the Truth if it smacked them in the face and I stand by
it right now and I will tell it straight to that Box of 12 should we ever get there.
So no, I am not afraid of any of these people. They are liars.
And wait for the sperm samples. They lit this bomb now watch it all implode.
3
Abby Windows had 4 Solid Days to Reach Out
After my Initial Video to the Second
I remember I wrote April Broughton, whose hubby appears to be one of those faithful
Abby Reviewers....who include the rest of Abby Staff. So where exactly is their
credibility you ask? A Jury will ask the same question if they ever get there.
4
5
6
7
8
9
10
11
12
13
On May 1, 2024, at 11:25 AM, Christopher King <[email protected]> wrote:
Good Day April,
Evelyn just referred me to you and I also just left a message at x700 for you as well. I
am looking to confirm some allegations I've reported and to obtain a response from you
because that is what responsible Journalists do:
We got both sides of a story.
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.
617.543.8085m
PS: I've always followed related matters as I have a Communications background, note
the 1990 story from the Indianapolis Star at bottom.
<Abby Windows Lawyer Text.jpeg>
***************
On May 4, 2024, at 12:45 PM, Christopher King <[email protected]> wrote:
Good Day Ms. Broughton,
I write to follow up to my inquiries regarding False and Deceptive Trade Practices, false
reviews, threats of retaliation and various other concerns as they have been presented
to me.
14
You have had three (3) days to respond to my phone call and two (2) emails yet I have
not heard a peep from you.
Wherefore, if I do not hear from you or your Attorney by Close of Business Monday,
May 6, 2024 I will assume Abby Windows declines to comment. You seem to be in
regular contact with Counsel so I'm sure they are reviewing this matter.
Also, from what I hear your Attorneys are quick to ejaculate Cease and Desist
Demands. I may or may not have proof of this. Whatever the case you will do well not to
attempt that route with me.
Best regards,
617.543.8085m
Also is this your husband leaving the 5-Star review here?
AbbyWindows
617.543.8085m
<Screenshot 2024-05-01 at 11.46.24 AM.png>

<Screenshot 2024-05-01 at 11.47.04 AM.png>
****************
Oh, also I have a report from an online "review" that Trevor, Blake, Adam and Jared
Itzel all staffers.
Further, that Ms. Laubenstein is a sales rep's wife.
15
I also have direct information that you manipulated homeowners into signing PO's at the
home point of sale during COVID knowing that materials would never arrive on time.
Further, that Abby Windows would then also use that signature to
Also that you back charge your sales reps for mistakes made by the measure tech; and
you back charge at retail rate. I'll be doing a zoom call tomorrow with Mikki Campbell,
you know her well right?
Thirty (30)+ years in the industry and she just told me flat out Abby would hide from
upset customers, do all the things noted above (including surreptitious recordings with
Rilla) and is "A snake in the grass."
I'll shoot you an invite for opportunity to join the zoom. Hell, bring your lawyers if you like
I don't care because them boys are not going to bully nor outlawyer me on this. Play
hard play dirty huh, and they want to go and threaten staffers behind some crap like this
are you kidding me? I fully intend to expose each and every unsavory aspect of this
company and this industry and the chip will fall as they may.
Mr. Studenac, I was a regulatory/AAG and have extensive experience as Journalist and
employment Attorney. To my eye your department has Jurisdiction. I will next call you
on Monday.
AbbyWindows
<433754593_949468896641086_4579804693852860712_n.jpg>
<hqdefault.jpg>
<Screenshot 2024-05-04 at 1.48.18 PM.png>


617.543.8085m
********************
Christopher King is inviting you to a scheduled Zoom meeting.
16
Topic: Allegations of Consumer Abuse, Elder Abuse, IRS Abuse, False Reviews,
Surreptitious Recording.
Time: May 5, 2024 02:00 AM Pacific Time (US and Canada)
Join Zoom Meeting

https://us06web.zoom.us/j/88536895232?pwd=Mp4PqL9rKTbVI2ETy5kDYaY66XXzJn.
1
Meeting ID: 885 3689 5232

Passcode: 289284
PS: Also is this SS-8 Violation on the Daniel R. Tarpey case a True and Accurate
Report as well?
<Tarpey IRS.png.pdf>
***************
To All,
Note that the zoom is of course at 2pm today; the same link should work but just to be
certain I have provided another one.
Christopher King is inviting you to a scheduled Zoom meeting.
Topic: Allegations of Consumer Abuse, Elder Abuse, IRS Abuse, False Reviews,
Surreptitious Recording.
Time: May 5, 2024 02:00 PM Pacific Time (US and Canada)
Join Zoom Meeting

https://us06web.zoom.us/j/86776024756?pwd=PuCzSSYGe6YXdBr9L9fhfpQ9pQgLrz.1
Meeting ID: 867 7602 4756

