2010 11 23 Smith Motion to Compel FH1, LLC_Page_011
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ANDREW & CYNTHIA SMITH,
V&
CITY OF YELM, et a].,
Plaintiffs, I NO. 09-2-02879-3
Defendants. CIVIL NOTICE OF ISStJE (NTIS)
I Clerk's Action Required
TO: THURSTON COUNTY CLERK and to all other parties listed herein:
PLEASE TAKE NOTICE that an issue of law in this case will be heard on the date below and
the Clerk is directed to note this issue on the calendar checked below.
Calendar hates December 3, 2010 Day of Week: Friday
IMPORTANT WARNING: If this Notice of Issue is not timely filed, contains a wrong day or
date. or is scheduled for a wrong calendar date, your hearing will not be scheduled. You will. not
be notified.
Bench/Judge Copies: Deliver to Superior Court, Building 2, Rm. 150
Filing Deadlines: By 12:00 noon, 5 court days preceding the scheduled hearing date [LCR 5(b)(2)]
Confirmation: Confirm at www.co.thurston.wa,us/clerk by clicking on I fearing Confirmation, by faxing
to (360) 753-4033. or by calling (360) 786-5423 by 12:00 noon three court days prior to
the hearing date [LCR 16(f)(2)].
Court Address: 2000 Lakeridge Drive SW, Building 2, Olympia WA 98502,
X CIVIL M0'1`10NS (Friday — 9:00 am) Type of Motion:
CONPIRMATION REQUIRED
0 Default
ASSIGNED J17DGE:
0 Judge Paula Casey 0 Discovery
X
Judge Thomas McPhee
.3 Summary Judgment/Dismissal
0 Judge Richard D. Hicks
C1 Judge Carol Murphy 0 Change Venue
- - - ------------- ------- ------ - ---------------------- Cl Continue Trial
771 UNLAWFULDEI'AINERS (Friday-, 10:00 am)
CONFIRMATION REQUIRED 0 Show Cause
---------------------------------- -------- -----------------
- - - - - 0 Present Order
rl DOL REVOCATIONS (Friday -9:00 am)
CONFIRMATION REQUIRED 0 TRO/1refirninary Injunction
------------------ ------------------------- X Other: Compel Discovery Requests
0 RALJ APPEALS (Tuesday — 9:00 am)
No (.'Onfirinafion Necessary
CIVIL NOTICE OF ISSUE - I of 2H-.\Files\2100to2i5o\�mitt),At)drew4,Cynthja\v-Yelm,etal\NoticeoFIssue--MtntoCompel,doc,
WW28/07
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I Certificate of Service
11V�
ffin
I certify that on November x,201 O, I X emailed and X Sign:
deposited in the U.S. mail, delivered through a legal Prim/Type Na it;nc: Ben D. Cuslumn
messenger service, 0 personally delivered. a copy of this
4
document to the attorneys) of record for 0 WSBA 263'�8 (if attorney) Plaintiff X
Defendants 0 All Other Parties of Record. Address: Cushman Law Offices, P.S
A 924 Capitol Way S.
UX 4A
On behalf of X Plaintiff City/State/Zip: Olympia, WA 98501
0 Defendant /Respondent Attorney for: Plaintiffs
C1 Other: Telephone:: 534-9183
Dated: November ,,...,�.' . 2010
LIST NAMES, ADDRESSES & TELEPHONE NUMBERS
OF ALL PARTIES REQUIRING NOTICE
Name:
Carol A. Morris
Attorney for:
Defendants: Yelp; Beek
WSRA #:
192141
Address-,
Morris & Taraday,P.C.
7223 Seawitch Lane NW
Telephone:
P. O. Box 948
Email:
Seabeck. WA 98380 -0948
Telephone:
360/830-0328
Email:
carol—a-,..rnorrisCq,)rnsn.com
Name: J. Michael Morgan
Attorney for: Defendants: Dan Lee, Triance
Name:
Attorney for:
WSBA ft:
Address:
Name: Richard L. Ditlevson
Attorney for: Defendant 1711.1, LLC
WSBA ft: 735
Address: Ditlevson Rodgers Dixon, P.S.
