FILED

13 OCT 31 AM 9:43
1

KING COUNTY
SUPERIOR COURT CLERK
E-FILED
CASE NUMBER: 13-2-37129-4 SEA

2
?

KING COUNTY SUPERIOR COUR]I

STA'TEOF WASHINGTON
6
7

E:

lJ LOGI

lA

lvl

0 FIALES -CAYETAN O.

/r marrir:cl worTl;dh,

Plaintiff,

Case No.:

vsi.

I
10
11

12
13
14
15
16

CITY OF SE:I\TTLE,
a Washington nruniciplal corporation;
JOHN DIAZ and "JAllE DOE"
DIAZ, hus;barnd and wife, and the
marital comrnunity of them compriseri;
BIUNDON EGGERS and "JANE DC)E,'
E:GGERIS, husband and wife and the
nriarital comrnunity of Lhem comprise(l;
LlI\DSA,Y C. IBFIOWN and "JANE DC)E,,
BFIOWI',!, husbarnd anrlJ wife and the
nrarital comrnunrity of t,hem compriserl;
DIVID l-. BlrLlE:R and "JANE DOE,
EAUER, frusbrand and wife and the
milrital comrnunrity of them compriserl.

SUMMONS

Dc'fendarnts.
17
18

TO THE DEFIHI\IDANI.S:

19

A lawsr-rit lhas bt>en started against you in the above entitfled corurt by Eulogia
[Vlorales-Caye,tano, Plaintiff. Plaintiff's clairn is stated in the writllen cormplaint, r]opy,ref
it
which is serverd upon !'ou with this summons.

20
21
,22

In ordr--r trc defenrd against this lawsurit, you must respond to the complaint
by
stating your <tefense inr writing, and brl serving a copy upon the person signirng
this
slJl"nmons within 20 days after the service of this summons, if se,rved wiil-rin
of the statr:r of

"23
SIJMMONS
"24

Page

ARMIJO LAW OFI=ICE

917 North 2nd Street
Tacoma,

WA

98,103

washington, and 60 days after tfre s,-5rvic) of this

summons, if served outsiide of the sitate
of washington, excruoring the daf of
servic:e, or a defaurt judgment may
be enr.e,red
against you without notice A de{auft judgnnent
is one where plaintiff is entifled tro whiat
(s)he/they aslk(s;) for because, yofr
have not responded. lf you serve a notice
ojl
person, v,ru are entitted to notice before a deraurt

Jffffii:ildersisnred

10
'11

'12

13

You miay cjernand tl'rat the plaintiffs file this

lawsuit with the court. lf you do so, *he
demand must bre in writing and n'iust be served
upon the person signing this surnmons.
within 14 days after you servr3 thp demancl, the plaintiffs
must file this lawsruit wiith the
court, or the service on you o1'thip summons
and complaint will be void.
lf you vrrish to serek the aOriice ,lf an attorney
in this matter, you should do so
promptly so thrat your vrritten resdonse,
if any, may be served on time.
This summons is issued prttranf to rule 4 of
the Superior court civil Rules of tfre stiate
of Washingtorr.
DATED this 25th day

of

October, ZO13

ARMIJO LAW OFFICES;

14
1t5

Attorney for Pilaintiff

16
17
18
19

Address of Plaintiff's Attorneyr:

20

917 N. Second Street

Tacoma, WA 98403

21

22

PH:

253-627-AT7T

FAX: 253-627-A200
e-mail: sergio@arm ijolawoffic,e.

23
2,4
ARMIJO LAW OFFICE
917 North 2no Street
Tacoma, WA 98403

comr

,i
4
5

I(ING COTTNTY ST]PERIOR COURT

STATE OF WASHINGTON

EIJI.OGIA

MORALES-CAYETANO

10

12
13

I4
15
16

t7
18
19

Cause No.

Plaintifl;
11

a married wornan,

v.
CITY OF SEA.TTLE,
A V/ashington municipal
JOFIN DIAZ and "JANIj DOE"
husband and'n,ife, and the miuital community
of them comprised; Bzu\ND(lN EGGERS
and "JANE DOE" EGGIERS, husband and
wife, and the marital colnmunity of thenr
comrprised; Lil{DSAY C. BR.OWN and
"JOHN DOE" BROWN, husband and wife
and the maritallcommunity otf them
comrprised; DITVID L. B|AUIjR and
"JANE DOE'BAUER, husband and wife
and the maritallcommunity o:f them

corporation;
DIAZ,

) COMPLAINT

FOR DAMAGES

)
)
)

comLprised;
20

DefendanLts.