Passcode: 941316
PS: Do you have any comment on this update:
"Oh, not sure if anyone told you this story of Abby windows. But they fired a
woman, after having multiple “mini” strokes.
She had multiple strokes AT WORK, and when she came back to work, they
thought she “wasn’t keeping up” and they fired her."
17
Good Evening to All,
As promised I provide an opportunity for all to be heard because that is what

professional Journalists do. This way I can share your response in the same manner in
which I shared the allegations:
AbbyWindows
*************
That's all for now.
Oh but wait, there's more: Abby makes these employees retain the information from the
licensed software on their own devices that they required employees to pay for. That's a
neat trick. And did Abby ever issue any legal training to their staff regarding any
liabilities or responsibilities regarding Privacy concerns of these unsuspecting
customers? And why do all of their staffers have different contracts after the IRS called
them out on misclassification? How long is Riley Richarz’ contract… it’s basically an
indentured servitude thing from what I understand they basically loan him money it’s
sick if that’s true.
Am I right or wrong there?
Anyway nice how they paid Fred the disabled guy they made fun of after he wrote his
review:
18
Warm regards,
617.543.8085m
19
Case 2024CV000820 Document 7 Filed 05-16-2024 Page 1 of 27
FILED
05-16-2024
Clerk of Circuit Court
Waukesha County
2024CV000820
STATE OF WISCONSIN CIRCUIT COURT WAUKESHA COUNTY
ABBY WINDOWS, LLC

407 Pilot Court, Suite 400B
Waukesha, WI 53188
and
ABBY BINDER
525 N 94th Street
Milwaukee, WI 53226
Plaintiffs,
v. Case No.
Case Code: 30106
Case Classification: Intentional Tort
CHRISTOPHER KING
721 E. 5th Street, Suite B
Arlington, WA 98223
RILEY RICHARZ
5812 W. Plainfield Ave.
Milwaukee, WI 53220
TAYLOR STEPNIEWSKI
10190 W. Plum Tree Circle
Hales Corners, WI 53130
FRED MAYEN
W192S7863 Overlook Bay Road, Apt. E
Muskego, WI 53150
MICHAELE CAMPBELL
4333 S. Pine Ave.
Milwaukee, WI 53207
and
JASON CRISMOND
1741 Harrison Spring Rd. NW
Corydon, IN 47112
Defendants.
SUMMONS
THE STATE OF WISCONSIN to each person named above as a Defendant:
You are hereby notified that the Plaintiffs named above have filed a lawsuit or other
legal action against you. The Complaint, which is attached, states the nature and basis of the legal
action.
Within forty-five (45) days of receiving this Summons, you must respond with a
written answer, as that term is used in Wis. Stat. Ch. 802, to the Complaint. The Court may reject
or disregard an answer that does not follow the requirements of the Statutes. The answer must be
sent or delivered to the Court, whose address is 515 West Moreland Boulevard, Waukesha,
Wisconsin 53188 and to the attorneys, Cramer, Multhauf & Hammes, LLP, whose address is 1601
East Racine Avenue, P.O. Box 558, Waukesha, Wisconsin 53187. You may have an attorney
help or represent you.
If you do not provide a proper answer within forty-five (45) days, the Court may
grant judgment against you for the award of money or other legal action requested in the
Complaint, and you may lose your right to object to anything that is or may be incorrect in the
Complaint. A judgment may be enforced as provided by law. A judgment awarding money may
2
become a lien against any real estate you own now or in the future, and may also be enforced by
garnishment or seizure of property.
Dated: May 15, 2024 CRAMER MULTHAUF, LLC

Attorneys for Abby Windows LLC
Electronically signed by Timothy J. Andringa

Timothy Andringa
Wisconsin Bar No. 1001279
Contact Information:
1601 E Racine Ave #200
Waukesha, WI 53186
Phone: (262) 542-4278
E-mail: [email protected]
3
FILED
05-16-2024
Clerk of Circuit Court
Waukesha County
STATE OF WISCONSIN CIRCUIT COURT WAUKESHA COUNTY 2024CV000820
ABBY WINDOWS, LLC

