STATE OF WASHINGTON THURSTON COUNTY SUPERIOR COURT JUDGMENT JUDGMENT SUMMARY (RCW )

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1 2 F I L JAN t ZU Superior Courl Linda.Myhre F Thurston Count% STATE OF WASHINGTON THURSTON COUNTY SUPERIOR COURT STATE OF WASHINGTON, NO V. Plaintiff, SEIU ; and SEIU QUALITY CARE COMMITTEE, STIPULATION AND AGREED JUDGMENT JUDGMENT SUMMARY (RCW..00) A. JUDGMENT CREDITOR: Plaintiff, STATE OF WASHINGTON B. JUDGMENT DEBTORS: SEIU ; and SEIU QUALITY CARE COMMITTEE C. PRINCIPAL JUDGMENT: $2, with $,2.0 suspended for a period of years contingent on no further violations of the law during the period of suspension for Defendant SEIU and $,000 with $,00 suspended for a period of years contingent on no further violations of the law during the period of suspension for Defendant SEIU Quality Care Committee D. INTEREST: No prejudgment interest is owed. Principal judgment amount(s) due and owing shall not bear interest unless the principal judgment is unpaid by the due date specified herein E. COSTS AND FEES: $, as attorney fees and court costs $,.0 in investigation costs F. ATTORNEYS FOR ROBERT W. FERGUSON JUDGMENT CREDITOR Attorney General STIPULATION AND I ATTORNEY GENERAL OF WASHINGTON 2 Washington Street SE P PO Box 000 Olympia, WA (0) -00

2 LINDA A. DALTON, WSBA No. Senior Assistant Attorney General 2 CHAD C STANDIFER, WSBA No. Assistant Attorney General G. ATTORNEY FOR DMITRI IGLITZIN, WSBA No. JUDGMENT DEBTOR Schwerin Campbell Barnard Iglitzin & Lavitt, LLP STIPULATION The parties to this stipulation, Plaintiff, STATE OF WASHINGTON, (STATE) and the Defendants, SEIU and SEIU QUALITY CARE COMMITTEE, being desirous of g resolving all claims arising out of the State's complaint, hereby enter into the following stipulation: 0 A. Defendant SEIU. Defendant SEIU agrees to pay an assessed civil penalty in the amount of $2, for 2 its violations of RCW 2.A by failing to properly report contributions it made to Defendant SEIU QUALITY CARE COMMITTEE and failing to report the value of in-kind services, and administrative costs it provided to Defendant SEIU QUALITY CARE COMMITTEE, each of which should have been reported on its Lobbyist Employer Reports. 2. The parties agree that $,2.0 of the assessed civil penalty will be suspended based on 8 the following terms and conditions: a. The suspension will be in effect for four years from the date of execution of the Judgment. During the period of suspension, Defendant SEIU agrees that it will 2 not violate any provision of RCW 2.A. In the event Defendant SEIU is found to have committed any violation of RCW 2.A during the suspension 2 period, the suspended penalty of $,2.0 will immediately become due and 2 payable without further intervention of the Court. If, after four years, Defendant 2 SEIU has no violations of RCW 2.A, then the suspended portion of the 2 penalty will be set aside. STIPULATION AND 2 ATTORNEY GENERAL OF WASHINGTON 2 Washington Street SE PO Box 000 Olympia, WA (0)-00

3 2 b. Defendant SEIU agrees to work with the staff 'of the Public Disclosure Commission to bring its lobbyist employer contribution reports (either Forms L2 or Lc) current and to file amended five () annual lobbyist employer reports (Form L) which were due no later than the last day of February in the years - no later than 0 days from the date of the entry of the Judgment. ''. Defendant SEIU` agrees to pay. the State the unsuspended portion of the civil penalty ($,8.0) within 0 days of the date of entry of the Judgment. 8. Defendant SEIU agrees to pay, in a separate transmittal, the State the total amount of $,.0 as attorney fees, court costs, and costs of investigation in this action, this 0 amount to be paid within 0 days of the date of entry of the Judgment. B. Defendant SEIU QUALITY CARE COMMITTEE 2. Defendant SEIU QUALITY CARE COMMITTEE agrees to pay the State an assessed civil penalty in the amount of $,000 for its violations of RCW 2.A by failing to properly report the value of in-kind services and administrative costs it received from Defendant SEIU.. The parties agree that $,00 of the assessed civil penalty will be suspended based on the following terms and conditions: 8 C. The suspension will be in effect for four years from the date of execution of the Judgment. During the period of suspension, Defendant SEIU QUALITY CARE COMMITTEE agrees that it will not violate any provision of RCW 2.A. 2 In the event Defendant SEIU QUALITY CARE COMMITTEE is found to have committed any violation of RCW 2.A during the suspension period, the 2 suspended penalty of $,00 will immediately become due and payable without 2 further intervention of the Court. If, after four years, Defendant SEIU 2 2 STIPULATION AND ATTORNEY GENERAL OF WASHINGTON 2 Washington Street SE PO Box 000 Olympia, WA (0) -00