324 West Bay Drive NW, #201
Olympia, WA 98512
Telephone: 352-8311
Email- dickd(ti?buddbaylaw.com
CIVIL NOTICE OF ISSUE - 2 of 21- 1:1Fj1eS12100t0 22501 5Mith, Andrew 4, Cynthia% Yelm, et,31\Notice of Issue - -Mtn to Compej.doc,
09/28/07
Homes, State Farm Insurance
WSRA #:
1804
Address:
J. Michael Morgan, PLLC
1800 Cooper Pt, Rd SW Bldg 11.
01yrnpia.. WA 98502
Telephone:
360/292-7501
Email:
mike@jmmorganlaw.com
Name:
Attorney for:
WSBA ft:
Address:
Name: Richard L. Ditlevson
Attorney for: Defendant 1711.1, LLC
WSBA ft: 735
Address: Ditlevson Rodgers Dixon, P.S.
324 West Bay Drive NW, #201
Olympia, WA 98512
Telephone: 352-8311
Email- dickd(ti?buddbaylaw.com
CIVIL NOTICE OF ISSUE - 2 of 21- 1:1Fj1eS12100t0 22501 5Mith, Andrew 4, Cynthia% Yelm, et,31\Notice of Issue - -Mtn to Compej.doc,
09/28/07
1 U EXPEDFrE
2 U Hearing is set: 1213/10
Date/Time: 9:00 a.m.
3 Calendar/Judge-, McPhee
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8 SUPERIOR COURT OF WASHINGTON
9 FOR THURSTON COUNTY
10 ANDREW J. SMITH and CYNTHIA M. SMITH,
Husband and Wife, NO. 09-2-02879-3
11 Plaintiffs,
12 PLAINTIFFS' MOTION TO
V. COMPEL DISCOVERY REQUESTS
13 AND FOR TERMS FROM FH I, LLC
THE CITY OF YELM, et al.,
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Defendants.
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L RELIEF REQUESTED
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Plaintiff moves the court for an order compelling Defendant FH I, LLC to provide responses to
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19 Plaintiffs' First Interrogatories and Requests for Production, and to make the principal for FH 1, LLC,
20 Steve Chamberlain, available for deposition, and for an award of expenses, including attorney's fees.
21 11. STATEMENT OF FACTS
22 Service of Plaintiffs' discovery requests to Defendant FH I, LLC was made at the time it was
23 served with the pleadings in this matter on February 5, 2010, and responses were due 40 days later, on
24 March 17, 2010. More than forty days have elapsed since the date of service, and no responses have been
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received, Additionally, letters have been sent to the attorney of record for FI-11, LLC, Richard L.
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27 Ditlevson, inquiring about the responses and the deposition of Chamberlain, and a CR 26(i) telephone
PLAINTIFFS' MOTION TO CUSHMAN 924 CAPITOL WAY S01:TI 1
28 COMPEL DISCOVERY REQUESTS LAW OFFICES, P.S, OLYMPIA, WASI ZING TON 99501
AND FOR TERMS FROM FH 1, LLC - 1 ATf0RNTTYS AT LAW (360) 534-91,83 FAX: (3601) 956-9795
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conference was scheduled. Mr. Ditlevson has provided no response to any of these inquiries. (See
accompanying Declaration of Ben D. Cuslunan).
111. STATEMENT OF ISSUE
Whether an order to compel and awarding expenses should be entered on account of Defendant
FHI, LLCs failure to timely respond to Plaintiffs'discovery requests.
The Declaration of Ben D. Cushman, and exhibits attached thereto showing proof of service, and
CR 26(i) inquiries.
VAN 0 0 KV11 v- 41f M
Civil Rule 37(a)(2) provides that if a party fails to respond to discovery requests, the party
initiating discovery may move for an order compelling responses.
Civil Rule 37(a)(4) provides that if the motion is granted, the court shall, after opportunity for
hearing, require the party or deponent whose conduct necessitated the motion or the party or attorney
advising such conduct or both of them to pay to the moving party the reasonable expenses incurred in
obtaining the order, including attorney's fees, unless the court finds that the opposition to the motion was
substantially justified or that other circumstances make an award of expenses unjust.
DATED this day of November, 2010.
1,
PLAINTIFFS' MOTION TO
COMPEL DISCOVERY REQUESTS
AND FOR TERMS FROM FH 1, LLC - 2
CUSHMANJ,AW-0,FFlCES, P.S.