407 Pilot Court, Suite 400B
Waukesha, WI 53188
and
ABBY BINDER
525 N 94th Street
Milwaukee, WI 53226
Plaintiffs,
v. Case No.
Case Code: 30106
CHRISTOPHER KING Case Classification: Intentional Tort with
721 E. 5th Street, Suite B Money Judgment
Arlington, WA 98223
RILEY RICHARZ
5812 W. Plainfield Ave.
Milwaukee, WI 53220
TAYLOR STEPNIEWSKI
10190 W. Plum Tree Circle
Hales Corners, WI 53130
FRED MAYEN
W192S7863 Overlook Bay Road, Apt. E
Muskego, WI 53150
MICHAELE CAMPBELL
4333 S. Pine Ave.
Milwaukee, WI 53207
and
JASON CRISMOND
1741 Harrison Spring Rd. NW
Corydon, IN 47112
Defendants.
VERIFIED COMPLAINT
The above-named Plaintiffs, Abby Windows LLC and Abby Binder, by Cramer Multhauf,
LLP, for their causes of action against the above-named Defendants, respectfully allege the
following:
PARTIES
1. The Plaintiff ABBY WINDOWS, LLC (“Abby Windows”), is a limited liability
company organized under the laws of Wisconsin and having a principal place of business in
Waukesha, Wisconsin within Waukesha County. At all times relevant, Abby Windows has been
authorized to conduct business and conducts substantial business in the State of Wisconsin.
2. Plaintiff ABBY BINDER (“Binder”) is the owner of Abby Windows. She resides
in Milwaukee, Wisconsin, and regularly conducts business in Waukesha, County of Waukesha,
State of Wisconsin.
3. Defendant CHRISTOPHER KING (“King”) is an individual residing, upon
information and belief, in Arlington, Snohomish County, State of Washington.
4. Defendant RILEY RICHARZ (“Richarz”) is an individual residing, upon
information and belief, in Milwaukee, Milwaukee County, State of Wisconsin. He was an
Account Associate with Abby Windows from on or about June 5, 2023 to on or about January 29,
2024.
5. Defendant TAYLOR STEPNIEWSKI (“Stepniewski”) is an individual residing,
upon information and belief, in Hales Corners, Milwaukee County, State of Wisconsin. She was
an employee of Abby Windows from June 7, 2021 until May 5, 2023.
6. Defendant FRED MAYEN (“Mayen”) is an individual residing, upon information
and belief, in Muskego, Waukesha County, State of Wisconsin. He was an Account Associate
with Abby Windows from on or about January 30, 2023 until on or about January 16, 2024.
2
7. Defendant MICHAELE CAMPBELL (“Campbell”) is an individual residing,
upon information and belief, in Milwaukee, Milwaukee County, State of Wisconsin. She was an
employee of Abby Windows from on or about September 13, 2021 until August 2022.
8. Defendant JASON CRISMOND (“Crismond”) is an individual residing, upon
information and belief, in Corydon, Indiana. He was an independent consultant of Abby
Windows from on or about December 8, 2023 until January 2024.
JURISDICTION AND VENUE
9. This Court has jurisdiction over the matters alleged herein pursuant to Wis. Stats.
§ 801.05.
10. Venue is proper in this Court because the causes of action alleged herein arose in
Waukesha County; most of the defendants either reside in or conduct substantial business in
Waukesha County; and where applicable, parties to contracts that are the subject of certain claims
alleged herein agreed that the venue for the resolution of disputes would be Waukesha County.
FACTS
11. Defendant King has posted videos to YouTube for over ten years as a self-described
independent journalist, sometimes using the name KingCast. Upon information and belief,
Defendant King had formed a limited liability company, King Cast LLC, in the State of Georgia
on or about February 24, 2021, but that limited liability company was administratively dissolved
on October 28, 2022. Upon information and belief, Defendant King previously worked as a
reporter for the Indianapolis Star. Upon information and belief, he was also an attorney in the
State of Ohio until 2005.
12. On or about April 30, 2024, Defendant King posted a video to YouTube entitled
“KingCast Fields Allegations of Widespread #ElderAbuse and Illegal Eavesdropping by Window
Companies.” In this video, Defendant King summarized allegations that he would share in later
3
videos about certain home improvement companies – including Plaintiff Abby Windows –
engaging in what Defendant King described as elder abuse and surreptitiously eavesdropping on
customers during sales visits. Defendant King later added a “Retraction/Correction” in the video
description, which stated, “I misspoke - the software is #Rilla and there is some dispute as whether
live monitoring is possible but they definitely eavesdrop and collect your meta.” (emphasis
added)
13. Rilla is a software tool used by companies, including Plaintiff Abby Windows, to
record customer interactions with the goal of providing a training tool for sales personnel skills
development. 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.
4
14. On or about May 1, 2024, Defendant King contacted Plaintiff Abby Windows for
the first time to seek comment on the allegations that were described the video he posted to
YouTube the previous day. Plaintiff Abby Windows opted not to provide a comment at that time.
15. On or about May 4, 2024, Defendant King contacted Plaintiff Abby Windows
again, this time taking a more aggressive tone:
I write to follow up to my inquiries regarding False and Deceptive Trade Practices,

false reviews, threats of retaliation and various other concerns as they have been
presented to me.
You have had three (3) days to respond to my phone call and two (2) emails yet I
have not heard a peep from you.
Wherefore, if I do not hear from you or your Attorney by Close of Business

