case 2:14-cv-01566 document 1 filed 10/10/14 page 1 of...

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1918 EIGHTH AVENUE, SUITE 3300 • SEATTLE, WA 98101

(206) 623-7292 • FAX (206) 623-0594COMPLAINT Case No.

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON

AT SEATTLE

DAVID B. AAMODT and PATRICIA A. AAMODT, husband and wife, and the marital community composed thereof; SCOTT F. ABRAMS and GLORIA E. ABRAMS, husband and wife, and the marital community composed thereof; DAVID ADLER and MARCIA ADLER, husband and wife, and the marital community composed thereof; PATRICIA A. AHERN, a single woman; ALAN F. ALEXANDER and PATRICIA J. ALEXANDER, husband and wife, and the marital community composed thereof; MICHAEL J. ALLMAN and PATRICIA A. ALLMAN, husband and wife, and the marital community composed thereof; BIRGIT AMUNDSON, a single woman; CAMILLE J. ANDERSON, a single woman; LYNN ARGYLE, a single woman; DONALD ASELIN and SHARON ASELIN, husband and wife, and the marital community composed thereof; VIRGINIA AUGUST, a single woman; WILLIAM M. BACKLUND and PATRICIA A. BACKLUND, husband and wife, and the marital community composed thereof; KEVIN BAIL and KARLA HEATH, husband and wife, and the marital community composed thereof; BETH E. BAKER, a single woman; BEBE BAKER and SKIP BAKER, husband and wife, and the marital community composed thereof; JUANITA L. BALDWIN, a single woman; SHARON M.

Case No.

MASS ACTION

Case 2:14-cv-01566 Document 1 Filed 10/10/14 of 82

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BALLISTY, a single woman; PATRICIA D. BANNER, a single woman; MARGIE Y. BARATTO, a single woman; DAMON BARDELEBEN and NANCY BARDELEBEN, husband and wife, and the marital community composed thereof; BERT BARGMANN and GAYLE BARGMANN, husband and wife, and the marital community composed thereof; ROBERT P. BARILETTI and NANCY J. BARILETTI, husband and wife, and the marital community composed thereof; STEVE R. BARKER and RUTH L. BARKER, husband and wife, and the marital community composed thereof; DOROTHY F. BARTON, a single woman; JOHN D. BATJER and DEBORAH D. BATJER, husband and wife, and the marital community composed thereof; DAVID W. BECKER, a single man; JEAN BECKFORD and SOLIS FORTUNATO, husband and wife, and the marital community composed thereof; ROBERT BELL and CATHERINE BELL, husband and wife, and the marital community composed thereof; BARRY BELOVSKY and CLAIRE BELOVSKY, husband and wife, and the marital community composed thereof; GARLAND BERNS and JUDITH D. BERNS, husband and wife, and the marital community composed thereof; BARBARA BERNSTEIN, a single woman; CRAIG L. BERRY and SIRI BERRY, husband and wife, and the marital community composed thereof; NASSER BESSADA, a single man; PAUL G. BEST and DINANNE L. BEST, husband and wife, and the marital community composed thereof; ADRIENNE BESTE, a single woman; CHERYL BICK, a single woman; JOHN BICKERSTAFF and ALICIA BICKERSTAFF, husband and wife, and the marital community composed thereof; GAIL F. BJORKMAN, a single woman; ALAN BLACK and KATHERINE BLACK, husband and wife, and the marital community composed thereof; RONALD V. BLACK and STELLA J. BALCK, husband and wife, and the marital community composed thereof; MARGARET


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BLACK, a single woman; RONALD W. BLUHM and SUSAN C. BLUHM, husband and wife, and the marital community composed thereof; CAROL A. BOBREK, a single woman; MOLLY M. BOLL, a single woman; RANDALL T. BORDEN and DEETTE D. BORDEN, husband and wife, and the marital community composed thereof; JOHN P. BORDENET and CECELIA J. BORDENET, husband and wife, and the marital community composed thereof; LINDA BORICHEWSKI and JOSEPH BORICHEWSKI, husband and wife, and the marital community composed thereof; DONNA J. BOVEE, a single woman; JAMES L. BOYLE and GRETCHANN E. BOYLE, husband and wife, and the marital community composed thereof; JOHN L. BOYLE and BARBARA E. BOYLE, husband and wife, and the marital community composed thereof; JAY E. BRACK, a single man; WILLIAM C. BRADFORD and SUNDAE BRADFOR, husband and wife, and the marital community composed thereof; JOHN F. BRADLEY and FRANCES M. BRADLEY, husband and wife, and the marital community composed thereof; LESLIE BRADY and NANCY C. BRADY, a married couple and the marital community composed thereof; JANET R. BRANDY, a single woman; ROBERT J. BRAUNSTEIN and SUSAN BRAUNSTEIN, a married couple and the marital community composed thereof; MARK A. BREIDENBACH, a single man; WINTSTON BILL and NANCY BRILL, a married couple and the marital community composed thereof; LAWRENCE N. BRODER and SUSAN J. BRODER, a married couple and the marital community composed thereof; THERESA A. BRONSON, a single woman; MELVIN BROOK and JENNIFER BROOK, a married couple and the marital community composed thereof; DAVID W. BROOKS and JEANNIE BROOKS, a married couple and the marital community composed thereof; ALVIN BROWN and DEBORAH R. BROWN, a


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married couple and the marital community composed thereof; DIANE M. BROWN, a single woman; McDONALD G. BROWN and ROSEMARY P. BRWON, a married couple and the marital community composed thereof; JAMES A. BROZ and JANICE W. BROZ, a married couple and the marital community composed thereof; WILLIAM T. BRUCH and MARY P. BRUCH, a married couple and the marital community composed thereof; DAVID H. BRUNEAU and CHRYSTINA BRUNEAU, a married couple and the marital community composed thereof; THEODOR KEIL and JEAN KEIL, a married couple and the marital community composed thereof; LYNN A. BURCH, a single woman; MAGARET D. BURNELL, a single woman; GORDON BURNET and SALLY BURNET, a married couple and the marital community composed thereof; LARRY L. BURNS and JUDITH A. BURNS, a married couple and the marital community composed thereof; SHANNON BURRELL, a single woman; BARBARA BURROWS and MICHAEL J. USHKA, a married couple and the marital community composed thereof; JINNIE C. BUS, a single woman; JAMES R. BUSS and MARIAN F. BUSS; a married couple and the marital community composed thereof; JEREMY BUTLER and KAREN BUTLER, a married couple and the marital community composed thereof; BARBARA BYE and DICK BYE, a married couple and the marital community composed thereof; BEN C. BALEY, a single man; JOHN CALHOUN and JAMIE L. CALHOUN, a married couple and the marital community composed thereof; ELLANORA L. CAMPBELL, a single woman; ELLEN CAMPBELL, a single woman; JOHN D. CAMPBELL And KAREN L. CAMPBELL, a married couple and the marital community composed thereof; WILLIAM CARLSTROM and ANN CARLSTROM, husband and wife, and the marital community composed thereof;


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MICHAEL P. CARROLL and PATRICIA S. CARROLL, a married couple and the marital community composed thereof; FRANK A. CARTER and JOSEPHINE A. CARTER, , a married couple and the marital community composed thereof; GAIL CERRA, a single woman; WAYNE V. CHAMBERS and SHARON J. CHAMBERS, , a married couple and the marital community composed thereof; PHILIP CHAN, a single man; AGNES Y. CHANG, a single woman; CHUN CHANG and MYEONG CHANG, a married couple and the marital community composed thereof; SANDRA B. CHIVERS, a single woman; DAVID M. CHRISTIAN And MARLENE K. CHRISTIAN, a married couple and the marital community composed thereof; CHUN REVOCABLE LIVING TRUST; CAROL JEAN CHURCH, a single woman; DALE CLARK and JANET LEA CLARK, , a married couple and the marital community composed thereof; KURT CLASSEN and KATIE BUCHAN CLASSEN, , a married couple and the marital community composed thereof; JAMES C. CLEMETSON and SHARON CLEMETSON, , a married couple and the marital community composed thereof; PHILIP P. COADY and ELIZABETH A. COADY, , a married couple and the marital community composed thereof; COADY LIVING TRUST; ROGER L. COLEMAN and SOLWEIG B. COLEMAN, , a married couple and the marital community composed thereof; JAY COLLINS and PAMELA COLLINS, , a married couple and the marital community composed thereof; JOHN CONNELLY and EVELYN CONNELLY, , a married couple and the marital community composed thereof; CONNELLY FAMILY TRUST; KAREN MCBRIDE COOK, a single woman; MIKE COOK and LEE ANN COOK, husband and wife, and the marital community composed thereof; JOHN G. COPERNOLL, a single man; DAVID C. CORREA and VERNALEE W. CORREA, a married couple and the marital


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community composed thereof; ELEANOR CORRIGAN, a single woman; GWEN COTTINGHAM and DALE STIRN, a married couple and the marital community composed thereof; ERLENE COURTNEY, a single woman; AGNES CRIST and PER-ERIK MANSSON, a married couple and the marital community composed thereof; JEAN K. CROCKER, a single woman; DORIS M. CROSIER, a single woman; INDY CROWLEY and CHERYL CROWLEY, a married couple and the marital community composed thereof; LYNN S. CUSHMAN and JULIE P. CUSHMAN, a married couple and the marital community composed thereof; JAY R. CUSHNIE and LOIS J. CUSHNIE , a married couple and the marital community composed thereof; CUSHNIE FAMILY TRUST; DIANE L. CVETOVICH, a single woman; CARL A. CZAJKOWSKI and HELENA J. CZAJKOWSKI, a married couple and the marital community composed thereof; JANA CZECH, a single woman; CAROL DAHLBERG, a single woman; JAMES L. DALGARN and IRENE DALGARN, a married couple and the marital community composed thereof; PATRICK E. DAVIDSON and LINETTE WYATT, a married couple and the marital community composed thereof; SHARON D. DAVIS, a single woman; THOMAS W. DAVIS and TERESA C. DAVIS, a married couple and the marital community composed thereof; HENK I. DAWSON and ELKE DAWSON, a married couple and the marital community composed thereof; ROGER L. DEEGAN and SANDRA J. DEEGAN, a married couple and the marital community composed thereof; CHARLOTT DEFRANCES, a single woman; DAVID DEINES, a single man; LYNDA DENNEMARCK, a single woman; EDWIN J. DESCAMP and JEANNE E. DESCAMP, a married couple and the marital community composed thereof; RICHARD E. DILL and KATHLEEN J. DILL, a married couple and the marital community composed


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thereof; THOMAS P. DILLON and BEVERLY A. DILLON, a married couple and the marital community composed thereof; ROBERT E. DIXON and EDITH L. DIXON, a married couple and the marital community composed thereof; RANDY A. DOBLAR and DEBRA M. DOBLAR, a married couple and the marital community composed thereof; ALAN R. DOE and NORMA F. DOE, a married couple and the marital community composed thereof; BEVERLY DOMAN, a single woman; THOMAS J. DONAHEY and LINDA J. DONAHEY, a married couple and the marital community composed thereof; TURRELL S. DOOLITTLE, a single man; DANIEL F. DORAN and JANETTE F. DORAN, a married couple and the marital community composed thereof; JUDY DOW, a single woman; WILLIAM L. DOWNS and MYRNA DOWNS, a married couple and the marital community composed thereof; DOWNS LIVING TRUST; BENJAMIN Z. DRAJPUCH and JACALYN DRAJPUCH, a married couple and the marital community composed thereof; THOMAS DRZEWIECKI and ANGELA DRZEWIECKI, a married couple and the marital community composed thereof; ROBERT A. DUCHI and JANICE C. DUCHI, a married couple and the marital community composed thereof; BEVERLY J. DUKE, a single woman; THE DUKE TRUST; GEORGE S. DULEBA, a single man; GARY A . DUNN, a single man; EBBE B. EBBESEN and JOANNE T. EBBESON, a married couple and the marital community composed thereof; JERRY L. EDGERTON and DARLENE G. EDGERTON, a married couple and the marital community composed thereof; MICHAEL R. EDGMAND and JUDITH J. EDGMAND, a married couple and the marital community composed thereof; LEILA EDWINS, a single woman; ELLEN L. EGGE, a single woman; DAVID ELDER and MURIEL ELDER, a married couple and the marital community composed thereof; MARICA J. ELLISON, a


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single woman; JAMES R. EMCH, a single man; THOMAS H. ESSIG and JUDITH ESSIG, a married couple and the marital community composed thereof; STEVE ESTBY and DENISE ESTBY, a married couple and the marital community composed thereof; SANDRA EVANS and WAYNE EVANS, a married couple and the marital community composed thereof; MASON G. FARRELL, JR. and LINDA H. FARRELL, a married couple and the marital community composed thereof; ROBERT FERGUSON and SHIRLEY FERGUSON, a married couple and the marital community composed thereof; ELEANOR J. FERRER, a single woman; JAMES J. FISCHER and JUDITH A. FISCHER, a married couple and the marital community composed thereof; KENNETH FLAJOLE and COLLEEN A. FLAJOLE, a married couple and the marital community composed thereof; JOYCE D. FLYNN, a single woman; GEORGE FORD and NANCY SNELL, a married couple and the marital community composed thereof; HUGH J. FORD and JOYCE D. FORD, a married couple and the marital community composed thereof; JEFFREY A. FORREY and JEANNE FORREY, a married couple and the marital community composed thereof; DON W. FOWLER and MARY C. FOWLER, a married couple and the marital community composed thereof; RONALD L. FRANKLIN and LESLYN M. ROSE FRANKLIN, a married couple and the marital community composed thereof; MARVIN FREDRICKSON and LINDA L. FREDRICKSON, a married couple and the marital community composed thereof; JEFFREY H. FRENCH and CAROLYN M. FRENCH, a married couple and the marital community composed thereof; ROY A. FRICKE and TING Y. FRICKE, a married couple and the marital community composed thereof; KURT FRIEDRICH and KATLEEN FRIEDRICH, a married couple and the marital community composed thereof; JAMES A. FRY and JODIE


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L. FRY, a married couple and the marital community composed thereof; MICHAEL FULLER and MARY FULLER, a married couple and the marital community composed thereof; JAMES GALLAGHER and BETTY GALLAGHER, a married couple and the marital community composed thereof; DONALD E. GARCIA and DOLORES GARCIA, a married couple and the marital community composed thereof; RICHARD E. GARDNER and SAVILLE H. GARDNER, a married couple and the marital community composed thereof; ROBALD L. GARRETT and SANDRA L. GARRETT, a married couple and the marital community composed thereof; GARRETT LIVING TRUST; DALE MARTIN GARVEY, JR. and JANICE MOORE, a married couple and the marital community composed thereof; RONALD V. GAUTREAU and SYBIL H. GAUTREAU, a married couple and the marital community composed thereof; ZHENIN GELT and LYUDMILA GELT, a married couple and the marital community composed thereof; JOSEPH W. GELZER and LORELEI L. GELZER, a married couple and the marital community composed thereof; ROBIN S. GENTILE and RONALD L. GENTILE, a married couple and the marital community composed thereof; DENNIS GIBBS, a single man; LAWRENCE C. GIBSON and DIANE M. GIBSON, a married couple and the marital community composed thereof; ALLEN GLENN and SANDRA GLENN, a married couple and the marital community composed thereof; MIKELL GOE and RICHARD GOE, a married couple and the marital community composed thereof; DONALD W. GOETSCH and KATHLEEN L. GOETSCH, a married couple and the marital community composed thereof; BARBARA D. GOLDHAMMER, a single woman; ROBERT GOODKIN and SANDRA R. GOODKIN, a married couple and the marital community composed thereof; DAVID M. GORDON and DIANE GORDON, a married


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couple and the marital community composed thereof; SARAH L. GORE, a single woman; MARJORIE N. GORODKO, a single woman; KENNETH T. GRAAT and PAMELA D. GRAAT, a married couple and the marital community composed thereof; STEPHEN GRAY and CAROLINE A. GRAY, a married couple and the marital community composed thereof; PAUL W. GRECO and MARELU M. GRECO, a married couple and the marital community composed thereof; SKIP GREENE and LINDA GREENE, a married couple and the marital community composed thereof; RAYMOND GREGIORE and CHRISTINE GREGOIRE, a married couple and the marital community composed thereof; WILLIAM CHARLES GRESS, III and RUBY ANN GRESS, a married couple and the marital community composed thereof; PATRICIA L. GRIBBON and WILLIAM T. GRIBBON, a married couple and the marital community composed thereof; JEFFREY D. GROSSMAN and VIVIAN GROSSMAN, a married couple and the marital community composed thereof; PATRICIA E. GUERNSEY, a single woman; ARTHUR L. GURTEL and SHARON F. GURTEL, a married couple and the marital community composed thereof; LUCIAN G. GUTHRIE and JO ANN A. GUTHRIE, a married couple and the marital community composed thereof; JANINE R. GWILYM and MILES L. GWILYM, a married couple and the marital community composed thereof; JOEL E. HAAS and CAROLYN A. HAAS, a married couple and the marital community composed thereof; JEFFREY HAGANDER and LUCIA HAGANDER, a married couple and the marital community composed thereof; JOELL L. HAGBERG, a single individual; JAMES O. HAGEN and NANCY C. HAGEN, a married couple and the marital community composed thereof; EUGENE ROSS HAISCH, JR. and WYNONNA D. HAISCH, a married couple and the marital community composed thereof;


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KAREN JEAN HALL, a single woman; ANNETTE I. HALLEN, a single woman; KENNETH A. HAMERNIK and PEGGY ANN HAMERNIK, a married couple and the marital community composed thereof; MERRIE E. HAMLIN, a single individual; HAMMERBACK FAMILY TRUST; JESSE E. HAMMOND and SANDRA J. HAMMOND, a married couple and the marital community composed thereof; JOHN K. HANCOCK and JACQUELYN HANCOCK, a married couple and the marital community composed thereof; ROBERT L. HANDLEY and CELIA B. HANDLEY, a married couple and the marital community composed thereof; JEAN M. HANSEN, a single individual; EDWARD M. HARTSTEIN, a single man; RICHARD R. HASKITT and JOYCE E. HASKITT, a married couple and the marital community composed thereof; GAIL . HAWLEY, a single woman; DAVID K. HAYES, JR. and SUSAN D. HAYES, a married couple and the marital community composed thereof; BARBARA HEADMAN, a single woman; GEORGE ROSS HEATH and LORNA M. HEATH, a married couple and the marital community composed thereof; WILLIAM R. HEGGER and KRISTINE A. HEGGER, a married couple and the marital community composed thereof; KARL A. HEILBORN and MARIE HEILBORN, husband and wife, and the marital community composed thereof; SUSAN HELLER, a single woman; JOCELYN B. HELM, a single woman; NOEL A. HENDERSON and CAROLYN J. HARRIS, a married couple and the marital community composed thereof; HESS LIVING TRUST; RICHARD HETHERINGTON and ANN HETHERINGTON, a married couple and the marital community composed thereof; CHERYL HIGGINS and JAN HIGGINES, a married couple and the marital community composed thereof; WILLIAM A. HILTON, a single man; WINEFRED T. HIRANO, a single individual; CHARLES S. HOFF and SHEILA R. HOFF, a married couple and the marital community


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composed thereof; NEIL R. HOFFMAN and MARIANNE M. HOFFMAN, a married couple and the marital community composed thereof; KERMIT L. HOLMAN and AUDREY R. HOLMAN, a married couple and the marital community composed thereof; BURDETTE HOLMES and SHARON L. HOLMES, a married couple and the marital community composed thereof; JAMES A. HOOKER and ALME LEE HOOKER, a married couple and the marital community composed thereof; JACK HOOPER and ANDREA L. WELKER, a married couple and the marital community composed thereof; BRIAN HORAN and SUE ATKINSON HORAN, a married couple and the marital community composed thereof; JAMES F. HORRELL and BARBARA HORRELL, a married couple and the marital community composed thereof; FRANK R. HOUMIEL, a single man; LORRAINE HOUMIEL, a single woman; ELEANOR M. HOWARD and ROBERT C. HOWARD, a married couple and the marital community composed thereof; HOXIE REVOCABLE TRUST; PHILIP HOY and BRENDA WEST, a married couple and the marital community composed thereof; ALICE HUANG, a single woman; JANE R. HUBBELL, a single woman; ALLEN HUGHES and NANCY HUGHES, a married couple and the marital community composed thereof; BARRY HUI and AMY YUEN-FUN, a married couple and the marital community composed thereof; FRANK HUI and YVONNE HUI, a married couple and the marital community composed thereof; STANLEY D. HUMANN and KAY A. HUMANN, a married couple and the marital community composed thereof; DAVID HUNTMAN and SHEILA HUNTMAN, a married couple and the marital community composed thereof; DAVID R. HYDE and DAPHNE E. HYDE, a married couple and the marital community composed thereof; MARK R. IRAOLA and KAREN E. IRAOLA, a married couple and the marital community composed


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thereof; MORRIS R. ISRAEL and NANCY E. ISRAEL, a married couple and the marital community composed thereof; MARILYN IVERSON, a single woman; RANDALL V. JACKSON and PATRICIA K. JACKSON, a married couple and the marital community composed thereof; JAMES FAMILY TRUST; LINDA A. JATON and WAYNE JATON, a married couple and the marital community composed thereof; THOMAS L. JENKINS and DIANE M. JENKINS, a married couple and the marital community composed thereof; WILLIAM C. JENSEN and CAROL W. JENSON, a married couple and the marital community composed thereof; CANDACE JOHNSON and RONALD JOHNSON, a married couple and the marital community composed thereof; GARY JOHNSON and VERLE JOHNSON, a married couple and the marital community composed thereof; JOHN N. JOHNSON and VIRGINIA A. JOHNSON, a married couple and the marital community composed thereof; JOAN M. JOHNSTON, a single woman; JOSEPHINE A. HARVEY, a single woman; LAWRENCE A. KAHN and ROSANNE S. COHN, husband and wife, and the marital community composed thereof; STEPHEN E. KALISH and SUZANNE H. KALISH, husband and wife, and the marital community composed thereof; SAT DEV KAPAHI, a married man, individually and as Trustee of the KAPAHI FAMILY TRUST; ASHOK N. KATTI and SUDHA N. KATTI, husband and wife, and the marital community composed thereof; KAREN V. KELLY, a single woman; DON M. KENNEDY and PATRICIA L. KENNEDY, husband and wife, and the marital community composed thereof; ROBERT B. KENNEDY and SANDRA L. KENNEDY, husband and wife, and the marital community composed thereof; CECILE E. KERKOF and MICHELLE M. KIRWIN, individually, and the Washington State Registered Domestic Partnership composed thereof; MAURICE A.


