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NOTE: On July 13, 2015, the following cover letter was sent to the Office of

DisciplinaryCounseloftheWashingtonStateBARAssociationfortheiractionon
theComplaintslistedbelowbyUSPSCertifiedMail#70113500000186255639.

ConnieLaRue
1045KittNarcisseRd.
Colville,Washington99114
(509)6842627
July13,2015

OfficeofDisciplinaryCounsel
WashingtonStateBarAssociation
1325FourthAvenue,Suite600
Seattle,WA981012539

InRe:
1.
COMPLAINT FOR DISBARMENT AND REFERRAL FOR PROSECUTION OF TIMOTHY
RASMUSSEN, WSBA #32105, FOR CRIMINAL IMPERSONATION OF A PUBLIC OFFICIAL,
OBSTRUCTIONOFJUSTICEANDVIOLATINGHISSWORNOATHOFATTORNEY.

2.
COMPLAINTFORDISBARMENTANDREFERRALFORPROSECUTIONOFJESSICATAYLOR,
WSBA #36248, FOR CRIMINAL IMPERSONATION OF A DEPUTY PROSECUTOR, OBSTRUCTING
JUSTICEANDVIOLATINGHERSWORNOATHOFATTORNEY.

DearClerk:

EnclosedwiththisCoverLetterisaComplaintforDisbarmentofTimothyRasmussenand
JessicaTaylorandanExhibitPackageinsupport.

Ihavealsoenclosedthefirstpagesoftheenclosuresforyoutopleaseconformandreturn
themtomeintheenclosedSASE.

Thankyou.

ConnieLaRue

Connie LaRue
1045 Kitt-Narcisse Rd
Colville, Washington 99114
USPS Cert. Mail 701135000001 8625 5585

TO THE SUPREME COURT OF THE STATE OF WASHINGTON

COMPLAINT FOR DISBARMENT AND REFERRAL FOR PROSECUTION

OF JESSICA TAYLOR, WSBA #36248, FOR CRIMINAL IMPERSONATION OF A

DEPUTY PROSECUTOR, OBSTRUCTING JUSTICE

AND VIOLATING HER SWORN OATH OF ATIORNEY.

LaRue relies on the following relevant facts, statutes and court rulings from the
Washington state and Federal courts in making this complaint.

FACTS:

1.

JESSICA TAYLOR, WSBA #36248, (hereafter TAYLOR), was "appointed"


on December 31, 2014, to the public office of STEVENS COUNTY DEPUTY
PROSECUTOR by TIMOTHY RASMUSSEN WSBA #32105.
RASMUSSEN
failed to duly qualify for the office of STEVENS COUNTY PROSECUTOR
and was without authority to appoint TAYLOR to any office.

2.

Although TAYLOR has been acting as DEPUTY PROSECUTOR and blindly


executing the illegal "orders" of RASMUSSEN, there exists no evidence
that TAYLOR could be duly qualified for the office or perform such duties
because RASMUSSEN was illegally impersonating a county prosecutor at
the time of TAYLOR's appointment.

3.

RCW 36.27.040 Appointment of deputies - Special and temporary


deputies. "The prosecuting attorney may appoint one or more deputies
who shall have the same power in all respects as their principal. Each

COMPLAINT FOR DISBARMENT AND REFERRAL FOR PROSECUTION

Page 1 of 15

appointment shall be in writing, signed by the prosecuting attorney, and


filed in the county auditor's office. Each deputy thus appointed shall have
the same qualifications required of the prosecuting attorney...
/I

4.

What does not appear does not exist. It is believed that for this very
reason, TAYLOR's Appointment was never legitimately filed into the
official public records with evidence of Fee Paid (RCW 65.04.015(2), (3)
and (4}) for the filing and an Auditor's File Number assigned because
RASMUSSEN was without lawful authority to make the appointment and
did not want to be accused of filing a false instrument in addition to all
his other criminal acts.

5.

It was TAYLOR's duty to vet and verify that RASMUSSEN (her Superior)
was in fact a duly-qualified COUNTY PROSECUTOR at the time of
accepting her alleged "appointment" and performing the duties of that
office.

6.

TAYLOR obediently carried out her Superior's (RASMUSSEN's) illegal


1
orders to prosecute Citizens of STEVENS COUNTY that resulted in
deprivations of unalienable rights to life, liberty and property from
unlawful imprisonment and/or fines. TAYLOR must accept unlimited
liability for her actions in her individual capacity. "Ignorance of the law
does not excuse" and blindly following illegal orders of a Superior does
not absolve of personal liability.

7.

TAYLOR is a Washington State Bar member with an Oath of Attorney


who has ignored the law and its requirements to duly qualify, for which
she should be disbarred.

8.

TAYLOR swore an OATH OF ATIORNEY (see RCW 2.48.210) which is on


file with the Washington Supreme Court and states in relevant part:

This footnote applies to those who have been allegedly "appointed" and are blindly obeying orders of an illegal
usurper of a public office (i.e. "Superior"). Obeying illegal orders did not stop the Nazi subordinates from being
held accountable for their crimes at the Nuremburg Trials. The defense of superior orders was no longer
considered enough to escape punishment; but merely enough to lessen punishment. H.T. King, Jr., The Legacy of
Nuremberg, Case Western Journal of International Law, Vol. 34. (Fall 2002) at pg. 335.e
1

COMPLAINT FOR DISBARMENT AND REFERRAL FOR PROSECUTION

Page 2 of 15

"I am fully subject to the laws of the State of Washington and


the laws of the United States, and will abide by the same. "; "I
will support the constitution of the State of Washington and
the constitution of the United States"; and "I will abide by the
Rules of Professional Conduct approved by the Supreme Court
of the State of Washington.
II

9.

TAYLOR has been knowingly, willfully and criminally impersonating a


public officer and usurping a public office since first being illegitimately
"appointed ll to the position of DEPUTY PROSECUTOR.

10.

During TAYLOR's "tenure ll of criminally impersonating a DEPUTY


PROSECUTOR and the criminal usurpation of the office of STEVENS
COUNTY DEPUTY PROSECUTOR, TAYLOR has conducted hundreds,
perhaps thousands, of illegal "prosecutions ll by fraud and deception,
passing off a simulated legal process as legitimate legal process,
resulting in the deprivation of people's property through unauthorized
fines and their lives through illegal imprisonments.

11.

TAYLOR illegally implemented a simulated legal process against Connie


LaRue in STEVENS COUNTY DISTRICT COURT, Case No. 5Z0133878 using
a false report from a criminal actor impersonating a CITY OF CHEWELAH
police officer named JOHNATHAN LLOYD BOWERS who "stopped and
ticketed" LaRue outside the jurisdiction of the CITY OF CHEWELAH and
that illegal case was dismissed.

12.

TAYLOR knew or should have known from the unauthorized BOWERS


"police" report that to illegally prosecute LaRue by the CITY OF
CHEWELAH was a violation of LaRue's due process rights and a form of
punishment by compelling her to defend against multiple illegal
prosecutions. "A court's jurisdiction... may be lost in the course of the

proceedings... If this requirement of the...{BiII of Rights] is not complied


with the court no longer has jurisdiction to proceed. The judgment...
pronounced by a court without jurisdiction is void... Johnson v. Zerbst
11

304 US 458, 468.

COMPLAINT FOR DISBARMENT AND REFERRAL FOR PROSECUTION

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13.

TAYLOR has blindly accepted a false ((police report" as grounds for


prosecution to punish LaRue through an organized enterprise to use an
illegal traffic stop for harassment that resulted in a false arrest, false
imprisonment in the county jail and other such illegal acts in conspiracy
with other impersonators in public office in STEVENS COUNTY. LaRue
was targeted and punished for exercising her right to travel to a safe and
well-lighted area because STEVENS COUNTY is renown for its recent rash
of rapist "officers of the law".

14.

While still criminally impersonating a county prosecutor, TAYLOR has


taken the lead to again ((charge" LaRue by naming the STATE OF
WASHINGTON as the Plaintiff (STEVENS COUNTY DISTRICT COURT No.
P7944) which has resulted in LaRue remaining under threat, duress and
coercion, and the continuing deprivation of LaRue's time, energy and
meager finances.

15.

TAYLOR has filed false documents. She has given four different locations
where the supposed crime occurred. The arresting "policeman" gave a
fifth location, but the dash cam and Dispatch call give a sixth location.

16.

TAYLOR has filed documents sworn by the involved "policeman" that


were replete with lies.

17.

TAYLOR claims that a form distributed by WASPC, allegedly signed by


usurper STEVENS COUNTY ((SHERIFF" KENDLE ALLEI\l on 12/21/2010,
gives police powers to all general authority agencies in WASHINGTON
STATE. ALLEN cannot be granted or grant to himself power the people
themselves do not possess. This fraudulent unconstitutional
((document" is not "filed" or ((recorded", and yet TAYLOR says it is law
and this is her stated source of jurisdiction for the arresting "policeman".
Even legitimate and duly-qualified sheriffs do not make law.