Monday, May 6, 2024 I will assume Abby Windows declines to comment. You
seem to be in regular contact with Counsel so I'm sure they are reviewing this
matter.
Also, from what I hear your Attorneys are quick to ejaculate Cease and Desist
Demands. I may or may not have proof of this. Whatever the case you will do well
not to attempt that route with me.
Best regards,
16. Defendant King did not wait until the close of business on May 6, 2024 for Abby
Windows to respond. On May 5, 2024, Defendant King posted a second video to YouTube
entitled, “AbbyWindowsAndExteriors Staff Discuss Grounds for Homeowner Class Action, FTC,
Wage/Labor Complaints,” in which he spoke with a former employee of Abby Windows,
Defendant Campbell. Defendant Campbell made numerous salacious and false statements in the
course of this interview. Notably, without any regard for Plaintiff Binder’s privacy, Defendant
Campbell disclosed certain facts surrounding the end of Plaintiff Binder’s previous marriage that
have no legitimate public interest whatsoever. Upon information and belief, Defendant Campbell
5
made these statements, in particular, to further discredit Plaintiff Binder in the community.
17. 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.
18. Specifically, in the May 7, 2024 video, Mayen described the sales practice of
“porchlighting” as one in which a sales person leaves prospective customers alone in their home
to discuss the proposed sale privately, “then [with Rilla still recording] I would either keep my
iPhone or my iPad on the counter and I would carry out just the [product] samples.”
6
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.
20. On May 8, 2024, Defendant King sent an email to Abby Windows, with copies sent
to numerous third parties, including multiple attorneys in the State of Wisconsin, an employee of
Milwaukee’s Fox Television affiliate, and at least one employee of the State of Wisconsin who
works as an investigator for the Department of Agriculture, Trade and Consumer Protection. The
email stated in relevant part as follows:
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:
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.
21. Pursuant to Wis. Stats. § 943.70(2)(b)2, any person who modifies or destroys
computer data, or takes possession of computer data, or copies computer data in an attempt to
7
defraud or obtain property is guilty of a Class I felony. Consequently, Defendant King falsely
accused Abby Windows and/or Binder of committing a felony and published that false accusation
to numerous third parties in the State of Wisconsin.
22. Linked in the May 8, 2024 email was a document that was also linked in the
descriptions of Defendant King’s YouTube videos about Abby Windows. This document contains
numerous false allegations about Abby Windows and Binder. The most outrageous among these
allegations, referenced in King’s May 8, 2024 email, was that Binder and her wife sought out the
semen of a former employee, Defendant Richarz, so that they could conceive a child. This
allegation is false, and it was only publicized with the intent to diminish Binder’s standing in the
community. Specifically, the allegations were from a January 29, 2024 letter from Richarz to
Abby Windows – which falsely stated:
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.
The document contains the entirety of Richarz’s January 29, 2024 letter, among other baseless
accusations.
23. On May 11, 2024, Defendant King posted yet another video to YouTube, titled
“Nasty Abby Windows Owners Seek Sperm, Eavesdrop on Customers and Abuse Staff.” This
video contained an interview with Defendant Richarz. In this video, Defendants King and
Richarz repeated the false allegation that Binder sought a semen sample from Richarz in order to
conceive a child. Further, King and Richarz shared a portion of a Rilla recording from January
17, 2024 that purported to show Richarz deceptively raising the price quoted to a customer by
$1,000 without any justification at the behest of Abby Windows.
8
24. Specifically, Defendant King made false and defamatory statements about Abby
Windows’ sales practices, including:
So, this elder matriarch is in love with these people [Defendant Richarz and another
salesperson] even as they silently rob her blind with already inflated charges
and another $1,000 bump for no lawful reason whatsoever. Okay. In this dirty
industry, it is known as “face punching,” as in “I punched that old lady right in the
face.”
(emphasis added). In fact, Defendant Richarz had misquoted the job and the prospective customer
never entered into any contract with Abby Windows. Defendant King further stated, with regard
to Abby Windows’ sales practices, generally, “They’re gonna have to be dealing with a much
larger issue in terms of all of these thousands of homeowners they’ve done this to, and it’s
documented.” (emphasis added) Once again, this unambiguously is a false and defamatory
statement because Abby Windows’ sales practices are lawful.
25. During this video, Defendants King and Richarz also falsely stated that:
Richarz: She [Binder] wanted you to “porchlight close” and, like, leave the Rilla
on in the house and just a bunch of dirty tricks, I don’t know.
King: Yeah, and I understand “porchlight” is when you will leave the device
recording with the customer and then you’ll go outside and let them debate about
the most, you know, [unintelligible] and private affairs of their lives while they
figure out these expensive windows, and you’re recording that.
Richarz: That was her way of “porchlighting,” yes.
King: Yeah, and I understood the last time you said that you could actually listen
to it in real time, is that correct?
Richarz: Um, so not until it is done recording unless you have another device from
another person, like, listening to your appointment.
King: It is possible, right?
Richarz: Yeah.
9
26. In fact, the Rilla software does not have any real-time monitoring capability.
Further, Abby Windows never directed salespersons working on its behalf to leave their devices
behind to eavesdrop on prospective customers.
27. Defendants Richarz and King also offered false and defamatory statements about
the recording of his interactions with a prospective customer in which Richarz quoted a price of
$12,749 and then apparently increased the price by $1,000 a few minutes later:
Richarz: I had the price. The price was good, and we told the customer. The
customer didn’t really realize it. The other sales rep is now their sales manager
[unintelligible] told me to add $1,000 and I thought it was wrong and I, like,
questioned it to him. And he was, like, “No, do it.” I did it and because it was an
old vulnerable lady, and she didn’t even really know. She just liked us and thought
we were being honest and truthful.
King: I saw that. I saw that part. She said, “I just love you guys,” and meanwhile
you’re giving her the business.
Richarz: Exactly.
28. In fact, Richarz had misquoted the price of the job and the higher price was the
correct price. Nevertheless, this prospective customer never entered into any agreement with
Abby Windows, and Abby Windows never took any money from her. Consequently, these false
and defamatory statements would create for a reasonable listener the impression that Abby
Windows had defrauded this customer.
29. Defendant King also republished and read from Richarz’s January 29, 2024 letter
referenced above. When asked whether the claim that Binder and her wife had sought Richarz’s
semen, he again defamed Binder when he stated, “I mean, yeah, that’s accurate. It wasn’t, like, a
request. It was brought up, you know, multiple times where I felt like they were serious.”
30. In fact, Binder and her wife never sought such a semen sample from Richarz, and
they never made any comment to that effect, whether serious or in jest.
10
31. Further, in the description to the May 11, 2024 YouTube video, King wrote the
following:
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.
(emphasis added) Again, this statement is completely false as Abby Windows never entered into
a contract with this prospective customer and Richarz had misquoted the proposed job.
32. On or about May 11, 2024, King sent an email to the same distribution list as the
May 8, 2024 email described above, plus Waukesha District Attorney Susan Opper and State
Representative Calvin T. Callahan, imploring them to undertake an investigation based upon these
false and defamatory allegations:
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.
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. […]
11
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,
[* * *]
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.
33. The May 11, 2024 email from King included yet another republication of the
