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Appellants Exhibit 22 (as referenced in June 30, 2017 Appellant WPDC Cleveland LLC's Witness and Exhibit List) ---PAGE BREAK--- 1 FILED 09 JAN 20 PM 2:54 CLERK 2 3 4 5 6 7 8 9 SUPERIOR COURT OF WASHINGTON FOR KING COUNTY 10 0 ')no.2 - 0 RAIN CITY DEVELOPMENT, LLC, a Washington limited iiability company, Plaintiff, ® 6 2 - 3 SEA r>O 11 SUMMONS 12 13 vs. SHILLA INCORPORATED, a Washington corporation, PACIFIC UNION BANK, HANMI BANK, 14 15 Defendant. 16 TO THE DEFENDANTS: A lawsuit has been started against you in the above-entitled court by plaintiff above named. Plaintiff claim is stated in the written complaint, a copy of which is served upon you with this>s.ummons. In order to defend against this lawsuit, you must respond to the complaint by stating your defense in writing, and serve a copy upon the person signing this within twenty (20) days after the service of this summons, excluding the day of service, or a default judgment may be entered against you without notice. A default judgment is one where plaintiff entitled to what ask for because you have not responded. If you serve a notice of appearance on the undersigned person, you are entitled to notice before a default judgment may be entered. You may demand that the plaintiff file this lawsuit with the court. If you do the demand must be in writing and must be served upon the person signing this SUMMONS -1 17 18 19 20 21 summons 22 23 24 25 so, Kiilicfa, La Porte, 'West&Lockner,P.S. 524 Tacoma Avenue South Tacoma, Washington 98402 (253) 383-4704 ORIGINAL Appellant WPDC Cleveland's Exhibit 22 - Page 1 of 5 ---PAGE BREAK--- V summons. Within fourteen (14) days after you serve the demand, the plaintiff must file this lawsuit with the court, or the service on you of this summons and complaint will be void. 1 2 If you wish to seek the advice of an attorney in this matter, you should do so so that your written response, if any, may be served on time. This summons is issued pursuant to Rule 4 of the Superior Court Civil Rules of the state of Washington.* ^ 3 4 5 6 day of January, 2008. KRILICH, LA PORTE, WEST & LOCKNER, P.S. DATED this 7 8 9 10 c By Thomas G. Krilich,'WSSa'#2973 Attorney for Plaintiffs 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 SUMMONS -2 Krilich, La Porte, West & Locknef, P.S. 524 Tacoma Avenue South Tacoma, Washington 98402 (253) 383^704 Appellant WPDC Cleveland's Exhibit 22 - Page 2 of 5 ---PAGE BREAK--- 4^ 1 2 3 4 5 6 umbdbi 7 8 9 SUPERIOR COURT OF WASHINGTON FOR KING COUNTY 10 RAIN CITY DEVELOPMENT, LLC, a Washington limited liability company, Plaintiff, 1lf9-8 -089 62-.3 gM' ' COMPLAINT TO QUIET TITLE BY ^ ADVERSE POSSESSION 11 12 13 vs. SHILLA INCORPORATED, a Washington corporation, PAClFiC UNION BANK, HANMi BANK, 14 15 Defendant. 16 COMES NOW the piaintiff, and for cause of action against the defendant alleges 17 as follows: 18 L 19 Plaintiff Rain City Development, LLC is a Washington limited liability company having paid all licenses and fees due the state of Washington. 20 21 II. 22 Defendant Shilla Incorporated is a Washington corporation which does business in King County, Washington. 23 24 25 COMPLAINT TO QUIET TITLE BY ADVERSE POSSESSION - 1 KriKch, La Porte, West ScLockner, PS. 524 Tacoma Avenue South Tacoma, Wa^hin^oa 98402 [253) 383-4704 ORIGINAL Appellant WPDC Cleveland's Exhibit 22 - Page 3 of 5 ---PAGE BREAK--- 1 III. 2 Plaintiff is the legal owner and fee title holder of certain real property in King County legally described as: The south 60 feet of Lot 1, Block 6, as measured along the westerly line of said lot, Town of Redmond, according to the plat thereof recorded in Volume 7 of plats, page 74, records of King County, Washington. King County Tax Parcel No, [PHONE REDACTED]-08. 3 4 5 6 7 IV. 8 Defendant Shilla Incorporated is the owner of property in King County legally g described as: 10 Lots 1, 2, and 3, Block 6, Town of Redmond, according to the plat recorded in Volume 7 of plats, page 74, in King County, Washington, except the south 60 feet of Lot 1, records of King County, Washington. King County Tax Parcel No. [PHONE REDACTED]-07. 11 12 13 V. 14 Plaintiffs above described property is improved with a concrete commercial building which encroaches upon defendant’s Lot 1 on the north and defendant’s Lot 2 on The said concrete building has encroached onto defendant’s legally described property for more than 50 years. 15 16 the south. 17 18 VI. 19 The encroachment of said building has been open, notorious, and hostile. 20 VII. 21 Plaintiff is entitled to have title to the encroaching portion of the building quieted against the interest of defendant or anyone claiming by, through or under it. 22 23 24 25 COMPLAINT TO QUIET TITLE BY ADVERSE POSSESSION -2 Kdich, La Poite, West & Lockner, P.S. 524 Tacoma Avenue South Tacoma, Washington 98402 (253) 383.4704 Appellant WPDC Cleveland's Exhibit 22 - Page 4 of 5 ---PAGE BREAK--- vm. 1 Plaintiff is also entitled to have a reasonable area around the north and west side of the building, at least five feet in width, for access for maintenance and repair of their building. 2 3 4 IX. 5 Defendant Pacific Union Bank has an interest in defendant's real property as a result of a deed of trust dated November 16, 2000 and recorded under King County Recording No. 20001127000101. 6 7 8 X. 9 Defendant Hanmi Bank has an interest in defendant's real property as a result of deed of trust dated August 6, 2004 and recorded September 2, 2004 under King County Recording No. 20040902000954. WHEREFORE, plaintiff prays for judgment against defendant quieting title to that portion of Lots 1 and 2 of Block 6 upon which plaintiffs building encroaches against the interest of defendant, together with a reasonable area adjoining the building for access to the building for the purposes of maintenance and repair. Said judgment should be entered against the named defendant and anyone claiming by, through, or under it. Plaintiff also prays for, such costs and fees as are allowed by law. day of January, 2009. 10 11 a 12 13 14 15 16 17 18 DATED this 19 KRILICH, LA PORTE, WEST & LOCKNER, P.S. 20 21 22 'I 23 Thomas G. KrilicVi.^'^SBA Attorney for Plaintiffs 24 25 COMPLAINT TO QUIET TITLE BY ADVERSE POSSESSION -3 Krilich, La Poite, West & Locknec, P.S. S24 Tacoma Avenue South Tacoim, Washington 98402 (253) 383-4704 Appellant WPDC Cleveland's Exhibit 22 - Page 5 of 5