18.

LaRue attempted to file an Application for Writ of PrOhibition, Injunction


and Show Cause Order with the WASHINGTON SUPREME COURT and
was rejected because a "state officer" was not a party to the complaint.

COMPLAINT FOR DISBARMENT AND REFERRAL FOR PROSECUTION

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19.

LaRue re-filed the same Application for Writ of Prohibition, Injunction


and Show Cause Order with different heading to the STEVENS COUNTY
SUPERIOR COURT demanding a duly-qualified SUPERIOR COURT JUDGE
hear the case and giving the CLERK OF COURT 20 days to find and assign
a duly-qualified judge.

20.

More than 20 days have passed and LaRue's efforts have been stifled
(obstructing justice) by a non-qualified "judge" named ALLEN C.
NIELSOI\I.
NIELSOI\I is holding hostage LaRue's in forma pauperis
application. Nielson has no authority to grant LaRue's application to
proceed without costs because he is not a duly-qualified SUPERIOR
COURT JUDGE. NIELSON's action is obstructing LaRue's ability to have
her Application for a Pre-emptory Writ of Prohibition, Injunction, and
Show Cause Order heard before a competent and duly-qualified judge.

21.

Although LaRue has been unable to obtain justice in the STEVENS


COUNTY COURTS, the WASHINGTON DEPARTMENT OF LICENSING has
continued to move forward by issuing a NOTICE OF SUSPENSION of
LaRue's license and NOTICE OF DELINQUENCY. TAYLOR's participation in
2
this STEVENS COUNTY RIC0 enterprise could result in LaRue being
stopped, assaulted, kidnapped and falsely imprisoned again, in spite of
the fact that LaRue has not been found guilty of anything and has not
had her day in court.

22.

TAYLOR has illegally usurped and criminally impersonated a public


official and her illegal conduct has been protected by one or more
persons in STEVENS COUNTY that have not duly qualified to occupy and
perform the lawful duties of certain public offices. An honest audit of
STEVENS COUNTY by the STATE AUDITOR's OFFICE would expose that
thousands of Citizens have been deprived of their unalienable rights of
life, liberty and property through illegal fines and/or incarceration.

23.

It is believed that TAYLOR is participating in a STEVENS COUNTY RICO


enterprise, with illegal assaults (and assaults with a deadly weapon),

The Racketeer Influenced and Corrupt Organizations Act, commonly referred to as the RICO Act or simply RICO,
is a United States federal law that provides for extended criminal penalties and a civil cause of action for acts
performed as part of an ongoing criminal organization.

COMPLAINT FOR DISBARMENT AND REFERRAL FOR PROSECUTION

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false arrests, kidnapping, false imprisonment, extortion and other


crimes against the people happening on a daily basis.
24.

TAYLOR has repeatedly violated her sworn OATH OF ATTORNEY.

25.

TAYLOR's occupation of an office she was not authorized to possess is


prima facie evidence that she is an illegal usurper into public office.

26.

Every action taken by TAYLOR while impersonating a public officer is a


criminal act for which she has yet to be held accountable.

RELEVANT LAW RELIED UPON IN SUPPORT OF THIS COMPLAINT:

"We have no officers in this government from the President down to


the most subordinate agent, who does not hold office under the
law, with prescribed duties and limited authority. And while some of
these... exercise powers in some sense left to the more general
definitions necessarily incident to fundamental law found in the
Constitution, the larger portion of them are the creation of statutory

law, with duties and powers prescribed and limited by law." [Pierce
v. United States] THE FLOYD ACCEPTANCES, 74 US 666 at 676-677; (7
Wall. 666), Supreme Court 1868, Washington Law Reporter, Vol. XLII
Page 297.
Maxim of Law: "What does not appear does not exist."
Maxim of Law: Ignorantia juris non excusat: "Ignorance of the law
does not excuse."

Being Ilduly
qualijied to fill an office, in the constitutional sense and in the
ordinary acceptation of the words} means that the officer shall
possess every qualification; that he shall in all respects comply with
every requisite before entering on duties of the office; and that he
shall be bound by oath or affirmation to support the Constitution} and
Black's Law 6th Edition states: "Duly Qualified" N

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to perform the duties of the office with fidelity. Black's Law Dictionary
6th Edition.
RCW 42.20.030 (in relevant part) - Intrusion into and refusal to
surrender public office. Every person who shall falsely personate or

represent any public officer, ... or who shall willfully exercise any of
the functions or perform any of the duties of such officer, without
having duly qualified therefore, as required by law, ... shall be guilty
of a gross misdemeanor.

"The fact that the candidate is qualified at the time of his election is
not sufficient to entitle him to hold the office it at the time of his
commencement to his term of Office, or during the continuance of the
term, he ceases to be qualified. Eligibility to public office is of a
continuing nature, and must subsist at the commencement of the
term, and during the occupancy of the office. " Washington Attorney
General Opinion - AGO 63-64, no. 17.
LEGISLATIVE MANDATES TO DULY QUALIFY FOR PUBLIC OFFICE SUPPORTED BY
WASHINGTON COURT RULINGS

1.

RCW 2.48.210 Oath on admission requires an Oath of Attorney before


authorization to practice law in Washington stating: "Every person

before being admitted to practice law in this state shall take and
subscribe the following oath/!.
2.

RCW 36.27.040 Appointment of deputies deputies.

Special and temporary

"The prosecuting attorney may appoint one or more deputies who shall
have the same power in all respects as their principal. Each appointment
shall be in writing, signed by the prosecuting attorney, and filed in the
county auditor's office. Each deputy thus appointed shall have the same
qualifications required of the prosecutinq attorney, except that such
deputy need not be a resident of the county in which he or she serves.
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The prosecuting attorney may appoint one or more special deputy


prosecuting attorneys upon a contract or fee basis whose authority shall
be limited to the purposes stated in the writing signed by the prosecuting
attorney and filed in the county auditor's office. Such special deputy
prosecuting attorney shall be admitted to practice as an attorney before
the courts of this state but need not be a resident of the county in which
he or she serves and shaJl not be under the legal disabilities attendant
upon prosecuting attorneys or their deputies except to avoid any conflict
of interest with the purpose for which he or she has been engaged by the
prosecuting attorney. The prosecuting attorney shall be responsible for
the acts of his or her deputies and may revoke appointments at will. "

3.

Right to hold public office is subject to qualifications imposed by


legislature.// State ex reI. Carroll v. Simmons (1962) 61 Wash.2d 146, 377
P.2d 421, cert, denied 83 S. Ct. 1698, 374 U.S. 808, 10 L. Ed.2d 1032

4.

"Use of word "shaW~ in statute imposes mandatory duty/~ Waste


Management of Seattle, Inc. v. Utilities and Trans. Com'n, 869 P.2d 1034,
123 Wash.2d 621, reconsideration denied (1994).

5.

RCW 36.16.040 Oath of office. "Every person elected to county office

shall before he or she enters upon the duties of his or her office take and
subscribe an oath or affirmation that he or she will faithfully and
impartially discharge the duties of his or her office to the best of his or
her ability. //
6.

RCW 36.16.060 Place of filing oaths and bonds. "Every county officer~
before entering upon the duties of his or her office~ shall file his or her
oath of office in the Office of the county auditor and his or her official
bond in the office of the county clerk... Oaths and bonds of deputies
shall be filed in the offices in which the oaths and bonds of their

principals are required to be filed."


7.

RCW 65.04.030 Instruments to be recorded or filed.


The auditor or recording Officer must, upon the payment of the fees as

required in RCW 36.18.010...

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(3) All such other papers or writing as are required by law to be recorded
and such as are required by law to be filed.
8.

RCW 65.04.130 Fees to be paid or tendered.


Said county auditor is not bound to record any instrument or file any
paper or notice, or furnish any copies, or to render any service connected
with his or her office, until his or her fees for the same, as prescribed by
law, are if demanded paid or tendered.

NProvision requiring payment of fees in advance is mandatory.


State v. Nelson (1940) 6 Wash.2d 190, 107 P.2d 1113.

1/

NWhen papers are received by officer for filing, filing will not
become effective until necessary fees have been paid." State v.
Conners (1942) 12 Wash.2d 128, 120 P.2d 1002; State v. Nelson
(1940) 6 Wash.2d 190, 107 P.2d 1113.
NStatutes relating to compensation of public officer must be
strictly construed in favor of government, and such officers are
entitled only to what is clearly given by law. Murphy v. State
Dept. of Licensing (1981) 28 Wash. App. 620, 675 P.2d 732.
N

"Day on which oath of office is signed and filed by judge of


superior court is day on which he assumes office for purposes of
pension benefits, and day of Governor's announcement of
proposed appointment is immaterial." Jordan v. O'Brien (1971) 79
Wash.2d 406, 486 P.2d 890.
9.