document linked in King’s YouTube videos containing numerous false allegations, including the
Richarz’s false and defamatory allegations set forth above.
34. On or about December 8, 2023, Defendant Crismond entered into an Independent
Consulting Agreement with Abby Windows. That agreement included a confidentiality provision
and a travel and lodging package consisting of a $5,000 lump sum payment. The travel and
lodging package provided:
In the event that the Consultant fails to fulfill the entirety of this Agreement or does
not onboard with the Company and remain with the Company through June 2024,
the Consultant agrees to repay the lump sum travel and lodging package of 5,000
to the Company within 30 days of termination.
35. On or about December 8, 2023, Defendant Crismond also entered into a
Confidentiality and Non-Competition Agreement with Abby Windows. That agreement provided
in part as follows:
12
1. Confidentiality. Employee agrees to keep secret and confidential, and not to use
or disclose to any third parties, except as directly required for Employee's
employment responsibilities for Company, any of Company's proprietary
Confidential Information. Confidential Information includes, but is not limited to:
(a) customer or potential customer lists; (b) any information, designs, files, records,
reports, suppliers, vendors, related to Company’s products or services; (c) financial,
sales and marketing data relating to Company; (d) materials, designs, procedures,
processes, and techniques related to, development, production and quality control
of Company's products and services; (e) Company's relations with its past, current
and prospective customers, suppliers, marketing partners and the nature and type
of products or services; (f) Company's relations with its employees (including,
salaries, job classifications and skill levels); and (g) any other information
designated by Company as confidential, secret and/or proprietary.
Notwithstanding the foregoing, the term Confidential Information shall not consist
of any data or other information which is publicly available or otherwise placed in
the public domain other than by Employee in violation of this Agreement.
36. In January 2024, Abby Windows terminated its Independent Consulant Agreement
with Crismond. In response to this termination, Crismond stated, “I am going to burn this place
to the ground,” or words to that effect.
37. In addition, when Abby Windows demanded repayment of the $5,000 travel and
lodging package, Crismond stated, “You will have to sue me for it,” or words to that effect. In an
effort to resolve this dispute, Abby Windows offered to waive its right to recover the $5,000 travel
and lodging package in exchange for Crismond’s agreement to a non-disparagement agreement.
Crismond refused this offer, stating, “You are not going to silence me,” or words to that effect.
To date, Crismond has never repaid the $5,000 travel and lodging package to Abby Windows in
accordance with the terms of his Independent Consultant Agreement.
38. Upon information and belief, Crismond either wrote or assisted in writing Richarz’s
letter that falsely claimed, among other things, that Binder sought Richarz’s semen to conceive a
child.
39. Upon information and belief, Crismond was instrumental in connecting King with
13
the other defendants to this action in a scheme to falsely and maliciously defame Abby Windows
and Binder.
40. Upon information and belief, Defendants Crismond, Richarz, Mayen, Stepniewski,
and Campbell provided with Defendant King with false information and/or proprietary information
in furtherance of his efforts to defame Plaintiffs or otherwise wrongfully cause harm to their
business.
41. Upon information and belief, Defendants Crismond, Richarz, Mayen, Stepniewski,
and Campbell, or some combination of them provided Defendant King with confidential customer
information that he displayed in the May 11, 2024 YouTube video.
COUNT 1
Defamation of a Business
42. Plaintiffs reincorporate all previously alleged paragraphs as though fully set forth
herein.
43. Abby Windows is in the business of home improvement contracting.
44. Binder is the Owner and President of Abby Windows.
45. King’s April 30, 2024 YouTube video constitutes a publication.
46. King’s May 5, 2024 YouTube video featuring an interview with Campbell
constitutes a publication.
47. King’s May 7, 2024 YouTube video featuring an interview with Defendant Mayen
48. King’s May 8, 2024 email described above constitutes a publication.
49. King’s May 11, 2024 YouTube video featuring an interview with Defendant
Richarz constitutes a publication.
14
50. King’s May 11, 2024 email to various persons, including District Attorney Opper
and State Representative Callahan constitutes a publication.
51. These publications contain false and defamatory allegations that accuse Abby
Windows and/or Binder of criminal activity and/or otherwise seek the diminish their reputation in
the community.
52. Defendants King, Richarz, and Mayen made these false and defamatory statements
with actual malice in that these defendants either knew or should have known that such statements
were false, or these defendants acted with reckless disregard to whether such statements were true
or false.
53. By spreading false, defamatory, libelous and malicious information, Defendants
King, Richarz and Mayen have harmed Plaintiffs and their professional and business reputation.
COUNT 2
Defamation of Abby Binder
herein.
55. Abby Windows is in the business of home improvement contracting.
56. Binder is the Owner and President of Abby Windows.
57. King’s April 30, 2024 YouTube video constitutes a publication.
58. King’s May 5, 2024 YouTube video featuring an interview with Campbell
59. King’s May 7, 2024 YouTube video featuring an interview with Defendant Mayen
60. King’s May 8, 2024 email described above constitutes a publication.
15
61. King’s May 11, 2024 YouTube video featuring an interview with Defendant
Richarz constitutes a publication.
62. King’s May 11, 2024 email to various persons, including District Attorney Opper
and State Representative Callahan constitutes a publication.
63. These publications contain false and defamatory allegations that accuse Abby
Binder of criminal activity and/or otherwise seek the diminish her personal reputation in the
community.
64. Defendants King, Richarz, and Mayen made these false and defamatory statements
with actual malice in that these defendants either knew or should have known that such statements
were false, or these defendants acted with reckless disregard to whether such statements were true
or false.
65. By spreading false, defamatory, libelous and malicious information, Defendants
King, Richarz and Mayen have harmed Plaintiff Binder in her personal capacity.
COUNT 3
Public Disclosure of Private Facts
herein.
67. Defendant Campbell intentionally made a public disclosure about Plaintiff Binder’s
marital history with the intent of harming Binder’s public reputation.
68. The facts that Defendant Campbell disclosed publicly, to the extent that those facts
were true, were private facts.
69. The private facts that Defendant Campbell disclosed were highly offensive to a
reasonable person of ordinary sensibilities.
16
70. Defendant Campbell acted either unreasonably or recklessly as to whether there
was a legitimate public interest in the matter, or had actual knowledge that no legitimate public
interest existed.
71. Plaintiff Abby Binder have suffered harm as a result of Defendant Campbell’s
public disclosure of private facts.
COUNT 4
Civil Conspiracy
herein.
73. Defendants King, Richarz, Mayen, Stepniewski, Campbell, and Crismond all took
actions in furtherance of a common scheme to harm the professional reputation of Abby Windows
through the dissemination of false and defamatory allegations against the company, and to harm
the professional and personal reputation of Abby Binder through the dissemination of false and
defamatory allegations against her.
74. Defendants King, Richarz, Mayen, Stepniewski, Campbell, and Crismond all took
their respective actions with malice in that these defendants either knew or should have known
that such statements were false, or these defendants acted with reckless disregard to whether such
statements were true or false.
75. Plaintiffs Abby Windows and Abby Binder have suffered harm as a result of the
Defendants’ concerted actions.
COUNT 5
Breach of Contract - Richarz
herein.
17
77. Defendant Richarz entered into an Account Associate Agreement with Abby
Windows on or about June 5, 2023. (the “Richarz Contract”. Copy attached as Exhibit A)
78. The Richarz Contract states in relevant part as follows:
Section 5. Confidential Records and Information. Account Associate acknowledges