2T

22

CO.MES NO'W the pJ.aintiff by and through her attorney

23

and. complairr and alleges as follows:

of record,

Sergio Arrnijo,,

24
25
26

COIIPI,AINT FOIB DAMAGEiS

ARMIJO LAW OFFICE

1

of14

917 North Second Street

Tacoma, Washington 98403
Ph: e53) 627-8777 Fax: (253) 627-ti200

I.

Or
h

4,

E,

1.1 Plaintiff

PAR,TIES AND JURISDICTION

EUL,OGI:A MORALES-0A\|ETANO was,

at all 1;imes mater:ial.,

resirlent of King count5', washington, and. is competent to bring

a.

on the present;

claim.

6;

aI

1.2. Defendarnt CITY

oF

SEATTLET is, and

at all times mentionedl was, a municipal

corporation, duly orgamizerd under the laws of the state

of washington,

and situa.ted

in King County.

10
11
12

1'3' Defendant JOHI\I DIAZ at al,t times relevant was, Chief of the Seattle police

13

Department.

L4

In particulzr, he was appointed interim chief in May,

confi'rmed as Chief of the Seattle Police

inAugust

2009, and

2010. He then served. as Chierf of

15
16

the lSeattle P'olice continuouLsly unt;il his retirement on April g,

L7

mentioned, firom Mu:F, 2009 until April

18

employee

19

20

g, 2or},

21018.

At all

tirnes

defendant John Diaz was an

of defendarnt City, was e,mployed as Chief of the City of Seattle,s police

Depztrtment, and, in e:ngagfng in the acts and omissions described

below, acted. with.in

the course antl scope

o:f

that employnrent.

2I
22
23

1'4' lDefendant BRANDOI\I EGGERII, City of Seattle police offrcer

#7sg}, is, and at

24

all times relevant was, a rresident of King County, Washington, and a police office:r of

25
26

defendant Citly of Seatrble. In engaging in the acts and omissions descrribed below.
Brandon Eggers, acted within the course and scope of his employmerrt.

COMIII,AINT FOR DAMAGES

2 of.14

ARMiJO I,AW OFFICEI

917 North Second Street
Tacoma, ![ashington g8408
Ph: e53) 627-8777 Fax: (253) 627-8200

1'5 Defendarrt LINDX]AY BllOWN, City of Seattle police officer

#'trs36, is, and at all

2i

times relevant was,

a.

resident of

lfing county, Washington, and a police offrcerr. oll

defendant City of Seattler. lln engaging

in the acts and omissionrs described

bel<lw,

Lindsay Brovi'n acted witlLin the cou.rse a.nd scope of her

employmenLt.
6
7

8
9

1'6 Defendant DAWD| BAUFIR,

city of serattle police offrcer #b0g6, ris, and at all times

relevant was, a resident ollKing cou.nty, washington,

and a police officer of deferndant

10

City of Seattle. In engaging in the acts and omissions described

berlow, Davitl Bauer

11

acted within t;he course and srcope of his employment.

12
13
L4
15

r.7 At all times relevarnt, ,ceirend.ant cITy oF SEATTLE

was responsible for all acts
and omissionsr of its ag;ents and employees in the
instant matter under the doctrine of
yespondeat su:perior.

16
17
18
19

20
27

tr-.8-

The defendants Jolhn

f)iaz and "Jane Doe', Diazi Brandon

Eggerrs and

'fJane Doe" EE;gersi Lindsay (J. Brow'n and "John

Doe" Browni and David Bauer

''d

22

'iJane Doe" Ba'uer at arll tirnes relevant comprised

a marital commu:nit;y.That all acts

23

4'nd omissions

of John Diaz, Brandon Eggers, Lindsay C. Brown, and David B;auer,

24

4s complained of herein, were performed by them for, and on behaltf of thernsielrrers

,

25

and the maritaLl commurnity of'them comprised.

26

poMPLATNT FOR:DAMAGES

ARMIJO LAW OFFICE

North Second Street
Tacoma, Washington gg403
Ph: (253) 627-87",77 Fax: (z5g) 627-8200
917

3of14

1.9.
2l

All

actsr

of the above identi:fred

Defend.ants

giving rise to liability

iin this;

Complaint occurred ilr King County, Washington.