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KERKOF and CONSTANCE E. KERKOF, husband and wife, and the marital community composed thereof; THOMAS KIENTZ, a single man; BRIAN KIMBALL and BARBARA L. KIMBALL, husband and wife, and the marital community composed thereof; TIMOTHY M. KIMSEY and GLENDA M. KIMSEY, husband and wife, and the marital community composed thereof, individually and as Trustees for the KIMSEY LIVING TRUST; DAVID KING and KAREN KING, husband and wife, and the marital community composed thereof; RUTH KING, a single woman; RALPH A. KINGMAN, a single man; ANTHEA KJERULFF, a single woman; WILLIAM G. KNIGHT and DOROTHY A. GRAHAM, husband and wife, and the marital community composed thereof; DANIEL B. KOEBEL, an unmarried man, and SHARON L. COOPER, an unmarried woman; MICHAEL KOPPEL and RICKI KOPPEL, husband and wife, and the marital community composed thereof; MARGARET M. KRAHN, a single woman; RODNEY B. KREBS and JUDY L. KREBS, husband and wife, and the marital community composed thereof, individually and as Trustees for the KREBS FAMILY TRUST; OI LING KRIEFF, a single man; MIN-CHIU KUO, a single woman; KENNETH R. KUSHIN, a single man; MARILYN KUSSICK , a single woman, individually and as Trustee of the LEON AND MARILYN KUSSICK REVOCABLE TRUST; ROBERT M. LAGUARDIA and ROSE C. LAGUARDIA, husband and wife, and the marital community composed thereof; STEVEN B. LANMAN and BETTY L. LANMAN, husband and wife, and the marital community composed thereof; NORMAN A. LARSON and BARBARA L. LARSON, husband and wife, and the marital community composed thereof; MARIAM LATIF, a single woman, individually and on behalf of IMMOVENTURE, LLC, a Georgia limited liability company; BARRY C. LATTER and SUSAN E. LATTER, husband and wife, and the marital community composed


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thereof; PIERRE LAUZON and EILEEN M. LAUZON, husband and wife, and the marital community composed thereof; CHARLES W. LAWRENCE and LOIS L. LAWRENCE, husband and wife, and the marital community composed thereof; VIRGINIA F. LAWSON, a single woman; JANIS B. LEE, a single woman; LYNDEN D. LEE and HELEN B. LEE, husband and wife, and the marital community composed thereof; DEAN LESTER and DIANNE LESTER, husband and wife, and the marital community composed thereof; BARBARA A. LEWIS, a single woman, and MICHELLE R. BURTON, a single woman; W. WAYNE LICHTENBERGER and BONNIE A. LICHTENBERGER, husband and wife, and the marital community composed thereof; JOHN A. LIEBOWITZ and DIANE B. LIEBOWITZ, husband and wife, and the marital community composed thereof; WILMOT H. LILLY, III and MARILYN R. LILLY, husband and wife, and the marital community composed thereof; LAURENCE T. LINDE and GAIL A. LINDE, husband and wife, and the marital community composed thereof; NANCY I. LINDSTROM, a single woman; ANNA LISINA, a single woman;JOHN LIU and WINNIE LIU, husband and wife, and the marital community composed thereof; FRANCES W. LLOYD, a single woman; GILBERT A. LONG and ILONE D. LONG, husband and wife, and the marital community composed thereof; JOAN S. LONG, a single woman; PATRICIO LOPEZ and NORA GUZMAN, husband and wife, and the marital community composed thereof; BONNIE LORENZ, a single woman; JERI L. LOVELAND, a single woman; GORDON H. LOWELL and LINDA K. LOWELL, husband and wife, and the marital community composed thereof; DAVID J. LUBOCKI and JACKIE C. LUBOCKI, husband and wife, and the marital community composed thereof; SUSAN A. LUCAS, a single woman; MATTHEW B. LUEBBERS and CYNTHIA L. LUEBBERS,


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husband and wife, and the marital community composed thereof; HAROLD L. LUHN and KAREN R. LUHN, husband and wife, and the marital community composed thereof; FLOYD M. LUKECART and LORA I. LUKECART, husband and wife, and the marital community composed thereof; FREDRICK J. LUKSON and CAROLYN K. LUKSON, husband and wife, and the marital community composed thereof; KENNETH D. LYON and ROBERTA J. LYON, husband and wife, and the marital community composed thereof; MORTEN T. B. JOSLIN and ALMA V. JOSLIN, husband and wife, and the marital community composed thereof, individually and as Trustees for the M&A JOSLIN FAMILY TRUST; DOUGLAS K. MACDUFF and KAREN D. MACDUFF, husband and wife, and the marital community composed thereof; CHERIE K. MACLANE, a single woman; DAVID M. MAGNUSON and DIANE L. MAGNUSON, husband and wife, and the marital community composed thereof; CHERI LYN MAHONEY and DARWIN J. SAMU, wife and husband, and the marital community composed thereof; MARGARET C. MALONE, a single woman; RICHARD JOHN MARASCO and DARLENE D. MARASCO, husband and wife, and the marital community composed thereof, individually and as Trustees for the MARASCO FAMILY TRUST; RONALD L. MARKEZICH and BEVERLY J. MARKEZICH, husband and wife, and the marital community composed thereof; RICHARD D. MARSHALL and NANCY K. MARSHALL, husband and wife, and the marital community composed thereof; DALE A. MARTIN and SUSAN D. MARTIN, husband and wife, and the marital community composed thereof, individually and as Trustees of the DALE A. MARTIN AND SUSAN D. MARTIN LIVING TRUST; JAMES E. MARTINEAU and KATHLEEN M. MARTINEAU, husband and wife, and the marital community composed thereof; STEVEN I. MATHENY and ANITA R.


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MATHENY, husband and wife, and the marital community composed thereof; DONALD L. MATTHES and SUSAN J. MATTHES, husband and wife, and the marital community composed thereof; DAVID E. MATTHIAS and JUDY A. MATTHIAS, husband and wife, and the marital community composed thereof; GEOFFREY MAYER and SUSAN MAYER, husband and wife, and the marital community composed thereof; CHARLES J. MCCALLUM, JR. and PENNIE J. MACCALLUM, husband and wife, and the marital community composed thereof; JOHN R. MCCANDLESS and CAROL A. MCCANDLESS, husband and wife, and the marital community composed thereof; KURT D. MCCANN and MARY DEE MCCANN, husband and wife, and the marital community composed thereof; RONALD A. MCCRAY and CAROL LEE MCCRAY, husband and wife, and the marital community composed thereof; STEPHEN E. MCFARLAND, SR. and ANNE RACKERS MCFARLAND, husband and wife, and the marital community composed thereof; ROBERT MCINTOSH and LOIS C. MCINTOSH, husband and wife, and the marital community composed thereof; THOMAS A. MCKAY and SHEILA E. MCKAY, husband and wife, and the marital community composed thereof; DAVID MCMANAMON and MELEAH D. MCMANAMON, husband and wife, and the marital community composed thereof; KENNETH D. MCRAE, a single man; JAMES MEAD and JULIE MEAD, husband and wife, and the marital community composed thereof; S. RICK MEIKLE and KAREN T. MEIKLE, husband and wife, and the marital community composed thereof; DONALD MEISER and MARLENE MEISER, husband and wife, and the marital community composed thereof; MARGARITA E. MENDOZA and JUSTINIANO R. MENDOZA wife and husband, and the marital community composed thereof; STEPHEN A. MEREDITH and LINDA L. MEREDITH, husband and wife, and the marital


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community composed thereof; MIKE MESAROS and ROZI MESAROS, husband and wife, and the marital community composed thereof; ROBERT E. MICHALAK, a single man, individually and as Trustee of the MICHALAK LIVING TRUST; JOSEF MICKLITZ and ELIZABETH MICKLITZ, husband and wife, and the marital community composed thereof, individually and as Trustees of the JOSEF MICKLITZ AND ELIZABETH MICKLITZ FAMILY TRUST; JOHN J. MIHOVILOVICH and DONNA J. MIHOVILOVICH, husband and wife, and the marital community composed thereof; RICHARD MILBRODT and BONNIE MILBRODT, husband and wife, and the marital community composed thereof; MASARU MINEMOTO and VICKI LYNN MINEMOTO, husband and wife, and the marital community composed thereof, individually and as Trustees of the MASARU MINEMOTO AND VICKI LYNN MINEMOTO REVOCABLE LIVING TRUST; DAVID S. MITCHELL and LILLY O. MITCHELL, husband and wife, and the marital community composed thereof; JEFFREY K. MOIR, a single man; DONALD M. MONCRIEFF and ROSEMARY J. MONCRIEFF, husband and wife, and the marital community composed thereof; TED L. MONTGOMERY and KATHLEEN G. MONTGOMERY, husband and wife, and the marital community composed thereof; WILLIAM A. MOORE, a single man; JUDITH A. MORLAND, a single woman; ROBERT S. MORRIS and DONNA G. MORRIS, husband and wife, and the marital community composed thereof; MICHAEL R. MORRISON and JEANNE M. MORRISON, husband and wife, and the marital community composed thereof; DORIS E. MOSER, a single woman, and BARBARA M. DOYLE, a single woman; JOE L. MOYA and SALLY A. MOYA, husband and wife, and the marital community composed thereof; MARIE MUDD, a single woman;


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MICHELLE M. MURPHY, a single woman; MICHAEL MYERS and KATHLEEN MYERS, husband and wife, and the marital community composed thereof; WILLIAM M. MYERS and PRUDENCIA D. MYERS, husband and wife, and the marital community composed thereof; SHIRLEY J. NAFE, a single woman; WILLIAM D. NEER and CAROLE M. NEER, husband and wife, and the marital community composed thereof; SANDRA A. NELSON, a single woman; LAWRENCE H. NESS and JANE E. NESS, husband and wife, and the marital community composed thereof; JOHN NEWSOM and SHARON NEWSOM, husband and wife, and the marital community composed thereof; DOUGLAS B. NICHOLSON and CONSTANCE A. NICHOLSON, husband and wife, and the marital community composed thereof, individually and as Trustees of the DOUGLAS B. AND CONSTANCE A. NICHOLSON TRUST; MARSHA M. NIEMAN, a single woman; JUDITH M. NILSEN, a single woman; FRANK NOMIYAMA and BETTY Y. NOMIYAMA, husband and wife, and the marital community composed thereof; KUMIKO Y. NOMOTO, a single woman; JOHN C. NORRIS and GLENDA C. NORRIS, husband and wife, and the marital community composed thereof; LORENA M. OBLANDER, a single woman; MICHAEL T. OLIVER and BARBARA S. OLIVER, husband and wife, and the marital community composed thereof; ELLA JEAN OLSEN, a single woman; HARVEY T. OLSON and MARIA M. OLSON, husband and wife, and the marital community composed thereof; DENNIS G. OPACKI and JUDITH OPACKI, husband and wife, and the marital community composed thereof; FRAN OPHEIM, a single woman; MARVIN M. OWENS and BETTY M. OWENS, husband and wife, and the marital community composed thereof; CONNIE PALAZZOLO, a single woman, and ALICE HRNCIR, a single woman; KATHLEEN. J. PARIS, M.D., a single woman,


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individually and as Trustee of the KATHLEEN J. PARIS, M.D. TRUST; HELEN C. PARRISH, a single woman; JAMES D. PASS and SUSAN PASS, husband and wife, and the marital community composed thereof; JACK D. PATTERSON and CATHERINE E. PATTERSON, husband and wife, and the marital community composed thereof; RICHARD A. PAUL and KATHERINE G. PAUL, husband and wife, and the marital community composed thereof; JAMES A. PAXTON and MARY L. PAXTON, husband and wife, and the marital community composed thereof, individually and as Trustees for the JAMES AND MARY PAXTON FAMILY REVOCABLE TRUST; CHARLES A. PEDRIDO, a single man, individually and as Trustee for the PEDRIDO FAMILY TRUST; WILLIAM R. PEERCE, JR. and SUSAN L. PEERCE, husband and wife, and the marital community composed thereof; KRISTINE S. PEPPER, a single woman; MICHAEL A. PERKINS and SHELLEY M. PERKINS, husband and wife, and the marital community composed thereof; DIANE M. PETERSON, a single woman; DOUGLAS W. PETERSON and MARYANNE PETERSON, husband and wife, and the marital community composed thereof; ROGER F. PETERSON and DIANNE LISLE PETERSON, husband and wife, and the marital community composed thereof; JOHN J. PHILLIPS and ELEANOR F. PHILLIPS, husband and wife, and the marital community composed thereof; ROBERT L. PIRTLE and JENNIFER PIRTLE, husband and wife, and the marital community composed thereof; STEPHEN V. W. POPE and ANDREA A. POPE, husband and wife, and the marital community composed thereof; ROSE PORTER, a single woman; GREGORY R. POWERS and MARIANNE N. POWERS, husband and wife, and the marital community composed thereof; CHRISTINE D. PRESLEY, a single woman, individually and as Trustee of the CHRISTINE


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D. PRESLEY TRUST; ROBERT C. PRINGLE and TINA A. PRINGLE, husband and wife, and the marital community composed thereof; CAROL WERTHEIMER PROESEL, a single woman; RONALD F. RADKE and RUTH E. RADKE, husband and wife, and the marital community composed thereof; JEANETTE B. RAGSDALE and BOBBY J. RAGSDALE, wife and husband, and the marital community composed thereof; DIANA L. RALL and STANLEY C. RALL, wife and husband, and the marital community composed thereof; SUNDER RANGARAM and CAROL ANN RANGARAM, husband and wife, and the marital community composed thereof, individually and as Trustees for the SUNDER RANGARAM AND CAROL ANN RANGARAM TRUST; RICHARD W. RECOB and LINDA A. RECOB, husband and wife, and the marital community composed thereof; JOHN D. REEVES and DIA M. REEVES, husband and wife, and the marital community composed thereof; CHARLES REILLY and GAY ANN REILLY, husband and wife, and the marital community composed thereof; JEAN A. REITAN, a single woman; JANE J. REUBISH, a single woman; RICHARD M. RESNIK and AMY M. RESNIK, husband and wife, and the marital community composed thereof; LARRY O. RICHARDS and PATRICIA C. RICHARDS, husband and wife, and the marital community composed thereof; MARGARET R. RIEDER, a single woman; DENNIS J. RIEGER and JANICE D. RIEGER, husband and wife, and the marital community composed thereof; KEIL A. RIEGER and MORETTA RIEGER, husband and wife, and the marital community composed thereof; VERA JANE RISDON, a single woman; DAVID ROBNETT and GERALDINE ROBNETT, husband and wife, and the marital community composed thereof; RICHARD L. RODMAN and CAROL F. RODMAN, husband and wife, and the marital community composed thereof; ROMANO DOUGLAS P. ROMANO


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and ALLISON E. ROMANO, husband and wife, and the marital community composed thereof, individually and as Trustees for the ROMANO FAMILY LIVING TRUST; DAVID H. ROSENBERG and SANDRA WEINSTEIN ROSENBERG, husband and wife, and the marital community composed thereof; ODILE M. ROSENFELD, as Trustee of the GODIDI TRUST; DONALD A. ROSS and REDITH F. ROSS, husband and wife, and the marital community composed thereof; JULITTA A. ROSS, a single woman; HOWARD ROTH and KATHY ROTH, husband and wife, and the marital community composed thereof; GERHARD F. RUBEN and PALMA T. RUBEN, husband and wife, and the marital community composed thereof; HARRY A. RUBIN and CYNTHIA E. RUBIN, husband and wife, and the marital community composed thereof; SIGMUND P. RUDOWICZ and ROSEMARY RUDOWICZ, husband and wife, and the marital community composed thereof; DIANE RUFF, a single woman; CATHLEEN A. RUGGIERO, a single woman; RICHARD G. RUHLAND and GERALDINE M. RUHLAND, husband and wife, and the marital community composed thereof; ROBERT RUSHING and GAIL RUSHING, husband and wife, and the marital community composed thereof; HARRIET L. RUSSELL, a single woman; WALTER R. RYAN, JR. and SARAH H. RYAN, husband and wife, and the marital community composed thereof, individually and as Trustees for the WALTER RIDGEWAY RYAN JR. AND SARAH COLEMAN HACKWORTH RYAN TRUST; JAMES R. SAARI and JOYCE M. SAARI, husband and wife, and the marital community composed thereof; ROBERT W. SACKMANN and DOROTHY C. SACKMANN, husband and wife, and the marital community composed thereof; RICHARD C. SADLER and CHERYL L. SADLER, husband and wife, and the marital community composed thereof, individually and as Trustees for the RICHARD AND CHERYL SADLER FAMILY TRUST; ELLEN SALDANA, a single woman; PHILIP C.


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SALVATORI and CONSTANCE M. SALVATORI, husband and wife, and the marital community composed thereof; JAMES C. SANBORN and E. SUE SANBORN, husband and wife, and the marital community composed thereof; WANTLAND SANDEL and PHYLLIS SANDEL, husband and wife, and the marital community composed thereof; JIM D. SATHER and BARBARA A. SATHER, husband and wife, and the marital community composed thereof; ANTHONY E. SCHAFF and PHYLLIS M. SCHAFF, husband and wife, and the marital community composed thereof; ARTHUR C. SCHEUNEMANN and MICHELLE E. OWENS, husband and wife, and the marital community composed thereof; IRENE M. SCHMIDT, a single woman; ROBERT A. SCHULTZ, a single man; MICHAEL SCHWARTZ and RENA SCHWARTZ, husband and wife, and the marital community composed thereof; MARSHALL R. SCOTT and GRACE L. SCOTT, husband and wife, and the marital community composed thereof; DANNY A. SHAEFFER and DIANE M. SHAEFFER, husband and wife, and the marital community composed thereof; JOHN G. SHAFFER and ADRIENNE H. SHAFFER, husband and wife, and the marital community composed thereof; TOM SHANLEY and SANDRA K. SHANLEY, a married couple and the marital community composed thereof; JOHN C. SHANNON and SANDRA M. SHANNON, husband and wife, and the marital community composed thereof; MARILYN T. SHAW, a single woman; DIANA G. SHEARER, a single woman; ELIZABETH SHEERAN, a single woman; CHRISTOPHER M. SHELDON and REBECCA J. SHELDON, husband and wife, and the marital community composed thereof; JERRY W. SHIFLET and ARDIS SHIFLET, husband and wife, and the marital community composed thereof; JAMES O. SHOULTS and DONNA M. SHOULTS, husband and wife, and the marital community composed thereof; DAVID SHRIVER and SHARON SHRIVER, husband and wife, and the marital community composed thereof; HARRY J. SHRIVER, a single man; MARGARITA


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SHTEYNBERG and MIKHAIL SHTEYNBERG, wife and husband, and the marital community composed thereof; KEVIN T. SHYNE and FRANCINE C. SHYNE, husband and wife, and the marital community composed thereof; HERBERT W. SIEFKES and LOIS E. SIEFKES, husband and wife, and the marital community composed thereof; CHAKWAN SIEW and MABEL SIEW, husband and wife, and the marital community composed thereof; JACOB A. SIGL and OLGA ANNE SIGL, husband and wife, and the marital community composed thereof; FRANCES CAROL SIMMONS, a single woman; ROBERT C. SMILOW and JEANIE L. SMILOW, husband and wife, and the marital community composed thereof; DONALD L. SMITH and F. ERNESTINE SMITH, husband and wife, and the marital community composed thereof; KIM W. SMITH individually, and as Trustee of the KIM SMITH LIVING TRUST; FRANKLIN P. SOKOL and VIRGINIA M. SOKOL, husband and wife, and the marital community composed thereof; MARTIN P. SOKULSKI and RACHELE A. SOKULSKI, husband and wife, and the marital community composed thereof; ARNOLD SOMERS, a single man; WILLIAM M. STAAB, a single man; WILLIAM H. STEIGER and SANDRA N. STEIGER, husband and wife, and the marital community composed thereof; MICHAEL J. STEPHENSON and CAROL K. STEPHENSON, husband and wife, and the marital community composed thereof; PAUL R. STEVENS and PATRICIA A. STEVENS, husband and wife, and the marital community composed thereof; SANDRA STORY, a single woman; MICHAEL T. STRAINER, an unmarried man, and JUTTA ROEHRIG, an unmarried woman; JAMES E. STROH and MARY J. STROH, husband and wife, and the marital community composed thereof, individually and as Trustees for the STROH REVOCABLE LIVING TRUST; EUGENE J. STUMPF and ELLEN T. STUMPF,


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husband and wife, and the marital community composed thereof, individually and as Trustees for the LIVING TRUST OF EUGENE J. AND ELLEN T. STRUMPF; DAVID R. SUTHERLAND and MARION M. SUTHERLAND, husband and wife, and the marital community composed thereof, individually and as Trustees for the SUTHERLAND REVOCABLE LIVING TRUST; TREVOR M. SWANGARD and MARIANNE L. SWANGARD, husband and wife, and the marital community composed thereof; CORNELL K. SWANSON and SHIRLEY K. SWANSON, husband and wife, and the marital community composed thereof; J. SHANNON SWEATTE and JANET E. SWEATTE, husband and wife, and the marital community composed thereof; DONALD SWENSON and BARBARA SWENSON, husband and wife, and the marital community composed thereof; GARY SWOFFORD and DIANE SWOFFORD, husband and wife, and the marital community composed thereof; MARILYN J. SYLVESTER, a single woman; SYLVIA A. SZYMANSKI, a single woman; JUDY L. TALBOTT, a single woman; RICHARD N. TAUBER and BARBARA A. TAUBER, husband and wife, and the marital community composed thereof; AYE AYE TAY, a single woman; DEAN TAYLOR and JOBESS TAYLOR, husband and wife, and the marital community composed thereof, individually and as Trustees for the TAYLOR LIVING TRUST; DAVID D. TESSMER, a single man; BRUCE D. THOMPSON and RHODA THOMPSON, husband and wife, and the marital community composed thereof; WILLIAM G. THOMPSON and JUDITH L. THOMPSON, husband and wife, and the marital community composed thereof; MATTHEW W. THOMSON and GRACE THOMSON, husband and wife, and the marital community composed thereof; GERALD F. TICE and JANICE F. TICE, husband and wife, and the marital community composed


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thereof, individually and as Trustees for the GERALD FRANK TICE AND JANICE FYRN TICE FAMILY TRUST; WALTER K. TIMPE and KATHRYN J. TIMPE, husband and wife, and the marital community composed thereof; ROBERT L. TOOLEN and LORRI L. TOOLEN, husband and wife, and the marital community composed thereof, individually and as Trustees for the ROBERT L. TOOLEN FAMILY TRUST; MARY TREMAIN, a single woman; THOMAS H. TRIMBLE, a single man; ROBERT F. TSCHUMPER and PATRICIA L. TSCHUMPER, husband and wife, and the marital community composed thereof, individually and as Trustees for the TSCHUMPER REVOCABLE TRUST; MINORU TSUJI and JOAN TSUJI, husband and wife, and the marital community composed thereof, individually and as Trustees for the MINORU AND JOAN TSUJI FAMILY TRUST; CHARLES H. TURNER, a single man; TURNPAUGH LISA and TIM TURNPAUGH, wife and husband, and the marital community composed thereof; BRENDA G. UTTER, a single woman; PER VAAGA and KATHRYN VAAGA, husband and wife, and the marital community composed thereof; REX C. VALENTINE and KEIKO VALENTINE, husband and wife, and the marital community composed thereof; DIANNE S. VALUCH and THOMAS L. VALUCH, wife and husband, and the marital community composed thereof; FRANCES C. VAN PAEMEL, a single woman, individually and as Trustee of the FRANCES C. VAN PAEMEL TRUST; MYUNG JA KIM VAN PATTEN, a single woman; PAUL E. VANDERSTOEP and KAREN VANDERSTOEP, husband and wife, and the marital community composed thereof; ARIE PIETER VANDERSTROOM and MAGDA JOHANNA VANDERSTROOM, husband and wife, and the marital community composed thereof; NEIL L. VONNAHME and DENISE S. VONNAHME, husband and wife, and the


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marital community composed thereof; ALAN E. VOORHEIS and JANICE VOORHEIS, husband and wife, and the marital community composed thereof; RICHARD L. WADE and SUSAN L. WADE, husband and wife, and the marital community composed thereof; RUSSELL T. WAITE and MARILYN P. WAITE, husband and wife, and the marital community composed thereof; ROXANNE L. WALLACE, a single woman; MARY WALMAR, a single woman; JOSEPH T. WALSH and ELIZABETH C. WALSH, husband and wife, and the marital community composed thereof; SCOTT E. WARREN, a single man; STANLEY D. WARREN and PATRICIA A. WARREN, husband and wife, and the marital community composed thereof; PETER B. WASSERMAN and BARBARA A. WASSERMAN, husband and wife, and the marital community composed thereof; KEITH WATENPAUGH and JOYCE WATENPAUGH, husband and wife, and the marital community composed thereof; JAMES C. WECKER, a single man; SANDRA J. WEDELL, single woman, individually and as Trustee of the WEDELL LIVING TRUST; STEPHEN J. WEHNER and ANDREA K. WEHNER, husband and wife, and the marital community composed thereof; JANICE T. WEINBERG, a single woman; SUSAN C. WHEELER, a single woman; DANIEL J. WHELAN and SUSAN C. SCHUTTE, husband and wife, and the marital community composed thereof; ANN RHODES WHITE and RONALD G. BANICK, wife and husband, and the marital community composed thereof; EVERETT R. WHITE and BETTY WHITE, husband and wife, and the marital community composed thereof; JOSEPH MICHAEL WILDERMAN, a single man, and JACQUELINE K. ROBERTS, a single woman, individually and as Trustee of the JACQUELINE K. ROBERTS FAMILY TRUST; JUDITH L. WILLINGHAM, a single woman; HAROLD R. WILSON and STEPHANIE WILSON, husband and wife, and


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the marital community composed thereof; MARLIN F. WILSON and ALICE E. WILSON, husband and wife, and the marital community composed thereof; NANCY P. WILSON, a single woman; JOSEPH C. WILTON, JR. and PAMELA P. WILTON, husband and wife, and the marital community composed thereof; JOHN E. WOODCOCK and JOANNA G. WOODCOCK, husband and wife, and the marital community composed thereof; BETTY B. WRIGHT and TERRY L. WRIGHT, wife and husband, and the marital community composed thereof; PAUL J. WRIGHT, JR. and NANCY T. WRIGHT, husband and wife, and the marital community composed thereof; ROBERT W. WRIGHT and BARBARA C. WRIGHT, husband and wife, and the marital community composed thereof; FREDERICK YOUMANS and MARY YOUMANS, husband and wife, and the marital community composed thereof; DONALD E. YOUNG and NANCY C. YOUNG, husband and wife, and the marital community composed thereof; ROBERT C. YOUNG and NANCY A. YOUNG, husband and wife, and the marital community composed thereof; SHEILA I. ZAMBROWSKY, a single woman; ELEANOR H. ZANIKER, a single woman; RONALD S. ZIMMERMAN and JUDITH K. ZIMMERMAN, husband and wife, and the marital community composed thereof; NANCY ZYTKOWICZ, a single woman, Plaintiffs, v. SHEA HOMES, INC., a Delaware corporation, Defendant.