M
Cushman, WSBA 426358
7 for Plaintiffs
CUSHMAN 924 CAPITOL WAY SOUTH
LAW OFFICES, P.S. OLYMPIA. WASHINGTON 98501
ATFORNEYSAT LAW (360) 534-9183 FAX: (360) 956-9795
11/23/2010 14:08 FAX 360 956 9795 CUSHMAN LAW OFFICES
U EXPEDITE
Z1 Hearkig; is SeV
2 Date/Time', 12 3/10, 9 a-111.
Calendar/JUd,',1'('- McPhee
3 t
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8 SUPERIOR COURT OF WAS14INGTON
o, FOR THURSTON COUNTY
10 ANDREW J. SMITH and CYNTHIA M. SMIT•
Husband and Wife,
11 Plaintiffs,
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THE CITY OF YELM, et al.,
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Defendants.
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BEN D. CUSH-MAN declares as follows.
NO. 09-2-02879-3
E
DECLARATION OF 13EN D.
CI, SHMAN IN SUPPORT OF MOTION
TO COMPEL DISCOVERY REQUESTS
AND FOR TERMS FROM FH 1 LLC
I am the attorney for the plaintiff
_s herein, and make this Declaration based on my own
personal knowledge,
2. Attached as Exhibit A is a copy of the Declaration of Service on Defendant FIJI, LLC.
of the initial pleadings in this matter. along with plaintiffs' First InterTogatories and Requests for
Production, showing that said Defendant was personally served with these docunjents on February 5,
2010.
3. The Court will take notice that attorney Richard Ditlevson filed an Answer on behalf of
Defendant F141, LLC on April 16, 2010. 1 have received no notice of withdrawal or substitution of
counsel for FH I, LLC.
C Ul S H NILA N 924 CAPIT01, WAY SOLI TI I
DECLARATION OF BEN D. CUSEMAN IN LAW OFFICES, F,S. C)IY\Pl A, \VASH1,N(Vj'( )N 98501
SUPPORT OF MOTION TO cOMPEL DISCOVERY (I( =1))534.998.1! -AK (360)956 -x 95 s 1t
REQUESTS AND FOR TERMS FROM F141 LLC - 1
11/23/2010 14:08 FAX 360 956 9795 CUSHMAN LAW OFFICES
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U002
4. Attached as Exhibit B is a copy of my ,November 5, 2014 letter to Mr. Ditievson
explaining that although we had previously received answers to interrogatories from Defendant Steve
Chamberlain, we had not received any from Defendant F141, LLC. Inasmuch as Defendant Steve
Chamberlain, personally, was dismissed as a Defendant in this matter, then the answers ftorri, FHI,
LLC remain particularly needed to these proceedings. I additionally stated that we wanted to take the
deposition of Steve Chamberlain in his capacity as agent for FHI, LLC- Neither 1, nor anyone from
my office has received any MSPOTISe to this letter.
5. Attached as Exhibit C is a copy of my November 17, 2010 letter to Mr. Ditlevson
scheduling a CR 26(i) conference to discuss the overdue discovery :responses and again requesting
potential dates that his client Steve Chamberlain could be made available for deposition- )Mien I
telephoned him on November 22, 2010, he was not available, and has still not returned my call.
6. 1 estimate that the costs of my paralegal to prepare the motion papers, assemble for
service, Mendaring, etc., will be $250, and the cost of my appearance at the motion hearing will be
$400, for a total of $650, and request that these tern-is be imposed against Defendant FHI, LLC wid/or
his attorney Richard Ditlevsori,
WASHINGTON THAT THE FOREGOING IS TRUE AND CORRECT.
DATED this day of November, 2010, at Olympia, Washington_
en D. Cushman
DECLARATION OF BEN D. CUSHMAN IN CUSHMAN 924 CANTM WAY SUL-11 I
SUPPORT OF MOTION TO COMPEL DISCOVERY LAW OFFICES, P.S. 01AMN A, WANI I } ",CTON 98501
REQUESTS AND FOR TERMS FROM FIA I LLC - 2 Geri) 534-1)163 FAX (360) 956-9795
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• EXPEDITE
• Hearing is set:
Date:/ Time: 1213110,9a.m.
Judge/Calendar Murphy
SUPERIOR COURT OF WASHINGTON
FOR THURSTON COUNTY I
ANDREW J. SMITH AND CYNTHIA M.
SMITH, Husband and Wife,
Plaintiffs,
V.
CITY OF YELM, et al.,
Defendants.
NO, 09-2-02879-3
DECLARATION OF FAXED
DOCUMENT (DCLR)
[Attach as last page of Faxed Document]
Pursuant to the provisions of GR 17, 1 declare as follows:
I I am the party who received the foregoing facsimile transmission for filing and certify its
authenticity.