4l

1'10' Plaintilf, throug;h undersigned counsel, filed

;

1',

by the City

o:f

Claim for Da:mages form issued.

Seattle with the City of Seattle in Februa

ry, 21r1..IJecause more t;han

sixty days haLve passerd since this filing, this court has jurisdiction pursuant
t<l RCW

4.92.II0.

I
10
11

1.11. Jurisdiction and venue are proper in King county, washingtorr

72

II.

13

FACTUALBACKGROUND

I4
15
16
T7

18
19

20

2'r on or abo'ut Novelmbe:r 4, 20ro, at

9:00 p.m.

plaintiff Eulogia

,Morales-CaJretano

"l\Is' Morales"), her husband Rufino ocampo Estrad,a ("Mr.

ocilmpo,,), their

son

mmanuel ocampo-Elstrada ('Emmanuel"), and Ms. Morales,

nephew Magtlaleno
re on the p:remises 0f the Viking llank at 5701 First
Avenue, Sealltle, Kirrg Cou'ty,

ashington.

2L
22
23
24
25

'3 At the date and tiime noted. in Paragraph 2.1 above, plaintiff.Ms. Morales. Mr.
po, Emmanuel, a.nd nflagdaleno were invitees of Viking
Bank, in that they had a

tract to cleian the ptemirss &t thal; date and time.

26

CO]VIPLAINT FOR DAMAGES

ARMIJO I,AW OFFICE

4of14

917 North Second Street

Tacoma, V/ashington g8403

Ph: (253) 627-8777.Fax: (253) 62?-8200

l
2l

2'4Plaintiff lMs' Mordrles, Mr. ocarnpo, Emmanuel, and Magdalenro

are Hispanic

andl

al

natives of Merxico.
A

6;

2'li Also ia't or about g:00 p.m. on November 4, 2010, d.efendanb lJrandon

("Officer Eggers"), was dir;patched to the Last

Chance Chili Shack (hereinafter ,,Last
Chance"), a tavern a0ross the street from the Viking Bank
referenced

9
10
11
T2

.Eggers

in paragraph

2'1 above, refbrenc a complaint that two male patrons that

had beern ord.ered to leave
thr-' tavernL forr

bringing al:ohol from outside onto the premises were hovering

eround

the front door and staring the bartender down in a threatening

manner.

13

I4
t5

'6 shortly before the distrratch, Emmanuel and Magdaleno, havinLg completect their

16

assignments on the Vildng Bank clearring contract, entered

the Last Charrce. and

17

conftont'ed by tltre bartender, who accused them of

trying to bring bee* from

18

ide into t.he tavern. Emmanuel and Nlagdaleno,

however, left the Last chance

19

ithout incident.

20
2T
,.r.

23

24
25

Emmanuel and MagdaLleno, although leaving the premises

of t.he Last ch:rnce

not leave the vicinity of the Last Chance, since they had
been workirrg with
iintiff Ms. l{orales ernd LMr. Ocampo at the Viking Bank.
They stood by tJhe door
tside the Larst chanoe, waiting for Mr. ocampo to pick them
up in.his car.

26

F'OR DAMAGES

ARMIJO LAW OFFICtr;

North Second Street

917

5of14

Tacoma, W'ashington gg403

Ph: e53) 627-87,77 lrax: (253) 627"a200

Mr.

Ocampo p,icked EmaLnuel ani. Magdaleno

up and brought them

bacl< to ther

4
5

parking lot aLdjacent to the Viking Bank, where they stood rvith Mr. Ocampo by

family car'.. llhe Lasl

ChaLnce

barte,nder had observed their continued prese.nce,

ther
ztndl

alarmed, l[adlcalled t]he Serattle Police.

,7

8
9

Emmanuel then vrralked away from the family car to the entrance of the Vriking

2.'7

Ilank to

.nreet lhis mr:rther,, Ms. Morales, who was walking out of the bank.. plaint;ifll

10
11

Ms. Mo:rales, M.r. C)campo, EmanueJ., and Magdaleno were prerparing t6 go hpnne.