RCW 65.08.150 Duty to Record: A recording officer, upon payment or


tender to him or her of the lawful fees therefor, shall record in his or her

office any instrument authorized or permitted to be so recorded by the


laws of this state or by the laws of the United States.
10.

"When legislative body provides definitions for statutory terms,


it is that definition to which the person must conform his

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conduct." City of Seattle v. Koh, 26 Wash. App. 708, 614 P.2d 665
(1980).

"Where an act uses the word in a special sense which it defines,


definition by average man or by ordinary dictionary is not
substitute for the definitions contained in the act." National
Homeopathic Hospital Ass'n of District of Columbia et.al. v.
Britton, Deputy Com'r., 147 F2d 561.
11.

II

II

Legislative Definitions (summation) of NFILE"J NFILED or NFILING and


NRECORD", NRECORDED or NRECORDING
RCW 65.04.015(2} FILED for Nrecording into the official public record"
RCW 65.04.015 (3) RECORD Nafter filing to incorporate the instrument
into the public records ll
RCW 65.04.015 (4) NRECORDING NUMBER Assignment of an Nauditor or
recording officer file numberllNthat identifies the storage location ll "of
each instrument in the public records ll Naccessible in the same recording
office where the instrument containing the reference to the location is
found. 11
J

II

II

II

12.

RCW 5.44.040 Certified copies of public records as evidence.


Copies of all records and documents on record or on file in the offices of
the various departments of the United States and of this state or any
other state or territory of the United States, when duly certified by the
respective officers having by law the custody thereof, under their
respective seals where such officers have official seals, shall be admitted
in evidence in the courts of this state. [NOTE: If the fees for filing and/or
recording are not paid in advance, an oath of office cannot be made a
part of the official public record.]

13.

RCW 42.20.100 Failure of duty by public officer a misdemeanor.


Whenever any duty is enjoined by law upon any public officer or other
person holding any public trust or employment, their wilful neglect to
pedorm such duty, except where otherwise speciallv provided for, shall
be a misdemeanor.

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14.

RCW 9A.80.010 Official Misconduct (l)(a) .. .intentionally commits an


unauthorized act under color of law (b) .. .intentionally refrains from
performing a duty imposed upon him or her by law. (2) OffiCial
misconduct is a gross misdemeanor, defined at RCW 9.92.020.

15.

RCW 42.12.010 Causes of vacancy, Every elective office shall become

vacant on the happening of any of the following events:


(5) ... any offense involving a violation of his or her official oath;
(6) His or her refusal or neglect to take his or her oath of office~ or to give
or renew his or her official bond~ or to deposit such oath or bond within
the time prescribed by law.
16.

RCW 42.20.030 -Intrusion into and refusal to surrender public office.

Every person who shall falsely personate or represent any public officer~
or who shall willfully intrude himself into a public office to which he has
not been duly elected or appointed, or who shall willfully exercise any
of the functions or perform any of the duties~ without having duly
qualified as required by law, ..., shall be guilty of a gross misdemeanor.
17.

RCW 9A.56.130 Extortion in the second degree.

(1) A person is guilty of extortion in the second degree if he commits


extortion by means of threat as defined in RCW 9A.04.110(28)(d)
through (j).
(2) Extortion in the second degree is a class C felony.
RCW 9A.04.110 - Definitions.
(28) "Threat means to communicate directly or indirectly the
N

intent:
(h) To take wrongful action as an official against anyone or
anything, or wrongfully withhold official action, or cause such
action or withholding;
The Washington Legislature enacted two laws, one which was enacted in 1866
and another that was enacted in 1909, both of which are still on the books and
are now recodified as RCW 42.12.010 and 42.20.030.

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RCW 42.12.010 originally enacted in 1866 and to date, remains almost


unchanged, allows no grace period under subsection (6) for any refusal or neglect
(to duly qualify] within the time prescribed by law.
RCW 42.20.030 was originally enacted in 1909 and has never been changed and
contains four different offenses that constitute the act of intrusion into public
office and one for refusal to surrender public office.
Three of these offenses require certain acts to be performed "willfully" in order to
be a crime, but two of the offenses only require that certain acts be performed.
The first element states, "Every person who shall falsely personate or represent
any public officer, or ... " Notice that no intent is required.
The second element states, "who shall willfully intrude himself into a public office
to which he has not been duly elected or appointed, or ... " Wilfullness
is established by knowledge (RCW 9A.08.010) and "duly" is defined in Black's
Law Dictionary 6th Ed. as "In due and proper form or manner; according to legal

requirements....; according to law in both form and substance."


The third element states, "who shall willfully exercise any of the functions or

perform any of the duties of such officer, without having duly qualified
therefor, as required by law; or... "
"Being duly qualified to fill an office, in the constitutional sense and in the ordinary
acceptation of the words, means that the officer shall possess every qualification;
that he shall in all respects comply with every requisite before enterinq on the
duties of the office; and that he shall be bound by oath or affirmation to support
the Constitution, and to perform the duties of the office with fidelity." Black's Law
Dictionary 6th Ed
The fourth element states, "Who, having been an executive or administrative
officer, shall Willfully exercise any of the functions of his office after his right to do
so has ceased, or ..."
The fifth element states, "wrongfully refuse to surrender the official seal or any
books or papers appertaining to such office, upon the demand of his lawful

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successor shall be guilty of a gross misdemeanor. "See RCW 9A.60.040


Impersonating a Public Officer and RCW Chapter 7.56 Quo Warranto.
RCW 9a.60.040
Criminal impersonation in the first degree.

(1) A person is guilty of criminal impersonation in the first degree if


the person:
(a) Assumes a false identity and does an act in his or her assumed
character with intent to defraud another or for any other unlawful
purpose; or
(b) Pretends to be a representative of some person or
organization or a public servant and does an act in his or her
pretended capacity with intent to defraud another or for any other
unlawful purpose.
(2) Criminal impersonation in the first degree is a class C felony.
CONCLUSIONS RELIED UPON FOR THIS CRIMINAL COMPLAINT:
First, if the fees for filing are not paid in advance, an oath of office cannot be

made a part of the official public record. see RCW 5.44.040.


Second, if the official oath is not made part of the official public record, it grants

no lawful authority.
Third, if the oath is not filed as defined in RCW 65.04.040, it is not part of the

official public record.

RCW 65.04.040 Method for recording instruments - Marginal


notations - Arrangement of records.
Any state, county, or municipal officer charged with the duty of
recording instruments in public records shall record them by *record
location number in the order filed, irrespective of the type of
instrument, using a process that has been tested and approved for
the intended purpose by the state archivist.
In addition, the county auditor or recording officer, in the exercise of
the duty of recording instruments in public records, may, in lieu of
transcription, record all instruments, that he or she is charged by law
to record, by any electronic data transfer, photographic, photostatic,

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microfilm~ microcard~

miniature photographic or other process that


actually reproduces or forms a durable medium for so reproducing
the origina/~ and which has been tested and approved for the
intended purpose by the state archivist. If the county auditor or
recording officer records any instrument by a process approved by
the state archivist it shall not be necessary thereafter to make any
notations or marginal notes~ which are otherwise required by law~
thereon if, in lieu of making said notations thereon~ the auditor or
recording officer immediately makes a note of such in the general
index in the column headed "remarks~" listing the record number
location of the instrument to which the current entry relates back.
Previously recorded or filed instruments may be processed and
preserved by any means authorized under this section for the
original recording of instruments. The county auditor or recording
officer may provide for the use of the public~ media containing
reproductions of instruments and other materials that have been
recorded pursuant to the provisions of this section. The contents of
the media may be arranged according to date of filing~ irrespective of
type of instrument or in such other manner as the county auditor or
recording officer deems proper.
Fourth, if the oath of office is not actually made part of the official public record,
as defined in law, it cannot be admitted into evidence under ER 902(d} or ER 1005
to support a lawful claim for salaries or benefits [or for any other purpose]
relating to a public office.
Fifth, as shown by the case law already supplied to you, all filing fees are
mandatory and are to be paid in advance and your [STATE AUDITOR] examiners
are supposed to know that an oath of office. an appointment to a public office.
and an official bond are required by law to be filed and/or recorded into and
made part of the official public record. requiring a paid receipt for those
transactions. AUDITORs know that there can be no lawful occupation of the
intended office by a person impersonating a public official or usurping a public
office.
Sixth, there are several sections in RCW 43.09 that would cover your [STATE
AUDITOR'S] department responsibility to verify that the bonds, appointments and

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oaths were filed, as required by law, such as RCW 43.09.200, 43.09.210,


43.09.230, and 43.09.245 but, under 43.09.260 your department has specific
information as to what is required pursuant to subsection (5). RCW 43.09.260(5)

"On every such examination, inquiry shall be made as to the financial condition
and resources of the local government; whether the Constitution and laws of the
state, the ordinances and orders of the local government and the requirements of
the state auditor have been properly complied with, and into the methods and
accuracy of the accounts and reports.