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COMPLAINT - i


(206) 623-7292 • FAX (206) 623-0594

TABLE OF CONTENTS

Page

I. INTRODUCTION ...............................................................................................................1

II. PARTIES .............................................................................................................................6

A. Plaintiffs ...................................................................................................................6

B. Defendant Shea Homes, Inc. ....................................................................................6

III. JURISDICTION AND VENUE ..........................................................................................6

IV. FACTS .................................................................................................................................7

A. The Design, Development and Approval of Trilogy at Redmond Ridge ................7

B. The “Shea Way”: the Manufacturing Process Utilized by Shea at Trilogy ..........10

1. Shea Cut Corners on Garage Floors – Shea omitted moisture barriers and capillary breaks on at least 958 Trilogy homes. ....................11

2. Shea Cut Corners on Corbels – Shea Omitted Metal Flashing on Corbels and Knee Braces. .....................................................................22

3. Shea Cut Corners on Columns – Shea Omitted Water Intrusion Elements on Every Column It Built at Trilogy ..........................................27

4. Shea Cut Corners on Windows and Doors – It Omitted the Required Head Flashings ...........................................................................31

5. Shea Cut Corners on Patios – Shea Omitted Flashing at the Patios ..........................................................................................................34

6. Shea Cut Corners on Exterior Walls — Shea Omitted Flashing at the Stone Veneer Wainscoting ...............................................................36

7. Shea Cut Corners on Decks – Shea Omitted the Flashing at the Deck-To-Wall Interfaces ......................................................................38

8. Shea Cut Corners on Drainage – Shea Installed Inadequate Drains and Ventilation in Crawl Spaces ....................................................41

9. Shea Cut Corners on Driveways – Shea Poured Slabs Directly Over Wet Soil and During Heavy Rains ....................................................43

C. Plaintiffs’ Homes at Trilogy Are Defective and Require Extensive Repair .....................................................................................................................45

D. Shea Knows and Has Known for Years that Its Building Practices Are the Cause of the Defects in Homes at Trilogy, Yet it Refuses to Make Required Repairs and Instead Requires Homebuyers to Make Costly Repairs Under its “Homeowner Maintenance” Rubric ..........................................47


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V. EQUITABLE TOLLING OF STATUTES OF LIMITATIONS .......................................49

A. Equitable Estoppel .................................................................................................49

B. Equitable Tolling ...................................................................................................50

VI. CAUSE OF ACTION VIOLATION OF THE WASHINGTON CONSUMER PROTECTION ACT, WASH. REV. CODE § 19.86 .......................................................50

VII. PRAYER FOR RELIEF ....................................................................................................51

DEMAND FOR JURY TRIAL .....................................................................................................52


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I. INTRODUCTION

1. A home is the single most important and largest investment for most Americans.

Homeowners need to know material facts concerning the quality of their home in order to

determine whether they can afford to purchase and to maintain their home. In the Pacific

Northwest, of paramount importance to a reasonable homeowner are facts relating to the care a

builder takes to protect the home from the corrosive effects of our region’s most dominant

weather feature – water.

2. Water and moisture intrusion are the most serious corrosive and degenerative

agents for homes in the Northwest. It is critical that homes here are planned to withstand water

and moisture and are built in accordance with such plans. A builder must take care that the

windows, doors, garages, columns, external architectural features – that all surfaces that are

exposed to groundwater or weather—are constructed to account for such exposure.

3. Code requirements, industry norms in the Northwest, and plans that builders

submit to regulatory agencies to obtain building permits are scrutinized to ensure finished

construction will withstand our wet climate. Home buyers expect, and reasonably rely on the

premise, that a reputable builder will not deviate from code, industry norms, and its own

approved plans when constructing homes for retail sale, especially without notification to buyers

of such deviations from submitted plans, codes, and regulatory requirements.

4. This case arises because defendant Shea Homes, Inc. (“Shea”) chose to build and

sell over 1,500 homes in the Trilogy at Redmond Ridge development (“Trilogy”) that it knew

deviated from its architects’ and contractors’ guidelines, county-approved plans, and

recommendations. Shea intentionally omitted nearly all industry-standard methods for building

homes to withstand our wet weather. And, even after its first homes suffered from various forms

of water intrusion due to the substandard construction, Shea refused to tell its customers of the

problems and continued building new homes with the same defects.

5. To increase its profits, Shea consciously cut out crucial weather-proofing methods

that all responsible Northwest architects and builders include in their homes. Shea ignored

applicable code requirements, industry norms, and its own submitted and approved plans, all of


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which required Shea to build homes with metal flashings and sufficient moisture intrusion

barriers, drainage, soil compaction, and construction elements for the homes to withstand the

Pacific Northwest climate.

6. As detailed below, Shea’s own experts, architects, and subcontractors have

admitted and confirmed that Shea purposefully omitted King County-required water and

moisture intrusion prevention components that were specifically called for in Shea’s approved

building plans. Yet Shea never disclosed its purposeful and repeated deviations from the county-

approved building plans.

7. Despite knowing that its customers wanted – in fact expected – durable, low-

maintenance, trouble-free homes, and despite Shea’s own promise to build high-quality homes,

Shea omitted telling buyers of at least the following deviations from the county-approved

building plans, which have directly resulted in significant water damage, rot, and moisture

intrusion that require expensive repairs:

A. Garage Floors: Shea’s approved plans required it to install pea gravel and

a moisture barrier under every garage slab at Trilogy. Shea’s Geotechnical Engineering Report,

which Shea submitted to the County and was incorporated into its approved plans, required

4 inches of pea gravel and moisture barriers under each slab to keep the underground water from

migrating through the concrete. Instead of following those plans, Shea instructed its builders and

subcontractors to ignore the plans and Geotechnical Engineering Report and pour the garage

slabs directly over the bare, and often wet, dirt at the lot – all to save about $50 per house. Shea

omitted telling buyers that it was deviating from the approved plans in construction of the garage

floors. Lacking the required pea gravel and moisture barrier, moisture from the ground under the

slabs seeps up through the garage floors of homes at Trilogy causing odors, mold, deterioration,

and the inability to use the garages in a normal and expected manner. Shea observed the

moisture problems on some of its very first homes, but kept building with its defective methods

to save a few extra dollars. In some cases, Shea ordered its subcontractors to pour concrete in

the rain and over puddles, knowing the slabs would fail, and knowing it would have to replace

the slabs, all in an effort to close the sale before anyone saw the problem.


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B. Corbels (also known as knee braces): Corbels are architectural design

elements on the exterior of homes that give the appearance of a beam and support passing

through a wall. They are a common element of “craftsman” style homes. At Trilogy, corbels

were designed to be solid wood 4x4 or bigger posts, joined at an angle, and attached to the siding

of the house. Shea’s County-approved plans required corbels to be installed with metal flashing

to prevent water intrusion and to be attached to the sides of houses with ½” thick lag bolts. But

Shea instructed its builders and subcontractors to ignore these requirements, to nail the corbels to

exterior walls with thin framing nails, and not to install metal flashing. Shea omitted telling any

buyers that it was deviating from the approved plans and standard good Northwest building

practices for the installation of corbels. Lacking the required metal flashing and lag-bolt

attachments, the corbels on homes at Trilogy are uniformly rotting and falling from the sides of

houses. At various stages of development, Shea observed the failing (and falling) corbels, yet

continued to build hundreds more houses with the same defects.

C. Columns. Hundreds of Trilogy homes have columns at or near the front

doors. Some columns also support the roof structure. All are exposed to wind and rain. Shea’s

County-approved plans required columns to be built with water intrusion prevention elements

such as metal flashing, treated structural support posts, weep screeds at the base to allow for

moisture drainage, and concrete pedestals to prevent moisture intrusion from the ground up.

Shea omitted telling buyers that instead of following its plans, it built columns without flashing,

without structural supports, without weep screeds, and without any method of preventing

moisture from coming up from the ground into the components of the columns. As with the

other omissions, Shea cut these important components out to save a few extra dollars per house.

Shea also built hundreds of homes long after an internal investigation revealed that its defective

method of building the columns caused them to rot right “from the beginning” of construction.

As a result of Shea’s failure to follow the County-approved plans for columns, the columns are

rotting from the top and the bottom.

D. Windows. Shea’s County-approved plans called for metal head flashings

above all windows in its homes. Contrary to building code and King County requirements, Shea


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deviated from the permitted plans continuously from 2001 to 2008 by omitting the required

metal head flashings above windows. Shea did this without asking for permission from or

informing the King County Building Department. King County Building Department

representative Jane McPherson has testified that eliminating the metal head flashings from the

plans “would never have been approved.” Shea’s retained expert, Randy Hart, has testified in

another case stemming from these same defects that head flashings are industry standard and that

he has not designed a building, or recommended construction of a building, without a head

flashing above a window or door in at least 15 years. Shea omitted informing buyers that despite

its approved plans, it was not installing metal head flashing above the windows in the homes it

was selling. As a result of Shea’s failure to install the metal head flashings above windows as

required in its County-approved plans, water is intruding into the window frames in Trilogy

homes and rotting the trim and surrounding siding.

E. Doors. Just as with the windows, Shea’s County-approved plans required

metal head flashings above its doors. Shea’s own architect testified that window and door head

flashings were critical elements of his design given the wet Northwest weather. Jane McPherson

likewise testified that removing door head flashings would not have been allowed by the County.

Shea omitted telling buyers that despite its approved plans, it was not installing metal head

flashing above the doors in the homes it was selling. As a result of Shea’s failure to install the

metal head flashings above doors as required in its approved plans, water is intruding into the

door frames in Trilogy homes and rotting the trim and surrounding siding.

F. Patios. King County building codes require the installation of L-metal

flashing where wall siding comes in contact with a patio slab. Shea’s own architect advised Shea

not to pour concrete patios against the siding. Despite this advice, Shea poured all of the

concrete at all of its homes directly against the wall siding, and purposefully failed to install the

required flashing. Again, Shea failed to tell its homebuyers that the patios on the houses it sold

were poured without the requisite L-metal flashing. Without the required flashing, water hitting

the siding (rain) runs down against the poured patio and causes the wall siding to rot, which is

what happened at Shea’s model homes, which Shea retroactively fixed with the required L-metal


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flashings. Shea’s expert, Randy Hart, has testified that this defect should be corrected at every

home at Trilogy at which it exists.

G. Stone Veneer Wainscoting. The County-approved and permitted drawings

by Shea’s architects required the installation of an L-metal flashing along the top of the stone

veneer wainscoting and under the Hardiplank or Cemplank wood siding above. Shea

purposefully failed to install the required flashing at all Trilogy homes on which it installed stone

veneer wainscoting, and Shea omitted telling homebuyers that the stone veneer wainscoting on

the houses it sold were installed without the requisite L-metal flashing. Without the required

flashing, water that makes its way behind the Hardiplank or Cemplank siding or that runs down

that siding has no way to escape and causes the wall to rot.

H. Decks. As with patios, deck installations are required to have L-metal

flashing where the decking abuts to the wall siding. Shea’s subcontractors have acknowledged

that they knew L-metal flashing was required, but Shea instructed them not to install it. Shea

omitted telling home buyers that it built the decks without the required L-metal flashing.

Without the required flashing, water running down the exterior wall remains in contact with the

decking causing the siding and decking to rot.

I. Drainage. Shea omitted required drainage components, ran downspouts

straight into the soil rather than connecting them to the required tight-line drain, and failed to

correct the problems despite Shea’s knowledge of standing water in crawlspaces that caused

mold and attracted frogs and vermin, standing water in yards, and resulting damage to homes at

Trilogy. Shea directed its subcontractors to frame over standing water in the crawl spaces, and to

install hardwood flooring while knowing the moisture in the crawl spaces would warp the floor

and breed mold on the framing.

J. Driveways. Shea omitted necessary soil compaction and adherence to

weather and soil limitations in constructing driveways and, as a result, hundreds of driveways at

Trilogy have suffered cracking, spalling, settlement, or other failure.

8. As a result of Shea’s reckless and material disregard of the King County building

codes, its own consultants, its subcontractors, and its architects, and Shea’s failure to disclose


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any of these omissions to its customers, Plaintiffs have suffered substantial damages. They have,

for example, garage floors that need pea gravel and moisture barriers, corbels and columns that

need replacement, and windows, doors, patios, and decks that need flashing and new trim.

Plaintiffs’ damages are the direct result of Shea’s deviation from King County Code, industry

norms, and its own building plans – none of which deviations Shea ever disclosed.

II. PARTIES

A. Plaintiffs

9. Each of the Plaintiffs purchased a home at Trilogy. The address of each

Plaintiff’s home, the model of the home, and the year of construction by Shea are listed in

Exhibit 1. Exhibit 1 also lists, for each Plaintiff, the recently discovered defectively constructed

elements of such Plaintiff’s home.1 The expected repair costs for all defects at each home,

together with stigma damages based on the known problems with construction at Trilogy

resulting from Shea’s omissions, and trebled under the provisions of the Washington Consumer

Protection Act, exceeds $75,000 for each home and thus for each Plaintiff.

B. Defendant Shea Homes, Inc.

10. Defendant Shea Homes, Inc. is a Delaware Corporation. Shea is registered as a

contractor in Washington under License No. SHEAHI*997D1. Shea is the developer and builder

of Trilogy at Redmond Ridge, which is located in King County, Washington.

III. JURISDICTION AND VENUE

11. The events and actions alleged herein took place in King County, Washington.

The homes which are the subject of this suit are located at Trilogy at Redmond Ridge, which is

in King County. At all relevant times, Shea has been doing business in King County,

Washington, and continues to do so to this day.

12. The United States District Court for the Western District of Washington has

jurisdiction over this matter pursuant to 28 U.S.C § 1332(a). Plaintiffs are residents of

Washington, and Shea is a resident of Delaware and California. After trebling under the

1 Where more than one Plaintiff has owned a single home (i.e., the home has been sold at least once since it was

sold by Shea), all Plaintiffs who have owned such home are listed as owners. See Exhibit 1.


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Washington Consumer Protection Act, alleged herein, each Plaintiff’s damages will exceed

$75,000 exclusive of interests and costs.

IV. FACTS

13. Shea is a national company in the business of building and selling new homes and

developing master-planned communities. Trilogy is one of at least 11 “resort communities” that

Shea has developed.

14. Shea has developed and built housing developments across the United States,2

but, prior to building Trilogy, Shea had never built a development farther north than the 39th

parallel (Denver). Trilogy, in contrast, is above the 47th parallel and thus over 550 miles farther

north than any prior Shea development.3 Moreover, all of Shea’s listed developments prior to

Trilogy are in arid, if not desert locales. Building practices that worked adequately in Shea’s

other developments would provide no baseline of effectiveness in the comparatively very wet

Pacific Northwest.

15. Trilogy is a planned adult (age 55 and over) community of 1,522 single-family

“production” homes within 12 divisions. Division Four is a commercial area and Division Seven

is a community center.

16. Trilogy consists of residential homes built in 23 different models, based on square

footage and design, each with two or three “elevation” options. Some of the homes are zero lot

line homes, and they share a party wall with an adjacent Trilogy home.

A. The Design, Development and Approval of Trilogy at Redmond Ridge

17. Shea retained Mithun Architects, a Seattle-based firm, to serve as lead architect

on the Trilogy project. The partner in charge at Mithun, Bill Kreager, was and is one of the

country’s leading architects for residential communities, and he has particular knowledge of the

primary concerns of the over-55 demographic in purchasing a home. One primary concern for

2 Shea’s website, www.sheahomes.com, lists developments in the Phoenix area of Arizona; throughout

California from the Bay Area southward; the Denver area of Colorado; central Florida; Las Vegas, Nevada; Charlotte and Greensborough, North Carolina; Houston, Texas; northern Virginia; and the Seattle Area (Trilogy).

3 Each degree of latitude is approximately 69 miles distant from the next.


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those over 55 is a low-maintenance home, which Shea knew from conducting focus groups in the

Redmond area before commencing construction.

18. Even prior to beginning the design of the homes at Trilogy, Mr. Kreager visited

Shea projects in Arizona to observe Shea’s methods and style of construction. Upon viewing

those Shea communities in the Southwest, Mr. Kreager warned Shea that its Arizona

construction methods, which depended on dry weather – including stucco and slab-on-grade

construction – were not suitable for home construction in the much wetter Pacific Northwest.

19. Mithun Architects reviewed climate records for Trilogy before designing a single

model. It learned that the Redmond Ridge area has a particularly wet climate – indeed, it

receives 40 inches or more of rain each year on average, as compared with 32 inches in Seattle,

and just 8.2 inches in Phoenix.4

20. Because of the wet climate in the Pacific Northwest and particularly wet climate

at Redmond Ridge, and its knowledge that Trilogy homebuyers’ (55+ in age) would desire low-

maintenance homes, Mithun Architects designed homes that included metal flashing on all

protruding wood such as at windows and doors and on corbels and columns.

21. The flashing details in the building plans were extensive and numerous, and they

were included in every model of home that Mithun Architects designed for Shea to build at

Trilogy.

22. The diagram below is an excerpt for Model 6220, the “Hemlock,” which is the

most common design built at Trilogy. At least 240 of the Plaintiffs in this action own Hemlock

model homes. These approved plans show Mithun Architects’ intent, and the County’s approval

requiring, that flashing be installed on the protruding wood features.

4 See http://www.currentresults.com/Weather/Arizona/yearly-average-precipitation.php.


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23. Mithun Architects’ drawings incorporated a soils report prepared by Associated

Earth Sciences, Inc. (“AESI”), the geotechnical engineering firm retained to investigate the

hydrology and geology at the Trilogy building site. AESI concluded that the site was suitable for

construction provided its building recommendations were followed.

24. AESI’s recommendations included the installation of a capillary break (pea

gravel) and a moisture barrier (visqueen) under the concrete garage slabs to be poured at Trilogy.

25. Shea submitted its building plans for Trilogy, including the Mithun Architects’

drawings incorporating metal flashing and the AESI report incorporating the capillary break and

moisture barrier, to the King County Building Services Division in the Department of Permitting

and Environmental Review (“DPER”) under the “Basics” program.

26. The Basics program was set up for larger, more experienced builders who were

going to build the same floor plan multiple times. Basics program plans are reviewed with

heightened scrutiny by the Building Services Division because if anything is missed, it could be

repeated in each home the builder constructs based on that County-approved plan.

27. The Building Services Division expects that a builder in the Basics program

knows how to build homes in accordance with applicable building code and local industry


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standards. The Building Services Division reviewed Shea’s plans independent of the site plan

and, once approved, stored the approved plans in its library and cataloged them.

28. For each home building site, a builder in the Basics program could come into the

Division with the site plan indicating which plan approved in the Basics program it would use for

that specific home site, as well as any additional information that the builder needed to provide

to accommodate the site conditions. In this manner, the Basics program sped up the permit

process and Shea used it exclusively in building the 1,522 homes at Trilogy.

29. Once King County had issued the site building permit, Shea was obligated to

build exactly according to the approved plans. If Shea wanted to make site-specific revisions,

the Basics program had a revision process by which Shea could seek revisions for a specific

permit. Absent an error in the approved Basic plan, site-specific revisions to plans in the Basics

library were rare.

30. If a Basics program builder wanted a revision, it had to submit new plans to the

Basic program and get a new plan approval from the County, i.e., start the process all over again.

31. As relevant to the facts of this case, for example, Shea’s elimination of the metal

head flashings that Mithun Architects had specified for every plan at Trilogy was a design

revision that required it to submit new plans. But as Jane McPherson from the Building Services

Division has testified in a related case, King County would never have approved such a revision.

32. Indeed, Shea submitted numerous supplemental design sheets during the 12 years

of active building at Trilogy to address code-required updates to the plans, but Shea never

altered or eliminated from the County-approved drawings the architect’s details requiring metal

flashings on the homes Shea was building at Trilogy. All the while, Shea was building the

homes without these same required flashings.

B. The “Shea Way”: the Manufacturing Process Utilized by Shea at Trilogy

33. Shea let it be known to Building Services Division personnel that the level of

scrutiny that King County required was not what Shea was used to and not how things were done

in the Southwest, where Shea had built its prior projects.


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34. Shea challenged virtually every requirement in an effort to reduce its building

costs at Trilogy. It “value engineered” its houses so that, for example, Shea built with the exact

minimum number of nails. It created a climate during construction at Trilogy that encouraged

and often required subcontractors to cut corners wherever possible.

35. Shea’s corner cutting at Trilogy became so renowned that its subcontractors, who

Shea dubbed “TradePartners,” coined the phrase “the Shea Way” to describe Shea’s relentless

focus on the bottom line, including minimizing construction costs and maximizing the speed at

which Trilogy homes were built.

36. During the course of construction, Shea repeatedly demanded unilateral and

immediate price reductions from its TradePartners – by as much as 13% – under threat that if the

TradePartner did not cut its price for doing the same scope of work, Shea would put the work

back out to bid.

1. Shea Cut Corners on Garage Floors – Shea omitted moisture barriers and capillary breaks on at least 958 Trilogy homes.

37. Shea began cost cutting at Trilogy right at the bottom with its first homes: Shea

ordered its concrete subcontractors to pour driveways and garage slabs over uncompacted and wet

ground without draining the site as the plans required. It omitted the gravel and moisture barrier

that its geotechnical engineer required Shea to install under the garage slabs.

38. In late 2000 or early 2001, Shea Homes contacted a concrete contractor, Artistic

Concrete Design, Inc. (“Artistic”) to bid the Trilogy project. Shea’s project manager, Alexander

(“Zander”) Hawxhurst, contacted Artistic’s president, Raymond Harvie, for a pre-construction

meeting to do a job walk and discuss the project. At that meeting, Hawxhurst provided

approximately 16 full sets of building plans (drawings) to Artistic. He asked Mr. Harvie to bid each

plan set for turn-key installation of all concrete hardscapes which included: garage floors, patios,

sidewalks, entry, and driveways. Shea required that each concrete subcontractor’s bid include costs

for all labor, materials, pumps, tools, and equipment to complete the work. Artistic’s original

estimate for the Trilogy project was based on the plans Shea provided and included labor, concrete,

any necessary concrete pumps, rebar, moisture barrier, and other materials. Artistic did not provide


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any lot excavations or slab base preparation (i.e., import or export of structural base, or removal of

spoils). These services were provided by different Shea subcontractors.

39. After Mr. Harvie submitted Artistic’s bid for the Trilogy at Redmond Ridge project,

Hawxhurst told Mr. Harvie to remove from his bid the line items for rebar and moisture barrier.

This surprised Mr. Harvie, considering that Artistic had quoted a price of just 15 cents a square foot

to install the moisture barrier the plans required.

40. Shea’s decision to remove the moisture barrier from the scope of work for the garage

slabs caused Mr. Harvie great concern. At a follow-up meeting with Hawxurst, Mr. Harvie told

Hawxhurst that moisture barriers were industry standard here in the Northwest due to the amount of

rain, the proclivity of hydrostatic water intrusion, and the underground springs so common in this

area. Hawxurst told Harvie that Shea was not required to install a moisture barrier or rebar under the

garage slabs at Trilogy, and therefore, it wouldn’t do so, regardless of the local conditions.

41. Mr. Harvie warned Hawxhurst, Ken VanWestrienen, and other Shea representatives

about the risks of using Shea’s standard Arizona construction practices (i.e., slab over bare dirt

foundations and footings, stem wall foundations, no moisture barrier) here in the Pacific Northwest.

Mr. Harvie recommended to the Shea group that it listen to the local builders and re-think Shea’s

building practices to avoid almost certain long term failures. Despite the advice, Shea stuck to the

Shea Way, cutting corners (and costs) wherever possible.

42. As Hawxhurst directed him, Artistic removed all rebar and moisture barrier pricing

from its bid package, and Artistic ultimately poured Trilogy garage slabs directly onto bare soil per

Shea’s instructions. Shea instructed other concrete subcontractors to bid their work the same way.

43. As Mr. Harvie predicted, hundreds of the Shea Way garage slabs have failed.

Lacking the moisture and capillary breaks, the garages suffer from standing water, chemical

deposits (“efflorescence”), ugly stains, or all three of these conditions. The photographs below

are Trilogy garages that show the result of pouring the slabs without the required moisture

barriers or capillary breaks underneath:


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44. Even at houses where Shea attempted to conceal the problem by installing plastic

tiles on top of the wet garage floor before selling the home, evidence of the problem is now

apparent as efflorescence makes its way up through the joints in the plastic tiles:

45. Homebuyer surveys completed in 2002 at Shea’s request, and recently obtained

from Shea’s files, demonstrate that Shea knew of the water problems caused by the Shea Way of

construction at the beginning of the Trilogy building cycle. Pursuing cost savings over quality,

Shea continued to pour concrete over bare, wet dirt, and ignored its consultant’s requirements to

keep the garages dry. Shea simply ignored the County-approved plans.

46. The following examples, from three different surveys of early Trilogy

homebuyers in 2002, show Shea was clearly on notice that its construction was inadequate:


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“Since living in the home for six weeks, I have found troubling quantities of water underneath the house. This appears to be due to improper and misdirected drainage set-up.”

“Drainage grades were very poor on lots. Severe problems with water in crawlspace.”

“Customer service is still trying to fix loose flooring and wet crawl space. We have been given several reasons for the wet crawl space. Had to pay for an expert to evaluate water drainage problem and have had to remind Shea that the work needs to be done.”

47. The added emphasis immediately above has proved, over the years, to be an

important and consistent part of Shea’s strategy in responding to Trilogy homebuyers and

prospective homebuyers who called out the water issues in homes at Trilogy. Shea concocted a

string of false explanations as to why its homes were exhibiting atypical problems for new

homes, particularly given that they were built and marketed as high-quality and low-

maintenance. Shea would, for example, tell homeowners that water coming up through the

garage floor was “typical” of the Northwest, or that efflorescence was a consequence of concrete

“curing.” Shea also developed internal “scripts” for its personnel to use with homeowners to

explain away these various defects and resulting problems, all while failing to disclose that it

knew exactly what the real source of the problem was: the Shea Way.