I2
13
74

2'13

Officer Eggtlrs lirst con.tacted thr: complainant bartender i.nside ther Last Chan,:e,

an-d obtai.necl ]her descrip,tion

of the situation and her

co.ncerns a.bout EmanLuel,

15

16

t7

Magdalen,D, aLnd Mr. ()campo whom she apparently believed were me:nacing 1;he l,raLst

Chance teL'irern.

18
19

20

2.9 Office.r Eg;gerrs nex:t con,tacted thr: occuLpants of the family car in the parkiing lot
:next to

1;hc,

Vjiking

JBa:nk. A.t

this time Mr, Ocampo was sitting;in the driver's sieat and

21

,9

.Magdalen.o was sittinill

in the back s,tat.

23

At tht,r timer that 'tffficer Eggers

24

i2"l-0

25

parking

26

iLrr

lo1; nelxl;

to

bhe

contaLcted.

the occupants of the farnLily car iln thLe,

Viking Bank, there were at least three Seattle pol.ice ojfrcersi

at least two squad oars present at the scene to investigate plaintiffs' activiti,es.

,A'dditional officers may harre been plesent at the time or shortly therea.fter.
COMPI,AINT FOII DAMAGE$;

ARMIJO LAW OFFICE

North Siecond Street
lfacoma, Washington gB40B
Ph: ebg) 627-8777 Fax: (2bB) 627-Bt0o
917

6of14

2
3

Mr.

mpo forr his driver's license and then he conductrgrl a

computer l:heck. of ther drir,rers

Offrcer Eggers was accompanied by defendarnts

2..11 Officerr Eggers asked

David L. Eiauer (hereinafter

r Bauer")and defendant Lindsav C. Brown

("Officer Eirornrrf') in the in

tion of'the occupants of the family car. The tlrree

4
5

6
n

defendant police offir:ers kept yelling

dashboard

anLd

Magderleno to

at Mr.

Ocampo

to keep his

handsi on l;he

his ha:nds on the back of the driver's seat.

8
9

2.'I2 Officr 1;u,r.r, according to the incidr:nt report, saw Magdaleno remove his ha,rrds
10
11

from the back of the driver's seal; too ofben and ordered him out of the, car for

72

in',ze

stigatj ve dertentio:n.

13
T4

2.113

Both Mr'. Ocampo anLd.Ma

leno umderstand English to only a limited extent,

15

and did not understernd

bhe

16
17

commands. Both were becoming increasirrgly

frilghtened,

18
19

20

2.1.4 Immediately after Ms.

Emmanue]l e:xited thr: bank a

les' nephew was detained, Ms. Morales

&nd

routi:nely setting the alarm as their last wo,rk

2l
assignment fcrr the evening.
22
23

fbcurse,d

intenselrr on

were slhocked and confused bv the police presenrse,

. Ocamp'o and Magdaleno.

24
25

26

CCINPI,AINT FOII DAMAGES|

ARMIJO LAW OFFIC]E

North Second Street
Tacoma, Washington 98403
Ph: (253) 627-8777 Fax: (253) 627-82tO0
917

7 of14

Deferndants Officer Brown and Offiaer Bauer, apparently alarmed by Ms. Morales

'nd

Ihnrnanuel L:aving the trank well after business hours, on top of the he:ighterrred

.f

t;ension
4
5

in the investigati.rre detentircn of Mr. Ocampo and Magdaleno, rushed at I{s.

Morales and.Emmanuel and forcibl5'pushed them against the wall of the ban.k.

6
7

2.-15 Emmanuel,

the onl'y one of

'bhe group

who could speak English, repeatedly

demanded to know why the police were there without a response from Officers
Bro'wn

o,r rfauer. olflficers Brown and Bauer reacted

10
11

d.e.mands, ancl began treating, shovin.g, and

with force

to Emmanuel's verbal

grabbing him.

72
13

I4

2'l'9 Ms. Morales

beElged Officers Brown and Bauer

grabbing Emtnanuel in Spanish, and, as

ra

to stop beating, shoving,

,and

result, the offi.cers began beating, shov:irrg,

15

and grabbing Ms. Morales.

16

L7
18
19

20

2'20

Mr'

ocarmpo tried to

run to th.e aid of Ms. Morales and Emmanuel, and, as a

result, he was beaten, shorted, and g:rabbed by Officer Eggers and accordingly
kepb in
the vicinity of the family czr by Officer Eggers.

