2010 03 17 Yelm Response to Beck Interrogatories_Page_011
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❑ EXPEDITE
❑ Hearing is set:
Date /Time:
Calendar /Judge: Civil/McPhee
SUPERIOR COURT OF WASHINGTON
8 FOR THURSTON COUNTY
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ANDREW J. SMITH and CYNTHIA M. SMITH,
10 Husband and Wife,
11 1 Plaintiffs,
12 1 V.
13 THE CITY OF DOE, a Municipal Corporation;
GRANT BECK; STEVE CHAMBERLAIN; FHI,
14 LLC, a Washington corporation; DAN LEE;
15 TRIANCE GROUP INC., d /b /a TRIANCE
HOMES, a Washington corporation and a licensed
16 Washington construction contractor; STATE
FARM FIRE & CASUALTY CO., Bond No.
17 98GD85307; MAUREEN NIELAND;
VANDORM REALTY, INC., a Washington
18 corporation.
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Defendants.
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TO: Defendant Grant Beck
NO. 09 -2- 02879 -3
FIRST INTERROGATORIES AND
REQUESTS FOR PRODUCTION TO
DEFENDANT GRANT BECK AND
ANSWERS THERETO
L INTERROGATORIES
Pursuant to Civil Rules 26 and 33, Plaintiff submits the following interrogatories to be answered
in writing, under oath within forty (40) days of service. These interrogatories are intended to be
continuing in nature so as to require supplemental information under Civil Rule 26(e).
FIRST INTERROGATORIES AND
REQUESTS FOR PRODUCTION TO
DEFENDANT GRANT BECK
AND ANSWERS THERETO - I
CUSHMAN 924 CAPITOL WAY SOUTH
LAW OFFICES, P.S. OLYMPIA, WASHINGTON 98501
ATTORNEYS AT Lew (360) 534-9183 FAX: (360) 956 -9795
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II. REQUEST FOR PRODUCTION OF DOCUMENTS
Pursuant to Civil Rules 26 and 34, you are requested to produce at the Cushman Law Offices
P. S., all documents designated below that are in your possession, custody, or control of your agents,
attorneys, consultants, or representatives or which are accessible to any such person within forty (40)
days of service upon you. This Request for Production of Documents is also continuing in nature
under Civil Rule 26(e), and should you discover additional responsive documents after your initial
production, you are required to produce such documents.
III. INSTRUCTIONS
A. These Interrogatories and Requests for Production of Documents are continuing and
you are requested to provide any information which is responsive to them after the time you answer or
respond. If such responses are not furnished, plaintiffs will move at the time of trial to exclude from
evidence any requested information not so furnished.
B. Each Interrogatory and each subparagraph of each Interrogatory is to be fully and
separately answered, in writing and under oath. Before each response is given, the paragraph and
subparagraph number of the Interrogatory to which the answer or response relates is to be set forth.
C. The answer and response to each Interrogatory and Request for Production shall include
such knowledge and documents as are within your custody, possession or control, or readily obtainable
by you, including knowledge within the custody, possession or control of your attorneys, agents, and
other representatives.
D. If you refuse to answer or respond to any Interrogatory or Request for production, in
whole or in part, identify the basis for your refusal to answer or respond, including any claim of
privilege.
E. If you assert a claim of privilege to the production of any document requested below,
state for each document the following information:
1. Which privilege is claimed;
FIRST INTERROGATORIES AND CUSHMAN 924 CAPITOL WAY SOUTH
REQUESTS FOR PRODUCTION TO LAW OFFICES, P.S. OLYMPIA, WASHINGTON 98501
DEFENDANT GRANT BECK ATTORNEYS AT Lew (360) 534-9183 FAX: (360) 956 -9795
AND ANSWERS THERETO - 2
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2. A precise statement of the facts upon which said claim of privilege is based;
3. The following information as to each purportedly privileged document:
a. Its nature, e.g., letter, memo, minutes, etc.;
b. The date it bears;
C. The identify of the persons sending it;
d. The identity of each person receiving a copy;
e. A statement of the subject matter of the document;
If you contend only a portion of the document is privileged, please provide a redacted copy of
the document with a listing of the above information as to the redacted portion.
F. With respect to any Interrogatory or Request for Production contained herein, if you are
able to provide some, but not all, of the information requested, provide such information as you can
and specifically identify each item as to which you do not have sufficient information to fully respond.
G. The Interrogatories shall be answered within forty (40) days after the service thereof
upon you.
H. You are directed to produce all documents requested below regardless of when such
document was drafted or generated and regardless of whether or not such document was drafted or
generated after completion of the project.
I. The documents requested below shall be produced and made available for inspection and
copying at the Cushman Law Offices, P. S., 924 Capitol Way South, Suite 201, Olympia, Washington
98501 within forty (40) days after the date of service thereof upon you.
IV. DEFINITIONS
As used in these Interrogatories and Requests for Production, the following terms shall have the
following meanings:
FIRST INTERROGATORIES AND
REQUESTS FOR PRODUCTION TO
DEFENDANT GRANT BECK
AND ANSWERS THERETO - 3
CUSHMAN 924 CAPITOL WAY SOUTH
LAW OFFICES, P.S. OLYMPIA, WASHINGTON 98501
ATTORNEYS AT Lew (360) 534-9183 FAX: (360) 956 -9795
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A. The term "you" and "your" means yourself, and any and all other persons or entities
acting on your behalf, or on whose behalf you are acting, including, without limitation, your insurer,
bank, accountant and /or attorney.
B. The terms "and" and "or" shall, unless the context clearly indicates otherwise, and are
both the conjunctive and disjunctive.
C. In construing these Interrogatories and Requests for Production of Documents, the
singular of each term shall include the plural and the plural shall include the singular, and a masculine,
feminine, or neuter pronoun shall not exclude the other genders.
D. The term "document" means all written, graphic, or printed matter of any kind, however
produced or reproduced, including all originals, drafts, working papers and non - identical copies,
whether different from the originals by reason of any notation made on such copies or otherwise
including, but not limited to, papers, books, patents, letters, photographs, tangible things,
correspondence, telegrams, cables, telexes or telefax messages, memoranda, notes, data, notations, work
papers, interoffice communications, minutes, reports and records of any communications (including
telephone or other conversations, interviews, conferences or committee or other meetings), affidavits,
statements, summaries, opinions, reports, studies, analyses, plans, specifications, contracts, licenses,
agreements, journals, books or other records of accounts, summaries of accounts, bills, receipts, balance
sheets, income statements, advertisements, desk calendars, appointment books, diaries, lists, charts,
graphs, maps, surveys, sound recordings, computer records or impressions, microfilm, and all other
records kept by electronic, photographic, or mechanical means, and things similar to any of the
foregoing, however denominated.