that, during his relationship with Company, Company will give Account Associate
access to, and provide Account Associate with, Confidential Information. The term
"Confidential'' means trade secret info1mation, proprietary information, and
confidential information of Company relating to the Company Business, Buyers,
and its methods of doing business, regardless of the form or format of the
information, and includes, but is not limited to, information that is not generally
known by the public about Company's employees or agents, accounts, Buyers,
billing methods, business methods, operations. finances or financial condition,
marketing strategies, budgets, business plans, proposed ventures, or transactions.
The term "Information" means information that is or has been disclosed to Account
Associate or of which Account Associate became aware or to which Account
Associate had access as a consequence of or through his relationship with
Company.
[* * *]
(A) Account Associate agrees that Account Associate shall, both during and after
the term of this Agreement, maintain the Confidential Information in strict
confidence, shall not communicate, disclose, or make available all or any part of
the Confidential Information to any person(s) or entity, with the exception of other
representatives of Company to the extent necessary for Account Associate to
perform pursuant to this Agreement, and shall use his best efforts to prevent
inadvertent disclosure of all or any part of the Confidential Information to any third
party. (B) Account Associate agrees that Account Associate will not exploit or
attempt to exploit, commercially or otherwise, appropriate for Account Associate's
use, or reproduce in any form, all or any part of the Confidential information unless
specifically authorized by Company to do so in writing. (C) The restrictions of (A)
or (B). however, shall not apply to such Confidential Information that Account
Associate can establish by clear and convincing written proof is disclosed by
Account Associate in response to an order of any court or governmental agency
provided that Account Associate shall have promptly notified Company prior to
any such disclosure and provided reasonable cooperation in Company's effo1ts, if
any, to contest or limit the scope of such disclosure, and provided further that if
such disclosure is the subject of any protective or similar order, such information
will still be considered Confidential Information except for the limited purpose of
disclosure to such court.
[***]
18
Upon expiration or termination of this Agreement for any reason, Account

