[WSBARP] WSBARP Digest, Vol 106, Issue 23
Stephen Whitehouse
swhite8893 at aol.com
Thu Jul 27 14:39:52 PDT 2023
Paul, I think a preliminary injunction just complicates things. I tend to look for certainty or result as opposed to worrying about time frame. Also, I think some of this tends to depend on your local sheriff's department. We simply name all unknown occupants at such and such an address and send a process server out the and provide paperwork to whoever is there. The debate we have is whether we do an UD or an ejectment. The ejectment has less procedural traps. Also, a squatter is not a tenant. So in that instance you can't use 59.12. In the ejectment action, we ask for a Writ of Assistance, which a lot of sheriff's departments never heard of. When we first did one years ago, they conferred with a deputy prosecutor that we were working with and since then, no problem. As to the unknown occupants part of it, our sheriff's department is fine with it. But I think that is a county by county thing.
Steve
Stephen WhitehouseWhitehouse & Nichols, LLPP.O. Box 1273601 W. Railroad Ave. Shelton, Wa. 98584360-426-5885swhite8893 at aol.com
On Thursday, July 27, 2023 at 12:00:18 PM PDT, <wsbarp-request at lists.wsbarppt.com> wrote:
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Today's Topics:
1. Employment Law Referral for Dallas/Fort Worth (Annie Fitzsimmons)
2. Title Co's Request for Re-record of 1994 Deed
(Jeff at bellanddavispllc.com)
3. Re: Title Co's Request for Re-record of 1994 Deed (Bryce Dille)
4. Re: Title Co's Request for Re-record of 1994 Deed
(Jeff at bellanddavispllc.com)
5. Re: Off Topic - Whatcom Criminal Attorney? (Haylee Hurst)
6. Litigator Help -- Ejectment (Paul Neumiller)
7. Re: Litigator Help -- Ejectment (Bryce Dille)
8. Re: Litigator Help -- Ejectment (Paul Neumiller)
9. Re: Title Co's Request for Re-record of 1994 Deed (Mark Anderson)
10. Re: Title Co's Request for Re-record of 1994 Deed (Mark Anderson)
11. Re: WSBARP Digest, Vol 106, Issue 22 (YP Wang)
12. Property Manager (Meyler Legal, PLLC)
13. Re: Property Manager (Bryce Dille)
14. Re: Litigator Help -- Ejectment (Paul Neumiller)
15. Re: Litigator Help -- Ejectment (Eric Nelsen)
16. North Carolina Counsel (Stromberg, Spencer)
17. Re: Litigator Help -- Ejectment (Sarah McCarthy)
18. Re: Litigator Help -- Ejectment (Sarah McCarthy)
19. Building Permit help in Winthrop (Dean Prather)
----------------------------------------------------------------------
Message: 1
Date: Wed, 26 Jul 2023 12:09:10 -0700 (PDT)
From: Annie Fitzsimmons <atfitz at comcast.net>
To: "wsbarp at lists.wsbarppt.com" <wsbarp at lists.wsbarppt.com>
Subject: [WSBARP] Employment Law Referral for Dallas/Fort Worth
Message-ID: <239681154.792807.1690398550596 at connect.xfinity.com>
Content-Type: text/plain; charset="utf-8"
I know this is a long shot but does anyone have a recommendation? This would be an employee/plaintiff's claim.
Thanks! Annie
Annette T. Fitzsimmons P.S.
P.O. Box 430
Belfair, WA 98528
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Message: 2
Date: Wed, 26 Jul 2023 12:51:28 -0700
From: <Jeff at bellanddavispllc.com>
To: "'WSBA Real Property Listserv'" <wsbarp at lists.wsbarppt.com>
Subject: [WSBARP] Title Co's Request for Re-record of 1994 Deed
Message-ID: <004901d9bffa$91ddc620$b5995260$@bellanddavispllc.com>
Content-Type: text/plain; charset="us-ascii"
Listmates:
In 1994, Sellers were Grantees under a Statutory Warranty Deed that
contained parcels 1 and 2. Fast forward to present day, like in the movies,
Sellers on the eve of closing, are told by title co. that parcel 2 was
erroneously attached to their 1994 deed, and that Seller needs to re-record
the 1994 deed to remove parcel 2. Can that be done? The Grantors of the
1994 deed are dead. Any thoughts?
Jeff Davis
W. Jeff Davis
BELL & DAVIS PLLC
Attorneys at Law
P.O. Box 510
720 E. Washington Street, Suite 105
Sequim WA 98382
Phone: (360) 683.1129
Fax: (360) 683.1258
email: <mailto:jeff at bellanddavispllc.com> jeff at bellanddavispllc.com
<http://www.bellanddavispllc.com/> www.bellanddavispllc.com
The information contained in this e-mail message may be privileged,
confidential, and protected from disclosure. If you are not the intended
recipient, any dissemination, distribution, or copying is strictly
prohibited. If you think that you have received this e-mail message in
error, please e-mail the sender at <mailto:info at bellanddavispllc.com>
info at bellanddavispllc.com or call 360.683.1129.
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Message: 3
Date: Wed, 26 Jul 2023 19:58:19 +0000
From: Bryce Dille <Bryce at dillelaw.com>
To: WSBA Real Property Listserv <wsbarp at lists.wsbarppt.com>
Subject: Re: [WSBARP] Title Co's Request for Re-record of 1994 Deed
Message-ID:
<MN0PR11MB6230F77FF25C6B0CD5442E43C800A at MN0PR11MB6230.namprd11.prod.outlook.com>
Content-Type: text/plain; charset="us-ascii"
Cant they just Quit Claim back the parcel that was erroneously included?
Bryce H. Dille
Dille Law, PLLC
2010 Caton Way SW Ste. 101
Olympia, WA 98502
Office: 360-350-0270
Cell: 253-579-5561
[R_Alan_Swanson-WH-200]
** Please note that I use the dictation feature of my iPhone and that sometimes everything I say does not get properly translated**
This transmission contains confidential attorney-client communications and may not be disclosed to any person but the intended recipient(s). If this matter is transmitted to you in error, please notify the sender immediately.
Business Entity Creation and Management, Business, Government and Tax Law, Real Estate and Land Use, Residential, Commercial and Condominium Development Real Estate and Commercial Transactions & Closings, Including Performing Services as IRS Section 1031 Exchange Facilitator Estate Planning, including Wills and Trusts, and Probate Administration Representation Homeowners/Condominium Association Real Estate Developments Real Property Foreclosures and Forfeitures.
From: wsbarp-bounces at lists.wsbarppt.com <wsbarp-bounces at lists.wsbarppt.com> On Behalf Of Jeff at bellanddavispllc.com
Sent: Wednesday, July 26, 2023 12:51 PM
To: 'WSBA Real Property Listserv' <wsbarp at lists.wsbarppt.com>
Subject: [WSBARP] Title Co's Request for Re-record of 1994 Deed
Listmates:
In 1994, Sellers were Grantees under a Statutory Warranty Deed that contained parcels 1 and 2. Fast forward to present day, like in the movies, Sellers on the eve of closing, are told by title co. that parcel 2 was erroneously attached to their 1994 deed, and that Seller needs to re-record the 1994 deed to remove parcel 2. Can that be done? The Grantors of the 1994 deed are dead. Any thoughts?
Jeff Davis
W. Jeff Davis
BELL & DAVIS PLLC
Attorneys at Law
P.O. Box 510
720 E. Washington Street, Suite 105
Sequim WA 98382
Phone: (360) 683.1129
Fax: (360) 683.1258
email: jeff at bellanddavispllc.com<mailto:jeff at bellanddavispllc.com>
www.bellanddavispllc.com<https://urldefense.proofpoint.com/v2/url?u=http-3A__www.bellanddavispllc.com_&d=DwMFAg&c=euGZstcaTDllvimEN8b7jXrwqOf-v5A_CdpgnVfiiMM&r=ZjJT61sMYHYXW1a7W0qvaz-zO3o_Ea2RRxXvW5Yr3-0&m=R04z5KHM0gsHaBTUDe4T_yJsF_AUzwNZwx0Ak4ATrxryhIKXkb0x34_ItiDmvZUh&s=RnXcHeJPSpz9ZIuEgOmnrd-ZAoMiQRS4BThg1zIf52E&e=>
The information contained in this e-mail message may be privileged, confidential, and protected from disclosure. If you are not the intended recipient, any dissemination, distribution, or copying is strictly prohibited. If you think that you have received this e-mail message in error, please e-mail the sender at info at bellanddavispllc.com<mailto:info at bellanddavispllc.com> or call 360.683.1129.
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Message: 4
Date: Wed, 26 Jul 2023 13:01:29 -0700
From: <Jeff at bellanddavispllc.com>
To: "'WSBA Real Property Listserv'" <wsbarp at lists.wsbarppt.com>
Subject: Re: [WSBARP] Title Co's Request for Re-record of 1994 Deed
Message-ID: <006001d9bffb$f8449140$e8cdb3c0$@bellanddavispllc.com>
Content-Type: text/plain; charset="us-ascii"
That's a thought; but just being curious, have Sellers been paying real
property taxes on parcel 2 all these years? Shouldn't they be reimbursed if
they have?
W. Jeff Davis
BELL & DAVIS PLLC
Attorneys at Law
P.O. Box 510
720 E. Washington Street, Suite 105
Sequim WA 98382
Phone: (360) 683.1129
Fax: (360) 683.1258
email: jeff at bellanddavispllc.com <mailto:jeff at bellanddavispllc.com>
<http://www.bellanddavispllc.com/> www.bellanddavispllc.com
The information contained in this e-mail message may be privileged,
confidential, and protected from disclosure. If you are not the intended
recipient, any dissemination, distribution, or copying is strictly
prohibited. If you think that you have received this e-mail message in
error, please e-mail the sender at <mailto:info at bellanddavispllc.com>
info at bellanddavispllc.com or call 360.683.1129.
From: wsbarp-bounces at lists.wsbarppt.com <wsbarp-bounces at lists.wsbarppt.com>
On Behalf Of Bryce Dille
Sent: Wednesday, July 26, 2023 12:58 PM
To: WSBA Real Property Listserv <wsbarp at lists.wsbarppt.com>
Subject: Re: [WSBARP] Title Co's Request for Re-record of 1994 Deed
Cant they just Quit Claim back the parcel that was erroneously included?
Bryce H. Dille
Dille Law, PLLC
2010 Caton Way SW Ste. 101
Olympia, WA 98502
Office: 360-350-0270
Cell: 253-579-5561
** Please note that I use the dictation feature of my iPhone and that
sometimes everything I say does not get properly translated**
This transmission contains confidential attorney-client communications and
may not be disclosed to any person but the intended recipient(s). If this
matter is transmitted to you in error, please notify the sender immediately.
