<html>
<head>
<meta http-equiv="Content-Type" content="text/html;
charset=windows-1252">
</head>
<body text="#000000" bgcolor="#FFFFFF">
<p>Both the REK and fulfillment deed in Borghi were executed before
the 1988 effective date of RCW 64.28.020. It is odd though that
the statute was not mentioned in a footnote as not being
applicable due to the timing.</p>
<p>I haven't gone back and read Hurd and Deschamps to see how their
facts relate to this issue. I wonder what the legislature's
reasoning was for the need to amend RCW 64.28.020? Hurd was after
1988 and Deschamps was decades before. I wonder if there was
another decision that gave rise to a perceived need to amend CP
law?<br>
</p>
<pre class="moz-signature" cols="72">Kary L. Krismer
John L. Scott/KMS Renton
206 723-2148</pre>
<div class="moz-cite-prefix">On 9/18/2018 10:50 AM, Eric Nelsen
wrote:<br>
</div>
<blockquote type="cite"
cite="mid:8CF6ADB264BB704BB884B2ED9C1931D401B4674324@SBS2011.SayreLawOffices.local"><span
style="font-size:11.0pt;font-family:"Calibri","sans-serif";color:#1F497D"><u>Borghi</u>,
167 Wn.2d 480, 488,</span></blockquote>
<br>
</body>
</html>