II

IN CLOSING

For the foregoing reasons supported by facts, relevant law, statutes, and
Washington court rulings, JESSICA TAYLOR WSBA #32105 should be disbarred and
referred by this body of examiners and mandatory reporters for criminal
prosecution before the appropriate authorities, state or federal.
I declare under penalty for perjury that the foregoing facts, relevant laws relied
upon, legislative mandates relied upon, and conclusions to support this
COMPLAINT FOR DISBARMENT AND REFERRAL FOR PROSECUTION OF JESSICA
TAYLOR, WSBA #32105, FOR CRIMINAL IMPERSONATION OF A PUBLIC OFFICIAL,
OBSTRUCTION OF JUSTICE AND VIOLATING HER SWORN OATH OF ATIORNEY are
true and correct to the best of my knowledge, understanding and belief.
All Rights Reserved
(

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Connie LaRue, Affiant

JURAT
Washington State}
Stevens County

} ss.

tioed!

I, (] flKLfJ Y72
a Washington Notary Public, do certify that
Connie LaRue appeared before me and swears under penalty of perjury. that the.,
t t \; r'l J ,
.~ j ...
foregoing IS true.
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On this, the ~!::day of 3W1e

,2015.

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My appointment

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COMPLAINT FOR DISBARMENT AND REFERRAL FOR PROSECUTION

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Page 15 of 15

INDEX OF EXHIBITS
EXHIBIT 1: TIMOTHY RASMUSSENs various non-compliant-with-state law Oaths of
Office impersonating a COUNTY PROSECUTOR in STEVENS COUNTY and his
OATH OF ATTORNEY.
EXHIBIT 2: JESSICA TAYLORs illegal Appointment as an alleged DEPUTY
PROSECUTOR in STEVENS COUNTY by usurper TIMOTHY RASMUSSEN.
EXHIBIT 3: First two charging instruments CITY OF CHEWELAH v. CONNIE LARUE
Case No. 5Z0133878 & Case No. 5Z0133879.
EXHIBIT 4: MOTION AND MEMORANDUM FOR DISMISSAL showing TAYLOR
conducted an illegal prosecution and violated LaRues rights.
EXHIBIT 5: Order for dismissal of cases No. 5Z0133878 & No 5Z0133879
EXHIBIT 6: New Charge STATE OF WASHINGTON v. Connie LaRue, Case No. P7944
using the same illegal police report to justify re-prosecuting LaRue to extort over $1062.
EXHIBIT 7: WASHINGTON DEPARTMENT OF LICENSING NOTICE OF
SUSPENSION
NOTICE 8: WASHINGTON DEPARTMENT OF LICENSING NOTICE OF
DELINQENCY

NOTICE
There is no evidence that any of the below-named impersonators of a public official
and criminal usurpers of a public office are compliant with state law. None have an oath
of office or appointment properly filed and incorporated into the official public records.
This blatant disregard for Washington State Law has deprived LaRue of her right to
Justice through Due Process of Law at minimum.
TIMOTHY RASMUSSEN
JESSICA TAYLOR
SAUNDRA RICHARTZ
NICHOLAS FORCE
KENDLE ALLEN
TROY ANDERSON
JOHNATHAN BOWERS
GINA A. TVEIT
LLOYD B. NICKEL
ALLEN C. NIELSON
PATRICK A. MONASMITH

Page 1 of 1

Exhibit 1
Under this Exhibit are TIMOTHY RASMUSSENs
invalid, non-filed, non-compliant with Washington State
Law alleged Oaths of Office but they do not make him
duly qualified. Also find his Oath of Attorney where he
swore he was fully subject the laws of the State of
Washington and will abide by same.
A properly Filed Document will contain evidence of an
Auditor File Number, number of pages, amount of Fee
Paid, and where the document can be located for review.

Any document required by law to be recorded or


required by law to be filed must contain evidence
as viewed to the right.

The STAMP to the right does not


comply with state law as defined
in RCW 65.04.015(2), (3) and (4).
There is no Auditor File #, No
evidence of required Fee Paid,
etc. This "oath" has not been
made a part of the official public
record. This "oath" is just a
worthless piece of paper.

This "Oath of Office" does not


comply with state law as defined
in RCW 65.04.015(2), (3) and (4).
There is no Auditor File #, No
evidence of required Fee Paid,
etc. This "oath" has not been
made a part of the official public
record. This "oath" is just a
worthless piece of paper.

STATE OF WASHINGTON}

COUNTY OF STEVENS

OATH OF OFFICE
I, ~""'- 1<4....6 W\ lT6 6 e-'1
do solemnly swear (or affirm) that I will
support the Constitution of the United States and the Constitution and laws of the State of
Washington, and that I will faithfully and impartially perform and discharge the duties of
the office of rY'Dset.u-\ \V\
~rf..\lL
Cco~
6..
as such duties are prescribed y law, to the est of my ability.

Jov.

Subscribed and sworn to before me thisZ day of

,2

Oe~

01,'1.

I~
Return Document to:
Stevens County Auditor
215 S Oak, Room 106
Colville, WA. 99114-2836

- ..

OEC .
. .:. ~1,~;3 COUNTY
AUC~TOR

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, do solemnly declare:

1. 1 am fully subject to the laws of the State of Washington and the laws of the United States and will abide by
the same.

2. I will support the constitution ofthe State of Washington and the constitution of the United States.
3. 1 will abide by the Rules ofProfeSSional Conduct approved by the Supreme Court of the State of Washington.

4. I will maintain the respect due to the courts ofjustice and judicial officers.
5. I will not counsel, or maintain any suit, or proceeding, which shall appear to me to be unjust, or any defense
except as I believe to be honestly debatable under the law, unless it is in defense of a person charged with a
public offense. 1 will employ for the purpose of maintaining the causes confided to me only those means
consistent with truth and honor. I will never seek to mislead the judge or jury by any artifice or false
statement.

6. I will maintain the confidence and preserve inviolate the secrets of my client, and will accept no

compensation in connection with the business of my client unless this compensation is from or with the

knowledge and approval of the client or with the approval ofthe court.

7. I will abstain from all offensive personalities, and advance no fact prejudicial to the honor or reputation of a
party or witness unless required by the justice of the cause with which I am charged.
8. I will never reject, from any consideration personal to myself, the cause of the defenseless or oppressed, or
delay unjustly the cause of any person.

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."

Exhibit 2
Under this Exhibit is JESSICA TAYLORs invalid
Appointment by RASMUSSEN to the Office of Deputy
Prosecutor. A copy of TAYLORs sworn Oath of
Attorney required by RCW 2.48.210 was unable to be
procured upon public records request to the Supreme
Court. However it is believed that TAYLOR also swore
that she was fully subject the laws of the State of
Washington and will abide by same.
A properly Filed Document (Appointment) will contain
evidence of an Auditor File Number, number of pages,
amount of Fee Paid, and where the document can be
located for review.

Any document required by law to be recorded or


required by law to be filed must contain evidence
as viewed to the right.

'"

This "Appointment" does not


comply with state law as defined in
RCW 65.04.015(2), (3) and (4).
There is no Auditor File #, No
evidence of required Fee Paid, etc.
This "Appointment" has not been
made a part of the official public
record. This "appointment" is just a
worthless piece of paper.

- .-

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STEVENS COUNTY PROSECUTING

ATTORNEY

._.:.-,,---~.

State of Washington
County of Stevens

)
) ss
)

CERTIFICATE OF APPOINTMENT

I, Tim Rasmussen, Prosecuting Attorney of Stevens County, State of Washington,


having special confidence in Jessica Taylor, do hereby constitute and appoint Jessica
Taylor Deputy Prosecutor of said County, State of Washington, until revoked by me,
which appointment shall thereafter cease and be null and void.
IN TESTIMONY WHEREOF, I have hereunto set my hand this 31 day of
December 2014.

Tim Rasmussen
Stevens County Prosecutor

Exhibit 3
First two charging instruments
CITY OF CHEWELAH v. CONNIE LARUE
Cases No. 5Z0133878 & No. 5Z0133879.

CRIMINAL

Q]TRAFFIC

WA0330100
COURT ORI #: WA033023J
STEVENS COUNTY DISTRICT COURT

DNON-TRAFFIC

5Z0133878

LEA OR! #

IN 1HE QlDlSTRICT
MUNICIPAL COURT OF
nSTArEOFWASHINGTON
nCOUNTYOF

WlCITYfTOWNOF
CHEWELAH
THE UNDERSIGNED CERTIFIES AND SAYS THAT IN THE STATE OF WASHINGTON
PHOTO ID MA TCHED
NAME: LAST
FIRST

DRIVER'S LICENSE NO.