Business Entity Creation and Management, Business, Government and Tax Law,
Real Estate and Land Use, Residential, Commercial and Condominium
Development Real Estate and Commercial Transactions & Closings, Including
Performing Services as IRS Section 1031 Exchange Facilitator Estate
Planning, including Wills and Trusts, and Probate Administration
Representation Homeowners/Condominium Association Real Estate Developments
Real Property Foreclosures and Forfeitures.
From: wsbarp-bounces at lists.wsbarppt.com
<mailto:wsbarp-bounces at lists.wsbarppt.com>
<wsbarp-bounces at lists.wsbarppt.com
<mailto:wsbarp-bounces at lists.wsbarppt.com> > On Behalf Of
Jeff at bellanddavispllc.com <mailto:Jeff at bellanddavispllc.com>
Sent: Wednesday, July 26, 2023 12:51 PM
To: 'WSBA Real Property Listserv' <wsbarp at lists.wsbarppt.com
<mailto:wsbarp at lists.wsbarppt.com> >
Subject: [WSBARP] Title Co's Request for Re-record of 1994 Deed
Listmates:
In 1994, Sellers were Grantees under a Statutory Warranty Deed that
contained parcels 1 and 2. Fast forward to present day, like in the movies,
Sellers on the eve of closing, are told by title co. that parcel 2 was
erroneously attached to their 1994 deed, and that Seller needs to re-record
the 1994 deed to remove parcel 2. Can that be done? The Grantors of the
1994 deed are dead. Any thoughts?
Jeff Davis
W. Jeff Davis
BELL & DAVIS PLLC
Attorneys at Law
P.O. Box 510
720 E. Washington Street, Suite 105
Sequim WA 98382
Phone: (360) 683.1129
Fax: (360) 683.1258
email: jeff at bellanddavispllc.com <mailto:jeff at bellanddavispllc.com>
<https://urldefense.proofpoint.com/v2/url?u=http-3A__www.bellanddavispllc.co
m_&d=DwMFAg&c=euGZstcaTDllvimEN8b7jXrwqOf-v5A_CdpgnVfiiMM&r=ZjJT61sMYHYXW1a7
W0qvaz-zO3o_Ea2RRxXvW5Yr3-0&m=R04z5KHM0gsHaBTUDe4T_yJsF_AUzwNZwx0Ak4ATrxryhI
KXkb0x34_ItiDmvZUh&s=RnXcHeJPSpz9ZIuEgOmnrd-ZAoMiQRS4BThg1zIf52E&e=>
www.bellanddavispllc.com
The information contained in this e-mail message may be privileged,
confidential, and protected from disclosure. If you are not the intended
recipient, any dissemination, distribution, or copying is strictly
prohibited. If you think that you have received this e-mail message in
error, please e-mail the sender at <mailto:info at bellanddavispllc.com>
info at bellanddavispllc.com or call 360.683.1129.
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Message: 5
Date: Wed, 26 Jul 2023 13:14:28 -0700
From: Haylee Hurst <haylee at bellinghamlegal.com>
To: wsbarp at lists.wsbarppt.com
Subject: Re: [WSBARP] Off Topic - Whatcom Criminal Attorney?
Message-ID:
<CAOfdhSqaQ=G7_1ORtS1ypZO+r_n3t4XN0ASgxwnwO1mOSYB-Dw at mail.gmail.com>
Content-Type: text/plain; charset="utf-8"
Kristi, I recommend Emily Beschen for criminal law - she is located in
Bellingham.
https://www.beschenlaw.com/emily-c-beschen
--
Haylee Hurst
Wolf Lee Hurst & Slattery, PLLP
(p) (360) 676-0306 ext. 1002
(d) (360) 602-3826
haylee at bellinghamlegal.com <Haylee at bellinghamlegal.com>
www.bellinghamlegal.com
This email is intended only for the use of the individual or entity to whom
it is addressed and may contain confidential, privileged information. If
the reader of this email is not the addressee, please be advised that any
dissemination, distribution or copying of this email is strictly
prohibited. If you receive this communication in error, please
immediately call 360-676-0306, return this email to Wolf Lee Hurst &
Slattery, PLLP at the above email address and delete it from your files.
Thank you.
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Message: 6
Date: Wed, 26 Jul 2023 20:20:57 +0000
From: Paul Neumiller <pneumiller at hotmail.com>
To: WSBA Real Property Listserv <wsbarp at lists.wsbarppt.com>
Subject: [WSBARP] Litigator Help -- Ejectment
Message-ID:
<MW3PR13MB3980B4E080E8C4323377DAD6D200A at MW3PR13MB3980.namprd13.prod.outlook.com>
Content-Type: text/plain; charset="us-ascii"
I need to eject a homeless encampment. I am also bringing a motion for a preliminary injunction to kick them out early but CR 65 and RCWs are unclear as to the required notice to the squatters. I am finding no guidance on required advance notice of my motion. CR 65 just says that no preliminary injunction shall be issued without notice to other side (absent emergency situation). And, RCW 7.40.050 says that the "opposite party" needs to have "reasonable notice of the time and place" of the hearing for the injunction. My local court rules say I need to give 12 day's notice for a motion. I was going to have the Sheriff serve the summons and complaint along with the motion for order for the preliminary injunction and give the squatters about 5 days advance notice but now I question if I should give the squatters 12 days advance notice. But, if I have to wait the 12 days, I might as well as skip the preliminary injunction and bring a default or motion for summary judgement !
after 20 days. What say you?
[cid:image001.jpg at 01D9BFC0.DD36EA50]
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Message: 7
Date: Wed, 26 Jul 2023 20:38:08 +0000
From: Bryce Dille <Bryce at dillelaw.com>
To: WSBA Real Property Listserv <wsbarp at lists.wsbarppt.com>
Subject: Re: [WSBARP] Litigator Help -- Ejectment
Message-ID:
<MN0PR11MB62300921DDC8063AFCB1E0B4C800A at MN0PR11MB6230.namprd11.prod.outlook.com>
Content-Type: text/plain; charset="us-ascii"
Who are you naming as defendants do you have the names of the squatters or are they all named as john does In addition to RCW 7.28 Cant you bring action under the RCW 59.16 unlawful entry and detainer or RCW 59.12(6)
Bryce H. Dille
Dille Law, PLLC
2010 Caton Way SW Ste. 101
Olympia, WA 98502
Office: 360-350-0270
Cell: 253-579-5561
[R_Alan_Swanson-WH-200]
** Please note that I use the dictation feature of my iPhone and that sometimes everything I say does not get properly translated**
This transmission contains confidential attorney-client communications and may not be disclosed to any person but the intended recipient(s). If this matter is transmitted to you in error, please notify the sender immediately.
Business Entity Creation and Management, Business, Government and Tax Law, Real Estate and Land Use, Residential, Commercial and Condominium Development Real Estate and Commercial Transactions & Closings, Including Performing Services as IRS Section 1031 Exchange Facilitator Estate Planning, including Wills and Trusts, and Probate Administration Representation Homeowners/Condominium Association Real Estate Developments Real Property Foreclosures and Forfeitures.
From: wsbarp-bounces at lists.wsbarppt.com <wsbarp-bounces at lists.wsbarppt.com> On Behalf Of Paul Neumiller
Sent: Wednesday, July 26, 2023 1:21 PM
To: WSBA Real Property Listserv <wsbarp at lists.wsbarppt.com>
Subject: [WSBARP] Litigator Help -- Ejectment
I need to eject a homeless encampment. I am also bringing a motion for a preliminary injunction to kick them out early but CR 65 and RCWs are unclear as to the required notice to the squatters. I am finding no guidance on required advance notice of my motion. CR 65 just says that no preliminary injunction shall be issued without notice to other side (absent emergency situation). And, RCW 7.40.050 says that the "opposite party" needs to have "reasonable notice of the time and place" of the hearing for the injunction. My local court rules say I need to give 12 day's notice for a motion. I was going to have the Sheriff serve the summons and complaint along with the motion for order for the preliminary injunction and give the squatters about 5 days advance notice but now I question if I should give the squatters 12 days advance notice. But, if I have to wait the 12 days, I might as well as skip the preliminary injunction and bring a default or motion for summary judgement !
after 20 days. What say you?
[cid:image003.jpg at 01D9BFC5.CEF70CE0]
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Message: 8
Date: Wed, 26 Jul 2023 20:47:10 +0000
From: Paul Neumiller <pneumiller at hotmail.com>
To: WSBA Real Property Listserv <wsbarp at lists.wsbarppt.com>
Subject: Re: [WSBARP] Litigator Help -- Ejectment
Message-ID:
<MW3PR13MB3980215A7B541E4E0E441025D200A at MW3PR13MB3980.namprd13.prod.outlook.com>
Content-Type: text/plain; charset="us-ascii"
One person was initially given permission to stay on the vacant lot so we have his name but then he invited about 10 other people. Caption will read "Known Joe Blow and all other Occupants" Permission has been withdrawn. No lease, no rent paid or demanded. So, RCW 59.16, 59.12, and 59.18 don't apply.
[cid:image001.jpg at 01D9BFC7.AB501690]
IMPORTANT NOTICE: This e-mail message is intended to be received only by persons entitled to receive the confidential information it may contain. E-mail messages to clients of Paul A. Neumiller presumptively contain information that is confidential and legally privileged; e-mail messages to non-clients are normally confidential and may also be legally privileged. Please do not read, copy, forward or store this message unless you are the intended recipient of it. If you have received this message in error, please forward it back to the sender and delete it completely from your computer system.
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From: wsbarp-bounces at lists.wsbarppt.com <wsbarp-bounces at lists.wsbarppt.com> On Behalf Of Bryce Dille
Sent: Wednesday, July 26, 2023 1:38 PM
To: WSBA Real Property Listserv <wsbarp at lists.wsbarppt.com>
Subject: Re: [WSBARP] Litigator Help -- Ejectment
Who are you naming as defendants do you have the names of the squatters or are they all named as john does In addition to RCW 7.28 Cant you bring action under the RCW 59.16 unlawful entry and detainer or RCW 59.12(6)
Bryce H. Dille
Dille Law, PLLC
2010 Caton Way SW Ste. 101
Olympia, WA 98502
Office: 360-350-0270
Cell: 253-579-5561
[R_Alan_Swanson-WH-200]
** Please note that I use the dictation feature of my iPhone and that sometimes everything I say does not get properly translated**
This transmission contains confidential attorney-client communications and may not be disclosed to any person but the intended recipient(s). If this matter is transmitted to you in error, please notify the sender immediately.
