IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON IN AND FOR THE COUNTY OF KING

Similar documents
17 CRS COMPLAINT. NOW COMES the Plaintiff, by and through counsel, complaining of the Defendants, and states and alleges as follows: PARTIES

IN THE SUPERIOR COURT FOR THE STATE OF WASHINGTON IN AND FOR KING COUNTY

IN THE CIRCUIT COURT OF THE STATE OF OREGON FOR THE COUNTY OF [COUNTY NAME]

8 IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON FOR PIERCE COUNTY 9 STATE OF WASHINGTON, 10. Defendant. I. INTRODUCTION

STATE OF WASIDNGTON KING COUNTY SUPERIOR COURT

AGREEMENT BETWEEN PIERCE COUNTY AND CITY OF University Place FOR ANIMAL SERVICES

SUPERIOR COURT OF CALIFORNIA COUNTY OF FRESNO CENTRAL DIVISION UNLIMITED CIVIL CASE ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON IN AND FOR THE COUNTY OF KING

COMPLAINT FOR DECLARATORY RELIEF AND PETITION FOR WRIT OF MANDAMUS. Introduction

10/30/2017 7:04 PM 17CV47399 IN THE CIRCUIT COURT OF THE STATE OF OREGON FOR THE COUNTY OF MULTNOMAH ) ) ) ) ) ) ) ) ) ) ) ) ) PARTIES

SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN BERNARDINO. Case No.: COMPLAINT ) ) ) ) ) ) ) ) ) ) ) )

Case 2:16-cv RSL Document 1 Filed 08/05/16 Page 1 of 13

Sequoia Park Associates, a California limited partnership, Petitioner and Plaintiff,

STATE OF WASHINGTON KING COUNTY SUPERIOR COURT

Case 4:08-cv RCC Document 1 Filed 02/25/08 Page 1 of 16 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA TUCSON DIVISION

SUPERIOR COURT OF WASHINGTON FOR CLARK COUNTY 9. Case No.

CAUSE NO. PLAINTIFF S ORIGINAL PETITION FOR DECLARATORY JUDGMENT AND APPLICATION FOR UNOPPOSED EXPEDITED RELIEF

Case 4:04-cv SBA Document 48-1 Filed 07/18/2006 Page 1 of 13

FILED 16 AUG 09 PM 2:59

SUPERIOR COURT OF THE STATE OF CALIFORNIA

IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON IN AND FOR KING COUNTY

Case 2:06-cv RSM Document 30 Filed 05/04/2006 Page 1 of 6

NO. 14 The Plaintiff, State of Washington, by and through its attorneys Robert W. Ferguson,

Case 3:14-cv RBL Document 26 Filed 10/23/14 Page 1 of 7 UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WASHINGTON AT TACOMA

IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

STATE OF WASHINGTON KING COUNTY SUPERIOR COURT NO. I. INTRODUCTION

THE SUPERIOR COURT OF THE STATE OF WASHINGTON IN AND FOR THE COUNTY OF PIERCE. Defendants, Defendant.

STATE OF WASHINGTON KING COUNTY SUPERIOR COURT

Case 2:17-cv Document 1 Filed 06/30/17 Page 1 of 16 PageID: 1

Case 3:17-cv JCS Document 1 Filed 06/15/17 Page 1 of 8

IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON IN AND FOR THE COUNTY OF KING. No SEA

IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT, IN AND FOR MIAMI-DADE COUNTY, FLORIDA

IN THE COURT OF COMMON PLEAS FRANKLIN COUNTY, OHIO

POLE ATTACHMENT LICENSE AGREEMENT SKAMANIA COUNTY PUD

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA -CIVIL DIVISION-

Plaintiff, COMPLAINT FOR CIVIL

FILED 18 AUG 30 AM 11:45

IN THE SUPERIOR COURT OF THE STATE OF WASINGTON IN AND FOR THE COUNTY OF YAKIMA

STATE OF WASHINGTON KING COUNTY SUPERIOR COURT NO.