48. One of the first Trilogy buyers who noticed water in their crawlspace and a wet

garage floor contacted a drainage contractor, Bodine Construction, to assess the drainage at their

new Trilogy home. Bodine found extensive problems with the drainage and prepared reports

documenting the issues. In January 2003, Shea contacted Bodine:


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49. Steve Bodine met with the Shea team. He also forwarded them a basic article on

drainage for their edification:


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50. Shea ultimately hired Bodine to perform drainage inspections on over 100 homes

at Trilogy in 2003. Bodine found numerous problems and provided Shea with written reports

complete with color photographs. Bodine determined that even the clubhouse at Trilogy

required over $40,000 in drainage remediation work well after it was completed. Bodine’s

inspections revealed several inches of standing water in crawlspaces, a lack of pea gravel, and

other defects, including in a home that Shea currently had on the market.

51. Shea never disclosed any of these conditions to prospective Trilogy buyers, and

never told any prospective buyers or owners at Trilogy that, despite the known, wet conditions


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on Redmond Ridge both above and below ground, it had directed its concrete subcontractors to

omit the engineer-required pea gravel and moisture barrier from their scope of work in pouring

the garage slabs.

52. To the contrary, Shea promised that its foundations systems were “engineered for

local soil types to ensure greater structural integrity,” and that it took extra steps to ensure proper

drainage:

53. Early in 2003, as Shea’s recently disclosed internal files revealed, Shea customer

service personnel – who were either unaware of Shea’s omission of the moisture barrier and pea

gravel under the garage slabs or were directed by their superiors to search for an excuse – began

researching the possible cause of water intrusion and efflorescence on the garage floors at

Trilogy. They obtained a concrete industry article that indicated the likely source: lack of

moisture barrier and capillary break.

54. Rather than reveal the problem to homebuyers or change its construction practices

(adding perhaps $50 to the cost of each home for the plastic and gravel), Shea began concocting

false explanations. In early 2005, Shea wrote to multiple homeowners:


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55. Instead of coming clean and admitting the true source the problem, Shea blamed

the wet garage floors on a change in the temperature:

56. Shea had not actually obtained or read the referenced article, but instead copied

the reference from a Yahoo search result for “wet garage floors,” which was intended in answer

to a question about wet garage floors after a drop in temperature in Louisiana:


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57. A short time after Shea provided that inaccurate explanation to Trilogy

homeowners, Shea representative Ella Montgomery contacted its Arizona concrete contractor,

Jim Bebout, regarding the garage floor problem at Trilogy. Mr. Bebout’s response was

straightforward:

58. Mr. Bebout went on to describe the only two methods of dealing with the

problem, and both methods require removal of the garage slab. He also wrote:

59. Nevertheless, more than a year later, Shea was still building garage slabs without

the required moisture barrier and capillary break (even though it had already been forced to

replace a few slabs and install these omitted construction elements). And, as a recently obtained

internal Shea document demonstrates, Shea was even considering using a sealer despite its own

Arizona concrete subcontractor having advised against it:

60. Without justification, Shea refused to repair or replace its defective garage slabs.

Instead, Shea used a widely discredited calcium chloride test for water transmission through the

slab, but told homeowners: (1) that the test could only be performed in the dry months; (2) that


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the test results could not be shared with the homeowner; and (3) that the test result was just “one

of several factors” that Shea considered in deciding whether a particular garage slab should be

replaced. All the while, Shea was building homes on sites so wet that—even in summer months

like August—they contained deep standing water as in the photograph below.

61. Finally, on October 3, 2006, Shea began installing moisture barriers under garage

slabs on the homes it was building at Trilogy. But by that time, Shea had built 958 Trilogy

homes without the required moisture barrier or drain rock. To date, Shea has replaced 101

garage slabs, installing moisture barriers before re-pouring those slabs. But 871 defectively

constructed and installed garage slabs remain at Trilogy. Each homeowner was subject to the

same omission by Shea, namely it omitted to tell them that the garage slabs were not constructed

and installed according to the County-approved plans and soils report. And each homeowner has

suffered the same result: water and efflorescence percolate through their garage slab.

62. At least 388 of the Plaintiffs in this action have garage slabs defectively


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constructed without drain rock and moisture barriers.

2. Shea Cut Corners on Corbels – Shea Omitted Metal Flashing on Corbels and Knee Braces.

63. Certain models of Trilogy homes, including at least 70 of Plaintiffs’ homes, have

knee braces and/or corbels. A knee brace extends off the house with a horizontal, 6”x6” timber

supported by a vertical member flush against the house and an angled member creating a

triangle. A corbel or outlooker is the horizontal member by itself. (Sometimes the terms

“corbel” and “knee brace,” are used interchangeably.) Both corbels and knee braces can be seen

in this photograph of a Trilogy home:

64. In the photo, there is a knee brace in the foreground and another at the peak of the

roof below the fascia. There are several corbels that run across the top of the garage. Although

corbels and outlookers may look good from ground level to unsuspecting Trilogy home buyers

and owners, Shea omitted the required metal flashing from atop knee braces and corbels at

Trilogy from 2002 to 2012. As a result, regardless of how well a homeowner maintains their

home, the corbels and knee braces rot.


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65. The four photographs below are from one Trilogy home shortly before and during

the removal and replacement of the knee braces and corbels:

66. Trilogy home buyers Bill and Diane Fehr had to replace the corbel shown in the

photo below and numerous others at their Trilogy home after Shea had “repaired” them once

already, and despite the Fehrs’ regular maintenance of their home’s exterior:


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67. An internal Shea document recently obtained shows that in August 2009, Shea

calculated its “Exposure by Plan” for each of the home plans (models) at Trilogy based on its

omission of the flashing from the corbels and knee braces. Shea calculated that the cost of

replacing those components on the 671 homes that it had built by that time was in excess of $1.4

million.


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68. Despite having to replace rotted corbels on its model homes, and intentionally

omitting the structurally required ½” lag bolts, Shea continued to build homes with unflashed

corbels and knee braces until 2012, and all the while Shea told homeowners that their rotting

corbels were due to a lack of adequate “homeowner maintenance.” On the model homes that

Shea repaired and then sold to unsuspecting buyers, Shea asserted in an internal document that

the rotting corbels would be attributed to “homeowner maintenance” after the sale. As with all

its omissions, Shea never disclosed to any buyer the deviations from approved plans.

69. Rotted corbels and knee braces have fallen off of several Trilogy homes. Shea

even secretly replaced one such fallen corbel, using a work crew that Shea specifically instructed


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not to wear the Shea-standard, blaze orange work shirts. Shea was so intent on hiding its need to

repair the failing corbels that it took great pains to deceive the Trilogy homeowners so they

wouldn’t learn that the failing corbels were not a “homeowner maintenance” issue but rather

were a problem of Shea’s own making.

70. As Shea discovered more and more rotting corbels between 2009 and 2011, it

looked for ways to limit its potential $1.44 million “exposure.” Shea settled a pending class

action lawsuit involving only failing and moldy paint, known as the “Gaines Litigation” or

“MOTH (Mold on the Houses) Litigation.” It then claimed that it had intended to include all

possible construction defect claims within that limited settlement. After settling the paint case,

Shea personnel circulated an internal email dated October 24, 2011 which, after studying the

plan to contend it had settled all possible defect claims, concluded that the Gaines settlement

could not be interpreted so as to include the rotting corbels and columns.

71. Nevertheless, Shea personnel – including Area Vice President Richard

Obernessor, in June 2012 – advised Trilogy homeowners after the October 24, 2011 email that

any claims regarding rotted corbels were barred by the prior class action settlement. Indeed,

Trilogy homeowners Bob and Gwen Blough received that explanation from Patti Conrad of Shea

in a letter dated May 31, 2012:


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72. And Shea made the same, false assertion in a subsequent legal action, Blough, et

al. v. Shea Homes, Inc., both in arbitration in December 2012 and in its failed Motion to Dismiss

filed in that action in July 2013.

3. Shea Cut Corners on Columns – Shea Omitted Water Intrusion Elements on Every Column It Built at Trilogy

73. The architect’s plans required flashings on the tops of columns to prevent water

entry, and weep screeds at the bottom to allow any water that entered the column to escape.

These elements are essential to prevent rot. Omitting either component will lead to water

damage. Nonetheless, consistent with the Shea Way of doing business, Shea omitted flashing on

most columns and omitted the weep screed on every column at Trilogy.

74. After seeing many of the columns fail and repairing its own model homes, in

2007 Shea quietly investigated the cause of the failing columns on numerous homes at Trilogy.

It inspected homes without informing the homeowners so as not to arouse concern. Shea

concluded that “water is penetrating the cavity of the column in several ways. This has [caused]

and is currently causing damage to the different building materials used in the construction of the

column.” The report’s author also wrote, “I noticed that the footing or base of each column sits

below the flatwork of the home. This is a major concern that will cause water to penetrate from

the bottom up. The column base should be set above flatwork just as porch columns are done in

a typical installation practice.”

75. The report noted that the columns had been rotting from the inside out, that this

process likely began “soon after installation of the building materials,” and that “all materials

will eventually erode and challenge these areas as time moves forward.” The author questioned

whether the information should be shared with Trilogy owners. Not surprisingly, Shea kept the

report and its findings a secret.

76. In 2009, an internal Shea email by Shea’s area vice president acknowledged “a

struggle on the columns from the outset” of the project. And in 2011, an internal Shea email

acknowledged that columns were not built to plan and noted, “It states clearly on the plans that


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the plan is for the architectural design and that flashing and weatherproofing are the

responsibility of the contractor.”

77. Despite this clear knowledge, Shea advised Trilogy homeowners that the column

failures were a “homeowner maintenance” issue. Here is an example of just one Trilogy

homeowner’s problems with her columns, in spite of the fact that she regularly and properly

caulked and painted per Shea’s recommendation:

78. A close-up of the column shows it was well-painted and caulked:


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79. The well-maintained caulk and paint hid the ugly truth that only Shea knew:


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80. The column was built without a weep screed, and there is no concrete supporting the

framing. As a result, the entire column, like every other column at Trilogy, must now be

replaced.

81. The same condition can be found upon opening columns throughout Trilogy,

including at many other Trilogy homes such as this one:


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82. As with corbels and knee braces, Shea replaced failed columns on its own model

homes before selling them, but it never revealed this problem to its customers. Instead, corporate

policy required its customer service representatives to tell the future owners, and all other

Trilogy homeowners, that the water problems were attributable to “homeowner maintenance.”

83. Shea never disclosed its knowledge that columns throughout Trilogy were rotting

from the inside because of the corners Shea cut in construction. Shea chose to continue building

the inherently defective columns, knowing the problems would not reveal themselves until after

the one-year warranty period ended. At that point, Shea could and did blame the problems on

“homeowner maintenance” without ever revealing that it had omitted key construction

components and that it knew the columns had been rotting from the date they were built.

4. Shea Cut Corners on Windows and Doors – It Omitted the Required Head Flashings

84. The architect’s plans for Trilogy approved by the County included several details

requiring a head flashing above all windows and doors such as the one shown above in

Paragraph 25 from the Hemlock plans. The architect had contemplated flashings on all windows

and exposed trim from very early on, including in a letter to Shea dated May 22, 2001 which

included, among recommended specifications:

85. Shea’s own, subsequent specifications for the project dated October 8, 2001

likewise called for these flashing details to be followed:

86. And the window manufacturer, Milgard, also provided Shea with installation

standards that include a head flashing, but Shea rejected it, as evidenced by a document obtained

from Shea’s internal files:


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87. To save a few bucks per house, however, and rather than build the homes at

Trilogy as required by: (1) the architect; (2) the County; (3) the building code; (4) the window

manufacturer; and (5) even its own specifications, Shea simply omitted the 26-gauge metal

flashing and eliminated the 2x4 trim above the windows during the first seven years of

construction at Trilogy and into 2008 – by which time Shea had sold the large majority of homes

and reaped the profits from its deceptive practices.

88. Shea’s siding contractors, just like Shea’s concrete contractor, urged Shea to

follow the plans and install the necessary flashings. As with the other advice it received, Shea

ignored it and instructed its siding contractor to run the horizontal lap siding right up to the

windows and doors and then slap cheap 1x4 white wood on top of the siding as “trim.” As a

result, water makes its way behind the trim causing rot damage to the trim and siding from the

inside that is hidden from the unsuspecting Trilogy homeowner.

89. Only several years later, when the rot has made its way to the exterior of the trim,

does a homeowner learn the consequence of Shea’s omission of the head flashings. Here is a

window on one Trilogy home, and you can see that water has made its way behind the trim and

is coming out the bottom:


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90. This water intrusion leads to unseen rot, such as on this Trilogy home:

Trim showing decay and fungal growth Backside of removed trim


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91. The same condition reveals itself around unflashed doors, all as a result of Shea’s

omission of head flashing:

Rot discovered under paint Close-up of rot at door trim

92. Shea’s own expert has acknowledged under oath that Shea omitted head flashing

above doors throughout the project.

5. Shea Cut Corners on Patios – Shea Omitted Flashing at the Patios

93. At every home at Trilogy, Shea omitted the flashing at the patio-to-wall interface,

and instead Shea poured concrete directly against wood siding. This was in violation of the

building code, industry standards, and the architect’s recommendations.

94. In 2002, the architect provided a Shea-requested detail but specifically noted that

Shea’s plan to pour the patios against the wood rather than the foundation was not recommended:


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95. Shea’s subcontractors likewise urged Shea not to pour concrete patios against the

wood and to install an L-metal flashing. But Shea omitted the flashing. The patios poured at

Trilogy “pull” the house down when settling, such as what occurred at this Trilogy home:

96. And Shea’s failure to install an L-metal flashing also means that water makes its

way down between the patios and the wood, which leads to damage such as at this Trilogy home:

97. As with corbels, knee braces, and columns, Shea replaced damaged wood due to

missing patio-to-wall flashing on one of its own model homes before selling it.


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6. Shea Cut Corners on Exterior Walls — Shea Omitted Flashing at the Stone Veneer Wainscoting

98. Shea omitted flashing where the stone wainscoting meets the wood trim above.

99. The photograph below depicts an example of the stone veneer wainscoting on one

home at Trilogy:

100. The architect’s drawings approved by King County required the installation of a

flashing at the wainscoting:


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101. Shea failed to install the required flashing on 851 Trilogy homes. And Shea

failed to acknowledge its omission even when homeowners such as this one raised concerns:

102. The lack of flashing above the wainscoting prevents water from draining away

from the wall, allowing water to remain against the wood behind the impermeable wainscoting

materials and causing rot behind and above the wainscoting. The photo below is of a Trilogy

home with rot – including visible mushrooms growing – atop the unflashed wainscoting:


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7. Shea Cut Corners on Decks – Shea Omitted the Flashing at the Deck-To-Wall Interfaces

103. The approved plans for Trilogy required a water resistant membrane to be

installed where the decks meet the house. This requirement was in the original drawings for

Trilogy and all modified versions:

104. A similar detail was included in the permitted drawings for individual decks built

by Shea at Trilogy after original construction, such as this detail from Lot 1165 at Trilogy which

clearly shows that flashing is required:


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105. Shea built the decks at Trilogy directly against the siding and/or wood trim, like at

the Trilogy home shown here:

106. If installed, the flashing allows water to escape from behind the siding onto the

deck while also preventing water from making its way down into the deck-to-wall joint, where it


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can cause rot. That z-flashing is required if the deck is not built at least two inches below the

siding, as required by the building code, the siding manufacturer, and standard good building

practice:

107. When homeowners inquired about the missing flashing, Shea misrepresented its

obligation to install such flashing. For example, one new Trilogy homeowner wrote to Shea in

2012 expressing several concerns with her deck, including the missing flashing:

I noticed there is no mention of the flashing that is missing where the deck is attached to the house. The bolts are just screwed right into the siding on the house. Flashing is definitely needed. I assume you will also be fixing this so I don’t have any eventual water damage from the rain water getting in behind and under the siding.

108. Patti Conrad of Shea responded to her with this inaccurate statement:

109. As a result of Shea’s omission of the required flashing at the deck-to-wall

interface, water damages Trilogy homes at that interface. The photograph below shows an

example of the rot damage that results and that can go unseen for years under the exterior paint:


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8. Shea Cut Corners on Drainage – Shea Installed Inadequate Drains and Ventilation in Crawl Spaces

110. As noted above, Shea had extensive knowledge very early on in its construction

of Trilogy that its home sites had inadequate drainage, that homes suffered standing water in the

crawlspaces and yards, and that as a result of the moisture many homes suffered hardwood floor

damage including cupping, warping, and separation. Shea agreed to replace numerous hardwood

floors at Trilogy (while denying the existence of a problem or any liability to other Trilogy

homeowners), and when in 2006 Shea tried to blame its flooring supplier, Superfloors, Shea got

a swift rebuke from Superfloors explaining the problem again, as it had previously: moisture.

111. Shea ignored the advice and did nothing to address the moisture problems. It

should have been no surprise to Shea when, a year later, Superfloors submitted an independent


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inspector’s report to Shea regarding another Trilogy home with moisture problems and failing

floors. The inspector’s conclusions were the same:

112. Shea still concealed and refused to acknowledge that it had caused the problems

by refusing to spend the money necessary to install the proper drainage at Trilogy. Shea

continued this ruse for years, including two years later when, in 2009, Shea made an insurance

claim to recover the costs of replacing that very floor due to the moisture damage. Shea

represented to its insurer that the floor was damaged during other repair work:

113. Shea made numerous other insurance claims and recovered money for hardwood

floors Shea replaced due to excessive moisture, while at the same time Shea was telling other

homeowners that it was not responsible for their floor problems.

114. Shea installed crawlspace fans in various homes but concealed the real reason for

having done so. Shea even prepared a script (“external conversations”) for customer service

representatives (“CSRs”) to use in explaining the crawlspace fans to homeowners, with a

separate, explanatory section (“internal information”) for the CSRs’ eyes only that has

contradictory information and demonstrates that Shea’s representations to owners were

intentionally deceptive.


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115. Shea has continued its unfair and deceptive practice regarding its omitted

drainage and damage right through to 2014, professing to have no knowledge of ongoing

drainage problems at Trilogy. Patti Conrad, a Shea CSR, wrote to Plaintiff Jim Green in 2014,

concocting a slew of false reasons for the problems with moisture and hardwood floor failures at

Trilogy homes. Wrote Ms. Conrad:

As a builder, Shea Homes cannot control over what has occurred over the many years the home has been occupied, specific to weather conditions, additional hardscaping in the back of the home, augmented landscaping and the natural movement and evolution of the protected wetland directly behind this home.

116. By the time Ms. Conrad of Shea wrote this in April 2014, Shea had known for 12

years that its defective drainage saturated the ground under and around the Trilogy homes. The

virtual ponds below the hardwood floors were breeding grounds for mold and damaged the

floors, such as occurred at the Greene home and many other plaintiffs’ homes.

9. Shea Cut Corners on Driveways – Shea Poured Slabs Directly Over Wet Soil and During Heavy Rains

117. Shea poured driveways at Trilogy on uncompacted, wet soil, and as a result

driveways are failing in multiple divisions throughout Trilogy. Shea knew that its methods of

construction were causing driveways to fail as far back as 2003, as indicated by a homeowner’s

email to Al Seaton of Shea:

118. Just as it refused to compact the soil below the garage slabs and drain the crawl

spaces before building, Shea refused to alter its faulty construction practice. As a result, the

aggregate on the driveways spalls, as it has here at the home of Plaintiff Joan Myers:


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119. The failing, spalling driveways built by Shea lead to pooling water and further

failure. Failed aggregate pours into gardens, curb gutters, and storm water outfalls.

120. Shea replaced only a select few failed driveways, even making insurance claims

to recover the monies it spent correcting its own defective work:


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121. True to the Shea Way, Shea continued to tell homeowners, including Plaintiff

Joan Myers and others, that the driveways were within industry standards, while at the same time

Shea customer service personnel mocked Trilogy homeowners, in internal emails, for their

“driveway envy.”

C. Plaintiffs’ Homes at Trilogy Are Defective and Require Extensive Repair

122. Every one of the more than 1,000 homes inspected prior to the filing of this

lawsuit, including all of Plaintiffs’ homes, has at least one of the defects described above. Most

homes, including hundreds of Plaintiffs’ homes, have many or all of the defects, and as moisture

and water continue to penetrate the construction at Trilogy, additional defects are currently being

exposed.

123. As set forth for each Plaintiff in Exhibit 1, each Plaintiff’s cost of repair and

stigma damages to their property value is expected to exceed $25,000. Treble damages as

allowed under the Washington Consumer Protection Act, RCW Ch. 19.86, bring each plaintiff’s

total damages to in excess of $75,000, exclusive of interest and costs.

124. Shea has admitted that for all 958 Trilogy homes at which the garage slab was

poured prior to October 3, 2006, Shea failed to install those garage slabs in the manner required

by its geotechnical engineer; namely, Shea omitted the moisture barrier and capillary break that


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was to be installed prior to pouring the slab. Some homes have multiple garage slabs, including

a main garage and a second, smaller “hog pen.” Beginning sometime after October 3, 2006,

Shea replaced at least one garage slab at 101 different Trilogy homes.

125. There are 871 homes at Trilogy, including 388 of Plaintiffs’ homes, that have

defective garage slabs insofar as they were constructed without the required moisture barrier and

capillary break. Fourteen of the 101 houses where Shea has replaced one but not both slabs, will

require replacement of the remaining slab.

126. In 2009, Shea prepared an analysis of its “Exposure by Plan” for each of the

models at Trilogy that included knee braces or corbels. According to Shea’s own internal

analysis the total cost of replacing those components on the homes built to date exceeded $1.4

million. Shea did not replace those components, however, but instead continued building homes

at Trilogy through and including 2011 without flashing the knee braces or corbels. 597 homes at

Trilogy were built with defective corbels and knee braces, including Plaintiffs’ homes as set

forth in Exhibit 1.

127. Shea’s 2007 investigation of columns and one of its own experts concluded that

the footing or base of each column at Trilogy sits below the concrete flatwork of the home, and

that this is a major concern that will cause water to penetrate from the bottom up. Every home at

Trilogy with columns suffers from this defective manner of column construction. There are 687

homes at Trilogy that have defective columns that require repair, including Plaintiffs’ homes as

set forth in Exhibit 1.

128. On all of 1,275 of the homes that Shea built at Trilogy before May 1, 2008, Shea

omitted the required head flashings above every window. When Shea finally began installing the

required head flashings, it did so sporadically so that of the remaining 207 homes built after May

1, 2008, at least 75 additional homes lack required window head flashings. There are at least

1,350 homes at Trilogy that have defectively installed windows that require repair, including

Plaintiffs’ homes as set forth in Exhibit 1.

129. Shea’s own expert admitted under oath in a related lawsuit that none of the

architect-specified and county-required metal head flashing is installed above the doors at


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Trilogy. There are 1,522 homes at Trilogy that have defectively installed doors that require

repair, including Plaintiffs’ homes as set forth in Exhibit 1.

130. For every Trilogy home with stone veneer wainscoting, Shea omitted the required

metal flashing. There are 851 homes at Trilogy that have defectively installed stone wainscoting

that require repair, including Plaintiffs’ homes as set forth in Exhibit 1.

131. Shea’s own expert has admitted that concrete should not have been poured against

white wood as it was at Trilogy homes. All 1,522 homes at Trilogy have defectively installed

concrete patios, including Plaintiffs’ homes as set forth in Exhibit 1.

132. Shea failed to install the required flashing at the deck-to-wall interface of every

home at Trilogy with a deck, and those decks all require repair, including on the homes of all

Plaintiffs.

133. Shea failed to install the required drainage at many Plaintiffs’ homes, and as a

result these Plaintiffs have incurred or will incur thousands of dollars in drainage repairs, mold

remediation, and/or hardwood floor replacement.

134. Shea failed to properly compact the ground or pour the driveways at dozens of

Plaintiffs’ homes, and as a result these Plaintiffs have incurred or will incur thousands of dollars

in driveway repairs and/or replacement.

D. Shea Knows and Has Known for Years that Its Building Practices Are the Cause of the Defects in Homes at Trilogy, Yet it Refuses to Make Required Repairs and Instead Requires Homebuyers to Make Costly Repairs Under its “Homeowner Maintenance” Rubric

135. Recently obtained, internal Shea emails and statements by Shea personnel are

shocking in their brazenness, including even outright mocking of homeowners for having

“column envy” or “garage envy” when, for example, Shea replaces one homeowners’ defective

component while giving a litany of baseless explanations to another homeowner as to why the

identical defect on her home is simply a “homeowner maintenance” problem.


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136. Shea customer service personnel responsible for responding to homeowner

complaints about problems with their homes even joked internally in emails that the numerous,

concealed defects on Trilogy homes guaranteed them:

137. Carolyn Young, Shea’s Customer Service Manager, recently explained

homeowner “envy” under oath:

138. For example, Ms. Young inspected the Nicholsons’ home and discovered that the

column, which supported a roof structure, in addition to being severely saturated with water, was

“missing the 4 x 4 structural support.” Ms. Young’s concern was not the structural integrity of

the home, but rather the neighbor’s “column envy”:

139. For years prior to Ms. Young writing this email in 2011, Shea already knew of the

widespread water intrusion issues occurring at Trilogy. In 2007, Shea commissioned an internal

report on columns:

140. Although Shea has represented to one court that these are “minor problems,” its

own internal analyses recently obtained clearly demonstrate that Shea has known from the outset,


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but has never disclosed to buyers or owners at Trilogy, that these are serious and systemic

problems directly and solely attributable to Shea’s omissions.