Business Entity Creation and Management, Business, Government and Tax Law, Real Estate and Land Use, Residential, Commercial and Condominium Development Real Estate and Commercial Transactions & Closings, Including Performing Services as IRS Section 1031 Exchange Facilitator Estate Planning, including Wills and Trusts, and Probate Administration Representation Homeowners/Condominium Association Real Estate Developments Real Property Foreclosures and Forfeitures.
From: wsbarp-bounces at lists.wsbarppt.com<mailto:wsbarp-bounces at lists.wsbarppt.com> <wsbarp-bounces at lists.wsbarppt.com<mailto:wsbarp-bounces at lists.wsbarppt.com>> On Behalf Of Paul Neumiller
Sent: Wednesday, July 26, 2023 1:21 PM
To: WSBA Real Property Listserv <wsbarp at lists.wsbarppt.com<mailto:wsbarp at lists.wsbarppt.com>>
Subject: [WSBARP] Litigator Help -- Ejectment
I need to eject a homeless encampment. I am also bringing a motion for a preliminary injunction to kick them out early but CR 65 and RCWs are unclear as to the required notice to the squatters. I am finding no guidance on required advance notice of my motion. CR 65 just says that no preliminary injunction shall be issued without notice to other side (absent emergency situation). And, RCW 7.40.050 says that the "opposite party" needs to have "reasonable notice of the time and place" of the hearing for the injunction. My local court rules say I need to give 12 day's notice for a motion. I was going to have the Sheriff serve the summons and complaint along with the motion for order for the preliminary injunction and give the squatters about 5 days advance notice but now I question if I should give the squatters 12 days advance notice. But, if I have to wait the 12 days, I might as well as skip the preliminary injunction and bring a default or motion for summary judgement !
after 20 days. What say you?
[cid:image001.jpg at 01D9BFC7.AB501690]
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Message: 9
Date: Wed, 26 Jul 2023 23:08:42 +0000
From: Mark Anderson <marka at mbaesq.com>
To: WSBA Real Property Listserv <wsbarp at lists.wsbarppt.com>
Subject: Re: [WSBARP] Title Co's Request for Re-record of 1994 Deed
Message-ID:
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So many questions...
What led the title company to believe that Parcel 2 had been erroneously attached to the 1994 deed? Is that because the 1994 grantor did not own any interest in Parcel 2?
Is the current title company the same title company that insured the 1994 transaction? If so, are they just trying to fix their own mistake by having you re-record a deed and thereby defeating third party's claim against title?
And, jumping on the bandwagon, has Seller been paying taxes on Parcel 2 for the past 29 years?
Mark B. Anderson
ANDERSON LAW FIRM PLLC
821 Dock St Ste 209 PMB 4-12
Tacoma, Washington 98402
+1 253-327-1750
+1 253-327-1751 (fax)
marka at mbaesq.com<mailto:marka at mbaesq.com>
www.mbaesq.com<http://www.mbaesq.com/>
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This transmission is confidential and is intended solely for the use of the individual named recipient. It may be protected by the attorney-client privilege, work product doctrine, or other confidentiality protection. If you are not the intended recipient, or the person responsible to deliver it to the intended recipient, be advised that any dissemination, distribution, or copying of this communication is prohibited. If you have received this transmission in error, please immediately notify the sender via e-mail or by telephone at (253) 327-1750 that you have received the message in error, and then delete it. Thank you.
From: wsbarp-bounces at lists.wsbarppt.com <wsbarp-bounces at lists.wsbarppt.com> On Behalf Of Jeff at bellanddavispllc.com
Sent: 07/26/2023 12:51 PM
To: 'WSBA Real Property Listserv' <wsbarp at lists.wsbarppt.com>
Subject: [WSBARP] Title Co's Request for Re-record of 1994 Deed
Listmates:
In 1994, Sellers were Grantees under a Statutory Warranty Deed that contained parcels 1 and 2. Fast forward to present day, like in the movies, Sellers on the eve of closing, are told by title co. that parcel 2 was erroneously attached to their 1994 deed, and that Seller needs to re-record the 1994 deed to remove parcel 2. Can that be done? The Grantors of the 1994 deed are dead. Any thoughts?
Jeff Davis
W. Jeff Davis
BELL & DAVIS PLLC
Attorneys at Law
P.O. Box 510
720 E. Washington Street, Suite 105
Sequim WA 98382
Phone: (360) 683.1129
Fax: (360) 683.1258
email: jeff at bellanddavispllc.com<mailto:jeff at bellanddavispllc.com>
www.bellanddavispllc.com<http://www.bellanddavispllc.com/>
The information contained in this e-mail message may be privileged, confidential, and protected from disclosure. If you are not the intended recipient, any dissemination, distribution, or copying is strictly prohibited. If you think that you have received this e-mail message in error, please e-mail the sender at info at bellanddavispllc.com<mailto:info at bellanddavispllc.com> or call 360.683.1129.
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Message: 10
Date: Wed, 26 Jul 2023 23:09:49 +0000
From: Mark Anderson <marka at mbaesq.com>
To: WSBA Real Property Listserv <wsbarp at lists.wsbarppt.com>
Subject: Re: [WSBARP] Title Co's Request for Re-record of 1994 Deed
Message-ID:
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Content-Type: text/plain; charset="us-ascii"
And has Seller been using Parcel 2 in a manner that meets all the elements of adverse possession?
Mark B. Anderson
ANDERSON LAW FIRM PLLC
821 Dock St Ste 209 PMB 4-12
Tacoma, Washington 98402
+1 253-327-1750
+1 253-327-1751 (fax)
marka at mbaesq.com<mailto:marka at mbaesq.com>
www.mbaesq.com<http://www.mbaesq.com/>
CONFIDENTIALITY NOTICE
This transmission is confidential and is intended solely for the use of the individual named recipient. It may be protected by the attorney-client privilege, work product doctrine, or other confidentiality protection. If you are not the intended recipient, or the person responsible to deliver it to the intended recipient, be advised that any dissemination, distribution, or copying of this communication is prohibited. If you have received this transmission in error, please immediately notify the sender via e-mail or by telephone at (253) 327-1750 that you have received the message in error, and then delete it. Thank you.
From: wsbarp-bounces at lists.wsbarppt.com <wsbarp-bounces at lists.wsbarppt.com> On Behalf Of Jeff at bellanddavispllc.com
Sent: 07/26/2023 1:01 PM
To: 'WSBA Real Property Listserv' <wsbarp at lists.wsbarppt.com>
Subject: Re: [WSBARP] Title Co's Request for Re-record of 1994 Deed
That's a thought; but just being curious, have Sellers been paying real property taxes on parcel 2 all these years? Shouldn't they be reimbursed if they have?
W. Jeff Davis
BELL & DAVIS PLLC
Attorneys at Law
P.O. Box 510
720 E. Washington Street, Suite 105
Sequim WA 98382
Phone: (360) 683.1129
Fax: (360) 683.1258
email: jeff at bellanddavispllc.com<mailto:jeff at bellanddavispllc.com>
www.bellanddavispllc.com<http://www.bellanddavispllc.com/>
The information contained in this e-mail message may be privileged, confidential, and protected from disclosure. If you are not the intended recipient, any dissemination, distribution, or copying is strictly prohibited. If you think that you have received this e-mail message in error, please e-mail the sender at info at bellanddavispllc.com<mailto:info at bellanddavispllc.com> or call 360.683.1129.
From: wsbarp-bounces at lists.wsbarppt.com<mailto:wsbarp-bounces at lists.wsbarppt.com> <wsbarp-bounces at lists.wsbarppt.com<mailto:wsbarp-bounces at lists.wsbarppt.com>> On Behalf Of Bryce Dille
Sent: Wednesday, July 26, 2023 12:58 PM
To: WSBA Real Property Listserv <wsbarp at lists.wsbarppt.com<mailto:wsbarp at lists.wsbarppt.com>>
Subject: Re: [WSBARP] Title Co's Request for Re-record of 1994 Deed
Cant they just Quit Claim back the parcel that was erroneously included?
Bryce H. Dille
Dille Law, PLLC
2010 Caton Way SW Ste. 101
Olympia, WA 98502
Office: 360-350-0270
Cell: 253-579-5561
[R_Alan_Swanson-WH-200]
** Please note that I use the dictation feature of my iPhone and that sometimes everything I say does not get properly translated**
This transmission contains confidential attorney-client communications and may not be disclosed to any person but the intended recipient(s). If this matter is transmitted to you in error, please notify the sender immediately.
Business Entity Creation and Management, Business, Government and Tax Law, Real Estate and Land Use, Residential, Commercial and Condominium Development Real Estate and Commercial Transactions & Closings, Including Performing Services as IRS Section 1031 Exchange Facilitator Estate Planning, including Wills and Trusts, and Probate Administration Representation Homeowners/Condominium Association Real Estate Developments Real Property Foreclosures and Forfeitures.
From: wsbarp-bounces at lists.wsbarppt.com<mailto:wsbarp-bounces at lists.wsbarppt.com> <wsbarp-bounces at lists.wsbarppt.com<mailto:wsbarp-bounces at lists.wsbarppt.com>> On Behalf Of Jeff at bellanddavispllc.com<mailto:Jeff at bellanddavispllc.com>
Sent: Wednesday, July 26, 2023 12:51 PM
To: 'WSBA Real Property Listserv' <wsbarp at lists.wsbarppt.com<mailto:wsbarp at lists.wsbarppt.com>>
Subject: [WSBARP] Title Co's Request for Re-record of 1994 Deed
Listmates:
In 1994, Sellers were Grantees under a Statutory Warranty Deed that contained parcels 1 and 2. Fast forward to present day, like in the movies, Sellers on the eve of closing, are told by title co. that parcel 2 was erroneously attached to their 1994 deed, and that Seller needs to re-record the 1994 deed to remove parcel 2. Can that be done? The Grantors of the 1994 deed are dead. Any thoughts?
Jeff Davis
W. Jeff Davis
BELL & DAVIS PLLC
Attorneys at Law
P.O. Box 510
720 E. Washington Street, Suite 105
Sequim WA 98382
Phone: (360) 683.1129
Fax: (360) 683.1258
email: jeff at bellanddavispllc.com<mailto:jeff at bellanddavispllc.com>
www.bellanddavispllc.com<https://urldefense.proofpoint.com/v2/url?u=http-3A__www.bellanddavispllc.com_&d=DwMFAg&c=euGZstcaTDllvimEN8b7jXrwqOf-v5A_CdpgnVfiiMM&r=ZjJT61sMYHYXW1a7W0qvaz-zO3o_Ea2RRxXvW5Yr3-0&m=R04z5KHM0gsHaBTUDe4T_yJsF_AUzwNZwx0Ak4ATrxryhIKXkb0x34_ItiDmvZUh&s=RnXcHeJPSpz9ZIuEgOmnrd-ZAoMiQRS4BThg1zIf52E&e=>
The information contained in this e-mail message may be privileged, confidential, and protected from disclosure. If you are not the intended recipient, any dissemination, distribution, or copying is strictly prohibited. If you think that you have received this e-mail message in error, please e-mail the sender at info at bellanddavispllc.com<mailto:info at bellanddavispllc.com> or call 360.683.1129.