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA-SOUTHERN DIVISION ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

Case 8:10-cv RWT Document 77 Filed 03/09/12 Page 1 of 15 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND

UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA CASE NO.: 1. BREACH OF IMPLIED CONTRACT 2. TRESPASS TO CHATTEL

SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES. Plaintiff, Defendants. General of the State of California, hereby alleges as follows:

FILED SAN MAteO COUNTY

STATE OF WASHINGTON KING COUNTY SUPERIOR COURT ) ) ) ) Plaintiff Mohamed A. Hussein ( Plaintiff ), by his attorneys and on behalf of all others

Case 3:18-cv Document 1 Filed 09/19/18 Page 1 of 12 UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA

Case: 1:15-cv Document #: 1 Filed: 02/03/15 Page 1 of 10 PageID #:1

SUPERIOR COURT OF THE STATE OF WASHINGTON FOR KING COUNTY ) ) ) ) ) ) ) ) ) ) ) ) ) )

Case 2:16-cv JCC Document 9 Filed 02/29/16 Page 1 of 7 IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WASHINGTON AT SEATTLE

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA

SUPERIOR COURT OF WASHINGTON IN AND FOR KING COUNTY

Case 2:16-cv RSL Document 75 Filed 06/28/17 Page 1 of 17

TELECOMMUNICATIONS RIGHT-OF-WAY USE FRANCHISE AGREEMENT

Case 4:08-cv CW Document 19 Filed 07/22/2008 Page 1 of 12

FILED. Attorneys for Plaintiffs SUPERIOR COURT OF THE STATE OF WASHINGTON FOR KING COUNTY

SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF ORANGE, CENTRAL JUSTICE CENTER ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )_ ) ) ) ) )

ORDINANCE NO. 725 (AS AMENDED THROUGH 725

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA

IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF BUTTE UNLIMITED JURISDICTION

STATE OF WASHINGTON, NO. 16' Plaintiff, COMPLAINT FOR CIVIL

SUPERIOR COURT OF WASHINGTON FOR KING COUNTY. Defendant FedEx Ground Package System, Inc. (hereinafter FedEx Ground ), by and

SUPERIOR COURT OF WASHINGTON FOR KING COUNTY

IN THE SUPERIOR COURT OF CALIFORNIA

Attorneys for Pinal County IN THE SUPERIOR COURT OF THE STATE OF ARIZONA IN AND FOR THE COUNTY OF PINAL. No.

UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA THIRD DIVISION

SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF KERN, NORTH KERN DISTRICT ) ) ) ) ) ) ) ) ) ) ) ) )

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA SACRAMENTO DIVISION

SUPERIOR COURT OF CALIFORNIA COUNTY OF YOLO. Plaintiff, Defendant. JEFF W. REISIG, District Attorney of Yolo County, by LARRY BARLLY, Supervising

Case 2:16-cv RSL Document 1 Filed 05/25/16 Page 1 of 10 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON AT SEATTLE NO.

Plaintiff Privacy Pop, LLC ( Plaintiff ) complains and alleges as follows against Defendant Gimme Gimme, LLC ( Defendant ).

IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON COUNTY OF KING NO.

Case 1:17-cv Document 1 Filed 08/30/17 Page 1 of 13 PageID #: 1. No.: Defendants.

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON TACOMA DIVISION. Plaintiff(s), Defendant(s).

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

IN THE CIRCUIT COURT OF THE SECOND JUDICIAL CIRCUIT IN AND FOR LEON COUNTY, FLORIDA

STATE OF WASHINGTON KING COUNTY SUPERIOR COURT NO. I. INTRODUCTION. action against Defendants Garnishment Services, LLC and Richard John Brees, d/b/a

IN THE CIRCUIT COURT OF BOONE COUNTY, MISSOURI

Case 4:14-cv Document 1 Filed in TXSD on 09/08/14 Page 1 of 6

FILED 16 AUG 29 PM 2:30

the Sheriff, Contra Costa County and DOES 1-20 seized his medical marijuana and destroyed it

IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON FOR KING COUNTY

THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

COMPLAINT FOR DECLARATORY JUDGMENT AND INJUNCTIVE RELIEF

IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON FOR THE COUNTY OF KING

United States Bankruptcy Court. Northern District of California ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF LOUISIANA. Plaintiff, Number:

Attorneys for Plaintiff STEVE THOMA UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA STEVE THOMA

SUPERIOR COURT OF WASHINGTON COUNTY OF STEVENS

11 CLASS ACTION COMPLAINT

IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA - CIVIL DIVISION - Plaintiff CASE NO.

Case 3:16-cv LB Document 1 Filed 06/11/16 Page 1 of 14

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

)(

Case 8:16-cv Document 1 Filed 03/18/16 Page 1 of 19 Page ID #:1

Plaintiff, COMPLAINT FOR CIVIL

SUPERIOR COURT OF WASHINGTON FOR KING COUNTY

Case 3:18-cv Document 1 Filed 10/03/18 Page 1 of 10 IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WASHINGTON AT TACOMA

UNITED STATES BANKRUPTCY COURT DISTRICT OF DELAWARE CASE # ADVERSARY # 7001(2)

7 IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON IN AND FOR THE COUNTY OF PIERCE 8 STATE OF WASHINGTON, 9 Plaintiff,

Transcription:

1 1 1 1 LARRY GALLAWA, vs. IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON IN AND FOR THE COUNTY OF KING Plaintiff, THE HUMANE SOCIETY SOCIETY FOR TACOMA & PIERCE COUNTY, a Washington nonprofit corporation (UBI - 00-0); PIERCE COUNTY, a Washington municipal corporation; and DOES 1-; Defendants. Case No.: 0--- SEA JURISDICTION, PARTIES, AND VENUE The Honorable Helen Halpert ACT 1. This court has subject-matter jurisdiction over this action under RCW.0.0.. All of the events complained of herein occurred in Pierce County, Washington.. Plaintiff LARRY GALLAWA (hereinafter Gallawa ) is an individual residing in the City of Redmond, King County, State of Washington.. Defendant THE TACOMA-PIERCE COUNTY HUMANE SOCIETY ( TPCHS ) is, and at all times herein was, a Washington non-profit corporation duly incorporated in the State of Washington with its principal place of business in Tacoma, Pierce County, Washington. At the time of the events complained of, TPCHS contracted with Pierce County to provide core governmental services, viz., animal care and control. ACT - 1 W. Magnolia St., Ste. Bellingham, WA

1 1 1 1. Defendant PIERCE COUNTY ( County ) is a municipal corporation and organized under the laws of the State of Washington. At the time of the events complained of, County fully delegated all core animal control-related governmental tasks to TPCHS.. Plaintiff is ignorant of the true names and capacities, whether individual, corporate or otherwise, of Defendants Does 1-, inclusive, and therefore sues said Defendants by said fictitious names. Plaintiff is informed and believes, and based on that information and belief alleges, that each of the Defendants sued herein under a fictitious name is responsible in some manner for the events and occurrences referred to herein. When the true names, capacities and involvement of said Defendants are ascertained, Plaintiff will seek leave to amend the complaint accordingly.. This matter is properly venued in King County, pursuant to RCW.01.00. ACT - GENERAL ALLEGATIONS 1. Beginning in or about June 0 and for several months thereafter, Gallawa repeatedly submitted several public disclosure requests to TPCHS concerning allegations of animal cruelty and neglect involving Scudder Aviary, Cripple Creek Aviary, and Binning Aviary.. TPCHS, through its officers and agents, expressly denied Gallawa s requests, claiming that it was not subject to the Public Disclosure Act.. In late 0, after receiving blanket denials from TPCHS, Gallawa repeatedly submitted several public disclosure requests to County concerning the same or similar records requested of TPCHS. In some of these communications, Gallawa informed County of TPCHS s position.. County, through its contract with TPCHS, had access to these requested records. Indeed, in one instance, an employee for County requested one of these requested records from TPCHS, which she then forwarded to Gallawa.. Aside from this single record, the County refused Gallawa s requests to obtain the records from TPCHS. Accordingly, it failed to provide the fullest assistance required under the Public Disclosure Act.. TPCHS, at the time of events complained of, was charged with faithfully enforcing all ordinances, regulations, and laws relative to licensing, impounding, and care of animals, dangerous animals or animals creating nuisances, and animals diseased or suspected of being diseased in County. TPCHS also took an active role in investigating animal cruelty and neglect. The County delegated its core animal control functions virtually in W. Magnolia St., Ste. Bellingham, WA