DNO

LARUEC*527LO
1045 KITT NARL:ISSE RD

LARUE

REPORT #

H1500190

=i

. PLAIIHIFF VS NAMED DEFENDANT


MIDDLE

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COL
DYES[ZjNO

CONNIE

Z
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en

ADDRESS

COLVILLE

99114

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CYJ
----I
CYJ

RESIDENTIAL PHONE NO.


M.P.
....... ,,,"-','\".................

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VEH L1C NO

STATE

EXPIRES

B44102Z

WA

01-02-15

TR#l L1CNO

STATE

EXPIRES

,BLOCK#

DID OPERATE THE FOLLOWING VEHICLEIMOTOR VEHICLE ON A PUBLIC HIGHWAY AND


VEHYR
IMAKE

1985

I~OOEL

TOYOTA

PU

TRYR

ITR#2 L1CNO

STATE

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uvu

ICOLOR

ITRYR

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99114

JBAC

COMMERCIAL

VEHICLE

EXEMPT
VEHICLE

=
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FIRE
LEA

;;;;;;;;;;

DID THEN AND THERE COMMIT EACH OF THE FOLLOWING OFFENSES

I VIOLA'nON/STATUTE CODE

46.61.020.1

UD v

\7EH OPR-REFUSE COMPLY POLICE

DD-V

2. VIOLAT10NISTATUTE CODE
l. VIOLA nONISTA TUTE CODE

DDV

4. VIOLATION/STATUTE CODE

[]DV

5. VIOLATIONISTATUTE CODE

DDV

-=-"1

;;;0

ISTYLE
PICKUP
IEXPIRES

-U
0

L.T"'\'U_' ..... VL.-I,._

ZIP CODE

1045 KITT NARCISSE RD

1045 KITT NARCISSE RD

NO

II., .... 1''I'''''''''~11I

CONNIE L SCHLEICHE~

OWNER/COMPANY IF OTHER THAN DRIVER


ADDRESS

ACCIDENT

....... uvnl

---

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;;;;;;;;;;

;;;;;;;;;;

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1 OF 2
IDATE ISSUED
02-02-15
MANOA TORY APPEARANCE
One of Ihe followinq oplions applies:
MANDA TORY COURT APPEARANCE
APPEARANCE DATE
TIME
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 1 1 . If Ihere is a date in the appearance date box you must appear in court at Illat dale and time.
Q] TICKET SERVED ON VIOLATOR
TICKET REFERRED TO PROSECUTOR
2. If there is a nUnOer in the appearance dale box you musl appear in court wllhin the number of days indicaled.
TICKET SENT TO COURT FOR MAILING
[Z/BOOKED
3. Iflhe appearance dale box is blank
.lhe court WIll notify you in wriling '.'1hen to appear. If you do nol receiv
CRJMINAl CITATION
a nollce wahin filleen (15) days please conlad Ihe court immediately.
_
.
.
.
.
When you appear. you 'Mil be advised of your consiliutional righls and Ihe pOSSible penallies if you are convicted.
You are charged WIth Ihe CrlmelS) deSCribed on Ihls form. You musl respond 10 Ihe court below.
You also may be asked 10 enter a plea of NOT GUILTY or GUlLTY.
RELATED#

STEVENS COUNTY DISTRICT COURT


215 S OAK. ROOM 213
COLVILLE WA 99114-2861
ourt Conlacl Info:
Phone 1: 15091684-5249
Website. wwwco slevens wa.usldislcourtlindex.htm
.
..
.

IF RCW LISTED APPEARS BELOW PLEASE READ


RCW 46.61.502 Drivinq Under the Influence fOUII
dnve a molor vehicle and p,lher: have a 0.08 or higher brealh or blood alcohol concentration or THC concenlralion of
5.00 or higher within 2 hours afler driving or be under Ihe influence of or affected by liquor. marijuana. or any drug. 0
IF YOU DO NOT APPEAR this may result a combination of 'quor. mdrlJuana. and any drug.

in a warrant for your arr-;Sl and .. .


RCW 46.20.342(1l[a) First Deqree Drivinq While Suspended/Revoked JDWLS)

d~te~tl~n on Jail. A:SO, If "Tra::.c '~


be an habiluallraffic offend~' and drive a motor vehicle wh~e an order or revocalion Issued under chapler 46.65

Ice<: e you may oseyour IVeI" s


I~cwprohibiting such o""'dllon is in effect.

hcenseJpnvllege.
RCW 46.20.342(1l[b) Second Deqree Drivinq While Suspended/Revoked (DWLS)

I ~;.,~~.Cit3tions may go on your driving

drive a motor vehicle while an order of suspension or revocalion prohibiting such operalion is in effecl. and nol be
oligible 10 reinslate Ihe ticense or driving privilege
RCW 46.20.34211l[c) Third Deqree Drivinq While Suspended/Revoked JDWLS)
drive a motor vehicle while Ihe license or priviege 10 drive is suspended or revoked fOf( 1) railLXe 10 rurnish proof of
f-'-=C-=E=R=T"'FY=-:--U"""N-=D-=E=R-=-P=E"""NA""""L-=TY:-O'"'F'-P""E-R"""JU---=-R-Y-U-N-D"E"R:-T'"'H-=E'"'L-A-W-'S-O"F=T-H=E-S-T-A-T-E-LO-F-W-A-S-H-IN-G-T-O-N-T-H-A-T-I-H-A-V-E-IS-S-U-E-D----lsatisfaclory progress in a required alcoholis m or d' .q trealmenl program: or 121 failure 10 furnish proof of financial
!THIS ON THE DATE AND AT THE LOCATION ABOVE. THAT' HAVE PROBABLE CAU,>E TO BELIEVE THE ABOVE
responsibility pursuant 10 chapler 46.29 RCW: or I~) railure 10 comply wilh chapler 46.29 RCW relaling 10 uninsured
NAMED PERSON COMMITIED THE ABOVE OFFENSEIS). AND I AM ENTERINe- MY AUTHORIZED USER ID Ar-o
'ccidents: or (4) railure to respond 10 a nolice of hallic .nfrachon. failure to appear at a requested hearing. violation 0
PASSWORD TO AUTHENTICATE IT.
a wrilten promise to appear In court. or failure 10 comply wah Ihe terms of a nolice of traffic infraction or cilalion: or
(5) suspension or revocalion in ~nolher state thai would nol resull in suspension or revocation in this slale: or 16)
failure 10 reinslate Ihe driver's license or privilege aller suspension or revocalion in Ihe second degree: or (7) Ihe
OFFJrER J. BOWERS
# 424
person has a suspension under RCW 46.20.267 relating to inlermediate driver's licenses. or any cumhlrliJlion oflhf'
OFl',cER
#
above.

PAGE 1 01

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INFRACTION

Q]TRAFFIC

LEA ORI #: WA0330100

DNON-TRAFFIC

COURTORI # WA033023J

INFRACTION#: 5Z0133879

IN lHE lZ]DISTRICT
DMUNICIPAL COURT OF
DSTATE OF WASHINGTON
COUNTY OF

STEVENS COUNTY DISTRICT COURT


lZ]CITYITOINN OF
CHEWELAH
THE UNDERSIGNED CERTIFIES AND SAYS THAT IN THE STATE OF WASHINGTON
FIRST
DRIVER'S L1CE-N-S-E-N-O-.-----~ls,."T,."A",TE~IE,...X...,P-IR-E-S-~I-PH-O'"'T'"'O-IDMATCHED I NAME: LAST

LARUE

REPORT#: H1500190

"
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PLAINTIFF VS. NAMED DEFENDANT

l>

MIDDLE

SFX

CONNIE

COLVILLE

-t

CDL
DYES [ZINO

Z
It
U-,
N

99114

EMPLOYER
RESIDENllAL PHONE NO.

DA TE OF BIRTH
IRACE
06-20-48
W
VIOLATION DATE
ON OR ABOUT 02102/2015 20:45
VEH L1C NO
B44102Z
TR#1 LICNO
. __ .