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Message: 11
Date: Thu, 27 Jul 2023 05:44:37 +0000
From: YP Wang <yupwang at outlook.com>
To: "wsbarp at lists.wsbarppt.com" <wsbarp at lists.wsbarppt.com>
Subject: Re: [WSBARP] WSBARP Digest, Vol 106, Issue 22
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Hello Nicholas,
Thank you for the information, very clear. Unfortunately they filed separately then.
-----Original Message-----
From: wsbarp-bounces at lists.wsbarppt.com <wsbarp-bounces at lists.wsbarppt.com> On Behalf Of wsbarp-request at lists.wsbarppt.com
Sent: Wednesday, July 26, 2023 12:00 PM
To: wsbarp at lists.wsbarppt.com
Subject: WSBARP Digest, Vol 106, Issue 22
Send WSBARP mailing list submissions to
wsbarp at lists.wsbarppt.com
To subscribe or unsubscribe via the World Wide Web, visit
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You can reach the person managing the list at
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When replying, please edit your Subject line so it is more specific
than "Re: Contents of WSBARP digest..."
Today's Topics:
1. Re: Is there a way to cash a IRS refund check without
probate? (Nick Pleasants)
2. properties in Kitsap and Mason County / loans in default
(Elizabeth [Lisa] M. Carney)
3. Re: properties in Kitsap and Mason County / loans in default
(Info Contact)
4. Re: properties in Kitsap and Mason County / loans in default
(Bryce Dille)
5. Off Topic - Whatcom Criminal Attorney? (Kristi Richards)
6. Re: Off Topic - Whatcom Criminal Attorney? (Eric Nelsen)
7. Re: Off Topic - Whatcom Criminal Attorney? (Carla J. Higginson)
----------------------------------------------------------------------
Message: 1
Date: Tue, 25 Jul 2023 19:31:24 +0000
From: Nick Pleasants <npleasants at ohswlaw.com>
To: "wsbarp at lists.wsbarppt.com" <wsbarp at lists.wsbarppt.com>
Subject: Re: [WSBARP] Is there a way to cash a IRS refund check
without probate?
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Yuping,
If wife filed as Married Filing Jointly, then she can request the check be reissued in her name only. See IRS Publication 559 https://www.irs.gov/publications/p559#en_US_2022_publink100099504
[https://www.irs.gov/pub/image/logo_small.jpg]<https://www.irs.gov/publications/p559#en_US_2022_publink100099504>
Publication 559 (2022), Survivors, Executors, and Administrators | Internal Revenue Service<https://www.irs.gov/publications/p559#en_US_2022_publink100099504>
http://www.irs.gov/
If the check was issued only to the decedent because they filed separately, then I think a probate would be required to open an estate account to receive the funds.
Best,
Nick
Nicholas Pleasants | Shareholder
[OseranHahnAttyatLaw 8]
11225 SE 6th Street | Suite 100 | Bellevue, WA 98004
Main: (425) 455-3900 | Fax: (425) 455-9201 | E-mail: npleasants at ohswlaw.com<mailto:npleasants at ohswlaw.com>
CONFIDENTIALITY NOTE: This e-mail message contains information belonging to the law firm of Oseran Hahn, P.S., which may be privileged, confidential and/or protected from disclosure. The information is intended only for the use of the individual or entity named above. If you think that you have received this message in error, please e-mail the sender. If you are not the intended recipient, any dissemination, distribution or copying is strictly prohibited.
________________________________
From: wsbarp-bounces at lists.wsbarppt.com <wsbarp-bounces at lists.wsbarppt.com> on behalf of YP Wang <yupwang at outlook.com>
Sent: Tuesday, July 25, 2023 11:47 AM
To: wsbarp at lists.wsbarppt.com <wsbarp at lists.wsbarppt.com>
Subject: [WSBARP] Is there a way to cash a IRS refund check without probate?
Dear All
Seek your experience on this matter. Do we have to probate or is there a way to cash the IRS check without probate? The background:
1) Husband (who never lived in the US) passed away in 2022 in another country. No Will. No asset in the US.
2) Husband and Wife once owned a property in WA, they sold it long before 2022. Husband was subject to tax withholding and IRS sent a tax refund (less than 30,000) in 2023.
Wife (live in WA) tried to cash the IRS check to herself and was rejected by banks.
In your experience, is there a way, without probate, to deposit the IRS check to the bank account of Wife?
Thank you!
Yuping Wang
WYP Law PLLC
Tel: 206 383 2826
Email: yuping at wyp-law.com
-----Original Message-----
From: wsbarp-bounces at lists.wsbarppt.com <wsbarp-bounces at lists.wsbarppt.com> On Behalf Of wsbarp-request at lists.wsbarppt.com
Sent: Monday, July 24, 2023 2:45 PM
To: wsbarp at lists.wsbarppt.com
Subject: WSBARP Digest, Vol 106, Issue 20
Send WSBARP mailing list submissions to
wsbarp at lists.wsbarppt.com
To subscribe or unsubscribe via the World Wide Web, visit
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When replying, please edit your Subject line so it is more specific than "Re: Contents of WSBARP digest..."
Today's Topics:
1. Dissolved LLC and Power to Evict (Paul Neumiller)
2. Re: cry trustee's sale (Rob Rowley)
3. Re: Dissolved LLC and Power to Evict (Britt, Christopher)
4. Re: Dissolved LLC and Power to Evict (Inge Fordham)
5. Re: Dissolved LLC and Power to Evict (Paul Neumiller)
----------------------------------------------------------------------
Message: 1
Date: Mon, 24 Jul 2023 19:10:45 +0000
From: Paul Neumiller <pneumiller at hotmail.com>
To: WSBA Real Property Listserv <wsbarp at lists.wsbarppt.com>
Subject: [WSBARP] Dissolved LLC and Power to Evict
Message-ID:
<MW3PR13MB39807EC953DAA16995652AC0D202A at MW3PR13MB3980.namprd13.prod.outlook.com>
Content-Type: text/plain; charset="us-ascii"
Cutting to the Chase: Can an administratively dissolved WA LLC use the court system to eject squatters from real property it has under contract to sell as part of its "winding up" actions under RCW 25.15.297? Background: LLC was administratively dissolved last year by WA Secretary of State. Managing Members now selling last piece of vacant property and discovers a homeless encampment. Removing encampment is now a condition of closing escrow for sale of vacant property. Is bringing a lawsuit for a Writ of Ejectment a valid "winding up" activity for a dissolved LLC? (Or, do I have to reinstate the LLC to be in good standing to use the WA courts?) I can't find any cases or law on this question.
[cid:image001.jpg at 01D9BE27.62B177E0]
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Message: 2
Date: Mon, 24 Jul 2023 12:58:35 -0700
From: Rob Rowley <rob at rowleylegal.com>
To: WSBA Real Property Listserv <wsbarp at lists.wsbarppt.com>
Subject: Re: [WSBARP] cry trustee's sale
Message-ID: <3283e5b095aa69ce9080fb15fbc3f030 at mail.gmail.com>
Content-Type: text/plain; charset="utf-8"
I use Gary?s Process Serving to cry all of my out of county sales including Pierce.
https://garysprocess.com/
*From:* wsbarp-bounces at lists.wsbarppt.com <wsbarp-bounces at lists.wsbarppt.com>
*On Behalf Of *Bryce Dille
*Sent:* Monday, July 24, 2023 10:18 AM
*To:* WSBA Real Property Listserv <wsbarp at lists.wsbarppt.com>
*Subject:* [WSBARP] cry trustees sale
I Need recommendation of someone to cry a non judicial trustees sale for me on Friday in Pierce County Thank you
Bryce H. Dille
Dille Law, PLLC
2010 Caton Way SW Ste. 101
Olympia, WA 98502
Office: 360-350-0270
Cell: 253-579-5561
[image: R_Alan_Swanson-WH-200]
** Please note that I use the dictation feature of my iPhone and that sometimes everything I say does not get properly translated**
This transmission contains confidential attorney-client communications and may not be disclosed to any person but the intended recipient(s). If this matter is transmitted to you in error, please notify the sender immediately.
Business Entity Creation and Management, Business, Government and Tax Law, Real Estate and Land Use, Residential, Commercial and Condominium Development Real Estate and Commercial Transactions & Closings, Including Performing Services as IRS Section 1031 Exchange Facilitator Estate Planning, including Wills and Trusts, and Probate Administration Representation Homeowners/Condominium Association Real Estate Developments Real Property Foreclosures and Forfeitures.
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Message: 3
Date: Mon, 24 Jul 2023 13:18:29 -0700
From: "Britt, Christopher" <christopher at lucentlaw.com>
To: WSBA Real Property Listserv <wsbarp at lists.wsbarppt.com>
Subject: Re: [WSBARP] Dissolved LLC and Power to Evict
Message-ID:
<CALBbJgNmanWHkV0ZzpXbwXsmR7VoHtF7Q-2LpGD=GLpdhVjiGQ at mail.gmail.com>
Content-Type: text/plain; charset="utf-8"
(2) In winding up its activities, the limited liability company:
(a) May file a certificate of dissolution with the secretary of state to provide notice that the limited liability company is dissolved; preserve the limited liability company's business or property as a going concern for a reasonable time; *prosecute and defend actions and proceedings, whether civil, criminal, or administrative, transfer the limited liability company's property; settle disputes; and perform other necessary acts*
I think you are well within your parameters to pursue your cause(s).
Christopher G. Britt, M.A., J.D.
Attorney at Law
1403 S. Grand Blvd., Suite 201-S
Spokane, WA 99203-2278
P: 509.455.3713
D: 509.316.2131
F: +1.509.455.3718 (must dial 1 before area code)
E: *christopher at lucentlaw.com <christopher at lucentlaw.com>*
Web: http://www.lucentlaw.com/
On Mon, Jul 24, 2023 at 12:16?PM Paul Neumiller <pneumiller at hotmail.com>
wrote:
> Cutting to the Chase: Can an administratively dissolved WA LLC use
> the court system to eject squatters from real property it has under
> contract to sell as part of its ?winding up? actions under RCW 25.15.297? Background:
> LLC was administratively dissolved last year by WA Secretary of State.
> Managing Members now selling last piece of vacant property and
> discovers a homeless encampment. Removing encampment is now a
> condition of closing escrow for sale of vacant property. Is bringing
> a lawsuit for a Writ of Ejectment a valid ?winding up? activity for a
> dissolved LLC? (Or, do I have to reinstate the LLC to be in good
> standing to use the WA courts?) I can?t find any cases or law on this question.