1 1 1 1 toto to TPCHS, in which it vested final decision-making authority for its governmental ends and purposes.. The records requested by Gallawa of TPCHS and County were employed for, applied to, or made instrumental to a governmental end or purpose. FIRST CLAIM FOR RELIEF RESPONDEAT SUPERIOR 1. At all times relevant to this matter, Does 1- were employees and supervisors acting in the course and scope of their employment relationship with defendants.. Defendants are vicariously liable for the alleged statutory violations of their employees and supervisors on the basis of respondeat superior. SECOND CLAIM FOR RELIEF PUBLIC DISCLOSURE ACT VIOLATION (Ch.. RCW). Gallawa is entitled to an award of reasonable attorney s fees and costs for bringing this action, plus sanctions of up to one hundred ($0) dollars per day for each day TPCHS has denied and continues to unreasonably deny access to the requested documents under RCW..0.. Gallawa is entitled to an award of reasonable attorney s fees and costs for bringing this action, plus sanctions of up to one hundred ($0) dollars per day for each day County has denied and continues to unreasonably deny access to the requested documents under RCW..0.. This suit is filed within the five-year statute of limitations, under RCW.... Defendants violated the Public Disclosure Act by failing to provide Gallawa the fullest assistance in promptly responding to his several requests.. Defendants acted in bad faith. THIRD CLAIM FOR RELIEF DECLARATORY RELIEF (Ch.. RCW). Gallawa is entitled to a declaratory judgment that TPCHS and all similarly-situated entities contracting with municipalities to provide core animal control services are subject to the Public Disclosure Act. FOURTH CLAIM FOR RELIEF PERMANENT INJUNCTIVE RELIEF. This court has the power under RCW.0 to enjoin TPCHS and similarly-situated ACT - W. Magnolia St., Ste. Bellingham, WA

1 1 1 1 entities from taking illegal actions in violation of Gallawa s rights and those similarly situated.. Gallawa is entitled to permanent injunctive relief, in the form of an Order requiring TPCHS and similarly-situated entities to comply with all properly propounded public disclosure requests, pursuant to Ch.. RCW. PRAYER WHEREFORE, Plaintiff prays for judgment against Defendants as follows: 1. For a finding that Defendants are vicariously liable for the acts of their employee(s) and supervisor(s) Doe(s) 1-.. For reasonable attorney s fees as allowed by law, RCW..0, or, in the alternative, statutory attorney s fees in the amount of $0;. Declaratory and injunctive relief as stated above;. For postjudgment interest at 1% per annum or the highest rate permitted by law, pursuant to RCW..1;. For penalties of $0 a day against each Defendant as provided by RCW..0; and. For such other and further relief as the Court may deem just and proper. Dated this September, 0. LAW OFFICE OF ADAM P. KARP /s/ Adam P. Karp Adam P. Karp, WSBA No. Attorney for Plaintiff ACT - W. Magnolia St., Ste. Bellingham, WA

[Sadly, Mr. Gallawa had to sue the Humane Society to get records which should have been made readily available to him under the Freedom of Information Act. The picture with the Pierce County Humane Society is further besmirched by allegations that Martha Scudder was informed by Wally Hall in advance of any upcoming inspections by the PCHS : Her [Martha's] comment was that she just had Wally Hall in the palm of her hand. [Deposition of K. Scudder; Pt. I] Editors.]