E. The term "person" includes any natural person, firm, company, association, partnership
and joint venture corporation, and any other form of legal entity, and any city, state or federal
governmental entity or any agency, board or court thereof.
FIRST INTERROGATORIES AND CUSHMAN 924 CAPITOL WAY SOUTH
REQUESTS FOR PRODUCTION TO LAW OFFICES, P.S. OLYMPIA, WASHINGTON 98501
DEFENDANT GRANT BECK ATTORNEYS AT Lew (360) 534-9183 FAX: (360) 956 -9795
AND ANSWERS THERETO - 4
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F. The term "identify" means, with respect to a document, to state its type (e.g., letter,
interoffice memorandum, etc.), date, author, subject matter, present custodian, and if you are no longer
in possession of the document, whether it was lost, destroyed or otherwise disposed of and the
accompanying circumstances.
G. The term "identify" means, with respect to a natural person, to state his or her full name,
address, present or last known employer and position held; with respect to a person other than a natural
person, "identify" means to state the name and address of such person.
H. "Identify" or "describe," when used with respect to an act occurrence, contract,
transaction, decision, statement, communication or conduct (hereinafter collectively called "act ") means
to describe in substance the event or events constituting such act, or what transpired, the place, the date;
and to identify the persons involved and the documents referring or relating thereto.
I. The terms "relate," "in relation to," or "relating to" mean directly or indirectly
referring to, pertaining to, discussing, describing, commenting on, constituting, evidencing, referencing,
comprising, or reflecting upon a stated subject, in whole or in part.
J. The term "professional services" includes all architectural, engineering, construction or
material testing, accounting, landscaping, estimating or construction management services.
K. The term "Project" refers to the Plaintiffs' land and constructed house at 10756 Palisades
St SE, Yelm, Washington, also known as Lot 15 of the Plat of Palisades West.
L. The term "Contract" refers to any written agreement you (see Definition at "A" above)
had or have with Plaintiffs concerning the purchase, construction, permitting, approval for occupancy,
and /or the providing of utilities to the Project in this matter.
//I
FIRST INTERROGATORIES AND CUSHMAN 924 CAPITOL WAY SOUTH
REQUESTS FOR PRODUCTION TO LAW OFFICES, P.S. OLYMPIA, WASHINGTON 98501
DEFENDANT GRANT BECK ATTORNEYS AT Lew (360) 534-9183 FAX: (360) 956 -9795
AND ANSWERS THERETO - 5
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INTERROGATORIES
INTERROGATORY NO. 1: Prior to responding to these discovery requests, have you thoroughly
researched and identified every document and made inquiry of every employee or agent having
knowledge of the information and subject matter sought by these discovery requests?
ANSWER:
As much as possible, given the broad scope of the interrogatories (refer to objections set forth herein).
INTERROGATORY NO. 2: Please identify by name, address, telephone number, employer and job
title of each person who was consulted or who assisted in the answering of these discovery requests, or
who furnished information which was used in answering them.
ANSWER:
Shelly Badger, Yelm City Administrator 360- 458 -3244
John Rowland, Yelm Building Inspector 360- 458 -3244
Tim Peterson, Yelm Public Works Director 360- 458 -3244
Gary Carlson, Yelm Building Official 360- 458 -3244
Grant Beck, Yelm Community Development Director 360- 458 -3244
City of Yelm, 105 Yelm Avenue West, Yelm, WA 98597
Randy Raymond, P.E. Parametrix, Inc. 1231 Fryar Avenue, Sumner, WA 98390 253- 863 -5128
INTERROGATORY NO. 3: For each of you, please state:
a. Your full name;
b. Your date and place of birth;
C. Your residence address and telephone number;
FIRST INTERROGATORIES AND CUSHMAN 924 CAPITOL WAY SOUTH
REQUESTS FOR PRODUCTION TO LAW OFFICES, P.S. OLYMPIA, WASHINGTON 98501
DEFENDANT GRANT BECK ATTORNEYS AT Lew (360) 534-9183 FAX: (360) 956 -9795
AND ANSWERS THERETO - 6
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d. Your social security number; PURSUANT TO THE FEBRUARY 19, 2010 ORDER
GRANTING DEFENDANT BECK'S MOTION FOR PROTECTIVE ORDER, THE
DEFENDANT BECK IS NOT REQUIRED TO ANSWER.
e. Name, address and telephone number of your employer, if any;
f. Any and all of the names you have used during your lifetime and the dates and localities
where used.
ANSWER:
Grant Wesley Beck
August 6, 1964
Seattle, Washington
6119 Winnwood Loop S.E.
Olympia, WA 98513
360- 493 -2587
City of Yelm
105 Yelm Ave. West
Yelm, WA
360- 458 -3244
INTERROGATORY NO. 4: As to each of your marriages, if any, please state:
a. Inclusive dates of marriage;
b. Present name, address and telephone number of spouse;
C. Name, address and telephone number of spouse's present employer;
d. Whether marriage terminated and, if so, how terminated.
FIRST INTERROGATORIES AND
REQUESTS FOR PRODUCTION TO
DEFENDANT GRANT BECK
AND ANSWERS THERETO - 7
CUSHMAN 924 CAPITOL WAY SOUTH
LAW OFFICES, P.S. OLYMPIA, WASHINGTON 98501
ATTORNEYS AT Lew (360) 534-9183 FAX: (360) 956 -9795
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ANSWER: PURSUANT TO THE FEBRUARY 19, 2010 ORDER GRANTING DEFENDANT
BECK'S MOTION FOR PROTECTIVE ORDER, THE DEFENDANT BECK IS NOT
REQUIRED TO ANSWER.
INTERROGATORY NO. 5: As to each of your residences for the past 10 years, please state
chronologically:
a. Inclusive dates of residence;
b. Street address;
C. Present name, address, telephone number and nature of relationship of each person with
whom you resided.
ANSWER: PURSUANT TO THE FEBRUARY 19, 2010 ORDER GRANTING DEFENDANT
BECK'S MOTION FOR PROTECTIVE ORDER, THE DEFENDANT BECK IS NOT
REQUIRED TO ANSWER.
INTERROGATORY NO. 6: As to each of your employment positions (including self employment)
for the past 10 years, please state chronologically:
a. Inclusive dates of employment;
b. Name, address and telephone number of employer;
C. Name, address and telephone number of immediate supervisor(s);
d. Job title and nature of duties you performed;
e. Reason employment terminated.