>
>
>
>
>
>
>
>
>
>
> ***Disclaimer: Please note that RPPT listserv participation is not
> restricted to practicing attorneys and may include non-practicing
> attorneys, law students, professionals working in related fields, and
> others.***
>
> _______________________________________________
> WSBARP mailing list
> WSBARP at lists.wsbarppt.com
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Message: 4
Date: Mon, 24 Jul 2023 20:44:08 +0000
From: Inge Fordham <inge at fordhamlegal.com>
To: WSBA Real Property Listserv <wsbarp at lists.wsbarppt.com>
Subject: Re: [WSBARP] Dissolved LLC and Power to Evict
Message-ID:
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Content-Type: text/plain; charset="windows-1252"
A dissolved LLC can sue and be sued for three years following the filing of a certificate of dissolution. See RCW 25.15.297(1)(a) and RCW 25.15.309. See also Chadwick Farms and Emily Lane.
[uc%3fexport=download&id=1W3rEcChy0_E0cCfV5up02mkhwnL6eWIs&revid=0B4P5JoIHdbFaR29EbHlRWHFseFV5STZpSUVGeUNPWldkVDFVPQ]
Inge A. Fordham | Attorney
Fordham Law, PLLC
3218 Sixth Avenue | Tacoma, WA 98406
Office: (253) 348-2657 | Mobile: (206) 778-3131 http://www.fordhamlegal.com/<http://www.fordhamlegal.com/>
Confidential Communication: This email is sent to a recipient on behalf of an attorney/law firm, and is information intended exclusively for the individual, entity or company to which it is sent. This communication may contain proprietary, privileged or confidential information or may otherwise be legally exempt from disclosure other than to the intended recipient. If you are not the named addressee, you are not authorized to read, print, retain, copy or otherwise disseminate this message or any part of it. If you have received this email in error, please notify the sender immediately by email or other communication and delete all copies of the message.
From: wsbarp-bounces at lists.wsbarppt.com <wsbarp-bounces at lists.wsbarppt.com> on behalf of Paul Neumiller <pneumiller at hotmail.com>
Date: Monday, July 24, 2023 at 12:14 PM
To: WSBA Real Property Listserv <wsbarp at lists.wsbarppt.com>
Subject: [WSBARP] Dissolved LLC and Power to Evict Cutting to the Chase: Can an administratively dissolved WA LLC use the court system to eject squatters from real property it has under contract to sell as part of its ?winding up? actions under RCW 25.15.297? Background: LLC was administratively dissolved last year by WA Secretary of State. Managing Members now selling last piece of vacant property and discovers a homeless encampment. Removing encampment is now a condition of closing escrow for sale of vacant property. Is bringing a lawsuit for a Writ of Ejectment a valid ?winding up? activity for a dissolved LLC? (Or, do I have to reinstate the LLC to be in good standing to use the WA courts?) I can?t find any cases or law on this question.
[cid:image001.jpg at 01D9BE27.62B177E0]
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Message: 5
Date: Mon, 24 Jul 2023 21:44:16 +0000
From: Paul Neumiller <pneumiller at hotmail.com>
To: WSBA Real Property Listserv <wsbarp at lists.wsbarppt.com>
Subject: Re: [WSBARP] Dissolved LLC and Power to Evict
Message-ID:
<MW3PR13MB39801F37666ED3F19685C4FBD202A at MW3PR13MB3980.namprd13.prod.outlook.com>
Content-Type: text/plain; charset="us-ascii"
Thanks to all who answered. Very helpful.
[cid:image001.jpg at 01D9BE3D.50216A70]
From: wsbarp-bounces at lists.wsbarppt.com <wsbarp-bounces at lists.wsbarppt.com> On Behalf Of Inge Fordham
Sent: Monday, July 24, 2023 1:44 PM
To: WSBA Real Property Listserv <wsbarp at lists.wsbarppt.com>
Subject: Re: [WSBARP] Dissolved LLC and Power to Evict
A dissolved LLC can sue and be sued for three years following the filing of a certificate of dissolution. See RCW 25.15.297(1)(a) and RCW 25.15.309. See also Chadwick Farms and Emily Lane.
[uc%3fexport=download&id=1W3rEcChy0_E0cCfV5up02mkhwnL6eWIs&revid=0B4P5JoIHdbFaR29EbHlRWHFseFV5STZpSUVGeUNPWldkVDFVPQ]
Inge A. Fordham | Attorney
Fordham Law, PLLC
3218 Sixth Avenue | Tacoma, WA 98406
Office: (253) 348-2657 | Mobile: (206) 778-3131 http://www.fordhamlegal.com/<http://www.fordhamlegal.com/>
Confidential Communication: This email is sent to a recipient on behalf of an attorney/law firm, and is information intended exclusively for the individual, entity or company to which it is sent. This communication may contain proprietary, privileged or confidential information or may otherwise be legally exempt from disclosure other than to the intended recipient. If you are not the named addressee, you are not authorized to read, print, retain, copy or otherwise disseminate this message or any part of it. If you have received this email in error, please notify the sender immediately by email or other communication and delete all copies of the message.
From: wsbarp-bounces at lists.wsbarppt.com<mailto:wsbarp-bounces at lists.wsbarppt.com> <wsbarp-bounces at lists.wsbarppt.com<mailto:wsbarp-bounces at lists.wsbarppt.com>> on behalf of Paul Neumiller <pneumiller at hotmail.com<mailto:pneumiller at hotmail.com>>
Date: Monday, July 24, 2023 at 12:14 PM
To: WSBA Real Property Listserv <wsbarp at lists.wsbarppt.com<mailto:wsbarp at lists.wsbarppt.com>>
Subject: [WSBARP] Dissolved LLC and Power to Evict Cutting to the Chase: Can an administratively dissolved WA LLC use the court system to eject squatters from real property it has under contract to sell as part of its "winding up" actions under RCW 25.15.297? Background: LLC was administratively dissolved last year by WA Secretary of State. Managing Members now selling last piece of vacant property and discovers a homeless encampment. Removing encampment is now a condition of closing escrow for sale of vacant property. Is bringing a lawsuit for a Writ of Ejectment a valid "winding up" activity for a dissolved LLC? (Or, do I have to reinstate the LLC to be in good standing to use the WA courts?) I can't find any cases or law on this question.
[cid:image001.jpg at 01D9BE3D.50216A70]
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End of WSBARP Digest, Vol 106, Issue 20
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Message: 2
Date: Tue, 25 Jul 2023 23:07:59 +0000
From: "Elizabeth [Lisa] M. Carney" <carney at westseattlelaw.com>
To: WSBA Real Property Listserv <wsbarp at lists.wsbarppt.com>
Subject: [WSBARP] properties in Kitsap and Mason County / loans in
default
Message-ID:
<SA3PR22MB4425E1724CD435D153654B98A603A at SA3PR22MB4425.namprd22.prod.outlook.com>
Content-Type: text/plain; charset="utf-8"
Colleagues,
Client has loaned dollars on several properties in Kitsap and Mason County.
He is seeking assistance to get payments that are due.
Based on initial discussion, solution may include demand letters to borrowers and deeds in lieu of foreclosure, or foreclosures.
Seeking practitioner in those locales.
Thanks.
Lisa
Elizabeth [Lisa] M. Carney
Attorney at Law
[devrieze-carney logo 6 13_60%]
de Vrieze | Carney pllc
3909 California Avenue SW
Seattle, WA 98116-3705
Phone: 206.938.5500
Fax: 206.535.6264
Our office will be closed Fridays from July 14 through August 25th.
Carney at WestSeattleLaw.com<mailto:Carney at WestSeattleLaw.com>
http://www.westseattlelaw.com/<http://www.westseattlelaw.com/>
CONFIDENTIAL & PRIVILEGED. This e-mail message may contain legally privileged and/or confidential information. If you have received this e-mail in error, please notify the sender immediately and delete all copies of this e-mail message and any attachment. Unless you have previously signed an engagement agreement with this firm, and the firm has accepted you as a client, NO exchange of information by virtue of emails or communications will create any attorney client relationship, including any duty of confidentiality, between sender and/or recipient.
Click here to connect with de Vrieze | Carney on Facebook: [FB Logo] <https://www.facebook.com/DeVriezeCarney>
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Message: 3
Date: Tue, 25 Jul 2023 16:16:32 -0700
From: Info Contact <info at lawpls.com>
To: WSBA Real Property Listserv <wsbarp at lists.wsbarppt.com>
Subject: Re: [WSBARP] properties in Kitsap and Mason County / loans in
default
Message-ID:
<CAAZJk=OCo46NzM+-EghF6iVVA_uJhnhjx2RbViaQeHdStUCsCA at mail.gmail.com>
Content-Type: text/plain; charset="utf-8"
Lisa,
We have an office in Mason county and may be able to help. Contact info: Prime
Legal <https://lawpls.com/locations/>.
Thanks-
On Tue, Jul 25, 2023 at 4:13?PM Elizabeth [Lisa] M. Carney <
carney at westseattlelaw.com> wrote:
> Colleagues,
>
>
>
> Client has loaned dollars on several properties in Kitsap and Mason County.
>
>
>
> He is seeking assistance to get payments that are due.
>
>
>
> Based on initial discussion, solution may include demand letters to
> borrowers and deeds in lieu of foreclosure, or foreclosures.
>
>
>
> Seeking practitioner in those locales.
>
>
>
> Thanks.
>
>
>
> Lisa
>
>
>
>
>
> * Elizabeth [Lisa] M. Carney*
>
> Attorney at Law
>
>
>
> [image: devrieze-carney logo 6 13_60%]
>
> de Vrieze | Carney pllc
>
> 3909 California Avenue SW
>
> Seattle, WA 98116-3705
>
> Phone: 206.938.5500
>
> Fax: 206.535.6264
>
> Our office will be *closed Fridays* from July 14 through August 25th.
>
> Carney at WestSeattleLaw.com
>
> http://www.westseattlelaw.com/ <http://www.westseattlelaw.com/>
>
> CONFIDENTIAL & PRIVILEGED. This e-mail message may contain legally
> privileged and/or confidential information. If you have received this
> e-mail in error, please notify the sender immediately and delete all copies
> of this e-mail message and any attachment. Unless you have
> previously signed an engagement agreement with this firm, and the firm
> has accepted you as a client, NO exchange of information by virtue of
> emails or communications will create any attorney client relationship,
> including any duty of confidentiality, between sender and/or recipient.
