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1030 EUCLID AVE.PDF11111111111111 11244 1030 EUCLID AVE TO: Initial Date a i s 2. 3. 4. S. Message: S TR SET � lLE From: /, Date: ' 7 3 E-7-72 G` of t APPLICATION and/or CHANGE ORDER`S - _ _=_r'✓ �l EDMONDS WATER DEPARTMENT u L 3 ' C 1573 1. - \ Date y� / Acct. Nol I hereby apply for the use of water in accordance with all rules and regulations of the City Water Department and the Eomonds City Code. This form properly executed and signed by the owner or his agent and filed with the Edmonds Water Department consti- i \ � es a proper notice of change of occupancy or mailing address for the property herein described. P� OFFICE RECORD `- MASTER DA DB DC DD - MASTER CHANGE ACTIVATE vl ADDRESS CROSS FILE - ALPHA NEW OCCUPANT f /Meter Book \/'On�, T' FLO ase ripfj r', i Date - SIGN HERE � •C � �'!-LS, New Deter S Size Mailing address if other than above Rental Deposit S_ ALL BILLS ARE DUE AND PAYABLE 10 DAYS AFTER BILLING DATE. Sr9FfJFkE r A STREET FIDE JUNE 1.7, -1.973 CITY OF EDIPUNDS PUBLIC '-,Cr-,xS 200 Dayton Ave. Edmonds, Wash. Dept. of Public :works: You are hereby notified as cf June 21, 1973 as per conversation by phone that the legal owner of property at 1030 Euclid Street has ordered a reading of meter and shutoff of water. There shall be no additional respcnsibilty or libelity for payment by owner as of this date. If this bill is past due for a. period exceeding 60 days the legal owner is demanding sutoff as per city ordinance. Any question regarding this action may be directed to LEVY JC�E STOh, 774-6677 ettcrney. LAREY R. nIRVd legal owner, STD •� t EDf,AO, .r.15 A-aTr:t, uE_: r=,,; ,"A..NT c" �1--Z Cats_ / _ � Acct. No. -/-- - Meter Number PreVi0U5 Reading Meter Book T/On T/Off _.�sy occuPANr _ C� (Please print) —i pate i Met enra n Sc-nd Closing ic> - — ---- -- - --- -f f co ` WASNINGTON (Jc + C - Box 427 ; `,�_ a �, 4 - Shaw Island, Wn. z ) N ` OD - ISENNBWEA'USASA 191 46L9�g' URN POW CITY OF EDMONDS PIQUUM DEPARTMETIT OF PUBLIC WCRKS 200 Dayton Ave. ` Edmonds. Wash. 98020 ' -10 r ' !1 i I I 8606 oa 1l d Ixr 1 25 2-41 'f}c�v3� 'PRo^ac,s r R per, r-1 a r� s0/ *I -XI s i I C,I,q(3tqiy-1 -30 N ),03o QA&A P � r LOT ISO a N 7, i. 2115' �7-c�'TS I oL 1 v� Z> The City of Edmonds OWNER G APPLICATION for SIDE SEWER PERMIT NEW CONSTRUCTION ❑ REPAIRS ❑ iq EASEMENT No........................................... x- ,,0 /Dc--, f9 CONTRACTOR. ` ----- ram ---------------- -------- •-•-- PERMIT No. ...... EGAL DESCRIPTION: LOT No...J ..... BLOCK No. .7 J................................ NAME OF ADDITION PQ-SiA' Lly�K-ftrc��i� } -_cam 5 (1.. ................................................ AP? ()VED f Approved: DATE ...(Z) ...1...-...�9------------ V��. �.._ .... r.... CITY OF EDYMONDS` pall PRospeet 6-1101 when work NTER — WATER -SEWER DEP2iRTMENT is ready for tnapectton. (No inspe� T 2401 CIVIC CE .. - tions Saturday, Sunday or holldaSs.) 56®E SEER PER--------------------------------------------- ►d�IT: • ---- -- AIDDRESS.--------- T03:Q:. Ec11: venue = ` Lee Woole �y Birum----------------------------------- = coNTRAC'1'OR y OwNER.._ ..Carr July-?7________________ ___ _.