ANSWER:
May 1996 to June 2002
San Juan County, Washington
350 Court Street
Friday Harbor, WA 98250 360- 378 -2898
FIRST INTERROGATORIES AND CUSHMAN 924 CAPITOL WAY SOUTH
REQUESTS FOR PRODUCTION TO LAW OFFICES, P.S. OLYMPIA, WASHINGTON 98501
DEFENDANT GRANT BECK ATTORNEYS AT Lew (360) 534-9183 FAX: (360) 956 -9795
AND ANSWERS THERETO - 8
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Board of San Juan County Commissioners
350 Court Street
Friday Harbor, WA 98250
360- 378 -2898
Permit Center Director
Directed the current planning and building programs
Accepted position of Community Development Director for City of Yelm
June 2002 to present
City of Yelm, Washington
105 Yelm Avenue West
Yelm, WA 98597
360- 458 -3244
Community Development Director
Directs the long range planning, current planning, development review engineering, and building permit
programs.
N/A
INTERROGATORY NO. 7: As to each school you have attended or through which you have pursued
studies, please state chronologically:
a. Name, address and telephone number;
b. Inclusive dates of attendance;
C. Course of study;
d. Name and date of degree conferred.
ANSWER:
FIRST INTERROGATORIES AND CUSHMAN 924 CAPITOL WAY SOUTH
REQUESTS FOR PRODUCTION TO LAW OFFICES, P.S. OLYMPIA, WASHINGTON 98501
DEFENDANT GRANT BECK ATTORNEYS AT Lew (360) 534-9183 FAX: (360) 956 -9795
AND ANSWERS THERETO - 9
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Lacy Elementary
1800 Homann Drive S.E.
Lacey, WA 98503 -2844
360- 412 -4650
Michael T. Simmons Elementary
1205-2 nd Avenue
Tumwater, WA 98512
360- 709 -7100
Tumwater Junior High School
6335 Littlerock Road S.W.
Tumwater, WA 98512
360- 709 -7500
Tumwater High School
700 Israel Road S.W.
Tumwater, WA 98501
36- 709 -7615
1978 -1982
High School Diploma
Western Washington University
516 High Street
Bellingham, WA 98225
360- 650 -3000
1982 -1986
Urban and Regional Planning
Bachelor of Arts, Urban and Regional Planning
FIRST INTERROGATORIES AND
REQUESTS FOR PRODUCTION TO
DEFENDANT GRANT BECK
AND ANSWERS THERETO - 10
CUSHMAN 924 CAPITOL WAY SOUTH
LAW OFFICES, P.S. OLYMPIA, WASHINGTON 98501
ATTORNEYS AT Lew (360) 534-9183 FAX: (360) 956 -9795
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INTERROGATORY NO. 8: Were you ever in any branch of the military? If so, for each of you
please state:
a. Dates of service;
b. Branch;
C. Rank at discharge;
d. Type of discharge.
ANSWER:
No.
INTERROGATORY NO. 9: Have you ever been convicted of a felony, gross misdemeanor, or
misdemeanor? If so, for each of you please state:
a. Offense charged;
b. Offense you were found to have violated;
C. Date violation was found or established;
d. Court and cause number;
e. Sentence imposed;
f. Sentence served.
ANSWER: PURSUANT TO THE FEBRUARY 19, 2010 ORDER GRANTING DEFENDANT
BECK'S MOTION FOR PROTECTIVE ORDER, THE DEFENDANT BECK IS NOT
REQUIRED TO ANSWER.
INTERROGATORY NO. 10: Have you ever been a party to a legal action other than the instant
action? If so, for each of you please state as to each action:
a. Date the action was filed;
b. Title of the action;
FIRST INTERROGATORIES AND CUSHMAN 924 CAPITOL WAY SOUTH
REQUESTS FOR PRODUCTION TO LAW OFFICES, P.S. OLYMPIA, WASHINGTON 98501
DEFENDANT GRANT BECK ATTORNEYS AT Lew (360) 534-9183 FAX: (360) 956 -9795
AND ANSWERS THERETO - 11
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C. Nature of the action;
d. Court and cause number of the action;
e. Disposition of the action;
f. Name, address and telephone number of your attorney(s);
g. Name, address and telephone number of attorney(s) for all other parties.
ANSWER:
March 3, 2003
James E. and Mary Jacobs v. San Juan County, et al.
Unsure of nature of cause
Skagit County Superior Court 03 -2- 00535 -8
This case was filed after Mr. Beck left employment with San Juan County, and he was dismissed as a
party before he ever learned of the litigation. Unsure of nature of disposition
Randy Gaylord, San Juan County Prosecuting Attorney
Karen Vedder, San Juan County Prosecuting Attorney's office may have more info.
350 Court Street
P.O. Box 760
Friday Harbor, WA 98250
360- 378 -4101
Unsure of names of other attorneys
FIRST INTERROGATORIES AND
REQUESTS FOR PRODUCTION TO
DEFENDANT GRANT BECK
AND ANSWERS THERETO - 12
CUSHMAN 924 CAPITOL WAY SOUTH
LAW OFFICES, P.S. OLYMPIA, WASHINGTON 98501
ATTORNEYS AT Lew (360) 534-9183 FAX: (360) 956 -9795
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INTERROGATORY NO. II: Do any oral or written agreements exist which requires any party to
obtain approval prior to entering a settlement, or which in any way limits any party's ability to enter into
a settlement? If so, please identify all parties to each such agreement and state in detail the terms of the
agreement.
ANSWER:
This interrogatory is directed to Grant Beck. We assume that you are asking whether there is any oral or
written agreement which requires Mr. Beck to obtain approval prior to entering into a settlement, or
which in any way limits Mr. Beck's ability to enter into a settlement. However, no facts are alleged in
the Complaint (and neither Mr. Beck nor the City of Yelm have any knowledge of any such facts) that
would justify the plaintiffs' filing of this lawsuit against Mr. Beck personally. The only facts alleged
relate to his actions that were taken within the scope of his employment. We know of no such
agreements that respond to this interrogatory.
INTERROGATORY NO. 12: Do any oral or written agreements exist allocating or apportioning
responsibility for payment of any settlement or judgment that may be made or entered in this action? If
so, please identify all parties to each such agreement, state in detail the terms of the agreement, and state
the date the agreement was made.
ANSWER:
See answer to Interrogatory No. 11 above.
INTERROGATORY NO. 13: Identify all documents (see Definition Section IV.D. above) transmitted
between you and any other party to this lawsuit regarding the Project.
ANSWER:
None.