141. These omissions were material in every respect. The Shea Way – of cutting

corners to cut costs, of misleading and deceiving elderly home buyers while internally mocking

them, and of flouting its own geotechnical engineer, its architects, the County, and its

subcontractors’ strong urgings throughout Shea’s construction, marketing, and sale of the homes

at Trilogy – was unanticipated and unknowable by every buyer at Trilogy.

V. EQUITABLE TOLLING OF STATUTES OF LIMITATIONS

142. Plaintiffs’ claims are subject to both equitable estoppel, stemming from Shea’s

knowingly and fraudulently concealing the facts alleged herein, and equitable tolling, stemming

from Plaintiffs’ inability to obtain vital information underlying their claims. Shea is estopped

from relying upon a statute of limitations defense because Shea purposefully concealed its

knowledge of the above-described defects, and Shea purposely concealed its failure to seek

approval from the King County Building Department for its modifications to, and omissions

from, the approved building plans. Separate and apart from Shea’s acts of concealment, any

applicable statutes of limitations are properly tolled because Plaintiffs did not know and could

not have learned the true facts underlying their claims until this year.

A. Equitable Estoppel

143. Shea is estopped by its own fraudulent concealment from asserting the statute of

limitations as an affirmative defense against Plaintiffs’ claims. Throughout the construction and

sales of homes at Trilogy, Shea repeatedly asserted that its homes were built in accordance with

the approved plans and its high quality standards. Continuing throughout its construction at

Trilogy and through to the present, Shea has asserted that it built all homes in accordance with

the building codes and industry standards.

144. Plaintiffs reasonably relied on Shea’s representations.

145. Shea had actual or constructive knowledge that it violated the local building codes

by removing key building components from the permitted plans without approval from the King


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County Building Department. Shea’s conduct was deceptive, in that it consciously concealed its

knowing and material omissions.

146. The purposes of the statutes of limitations period are satisfied because Shea

cannot claim prejudice due to a late filing where Plaintiffs filed this lawsuit promptly upon

discovering the facts essential to their claims, described herein, which Shea knowingly

concealed.

B. Equitable Tolling

147. Plaintiffs were unable to obtain vital information bearing on their claims absent

any fault or lack of diligence on their part. As further set forth below, Plaintiffs were not on

inquiry notice of Shea’s wrongdoing and had no duty to initiate any investigation. Plaintiffs did

not have any reason to know of Shea’s knowing omissions of key building components.

148. Plaintiffs were relieved of any duty to investigate because they reasonably and

justifiably relied on Shea’s representations that it constructed their homes in accordance with the

building plans and building code.

149. Plaintiffs did not discover and could not have discovered, despite all due

diligence, that: (1) Shea unlawfully altered permitted plans; (2) Shea knowingly omitted key

building components; and, (3) Shea knew that its homes were damaged or would suffer damage

as a result of these omissions.

150. Plaintiffs’ claims were thus equitably tolled until they discovered the true facts

underlying their claims shortly before filing this Complaint.

VI. CAUSE OF ACTION

VIOLATION OF THE WASHINGTON CONSUMER PROTECTION ACT, WASH. REV. CODE § 19.86

151. Plaintiffs re-allege and incorporate by reference the allegations contained in the

preceding paragraphs.

152. Plaintiffs are persons within the meaning and coverage of the Washington

Consumer Protection Act, RCW 19.86 (the “CPA”).


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153. The CPA prohibits “[u]nfair methods of competition and unfair or deceptive acts

or practices in the conduct of commerce ….” RCW 19.86.020.

154. Shea marketed to the public and sold to Plaintiffs and others homes that it built at

Trilogy at Redmond Ridge.

155. Shea unfairly and deceptively omitted to tell home purchasers that in constructing

homes at Trilogy it deviated from: (1) County code requirements; (2) from the recommendations

of its architects and engineers; and (3) from its own submitted and approved plans by: (a) failing

to install necessary and required water and moisture intrusion elements such as flashing,

capillary breaks, vapor barriers, and adequate drainage; and (b) failing to construct driveways

and common concrete fixtures with industry standard and required methods to prevent erosion,

collapse, and other exposure-related failures.

156. Shea’s conduct, as detailed above, constitutes unfair and deceptive acts and

practices in violation of the CPA.

157. Shea’s acts occurred in the conduct of trade or commerce.

158. Shea’s deceptive acts or practices impact the public interest and have the capacity

to deceive a substantial portion of the public. The acts are committed in the course of Shea’s

business; the acts are part of a pattern or generalized course of business; the acts were committed

repeatedly prior to the acts involving Plaintiffs and since; and there is a real and substantial

potential for repetition of Shea’s conduct.

159. Shea’s unfair and deceptive acts and practices have directly and proximately

caused damage to Plaintiffs. But for Shea’s unfair and deceptive acts and practices, Plaintiffs

would not have suffered an injury. The defects directly flowing from Shea’s deceptive acts and

practices for each Plaintiff’s home are set forth in the attached Exhibit 1.

VII. PRAYER FOR RELIEF

160. Plaintiffs pray for relief as follows:

A. For judgment for Plaintiffs on their claims in an amount to be proven at trial, for

compensatory damages caused by Defendants’ unfair or deceptive practices, along with

exemplary damages to each Plaintiff for each violation;


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B. For pre-judgment and post-judgment interest as provided for by law or allowed in

equity;

C. For an order awarding Plaintiffs their attorneys’ fees and costs; and

D. For such other and further relief as may appear necessary and appropriate.

DEMAND FOR JURY TRIAL

Pursuant to Federal Rule of Civil Procedure 38(b), Plaintiffs demand a trial by jury on all

issues so triable.

DATED: October 10, 2014. Respectfully submitted,

By: s/ Steve W. Berman Steve W. Berman, WSBA #12536

By: s/ Thomas E. Loeser Thomas E. Loeser, WSBA #38701 HAGENS BERMAN SOBOL SHAPIRO LLP 1918 Eighth Avenue, Suite 3300 Seattle, WA 98101 Telephone: (206) 623-7292 Facsimile: (206) 623-0594 [email protected] [email protected] By: s/ David von Beck

David von Beck, WSBA No. 26166 [email protected] By: s/ Katie J. Comstock Katie J. Comstock, WSBA No. 40637 [email protected] By: s/ Sanford R. Levy Sanford R. Levy, WSBA No. 11101 [email protected] By: s/ Seth E. Chastain Seth E. Chastain, WSBA No. 43006 [email protected] LEVY VON BECK & ASSOCIATES, P.S. 600 University Street, Ste. 3300 Seattle, WA 98101 Telephone: (206) 626-5444 Facsimile: (206) 382-5527 Attorneys for Plaintiffs


Exhibit 1

Case 2:14-cv-01566 Document 1-1 Filed 10/10/14 Page 1 of 7

AAMODT ET Al. v. SHEA HOMES

TABLE OF PLAINTIFFS

Owner

Shea Plan

Number Address Model Style

Date

Permited

Total

Windows

Unflashed

Total

Doors

Unflashed

Total

Corbels Not

Flashed By

Shea

Defective

Columns

Defective

Garage

Slab

Lineal Feet of

Defective

Wainscott

Unflashed

Patio/DeckAAMODT DAVID B+PATRICIA A 3320 13711 MORGAN DR NE Union A 10/10/2006 21 2 3 ‐ ‐ YesABRAMS SCOTT F+GLORIA E 6220 12527 230th PL NE Hemlock C 7/3/2003 27 3 29 2 Yes 27 YesADLER DAVID+MARCIA 4091 22856 NE 130th ST Vancouver B 12/2/2004 20 2 9 ‐ Yes 41 YesAHERN PATRICIA A 4091 23339 NE 126th ST Vancouver B 9/17/2003 unk* unk 9 ‐ Yes YesAHOLT RAYMOND E+MARY BETH 6220 23009 NE 127th WAY Hemlock C 5/11/2004 25 3 29 2 Yes ‐ YesALEXANDER ALAN F+PATRICIA J 4060 23223 NE 123rd ST Whidbey A 11/5/2002 20 2 ‐ 2 Yes ‐ YesALLMAN MICHAEL J+PATRICIA A 6510 12612 237th WAY NE Monticello B 3/25/2003 21 3 7 2 Yes 12 YesAMUNDSON BIRGIT A SURVIVORS TRUST 4050 13232 230th Pl NE Vashon A 2/12/2004 20 2 1 3 Yes ‐ YesANDERSON CAMILLE J 3310 13465 ADAIR CREEK WAY NE Chelan Craftsman 1/17/2006 12 2 ‐ 2 Yes ‐ YesARGYLE LYNN 3320 13440 238th PL NE Union A 8/8/2006 26 2 3 ‐ 28 YesASELIN DONALD G+SHARON L 2050 11802 BIG LEAF WAY NE Madison C 1/6/2005 40 2 11 2 Yes ‐ YesAUGUST VIRGINIA S REVOCABLE LIVING TRUST 2030 22847 NE 132nd PL Discovery A 7/20/2004 16 2 ‐ ‐ Yes YesBACKLUND WILLIAM M+BACKLUND PATRICIA A 6250 23736 NE 116th PL Alder Prairie 2/28/2002 47 2 ‐ 4 Yes 29 YesBAIL KEVIN D+HEATH KARLA J 3340 13766 MORGAN DR NE Washington A 10/24/2006 22 2 2 1 ‐ YesBAKER BETH E 6220 12431 231st AVE NE Hemlock B 7/22/2003 38 1 ‐ 2 Yes 30 YesBAKER, BEBE + SKIP 2040 23652 NE 135th WAY Orchard B 12/27/2006 13 2 ‐ 2 YesBALDWIN JUANITA LOUISE 2040 12445 232nd WAY NE Orchard C 2/25/2003 10 1 13 2 Yes ‐ YesBALLISTY M SHARON 3310 13804 231st LN NE Chelan American Traditional 8/15/2006 10 2 ‐ ‐ ‐ YesBANNER PATRICIA D 3310 13744 231st LN NE Chelan American Traditional 7/25/2006 12 2 ‐ ‐ YesBARATTO MARGIE Y 2030 24317 NE VINE MAPLE WAY Discovery B 9/1/2005 unk unk ‐ 2 Yes YesBARDELEBEN DAMON L+NANCY 6220 23712 NE 127th ST Hemlock C 7/8/2008 17 ‐ 29 2 20 YesBARGMANN BERT L+GAYLE E 6220 13219 ADAIR CREEK WAY NE Hemlock C 1/30/2007 30 1 29 2 28 YesBARILETTI ROBERT P+NANCY J 3320 23721 NE 134th PL Union A 9/26/2006 26 2 3 ‐ 35 YesBARKER STEVE R+RUTH L 4091 24542 NE VINE MAPLE WAY Vancouver A 6/7/2005 21 2 5 ‐ Yes 42 YesBARTON DOROTHY FULLER 2040 12437 240th PL NE Orchard C 6/10/2010 1 1 13 2 ‐ YesBATJER JOHN DANNER+DEBORAH DWYER BATJER 6540 12521 237th WAY NE Maryhill B 2/26/2003 46 3 12 ‐ Yes ‐ Yes

BAUER MICHAEL + CAROLYN 6240 24124 NE 131st TER Cedar Prairie 10/9/2007 30 3 ‐ 4 53 Yes

BECKER DAVID WILLIAM 4060 12502 230th PL NE Whidbey A 12/31/2002 unk unk ‐ 2 Yes Yes

BECKFORD JEAN+SOLIS FORTUNATO 3340 22888 NE 130th ST Washington A 4/27/2004 25 2 2 1 Yes ‐ Yes

BELL ROBERT+CATHERINE 2050 12498 240th PL NE Madison B 9/2/2008 20 2 ‐ 1 8 Yes

BELOVSKY BARRY+CLAIRE ‐2004 FAMILY TRUST 6510 23649 NE TWINBERRY WAY Monticello C 12/23/2010 ‐ 1 ‐ 2 44 Yes

BERNS GARLAND L+JUDITH D 6240 23146 NE DEVON WAY Cedar Craftsman 2/27/2007 20 1 15 4 16 Yes

BERNSTEIN BARBARA 4060 13035 243rd PL NE Whidbey C 12/23/2009 ‐ 1 3 2 ‐ Yes

BERRY CRAIG L+SIRI 6510 23817 NE GREENS CROSSING RD Monticello B 5/27/2010 3 1 7 2 24 Yes

BERRY RICHARD W+KATHRYN I 6220 13859 231st LN NE Hemlock C 10/24/2006 26 2 29 2 30 Yes

BESSADA NASSER 6250 12528 232nd TER NE Alder French Traditional 7/3/2003 26 4 ‐ ‐ Yes Yes

BEST G PAUL+DIANNE L 6520 12762 240th PL NE Oakwood C 5/3/2012 6 1 ‐ ‐ 50 Yes

BESTE ADRIENNE A 3310 23147 NE 128th PL Chelan Craftsman 4/21/2004 14 4 ‐ 2 Yes Yes

BICKERSTAFF JOHN + ALICIA 2020 13291 228th PL NE Townsend B 3/9/2004 16 3 ‐ 1 Yes Yes

BJORKMAN GAIL F 2020 13242 SUNBREAK WAY NE Townsend B 1/20/2004 16 2 ‐ 1 Yes 42 Yes

BLACK ALAN+KATHERINE 2020 13213 239th WAY NE Townsend A 1/22/2008 1 1 ‐ ‐ ‐ Yes

BLACK RONALD V+STELLA J 2050 24588 NE 118th PL Madison B 5/12/2005 unk unk ‐ 1 Yes Yes

BLACK, Margaret 6240 23758 NE GREENS CROSSING RD Cedar Craftsman 3/13/2003 16 2 15 4 Yes 16 Yes

BLUHM RONALD W+SUSAN C 4081 11739 238th PL NE Bainbridge Cottage 6/4/2002 22 2 ‐ ‐ Yes 13 Yes

BOBREK CAROL A+YOUNG C DARLENE+FLYNN KATHRYN Y+JAMES H 3310 24589 NE 118th PL Chelan American Traditional 7/26/2005 11 2 ‐ ‐ Yes 12 Yes

BOLL MOLLY M 4081 12534 230th PL NE Bainbridge Craftsman 9/2/2003 17 2 ‐ ‐ Yes 16 Yes

BORDEN RANDALL T+DEETTE D 4091 13019 243rd PL NE Vancouver C 12/11/2007 5 ‐ 5 ‐ ‐ Yes

BORDENET JOHN P+CECILIA J 6220 12561 237th WAY NE Hemlock B 2/26/2003 43 3 ‐ 2 Yes 24 Yes

BORICHEWSKI LINDA L+JOSEPH 2030 24307 NE VINE MAPLE WAY Discovery A 9/1/2005 16 2 ‐ ‐ Yes ‐ Yes

BOVEE DONNA J 4050 12373 BIG LEAF WAY NE Vashon A 12/13/2005 18 2 1 3 Yes ‐ Yes

BOYLE JAMES R+GRETCHANN E 6220 23727 NE 134th PL Hemlock B 8/29/2006 46 2 ‐ 2 29 Yes

BOYLE JOHN L SR+BARBARA E 6220 12223 243rd PL NE Hemlock A 8/23/2005 25 2 ‐ 2 Yes 16 Yes

BRACK JAY E and JUDITH 6510 13025 SUNBREAK WAY NE Monticello B 3/3/2005 17 2 7 2 Yes 11 Yes

BRADFORD WILLIAM C+SUNDAE 4060 23018 NE 128th PL Whidbey B 6/8/2004 unk unk 12 2 Yes Yes

BRADLEY JOHN F+FRANCES M 6510 12310 232nd TER NE Monticello C 12/31/2002 23 2 ‐ 2 Yes 65 Yes

BRADY LESLIE RAY JR+NANCY C 6230 23132 NE 123rd ST Maple A 1/10/2002 27 1 ‐ 1 Yes ‐ Yes

BRANDT JANET R 6250 23734 NE GREENS CROSSING RD Alder French Traditional 10/15/2002 unk unk ‐ ‐ Yes Yes

BRAUNSTEIN ROBERT J+SUSAN 3330 13840 231st LN NE Sammamish A 11/7/2006 unk unk 2 2 Yes

BRILL WINSTON J+NANCY 6220 12529 237th WAY NE Hemlock B 11/26/2002 48 2 ‐ 2 Yes ‐ Yes

BRODER LAWRENCE N+SUSAN J ‐REV TRUST 6220 13316 ADAIR CREEK WAY NE Hemlock C 6/19/2007 29 2 29 2 ‐ Yes

BRONSON THERESA A 2030 11660 239th AVE NE Discovery C 5/2/2002 13 2 13 2 Yes ‐ Yes

BROOK MELVIN+JENNIFER 6220 22840 NE 130th ST Hemlock B 5/11/2004 47 2 ‐ 2 Yes 25 Yes

BROOKS DAVID W+JEANNIE 4081 24175 NE 122nd ST Bainbridge Craftsman 10/28/2005 19 2 ‐ ‐ Yes 15 Yes

BROWN ALVIN+DEBORAH R 2040 24151 NE 122nd ST Orchard B 10/19/2005 unk unk ‐ 2 Yes Yes

BROWN DAVID P+M DELORES 4091 24525 NE 118th PL Vancouver C 6/2/2005 16 2 5 ‐ Yes ‐ Yes

BROWN DIANE M 6220 23728 NE 116th PL Hemlock C 3/12/2002 25 2 29 2 Yes 22 Yes

BROWN MCDONALD G+ROSEMARY P+BROWN LIVING TRUST 4091 22911 NE 132nd St Vancouver A 8/3/2004 18 2 5 ‐ Yes 43 Yes

BROZ JAMES A+JANICE W 4091 22926 NE 132nd St Vancouver B 10/19/2004 20 2 9 ‐ Yes 25 Yes

BRUCH WILLIAM T+MARY P 6220 23772 NE 134th ST Hemlock A 2/20/2007 29 1 ‐ 2 ‐ Yes

BRUNEAU DAVID H+CHRYSTINA 6220 23912 NE GREENS CROSSING RD Hemlock C 5/31/2012 3 ‐ 1 2 20 Yes

BRUNO MICHAEL+JUDITH 6220 12554 232nd WAY NE Hemlock C 1/7/2003 30 2 29 2 Yes 25 Yes

BUCHMAN KATHY 6540 23170 NE DEVON WAY Maryhill B 3/6/2007 49 3 12 ‐ ‐ Yes

BULLIMAN DAVID S AND KIEL TED 6510 23823 NE 124th TER Monticello B 7/12/2005 23 2 7 2 Yes ‐ Yes

BURCH LYNN A 2020 12421 232nd WAY NE Townsend A 2/26/2003 13 2 ‐ ‐ Yes ‐ Yes

BURNELL MARGARET D 4060 11646 238th PL NE Whidbey B 7/16/2002 22 2 12 2 Yes 17 Yes

BURNET GORDON+SALLY 4050 23133 NE DEVON WAY Vashon A 8/22/2006 20 3 1 3 25 Yes

BURNS LARRY LEE+JUDITH ANN 2040 13247 239th WAY NE Orchard B 5/22/2008 4 1 ‐ 2 ‐ Yes

BURRELL, SHANNON 3340 23820 NE GREENS CROSSING RD Washington A 6/28/2013 unk unk 2 1 Yes

BURROWS BARBARA L+USHKA MICHAEL J 2050 12469 232nd WAY NE Madison A 2/18/2003 37 2 ‐ 2 Yes 34 Yes

BUS JINNIE C 6220 12415 235th PL NE Hemlock B 9/3/2002 41 2 ‐ 2 Yes 24 Yes

BUSS JAMES R+MARIAN F ‐LIVING TRUST 4091 23530 NE 122nd CT Vancouver C 5/14/2002 20 2 5 ‐ Yes ‐ Yes

BUTLER JEREMY+KAREN 6540 24103 NE 122nd ST Maryhill A 4/26/2005 45 2 3 ‐ Yes 73 Yes

BUTLER RONALD 3320 12114 BIG LEAF WAY NE Union A 2/8/2005 unk unk 3 ‐ Yes Yes

BYE A R+BARBARA 4050 13322 MAHONIA PL NE Vashon B 4/12/2007 17 3 ‐ ‐ ‐ Yes

CALEY C BEN 4060 23119 NE 127th WAY Whidbey C 1/12/2004 unk unk 3 2 Yes Yes

CALHOUN JOHN S+JAMIE L 6250 12550 237th WAY NE Alder Craftsman 3/13/2003 30 3 22 3 Yes 42 Yes

CAMPBELL ELLANORA L 2030 22921 NE 132nd PL Discovery C 1/20/2004 16 2 13 2 Yes 20 Yes

CAMPBELL ELLEN 2040 22859 NE 128th PL Orchard C 9/28/2004 10 2 13 2 Yes ‐ Yes

CAMPBELL JOHN D+KAREN L 2030 23614 NE TWINBERRY WAY Discovery A 1/24/2007 13 2 ‐ ‐ ‐ Yes

CAMPBELL JOHN D+KAREN L 6220 12402 ADAIR CREEK WAY NE Hemlock A 4/29/2010 ‐ ‐ ‐ 2 15 Yes

CARROLL MICHAEL P+PATRICIA S 4081 12724 ADAIR CREEK WAY NE Bainbridge Cottage 8/6/2009 1 ‐ ‐ ‐ 19 Yes

CARTER FRANK A II+JOSEPHINE ANNE 6250 12423 235th PL NE Alder Craftsman 10/15/2002 26 1 22 3 Yes 20 Yes

CERRA GAIL 6220 13944 MORGAN DR NE Hemlock B 7/11/2006 47 3 ‐ 2 ‐ Yes

CHAMBERS WAYNE V+SHARON J 4060 12524 231st AVE NE Whidbey B 3/12/2003 14 7 12 2 Yes 20 Yes

CHAN PHILLIP 4060 13443 MAHONIA PL NE Whidbey C 4/3/2007 unk unk 3 2 Yes

CHANG AGNES Y 2030 13225 SUNBREAK WAY NE Discovery A 3/30/2004 unk unk ‐ ‐ Yes Yes

CHANG CHUN+MYEONG 4081 23913 NE GREENS CROSSING RD Bainbridge Prairie 12/2/2010 ‐ 1 ‐ ‐ 25 Yes

CHIVERS SANDRA B 6230 12041 BIG LEAF WAY NE Maple A 3/22/2005 27 2 ‐ 1 Yes ‐ Yes

CHRISTIAN DAVID M+MARLENE K 4060 13115 234th CT NE Whidbey C 11/18/2003 23 2 3 2 Yes ‐ Yes

CHUN REVOCABLE S H ‐REV LVG TRUST 6220 13134 234th CT NE Hemlock B 10/23/2003 49 3 ‐ 2 Yes 36 Yes

CHURCH CAROL JEAN 4081 23769 NE 134th ST Bainbridge Prairie 2/27/2007 unk unk ‐ ‐ Yes

CLARK J DALE+JANET LEA 6220 12341 235th PL NE Hemlock B 8/15/2002 49 2 ‐ 2 Yes ‐ Yes

CLASSEN KURT + KATIE 4084 23841 NE GREENS CROSSING RD Nice Prairie 5/25/2012 ‐ ‐ ‐ 1 46 Yes

CLEMETSON JAMES C+SHARON 4060 11747 238th PL NE Whidbey C 6/13/2002 19 4 3 2 Yes ‐ Yes

CLEVENGER SPENCER + CELIA 4091 12427 232nd TER NE Vancouver C 7/3/2003 unk unk 5 ‐ Yes Yes

COADY PHILIP P+ELIZABETH A LIVING TRUST 6230 13568 ADAIR CREEK WAY NE Maple C 7/18/2006 24 2 24 2 51 Yes

COLEMAN ROGER L+SOLWEIG B 6220 13886 MORGAN DR NE Hemlock C 1/16/2007 29 2 29 2 32 Yes

COLLINS JAY+PAMELA 3340 12604 ADAIR CREEK WAY NE Washington A 1/14/2010 ‐ 1 2 1 ‐ Yes

CONNELLY JOHN+EVELYN ‐FAMILY TRUST 4081 12421 240th PL NE Bainbridge Prairie 10/21/2010 ‐ ‐ ‐ ‐ 56 Yes

CONSGROVE THOMAS S JR+PEGGY W 4091 12438 231st AVE NE Vancouver C unknown 20 2 5 ‐ Yes Yes

COOK KAREN MCBRIDE 3320 24191 NE 131st TER Union A 6/5/2007 26 3 3 ‐ 30 Yes

COOK MIKE AND LEE ANN 2040 12328 232nd WAY NE Orchard B 9/9/2003 9 6 ‐ 2 Yes Yes

COPERNOLL JOHN G 3340 24239 NE 130th PL Washington A 6/27/2007 unk unk 2 1 Yes

CORREA DAVID C+VERNALEE W 6240 23761 NE 116th PL Cedar American Traditional 7/30/2002 unk unk ‐ ‐ Yes Yes

*Fields marked unknown or "unk" are presently unknown but will be determine upon completion of Plaintiffs

home inspections and provided to Defendant no later than initial disclosures. Page 1 of 6



TABLE OF PLAINTIFFS

Owner

Shea Plan


Date

Permited

Total

Windows

Unflashed

Total

Doors

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Total

Corbels Not

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Defective

Columns

Defective

Garage

Slab

Lineal Feet of

Defective

Wainscott

Unflashed

Patio/DeckCORRIGAN ELEANOR 3310 13404 238th PL NE Chelan Craftsman 4/3/2007 unk unk ‐ 2 Yes

COTTINGHAM GWEN and DALE STIRN 6230 12604 237th WAY NE Maple C 3/25/2003 22 3 24 2 Yes 31 Yes