>
> *Click here to connect with de Vrieze | Carney on Facebook: * *[image:
> FB Logo]* <https://www.facebook.com/DeVriezeCarney>
>
>
>
>
>
>
>
>
> ***Disclaimer: Please note that RPPT listserv participation is not
> restricted to practicing attorneys and may include non-practicing
> attorneys, law students, professionals working in related fields, and
> others.***
>
> _______________________________________________
> WSBARP mailing list
> WSBARP at lists.wsbarppt.com
> http://mailman.fsr.com/mailman/listinfo/wsbarp
>
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Message: 4
Date: Tue, 25 Jul 2023 23:17:14 +0000
From: Bryce Dille <Bryce at dillelaw.com>
To: WSBA Real Property Listserv <wsbarp at lists.wsbarppt.com>
Subject: Re: [WSBARP] properties in Kitsap and Mason County / loans in
default
Message-ID:
<MN0PR11MB6230DB2984DE5EAD9B94A9C7C803A at MN0PR11MB6230.namprd11.prod.outlook.com>
Content-Type: text/plain; charset="utf-8"
I do foreclosure work in Mason County would like to assist please have you or your client call thanks
Bryce H. Dille
Dille Law, PLLC
2010 Caton Way SW Ste. 101
Olympia, WA 98502
Office: 360-350-0270
Cell: 253-579-5561
[R_Alan_Swanson-WH-200]
** Please note that I use the dictation feature of my iPhone and that sometimes everything I say does not get properly translated**
This transmission contains confidential attorney-client communications and may not be disclosed to any person but the intended recipient(s). If this matter is transmitted to you in error, please notify the sender immediately.
Business Entity Creation and Management, Business, Government and Tax Law, Real Estate and Land Use, Residential, Commercial and Condominium Development Real Estate and Commercial Transactions & Closings, Including Performing Services as IRS Section 1031 Exchange Facilitator Estate Planning, including Wills and Trusts, and Probate Administration Representation Homeowners/Condominium Association Real Estate Developments Real Property Foreclosures and Forfeitures.
From: wsbarp-bounces at lists.wsbarppt.com <wsbarp-bounces at lists.wsbarppt.com> On Behalf Of Elizabeth [Lisa] M. Carney
Sent: Tuesday, July 25, 2023 4:08 PM
To: WSBA Real Property Listserv <wsbarp at lists.wsbarppt.com>
Subject: [WSBARP] properties in Kitsap and Mason County / loans in default
Colleagues,
Client has loaned dollars on several properties in Kitsap and Mason County.
He is seeking assistance to get payments that are due.
Based on initial discussion, solution may include demand letters to borrowers and deeds in lieu of foreclosure, or foreclosures.
Seeking practitioner in those locales.
Thanks.
Lisa
Elizabeth [Lisa] M. Carney
Attorney at Law
[devrieze-carney logo 6 13_60%]
de Vrieze | Carney pllc
3909 California Avenue SW
Seattle, WA 98116-3705
Phone: 206.938.5500
Fax: 206.535.6264
Our office will be closed Fridays from July 14 through August 25th.
Carney at WestSeattleLaw.com<mailto:Carney at WestSeattleLaw.com>
http://www.westseattlelaw.com/<https://urldefense.proofpoint.com/v2/url?u=http-3A__www.westseattlelaw.com_&d=DwMGaQ&c=euGZstcaTDllvimEN8b7jXrwqOf-v5A_CdpgnVfiiMM&r=ZjJT61sMYHYXW1a7W0qvaz-zO3o_Ea2RRxXvW5Yr3-0&m=Ol_Sq6SdK3hBH2aDBxBhB5Wk0aDKDS3WsErXOqP4UBRS1AIo6msdwqDZhWZ8rDzy&s=uX1yNlTkMK_329MuWwwCnzucRshqz_MuH1I4WLlgTUY&e=>
CONFIDENTIAL & PRIVILEGED. This e-mail message may contain legally privileged and/or confidential information. If you have received this e-mail in error, please notify the sender immediately and delete all copies of this e-mail message and any attachment. Unless you have previously signed an engagement agreement with this firm, and the firm has accepted you as a client, NO exchange of information by virtue of emails or communications will create any attorney client relationship, including any duty of confidentiality, between sender and/or recipient.
Click here to connect with de Vrieze | Carney on Facebook: [FB Logo] <https://urldefense.proofpoint.com/v2/url?u=https-3A__www.facebook.com_DeVriezeCarney&d=DwMGaQ&c=euGZstcaTDllvimEN8b7jXrwqOf-v5A_CdpgnVfiiMM&r=ZjJT61sMYHYXW1a7W0qvaz-zO3o_Ea2RRxXvW5Yr3-0&m=Ol_Sq6SdK3hBH2aDBxBhB5Wk0aDKDS3WsErXOqP4UBRS1AIo6msdwqDZhWZ8rDzy&s=w4Q5cuvXKJl774YSUXcCUKw_whwGkk7pmGn1NzAa86c&e=>
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Message: 5
Date: Wed, 26 Jul 2023 16:27:38 +0000
From: Kristi Richards <krichards at radiuslawseattle.com>
To: WSBA Real Property Listserv <wsbarp at lists.wsbarppt.com>
Subject: [WSBARP] Off Topic - Whatcom Criminal Attorney?
Message-ID:
<DM6PR07MB7034E325D9FA068F32613F82D600A at DM6PR07MB7034.namprd07.prod.outlook.com>
Content-Type: text/plain; charset="us-ascii"
Does anyone know a good criminal attorney - with bonus points for one that works in Whatcom county.
I would appreciate the name/contact info. All names will be forwarded.
Kristi L. Richards (she/her)
Attorney, Trusts and Estates Practice
[cid:image001.png at 01D9BFA3.6C5D2B40].
1700 7th Avenue, Suite 2100
Seattle, WA 98101-1360
(206) 388-5005
NOTICE: This communication and the information contained within, along with any items attached as an enclosure, are privileged and confidential. This communication is intended solely for the use of the individual(s) named above. If you are not one of the intended addressees or you believe you may have received this communication in error, you are hereby notified that any consideration, dissemination or duplication of this communication is strictly prohibited. In addition, you shall not print, copy, retransmit, disseminate, or otherwise use this information in any form without first receiving specific written permission from the author of this communication. If you have received this communication in error, please reply to the sender indicating that fact and delete this message from your system immediately.
IRS CIRCULAR 230 DISCLOSURE: To ensure compliance with IRS requirements, we inform you that any advice contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein.
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------------------------------
Message: 6
Date: Wed, 26 Jul 2023 16:46:27 +0000
From: Eric Nelsen <eric at sayrelawoffices.com>
To: WSBA Real Property Listserv <wsbarp at lists.wsbarppt.com>
Subject: Re: [WSBARP] Off Topic - Whatcom Criminal Attorney?
Message-ID:
<SA1PR05MB7888BC1D8385D15F8D1C6BB0DD00A at SA1PR05MB7888.namprd05.prod.outlook.com>
Content-Type: text/plain; charset="us-ascii"
I refer to Jeff Kradel https://www.kradeldefense.com/ or Brit Mercer https://www.britmercerlaw.com/my-practice.
They're both in Seattle, but perhaps would know a referral if they don't practice in Whatcom.
Sincerely,
Eric
Eric C. Nelsen
Sayre Law Offices, PLLC
1417 31st Ave South
Seattle WA 98144-3909
206-625-0092
eric at sayrelawoffices.com<mailto:eric at sayrelawoffices.com>
From: wsbarp-bounces at lists.wsbarppt.com <wsbarp-bounces at lists.wsbarppt.com> On Behalf Of Kristi Richards
Sent: Wednesday, July 26, 2023 9:28 AM
To: WSBA Real Property Listserv <wsbarp at lists.wsbarppt.com>
Subject: [WSBARP] Off Topic - Whatcom Criminal Attorney?
Does anyone know a good criminal attorney - with bonus points for one that works in Whatcom county.
I would appreciate the name/contact info. All names will be forwarded.
Kristi L. Richards (she/her)
Attorney, Trusts and Estates Practice
[cid:image001.png at 01D9BFA6.0ADBE5C0].
1700 7th Avenue, Suite 2100
Seattle, WA 98101-1360
(206) 388-5005
NOTICE: This communication and the information contained within, along with any items attached as an enclosure, are privileged and confidential. This communication is intended solely for the use of the individual(s) named above. If you are not one of the intended addressees or you believe you may have received this communication in error, you are hereby notified that any consideration, dissemination or duplication of this communication is strictly prohibited. In addition, you shall not print, copy, retransmit, disseminate, or otherwise use this information in any form without first receiving specific written permission from the author of this communication. If you have received this communication in error, please reply to the sender indicating that fact and delete this message from your system immediately.
IRS CIRCULAR 230 DISCLOSURE: To ensure compliance with IRS requirements, we inform you that any advice contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein.
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Message: 7
Date: Wed, 26 Jul 2023 16:52:48 +0000
From: "Carla J. Higginson" <carla at higginsonbeyer.com>
To: WSBA Real Property Listserv <wsbarp at lists.wsbarppt.com>
Subject: Re: [WSBARP] Off Topic - Whatcom Criminal Attorney?
Message-ID: <5FBEFA16-4678-4E38-9B52-E95CAB43EFC8 at higginsonbeyer.com>
Content-Type: text/plain; charset="utf-8"
I'd recommend Mark Kaiman of Victory Legal. He's in Bellingham and is an extremely experienced criminal defense attorney. His office number is 360-685-4221.
Sent from my iPhone
On Jul 26, 2023, at 9:50 AM, Eric Nelsen <eric at sayrelawoffices.com> wrote:
?
I refer to Jeff Kradel https://www.kradeldefense.com/ or Brit Mercer https://www.britmercerlaw.com/my-practice.
They?re both in Seattle, but perhaps would know a referral if they don?t practice in Whatcom.
Sincerely,
Eric
Eric C. Nelsen
Sayre Law Offices, PLLC
1417 31st Ave South
Seattle WA 98144-3909
206-625-0092
eric at sayrelawoffices.com<mailto:eric at sayrelawoffices.com>
From: wsbarp-bounces at lists.wsbarppt.com <wsbarp-bounces at lists.wsbarppt.com> On Behalf Of Kristi Richards
Sent: Wednesday, July 26, 2023 9:28 AM
To: WSBA Real Property Listserv <wsbarp at lists.wsbarppt.com>
Subject: [WSBARP] Off Topic - Whatcom Criminal Attorney?
Does anyone know a good criminal attorney - with bonus points for one that works in Whatcom county.
I would appreciate the name/contact info. All names will be forwarded.
Kristi L. Richards (she/her)
Attorney, Trusts and Estates Practice
[image001.png].