------ days to REPAIR or CONNECT a side sewer n .19 67 , for Permission is ted -------------- with City Sewers'": accordance with application . an file and governing ordinances. ATTEPITION IS CAIJ,ED TO THE FOLLOWING: of sewer before it has been inspected. NOTE No. 1—The owners of the Property may obtain a.permit to construct sewer inside property line. A licensed Side Sewer Contractor must be employed to construct side sewer in street area. Do not cover any portion _ NOTE No. 2—Obtain :'full information regarding .Ordinance 11.16.030 and Regulations governing side sewers when You get Permit NOTE No. 3—Top of- side sewer must have at least 30 inches coverage at property line and 12 inches inside property line; minimum grade of 2%. No bends in grade sharper than % will"be permitted. NOTE No. '4—Trenches, in street must, be water settled "and surface of street restored to original condition. Contractors shall be responsible for failure due to•.improper work which may .develop within one year of completion. NOTE No. 5--It is es unlawful to insert the pipeithe the work than is provided for in the permit, or to do any work on the main sewer or its appur- 4 40 (5 7 th mth for (jjjRjfjj.".Lj If z 01101 J-1.,y Iv. STIORT and JOA?,\jN A° 0110- vi 11LIShand and wife, Plaintiff vs. TIARIRY R. BiRUM and MARY K. B I IRUl'.j, husband and wife 7HE C:El'y OF LEVY I I 1'7ASf!INGTONJ, -.UI'VY S. and JANE DOE /C� J0'11"'STO,'T, husband and wife, Wn A till 11 Defendants THE STATE OF WASHINGTON, to the said hisl�and and Fife,THE CITY LARRY'R. and JAONDSINGRTUO and hIARYEjOjjNSj,ONh,S11NV o _ ,hand and wife.SJOUNSj�ol YOU ARE HEREBY SUMMONED to appear within 20 days after se3.%,icc_ of I this summons, or I within',':60 . clays -if served I ou,-si&e_tj,.ja State .-of Washington ,, exclusive of the -13Y of service, and'defend the abo've *entitled action by serving a copy of Your �vrit,en a:lsvier III) L on the undersigned.' if you fail to appear and defend, judgment will <ainst You, according to the rendered q,,- •e demand of the corilplaint, which has been or will be fj Vdt-� the led court, a cOPY Of which is herewith served u Pon YOU. KAFE.TZ, GISSBr,,RG & WILSON �BY: DICK E. SCOTT Attorneys forthePIai_ntjff___.__ DICK E. SCOTT' Kafer, Giss,,-)ez_g & Wilson 2929 1? "t" nore Avenue Everett, Washington 932A, ALpir,c 9-7!88 I � II i Ii 2 i 3 SUPERIOR COURT OF WASHINGTON FOR SNOHOMISI-I COUNTY i {JAY W. SHORT and JOANN A. liSHORT, husband and wife, ) 5 Plaintiffs, N0. E IVS. ) I COMPLAINT I LARRY R. BIRWij and MARY K. ) iJ B RUI-1, husband and wife, r) E CITY OF EDMONDS, WASH- 9 �' f -llC j'ON , LEVY S . JOHNSTON and JAiII DOI, JOHNSTON, husband ) and wife, '`� ;i Defendants. ) li 13 j' COMES NOW the plaintiffs and for cause of action against .L 11 'I defendants alle`r'E allege: . i� 15 ' That the plaintiffs are husband and wife, and are residents 17 � of the County of Snohomish, � h, State of Washington; and that the is , defendants, LARRY R. BIRUM and MARY K. BIRUM, are husband - - i 19 wife Unc , and as such, constitute a marital community, and ;:fiat the acts complained of herein are the acts Of the said defendants 'and �� each Of them, and of the Znd community by them composed; and that 2 i E Vy S- JOHNSTON and JANE DOE JOHNSTON, his wife r �3 are husband and 24 I;''�'-z�e, and as such, constitute a marital community, and that th-! acts complained ` of herein are the acts of the said defenuants 9 5 i' .indi ;A V ually and of the community by them 2� jiCITY OF composed; and that the EDMONDS is 'II a Municipal Corporation. . IT That the plaintiffs are the contract vendees 29 recorded Januar y and under a contract 13th., n I �IOfficial as No. 2229214 in Volume 654 at Page 700 Redords of Snohomish sh County, wh h icsaid �Ithe house and lot contract effects at 1030 �^ 1' ... Euclid Avenue, Edmonds, Washington and i i I CO.NIPLAINT -1- KAFER, WILSON & LucIIINI Attnes at Law 2929 Wetmore, Everor Washington - 259-7188 S 1 Ilegally described as: 9 1 The northeasterly 103.25 feet of Lots'.. 