COURTNEY ERLENE+COURTNEY RANDY+HARUKA KOJIMA 2040 11630 239th AVE NE Orchard B 3/26/2002 11 1 ‐ 2 Yes ‐ Yes

CRIST AGNES S+PER‐ERIK MANSSON 4060 12415 231st AVE NE Whidbey A 6/17/2003 20 3 ‐ 2 Yes ‐ Yes

CROCKER JEAN K (TRUST) 4081 11816 242nd PL NE Bainbridge Prairie 12/13/2005 19 2 ‐ ‐ Yes 19 Yes

CROSIER DORIS M 3320 13708 231st LN NE Union B 4/18/2006 21 2 ‐ ‐ Yes ‐ Yes

CROWLEY INDY + CHERYL 4091 12563 232nd WAY NE Vancouver A 3/12/2003 20 2 5 ‐ Yes 35 Yes

CUSHMAN LYNN S+JULIE P 6540 23829 NE ADAIR RD Maryhill B 6/28/2005 47 4 12 ‐ Yes ‐ Yes

CUSHNIE JAY R+LOIS J ‐FAMILY TRUST 4060 23804 NE 127th ST Whidbey C 9/21/2012 3 1 3 2 ‐ Yes

CVETOVICH DIANE L 6220 23030 NE 130th ST Hemlock B 3/23/2004 45 2 ‐ 2 Yes ‐ Yes

CZAJKOWSKI CARL A+HELENA J 4060 22858 NE 127th WAY Whidbey C 4/19/2005 23 2 3 2 Yes ‐ Yes

CZECH JANA 3320 12711 ADAIR CREEK WAY NE Union B 3/25/2008 ‐ 2 ‐ ‐ 12 Yes

DAHLBERG CAROL 6240 11814 BIG LEAF WAY NE Cedar Prairie 1/11/2005 30 2 ‐ 4 Yes 36 Yes

DALGARN JAMES L and IRENE 4091 11832 242nd PL NE Vancouver A 10/4/2005 16 2 5 ‐ Yes 42 Yes

DAVIDSON PATRICK E+WYATT LINETTE 6220 24534 NE VINE MAPLE WAY Hemlock B 6/21/2005 41 3 ‐ 2 Yes 30 Yes

DAVIS SHARON D 4060 22919 NE 132nd St Whidbey C 7/29/2004 20 3 3 2 Yes ‐ Yes

DAVIS THOMAS W+TERESA C 2030 12451 243rd TER NE Discovery C 10/28/2010 7 ‐ 13 2 20 Yes

DAWSON HENK I+ELKE 6240 11723 238th PL NE Cedar American Traditional 2/12/2002 23 3 ‐ ‐ Yes ‐ Yes

DEEGAN ROGER L+DEEGAN SANDRA J 6510 12412 232nd TER NE Monticello B 7/8/2003 19 6 7 2 Yes 12 Yes

DEFRANCES CHARLOTTE 2030 13275 228th PL NE Discovery B 3/3/2004 16 3 ‐ 2 Yes 10 Yes

DEINES DAVID 3340 13790 MORGAN DR NE Washington A 11/21/2006 unk unk 2 1 Yes

DENNEMARCK LYNDA 2040 23730 NE SALAL PL Orchard C 7/6/2006 10 3 13 2 ‐ Yes

DESCAMP EDWIN J+JEANNE E 6240 12303 ADAIR CREEK WAY NE Cedar Prairie 2/14/2006 32 1 ‐ 4 Yes ‐ Yes

DILL RICHARD E+KATHLEEN J 6230 12719 ADAIR CREEK WAY NE Maple C 2/26/2008 unk unk 24 2 Yes

DILLON THOMAS P+BEVERLY A 2030 13245 230th Pl NE Discovery C 12/9/2003 13 2 13 2 Yes ‐ Yes

DIXON ROBERT EDWIN+EDITH L 4081 12424 230th PL NE Bainbridge Craftsman 3/25/2003 21 3 ‐ ‐ Yes 13 Yes

DOBLAR RANDY A+DEBRA M 4091 12430 243rd PL NE Vancouver C 10/6/2007 7 1 5 ‐ 28 Yes

DOE ALAN R+NORMA F 6230 12627 237th WAY NE Maple A 6/21/2012 7 1 ‐ 1 ‐ Yes

DOMAN BEVERLY 3320 13778 MORGAN DR NE Union B 10/31/2006 20 2 ‐ ‐ 10 Yes

DONAHEY THOMAS J+LINDA J 4060 24188 NE 131st TER Whidbey C 9/18/2007 7 2 3 2 ‐ Yes

DOOLITTLE TURRELL S 2040 13305 ADAIR CREEK WAY NE Orchard C 1/9/2007 13 2 13 2 ‐ Yes

DORAN DANIEL F+JANETTE F AND GREENE SKIP + LINDA 6220 23216 NE 126th ST Hemlock C 5/29/2003 23 3 29 2 Yes 28 Yes

DOW JUDY 6230 11619 239th AVE NE Maple C 4/23/2002 unk unk 24 2 Yes Yes

DOWNS WILLIAM L+MYRNA L LIVING TRUST 2050 11664 239th AVE NE Madison A 3/12/2002 40 2 ‐ 2 Yes 45 Yes

DRAJPUCH BENJAMIN Z+JACALYN 6220 13165 ADAIR CREEK WAY NE Hemlock C 8/16/2007 27 2 29 2 25 Yes

DRZEWIECKI THOMAS+ANGELA 4091 24020 NE ADAIR RD Vancouver B 10/28/2005 20 2 9 ‐ Yes 36 Yes

DUCHI ROBERT A+JANICE C 2050 23530 NE TWINBERRY WAY Madison C 8/1/2006 42 3 11 2 ‐ Yes

DUKE BEVERLY J 4050 23902 NE ADAIR RD Vashon A 9/27/2005 18 2 1 3 Yes ‐ Yes

DUKE TRUST THE 2030 24159 NE 122nd ST Discovery C 10/4/2005 16 3 13 2 Yes 20 Yes

DULEBA GEORGE S 4050 11637 238th PL NE Vashon C 2/28/2002 20 2 9 ‐ Yes 17 Yes

DUNN GARY A 6220 23634 NE 135th WAY Hemlock A 4/11/2006 30 2 ‐ 2 Yes ‐ Yes

EBBESEN EBBE B+JOANNE T 6220 24187 NE 122nd ST Hemlock C 12/20/2005 28 3 29 2 Yes 17 Yes

EDGERTON JERRY L+DARLENE G 4081 22866 NE 127th WAY Bainbridge Prairie 3/8/2005 19 2 ‐ ‐ Yes 27 Yes

EDGMAND MICHAEL R+JUDITH J 4081 22866 NE 132nd PL Bainbridge Prairie 3/24/2004 18 3 ‐ ‐ Yes 24 Yes

EDWINS LEILA 2030 23724 NE SALAL PL Discovery C 7/6/2006 13 2 13 2 ‐ Yes

EGGE ELLEN L 3320 24256 NE VINE MAPLE WAY Union A 12/20/2005 25 3 3 ‐ Yes 18 Yes

ELDER DAVID+MURIEL 6220 23646 NE 135th WAY Hemlock C 4/4/2006 unk unk 29 2 Yes Yes

ELLISON MARCIA J 2030 23558 NE 122nd CT Discovery B 6/11/2002 17 2 ‐ 2 Yes 41 Yes

EMCH JAMES R 6220 23014 NE 130th ST Hemlock C 4/22/2004 27 2 29 2 Yes 20 Yes

ESSIG THOMAS H + JUDITH 6250 12256 243rd PL NE Alder Craftsman 8/2/2005 32 3 22 3 Yes 35 Yes

ESTBY STEVE+DENISE 2030 24235 NE VINE MAPLE WAY Discovery C 8/23/2005 17 2 13 2 Yes 20 Yes

EVANS SANDRA + WAYNE 6510 11834 BIG LEAF WAY NE Monticello B 6/28/2005 20 4 7 2 Yes 12 Yes

FARRELL MASON G JR+LINDA H 3320 12034 BIG LEAF WAY NE Union A 2/22/2005 26 2 3 ‐ Yes 34 Yes

FERGUSON ROBERT + SHIRLEY 6540 23167 NE 127th WAY Maryhill A 1/8/2004 46 7 3 ‐ Yes 102 Yes

FEROGLIA CAROLYN J AND BICK CHERYL 2030 23617 NE 135th WAY Discovery C 1/24/2006 13 2 13 2 Yes ‐ Yes

FERRER ELEANOR J 2040 23922 NE ADAIR RD Orchard C 8/9/2005 12 3 13 2 Yes ‐ Yes

FISCHER JAMES J+JUDITH A 6220 24140 NE 131st TER Hemlock B 9/19/2007 27 2 ‐ 2 Yes

FLAJOLE KENNETH+COLLEEN A 6530 22864 NE 138th CT Redford A 5/9/2006 29 4 15 ‐ Yes ‐ Yes

FLYNN JOYCE D 3320 22873 NE 130th ST Union B 12/16/2004 21 2 ‐ ‐ Yes 15 Yes

FORD GEORGE+SNELL NANCY 3340 12300 BIG LEAF WAY NE Washington B 9/6/2005 23 2 ‐ ‐ Yes ‐ Yes

FORD HUGH JOHN+JOYCE D 2040 12336 232nd WAY NE Orchard A 10/29/2002 9 1 ‐ 2 Yes 67 Yes

FORREST DAVID F+JANET M 2030 22843 NE 128th PL Discovery C 11/16/2004 13 2 13 2 Yes ‐ Yes

FORREY JEFFREY A+FORREY JEANNE 6240 12409 230th PL NE Cedar Prairie 11/15/2002 21 1 ‐ 4 Yes 46 Yes

FOWLER DON W+MARY C 6220 12433 ADAIR CREEK WAY NE Hemlock C 3/3/2011 ‐ ‐ 29 2 28 Yes

FRANKLIN RONALD L+LESLYN M ROSE 2020 13288 230th Pl NE Townsend A 12/9/2003 16 2 ‐ ‐ Yes ‐ Yes

FREDRICKSON MARVIN & LINDA L 6220 12558 237th WAY NE Hemlock A 12/17/2002 30 2 ‐ 2 Yes Yes

FRENCH JEFFREY H+CAROLYN M 6220 13203 ADAIR CREEK WAY NE Hemlock C 2/13/2007 25 2 29 2 34 Yes

FRICKE ROY A+TING Y 4091 23744 NE 134th PL Vancouver A 2/8/2006 unk unk 5 ‐ Yes Yes

FRIEDRICH KURT+KATHLEEN 6540 23625 NE TWINBERRY WAY Maryhill B 6/12/2007 unk unk 12 ‐ Yes

FRY JAMES A+JODIE L 2020 23517 NE TWINBERRY WAY Townsend A 4/6/2006 11 3 ‐ ‐ Yes ‐ Yes

FULLER MICHAEL+MARY 2030 12445 240th PL NE Discovery C 6/10/2010 1 ‐ 13 2 ‐ Yes

GALLAGHER JAMES+BETTY (MIKE) 6230 23616 NE 135th WAY Maple C 9/19/2006 23 2 24 2 48 Yes

GARCIA DONALD E+DOLORES S ET AL 6510 12298 235th PL NE Monticello A 11/19/2002 26 1 ‐ 2 Yes ‐ Yes

GARDNER RICHARD E+SAVILLE H 4081 13109 ADAIR CREEK WAY NE Bainbridge Cottage 6/6/2007 21 3 ‐ ‐ 20 Yes

GARRETT RONALD L+SANDRA L ‐LIVING TRUST 3340 12026 BIG LEAF WAY NE Washington A 2/24/2005 27 2 2 1 Yes Yes

GARVEY DALE MARTIN JR+JANICE MOORE 6220 23737 NE 116th PL Hemlock B 6/6/2002 45 2 ‐ 2 Yes ‐ Yes

GAUTREAU RONALD V+SYBIL H 4084 23977 NE GREENS CROSSING RD Nice Craftsman 4/5/2012 ‐ ‐ ‐ 1 Yes

GELT ZHENIN+LYUDMILA 2050 24155 NE 122nd ST Madison B 10/19/2005 unk unk ‐ 1 Yes Yes

GELZER JOSPEH W+LORELEI L 4050 23104 NE 127th WAY Vashon B 12/30/2003 15 2 ‐ ‐ Yes 26 Yes

GENTILE ROBIN S+RONALD L 4060 23726 NE 134th PL Whidbey B 2/28/2006 22 3 12 2 Yes 25 Yes

GIBB DENNIS 6240 13139 234th CT NE Cedar Prairie 11/5/2003 31 3 ‐ 4 Yes 28 Yes

GIBSON LAWRENCE C+DIANE M 4060 22927 NE 132nd St Whidbey A 7/29/2004 20 2 ‐ 2 Yes ‐ Yes

GLENN ALLEN+SANDRA 6220 23729 NE 116th PL Hemlock C 6/13/2002 26 1 29 2 Yes 30 Yes

GODIDI ODILLE 4081 12255 243rd PL NE Bainbridge Cottage 1/10/2006 20 2 ‐ ‐ Yes 18 Yes

GOE MIKELL+RICHARD 4084 23827 NE 127th ST Nice Prairie 8/2/2012 ‐ ‐ ‐ 1 Yes

GOETSCH DONALD W+KATHLEEN L 3320 13549 ADAIR CREEK WAY NE Union B 4/25/2006 unk unk ‐ ‐ Yes Yes

GOLDHAMMER BARBARA DIANE 6220 23872 NE 126th PL Hemlock C 8/27/2009 11 1 29 2 20 Yes

GOODKIN ROBERT+SANDRA R 6540 23838 NE SALAL PL Maryhill C 7/6/2007 53 3 ‐ ‐ 90 Yes

GORDON DAVID M+L DIANE 4050 11853 239th AVE NE Vashon A 2/28/2002 20 2 1 3 Yes ‐ Yes

GORE SARAH L 6510 23231 NE 123rd ST Monticello B 10/24/2002 21 3 7 2 Yes ‐ Yes

GORODKO MARJORIE N 3320 22881 NE 130th ST Union B 9/21/2004 21 3 ‐ ‐ Yes 13 Yes

GOSSETT JOYCE E 3320 12252 BIG LEAF WAY NE Union B 9/6/2005 21 2 ‐ ‐ Yes Yes

GRAAT KENNETH T+PAMELA D (Tom Shanely) 6540 12730 240th PL NE Maryhill C 6/16/2011 2 2 ‐ ‐ 100 Yes

GRATT BARTON M+KAREN R 2050 23511 NE TWINBERRY WAY Madison A 7/27/2006 unk unk ‐ 2 Yes

GRAY STEPHEN+CAROLINE A 3320 24255 NE 130th PL Union B 8/23/2007 unk unk ‐ ‐ Yes

GRECO PAUL W+MARELU M 2030 12450 232nd WAY NE Discovery A 1/14/2003 7 1 ‐ ‐ Yes ‐ Yes

GREGOIRE RAYMOND+CHRISTINE 4081 23335 NE 126th ST Bainbridge Cottage 10/7/2003 unk unk ‐ ‐ Yes Yes

GRESS III WILLIAM CHARLES+RUBY ANN 3340 12130 BIG LEAF WAY NE Washington B 3/3/2005 22 2 ‐ ‐ Yes 4 Yes

GRIBBEN PATRICIA L+WILLIAM T 2040 13737 231st LN NE Orchard A 9/14/2007 12 2 ‐ 2 ‐ Yes

GROSSMAN JEFFREY D+VIVIAN 6220 23677 NE TWINBERRY WAY Hemlock C 4/5/2012 ‐ ‐ 29 2 30 Yes

GUERNSEY PATRICIA E 2020 23047 NE 130th ST Townsend C 6/24/2004 16 2 13 1 Yes ‐ Yes

GURTEL ARTHUR L+SHARON F 6240 12033 BIG LEAF WAY NE Cedar Prairie 6/21/2005 32 2 ‐ 4 Yes 34 Yes

GUTHRIE LUCIAN G+JO‐ANN A 4060 13224 230th Pl NE Whidbey C 1/29/2004 21 2 3 2 Yes ‐ Yes

GWILYM JANINE R+MILES L 6220 23766 NE SALAL PL Hemlock C 8/1/2006 29 2 29 2 24 Yes

HAAS JOEL E+CAROLYN A 6520 11826 BIG LEAF WAY NE Oakwood C 12/23/2004 29 3 ‐ ‐ Yes 67 Yes

HAGANDER JEFFREY+LUCIA 6540 23150 NE 126th ST Maryhill A unknown unk unk 3 ‐ Yes Yes

HAGBERG JOELL L 6520 11829 239th AVE NE Oakwood C 4/2/2002 unk unk ‐ ‐ Yes Yes

HAGEN JAMES O+NANCY C 6220 12407 235th PL NE Hemlock C 8/27/2002 29 1 29 2 Yes 27 Yes

HAISCH EUGENE ROSS JR+WYNONNA D 6220 23240 NE 126th ST Hemlock C 7/29/2003 28 2 29 2 Yes 26 Yes

HALL KAREN JEAN 2020 11656 239th AVE NE Townsend A 5/2/2002 13 2 ‐ ‐ Yes ‐ Yes

HALLEN ANNETTE I 6230 23004 NE 126th ST Maple A 7/22/2003 23 3 ‐ 1 Yes ‐ Yes

HAMERNIK KENNETH A+PEGGY ANN 6230 23760 NE SALAL PL Maple C 3/7/2006 23 2 24 2 Yes 53 Yes

HAMLIN MERRIE E 2030 24531 NE VINE MAPLE WAY Discovery C 4/5/2005 unk unk 13 2 Yes Yes

HAMMERBACK FAMILY TRUST 6240 13208 230th Pl NE Cedar Craftsman 12/30/2003 20 1 15 4 Yes 4 Yes





TABLE OF PLAINTIFFS

Owner

Shea Plan


Date

Permited

Total

Windows

Unflashed

Total

Doors

Unflashed

Total

Corbels Not

Flashed By

Shea

Defective

Columns

Defective

Garage

Slab

Lineal Feet of

Defective

Wainscott

Unflashed

Patio/DeckHAMMOND JESSE E+SANDRA* J AND EVERUD DAN + TERESA 4050 22860 NE 129th PL Vashon C 10/5/2004 20 2 9 ‐ Yes 26 Yes

HANCOCK JOHN K+JACQUELYN 4081 22861 NE 129th PL Bainbridge Craftsman 8/24/2004 21 2 ‐ ‐ Yes 10 Yes

HANDLEY ROBERT L+CELIA B N 4060 11823 242nd PL NE Whidbey C 8/23/2005 22 3 3 2 Yes 6 Yes

HANSEN JEAN M, TRUSTEE 6240 13454 MAHONIA PL NE Cedar Prairie 3/27/2007 33 2 ‐ 4 50 Yes

HART ROBERT S+ CHAMPE, Georgia 2030 12384 232nd WAY NE Discovery C 12/3/2002 unk unk 13 2 Yes Yes

HARTSTEIN EDWARD M 6540 12406 235th PL NE Maryhill A 9/10/2002 52 2 3 ‐ Yes 110 Yes

HASKITT RICHARD R+JOYCE E 6220 23820 NE SALAL PL Hemlock C 2/27/2007 29 1 29 2 26 Yes

HAWLEY GAIL L 6230 11890 BIG LEAF WAY NE Maple B 2/22/2005 44 1 ‐ ‐ Yes 36 Yes

HAYES DAVID K JR+SUSAN D 3320 24233 NE 131st TER Union B 8/23/2007 19 2 ‐ ‐ 13 Yes

HAZARD JAMES P+CAROL L 3340 23044 NE 139th CT Washington A 4/25/2006 unk unk 2 1 Yes Yes

HAZEN IRENE 6220 23745 NE 116th PL Hemlock A 4/9/2002 29 1 ‐ 2 Yes ‐ Yes

HEADMAN BARBARA A 4081 11654 238th PL NE Bainbridge Prairie 3/20/2002 16 1 ‐ ‐ Yes 28 Yes

HEATH GEORGE ROSS+LORNA M 6230 12513 237th WAY NE Maple A 12/10/2002 unk unk ‐ 1 Yes Yes

HEGGER WILLIAM R+KRISTINE A 6530 23845 NE ADAIR RD Redford C 7/7/2005 unk unk ‐ ‐ Yes Yes

HEILBORN KARL A + MARIE 6220 23547 NE 122nd CT Hemlock B 5/9/2002 48 2 ‐ 2 Yes ‐ Yes

HELLER SUSAN 2030 11616 239th AVE NE Discovery B 3/26/2002 13 1 ‐ 2 Yes 25 Yes

HELM JOCELYN B 2030 13283 228th PL NE Discovery C 3/9/2004 16 2 13 2 Yes ‐ Yes

HENDERSON NOEL A+LONGARZO DIANA I+HARRIS CAROLYN J 6240 13126 234th CT NE Cedar Craftsman 2/17/2004 22 3 15 4 Yes ‐ Yes

HESS LIVING TRUST JEANNE M 6230 13118 234th CT NE Maple C 11/13/2003 unk unk 24 2 Yes Yes

HETHERINGTON RICHARD + ANN 3310 23713 NE 134th PL Chelan Craftsman 9/26/2006 11 2 ‐ 2 ‐ Yes

HIGGINS CHERYL + JAN 4060 23121 NE DEVON WAY Whidbey B 8/29/2006 23 2 12 2 34 Yes

HILTON WILLIAM A 4060 23057 NE 127th WAY Whidbey C 6/22/2004 19 3 3 2 Yes ‐ Yes

HIRANO WINIFRED T 3310 13828 231st LN NE Chelan American Traditional 9/19/2006 12 2 ‐ ‐ ‐ Yes

HOFF CHARLES S+SHEILA R 6220 12628 ADAIR CREEK WAY NE Hemlock C 2/12/2008 19 1 29 2 19 Yes

HOFFMAN NEIL R+MARIANNE M 4081 13221 230th Pl NE Bainbridge Prairie 10/19/2004 19 3 ‐ ‐ Yes 21 Yes

HOLMAN KERMIT L+AUDREY R 2030 24583 NE VINE MAPLE WAY Discovery B 4/12/2005 19 2 ‐ 2 Yes Yes

HOLMES BURDETTE J+SHARON L 2030 11721 239th AVE NE Discovery B 1/3/2002 14 3 ‐ 2 Yes 36 Yes

HOOKER JAMES ALLEN+ALMA LEE MARIE ‐FAMILY REV TRUST 6540 12318 232nd TER NE Maryhill C 2/11/2003 52 4 ‐ ‐ Yes 99 Yes

HOOPER JACK+WELKER ANDREA L 6240 23031 NE 139th CT Cedar Craftsman 7/11/2006 20 2 15 4 ‐ Yes

HORAN BRIAN+SUE A ATKINSON HORAN 2030 24563 NE VINE MAPLE WAY Discovery C 4/12/2005 14 2 13 2 Yes 10 Yes

HORRELL JAMES F+BARBARA L 6220 23118 NE 126th ST Hemlock C 9/25/2003 23 2 29 2 Yes 21 Yes

HOUMIEL FRANK R+LORRAINE S+KATHRYN L 6220 13203 228th PL NE Hemlock C 3/3/2004 31 2 29 2 Yes 22 Yes

HOWARD ELEANOR M+ROBERT C 2030 24564 NE 118th PL Discovery B 10/26/2004 7 2 ‐ 2 Yes 25 Yes

HOXIE REVOCABLE TRUST 2020 12368 232nd WAY NE Townsend C 10/29/2002 12 3 13 1 Yes ‐ Yes

HOY PHILIP J+BRENDA WEST 6220 12657 SUNBREAK WAY NE Hemlock C 11/2/2004 29 3 29 2 Yes 28 Yes

HUANG LIVING TRUST 6220 23745 NE 134th PL Hemlock A 7/6/2006 31 2 ‐ 2 ‐ Yes

HUBBELL JANE R (TRUST) 2030 23749 NE SALAL PL Discovery C 2/21/2006 16 3 13 2 Yes 20 Yes

HUGHES ALLEN+NANCY 4081 22813 NE 132nd St Bainbridge Cottage 6/29/2004 22 2 ‐ ‐ Yes 20 Yes

HUI BARRY S+YUEN‐FUN AMY 4091 24036 NE ADAIR RD Vancouver A 10/28/2005 unk unk 5 ‐ Yes Yes

HUI FRANK/YVONNE 6240 12618 240th PL NE Cedar Prairie 11/17/2011 7 7 ‐ 4 64 Yes

HUMANN STANLEY D+KAY A 6220 12443 232nd TER NE Hemlock A 5/29/2003 30 2 ‐ 2 Yes 22 Yes

HUNTMAN DAVID+SHEILA LIVING TRUST 4060 13117 ADAIR CREEK WAY NE Whidbey C 9/14/2007 7 1 3 2 ‐ Yes

HYDE DAVID R+DAPHNE E 4091 12417 230th PL NE Vancouver B 12/10/2002 20 2 9 ‐ Yes 26 Yes

IRAOLA MARK R+KAREN E 6220 12201 243rd PL NE Hemlock A 9/13/2005 22 2 ‐ 2 Yes 2 Yes

ISRAEL MORRIS R+NANCY E 6220 12422 235th PL NE Hemlock C 9/10/2002 30 2 29 2 Yes 42 Yes