FIRST INTERROGATORIES AND CUSHMAN 924 CAPITOL WAY SOUTH
REQUESTS FOR PRODUCTION TO LAW OFFICES, P.S. OLYMPIA, WASHINGTON 98501
DEFENDANT GRANT BECK ATTORNEYS AT Lew (360) 534-9183 FAX: (360) 956 -9795
AND ANSWERS THERETO - 13
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INTERROGATORY NO. 14: Furnish the name, current address, telephone number, occupation, job
designation, and present location of any person known to you or your attorneys as having knowledge of
the relevant facts pertaining to the above - entitled case. This interrogatory is intended to include all
witnesses known to you or to your attorneys.
ANSWER:. The plaintiffs erroneously filed this lawsuit against Grant Beck personally, because the
actions alleged in the Complaint were performed (if they were performed at all) in the scope of his
employment with the City of Yelm. Plaintiffs have only recently filed a Complaint against the City of
Yelm, and the defendants have not yet performed any discovery. Therefore, Mr. Beck submits these
names as persons who might have information as to the relevant facts in this lawsuit, but no one has had
an opportunity to determine whether this is true. At this point, we also do not have complete addresses
and phone numbers for all of the persons. Finally, some of the information may be priviledged.
John Rowland, Yelm Building Inspector
Gary Carlson, Yelm Building Official
Karen Bennett, Yelm Permit Coordinator
Tami Merriman, Yelm Associate Planner
Jim Gibson, P.E. (former city engineer, now with Shea Carr) 2102 -H Carriage Drive SW Olympia, WA
98502 360- 352 -1465
Nisha Box c/o Rita Rohila 5633 54th Avenue SE Lacey, WA 98503 360- 915 -8744
Steve Harrington 1519 Oxford Lane Centralia, WA 98531 360 -508 -0070
Tim Peterson, Yelm Public Works Director
Shelly Badger, Yelm City Administrator
Stephanie Ray, Yelm Project Manager
FIRST INTERROGATORIES AND CUSHMAN 924 CAPITOL WAY SOUTH
REQUESTS FOR PRODUCTION TO LAW OFFICES, P.S. OLYMPIA, WASHINGTON 98501
DEFENDANT GRANT BECK ATTORNEYS AT Lew (360) 534-9183 FAX: (360) 956 -9795
AND ANSWERS THERETO - 14
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Kevin Ray, Yelm Public Works Lead
Edward `Smitty' Smith, Yelm Water Department
John Ivey, Yelm Water Department
Brent Dille, City Attorney, Owens Davies 1115 West Bay Drive, Suite 302 Olympia, WA 98502 360-
943 -8320
Ron Harding, Yelm Mayor
Don Miller, Yelm Councilmember
Joe Baker, Yelm Councilmember
Bob Isom, Yelm Councilmember
Mike McGowan, Yelm Councilmember
Pat Fetterly, Yelm Councilmember
Tracey Wood, Yelm Councilmember
John Thompson, Yelm Councilmember
Russ Hendrickson, Yelm Councilmember
Mike Olivant, Parametrix, Inc. 1231 Fryar Avenue, Sumner, WA 98390 253- 863 -5128
Randy Raymond, Parametrix, Inc. 1231 Fryar Avenue, Sumner, WA 98390 253- 863 -5128
Mark King, Deputy Chief, SE Yelm Fire/EMS 709 Mill Road SE, Yelm, WA 98597 360- 458 -2799
Rita Hutchenson, Chief, SE Yelm Fire/EMS 709 Mill Road SE, Yelm, WA 98597 360- 458 -2799
Steve Chamberlain, FH1, LLC, defendant
Doug Bloom, RGD, unknown address. Dan Lee, Triance Homes and Agent for FH1, defendant
Clint Pierpoint, KPFF Engineers, 4200 South Sixth Avenue, Suite 309 Lacey, WA 98503 360 -292-
7230
Mark Steepy, KPFF Engineers, 4200 South Sixth Avenue, Suite 309 Lacey, WA 98503 360- 292 -7230
Andrew and Cynthia M. Smith, plaintiffs
Info re: foreclosure: Kathleen Herdlein, Washington First International Bank 206 - 406 -5002
FIRST INTERROGATORIES AND CUSHMAN 924 CAPITOL WAY SOUTH
REQUESTS FOR PRODUCTION TO LAW OFFICES, P.S. OLYMPIA, WASHINGTON 98501
DEFENDANT GRANT BECK ATTORNEYS AT Lew (360) 534-9183 FAX: (360) 956 -9795
AND ANSWERS THERETO - 15
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Ron Remaine, Washington First International Bank 206 - 406 -5002
Lee Allison, Plats Perfected, LLC 253 -536 -1988
Lou Larsen, Pacific Engineering 15445 53rd Avenue S, Suite 100, Seattle, WA 98188 206 - 431 -7970
Greg Diener, Pacific Engineering 15445 53rd Avenue S, Suite 100, Seattle, WA 98188 206 - 431 -7970
INTERROGATORY NO. 15: For each person listed in response to the preceding interrogatory, please
set forth a brief statement of the information that this individual has concerning the allegations contained
in the Complaint.
ANSWER:
Objection. Under ER 602, a witness may not testify to a matter unless evidence has been introduced
sufficient to support a finding that the witness has personal knowledge of the matter. It is Mr. Beck's
belief that each of the above persons may have been exposed to circumstances which would make it
likely that he /she has knowledge of the relevant facts pertaining to the above - entitled case. However,
Mr. Beck can't possibly know exactly what facts each person knows. Some of these facts may be
privileged, such as discussions held in executive session.
INTERROGATORY NO. 16: Will you call any expert witnesses at trial?
ANSWER:
This decision has not yet been made.
INTERROGATORY NO. 17: If the answer to the preceding interrogatory is anything but an
unqualified "no," state with respect to each expert witness you expect to call as a witness at trial:
a. Name;
b. Profession or occupation and job title;
C. Resume of education, training and experience;
FIRST INTERROGATORIES AND CUSHMAN 924 CAPITOL WAY SOUTH
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DEFENDANT GRANT BECK ATTORNEYS AT Lew (360) 534-9183 FAX: (360) 956 -9795
AND ANSWERS THERETO - 16
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d. The subject matter or area upon which he or she will testify;
e. Whether such potential witness will base his or her opinion:
1. in whole or in part upon facts acquired personally by him or her in the course of
an investigation or examination of any of the issues of this case, or
2. solely upon information as to the facts provided him or her by others.
f. If your answer to "e" above discloses that any such witness has made a personal
investigation or examination relating to any of the issues of this case, state the nature and date of each
such investigation or examination;
g. Each and every fact, and each and every document, item, photograph or other
tangible object supplied or made available to such person;
h. The substance of the facts and opinions to which each such expert is expected to
testify;
i. A summary of the grounds for each opinion of each such expert;
j Whether he or she has rendered written reports, and, if so,
1. give the date of each report, and
2. state the name, address and phone number of the person having custody of each
such document.
k. Whether such expert has considered or intends to testify regarding statements contained
in Published treatises, periodicals or pamphlets and, if so, the author, title, issue date and publisher of
each and every such publication.