3 �i and the northeasterly 103.25 feet of ,,14 and l� f 01e south- easterly 5 feet of Lot 16 all as Edmonds, Wash. in Block 41, No,-`h 4 ' of plats on per plat recorded in Volue 2 5 y, Washington. in SnohomishpCountS, records of Snohommish County, 6 III r That the defendants LARRY R. BIRUM and MARY K 11the contract vendors of the contract and 13IIZU`� (iYe b �' Property ,•._ � as referred to in the next Y cl�s� , zl�cd therein 9 I preceding paragraph., 10 II IV 11 ICI That notwithstanding the contract right of the plaintiffs to .. 12 i�peaceful and quiet possession of the demised i,defendant, BIRUM changed the locks on the premises, the 1� � said dwellin doors and fence of t:he 14 g house, effectually barring the plaintiffs ,dwelling house and refused to remove the from their 15 said locks Pi aintiffs to h causing the ' 16 have them removed to -their. damage ' $100.00 for the replacement of ' g �n the amount of Ile the said locks r together 1-�j th the 2S 11cost of the use ofother quarters, while having the locks cha-�gE,d, 19 I to theirtotal damage in the sum of $600 2(1 ' .00 `. I V 21 + That the defendant, LEVY S. JOHNSTON Ithe manager of the co acting in his capGcity as mmunit J Y affairs of himself and his wife 13 Ewell knowing that the dwelling house was Occupied ar.d �cupied b 2 'ordered and directed the CityY the plazntzf`s" 4 , of Edmonds to remove the water meter 3 I rrom the said dwellingr house and to shut cuff the water to the cl�f�ellin , ?S g house, and that th.e defendant, City of Edmonds 17 NWi.th the direction of the said LEVY . cornl_lzed, S JOHNSTON and did remo,J,2 the i 2.S II� wat^r meter and did turn off the water to the dw 29 ;j�t'ell knowing thatelling house, t''`=Y the plaintiffs had a vendee's I !s interest in the 3� �+ said dwelling. VI ' . ^2 ; That the plaintiffs have two minor Childre n, age three and four, i MdI?LAINT ,2, ' KA 19R, WILSON ' 'Attorneys at Law CiIINI - - '� 2929 Wetmore, 'Everett,, Washington — 259-7188 1 1 'and two other minor children, aye fourteen and fifteen; and that 2 they were required to haul water from Bothell: in order th L I the a �. 3 I plumbin might be utilized' and in order that sanitar > >-�, g g c1 _a using 4 might be accomplished, and that the said plaintiffs w-� L were wit, ,-hout ,5 irunning water for a space of five (5) days before the defendant o !,City of Edmonds, agreed to replace the water meter and to turn on the water on the 2nd da of Jul Y y, 1973; that at no time during R the times mentioned herein, were'the plaintif fs fs In default of 9 kheir water service charges, and.that I that all charges.were current at IO `all times; that the said defendants, efendants, and all of them, have been 11 of extreme'and ' outrageous co nduct'intentionally and'recklessl 12 'without due regard to the rights of others, which ha s as caused the 13 plaintiffs severe e �, motional distress `arid embanassment to the damage ' 4 14 of the plaintiffs in'the sum of FIFTY THOUSAND ($SO,OOO.G0 DOLLARS :. ; 15 � VII 16 That because of the reckless and outrageous conduct. of the 17 defendants;' and each of ,them; the plaintiffs ,were unable to show 1S the property to prospective purchasers, on account of which, the 19 plaintiffs have been unable to negotiate,a sale of the demised 20 premise to plaintiffs,'damage in the amount of ,SIXTY THOUSAND '+ 21000.00 DOLLARS. 