MP
BLOCK #

STATE
WA
STATE

DID OPERATE THE FOLLOWING VEHICLE/MOTOR VEHICLE ON A PUBLIC HIGHWAY AND


VEHYR
I~AKE
I~ODEL
1985
TOYOTA
PU
TRYR
ITR#2 L1C NO
STATE

EXPIRES
01-02-15
EXPIRES

ICITY/COUNTY OF
CHEWELAH/STEVENS

800

ICOLOR

WTYLE
PICKUP
IEXPIRES

ITRYR

CONNIE L SCHLEICHER
-:::cST:::cA:-::T:;:E-'lhZI"'Pc::CC;;O"'D-==E---------

II

ICOLVILLE

WA

EXEMPT
VEHICLE

VEH SPEED
IN A
ZONE
1. VIOLAllONISTATUTE CODE 46. 16A. 030. 5. L

FIRE
LEA

99114

DID THEN AND THERE COMMIT EACH OF THE FOLLOWING OFFENSES


ISMD L~ I IAIRCRAFT
FL RENEW:-.-'=Eo-!:Xii:p;;ilR =-E=D=-=R-=E'"'G=--<=---=2-=M=T==H.."S=---------------------------rI,,-PE=-NA-LTY-,-,$,----;1'""2,.,-4--;;.0'""0-!PENALTY$
[PENALTY $

4. VIOLAllONISTATUTE CODE

]PENALTY$

5. VIOLAllONISTATUTE CODE

IPENALTY$

20F2

lDATEISSUED

o
o

-_ .........

02-02-15

r'~

IIIMlt,

~,Ill

TICKET SERVED ON VIOLA TOR

IHI-::.I:\rr-nfWr'-IHII,W.I(!t'lllIi\lII-//\V/-I:,,IILn IIII:-.'Jt~ rHI 11/',rlAN[I' i rrll


,'\1 IIHUI,'I/[I 11):...1 I,' If 1"\~JlII'.-'\:-,:::v'\.'UI"[1 I OAl.IIIII:Jlrtc /\ll-If