Associate shall immediately return all Confidential Information to Company.
Account Associate further agrees to return to Company any Confidential
Information upon Company's request at any time during his relationship with
Company. If the Confidential Information is such that it cannot reasonably be
returned, Account Associate shall provide reasonable evidence that such materials
have been destroyed, including but not limited to, the purging and/or erasing of any
and all computer records and/or data files. Account Associate recognizes that the
disclosure or alteration of Confidential Information may give rise to irreparable
harm to Company, inadequately compensable in damages, and that, accordingly,
Company may seek and obtain injunctive relief against the breach or threatened
breach of the undertakings of this Section, in addition to any other legal remedies
that may be available. In addition, the parties agree that Company shall be entitled
to collect liquidated damages of $500 per day during which Account Associate is
in breach of these covenants as well as its reasonable attorney's fees if it should
prevail in an action for breach of the covenants of this Section.
79. Defendant Richarz breached the Richarz Contract when he failed to protect the
Confidential Information in his possession.
80. Defendant Richarz breached the Richarz Contract when he disseminated
Confidential Information to Defendant King.
81. Plaintiff Abby Windows has been harmed by Defendant Richarz’s breach of this
Richarz Contract and seeks actual damages, liquidated damages, attorney fees and costs.
COUNT 6
Breach of Contract – Crismond Confidentiality Agreement
herein.
83. Defendant Crismond entered into a Confidentiality and Non-Competition
Agreement with Abby Windows on or about December 8, 2023. (the “Crismond Confidentiality
Agreement”. Copy attached as Exhibit B)
84. The Crismond Confidentiality Agreement states in relevant part as follows:
19
1. Confidentiality. Employee agrees to keep secret and confidential, and not to use
or disclose to any third parties, except as directly required for Employee's
employment responsibilities for Company, any of Company's proprietary
Confidential Information. Confidential Information includes, but is not limited to:
(a) customer or potential customer lists; (b) any information, designs, files, records,
reports, suppliers, vendors, related to Company’s products or services; (c) financial,
sales and marketing data relating to Company; (d) materials, designs, procedures,
processes, and techniques related to, development, production and quality control
of Company's products and services; (e) Company's relations with its past, current
and prospective customers, suppliers, marketing partners and the nature and type
of products or services; (f) Company's relations with its employees (including,
salaries, job classifications and skill levels); and (g) any other information
designated by Company as confidential, secret and/or proprietary. Notwithstanding
the foregoing, the term Confidential Information shall not consist of any data or
other information which is publicly available or otherwise placed in the public
domain other than by Employee in violation of this Agreement.
85. Defendant Crismond breached the Crismond Confidentiality Agreement when he
failed to protect the Confidential Information in his possession.
86. Defendant Crismond breached the Crismond Confidentiality Agreement when he
disseminated Confidential Information to Defendant King.
87. Plaintiff Abby Windows has been harmed by Defendant Crismond’s breach of this
Crismond Confidentiality Agreement and seeks actual damages, liquidated damages, attorney fees
and costs.
COUNT 7
Breach of Contract – Crismond Independent Consulting Agreement
herein.
89. Defendant Crismond entered into Independent Consulting Agreement with Abby
Windows on or about December 8, 2023. (the “Crismond Consulting Agreement”. Copy attached
as Exhibit B)
20
90. The Crismond Consulting Agreement states in relevant part as follows:
2. Compensation:
The Consultant will receive a total compensation of $30,000 for the three-
month engagement, to be paid in equal biweekly increments starting from
December 8th to March 8th,. Additionally, a lump sum travel and lodging
package of $5,000 will be paid prior to December 31, 2023.
(a) Travel and Lodging Package: In the event that the Consultant
fails to fulfill the entirety of this Agreement or does not onboard
with the Company and remain with the Company through June
2024, the Consultant agrees to repay the lump sum travel and
lodging package of $5,000 to the Company within 30 days of
termination.
91. Defendant Crismond breached the Crismond Consulting Agreement when he to
repay the $5,000 lump sum travel and lodging package within 30 days of the termination of his
services.
92. Plaintiff Abby Windows has been harmed by Defendant Crismond’s breach of this
Crismond Consulting Agreement and seeks actual damages.
RELIEF REQUESTED
Plaintiffs Abby Windows and Exteriors, LLC and Abby Binder demand judgment against
Defendants Christopher King, Riley Richarz, Taylor Stepniewski, Fred Mayen, Michaele
Campbell and Jason Crismond as follows:
1. On Count 1, an Order for Judgment and Judgment for monetary damages in an
amount to be determined at trial stemming from Defendants’ defamation of a business.
amount to be determined at trial stemming from Defendants’ defamatory and libelous statements.
3. On Count 3, Order for Judgment and Judgment for monetary damages in an amount
to be determined at trial stemming from Defendant Campbell’s defamatory and libelous
21
statements.
amount to be determined at trial stemming from Defendants’ civil conspiracy.
5. On Count 5, Abby Windows and Exteriors, LLC demands an Order for Judgment
and Judgment for monetary damages in an amount to be determined at trial stemming from
Defendant Richarz’s breach of contract.
Defendant Crismond’s breach of contract.
Defendant Crismond’s breach of contract.
8. An award of punitive damages of $200,000.00, or three times Plaintiff’s
compensatory damages for Counts 1 through 4, whichever is greater.
9. A temporary restraining order to bar further violations of Richarz’s and Crismond’s
confidentiality agreements.
10. A permanent injunction barring further violations of Richarz’s and Crismond’s
confidentiality agreements.
11. An award of Plaintiffs’ attorney fees.
12. An award of all statutory costs.
13. Judgment of such other and further relief as the Court may deem just and equitable.
PLAINTIFFS DEMAND A JURY ON ALL ISSUES SO TRIABLE.
22
Dated: May 15, 2024 CRAMER MULTHAUF, LLC