IVERSON MARILYN 4050 11662 238th PL NE Vashon C 3/12/2002 20 2 9 ‐ Yes 22 Yes

JACKSON RANDALL V+PATRICIA K 6230 23968 NE 127th ST Maple B 7/9/2009 18 2 ‐ ‐ 41 Yes

JAMES FAMILY TRUST 6230 23829 NE GREENS CROSSING RD Maple B unknown 26 2 ‐ ‐ 25 Yes

JATON LINDA A+H WAYNE 3320 13405 ADAIR CREEK WAY NE Union B 2/6/2007 19 2 ‐ ‐ 11 Yes

JENKINS THOMAS L+DIANE M 6240 12384 ADAIR CREEK WAY NE Cedar Craftsman 10/6/2007 19 3 15 4 Yes

JENSEN C WILLIAM+CAROL W 4060 22882 NE 127th WAY Whidbey C 9/7/2004 23 2 3 2 Yes ‐ Yes

JI SOOK JUN 6220 13958 MORGAN DR NE Hemlock B 8/29/2006 51 3 ‐ 2 26 Yes

JOHNSON CANDACE+RONALD 4081 12826 230th AVE NE Bainbridge Craftsman 6/1/2004 22 1 ‐ ‐ Yes 12 Yes

JOHNSON GARY+VERLE 2030 13311 239th WAY NE Discovery C 1/15/2008 6 1 13 2 ‐ Yes

JOHNSON JOHN N+VIRGINIA A 6230 22863 NE 127th WAY Maple A 12/7/2004 28 2 ‐ 1 Yes ‐ Yes

JOHNSTON JOAN M 2030 24555 NE VINE MAPLE WAY Discovery A 4/12/2005 16 2 ‐ ‐ Yes ‐ Yes

JOSEPHINE A HARVEY TRUST 3310 23136 NE 127th WAY Chelan Craftsman 5/18/2004 unk unk ‐ 2 Yes Yes

KAHN LAWRENCE A+COHN ROSANNE S 4081 12508 231st AVE NE Bainbridge Prairie 2/26/2003 21 2 ‐ ‐ Yes 28 Yes

KALISH STEPHEN E 6230 23726 NE GREENS CROSSING RD Maple A 2/11/2003 27 3 ‐ 1 Yes ‐ Yes

KAPAHI SAT DEV 4091 12432 230th PL NE Vancouver C 3/25/2003 20 2 5 ‐ Yes ‐ Yes

KATTI ASHOK N+SUDHA N 3320 13822 231st LN NE Union B 9/19/2006 21 2 ‐ ‐ ‐ Yes

KELLY KAREN V 3310 22899 NE 128th PL Chelan American Traditional 1/18/2005 12 2 ‐ 2 Yes Yes

KELLY WILLIAM+PATRICE NAGASAWA; VERSTEEG DOUG 4050 13027 243rd PL NE Vashon C 5/22/2008 6 1 9 ‐ 21 Yes

KENNEDY DON MIKE+PATRICIA L 6240 23802 NE SALAL PL Cedar American Traditional 4/6/2007 21 3 ‐ ‐ Yes

KENNEDY ROBERT B+SANDRA L 6540 12451 235th PL NE Maryhill A 9/10/2002 49 2 3 ‐ Yes 108 Yes

KERKOF CECILE E+KIRWIN MICHELLE M 3310 12106 BIG LEAF WAY NE Chelan Craftsman 3/8/2005 12 2 ‐ 2 Yes 12 Yes

KERKOF MAURICE A+CONSTANCE E 4060 12340 BIG LEAF WAY NE Whidbey C 9/27/2005 22 3 3 2 Yes ‐ Yes

KIENTZ THOMAS 2030 13217 SUNBREAK WAY NE Discovery C 3/30/2004 16 2 13 2 Yes ‐ Yes

KIMBALL BRIAN+BARBARA L 4081 12347 232nd TER NE Bainbridge Cottage 11/5/2002 22 1 ‐ ‐ Yes 18 Yes

KIMSEY LIVING TRUST 6230 23421 NE 131st PL Maple A 1/13/2003 27 2 ‐ 1 Yes ‐ Yes

KING DAVID+KAREN 4060 12321 BIG LEAF WAY NE Whidbey B 6/21/2005 22 3 12 2 Yes 24 Yes

KING LEONARD+RUTH 2030 24137 NE 122nd ST Discovery C 10/28/2005 16 3 13 2 Yes 20 Yes

KINGMAN A RALPH+OLSON JANE E 3330 23756 NE 134th PL Sammamish A 5/30/2006 17 2 2 2 Yes ‐ Yes

KJERULFF EVERETT R+ANTHEA 4050 12541 231st AVE NE Vashon C 7/3/2003 18 3 9 ‐ Yes 23 Yes

KNIGHT WILLIAM G+DOROTHY A GRAHAM 6220 23923 NE ADAIR RD Hemlock C 5/12/2005 23 1 29 2 Yes 20 Yes

KOEBEL DANIEL B+COOPER SHAR 6220 23960 NE GREENS CROSSING RD Hemlock B 4/5/2012 unk unk ‐ 2 Yes

KOPPEL MICHAEL+KOPPEL RICKI 3340 13335 ADAIR CREEK WAY NE Washington A 2/13/2007 22 2 2 1 10 Yes

KRAHN MARGARET M 3340 13777 MORGAN DR NE Washington A 7/25/2006 24 2 2 1 ‐ Yes

KREBS FAMILY TRUST 6230 12326 232nd TER NE Maple B 3/12/2003 43 2 ‐ ‐ Yes 19 Yes

KRIEFF OI LING 3340 12811 230th AVE NE Washington B 7/27/2004 22 2 ‐ ‐ Yes ‐ Yes

KUO MIN‐CHIU 3310 24246 NE 130th PL Chelan American Traditional 9/18/2007 unk unk ‐ ‐ Yes

KUSHIN KENNETH R 2030 23867 NE 124th TER Discovery C 6/24/2010 1 ‐ 13 2 ‐ Yes

KUSSICK LEON+MARILYN REVOCABLE TRUST 4081 22848 NE 130th ST Bainbridge Prairie 8/10/2004 18 2 ‐ ‐ Yes 27 Yes

LAGUARDIA ROBERT M+ROSE C 4081 23760 NE 116th PL Bainbridge Craftsman 4/9/2002 21 2 ‐ ‐ Yes 4 Yes

LANMAN STEVEN B+BETTY L 6220 22871 NE 127th WAY Hemlock C 1/25/2005 27 2 29 2 Yes Yes

LARSON NORMAN A+BARBARA L 4081 12414 243rd PL NE Bainbridge Prairie 10/4/2007 6 2 ‐ ‐ 23 Yes

LATIF MARIAM 6540 23116 NE 123rd ST Maryhill A 1/8/2002 unk unk 3 ‐ Yes Yes

LATTER BARRY C+SUSAN E 6250 13200 230th Pl NE Alder Craftsman 1/29/2004 25 3 22 3 Yes 23 Yes

LAUZON PIERRE+EILEEN M 6220 23241 NE 126th ST Hemlock B 8/12/2003 44 2 ‐ 2 Yes Yes

LAWRENCE CHARLES W+LOIS L 2030 12320 232nd WAY NE Discovery A 11/15/2002 13 2 ‐ ‐ Yes ‐ Yes

LAWSON VIRGINIA F 4091 22858 NE 132nd PL Vancouver C 3/24/2004 unk unk 5 ‐ Yes Yes

LEE JANIS B 2030 13221 239th WAY NE Discovery C 1/22/2008 8 1 13 2 24 Yes

LEE LYNDEN D+HELEN B 4091 12551 SUNBREAK WAY NE Vancouver B 2/12/2004 15 2 9 ‐ Yes 38 Yes

LESTER DEAN+DIANNE 4081 12567 SUNBREAK WAY NE Bainbridge Cottage 4/15/2004 22 2 ‐ ‐ Yes 18 Yes

LEWIS BARBARA A+BURTON MICHELLE R 3310 23750 NE 134th PL Chelan Craftsman 5/30/2006 unk unk ‐ 2 Yes Yes

LICHTENBERGER W WAYNE+BONNIE A 6230 11850 BIG LEAF WAY NE Maple A 12/23/2004 unk unk ‐ 1 Yes Yes

LIEBOWITZ JOHN A+DIANE B 6230 23142 NE 126th ST Maple A 9/25/2003 27 3 ‐ 1 Yes ‐ Yes

LILLIBRIDGE JAMES J+MARINA AND CARLSTROM WILLIAM + ANN 2040 13274 SUNBREAK WAY NE Orchard B 1/20/2004 13 2 ‐ 2 Yes ‐ Yes

LILLY WILMOT H III+MARILYN R 6540 12438 243rd PL NE Maryhill B 10/4/2007 9 ‐ 12 ‐ ‐ Yes

LINDE LAURENCE T+GAIL A 2030 12312 232nd WAY NE Discovery C 10/29/2002 16 2 13 2 Yes ‐ Yes

LINDSTROM NANCY I 4091 12243 235th PL NE Vancouver B 6/11/2002 20 2 9 ‐ Yes 37 Yes

LISINA ANNA 4050 12443 243rd TER NE Vashon C 12/23/2010 ‐ 1 9 ‐ 24 Yes

LIU JOHN+WINNIE 4050 23738 NE 134th PL Vashon C 2/8/2006 20 2 9 ‐ Yes 20 Yes

LLOYD FRANCES W 2040 12412 243rd TER NE Orchard B 5/13/2008 4 2 ‐ 2 ‐ Yes

LONG GILBERT ANDREW+ILONE DANNA 4091 23011 NE 124th PL Vancouver B 10/24/2002 20 2 9 ‐ Yes 26 Yes

LONG JOAN S 4060 12367 ADAIR CREEK WAY NE Whidbey C 1/10/2006 19 3 3 2 Yes ‐ Yes

LOPEZ, PATRICIAO 6220 23418 NE 129th CT Hemlock A 11/25/2003 unk unk ‐ 2 Yes Yes

LORENZ BONNIE 3330 24429 NE VINE MAPLE WAY Sammamish B 6/14/2005 23 2 ‐ ‐ Yes 15 Yes

LOVE DONALD O MARITAL TRUST B; STORY SANDRA 3320 13416 238th PL NE Union A 3/6/2007 21 2 3 ‐ 26 Yes

LOVELAND JERI L 2010 11663 239th AVE NE Angeles Craftsman 4/18/2002 10 1 19 2 Yes 20 Yes

LOWELL GORDON H+LINDA K 4081 23732 NE 134th PL Bainbridge Prairie 3/7/2006 20 2 ‐ ‐ Yes 19 Yes

LUBOCKI DAVID J+JACKIE C 4051 23953 NE GREENS CROSSING RD Monaco Craftsman 8/2/2012 ‐ ‐ ‐ 2 ‐ Yes





TABLE OF PLAINTIFFS

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Patio/DeckLUCAS SUSAN A 3320 13333 MAHONIA PL NE Union A 5/29/2007 unk unk 3 ‐ Yes

LUEBBERS MATTHEW B+CYNTHIA L 4060 11645 238th PL NE Whidbey C 8/22/2002 22 3 3 2 Yes ‐ Yes

LUHN HAROLD L+KAREN R 3330 13714 231st LN NE Sammamish A 6/27/2006 17 2 2 2 Yes ‐ Yes

LUI WING SHUM+JOSEPHINE FUNGYUE TAM 6220 12411 232nd TER NE Hemlock A 2/26/2003 unk unk ‐ 2 Yes Yes

LUKECART FLOYD M+FLORA I 6230 23915 NE ADAIR RD Maple A 5/3/2005 27 1 ‐ 1 Yes ‐ Yes

LUKSON FREDRICK J+CAROLYN K 6240 13034 243rd PL NE Cedar Prairie 7/1/2008 16 4 ‐ 4 42 Yes

LYON KENNETH D+ROBERTA J 6230 12239 243rd PL NE Maple C 11/15/2005 23 2 24 2 Yes 36 Yes

M & A JOSLIN FAMILY TRUST 4091 12516 231st AVE NE Vancouver B 2/25/2003 20 2 9 ‐ Yes 37 Yes

MACDUFF DOUGLAS K+KAREN D 6240 24148 NE 131st TER Cedar Prairie 1/15/2008 24 2 ‐ 4 42 Yes

MACLANE CHERIE K 6220 13927 MORGAN DR NE Hemlock B 8/22/2006 45 3 ‐ 2 ‐ Yes

MAGNUSON DAVID M+DIANE L 6240 23714 NE GREENS CROSSING RD Cedar Craftsman 12/17/2002 15 3 15 4 Yes Yes

MAHONEY CHERI LYN+SAMU DARWIN J 6240 12439 235th PL NE Cedar Prairie 8/20/2002 32 1 ‐ 4 Yes 45 Yes

MALONE MARGARET C 2040 13233 239th WAY NE Orchard C 4/29/2008 9 2 13 2 44 Yes

MARASCO RICHARD JOHN 6220 22930 NE 126th ST Hemlock C 6/17/2003 29 1 29 2 Yes 18 Yes

MARKEZICH RONALD L+MARKEZICH BEVERLY J 6520 22851 NE 138th CT Oakwood C 1/30/2007 28 3 ‐ ‐ 100 Yes

MARSHALL RICHARD D+NANCY K 4060 12818 230th AVE NE Whidbey A 7/13/2004 19 3 ‐ 2 Yes ‐ Yes

MARTIN DALE A+SUSAN D LIVING TRUST 4091 23554 NE 122nd CT Vancouver B 5/28/2002 21 2 9 ‐ Yes 41 Yes

MARTINEAU JAMES E+KATHLEEN M 4091 11807 242nd PL NE Vancouver A 8/23/2005 17 2 5 ‐ Yes 40 Yes

MATHENY STEVEN I+ANITA R 6220 23249 NE 126th ST Hemlock A 8/19/2003 29 2 ‐ 2 Yes 12 Yes

MATTHES DONALD L+ SUSAN J 2010 12434 232nd WAY NE Angeles Craftsman 12/31/2002 10 ‐ 19 2 Yes ‐ Yes

MATTHIAS DAVID E+JUDY A 6230 23758 NE 134th ST Maple A 2/13/2007 27 3 ‐ 1 ‐ Yes

MAYER GEOFFREY+SUSAN 6220 13862 MORGAN DR NE Hemlock C 9/12/2006 26 4 29 2 30 Yes

MCCALLUM CHARLES J JR+PENNIE J 6220 12460 240th PL NE Hemlock B 12/16/2010 ‐ ‐ ‐ 2 2 Yes

MCCANDLESS JOHN R+CAROL A 3340 13341 ADAIR CREEK WAY NE Washington B 2/6/2007 20 2 ‐ ‐ ‐ Yes

MCCANN KURT D+MCCANN MARY DEE 6220 11731 238th PL NE Hemlock B 2/12/2002 43 2 ‐ 2 Yes ‐ Yes

MCCRAY RONALD A+CAROL LEE 6220 11715 238th PL NE Hemlock C 2/12/2002 27 2 29 2 Yes 10 Yes

MCFARLAND STEPHEN E SR 2050 24571 NE VINE MAPLE WAY Madison B 4/12/2005 25 2 ‐ 1 Yes ‐ Yes

MCINTOSH ROBERT+LOIS C 6220 23126 NE 126th ST Hemlock A 9/18/2003 unk unk ‐ 2 Yes Yes

MCKAY THOMAS A+SHEILA E 2050 13344 239th WAY NE Madison B 6/26/2007 24 3 ‐ 1 10 Yes

MCMANAMON DAVID 6530 13128 SUNBREAK WAY NE Redford A 9/9/2004 27 3 15 ‐ Yes Yes

MCRAE KENNETH D 4081 23264 NE 126th ST Bainbridge Prairie 8/5/2003 unk unk ‐ ‐ Yes Yes

MEAD JAMES+JULIE 6220 23151 NE 127th WAY Hemlock B 1/8/2004 48 2 ‐ 2 Yes 30 Yes

MEHTA JAY T+ZOHREH 4060 11755 238th PL NE Whidbey A 7/2/2002 unk unk ‐ 2 Yes Yes

MEIKLE S RICK+KAREN T 3320 13796 MORGAN DR NE Union A 12/19/2006 25 2 3 ‐ 25 Yes

MEISER DONALD L + G MARLENE 6220 12512 232nd TER NE Hemlock C 6/10/2003 29 2 29 2 Yes 35 Yes

MENDOZA MARGARITA E+JUSTINIANO R 6220 23133 NE 123rd ST Hemlock B 3/29/2012 49 3 ‐ 2 26 Yes

MEREDITH STEPHEN A+LINDA L 6220 13562 ADAIR CREEK WAY NE Hemlock C 7/18/2006 31 3 29 2 19 Yes

MESAROS MIKE+ROZI 4060 23032 NE 127th WAY Whidbey A 4/27/2004 20 2 ‐ 2 Yes ‐ Yes

MICHALAK LIVING TRUST 2020 12515 232nd WAY NE Townsend C 2/18/2003 13 2 13 1 Yes 16 Yes

MICKLITZ JOSEF+ELIZABETH ‐TRUSTEES 4091 11708 238th PL NE Vancouver C 3/19/2002 18 2 5 ‐ Yes ‐ Yes

MIHOVILOVICH JOHN J+DONNA J 3320 13422 238th PL NE Union B 3/6/2007 17 2 ‐ ‐ 12 Yes

MILBRODT C RICHARD+BONNIE J 3320 23005 NE 128th PL Union B 1/18/2005 12 2 ‐ 2 Yes Yes

MINEMOTO MASARU+VICKI LYNN REVOCABLE LIVING TRUST 4081 23844 NE SALAL PL Bainbridge Cottage 3/27/2007 21 2 ‐ ‐ 16 Yes

MITCHELL DAVID S+LILLY O 4060 12406 231st AVE NE Whidbey A 6/19/2003 16 2 ‐ 2 Yes ‐ Yes

MOIR JEFFREY K 6220 23405 NE 131st PL Hemlock B 10/21/2003 43 3 ‐ 2 Yes 35 Yes

MONCRIEFF DONALD M+ROSEMARY J 4050 11638 238th PL NE Vashon B 2/28/2002 unk unk ‐ ‐ Yes Yes

MONTGOMERY TED L+KATHLEEN G 6220 13026 243rd PL NE Hemlock C 9/11/2007 29 2 29 2 ‐ Yes

MOORE ALICE M 6220 12369 243rd PL NE Hemlock C 11/15/2005 24 1 29 2 Yes 32 Yes

MOORE WILLIAM A 2030 24580 NE 118th PL Discovery A 10/26/2004 16 2 ‐ ‐ Yes ‐ Yes

MORLAND JUDITH A 4050 13236 ADAIR CREEK WAY NE Vashon C 5/10/2007 15 2 9 ‐ 18 Yes

MORRIS ROBERT S+DONNA G 6220 23277 NE 126th ST Hemlock A 9/23/2003 unk unk ‐ 2 Yes Yes

MORRISON MICHAEL R+JEANNE M 6510 12308 235th PL NE Monticello B 8/27/2002 20 5 7 2 Yes 14 Yes

MOSER DORIS E+DOYLE BARBARA M 6220 12235 235th PL NE Hemlock C 6/11/2002 26 ‐ 29 2 Yes 20 Yes

MOYA JOE L+SALLY A 6220 12023 BIG LEAF WAY NE Hemlock A 2/8/2005 30 2 ‐ 2 Yes 16 Yes

MUDD JEAN MARIE 3320 22880 NE 130th ST Union A 4/27/2004 26 2 3 ‐ Yes 19 Yes

MURPHY MICHELLE M 2040 11622 239th AVE NE Orchard C 3/26/2002 10 1 13 2 Yes 24 Yes

MYERS JOAN 2040 13234 SUNBREAK WAY NE Orchard C 2/10/2004 10 2 13 2 Yes 16 Yes

MYERS MICHAEL+KATHLEEN 6220 13206 239th WAY NE Hemlock B 9/30/2008 ‐ 1 ‐ 2 29 Yes

MYERS WILLIAM M+PRUDENCIA D 4081 12423 231st AVE NE Bainbridge Cottage 6/24/2003 unk unk ‐ ‐ Yes Yes

NAFE SHIRLEY J 2030 23608 NE TWINBERRY WAY Discovery C 1/2/2007 13 2 13 2 ‐ Yes

NEER WILLIAM D+CAROLE M 6530 23571 NE TWINBERRY WAY Redford C 5/22/2007 28 3 ‐ ‐ 72 Yes

NELSON SANDRA A 4060 23113 NE 124th PL Whidbey C 10/24/2002 unk unk 3 2 Yes Yes

NESS LAWRENCE H+JANE E 4060 13751 231st LN NE Whidbey C 6/29/2006 19 3 3 2 ‐ Yes

NEWSOM JOHN+SHARON 6230 23939 NE ADAIR RD Maple C 7/7/2005 22 2 24 2 Yes 46 Yes

NICHOLSON DOUGLAS B+CONSTANCE A TRUST 2040 12453 232nd WAY NE Orchard B 2/25/2003 12 1 ‐ 2 Yes ‐ Yes

NIEMAN RUSSELL A+MARSHA M 2020 22810 NE 132nd PL Townsend A 6/29/2004 16 2 ‐ ‐ Yes ‐ Yes

NILSEN JUDITH M 4060 23008 NE 127th WAY Whidbey B 4/22/2004 unk unk 12 2 Yes Yes

NOBLE DENISANN 4081 23546 NE 122nd CT Bainbridge Cottage 6/13/2002 unk unk ‐ ‐ Yes Yes

NOMIYAMA FRANK+BETTY Y 2040 24436 NE VINE MAPLE WAY Orchard C 6/14/2005 10 3 13 2 Yes ‐ Yes

NOMOTO KUMIKO Y 2030 13544 ADAIR CREEK WAY NE Discovery B 3/21/2006 unk unk ‐ 2 Yes Yes

NORRIS JOHN C+GLENDA C 6230 23780 NE 134th ST Maple B 2/13/2007 44 2 ‐ ‐ 41 Yes

OBLANDER LORENA M 4050 13835 231st LN NE Vashon C 10/5/2006 19 2 9 ‐ 26 Yes

OLIVER MICHAEL T+BARBARA S 4081 22877 NE 129th PL Bainbridge Cottage 4/26/2005 19 3 ‐ ‐ Yes 21 Yes

OLSEN ELLA JEAN 6250 13437 MAHONIA PL NE Alder Prairie 3/13/2007 47 4 ‐ 4 24 Yes

OLSON HARVEY T+MARIA M 6540 22850 NE 128th PL Maryhill B 12/12/2006 47 4 12 ‐ ‐ Yes

OPACKI DENNIS G+JUDITH 6230 12215 243rd PL NE Maple B 9/6/2005 44 1 ‐ ‐ Yes 39 Yes

OPHEIM FRAN 2030 11671 239th AVE NE Discovery A 2/21/2002 13 2 ‐ ‐ Yes ‐ Yes

OWENS MARVIN M+BETTY M 4060 13173 ADAIR CREEK WAY NE Whidbey C 6/19/2007 23 2 3 2 ‐ Yes

PALAZZOLO CONNIE+HRNCIR ALICE 2030 12437 232nd WAY NE Discovery B 2/26/2003 unk unk ‐ 2 Yes Yes

PARIS KATHLEEN J MD TRUST (REVOCABLE TRUST) 4060 22854 NE 128th PL Whidbey C 6/14/2005 23 2 3 2 Yes 6 Yes

PARRISH HELEN C 4050 23010 NE 128th PL Vashon B 6/1/2004 unk unk ‐ ‐ Yes Yes

PASS JAMES D+SUSAN 4091 12555 232nd WAY NE Vancouver A 2/19/2003 18 2 5 ‐ Yes 40 Yes

PATTERSON JACK D+CATHERINE E 2030 11806 BIG LEAF WAY NE Discovery C 1/11/2005 12 2 13 2 Yes ‐ Yes

PAUL RICHARD A+KATHERINE G 4060 23000 NE 127th WAY Whidbey A 5/11/2004 19 3 ‐ 2 Yes ‐ Yes

PAXTON JAMES ALFRED+MARY LOUISE ‐FAMILY REV TRUST 4050 12518 230th PL NE Vashon A 4/8/2003 15 4 1 3 Yes ‐ Yes

PEDRIDO FAMILY TRUST 2040 11711 239th AVE NE Orchard C 2/21/2002 unk unk 13 2 Yes Yes

PEERCE WILLIAM R JR+SUSAN L 3340 24247 NE 130th PL Washington B 8/23/2007 18 2 ‐ ‐ ‐ Yes

PEPPER KRISTINE S 3340 23775 NE 134th ST Washington A 5/15/2007 11 1 2 1 ‐ Yes

PERKINS MICHAEL A+SHELLEY M 6220 23127 NE 127th WAY Hemlock C 12/18/2003 29 2 29 2 Yes 22 Yes

PETERSON DIANE M 3310 13327 MAHONIA PL NE Chelan Craftsman 5/29/2007 9 2 ‐ 2 10 Yes

PETERSON DOUGLAS W+MARYANNE 4060 12263 243rd PL NE Whidbey B 1/10/2006 22 2 12 2 Yes 19 Yes

PETERSON ROGER F+PETERSON DIANNE LISLE 6220 12635 237th WAY NE Hemlock C 4/28/2011 ‐ ‐ 29 2 20 Yes

PHILLIPS JOHN J+ELEANOR F 6220 23025 NE 127th WAY Hemlock B 3/24/2004 48 3 ‐ 2 Yes 28 Yes