ANSWER:
This interrogatory makes no sense. Mr. Beck is not stating an "unqualified no," but if he doesn't know
at this time whether or who will be an expert witness at trial, none of the above questions can be
answered.
FIRST INTERROGATORIES AND CUSHMAN 924 CAPITOL WAY SOUTH
REQUESTS FOR PRODUCTION TO LAW OFFICES, P.S. OLYMPIA, WASHINGTON 98501
DEFENDANT GRANT BECK ATTORNEYS AT Lew (360) 534-9183 FAX: (360) 956 -9795
AND ANSWERS THERETO - 17
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INTERROGATORY NO. 18: If applicable, with respect to each Contract between you and Plaintiffs
concerning the Project, and any amendment, addition, and /or deletion thereto, state with particularity:
1. What you believe to be the effect of the Contract(s), amendment, addition, or deletion;
2. The date of the Contract(s), amendment, addition, or deletion;
3. The person or persons who requested the Contract(s), amendment, addition, or deletion;
4. The person or persons under whose authority the Contract(s), amendment, addition, or
deletion was made; and
5. In narrative form, the events involved and the procedure followed in the making or
issuance of the Contract(s) amendment, addition, or deletion.
ANSWER:
Objection. Plaintiffs have defined "Contract" as referring "to any written agreement you (see
Definition at "A" above) had or have with Plaintiffs concerning the purchase, construction, permitting,
approval for occupancy, and /or the providing of utilities to the Project in this matter." Mr. Beck has no
written agreement with Plaintiffs concerning the purchase, construction, permitting, approval for
occupancy and /or the providing of utilities to the Project in this matter. A building permit is not a
written agreement between Mr. Beck and the applicant (or even the City of Yelm and the applicant) for
construction. As a result, none of the questions in the interrogatory apply to Mr. Beck.
With the qualification that plaintiffs understand that the word "building permit" does not mean
"contract," and assuming that the plaintiffs acknowledge that Mr. Beck is not a permitting authority, and
did not issue any permits to the plaintiffs, Mr. Beck states the following:
1. The effect of the City's issuance of a building permit for a residential structure is set forth in
Section 105 of the International Building Code as adopted by the City of Yelm at Chapter 15.08 Yelm
Municipal Code.
2. If this interrogatory refers to the building permit issued for the one lot in the Palisades West
subdivision, the building permit was issued, with conditions, on September 17, 2008.
FIRST INTERROGATORIES AND CUSHMAN 924 CAPITOL WAY SOUTH
REQUESTS FOR PRODUCTION TO LAW OFFICES, P.S. OLYMPIA, WASHINGTON 98501
DEFENDANT GRANT BECK ATTORNEYS AT Lew (360) 534-9183 FAX: (360) 956 -9795
AND ANSWERS THERETO - 18
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3. The applicant for the building permit is shown on the face of the building permit application as
Dan Lee of Triance Homes.
4. The City of Yelm issued the building permit. Gary Carlson, Yelm Building Official, signed the
permit.
5. An application for building permit for a single family residence in the Palisades West
subdivision was made to the Community Development Department on September 5, 2008 by Dan Lee.
Mr. Lee requested that Gary Carlson, the Building Official for Yelm, consider the permit in place of the
model home allowed by the final plat condition, because the developer was not proceeding with the
construction of a model home. Construction, but not occupancy, of a model home was allowed under
the initial condition of final subdivision, provided a fire protection plan was approved to protect even the
limited potential risk to public safety from a fire in an unoccupied structure.
Mr. Lee informed Mr. Carlson that the booster pump station and pressure sustaining valve
required by the plat conditions would be in place before occupancy of the home. Thereafter, Mr.
Carlson issued the building permit for the home in lieu of the model home with conditions on the face
the building plans stating that occupancy of the home would not be allowed without installation of the
booster pump station or pressure sustaining valve.
Based on the representations of Mr. Lee, the fact that the civil engineering and building plans for
both the pressure sustaining valve and water booster pump station were approved on July 8 and July 23,
2008 respectively. And given Mr. Lee's acknowledged understanding that the permit would allow
construction, but not occupancy of a model home, Mr. Carlson issued the building permit informing Mr.
Lee that a certificate of occupancy would not be issued unless the improvements had been installed and
conditioning the building permit and plans accordingly.
FIRST INTERROGATORIES AND
REQUESTS FOR PRODUCTION TO
DEFENDANT GRANT BECK
AND ANSWERS THERETO - 19
CUSHMAN 924 CAPITOL WAY SOUTH
LAW OFFICES, P.S. OLYMPIA, WASHINGTON 98501
ATTORNEYS AT Lew (360) 534-9183 FAX: (360) 956 -9795
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INTERROGATORY NO. 19: If you deny, in whole or in part (except if the denial is based on lack of
knowledge), any of Plaintiffs' statements and allegation made in their Complaint, please state each and
every fact upon which you base your denial, and identify every witness who can support your facts:
ANSWER:
This interrogatory refers to the Complaint, not the Amended Complaint. In the Complaint, there are a
number of allegations relating to the city of Doe. Mr. Beck knows absolutely nothing about any city of
Doe or the activities of the City of Doe. Mr. Beck specifically denies that he works for the city of Doe,
or that he performed the actions described in the Complaint relating to the city of Doe. The Complaint
is completely unintelligible, as it refers to some fictional city of Doe, and asserts that Mr. Beck
performed actions either within or without the scope of his employment with this fictional city of Doe.
INTERROGATORY NO. 20: If you allege any Affirmative Defenses, please identify:
a. Each and every fact upon which you base your affirmative defense(s).
b. Each and every witness who can support the facts upon which you base your affirmative
defense(s).
ANSWER:
Objection. Mr. Beck has not even begun discovery, and cannot now identify "each and every
fact" or every witness associated with his affirmative defenses.