Attorneys for Abby Windows LLC
Electronically signed by Timothy J. Andringa

Timothy Andringa
Wisconsin Bar No. 1001279
Contact Information:
1601 E Racine Ave #200
Waukesha, WI 53186
Phone: (262) 542-4278
E-mail: [email protected]
23
VERIFICATION
I, Abby Binder, have personal knowledge about the facts set forth in the foregoing Verified
Complaint and I am competent to testify about them if called to do so at the trial of this action.
Under penalty of perjury, I verify that the facts set forth in this Verified Complaint are true to the
best of my knowledge.
Signed this 15th Day of May, 2024.
______________________________
Abby Windows and Exteriors, LLC
By: Abby Binder
______________________________
Abby Binder, individually
24

Abby Windows and Exteriors Sues Journo and 5 Employees For Exposing Corporate Corruption, Eavesdropping and Other Abuses

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Abby Windows and Exteriors Sues Journo and 5 Employees For Exposing Corporate Corruption, Eavesdropping and Other Abuses

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July 22, 2024

Re: File No. 153851 -Coltyn VonDeylen Complaint on Abby Windows

100.305 Prohibited selling practices during periods of abnormal economic disruption.

Second, the excuse about Rilla does not hold water:

cc: William F. Sulton, Esq.

) JUDGE BRAD SCHIMEL

NOTICE OF JOINDER IN MOTION TO DISMISS AND COUNTERCLAIM

NOW COMES DEFENDANT Taylor Stepniewski, without waiving any Defenses or

CHRISTOPHER KING, J.D. )

) JUDGE BRAD SCHIMEL

DECLARATION OF TAYLOR STEPNIEWSKI

NOW COMES DEFENDANT TAYLOR STEPNIEWSKI to solemnly aver to the

4. Everything I wrote about Plaintiffs is based on my own observations in the workplace;

5. Everything I have spoken about Plaintiffs is based on my own perceptions in the

9. I further believe her to be a Limited Purpose Public Figure; and

WITHOUT WAIVING SUPPLEMENTATION FURTHER DECLARANT SAYETH NAUGHT

Counsel via CCAP and at:

And to all named Defendants via email

This 11th Day of July, 2024

) JUDGE BRAD SCHIMEL

NOTICE OF JOINDER IN MOTION TO DISMISS AND COUNTERCLAIM

NOW COMES DEFENDANT Riley Richarz, without waiving any Defenses or

1. My name is Riley Richarz.

2. I maintain everything I said in my previous Declaration and I support homeowner Coltyn

DEMANDS FOR RELIEF

Counsel via CCAP and at:

And to all named Defendants via email

This 11th Day of July, 2024

Attn: Abby Windows & Exteriors HR Department

Re: Undocumented Payroll, Illegal Deductions and Demand for Settlement

https://enterprise.fiverr.com/blog/irs-20-factor-test/#:~:text=missed business opportunities.-,What is

How Much Can You Sue an Employer for Misclassification?

May 23, 2023

-required attendance at a central company location

-Overcharging undisclosed dealer fees

-Alteration of sales contracts/items and earnings through measure technician/order

June 11, 2021

DOOR-TO-DOOR SALES REP FILES CLASS ACTION FOR INDEPENDENT CONTRACTOR

Full docket text for document 29:

Administrative Penalty for Intentional Misclassification:

Criminal Penalty for Intentional Misclassification:

Administrative Penalty for Coercion:

2. Amount of training. Requesting or requiring workers to undergo company-provided training

6. Continuity of relationship. A continuous relationship between a company and a worker

Counsel via CCAP and at:

And to all named Defendants via email

This 11th Day of July, 2024

From: Harris, Deanne <[email protected]>

) JUDGE BRAD SCHIMEL

LITIGANT KING §902.01 REQUEST FOR JUDICIAL NOTICE OF CONSUMER

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

Counsel and Putative Counsel respectively via CCAP and at:

And to all named Defendants via email

) JUDGE BRAD SCHIMEL

LITIGANT KING §902.01 REQUEST FOR JUDICIAL NOTICE OF

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

From: Christopher King <[email protected]>

II. Law and Argument.

Counsel and Putative Counsel respectively via CCAP and at:

And to all named Defendants via email

From: Patrick Kenealy <[email protected]>

) JUDGE BRAD SCHIMEL

MEMORANDUM IN OPPOSITION TO ABBY LITIGANTS’ MOTION TO DISMISS