2I
22
23
24
25
26

CO]MPLAINT FOR DAMAGES

ARMIJO I,AW OFFIC]I

North Second Street
Tacoma, Washington g8utO3
917

8of14

Ph: (253) 627-8777 Fax: (253) 627-820A1

I
,.

2.2L

Mr.

Ocam

misdemeanor

booked,

in

Seattle

and charged

with first

degree trespass and

Court. The charges were subsequently

dismissed.
4
o

2.22 Ms.

misdemeanor

of

also booked, jailed, and charged with

Em

ult in Seattle M

Court. EEmanuel was convicted. on a plea

guilty and

I
10
11
T2

2.23PlantiffMs.

Emmaniuel all had to receive medical

treatment for

13

I4

Plaintiff

al$o

l5
$he
16

I7

months

witI
and

severe emotional distress and mental

umatic stress disorder and had to receive
treatment, including medication.

18

t9
20
2L

22
23

24
25
26

ABI\4IJO I,AW OFFICE

917

North Second Street

Tacoma, Washington g8408

Ph: e53) 627-8777 Fax: @ffi) 627-82ff,

z,

III.
3.

I I'laintiff

zrdo

FIR$JT CAUSE OIF ACTION: NEGLIGENCE

ts and reall.eges Paragraphs 1.1throug]'2.24of this complain.t

as set forth irr fu I here.

I
8
9
10
11

72

3..L When O

Br'wn and Bauer began shoving, grabbing kicking, and beating

Ms..Morales. an Emrnanr'el, they breachLed their duty to

act in a reasonable an,d
prrrdent manner y their initial offe'sive touching plaintiffs
of
Ms. I/Iorales arrd their
suicsequent use

excessive fbrce

ag'inst plaintiffs Ms. Morales. Defe'dant

poh.ce

officers' actions

re unreasonable :rnd totally without justifrcation.

3.2ll.s a direct

proximatr] result of the' tortious conduct of defend.ants

as de,scrilled

13
L4

15

abov'e,

plaintilff

113

t'7

Morales tras sufilered. damages as described bel'w

in

(entitled "Danla

s" ) of thiLs Complaint.

3.3 Defendant

nDiaz

secti'' !..

1B

19

20

defitndant police

arnd

defend:lnt c.ity of seattle had a duty to e'sure thal;

Eg;gers, Brown, and Bauer, had the proper

and special

21

22i

trai.ni.ng for the d ties that said defendant police

officers could forese,eably be
expected to

in the cou.rse of t;heir employment with defendarrt city

of fieattl:,

24

espr:cially withL

rd

25

espr:crially with. re

23;,

26

arrerst other inrili

forc,e t,o

control.

1;o

deter:mination of probable cause to detain and arrest,

1;o

the a.pplication of the use of force to either c'ntrol, detain,

or

uals, and in the determination of when

a'd

it is appropr:iate to use

or a:rrest other indi'yiduals.

COTTPI,AINT FOR

ARMIJO LAW OFFICE

North Second Street
Tacoma, Washington 9g408
Ph: e53) 627-87",77 I'ax: (253) 6,,27.8200
917

10 oI'14

!1.5

Defendarrt,John L)iaz and defen,lant tOity of Seattle breached

the dut:ies

referenceilin. paragrzr.ph 8.4 above, rlnd, as a proximate cause

of their lbortious actsi

and omission.s, plaint;iff Ms. Moraler; has suff'ered damages as

described below in

Section V. of this Con:rplaint.

IV. .\TIOI,ATION
SECOND CAIJSE OF ACTION: STATUTORY

()F CIoNSTITUTIONAL RIGHTS

9
10
11

4.1 Plai.ntiffs adopt a.nd reallege paragraphs 1.1 through

B.b.

I2
13

4'2 This cause of action arises unrler the lJnited States

Constiturtion, part,iculrrly

74

'under the provisions of the First,

Fourth, Eighth, and Fourteenth Amerndlmenl;s of the

15
16

lU.nited StaLtes; Constitution, and, under

fi:deral law, under the CiviJ. Rights Arct, T,ible
,L2

77

of the Unit;ed States Code, Sectiorr 1ggl3.