2. My address is: Cushi-nan Law Offices, 924 Capitol Way S., Olympia, WA 98501
3. My phone number is: 3601534-9183
4. The facsimile number where I received the document is: 3601956-9795
5. 1 have examined the foregoing document, determined that it consists of 2number of pages, not
including this Declaration page or exhibits, and that it is complete and legible.
I certify under penalty of perjury under the laws of the State of Washington that the above is true
and correct.
DATED this 23r`' day of November 2010, at Olympia Washington.
Printed Name: Doreen Milward
DECLARATION OF FAXED DOCUMENT - I CUSHMAN 924 CATIN-01, NMAY SOU'51
LAW OFFICES, P.S. OLYMPIA,WASAINGTON 98501
A' rroRINEM AT LAW (36Y) 534-9183 FAX: (360) 956-9795
ANDREW J SMITH AND CYNTHIA M SMITH,
HUSBAND AND WIFE
Plaintiff /Petitioner
vs,
THE CITY OF DOE, A MUNICIPAL
CORPORATION; ET AL. Defendant/Respondent
Cause #. 09-2-02879-3
Declaration of Service of*,
summONS; COMPLAINT FOR BREACH OF CONTRACT,
MANDAMUS. BREACH OF DUTY, AND DAMAGES; NOTICE
ASSIGNMENT] NOTICE OF STATUS CONFERENCE; FIRST
INTERROGATORIES AND REQUESTS FOP, PRODUCTION T
DEFENDANT FH1, LLC
Hearing Date:
Declaration:
The undersigned hereby declares: That s(he) is now and at all times herein mentioned, a citizen of the United States and a resident of the Stai
Washington, over the age of eighteen, not an officer of a plaintiff corporation, not 2 party to nor Interested in the above entitled action, and is c
to be a witness therein,
On the date and time of Feb 5 2010 1 0:60AM
at the address of 566 ISRAEL RD SW TUMWATER
within the County of THURSTON state of WASHINGTON
the declarant duly served the above described documents upon
FH1, LLC
by then and there personally delivering 1 true and correct coPY(ies) thereof, by then presenting to and leaving the same with
STEPHEN CHAMBERLAIN REGISTERED AGENT
No information was provided that indicates that the subjects served are members of the U.S. military.
I hereby declare under penalty of perjury under the laws of the State of Washington that the foregoing 4 ?r,
.uX#@'Hr,A" ,`31EENT
Dated: February 5, 20 lympiarA
CA-C� n
by
S. Treiber PSR2009-0311-06 F0111 FUNG
The documents listed above were served in accordance with RGW 4,28,080 and/or client instructions. If service was substituted on another person or IE
person that refused to identify themselves, it is incumbent upon the client to notify ABC Legal Services, Inc. irnmediat* In writing if further attempts to �
by mail, or investigate are required. If service was substituted on another person, pursuant to RCW 4,28. D80 (16), service shall be complete on the tonti
copy of the documents are mailed to the subject at the address where service was made. Documents were not mailed by ABC Legal Services, Inc.
Service Notes.
121171200911:40: PER AGENT PAM, SUBJECT NOT IN.
1711812009 13:55: PER AGENT PATTI, SUBJECT NOT IN.
121211200910:30: BUSINESS DARK AND LOCKED I'
121221200913:20: BUSINESS DARK AND LOCKED.
1 1213012009 11:50: Per contact; Subject not at work this week
I^A,..A^ A A.A^.
Documents: 22-00 Secretarial: 0.00 Cther; 40
Travel: 20.64 Postage: 0.00 Total: 121
Pre Paid Retainer: 0
Inxinfirl Afirirp-�-' e n 1 0,00 Photo: 0.00
ram.
Ah-
633 Yesler Way Seattle, WA 98104 www.abdegal.cova
206 521-9000 Pax: 206 224-3409
Cushman Law Off ices
924 Capitol Way S Suite #201
Olympia, WA 98601
Account ##; 55130
Attention: Doreen Milward 360 534-9183
X
INVOICE #: 2524102
1
DATE: Feb 5 2010
BILL REF. 2145.001
.1 -MOUNT DUE. $121.14
CASE` NA ACE: ANDREW J SMITH AND CYNTHIA M SMITH, HUSBANDAND WIFE vs. THE CITY OF DOE, A MUNICIPAL
CORPORATION; ET AL.