1700 7th Avenue, Suite 2100
Seattle, WA 98101-1360
(206) 388-5005
NOTICE: This communication and the information contained within, along with any items attached as an enclosure, are privileged and confidential. This communication is intended solely for the use of the individual(s) named above. If you are not one of the intended addressees or you believe you may have received this communication in error, you are hereby notified that any consideration, dissemination or duplication of this communication is strictly prohibited. In addition, you shall not print, copy, retransmit, disseminate, or otherwise use this information in any form without first receiving specific written permission from the author of this communication. If you have received this communication in error, please reply to the sender indicating that fact and delete this message from your system immediately.
IRS CIRCULAR 230 DISCLOSURE: To ensure compliance with IRS requirements, we inform you that any advice contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein.
***Disclaimer: Please note that RPPT listserv participation is not restricted to practicing attorneys and may include non-practicing attorneys, law students, professionals working in related fields, and others.***
_______________________________________________
WSBARP mailing list
WSBARP at lists.wsbarppt.com
http://mailman.fsr.com/mailman/listinfo/wsbarp
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------------------------------
***Disclaimer: Please note that RPPT listserv participation is not restricted to practicing attorneys and may include non-practicing attorneys, law students, professionals working in related fields, and others.***
_______________________________________________
WSBARP mailing list
WSBARP at lists.wsbarppt.com
http://mailman.fsr.com/mailman/listinfo/wsbarp
End of WSBARP Digest, Vol 106, Issue 22
***************************************
------------------------------
Message: 12
Date: Thu, 27 Jul 2023 06:29:28 -0700
From: "Meyler Legal, PLLC" <samuel at meylerlegal.com>
To: wsbarp at lists.wsbarppt.com
Subject: [WSBARP] Property Manager
Message-ID: <62C84458-0A8A-43DF-BEE7-485267836F21 at meylerlegal.com>
Content-Type: text/plain; charset="us-ascii"
Listmates,
Client is looking for a reputable property manager for a rental in Seattle. Who do you have?
Sam
Samuel M. Meyler
Meyler Legal, PLLC
1700 Westlake Ave. N., Ste. 200
Seattle, WA 98109
Main: 206-876-7770
Fax: 206-876-7771
Direct: 206-876-7772
Email: samuel at meylerlegal.com
NOTICE:
This electronic message contains information which may be Confidential or Privileged and constitutes an electronic communication within the meaning of the Electronic Communications Privacy Act 18 USC 2510. The information is intended to be for the use of the individual or entity named above. If you are not the intended recipient, please be aware that any disclosure, copying, distribution or use of the contents of this information is prohibited. If you received this transmission in error, please notify the sender and delete the copy you received together with any attachments. Thank you.
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Message: 13
Date: Thu, 27 Jul 2023 16:31:12 +0000
From: Bryce Dille <Bryce at dillelaw.com>
To: WSBA Real Property Listserv <wsbarp at lists.wsbarppt.com>
Cc: Tom Petramalo <petramalo at icloud.com>
Subject: Re: [WSBARP] Property Manager
Message-ID:
<MN0PR11MB6230E000CBAC43E4C120E60BC801A at MN0PR11MB6230.namprd11.prod.outlook.com>
Content-Type: text/plain; charset="utf-8"
Contact Targa Real Estate the person is Tom Petromalo 253 405 2085
Bryce H. Dille
Dille Law, PLLC
2010 Caton Way SW Ste. 101
Olympia, WA 98502
Office: 360-350-0270
Cell: 253-579-5561
[R_Alan_Swanson-WH-200]
** Please note that I use the dictation feature of my iPhone and that sometimes everything I say does not get properly translated**
This transmission contains confidential attorney-client communications and may not be disclosed to any person but the intended recipient(s). If this matter is transmitted to you in error, please notify the sender immediately.
Business Entity Creation and Management, Business, Government and Tax Law, Real Estate and Land Use, Residential, Commercial and Condominium Development Real Estate and Commercial Transactions & Closings, Including Performing Services as IRS Section 1031 Exchange Facilitator Estate Planning, including Wills and Trusts, and Probate Administration Representation Homeowners/Condominium Association Real Estate Developments Real Property Foreclosures and Forfeitures.
From: wsbarp-bounces at lists.wsbarppt.com <wsbarp-bounces at lists.wsbarppt.com> On Behalf Of Meyler Legal, PLLC
Sent: Thursday, July 27, 2023 6:29 AM
To: wsbarp at lists.wsbarppt.com
Subject: [WSBARP] Property Manager
Listmates,
Client is looking for a reputable property manager for a rental in Seattle. Who do you have?
Sam
Samuel M. Meyler
Meyler Legal, PLLC
1700 Westlake Ave. N., Ste. 200
Seattle, WA 98109
Main: 206-876-7770
Fax: 206-876-7771
Direct: 206-876-7772
Email: samuel at meylerlegal.com<mailto:samuel at meylerlegal.com>
NOTICE:
This electronic message contains information which may be Confidential or Privileged and constitutes an electronic communication within the meaning of the Electronic Communications Privacy Act 18 USC 2510. The information is intended to be for the use of the individual or entity named above. If you are not the intended recipient, please be aware that any disclosure, copying, distribution or use of the contents of this information is prohibited. If you received this transmission in error, please notify the sender and delete the copy you received together with any attachments. Thank you.
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Message: 14
Date: Thu, 27 Jul 2023 17:54:27 +0000
From: Paul Neumiller <pneumiller at hotmail.com>
To: WSBA Real Property Listserv <wsbarp at lists.wsbarppt.com>
Subject: Re: [WSBARP] Litigator Help -- Ejectment
Message-ID:
<MW3PR13MB3980A33D7795E3368BB958FBD201A at MW3PR13MB3980.namprd13.prod.outlook.com>
Content-Type: text/plain; charset="us-ascii"
Still looking for an answer: Anyone have an idea as to the amount of notice that is required for a preliminary injunction under CR 65 and RCW 7.40.050??
[cid:image001.jpg at 01D9C078.B43FF840]
IMPORTANT NOTICE: This e-mail message is intended to be received only by persons entitled to receive the confidential information it may contain. E-mail messages to clients of Paul A. Neumiller presumptively contain information that is confidential and legally privileged; e-mail messages to non-clients are normally confidential and may also be legally privileged. Please do not read, copy, forward or store this message unless you are the intended recipient of it. If you have received this message in error, please forward it back to the sender and delete it completely from your computer system.
E-mail communication on the Internet may NOT be secure. There is a risk that this confidential communication may be intercepted illegally. There may also be a risk of waiving attorney-client and/or work-product privileges that may attach to this communication. DO NOT forward this message to a third party. If you have any questions regarding this notice, please contact the sender.
From: wsbarp-bounces at lists.wsbarppt.com <wsbarp-bounces at lists.wsbarppt.com> On Behalf Of Paul Neumiller
Sent: Wednesday, July 26, 2023 1:47 PM
To: WSBA Real Property Listserv <wsbarp at lists.wsbarppt.com>
Subject: Re: [WSBARP] Litigator Help -- Ejectment
One person was initially given permission to stay on the vacant lot so we have his name but then he invited about 10 other people. Caption will read "Known Joe Blow and all other Occupants" Permission has been withdrawn. No lease, no rent paid or demanded. So, RCW 59.16, 59.12, and 59.18 don't apply.
[cid:image001.jpg at 01D9C078.B43FF840]
IMPORTANT NOTICE: This e-mail message is intended to be received only by persons entitled to receive the confidential information it may contain. E-mail messages to clients of Paul A. Neumiller presumptively contain information that is confidential and legally privileged; e-mail messages to non-clients are normally confidential and may also be legally privileged. Please do not read, copy, forward or store this message unless you are the intended recipient of it. If you have received this message in error, please forward it back to the sender and delete it completely from your computer system.
E-mail communication on the Internet may NOT be secure. There is a risk that this confidential communication may be intercepted illegally. There may also be a risk of waiving attorney-client and/or work-product privileges that may attach to this communication. DO NOT forward this message to a third party. If you have any questions regarding this notice, please contact the sender.
From: wsbarp-bounces at lists.wsbarppt.com<mailto:wsbarp-bounces at lists.wsbarppt.com> <wsbarp-bounces at lists.wsbarppt.com<mailto:wsbarp-bounces at lists.wsbarppt.com>> On Behalf Of Bryce Dille
Sent: Wednesday, July 26, 2023 1:38 PM
To: WSBA Real Property Listserv <wsbarp at lists.wsbarppt.com<mailto:wsbarp at lists.wsbarppt.com>>
Subject: Re: [WSBARP] Litigator Help -- Ejectment
Who are you naming as defendants do you have the names of the squatters or are they all named as john does In addition to RCW 7.28 Cant you bring action under the RCW 59.16 unlawful entry and detainer or RCW 59.12(6)
Bryce H. Dille
Dille Law, PLLC
2010 Caton Way SW Ste. 101
Olympia, WA 98502
Office: 360-350-0270
Cell: 253-579-5561
[R_Alan_Swanson-WH-200]
** Please note that I use the dictation feature of my iPhone and that sometimes everything I say does not get properly translated**
This transmission contains confidential attorney-client communications and may not be disclosed to any person but the intended recipient(s). If this matter is transmitted to you in error, please notify the sender immediately.
Business Entity Creation and Management, Business, Government and Tax Law, Real Estate and Land Use, Residential, Commercial and Condominium Development Real Estate and Commercial Transactions & Closings, Including Performing Services as IRS Section 1031 Exchange Facilitator Estate Planning, including Wills and Trusts, and Probate Administration Representation Homeowners/Condominium Association Real Estate Developments Real Property Foreclosures and Forfeitures.
From: wsbarp-bounces at lists.wsbarppt.com<mailto:wsbarp-bounces at lists.wsbarppt.com> <wsbarp-bounces at lists.wsbarppt.com<mailto:wsbarp-bounces at lists.wsbarppt.com>> On Behalf Of Paul Neumiller
Sent: Wednesday, July 26, 2023 1:21 PM
To: WSBA Real Property Listserv <wsbarp at lists.wsbarppt.com<mailto:wsbarp at lists.wsbarppt.com>>
Subject: [WSBARP] Litigator Help -- Ejectment
I need to eject a homeless encampment. I am also bringing a motion for a preliminary injunction to kick them out early but CR 65 and RCWs are unclear as to the required notice to the squatters. I am finding no guidance on required advance notice of my motion. CR 65 just says that no preliminary injunction shall be issued without notice to other side (absent emergency situation). And, RCW 7.40.050 says that the "opposite party" needs to have "reasonable notice of the time and place" of the hearing for the injunction. My local court rules say I need to give 12 day's notice for a motion. I was going to have the Sheriff serve the summons and complaint along with the motion for order for the preliminary injunction and give the squatters about 5 days advance notice but now I question if I should give the squatters 12 days advance notice. But, if I have to wait the 12 days, I might as well as skip the preliminary injunction and bring a default or motion for summary judgement !
after 20 days. What say you?