However, the plaintiffs knew or should have known that the applicant for the subdivision
approvals and building permits had not performed all of the conditions relating to such
approvals /permits. The plaintiffs failed to file timely appeals of the actions complained of in the
Complaint, including the building permit issuance. At the time the Complaint was filed, the City
(assuming they meant the City of Yelm, not the City of Doe) hadn't acted on their plat amendment
application. Plaintiffs entered into a purchase and sale agreement with the applicant, which likely
FIRST INTERROGATORIES AND CUSHMAN 924 CAPITOL WAY SOUTH
REQUESTS FOR PRODUCTION TO LAW OFFICES, P.S. OLYMPIA, WASHINGTON 98501
DEFENDANT GRANT BECK ATTORNEYS AT Lew (360) 534-9183 FAX: (360) 956 -9795
AND ANSWERS THERETO - 20
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addressed the situation described in the Complaint.
As to witnesses, see the list provided by Mr. Beck in response to Interrogatory No. 14. Discovery
has not been performed as yet, and this list may be incomplete.
INTERROGATORY NO. 21: For each discussion concerning any Contract that you have had with
Plaintiffs or their agents, set forth the following:
a. Date of the discussion;
b. Names of those participating in the discussion;
C. Location of the discussion;
d. Length of the discussion;
e. A statement describing what was said in the conversation, who said what, and what you
understood them to mean; and
f. A description of each document which supports your responses to subparts a — e above.
ANSWER:
Objection. Again, the use of the term "contract" is unintelligible. Again, the only way Mr. Beck can
answer this interrogatory is by ignoring the plaintiffs' definition of "contract" and supplying a totally
different one. There has been no contract between Mr. Beck and the plaintiffs or their agents.
INTERROGATORY NO. 22: Please identify your relationship with Plaintiffs. Specifically identify:
a. Date relationship began;
b. Date relationship ended, if applicable;
C. Reason for termination of the relationship, if applicable;
d. The nature of the relationship;
e. The expectations you had of Plaintiffs by virtue of the relationship;
FIRST INTERROGATORIES AND CUSHMAN 924 CAPITOL WAY SOUTH
REQUESTS FOR PRODUCTION TO LAW OFFICES, P.S. OLYMPIA, WASHINGTON 98501
DEFENDANT GRANT BECK ATTORNEYS AT Lew (360) 534-9183 FAX: (360) 956 -9795
AND ANSWERS THERETO - 21
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f. The expectations you believe Plaintiffs had of you by virtue of the relationship; and
g. Any failures by you in fulfilling the duties to Plaintiffs identified herein.
ANSWER:
Mr. Beck first met the Smiths at a meeting in April of 2009. The remainder of the answers would be the
same as the answers set forth in response to Interrogatory No. 23..
INTERROGATORY NO. 23: Please identify your relationship with Dan Lee and Triance Homes.
Specifically identify:
a. Date relationship began;
b. Date relationship ended, if applicable;
C. Reason for termination of the relationship, if applicable;
d. The nature of the relationship;
e. The expectations you had of Dan Lee and Triance Homes by virtue of the relationship;
f. The expectations you believe Dan Lee and Triance Homes had of you by virtue of the
relationship; and
g. Any failures by you to Dan Lee and Triance Homes in fulfilling the duties identified
herein.
ANSWER:
a. Objection. Mr. Beck has no "relationship" with Dan Lee and Steve Chamberlain, so this
interrogatory assumes facts not in evidence. Dan Lee and Steve Chamberlain first approached the City
regarding the development of the Forrester property in May of 2005 when a pre- submission request was
submitted to the Community Development Department. FH1, LLC was identified as the applicant when
the preliminary subdivision was submitted to the Community Development Department in January of
FIRST INTERROGATORIES AND CUSHMAN 924 CAPITOL WAY SOUTH
REQUESTS FOR PRODUCTION TO LAW OFFICES, P.S. OLYMPIA, WASHINGTON 98501
DEFENDANT GRANT BECK ATTORNEYS AT Lew (360) 534-9183 FAX: (360) 956 -9795
AND ANSWERS THERETO - 22
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2006. In other words, they were prospective permit applicants, and Mr. Beck was the Community
Development Director. This does not imply any type of "relationship."
b. According to records from the Washington Secretary of State's Office, the corporation expired
on September 30, 2009, and was dissolved on January 4, 2010.
C. The Corporation was dissolved.
d. FHI, LLC is a Limited Liability Corporation which applied for a subdivision of the James
Forrester property in the City of Yelm. Steve Chamberlain and Dan Lee acted as agents of the LLC
throughout the subdivision review process.
e. Objection, assumes facts not in evidence. Mr. Beck had no relationship with Dan Lee and Steve
Chamberlain. Applicants for permits /approvals are expected to conform to all applicable codes and to
comply with all conditions of the permits /approvals.
f Objection, assumes facts not in evidence. Mr. Beck had no relationship with Dan Lee and Steve
Chamberlain. Mr. Beck has no idea what expectations Dan Lee and Steve Chamberlain had of Mr.
Beck, other than for Mr. Beck to perform his job responsibilities.
g. See answer to (e) above. To the extent that the applicants for permits /approvals did not conform
to all applicable codes and comply with all conditions of the permits /approvals, they are responsible for
the consequences. The property owners also share responsibility for the condition of the property,
because it does not conform to the permits /approvals.
INTERROGATORY NO. 24: Please identify your relationship with FHI, LLC. Specifically
identify:
a. Date relationship began;
b. Date relationship ended, if applicable;
C. Reason for termination of the relationship, if applicable;
FIRST INTERROGATORIES AND CUSHMAN 924 CAPITOL WAY SOUTH
REQUESTS FOR PRODUCTION TO LAW OFFICES, P.S. OLYMPIA, WASHINGTON 98501
DEFENDANT GRANT BECK ATTORNEYS AT Lew (360) 534-9183 FAX: (360) 956 -9795
AND ANSWERS THERETO - 23
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d. The nature of the relationship;
e. The expectations you had of FH1, LLC by virtue of the relationship;
f. The expectations you believe FH1, LLC had of you by virtue of the relationship; and
g. Any failures by you in fulfilling the duties to FH1, LLC identified herein.
ANSWER:
a. Objection. Mr. Beck has no "relationship" with Dan Lee and Steve Chamberlain, so this
interrogatory assumes facts not in evidence. Mr. Beck first met Steve Chamberlain in April of 2003 at
pre- submission meeting for the development of the Yelm Terra subdivision.
b. Not applicable.