SERVEE: FH 1, LLC
PERSON SERVED: STEPHEN CHAMBERLAIN REGISTERED AGENT
SERVICE DATE: Feb 5 2010 10:50AM SERVED BY. S. Treiber
SERVICE, ADDRESS: 555 ISRAEL RD SW TUMWATER, WASHINGTON 98501
DOCUMENT'S SERVED: SUMMONS; COMPLAINT FOR BREACH OF CONTRACT, MANDAMUS, BREACH OF DUTY, AND DAMAGES; NOTICE OFASSIGNMENT;
NOTICE OF STATUS CONFERENCE; FIRST INTERROGATORIESAND REOUrSTS FOR PRODUG71ON TO DEFENDANT FFII, LLG
SERVICEELISTORY
0210512010 Local Service Event, Served 02105110 10:50 (SVD PRI)
02103/2010 Service Note (Web View) per Doreen, serve at Tumwater City Hall I Council Chambers, 555 Israel Rd. SW, Turnwater 98501 on
215 at 11:00 AM court appearance.
0210212010 Service Note (Web View) per Doreen, if not served by 213, cancel and narrative declaration of attempts
0112512010 Service Note (Web ViQ per Doreen, attempt at now address: 7407 Johnson SE, Olympia 98513
1212-812009 Service Note (Web View) orean, continue attempts.
1212312009 Service Note Meb View) F.Oft ' Dvoicemall for client re: serve-by date
1211612009 Work Order Received and Entered
SItAVICE NOTE
1211712009 11:40: PER AGENT PATTI, SUBJECT NOT IN,
1211812009 13:55: PER AGENT PATTI, SUBJECT NOT ft
1212112009 10:30, BUSINESS DARK AND LOCKED
92122%240913:20: BUSINESS DARK AND LOCKED
12130/2009 11:60. Per contact, Subject not at work this week
01104/201011:49: Per employee, Subject not at work today
01/12/2010 12:30: Per iect gone for the day
0111312010 13A2: Per employee, Subject Ste edoutforlunch
0111912010 11:17, Per employee, Subject left 15 minutes ago
411251201018:55: No Access to subjects door atedanirance)
0112712010 21:10: No Access to subject's door �gated entrance)
0112912010 20:51: No Access to subjects door (gated entrance)
011301201016:00; No Access to subjects door atedentranre)
0210212010 20:40: ADDRESS IS BEHIND SAM?INACCESSI BLF GATE
AS 7407- CALL BOX STILL NOT WORKING.
JM &DDRESS LIST
J;-111(all-M 5_1�_eOT
0-
SERVICE PERFORMED .—NOTE
Nio
RATE
Travel (Round Trip)
Roundtrip Travel to Service Address(es)
20.64
Rush Process Service
Misc. Travel,
ATTEMPTS TO JOHNSON RD AND TootH A E-
25.00
40.00
Proof of Service Preparation
10.00
Proof Summons Copy
Make copy of summons for filing with proof of service
3.50
Statutory Document Fee
22M
SUB TOTAL
121,14
PREPAID RETAINER
00
0.2 0
AMOUNT DUE,
121.14�
OFFICIAL PROCESS SERVER TO Page I of I
.22NS �D
'(t U.S. DEPT. 0 F JUSTICE, A,ND "U.S. STATE DEPT Olk-PUMAM14
A bwalof
CUSHMAN-11
LAIN
OFFICES, Rs,
A=ORNBYS AT LAW
Bell Cusftmall"WCU shniatil aw, com
Richard L. Ditlevson
Ditlevson Rodgers Dixon, P.S.
324 West Bay Drive N'W, Suite 201
Olympia, WA 98512
RE: Smith v. City of Yelm, et al,
Dear Mr, Ditlevson:
974 CAPITOL WAY SOUTH
W-AISHINGTON N501
(36T) 534-9183
FACSIMILE', (360) 956-9195
November 5, 2010
JON F. CUSTFIMANt
PENJAMIN D. CUSI-3,MAN-
tAl'-O ALM= IN OREGON
"'DI'IrTITT) IN ALVSV-A' CMT-GON, IDAHO 81*
NORTH C'A'ItOUNi
',K ALASKA, ORZGON, GUAM &
IN I N N'r 8 C iA
We would like to take the deposition of Steve Chamberlain in his capacity as agent for
Defendant FH-1, LLC in this matter. Please call or email my paralegal Doreen Milward at
di-nilwai�d(i�,,custu-natilavv.com to discuss deposition date options witliffi the next month.