"

~~~

D TICKET REFERRED TO PROSECUTOR

NOnCE OF INFRACTION
This is a non-criminal offense for which you cannol ~o 10 jail.
YOU MUST RESPOND WITHIN FIFTEEN (15) DAYS FROM "THE DATE ISSUED.
Your response must be postmarked bymidnighl of the dayil is due allhe court.
II you do not respond or a ,pear for court hearinqs:
TRAFFIC

NON-TRAFFIC

The court will find Ihal you commilled Ihe infradion.

The court w;1I find Ihat you commilled Ihe Infraclbn.

You may lose your dnve(s license privileqe.

II is a crime and will be treated accordingly.

Your penany will be increased.

Yo..- penally may be increased.

Failure 10 pay may rec'Jll in a referral of your case to a

Failure to pay may resull in a referral of your case 10 a


collection agency.
I
collection agency.
Check one orthe 3 boxes to the right, sign, date, and mail this fonn to:
Court conlacl information:
Phone 1: (5091684.5249
STEVENS COUNTY DISTRICT COURT
Website: YMIW.co.stevens.wa.us/distcourVindex.htm
To make online payments by credit card, please go to
215 S OAK. ROOM 213
www.stevenstix.com.

l\j(

fI,!tOl\lI\Wl'vE. l"Irr,IIII!\\/1 l'r"')lJi\J"iL[(

~"ll:'(

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=~

-==-=
----==
----

1,062.00

===

!iii!!!

==

lour til 'II nn {.IJl;1'1 11 .. fllllr'l",~~.i."'1

......',' .... 1.."

TICKET SENT TO COURT FOR MAILING

I,

==

!iii!!! 0

ITOTALPENALTY$ 1.186.00

rlll~t,'\v"'/H

,....,

---.J

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!iii!!!

3 VIOLAllON/STATUTE CODE

It I IHll','lll>.Jrrrl\1'[ Nl\l Ii" (~ I'III'JIII,", IINll[F


i iMMl1 rrri 1111 /dJeNI
'. if I-[N:! (:-1. :\fH.11 ;'.M l

en
rD

===

FJij [-T~:fYrELD-TOE-lVfE-R""G-E-fJe)T\7EHICLE

2 VIOLAllONISTATUTE CODE 46.61.210

." " ..... L..., .....

0-l

'

jCiTv

RELATED #

IWORK PHONE NO.

CELLIPAGER PHONE NO.

COLVILLE WA 99114-2861

o
o

"
I have enclosed a check or money order. ,n U.S funds. for Ihe amounllisted I understand IhlS will go on my
dnvmg record If "raffic" IS checked. DO NOT SEND CASH. NSF checks Will be trealed as failure 10 respond.
Mitigalion Hearing. I agree' have commilled Ihe infraclion(s). bull wanl a hearing 10 explain Ihe circumslances.
Please send me a court dale. and I prom,se 10 appear on that dale. I know I can ask w,lnesses 10 appear bul
Ihey are nol required 10 appear. I understand IhlS Will go on my driving record if 'traffic" 's checked. The court
may allow lime payments or reduce Ihe penally where allowed by law.
Contested Hearing. I wanllo conlesl (challenge) this infraction. I did nol commillhe infraction. Please send me
a court dale. and I promise to appear on thai dale. The slate must prove by a preponderance oflhe evidence
thai I Lommilled Ihe infraction. 1know I cLln require (subpoena) \"';Inesses. Including the officer who wTole the
Iicketto attend lhe heanng. The court wililell me hIM' 10 requesl a witness's appearance. I undersland Ihis V'JiIl
go on my driving record {I lose and "raffic" is checked.

NOTICE: You may be able to enter into a payment plan with the court under RCW 46.63.110.

.AJ

My mailing address is: (PLEASE PRINT)


Name:
Streel or PO Box
Slate:
Work:

ICilY:
Telephone: Home:
Dis interpreler needed? Language:

Ix:

At:
Zip Code:

o
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;T1

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(SIGNATURE.

5Z0133879
PAGE 1 OF 1

-f:>

CO

Exhibit 4
MOTION AND MEMORANDUM FOR DISMISSAL
showing TAYLOR conducted an illegal prosecution and
violated LaRues rights.

COpy

RECEIVED

ORIGINAL FIL~D

APR 14 2015

STEVENS COUNTY

PROSECUTING AnORNEY

DISTRICT COURT

STEVENS COUNTY, WA

IN THE DISTRICT COURT OF THE STATE OF WASHINGTON

IN AND FOR THE COUNTY OF STEVENS

10

11

CITY OF CHEWELAIL

Plaintiff,

12

13

14

is
16

NO.: 5Z133878

MOTION AND MEMORANDUM TO

SUPPRESS AND TO DISMISS COUNT 1

vs.
CONNIE LA RUE
DOB: 06/20/1948
Defendant.

17

18

19

MOTION

COMES NOW the Defendant, by and through the undersigned counsel of record, and

20

moves the Court to suppress the traffic stop due to want of authority of the arresting officer or, in
21

22
.

the alternative, to dismiss for lack ofjurisdiction ofthe City of Chewelah over the Defendant

23

with respect to the alleged course of conduct.

24

2S

BASIS OF MOTION
This motion is made pmsuant to the testimony put forward at hearing by Officer Bowers

26

27

on April 9, 2015, the law as set forth below, CrRLJ 3.6, CrRLJ 5.1, and the records herein.

28

MOTION AND MEMORANDUM TO SUPPRESS

AND TO DISMISS COUNT 1

GOLDEN LAW OFFICE P.L.LC.

298 S. Main, Ste. 203

Colville, WA 99114

509-684-6322

Fax 509-684-3286

LAW AND ARGUMENT

I.

Did the arresting officer exercise lawful authority when he arrested the Defendant

beyond the territorial boundary of the City of Chewelah?


4
5
6
7

RCW 10.93.070 expressly limits those occasions when a peace officer operating
under the laws of the State of Washington may make an arrest outside the bounds ofhis
jurisdiction. It is the understanding of defense counsel that the City will rely uPQn RCW

10

10.93.070*1) to establish that Officer Bowers had authority to operate outside the city

11

limits. That statute permits: "Upon the prior written consent of the sheriff or chief of

12

police whose primary territorial jurisdiction the exercise ofthe powers occurs." RCW

13

10.93.070(1). ''When an officer's authority to act under subsection (1) has been

14

cballenged, it is the [City] which must prove compliance with the statute's requirements."
15

.16

Ghaffari v. Department ojLicensing, 62 Wn.App.870, 875, 816 P.2d 66 (Div 1 1991).

17

At hearing, the City was not able to provide any evidence in support of the

18

proposition that Officer Bowers had authority to operate beyond the bounds of the City 0

19

Chewelah. Following the hearing, the City was able to provide via counsel a signed lette

20

from the Stevens County Sheriff's Office, issued in December 2010, authorizing all law
21
22

enforcement agencies in Washington State to operate under the Sherriff's authority in

23

Stevens County. it would appear that this is sufficient statutorily to render the officer's

24

actions lawful and within the bounds of the authority granted him under State law.

25

However, it does not permit the City authority to prosecute for actions outside its

26
27

authority or for its municipal court to extend jurisdiction to such actions.

28
MOTION AND MEMORANDUM TO SUPPRESS
. AND TO DISMISS COUNT 1

GOLDEN LAW OFFICE P.L.LC.


298 S. Main, Ste. 203

Colville, WA 99114
509-084-6322
Fax 509-684-3286

II.

May the City of Chewelah prosecute the Defendant for alleged conduct that, by
undisputed testimony, took place entirely outside the territorial boundaries of the

City of Chewelah?
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"Each county, city, and town is responsible for the prosecution, adjudication, sentencing,

and incarceration of misdemeanor and gross misdemeanor offenses committed by adults

in their respective jurisdictions." RCW 39.34.180(1),(emphasis added).

The municipal court shall have exclusive original jurisdiction over traffic
infractions arising under city ordinances and exclusive original criminal
jurisdiction of all violations of city ordinances duly adopted by the city
and shall have original jurisdiction of all other actions brought to enforce
or recover license penalties or forfeitures declared or given by such
ordinances or by state statutes. A hosting jurisdiction shall have exclusive
original criminal and other jurisdiction as described in this section for all
matters filed by a contracting city. RCW 3.50.020 (2008).

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legislature to violations of the city ordinances, which by definition may only be violated

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within thejurisdictional boundaries of the municipality. If a city has not adopted a state

the authority ofthe municipal court is directly limited by the Washington

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statute, it lacks the independent authority to prosecute crimes under that statute: "The
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City may not enforce a state law without having first adopted the state law by reference

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or having adopted a compatible ordinance." City ofAuburn v. Gauntt, 174 Wn.2d 321,

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323,274 P.3d 1033 (2012).

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The City of Chewelah has adopted state misdemeanors as follows: "Titles 9 and

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9A of the Revised Code of Washington and all laws enacted which may add to or

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supersede said titles are adopted as the criminal code of the city subject to the restriction

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that only those crimes which fall within the jurisdiction of the District Court of Stevens

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County for the city shall actually be tried by said court." Chewelah, Washington,

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MOTlON AND MEMORANDUM TO SUPPRESS
AND TO DISMISS COUNT 1

GOLDEN LAW OFFICE P.LLC.


298 S. Main, Ste. 203
Colville, WA 99114
509-684-6322
Fax 509-684-3286

Municipal Code, 9.04.010. The municipal code also defines the jurisdiction for the city

as ''the area within the territorial limits of the city of Chewel~ Washington."

Chewel~

Washington, Municipal Code, 1.04.010(A).


4

Thus, the City could prosecute for violations of Title 9 and Title 9A RCW that

occurred within its territorial boundaries. However, by law and statute, the City lacks the

authority to prosecute ordinances and misdemeanors outside the territorial limits of the

city of Chewelah. Per the testimony at hearing on April 9, 2015, of Officer Bowers, he

did not become aware of the illegal conduct for which he stopped the Defendant until he
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was already past the city limits; he initiated the traffic stop beyond the territorial limits of

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the City of Chewel~ and concluded the traffic stop and made the arrest beyond the

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territorial limits ofthe City of Chewelah.

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Even if Officer Bowers had the authority to act, the City of Chewelah still lacks

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the authority to prosecute misdemeanors that occur outside the territorial limits of the

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City of Chewelah. Further, the municipal court lacks jurisdiction to hear a case beyond

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those same bounds. The municipal court is created and defined by statute; its limits and

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constraints are defined by the ordinances of the City. The law limits the scope of the

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City's power to its borders. There is no evidence of any criminal activity within the
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City's statutory authority to prosecute; this failure of evidence places this case finnly

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outside the bounds of the municipal court's jurisdiction to hear and the City's power to

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act. Therefore, the case against the Defendant must be dismissed for want ofjurisdiction.

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RELIEF REQUESTED

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. Based on the foregoing, the Defendant respectfully requests that the Court enter an order
of dismissal.
MOTION AND MEMORAIlIOUM TO SUPPRESS
AND TO DISMISS COUNT 1

GOLDEN LAW OFFICE P.LLC.


298 S. Main, Ste. 203
Colville, WA 99114
5Q9..684..a322
Fax 509-684-3286

DATED this

J!i 11-day of 4~

,2015.

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4

Tereno, WSBA# 43245


Defendant

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MOTION AND MEMORANDUM TO SUPPRESS
. AND TO DISMISS COUNT 1

GOLDEN LAW OFFICE P.LLC.


298 S. Main, Ste. 203