PIRTLE ROBERT L+JENNIFER JO 6220 13326 239th WAY NE Hemlock C 5/10/2007 29 2 29 2 30 Yes

PORTER ROSE 4091 13256 230TH PL NE Vancouver B 2/11/2004 9 ‐ Yes Yes

POWERS GREGORY R+MARIANNE N 2050 23824 NE 116th PL Madison B 4/23/2002 23 ‐ ‐ 1 Yes ‐ Yes

PRESLEY TRUST CHRISTINE D 2030 23658 NE 135th WAY Discovery B 12/27/2005 17 2 ‐ 2 Yes Yes

PRINGLE ROBERT C+TINA A 6230 13018 243rd PL NE Maple C 9/13/2007 21 2 24 2 ‐ Yes

PROESEL CAROL WERTHEIMER 2040 23875 NE 124th TER Orchard C 6/24/2010 5 1 13 2 ‐ Yes

RACKERS ANNE E 6250 12511 230th PL NE Alder French Traditional 4/8/2003 27 2 ‐ ‐ Yes ‐ Yes

RADKE RONALD F+RUTH E 6220 23610 NE 135th WAY Hemlock C 5/16/2006 29 2 29 2 Yes 23 Yes

RAGSDALE JEANETTE BUSSEY 4081 23128 NE 127th WAY Bainbridge Prairie 2/3/2004 21 2 ‐ ‐ Yes 27 Yes

RALL DIANA + STANLEY 6230 24266 NE 131st TER Maple C 3/4/2010 ‐ 1 24 2 25 Yes

RANGARAM SUNDER+CAROL ANN 4081 12538 232nd WAY NE Bainbridge Cottage 1/7/2003 22 1 ‐ ‐ Yes 18 Yes

RECOB RICHARD W+LINDA A 4060 12546 232nd WAY NE Whidbey A 1/7/2003 21 2 ‐ 2 Yes ‐ Yes

REEVES GIA R MENDOZA+MICHAEL JOHN 4081 23140 NE 123rd ST Bainbridge Cottage 3/28/2012 20 2 ‐ ‐ Yes

REILLY CHARLES 4081 12307 BIG LEAF WAY NE Bainbridge Cottage 6/21/2005 22 2 ‐ ‐ Yes 16 Yes

REITAN Jean 6220 24258 NE 131st TER Hemlock C 12/11/2007 16 ‐ 29 2 ‐ Yes

RESNIK RICHARD M+AMY M 4060 23109 NE DEVON WAY Whidbey C 8/29/2006 23 2 3 2 ‐ Yes

REUBISH JANE J 2020 13235 228th PL NE Townsend A 3/3/2004 16 2 ‐ ‐ Yes ‐ Yes

RICHARDS LARRY O+PATRICIA C 4060 12665 SUNBREAK WAY NE Whidbey C 4/19/2005 21 3 3 2 Yes ‐ Yes

RIEDER MARGARET R 3320 24597 NE 118th PL Union B 7/26/2005 19 2 ‐ ‐ Yes 11 Yes

RIEGER DENNIS J+JANICE D 4081 23248 NE 126th ST Bainbridge Craftsman 10/3/2003 17 2 ‐ ‐ Yes 8 Yes

RIEGER KEIL A 6240 23735 NE 134th PL Cedar Prairie 9/5/2006 32 3 ‐ 4 ‐ Yes





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Unflashed

Patio/DeckRISDON VERA JANE 6220 12325 235th PL NE Hemlock B 9/12/2002 48 2 ‐ 2 Yes 33 Yes

ROBNETT DAVID+GERALDINE 2040 13556 ADAIR CREEK WAY NE Orchard B 3/3/2006 14 3 ‐ 2 Yes ‐ Yes

RODEN NANCY ANN 4081 12010 BIG LEAF WAY NE Bainbridge Prairie 5/31/2005 unk unk ‐ ‐ Yes Yes

RODMAN RICHARD L+CAROL F 4060 12226 235th PL NE Whidbey C 6/11/2002 23 2 3 2 Yes ‐ Yes

ROMANO DOUGLAS P+ALLISON E ‐ TTES 6540 13585 ADAIR CREEK WAY NE Maryhill A 2/28/2006 48 3 3 ‐ Yes 49 Yes

ROSENBERG DAVID H+SANDRA 2050 22897 NE 130th ST Madison B 3/22/2005 21 2 ‐ 1 Yes ‐ Yes

ROSS DONALD A+REDITH F 3330 23787 NE 134th ST Sammamish A 4/3/2007 22 2 2 2 16 Yes

ROSS JULITTA A 3330 12042 BIG LEAF WAY NE Sammamish A 2/8/2005 10 2 2 2 Yes 20 Yes

ROTH HOWARD and KATHY 6240 22914 NE 126th ST Cedar Craftsman 7/1/2003 17 3 15 4 Yes ‐ Yes

RUBEN GERHARD F+PALMA T 4081 11882 BIG LEAF WAY NE Bainbridge Cottage 5/17/2005 15 3 ‐ ‐ Yes 24 Yes

RUBIN HARRY A+CYNTHIA E 6230 23022 NE 130th ST Maple A 4/22/2004 24 1 ‐ 1 Yes ‐ Yes

RUDOWICZ SIGMUND P+ROSEMARY 6520 12414 235th PL NE Oakwood C 9/10/2002 28 2 ‐ ‐ Yes 64 Yes

RUFF DIANE 6230 13222 239th WAY NE Maple B 9/30/2008 ‐ ‐ ‐ ‐ 26 Yes

RUGGIERO CATHLEEN A 3320 24322 NE VINE MAPLE WAY Union A 10/11/2005 22 3 3 ‐ Yes 34 Yes

RUHLAND RICHARD G+GERALDINE M 6220 13131 234th CT NE Hemlock A 10/14/2003 24 1 ‐ 2 Yes 4 Yes

RUSHING ROBERT+GAIL 2040 13301 239th WAY NE Orchard A 1/15/2008 8 1 ‐ 2 56 Yes

RYAN WALTER RIDGWAY JR+HACKWORTH SARAH COLEMAN ‐TRUST 4081 12419 243rd TER NE Bainbridge Cottage 10/21/2010 ‐ ‐ ‐ ‐ Yes

SAARI JAMES R+JOYCE M 4050 12357 BIG LEAF WAY NE Vashon C 7/26/2005 20 2 9 ‐ Yes 20 Yes

SACKMANN ROBERT W+DOROTHY C 6220 12748 ADAIR CREEK WAY NE Hemlock C 4/1/2008 22 2 29 2 20 Yes

SADLER RICHARD C+CHERYL L ‐FAMILY TRUST 4060 23145 NE DEVON WAY Whidbey C 7/11/2006 22 4 3 2 ‐ Yes

SALDANA ELLEN 2030 23815 NE SALAL PL Discovery A 6/6/2007 13 2 ‐ ‐ ‐ Yes

SALVATORI PHILIP C+CONSTANCE M 6220 12299 235th PL NE Hemlock A 5/7/2002 27 2 ‐ 2 Yes ‐ Yes

SANBORN JAMES C+E SUE 6220 23828 NE 127th ST Hemlock B 5/6/2008 42 2 ‐ 2 Yes

SANDEL WANTLAND+PHYLLIS 3320 12154 BIG LEAF WAY NE Union A 3/29/2005 26 2 3 ‐ Yes 24 Yes

SATHER JIM D and Barbara 6220 13418 MAHONIA PL NE Hemlock B 5/29/2007 48 3 ‐ 2 ‐ Yes

SCHAFF ANTHONY E+PHYLLIS M 4050 23115 NE DEVON WAY Vashon A 8/1/2006 20 2 1 3 ‐ Yes

SCHEUNEMANN ARTHUR C+MICHELLE E OWENS 3320 13705 MORGAN DR NE Union B 11/21/2006 21 3 ‐ ‐ 13 Yes

SCHMIDT IRENE M 2030 11612 239th AVE NE Discovery C 2/7/2002 13 3 13 2 Yes ‐ Yes

SCHULTZ ROBERT A 2030 23710 NE TWINBERRY WAY Discovery C 4/24/2007 13 2 13 2 ‐ Yes

SCHWARTZ MICHAEL+RENA 4050 12375 ADAIR CREEK WAY NE Vashon C 4/18/2006 17 2 9 ‐ Yes 27 Yes

SCOTT MARSHALL RALPH+GRACE LYNNE 6230 23319 NE 126th ST Maple B 10/7/2003 41 2 ‐ ‐ Yes 42 Yes

SETZER, SCOTT and WEBB‐SETZER, DENISE 6240 23779 NE GREENS CROSSING RD Cedar Prairie 9/12/2002 unk unk ‐ 4 Yes Yes

SHAEFFER DANNY A+DIANE M 4081 13254 228th PL NE Bainbridge Prairie 2/15/2005 21 2 ‐ ‐ Yes 20 Yes

SHAFFER JOHN G+ADRIENNE H 6240 13880 MORGAN DR NE Cedar Craftsman 11/14/2006 18 2 15 4 4 Yes

SHANNON JOHN C+SANDRA MICHELE 6540 12208 243rd PL NE Maryhill B 11/1/2005 43 5 12 ‐ Yes ‐ Yes

SHAW MARILYN T 6530 12628 239th PL NE Redford B 11/10/2011 1 ‐ ‐ ‐ 33 Yes

SHEARER DIANA G 4081 23428 NE 131st PL Bainbridge Craftsman 3/9/2004 17 2 ‐ ‐ Yes 7 Yes

SHEERAN ELIZABETH 3330 13771 MORGAN DR NE Sammamish A 7/25/2006 22 2 2 2 Yes

SHELDON CHRISTOPHER M+REBECCA J 4091 12542 230th PL NE Vancouver B 6/24/2003 20 3 9 ‐ Yes 40 Yes

SHIFLET JERRY W+ARDIS 2040 13253 230th PL NE Orchard C 12/2/2003 9 3 13 2 Yes ‐ Yes

SHOULTS JAMES O+DONNA M 4081 24173 NE 131st TER Bainbridge Prairie 9/29/2007 3 1 ‐ ‐ 22 Yes

SHRIVER DAVID+SHARON 4060 13580 ADAIR CREEK WAY NE Whidbey B 5/9/2009 22 3 12 2 28 Yes

SHRIVER HARRY J 6220 23124 NE 123rd ST Hemlock C 1/10/2002 32 1 29 2 Yes 25 Yes

SHTEYNBERG MARGARITA+SHTEYNBERG MIKHAIL 2030 11667 239th AVE NE Discovery B 4/18/2002 14 2 ‐ 2 Yes Yes

SHYNE KEVIN T+FRANCINE C 6250 23744 NE 116th PL Alder Craftsman 2/28/2002 34 2 22 3 Yes 25 Yes

SIEFKES HERBERT W+LOIS E 4081 23026 NE 139th CT Bainbridge Prairie 5/9/2006 18 2 ‐ ‐ Yes 24 Yes

SIEW CHAKWAN+SIEW MABEL CHIA‐HSIN 6240 13847 231st LN NE Cedar Prairie 12/5/2006 33 2 ‐ 4 ‐ Yes

SIGL JACOB A+OLGA ANNE SIGL 6220 12510 237th WAY NE Hemlock A 2/11/2003 28 2 ‐ 2 Yes ‐ Yes

SIMMONS CAROL 4060 23971 NE GREENS CROSSING RD Whidbey C 6/1/2012 ‐ 1 3 2 Yes

SIMMONS F C 6510 22857 NE 138th CT Monticello B 10/17/2006 19 4 7 2 Yes

SMILOW ROBERT C+JEANIE L 3320 12420 240th PL NE Union A 4/21/2011 ‐ 2 3 ‐ 24 Yes

SMITH DONALD L+F ERNESTINE 4050 22862 NE 128th PL Vashon C 5/17/2005 18 2 9 ‐ Yes 21 Yes

SMITH KIM W 2030 13272 230th Pl NE Discovery C 12/2/2003 16 2 13 2 Yes ‐ Yes

SOKOL FRANKLIN P+VIRGINIA M 2040 11672 239th AVE NE Orchard C 3/12/2002 10 1 13 2 Yes ‐ Yes

SOKULSKI MARTIN P+RACHELE A 2030 13241 239th WAY NE Discovery B 5/22/2008 3 1 ‐ 2 28 Yes

SOMERS ARNOLD 4081 11815 242nd PL NE Bainbridge Prairie 9/6/2005 21 2 ‐ ‐ Yes 22 Yes

STAAB WILLIAM M 4081 12907 SUNBREAK WAY NE Bainbridge Cottage 2/1/2005 22 1 ‐ ‐ Yes 18 Yes

STEIGER WILLIAM H+SANDRA N 4060 24169 NE 122nd ST Whidbey C 10/28/2005 18 3 3 2 Yes ‐ Yes

STEPHENSON MICHAEL J+CAROL K 6540 11813 239th AVE NE Maryhill A 4/2/2002 unk unk 3 ‐ Yes Yes

STEVENS PAUL R 3320 12617 SUNBREAK WAY NE Union B 3/4/2004 21 3 ‐ ‐ Yes 12 Yes

STEVENS PAUL R+PATRICIA A 6540 12342 232nd TER NE Maryhill A 8/26/2003 48 5 3 ‐ Yes 100 Yes

STRAINER MICHAEL T+ROEHRIG JUTTA 4060 23054 NE 130th ST Whidbey B 3/23/2004 16 2 12 2 Yes 23 Yes

STROH REVOCABLE LIVING TRUST 6220 12449 ADAIR CREEK WAY NE Hemlock B 3/25/2008 32 2 ‐ 2 10 Yes

STUMPF EUGENE J+ELLEN T+STUMPF FAMILY TRUST 6540 11821 239th AVE NE Maryhill C 4/2/2002 53 5 ‐ ‐ Yes 48 Yes

SUTHERLAND DAVID R+MARION M ‐TRUSTEES 4091 11669 238th PL NE Vancouver C 4/9/2002 15 1 5 ‐ Yes ‐ Yes

SWANGARD TREVOR M+MARIANNE L 4081 23146 NE 128th PL Bainbridge Prairie 4/21/2004 21 2 ‐ ‐ Yes 20 Yes

SWANSON CORNELL K+SHIRLEY K 4081 23138 NE 128th PL Bainbridge Craftsman 4/13/2004 19 2 ‐ ‐ Yes 7 Yes

SWEATTE J SHANNON+JANET E 2050 12418 232nd WAY NE Madison A 12/31/2002 unk unk ‐ 2 Yes Yes

SWEET TOM+JOAN 6220 24132 NE 131st TER Hemlock C 8/23/2007 26 4 29 2 14 Yes

SWENSON DONALD+BARBARA 2030 13218 SUNBREAK WAY NE Discovery C 2/10/2004 16 2 13 2 Yes ‐ Yes

SWOFFORD GARY+DIANE 4081 23049 NE 127th WAY Bainbridge Craftsman 5/11/2004 19 2 ‐ ‐ Yes 15 Yes

SYLVESTER MARILYN J 2030 22851 NE 128th PL Discovery B 9/28/2004 unk unk ‐ 2 Yes Yes

SZYMANSKI SYLVIA A 3320 12727 ADAIR CREEK WAY NE Union A 4/15/2008 unk unk 3 ‐ Yes

TALBOTT JUDY L 2050 13715 231st LN NE Madison C 4/25/2006 40 2 11 2 Yes ‐ Yes

TAUBER RICHARD N+BARBARA A 6240 11842 BIG LEAF WAY NE Cedar Craftsman 1/11/2005 21 2 15 4 Yes 30 Yes

TAY AYE AYE L+CHLOE F 4081 12389 BIG LEAF WAY NE Bainbridge Craftsman 9/20/2005 19 2 ‐ ‐ Yes Yes

TAYLOR LIVING TRUST 2050 12429 243rd PL NE Madison C 5/6/2008 8 2 11 2 ‐ Yes

TESSMER DAVID D 4081 12716 SUNBREAK WAY NE Bainbridge Cottage 5/17/2005 22 2 ‐ ‐ Yes 13 Yes

THOMPSON BRUCE D+RHODA 2040 23611 NE 135th WAY Orchard C 2/9/2006 12 3 13 2 Yes ‐ Yes

THOMPSON WILLIAM G+JUDITH L 4091 23056 NE 127th WAY Vancouver B 6/15/2004 unk unk 9 ‐ Yes Yes

THOMSON MATTHEW WILLIAMS+GRACE 2030 24515 NE VINE MAPLE WAY Discovery A 2/15/2005 17 2 ‐ ‐ Yes ‐ Yes

TICE GERALD FRANK & JANICE F ‐FAMILY TRUST 6240 13318 239th WAY NE Cedar Prairie 5/22/2007 32 3 ‐ 4 38 Yes

TIMPE WALTER K+KATHRYN J 2040 23712 NE SALAL PL Orchard B 6/6/2008 14 3 ‐ 2 ‐ Yes

TOOLEN FAMILY TRUST 6540 22865 NE 138th CT Maryhill B 10/10/2006 45 5 12 ‐ ‐ Yes

TREMAIN MARY 2050 24312 NE 123rd LN Madison C 10/6/2007 39 3 11 2 ‐ Yes

TRIMBLE THOMAS H 2030 13226 SUNBREAK WAY NE Discovery B 2/10/2004 14 2 ‐ 2 Yes 28 Yes

TSCHUMPER REVOCABLE TRUST 2040 23847 NE 124th TER Orchard A unknown 2 2 ‐ 2 46 Yes

TSUJI FAMILY TRUST 4091 13449 MAHONIA PL NE Vancouver C 4/3/2007 18 2 5 ‐ ‐ Yes

TUGGLE JAMES B+JOYCE F AND VAAGA PER + KATHRYN 6510 12328 235th PL NE Monticello C 10/22/2002 15 2 ‐ 2 Yes Yes

TURNER CHARLES H 4081 11813 BIG LEAF WAY NE Bainbridge Cottage 7/19/2005 unk unk ‐ ‐ Yes Yes

TURNPAUGH LISA+TIM 6230 24526 NE VINE MAPLE WAY Maple A 10/11/2005 26 3 ‐ 1 Yes Yes

UTTER BRENDA G 4091 11734 239th AVE NE Vancouver A 1/15/2002 unk unk 5 ‐ Yes Yes

VALENTINE REX C+KEIKO 6540 13939 MORGAN DR NE Maryhill A 10/5/2006 26 2 3 ‐ 82 Yes

VALUCH DIANNE S+THOMAS L 2050 11741 239th AVE NE Madison C 1/3/2002 35 2 11 2 Yes Yes

VAN PAEMEL FRANCES C TRUST 4060 23763 NE 134th ST Whidbey C 2/6/2007 unk unk 3 2 Yes

VAN PATTEN MYUNG JA KIM 6220 24420 NE VINE MAPLE WAY Hemlock C 6/28/2005 27 2 29 2 Yes 25 Yes

VANDERSTOEP PAUL E+KAREN 4050 13262 228th PL NE Vashon A 10/5/2004 20 2 1 3 Yes ‐ Yes

VANDERSTROOM ARIE PIETER+MAGDA JOHANNA 6510 22836 NE 126th ST Monticello B 3/30/2004 unk unk 7 2 Yes Yes

VONNAHME NEIL L+DENISE S 6220 12240 243rd PL NE Hemlock C 8/16/2005 29 ‐ 29 2 Yes 21 Yes

VOORHEIS ALAN E+JANICE 3320 13846 231st LN NE Union A 11/7/2006 26 2 3 ‐ ‐ Yes

WADE RICHARD L+SUSAN L 6510 12714 232nd PL NE Monticello B 3/16/2004 20 2 7 2 Yes 12 Yes

WAITE RUSSELL T+MARILYN P 3340 24179 NE 131st TER Washington B 6/26/2007 23 2 ‐ ‐ ‐ Yes

WALLACE ROXANNE L 4060 23543 NE 122nd CT Whidbey B 7/2/2002 22 4 12 2 Yes 27 Yes

WALMAR MARY 4084 23842 NE 126th PL Nice Prairie 9/20/2012 2 1 ‐ 1 28 Yes

WALSH JOSEPH T+ELIZABETH C 2050 11717 239th AVE NE Madison B 2/21/2002 23 2 ‐ 1 Yes 10 Yes

WARREN SCOTT E 2020 23650 NE TWINBERRY WAY Townsend C 2/20/2007 unk unk 13 1 Yes

WARREN STANLEY D+PATRICIA A 6220 23327 NE 126th ST Hemlock B 9/2/2003 47 2 ‐ 2 Yes 24 Yes

WASSERMAN PETER B+BARBARA A 6240 24590 NE VINE MAPLE WAY Cedar Prairie 5/24/2005 31 2 ‐ 4 Yes 53 Yes

WATENPAUGH KEITH+JOYCE 6230 23983 NE GREENS CROSSING RD Maple B unknown 24 2 ‐ ‐ 34 Yes

WECKER JAMES C 4060 23754 NE SALAL PL Whidbey C 4/11/2006 22 3 3 2 Yes ‐ Yes

WEDELL LIVING TRUST 2030 24327 NE VINE MAPLE WAY Discovery A 7/21/2005 16 2 ‐ ‐ Yes ‐ Yes

WEHNER STEPHEN J+ANDREA K 2020 23692 NE TWINBERRY WAY Townsend A 4/24/2007 13 2 ‐ ‐ ‐ Yes

WEINBERG JANICE T 4060 24550 NE VINE MAPLE WAY Whidbey B 5/14/2005 23 2 12 2 Yes 28 Yes





TABLE OF PLAINTIFFS

Owner

Shea Plan


Date

Permited

Total

Windows

Unflashed

Total

Doors

Unflashed

Total

Corbels Not

Flashed By

Shea

Defective

Columns

Defective

Garage

Slab

Lineal Feet of

Defective

Wainscott

Unflashed

Patio/DeckWERTZ JOHN C + RAMONA 4081 24558 NE VINE MAPLE WAY Bainbridge Prairie 6/7/2005 21 2 ‐ ‐ Yes 21 Yes

WHEELER SUSAN C 2010 23832 NE 116th PL Angeles American Traditional 4/18/2002 10 3 ‐ ‐ Yes ‐ Yes

WHELAND DANIEL J+SUSAN C SCHUTTE 6220 12607 ADAIR CREEK WAY NE Hemlock C 7/7/2011 ‐ ‐ 29 2 23 Yes

WHITE ANN RHODES+BANICK RONALD G 6230 12232 243rd PL NE Maple B 8/2/2005 44 2 ‐ ‐ Yes 32 Yes

WHITE EVERETT ROY+BETTY‐ELAINE 2030 24157 NE 131st TER Discovery C 9/29/2007 8 1 13 2 ‐ Yes

WILDERMAN JOSEPH MICHAEL+ROBERTS JACQUELINE K 6240 11707 238th PL NE Cedar Craftsman 4/9/2002 17 1 15 4 Yes ‐ Yes

WILLINGHAM JUDITH L 3320 13673 MORGAN DR NE Union A 12/19/2006 18 2 3 ‐ 28 Yes

WILSON HAROLD R+STEPHANIE KING WILSON 6510 23782 NE GREENS CROSSING RD Monticello B 3/25/2003 22 2 7 2 Yes 10 Yes

WILSON MARLIN F+ALICE E 6220 12274 235th PL NE Hemlock C 6/11/2002 30 2 29 2 Yes 21 Yes

WILSON NANCY P 4050 23752 NE TWINBERRY WAY Vashon A 1/9/2007 20 2 1 3 ‐ Yes

WILTON JOSEPH C JR+PAMELA P 4081 23053 NE 128th PL Bainbridge Prairie 10/5/2004 17 2 ‐ ‐ Yes 25 Yes

WOODCOCK JOHN E+JOANNA G 6220 23121 NE 124th PL Hemlock C 1/28/2003 28 3 29 2 Yes 25 Yes

WRIGHT BETTY B+TERRY L 3320 13411 ADAIR CREEK WAY NE Union B 1/24/2007 unk unk ‐ ‐ Yes

WRIGHT PAUL J JR+NANCY T 6220 24180 NE 131st TER Hemlock C 9/11/2007 10 1 29 2 20 Yes

WRIGHT ROBERT W+BARBARA C 4091 22885 NE 129th PL Vancouver C 5/17/2005 17 1 5 ‐ Yes 3 Yes

YOUMANS FREDERICK+MARY 2020 11648 239th AVE NE Townsend C 5/2/2002 13 1 13 1 Yes 10 Yes

YOUNG DONALD E+YOUNG NANCY C 6220 12457 ADAIR CREEK WAY NE Hemlock A 6/14/2012 6 1 ‐ 2 2 Yes

YOUNG ROBERT C+NANCY A 6220 12333 235th PL NE Hemlock C 8/22/2002 27 2 29 2 Yes 20 Yes

ZAMBROWSKY SHEILA I 3310 23107 NE 128th PL Chelan Craftsman 6/15/2004 12 2 ‐ 2 Yes ‐ Yes

ZANIKER ELEANOR H 3320 24314 NE VINE MAPLE WAY Union A 11/1/2005 24 2 3 ‐ Yes 30 Yes

ZIMMERMAN RONALD S+JUDITH K 6240 23628 NE 135th WAY Cedar Craftsman 9/26/2006 14 2 15 4 6 Yes

ZYTKOWICZ NANCY 3320 23037 NE 128th PL Union A 8/10/2004 24 2 3 ‐ Yes 33 Yes




case 2:14-cv-01566 document 1 filed 10/10/14 page 1 of...

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