22 F . VIII 23 That defendants,: by and.ihrough their attorney, defendan 24 t JOHNSTON, did deliver to plai.ntif f s' a Notice of Intention to De'clar 25 a Forfeiture and Cancel Contract, which' notice was dated June 15 th, ; 26 1973, requiring all payments.. 27 to be made cu rrerit on or before July 15th,' 1973; and, that .because o,f 'thle outrageous conduct of the said 2� Idefendants;•and each of them, that the said defendant M 29 '. BTRUM should ' jibe rc strained from effecting a;foreiture, and ` 36 r permitting the ¢ plaintiffs a reasonable•time within which'to .�1 11in sell the said property addition to the damages -to -be be awarded 2 ,I to the plaintiffs because (1of the outrageous conduct of the defendants. j COPIPI,AINT _ 3 KAFE$, [WILSON R LucurN, t2929 Wetmore, Everett, Washington — 259-7188 - i I, r 11 • � d d Ix 2 That because of the conduct of the defendants - 3 a d the conspiracy by them composed, tlle plaintiffs ntiffs hilvC beC., ' 4 ,humiliated, embarrassed, and the minor children haN7e sLifr (nesses, the exact extent of which is unknown 3 j� to the k; r 1Ji 4 �dh ch wi11 be delineated at the trial toibe , had in �his mat_tci- tc> 7 the financial damage of the plaintiffs and damacxe their to ' X That because of the acts complained of herein the r �•1 i.i ;�.� fs were required to and did employ an attorney to assist ther;t �i i getting possession of their home and in:obtainin r g runr. n 1'='ha4 the acts � complained of herein occassioned the em,i 3 Ilan attorney and that be of the outrageous conduct g of the 7 defendants the expense of the attorney r � 15 �+! y should be charged tc the 'de`endants to the damage of the plaintiff s in, the amount of One 10 Thousand ($1,000.00) Dollars. WHEREF''bRE,;plaintiffs pray for damages against the defendants 18 and each of them jointly and severally ari Y d against the cor.r,,u,,Ij ties 19 by them composed, and against the CITY ©p,, 0 EDMI NDS, a Munici al 20 `Corperatzo15 n, in the amount of $600.00 actual p 21 damage, for the sum of $50, 000'. 0,0 for humiliation and embarr E" assment, and the surz of ! $60,000.00 for the loss of a sale and $1,000.00 reasonable nab_e attorneys fees; and that the defendantsbe restrain w4 a ed from pur.;ing ,f forfeiture of the property for a period of ninety Y (90) days and that the" Plaintiffs be } per to have ninet ' w Ich to 's'm11 their. (90) days�w th hbme,and�fr such other and further relief as to the court seems k just and equitable in the premises. Dated this o f J u 1 y 1973. 20 kAFER, WIC; 0 �'��& LUCHINI 31 By -'i, K J'. A , i E: SCOTT Attorne y. r`P1aintiffs COS', PLAINT -- 4 = , I ` Karax, W' ILSON & LucfttNr AttOTUeys at LaIV 2929 Wetmore, Everett, Wa hittgton -- 259-7' 188 7 j1STATE OF WASHINGTON) 2 ICOUNTY OF 8NO110MISi-1) ss t 3 i J'OANN.A, SHORT, being first duly sworn on oath, deposes and 4 says: That*she is one of the plaintiffs herein; � that she has 5 +read the within and foregoing Complaint, knows the contents thereof. ;and believes the same � to be .true . • 7 8U33SCRIBED • AND SWORN to, be 10fore me this 'f , z! day of July, 1973. 12 c�tary Public in and fors the State of 13 '1`. W'ashin ton t . 5 :'residing at Everett.. 14 1. 15 18 17 ' t4 18 >.. 29. .21 ; 24 ,27 30 v2 COMPLAINT I . $�AFL'II,'WILSON Tt L UC,IrNI-Attorne. at Law 2929 SVetmore, Everett, tiVashin ton — 4� S 2597188