[cid:image001.jpg at 01D9C078.B43FF840]
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Message: 15
Date: Thu, 27 Jul 2023 18:19:09 +0000
From: Eric Nelsen <eric at sayrelawoffices.com>
To: WSBA Real Property Listserv <wsbarp at lists.wsbarppt.com>
Subject: Re: [WSBARP] Litigator Help -- Ejectment
Message-ID:
<SA1PR05MB78887035B0728A95822DC155DD01A at SA1PR05MB7888.namprd05.prod.outlook.com>
Content-Type: text/plain; charset="us-ascii"
I think that's just an ordinary motion so whatever local rule requires. That said, I agree with you that given the "reasonable notice" requirement it might be prudent to set it out with extra time so there's no argument about the defendant not having enough time to respond on such a consequential matter. And because of that, why not just go with a summary judgment and/or default.
Sincerely,
Eric
Eric C. Nelsen
Sayre Law Offices, PLLC
1417 31st Ave South
Seattle WA 98144-3909
206-625-0092
eric at sayrelawoffices.com<mailto:eric at sayrelawoffices.com>
From: wsbarp-bounces at lists.wsbarppt.com <wsbarp-bounces at lists.wsbarppt.com> On Behalf Of Paul Neumiller
Sent: Thursday, July 27, 2023 10:54 AM
To: WSBA Real Property Listserv <wsbarp at lists.wsbarppt.com>
Subject: Re: [WSBARP] Litigator Help -- Ejectment
Still looking for an answer: Anyone have an idea as to the amount of notice that is required for a preliminary injunction under CR 65 and RCW 7.40.050??
[cid:image001.jpg at 01D9C07C.28A17D50]
IMPORTANT NOTICE: This e-mail message is intended to be received only by persons entitled to receive the confidential information it may contain. E-mail messages to clients of Paul A. Neumiller presumptively contain information that is confidential and legally privileged; e-mail messages to non-clients are normally confidential and may also be legally privileged. Please do not read, copy, forward or store this message unless you are the intended recipient of it. If you have received this message in error, please forward it back to the sender and delete it completely from your computer system.
E-mail communication on the Internet may NOT be secure. There is a risk that this confidential communication may be intercepted illegally. There may also be a risk of waiving attorney-client and/or work-product privileges that may attach to this communication. DO NOT forward this message to a third party. If you have any questions regarding this notice, please contact the sender.
From: wsbarp-bounces at lists.wsbarppt.com<mailto:wsbarp-bounces at lists.wsbarppt.com> <wsbarp-bounces at lists.wsbarppt.com<mailto:wsbarp-bounces at lists.wsbarppt.com>> On Behalf Of Paul Neumiller
Sent: Wednesday, July 26, 2023 1:47 PM
To: WSBA Real Property Listserv <wsbarp at lists.wsbarppt.com<mailto:wsbarp at lists.wsbarppt.com>>
Subject: Re: [WSBARP] Litigator Help -- Ejectment
One person was initially given permission to stay on the vacant lot so we have his name but then he invited about 10 other people. Caption will read "Known Joe Blow and all other Occupants" Permission has been withdrawn. No lease, no rent paid or demanded. So, RCW 59.16, 59.12, and 59.18 don't apply.
[cid:image001.jpg at 01D9C07C.28A17D50]
IMPORTANT NOTICE: This e-mail message is intended to be received only by persons entitled to receive the confidential information it may contain. E-mail messages to clients of Paul A. Neumiller presumptively contain information that is confidential and legally privileged; e-mail messages to non-clients are normally confidential and may also be legally privileged. Please do not read, copy, forward or store this message unless you are the intended recipient of it. If you have received this message in error, please forward it back to the sender and delete it completely from your computer system.
E-mail communication on the Internet may NOT be secure. There is a risk that this confidential communication may be intercepted illegally. There may also be a risk of waiving attorney-client and/or work-product privileges that may attach to this communication. DO NOT forward this message to a third party. If you have any questions regarding this notice, please contact the sender.
From: wsbarp-bounces at lists.wsbarppt.com<mailto:wsbarp-bounces at lists.wsbarppt.com> <wsbarp-bounces at lists.wsbarppt.com<mailto:wsbarp-bounces at lists.wsbarppt.com>> On Behalf Of Bryce Dille
Sent: Wednesday, July 26, 2023 1:38 PM
To: WSBA Real Property Listserv <wsbarp at lists.wsbarppt.com<mailto:wsbarp at lists.wsbarppt.com>>
Subject: Re: [WSBARP] Litigator Help -- Ejectment
Who are you naming as defendants do you have the names of the squatters or are they all named as john does In addition to RCW 7.28 Cant you bring action under the RCW 59.16 unlawful entry and detainer or RCW 59.12(6)
Bryce H. Dille
Dille Law, PLLC
2010 Caton Way SW Ste. 101
Olympia, WA 98502
Office: 360-350-0270
Cell: 253-579-5561
[R_Alan_Swanson-WH-200]
** Please note that I use the dictation feature of my iPhone and that sometimes everything I say does not get properly translated**
This transmission contains confidential attorney-client communications and may not be disclosed to any person but the intended recipient(s). If this matter is transmitted to you in error, please notify the sender immediately.
Business Entity Creation and Management, Business, Government and Tax Law, Real Estate and Land Use, Residential, Commercial and Condominium Development Real Estate and Commercial Transactions & Closings, Including Performing Services as IRS Section 1031 Exchange Facilitator Estate Planning, including Wills and Trusts, and Probate Administration Representation Homeowners/Condominium Association Real Estate Developments Real Property Foreclosures and Forfeitures.
From: wsbarp-bounces at lists.wsbarppt.com<mailto:wsbarp-bounces at lists.wsbarppt.com> <wsbarp-bounces at lists.wsbarppt.com<mailto:wsbarp-bounces at lists.wsbarppt.com>> On Behalf Of Paul Neumiller
Sent: Wednesday, July 26, 2023 1:21 PM
To: WSBA Real Property Listserv <wsbarp at lists.wsbarppt.com<mailto:wsbarp at lists.wsbarppt.com>>
Subject: [WSBARP] Litigator Help -- Ejectment
I need to eject a homeless encampment. I am also bringing a motion for a preliminary injunction to kick them out early but CR 65 and RCWs are unclear as to the required notice to the squatters. I am finding no guidance on required advance notice of my motion. CR 65 just says that no preliminary injunction shall be issued without notice to other side (absent emergency situation). And, RCW 7.40.050 says that the "opposite party" needs to have "reasonable notice of the time and place" of the hearing for the injunction. My local court rules say I need to give 12 day's notice for a motion. I was going to have the Sheriff serve the summons and complaint along with the motion for order for the preliminary injunction and give the squatters about 5 days advance notice but now I question if I should give the squatters 12 days advance notice. But, if I have to wait the 12 days, I might as well as skip the preliminary injunction and bring a default or motion for summary judgement !
after 20 days. What say you?
[cid:image001.jpg at 01D9C07C.28A17D50]
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Message: 16
Date: Thu, 27 Jul 2023 11:19:46 -0700
From: "Stromberg, Spencer" <spencer at lucentlaw.com>
To: RPPT RP Listserv <wsbarp at lists.wsbarppt.com>
Subject: [WSBARP] North Carolina Counsel
Message-ID:
<CAGyXgZ+m6vS7Q8S1JTOZ-s2MtMZZC489Ad3itYO2mpV4L9vMVg at mail.gmail.com>
Content-Type: text/plain; charset="utf-8"
Hello Listmates -
Can anyone offer a referral to a real estate attorney licensed in North
Carolina? This has to do with an earnest money dispute involving property
in the Fayetteville area.
Thanks in advance.
*Spencer A. W. Stromberg*
Attorney at Law
1403 S. Grand Blvd., Suite 201-S
Spokane, WA 99203-2278
P: 509.455.3713
D: 509.828.4644
F: +1.509.455.3718 (must dial 1 before area code)
E: spencer at lucentlaw.com
lucentlaw.com <https://www.lucentlaw.com/>
Facebook <https://www.facebook.com/lucentlaw>
LinkedIn <https://www.linkedin.com/company/lucent-law>
Twitter <https://twitter.com/LucentLaw>
CONFIDENTIALITY NOTICE: This email and any attachments are confidential and
may be protected by legal privilege. If you are not the intended recipient,
be aware that any disclosure, copying or distribution, or use of this email
or any attachment is prohibited. If you have received this email in error,
please notify me and delete it from your system.
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Message: 17
Date: Thu, 27 Jul 2023 11:49:07 -0700
From: Sarah McCarthy <sarah at kawlawyers.com>
To: WSBA Real Property Listserv <wsbarp at lists.wsbarppt.com>
Subject: Re: [WSBARP] Litigator Help -- Ejectment
Message-ID: <814C6A4B-9045-4555-B253-A46EA7300D15 at kawlawyers.com>
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Message: 18
Date: Thu, 27 Jul 2023 11:50:12 -0700
From: Sarah McCarthy <sarah at kawlawyers.com>
To: WSBA Real Property Listserv <wsbarp at lists.wsbarppt.com>
Subject: Re: [WSBARP] Litigator Help -- Ejectment
Message-ID: <EEEE6223-E6B6-4D47-A114-2160807D7C6E at kawlawyers.com>
Content-Type: text/plain; charset="us-ascii"
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Message: 19
Date: Thu, 27 Jul 2023 18:58:06 +0000
From: Dean Prather <dean at deanpratheresquire.com>
To: WSBA Real Property Listserv <wsbarp at lists.wsbarppt.com>
Subject: [WSBARP] Building Permit help in Winthrop
Message-ID:
<SN7P223MB06235F70A9F73C7FDCA08F72B101A at SN7P223MB0623.NAMP223.PROD.OUTLOOK.COM>
Content-Type: text/plain; charset="us-ascii"
PC having problems with Okanogan County P & D on building permit issues. Would like to refer out to local counsel with local knowledge. PC claims that county code is being misinterpreted and they are also failing to recognize survey work that defies what the county is claiming re flood plain and building site location.
Any takers?
Dean Prather
Attorney
Dean Prather Esq. PLLC
Ph (360) 643-0499
Fax (360) 838-6605
E dean at deanpratheresquire.com<mailto:dean at deanpratheresquire.com>
This is a transmission from the solo law firm of DEAN PRATHER ESQ. PLLC and may contain information which is privileged, confidential, and protected by the attorney-client or attorney work product privileges. If you are not the addressee, note that any disclosure, copying, distribution, or use of the contents of this message is prohibited. If you have received this transmission in error, please destroy it and notify us immediately at our telephone number (360) 643-0499. The name and biographical data provided above are for informational purposes only and are not intended to be a signature or other indication of an intent by the sender to authenticate the contents of this or any electronic message.
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