C. Not applicable.
d. Objection, Mr. Beck is the Community Development Director for the City of Yelm. Steve
Chamberlain has acted as developer or the engineer representing various development projects in Yelm,
including the subdivision of Yelm Terra, the Tahoma Terra Master Planned Community, the Thurston
Highlands Master Planned Community, the subdivision of Forrester Heights (Palisades West), the short
subdivision of the Burnett Road commercial park, and other projects in Yelm. Other than the fact that
Mr. Chamberlain has submitted applications for approvals to the City, there is no "relationship" between
Mr. Beck and Mr. Chamberlain.
e. Objection, assumes facts not in evidence. Mr. Beck had no relationship with Mr. Chamberlain
and his company. Applicants for permits /approvals are expected to conform to all applicable codes and
to comply with all conditions of the permits /approvals.
f. Objection, assumes facts not in evidence. Mr. Beck had no relationship with Steve Chamberlain
and his company. Mr. Beck has no idea what expectations Steve Chamberlain had of Mr. Beck, other
than for Mr. Beck to perform his job responsibilities.
FIRST INTERROGATORIES AND CUSHMAN 924 CAPITOL WAY SOUTH
REQUESTS FOR PRODUCTION TO LAW OFFICES, P.S. OLYMPIA, WASHINGTON 98501
DEFENDANT GRANT BECK ATTORNEYS AT Lew (360) 534-9183 FAX: (360) 956 -9795
AND ANSWERS THERETO - 24
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g. See answer to (e) above. To the extent that the applicants for permits /approvals did not conform
to all applicable codes and comply with all conditions of the permits /approvals, they are responsible for
the consequences. The property owners also share responsibility for the condition of the property,
because it does not conform to the permits /approvals.
INTERROGATORY NO. 25: Please identify your relationship with Steve Chamberlain. Specifically
identify:
a. Date relationship began;
b. Date relationship ended, if applicable;
C. Reason for termination of the relationship, if applicable;
d. The nature of the relationship;
e. The expectations you had of Steve Chamberlain by virtue of the relationship;
f. The expectations you believe Steve Chamberlain had of you by virtue of the
relationship; and
g. Any failures by you in fulfilling the duties to Steve Chamberlain identified herein.
ANSWER:
See above answer to No. 24.
INTERROGATORY NO. 26: Please identify any and all general or specific performance or
development bonds FHI, LLC or other entity on its behalf, had or has with the City of Yelm which
could be, or could have been, used to implement any of the improvements for Palisades West f /k/a
Forrester Heights that were made conditions of preliminary and final plat approval. Your answer is to
FIRST INTERROGATORIES AND
REQUESTS FOR PRODUCTION TO
DEFENDANT GRANT BECK
AND ANSWERS THERETO - 25
CUSHMAN 924 CAPITOL WAY SOUTH
LAW OFFICES, P.S. OLYMPIA, WASHINGTON 98501
ATTORNEYS AT Lew (360) 534-9183 FAX: (360) 956 -9795
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include, but is not limited to, any performance bond to install the two final plat conditions (see p. 3 of
Complaint). As to each bond, identify:
(a) the date the bond was posted and the amount bonded;
(b) the financial entity who posted the bond;
(c) the requirements imposed before the bond could be released or satisfied;
(d) the date the bond was released or satisfied.
ANSWER:
None. The developer provided a warranty agreement.
INTERROGATORY NO. 27:
If no performance or development bonds were required by FHI, LLC or another entity on its behalf, for
the performance of the two final plat conditions, explain your rationale for not requiring them or making
no recommendation to require them.
ANSWER:
The City is not required to require such bond. In addition, the applicant for final plat approval
represented to the City (both verbally and in written documentation) that it would be immediately
constructing the booster pump station after approval of the design by the City and Department of Health.
Conditions requiring the booster pump station and pressure sustaining valve to be in place and
operational before occupancy of any structure on the property appeared to be sufficient incentive to
ensure that the developer proceed with the required improvements. In addition, Mr. Chamberlain signed
a warranty agreement in which he agreed to complete the required improvements in a timely manner.
Mr. Chamberlain defaulted on his agreement. The applicant/property owner(s), not the City, is
responsible for compliance with all codes and to perform the conditions of any approval /permit. There
was no appeal of the City's final decision on the final plat (without a requirement for a bond).
FIRST INTERROGATORIES AND
REQUESTS FOR PRODUCTION TO
DEFENDANT GRANT BECK
AND ANSWERS THERETO - 26
CUSHMAN 924 CAPITOL WAY SOUTH
LAW OFFICES, P.S. OLYMPIA, WASHINGTON 98501
ATTORNEYS AT Lew (360) 534-9183 FAX: (360) 956 -9795
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INTERROGATORY NO. 28:
Explain why you granted or authorized the granting of Plaintiffs' building permit in advance of the
installation of the water booster pump station, contrary to Final Plat Condition No. 1 (see p. 3 of
Complaint).
ANSWER:
The building permit application demonstrated compliance with the applicable codes. The development
approvals included additional conditions that the applicant was required to perform. These additional
conditions of development, which had to be performed before the City would issue a certificate of
occupancy, were reflected on the face of the approved plans. In addition, the applicant was informed of
the need for compliance with the conditions prior to issuance of a certificate of occupancy. The
applicant/property owner(s), not the City, is responsible for compliance with all codes and to perform
the conditions of any approval /permit. If the plaintiffs believed that issuance of the building permit was
erroneous, they could have appealed it in a timely manner.
TNTT RRl1!` A Tl1RV 1V" 70•
Explain why you changed or authorized a change of Final Plat Condition No. 1 from the building permit
requirement, to an occupancy permit, thus allowing Plaintiffs to begin and complete a residence they
cannot legally occupy (see Complaint at Paragraph 4.7a). Explain the procedures you took to implement
this change to the Final Plat conditions.
ANSWER:
The City's allowance for a model home is contemplated by state law (RCW 58.17.205), to allow
homebuilders to operate a sales office prior to completion of a subdivision. Typically model homes are
completed before the subdivision is finished but are connected to all utilities, including water and sewer.
In the case of Palisades West, the developer requested that the final subdivision condition allow
for the construction of a model home, knowing that it could not be occupied even as a sales office until
the water booster pump and pressure sustaining valve were installed, even though the subdivision was
FIRST INTERROGATORIES AND CUSHMAN 924 CAPITOL WAY SOUTH
REQUESTS FOR PRODUCTION TO LAW OFFICES, P.S. OLYMPIA, WASHINGTON 98501
DEFENDANT GRANT BECK ATTORNEYS AT Lew (360) 534-9183 FAX: (360) 956 -9795
AND ANSWERS THERETO - 27
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recorded. The purpose of the subdivision condition was to allow construction of a model home to begin
so as to be ready for occupancy once the booster pump and a pressure sustaining value were in place.