18
19

20

'3

The co:nducl; of deibndants as der;cribed above,

acting under color: oilstate law. .nLd

ting rec'klessl;y in a grossly negligent rnanner, and with deliberate

indifferencer

2L

,.,

laintiffs r:ights, privijleges, and imn.unities,

25
26

plaintiffs of the right to be fb,e,e

unreasonalrle sezrrches and seiz;ures, including the use

23

24

<Ieprived

he

1;o

of excessi.ye

force. urrrlrerr

Fourth Annendmerrt of the u.S. (lonstitutioni and the right

not to be depr:iveil, of

rty, or p'roperfty without due process of law and to be accorded the

equal protect.io.n
the laws unrler the li'ourteenth AmendnrLent of the u.s. constitution.

OOMPI,AINT I'OR DAMAGES

ARMIJO LAW OFFICE

North Second Street

917
11

of 14

Tacoma, Washingl;on gg4t)B

Ph: (253) 627-87'77 tr'ax: (253) 6"27-82CtO

2.

4.4 As a dii

anrl proxima

.J

Paragraphs

1."1

4
5

through 5.3

cause of the acts and omissions as describerl

ln

bove,

phintiff has been damaged

AS

described in

"Section V. Dam ges" belc,w.

6
7

DA]\4AGES

8
9

5.1

Plaintiff

ts and

10

ges paragraphs 1.1 through 4.4.

11

I2

.2Asa

13

I4

direc.b

and pro.xima

above, pla.lntiffs

ting in med

I e,xpenses

15

ntitled to fair: a

result

of

defendants, actions and omissions as

suffered severe physical and mental injuries,

rtther out-of-pocket expenses, for which they are

reasonaLble

16
T7

18

Asa

19

ibed above.

20

mployment,

ano pr0xrma

aLntl

lainl;iffs have
entitled to

2l

result of defendants' actions and omissions ils

fifered loss

in income from their respective fbrmsi of

ir and rr:asonable compensation.

22
23

24
25

.4 As a direct

pro:rimeLte

t of defi:ndants'actions and omissions as describ,e,d

bove, plaintiffs

ve sruffered

physical pain and suffering, and. are entitled

1;o

ir and reasonab

26

ARMIJO I,AW OFFICE

North Second Street
Tacoma, Washington 9g408
917

12 o1'14

Ph: (25S) 627-8777 Fax: (253) 627-8200

1
f

2
J
4,

{i'5 As a direct arrd proxintate result; of de,fendants'

acts and omissions, plaintiffs

havr: suffered menta'l anguish and emotional

distress, and are entitled to fair

ernd.

reasonable compensal;ion.

6
7

ti'6 'As a direct arrd proxinrate resuh; of

civil rights

9
10

asr

tLLe

violations of plaintiffs, Constitutional and

pled in Paragraphs 4.1 through 4.4 under

Title 42of the unitetl states

Oode, Section 1gEg, plaintiffs are enrbitled to punitive

damages.

11

wHEr[EFoRE, plaintiff Eulogia

T2

13

]vlorales- cayetano prays fo:r judgmenl;

againstdefenda'ntsserveretllY, individually, and

as a marital commu.nity, as fol.lows:

I4
15

1'
1,6

r'7
113

19

2t)

F'r

special damagesr as detailed in para.graphs b.2

and b.B above.

2. Ilor general darnages as detailed

3.

i'par'graphs b.4 and 5.b above.

l'or punitive damages as d.etailed in par:agraph 5.6 above.

4. tr'or reasonable attorneys, fees.

5. For prejudgmenLt interesb on

all special damages.

2tl

6. trbr costs and disburisements hereirr.

22t

zil

7' F or such ottrer

amd fiurthrer

relief as the rOourt

d.eems

just and equitable.

241

25;
zei

COMPI.AINTFOR DAMAGES

ARMIJO LAW OFFICE

13 oii 14

917 North Second Street

Tacoma, Washington gg403
Ph: (253) 627-8777 Fax: (253) 627-8200

4
5

Dat;ed

th's 2'irh d]ay

Oc1lober. 20

Respectfully submitted,
ARMI4Q LAW OFFICE

I
Attorney for Plaintiff
Eulogia Morales- Cayetano

l:0
1.1

72
13

L4
15

16
L7
1rB

1t9

2t)
2.1

2t,

zil
21t
2E;

2(i

FOR DAMAGES

ARMIJO I,AW OFFICE

1! of 1a

917 North Second Street

Tacoma, Washington gg403
Ph: e53) 627-8777 Fax: (zs3) 627-8200