CoMIIe, WA 99114

509-084-6322
Fax 509-684-3286

Exhibit 5
Order for dismissal of cases
No. 5Z0133878
&
No 5Z0133879

FILED
IN THE DISTRICT COURT OF THE STATE OF WASHINGTON APR 1 6 2015
DISTRICT COURT
IN AND FOR THE COUNTY OF STEVENS
STEVENS COUNTY, WA

2
3

IZJ CITY/TOWN OF CHEWELAH


Plaintiff,

vs.

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9

10
II
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CONNIE LARUE, a/k/a Connie LaRue

Defendant

No.5Z0133878

MOTION AND ORDER

~ DISMISSING CHARGE(S)

[Z] DISMISSING 3.2 CONDITIONS


,
DISMISSING DV NO-CONTACT ORDER
DISMISSING AH NO-CONTACT ORDER

EXONERATING OF BAIL

DISMISSING DEFERRED SENTENCE


DISMISSING DEFERRED PROSECUTION

o
o
o
o

The [gJ Plaintiff 0 Defendant 0 Court moved for and the court finds good cause to
Dismiss the Charge(s) of Refusal to Give Information to or Cooperate with Officer
[gJ Dismiss the Conditions of release set forth in the Rule 3.2 Hearing Order
Dismiss the Domestic Violence No-Contact Order
Dismiss the Anti-harassment No-Contact Order
D Exonerate the Bail posted
Dismiss the Deferred Sentence
.J . )
:.'
Dismiss the Deferred Prosecution
. .
For the following reason(s): Pending Further ReVIew and Determination RE: Venue/Jurisdiction

IZJ

D
D

D
D

NOW, THEREFORE, IT IS ORDERED that:


[gJ The charge(s) are dismissed D with prejudice ~ without prejudice
All conditions of release entered in the Rule 3.2 Hearing Order, and any modifications or
supplements thereto, are hereby dismissed.
The Domestic Violence No-Contact Order is hereby dismissed
The Anti-Harassment No-Contact Order is hereby dismissed
Any bail/bond posted herein shaJ.1 be exonerated.
The finding of guilt is withdrawn and the cause is dismissed with prejudice.

The deferred prosecution herein is terminated and the charge(s) of


_

=
against the Defendant is dismissed with prejudice

D The Defendant forfeits any property interests in any evidence seized.

IZJ

o
o
o
o
D

DATED this \G~ day of April, 2015.

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24

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Reviewedc:nd"A

.;I
.
l . /
DefendantlDefe'ndant's Attorney

27

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STEVENS COUNTY PROSECUTING ATTORNEY

29

215 S. Oak Street, Room 114

Colville, WA 99114

(509) 684-7500 fax (509) 684-7589

IN THE DISTRlCT COURT OF THE STATE OF WASHINGT~~R.

TN AND FOR THE COUNTY OF STEVENS

2
3

J 6 2015

;'" DI~,! /--:ICT COURT


STEVEN;:; COUNTY, WA

cg] CITY/TOWN OF CHEWELAH

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/1

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/9

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No. 520133879

MOTION AND ORDER

Plaintiff,

~ DISMISSING CHARGE(S)

DISMISSING 3.2 CONDITIONS


vs.

DISMISSING DV NO-CONTACT ORDER


DISMISSING AH NO-CONTACT ORDER
EXONERATING OF BAIL

CONNIE LARUE, a/k/a Connie LaRue


Defendant

D DISMISSING DEFERRED SENTENCE


DISMISSING DEFERRED PROSECUTION
The ~ Plaintiff 0 Defendant D Court moved for and the court finds good cause to
k8J Dismiss the Charge(s) of Failure to Yield Right of Way to an Authorized Emergency Vehicle and
Failure to Renew Expired Vehicle License Less than two (2) Months Old
Dismiss the Conditions of release set forth in the Rule 3.2 Hearing Order
Dismiss the Domestic Violence No-Contact Order
Dismiss the Anti-harassment No-Contact Order
Exonerate the Bail posted

Dismiss the Deferred Sentence

Dismiss the Deferred Prosecution .


.

For the following reason(s): Pending FurtherReview and Determination RE: Venue/Jurisdiction

o
o

o
o
o

D
D

NOW, THEREFORE, IT IS ORDERED that:


[gJ The charge(s) are dismissed
with prejudice k8J without prejudice
0 All conditions ofreJease entered in the Rule 3.2 Hearing Order, and any modifications or
supplements thereto, are hereby dismissed.
The Domestic Violence No-Contact Order is hereby dismissed
The Anti-Harassment No-Contact Order is hereby dismissed
Any baillbond posted herein shaJJbe exonerated.
The finding of guilt is withdrawn and the cause is dismissed with prejudice.
The deferred prosecution herein is terminated and the charge(s) of
-------------=
against the Defendant is dismissed with prejudice
The Defendant forfeits any property interests in any evidence seized.

D
D

22

DATED this
23

l~-t'

day of April, 2015.

~O
Judge/~

24

Reviewed and Approved

(.

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26

# 44789

27

Jessica L. Taylor, WSB


36248/

Deputy Prosecuting Attorney

28

./

br//7

!pr-a-\cff\

~ ZG/ZEJ
ant's Attorney

STEVENS COUNTY PROSECUTING ATTORNEY

215 S. Oak Street, Room 114

Colville, WA 99114

(509) 684-7500 fax (509) 684-7589

Exhibit 6
New Charge Notification of Infraction
STATE OF WASHINGTON v. Connie LaRue,
Case No. P7944
using the same illegal police report to justify
re-prosecuting LaRue to extort over $1062.

COPy

0RI

STEVENS COUNTY DISTRICT COURT


215 S OAK ROOM 213
COLVILLE, WA 99114
BUSN: 509-684-5249

FAX: 509-684-7571

GINAL FILED

MAY 0520'5

DfSTR
I
STEVEN fCT CaUR
TTY: 800-833-6388
I S COUNTY, "c"4

NOTIFICATION OF INFRACTION
Date Mailed: 4/24/2015

Name/Address

Connie LaRue
1045 Kitt Narcisse Rd
Colville, WA 99114

NAY

Case No.: P7944

-------

Amount Due: $1,062.00


Date Due: 5/9/2015

-------

0 vt~

?n._'J:]
r

. STEVENS CCJUNTY
'JHOr'>Er'lJT'
'
-'
i ,. ::-> o J . hG .6,'IORrJE'(

A notice of traffic infraction has been issued to you by a law enforcement officer and filed with this

court.

To respond you must check one of the boxes below, sign your name, and return this form to the ,court

by 5/9/2015

1.

I choose to pay the penalty and have enclosed full payment in the amount of

2.

J request a hearing to explain the circumstances. If you agree that you committed the
infraction but would like to explain the circumstances, the court will notify you, in writing, of
the hearing date. You may not require witnesses to appear at the hearing, but they may attend
voluntarily.

3.

I request a hearing to contest this infraction. If you believe you did not commit the infraction,
you may request a hearing, At the hearing, the state/city must prove by a preponderance of the
evidence (more likely than not) that you committed the infraction. You may require witnesses,
including the officer who issued the notice, to appear at this hearing. The court will notify you,
in writing, of the,bearing date and how to request that t"'itnesses be present.
'
\. ('

~. 'Sa ~

No:t:1.tL

cA In.\e\.\

$ 1,062.00

.\0 J\.pr'.M ~ -\-k was\.\;I-.~teN\. S~le.:rt\.e c.o~

-\u(

If you do not respond by 5/9/2015


, the court m\ist add an additional penalty of
$52.00 to the original
bail. In addition, your driving priviledge may be suspended until you have paid all the penalties ~equired
~

bylaw.

~'i~~()"""' l0".~ ,,~ WO~tA-tO"V\.J~~~ ot~ ~h.e~ 0.-a~


D"'I'ae.~
Rt-ul 1- \ \., .~<bP O\VWL t. \ Ie., '3\0

All traffic infractions must De reported to the Department of Licensing if you are found to have committed the
infraction.
.
enclose payment in full (if Box #1 is checked), or promise to appear (if Box #2 or #3 is

check~d).

Defendants signature:
Address (if different from above):

--,-

Phone number:

Court

Clerk:~....o ill, \JJ--.


J

Exhibit 7
WASHINGTON DEPARTMENT OF LICENSING
NOTICE OF SUSPENSION

STATE OF WASHINGTON

DEPARTMENT OF LICENSING
PO Box 9030. Olympia, Washington 98501-9030

CERTIFIED

Notice of Suspension

06/09/2015

ABFf
LA RUE,CONNIE
1045 KilT NARCISSE RD
COLVILLE WA 99114-9711 .

Lie. # LARUEC*527LO

On 07/24/2015 at 12:01 a.m. we will suspend your driving privilege because you failed to respond, appear,
pay, or comply with the terms of the citation below:
Citation number
P00007944

Violation date
02/0212015

Reason for Citation


Fail To Yield-Emgy Veh

What do I have to do?


1. Use the contact information below to find out how to take care of this citation:
Stevens Co Dist Ct District Court

215 SOUTH OAK

Colville WA 99114-2861

(509)684-524.9

2. Don't wait until the last minute. We must receive and process proof that this citation has been resolved
prior to your suspension date. Processing can take 7-10 business days from the date we receive it. Ask the
court to notify us as soon as this matter is resolved.

Will DOL notify my state of record?


Washington State will notify your state licensing department about this Washington suspension. It is your
responsibility to check with your state of record.
What happens if I don't resolve it?
Your driving privilege will be suspended and any Washington driver license or permit, including
occupational (ORL) or ignition interlock licenses (IlL), will not be valid. Your license must be returned
to Department of Licensing, PO Box 9030, Olympia, WA 98507-9030. You will be charged a non
refundable reissue fee, along with other applicable fees, to get your license back.
What other options are available?
You can contest this action by returning the enclosed form or a written request postmarked within 15 days
from the date of this notice.
We suggest that you always check the status of your driving privilege before you drive. Find out more at
www.dol.wa.gov or by calling Customer Service at 360-902-3900.
Driver Records

Authority: RCW 46.20.289

The Department a/Licensing certifies that this document was mailed via US post office on 0610912015 to the person named herein at the address
shown, which is the last address a/record with the Department.

We are committed to providing equal access to our services.

Ifyou need accommodation, please call 360-902-3900 or TTY 360-664-0116.

52987085

Exhibit 8
WASHINGTON DEPARTMENT OF LICENSING
DELINQUENCY NOTICE

STEVENS COUNTY DISTRICT CO


215 S OAK ROOM 213
COLVILLE WA 99114

509-684-5249

JuneS 2015

414785
CONNIE LARUE
1045 Kitt Narcisse Rd
Colville WA 99 114-9711

RE, FAIL TO YIELD TO EMERGENC

Case Number:
Violation Date:
Balance Due:

DELINQUENCY

P00007944 SCS IT
06-05- 15
$ I I 14.00

NOTICE

YOU MUST PAY IN FULL WITHIN 30 DAYS OF MAILING.


Your account balance is past due and needs your immediate attention. Ifpayment in full is not received within 30 days,
your account will be assigned to Armada Corp. and may be reported on your credit bureau files. In addition, a collection
fee will be assessed pursuant to the provisions ofRCW 19.16.500. Depending on your balance, the additional costs may
range from 40% to 100% of the current amount due.
Please remit the full amount owing. If you have any questions regarding your balance you may call 509-684-5249.
It is suggested that you pay with cashier's check or money order as payment by personal check may cause delays in
processing/resolution of this account. Do not send cash.
USTED DEBE DE PAGAR LA DEUDA ENTERA DENTRO DE 30 DIAS DEPUES DE QUE RECIBAN ESTA
CARTA.
Su saldo de cuenta esta sobre pasada y necesita su atenci n inmediata. Si el pago no es recibido dentro de 30 d as, su
cuenta ser asignada a Armada Corp. Y puedemos informales a sus archivos de la oficina del cr dito. Adem s, un honorario
de colecci n sera argregara de acuerdo con la ley de RCW 19.16.500. Dependiendo con su balance, los costos adicionales
pueden recorrer de 40% a 100% de la cantidad actual debida.
Remita por favor la cantidad que debe. Nota: Si usted ya tiene un plan de pagos en existencia este nueva multa NO es
incluida. Si usted tiene cualquier pregunta sobre su cuenta 0 sobre su balance por favor de llamar al 509-684-5249.
Gracias.

Se Ie sugiere que page por cheque bancario 0 money order por la razon que cheques personales pueden causar
retrasos sobre el procesos y resolucion en su cuenta. Por favor no manden dinero en efectivo por coreo.
427-HWARMA01-252-1/06/10

*** Please detach the lower portion and return with your payment -k*,.
Y18C5FBCD8

111111111111 11111111111 11111111111111111111 ""1111111111111

PO Box 505
Linden MI 48451-0505
ADDRESS SERVICE REQUESTED

Case #:
Balance Due:

P00007944 SCS IT
$1114.00

June 5 2015

II, ,'II I, I' 11'1 II 111 11 I' 'II II II'" I II II, 'I 'II, I', ,"I" 111111
0008120024016525855799114971145-1YA1-Y18C5FBC08427

252 - 427

CONNIE LARUE
1045 Kitt Narcisse Rd
Colville WA 991 14-9711

STEVENS COUNTY DISTRICT CO


215 S OAK ROOM 213
COLVILLE WA 99114


CHEWELAH MPO
CHEWELAH, Washington
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06/30/2015 (509}935-8801 10:44:24 AM

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