As stated above, the City repeatedly informed the applicants that the remaining final plat
conditions would have to be constructed prior to the time that the City issued a certificate of occupancy.
This was also written on the face of the building plans.
REQUESTS FOR PRODUCTION
REQUEST FOR PRODUCTION NO. 1: Provide copies of any documentation relating
to any Contract, amendment, modification, addition, or deletion thereto.
RESPONSE:
Objection. The definition of "contract" is too ambiguous. If the plaintiffs want a copy of
the preliminary plat, final plat, building permit files (as they currently exist) or any other
document, all they need to do is identify it and the City will provide a copy to them.
REQUEST FOR PRODUCTION NO. 2: Please produce all correspondence and
documents to which you have access related to this Project.
RESPONSE:
Objection. The identification of documents as "all correspondence and documents to
which you have access related to this Project" is ambiguous. If the plaintiffs want a copy
of the City's files (as they currently exist) relating to the preliminary plat, final plat,
building permit or plat amendment for the Palisades West subdivision, all they need to do
is request such documents and the City will provide copies.
REQUEST FOR PRODUCTION NO. 3: Please produce all logs, diaries, notes or
other documents that recorded any event, conversation, observation or activity related to
this Project.
FIRST INTERROGATORIES AND CUSHMAN 924 CAPITOL WAY SOUTH
REQUESTS FOR PRODUCTION TO LAW OFFICES, P.S. OLYMPIA, WASHINGTON 98501
DEFENDANT GRANT BECK ATTORNEYS AT Lew (360) 534-9183 FAX: (360) 956 -9795
AND ANSWERS THERETO - 28
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RESPONSE:
Objection as to scope. The definition of "project" in these interrogatories is limited to the
"land and constructed house" that is apparently now owned by the plaintiffs. This
interrogatory is not limited as to time, and apparently would include all "logs, diaries,
notes or other documents that recorded any event, conversation, observation or activity"
related to the land, prior to any preliminary plat approval. Furthermore, this interrogatory
is not limited to the documents in the City's files, but apparently includes documents in
the files of the new owner (the bank), the previous owner, the plaintiffs, or anyone else.
Some of this information is already in the hands of the plaintiffs. If the plaintiffs restrict
their interrogatory to documents in Mr. Beck's possession or the City's files, with a time
limit, Mr. Beck will be able to respond to this request for production.
REQUEST FOR PRODUCTION NO. 4: To the extent not otherwise requested, please
produce any and all documents related to this Project in any way.
RESPONSE:
See above.
REQUEST FOR PRODUCTION NO. 5: To the extent not otherwise requested, please produce any
and all documents related to or referred to in any of your answers to these Interrogatories.
RESPONSE: Objection as to scope. These interrogatories ask for all information known by person
other than Mr. Beck, for documents relating to the "land" upon which the plaintiffs' home is
constructed, for a description of all activities associated with the permitting and development of
Palisades West subdivision. This interrogatory is too broad. If the plaintiffs want copies of the existi
City files on the preliminary plat, final plat, building permit, plat amendment, etc., the plaintiffs
only to let us know and copies will be made.
FIRST INTERROGATORIES AND
REQUESTS FOR PRODUCTION TO
DEFENDANT GRANT BECK
AND ANSWERS THERETO - 29
CUSHMAN 924 CAPITOL WAY SOUTH
LAW OFFICES, P.S. OLYMPIA, WASHINGTON 98501
ATTORNEYS AT Lew (360) 534-9183 FAX: (360) 956 -9795
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DATED this day of December, 2009.
CUSHMAN LAW OFFICES, P.S.
Ben D. Cushman, WSBA # 26358
Attorney for Plaintiffs
The undersigned attorney for the named Defendants has read the foregoing Interrogatories and
Requests for Production of Documents to Defendants and the answers thereto and they are in
compliance with CR 26(g).
DATED on this day of , 2010.
Attorney for Defendants
STATE OF WASHINGTON)
ss
County of )
I , being first duly sworn on oath, deposes and says:
I am one of the Defendants in the above - entitled action; have read the above Answers to
Interrogatories and Response to Request for Production of Documents and believe the same to be true.
By:
(signature)
SUBSCRIBED AND SWORN TO before me this day of
11:
NOTARY PUBLIC in and for the State of
FIRST INTERROGATORIES AND CUSHMAN 924 CAPITOL WAY SOUTH
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DEFENDANT GRANT BECK ATTORNEYS AT Lew (360) 534-9183 FAX: (360) 956 -9795
AND ANSWERS THERETO - 30
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FIRST INTERROGATORIES AND
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DEFENDANT GRANT BECK
AND ANSWERS THERETO - 31
Residing at:
CUSHMAN 924 CAPITOL WAY SOUTH
LAW OFFICES, P.S. OLYMPIA, WASHINGTON 98501
ATTORNEYS AT Lew (360) 534-9183 FAX: (360) 956 -9795
1 DATED this day of December, 2009.
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CUSHMAN LAW OFFICES, P.S.
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Ben D. Cushman, WSBA # 26358
5 Attorney for Plaintiffs
6 The undersigned attorney for the named Defendants has read the foregoing Interrogatories and
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8 Requests for Production of Documents to Defendants and the answers thereto and they are in
9 compliance with CR 26(g).
10 DATED on this ]I— day of
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STATE OF WASHINGTON)
ss
County
being first duly sworn on oath, deposes and says:
I am one of the Defendants in the above - entitled action z have read the above Answers to
Interrogatories and Response to Request for
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SUBSCR
24 � O `S-WORN TO
F �• psT
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27 p,:.
FIRST iNTERRO'6A"IT(JR(ES AND
28 REQUESTS FOR PRODUCTION TO
DEFENDANT GRANT BECK
AND ANSWERS THERETO - 30
and believe the same to be true.
to this day of Zt ` q- fit/ 2%8.
r/ 11/Z ,r, z,
NOTARY PUBLICin and for the State of
CUSHMAN 924 CAPITOL WAY sourr i
L.NW OFFICES, P.S. OLYMPIA, WASIIINGTov 98501
MTORNEYS NF LAW (W)) 534 -9183 FAX; (360) 956-9795
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FIRST INTERROGATORIES AND
28 REQUESTS FOR PRODUCTION TO
DEFENDANT GRANT BECK
AND ANSWERS THERETO - 31
Residing at:
CUSI- Ii•IAN
LAW OFFICES, P.S.
A'E'FOt2tiliY'S : \T )..:11Y'
924 CA 1111-01, WAY SOU y] I
OLYMPIA, %VASIIINGCON 98,501
(360) 534-9183 FAX: (360) 956.9795