4 further intervention of the Court. If, after four years, Defendant SEIV 2 QUALITY CARE COMMITTEE has no violations of RCW 2.A, then the suspended portion of the penalty will be set aside ' d. Defendant SEIU QUALITY CARE COMMITTEE agrees to work with the staff of the Public Disclosure Commission to bring its contribution reports current no later than 0 days from the date of the entry of the Judgment.. Defendant SEIU QUALITY CARE COMMITTEE agrees to pay the State the 8 unsuspended portion of the civil penalty ($,00) within 0 days of the date of entry of the Judgment. 0 DATED this Kday of January,. ROBERT W. FERGUSON 2 Attorney General A. DALTON, SBA No. for Assistant Attorney General CHAD C. STANDIFER, WSBA No. Assistant Attorney General Attorne s for Plaintiff 8 DMITRI IGLITZINVW SEKNo. Schwerin Campbell Barnard Iglitzin & Lavitt, LLP Attorney for Defendants JUDGMENT 2 THIS MATTER came on regularly before the undersigned judge of the above-entitled Court. The Plaintiff, STATE OF WASHINGTON, appearing through its attorneys of record, 2 ROBERT W. FERGUSON, Attorney General, and LINDA A. DALTON, Senior Assistant 2 Attorney General, and CHAD C. STANDIFER, Assistant Attorney General and Defendants, 2 SEIU and SEIU QUALITY CARE COMMITTEE, appearing through their attorney, 2 DMITRI IGLITZIN, apprised the Court of their agreement to the entry of this judgment for the STIPULATION AND. Error! AntoTeat entry not defined.

5 having reviewed the records and files herein, and having found the settlement to be a just and proper resolution of this matter, and. being otherwise fully advised in the premises, now, therefore, it is hereby ORDERED that Defendant, SEIU, hereby is assessed a civil penalty, under the provisions of RCW 2.A, in the amount of $2, payable to the State of Washington. It is further ORDERED that the amount of $,2.0 of the assessed penalty is hereby suspended upon Defendant SEIU 's compliance with the following court-ordered conditions: a. The suspension shall be in effect for four years from the date of this judgment, during which time Defendant SEIU shall not violate any provision of RCW 2.A. In the event Defendant SEIU is found to have committed any violation of RCW 2.A during the suspended period, the suspended penalty of $,2.0 is immediately due and payable without any further intervention of the Court. If, after four years, Defendant SEN has no violations of RCW 2.A, then the suspended portion of the penalty will be set aside. b. Defendant SEIU shall work with the staff of the Public Disclosure Commission to bring its lobbyist employer contribution reports (either Forms L2 or Lc) current and shall file amended five () annual lobbyist employer reports (Form L) which were due no later than the last day of February in the years - no later than 0 days from the date of the entry of the Judgment. It is further ORDERED that Defendant SEIU shall pay to the State of Washington the unsuspended portion of the assessed civil penalty ($,8.0) within 0 days of the entry of this Judgment. It is further 2 STIPULATION AND ATTORNEY GENERAL OF WASHINGTON 2 Washington Street SE PO Box 000 Olympia, WA (0)-00

6 ORDERED that Defendant SEIU QUALITY CARE COMMITTEE hereby is 2 assessed a civil penalty, under the provisions of RCW 2.A, in the amount of $,000 payable to the State of Washington. It is further ORDERED that the amount of $,00 of the Defendant SEIU QUALITY CARE COMMITTEE'S assessed penalty is hereby suspended upon Defendant SEIU QUALITY CARE COMMITTEE's compliance with the following court-ordered conditions: a. The suspension shall be in effect for four years from the date of this judgment, 8 during which time Defendant SEIU QUALITY CARE COMMITTEE shall not violate any provision of RCW 2.A. In the event Defendant SEIU ' 0 QUALITY CARE COMMITTEE is found to have committed any violation of RCW 2.A during the suspended period, the suspended penalty of $,00 is 2 immediately due and payable without any further intervention of the Court. If, after four years, Defendant SEIU QUALITY CARE COMMITTEE has no violations of RCW 2.A, then the suspended portion of the penalty will be set aside. b. Defendant SEIU QUALITY CARE COMMITTEE shall work with the staff of the Public Disclosure Commission to bring its contribution reports current no later 8 than 0 days from the date of the entry of the Judgment. It is further ORDERED that Defendant SEIU QUALITY CARE COMMITTEE shall pay to 2 the State of Washington the unsuspended portion of the assessed civil penalty ($,00) within 0 days of the entry.of this Judgment. It is further 2 ORDERED that Defendant SEIU shall pay to the. State of Washington by separate 2 transmittal, the amount of $, as attorney fees and court costs and $,.0 as costs of 2 investigation as authorized under RCW 2.A.. 2 STIPULATION AND ATTORNEY GENERAL OF WASHINGTON 2 Washington Street SE PO Box 000 Olympia, WA (0)-00

7 DONE IN OPEN COURT this day of January,. 2'' ANNE HIRSCH Presented by: ROBERT W. FERGUSON Attorney General The Honorable ANNE HIRSCH, Judge 8 `iuanda A. DALTON, WSBA No. Senior Assistant Attorney General 0 CHAD C. STANDIFER, WSBA No. Assistant Attorney General Attorneys for Plaintiff 2 Approved as to Form: DNGTRI IGLITZ, W A No. Schwerin Campbell Barnard Iglitzin & Lavitt, LLP Attorney for Defendants STIPULATION AND Error! AutoTeat entry not defined.

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