Also, 171-1-1, LLC's responses to the interrogatories and requests for production we propounded
to it are nearly 10'/2 months overdue! Although we received Steve Chamberlain's responses long
ago to his set, he is no longer a party to this lawsuit, and. the questions to FH- 1, LLC, though
similar to the ernes sent to Mr. Chamberlain, are not identical. Please provide complete
responses, including the documents requested, by November 15. 2010. Thank you.
Very truly yours,
D, �Cusl'nan
cc: clients
. bi
C'USHMAN
LAW
OFFICES, P.S.
ATrORINEYS AX LAW
BenCitshiiian(tbCushmaiiiaw.coi,n
via email and regular mail
Richard L. Ditlevson
Ditlevson Rodgers Dixon, P,S.
324 West Bay Drive N'W, Suite 201
Olympia, WA 98512
RE: Smith v, City of Yelrn, et al,
CR 26(i) Conference
Dear Mr, Ditlewson:
Q-zl CAPF"01, WAY SM , 'I'll
OLYMPIA, WAS"UNGTON 98501
FACSINMJ11 (36T �56 )795
I I
November 17, 2010
JON' P,- CUSIWAINt
BENJAIMINN D. CLISHINALAN'
JOSEPH W SCUDF'R1#
{A),-SG AMA11TIU, IN OM-GON
I m I 'v4 'V, t -SK{ " oRwON, I I) "Lao F",
#M,$0 ADWTITM 711 AASICI�, ORfiGON, (iUAM &
MTNINESOUA
I have had no response to my November 5, 201.0 letter to you which requested FI-1-1. LLUs long
overdue responses to our discovery requests by November 15, 2010, and also asked for potential
dates to depose Steve Chamberlain on behalf of 1µi1-1, LLC, I am therefore scheduling a CR
26(i) conference by telephone, and will call you on Monday, November 22, at 10 a.m. to discuss
these matters,
Very truly yours,
Ben D, Cusbman
cc: clients
i U EXPEDITE
2 Ll Hearing is set: 1213/10
Date/Time: 9:00 a.m.
3 Calendar/Judge: McPhee
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8 SUPERIOR COURT OF WASHINGTON
9 FOR THURSTON COUNTY
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ANDREW J. SMITH and CYNTHIA M. SMITH,
Husband and Wife,
Plaintiffs,
NO. 09-2-02879-3
V. Proposed
ORDER GRANTING PLAINTIFFS'
MOTION TO COMPEL DISCOVERY
THE CITY OF YELM, et al., REQUESTS AND FOR TERMS FROM
FH I, LLC
Defendants.
THIS MATTER having come before the Court, and the Court having considered Plaintiffs'
Motion to Compel Discovery Requests and for Terms from Defendant F11 I, LLC, the Declaration of
Ben Cushman in Support of Plaintiffs' Motion, and the records and files herein, NOW, THEREFORE,
GRANTS Plaintiffs' Motion to Compel, and ORDERS Defendant FIJI, LLC to provide
responses to Plaintiffs' First Interrogatories and Requests for Production by
require the principal of FH I, LLC Steve Chamberlain to be made available for deposition before the
end of January 2011; and impose terms in the amount of $ against Defendant FI-11, LLC.
DONE IN OPEN COURT this day of December, 2010.
ORDER GRANTING PLAINTIFFS' MOTION
TO COMPEL DISCOVERY REQUESTS
AND FOR TERMS FROM FH L LLC - 1.
THE HONORALBE THOMAS McPIIEE
CUSHMAN 924 (:APITCA, WAYSOUITH
LAW OFFICES, P.S. OLYNIPIA, WAS[ IINGTON 98501
ATFORNEWS A'r LAW {%()) 534-9183 FAX (360) 956-9795
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Presented by:
CUSHMAN LAW OFFICES, P.S.
Ben D. Cushman, WSBA # 26358
Attorney for Plaintiffs
Approved as to Form,
Notice of Presentation Waived:
J. Michael Morgan, WSBA #18404
Attorney for Defendants Lee, Triance, State Farm
Carol A. Morris, WSBA 419421
Attorney for Defendants City of Yelm and Beek
Richard L. Ditlevson, WSBA #735
Attorney for Defendant FH L, LLC
ORDER GRANTING PLAINTIFFS' MOTION CL SHINL�N 924 CANTOL WV SOUTH
TO COMPEL DISCOVERY REQUESTS LAW OFFICES, P.S. OLYMPIA, WASTIINGMN 98501
AND FOR TERMS FROM FH I, LLC - 2 Xn'ORNENS XYLAW (360) 534-9193 FAX (360) 950-9795