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IN THE SUPERIOR COURT OF THE STATE

OF WASHINGTON FOR THURSTON COUNTY


_____________________________________________________________________________
_

_____________________________________________________________________________
_
ARTHUR WEST )
plaintiff )
vs. )
NORTHERN SPOTTED OWL POLICY WORK GROUP, )
LOIS SCHWENNESEN, SCHWENNESEN )
ASSOCIATES, LLC, WASHINGTON STATE FOREST )
PRACITCES BOARD, WASHINGTON, STATE DNR, )
WASHINGTON STATE, KEN BERG, SHAWN )
CANTRELL, VICKI CHRISTIANSEN, MARK DOUMIT,)
KEVIN GODBOUT, DON HALABISKY, CHRIS )
LIPTON, BOB MEIER, BRIGET MORAN, VIC ) No.
MUSSELMAN, MIGUEL PEREZ-GIBSON, TOM )
ROBINSON, PAULA SWEDEEN, CHUCK TURLEY, ) PLAINTIFF'S
JOSH WEISS, PATRICIA ANDERSON, LENNY ) ORIGINAL
YOUNG, SEATTLE AUDUBOHN, WASHINGTON ) COMPLAINT
FOREST PROTECTION ASSOCIATION, )
WEYERHAEUSER, SIERRA CLUB CASCADE CPT, )
LONGVIEW TIMBERLANDS, LLC, RAYONIER, )
WASHINGTON STATE DEPARTMENT OF FISH AND )
WILDLIFE, WASHINGTON STATE ASSOCIATION )
OF COUNTIES, SWEDEEN CONSULTING, )
AUDUBOHN WASHINGTON, )
defendants )
________________________________________________)

I INTRODUCTION
1.1 This is an action for declaratory and injunctive relief and penalties in regard to
the actions of a sub-agency of the DNR and the Forest Practices Board, the Northern
Spotted Owl Work Policy Group, which has operated secretly and unlawfully, violated
environmental and sunshine laws and wasted over a quarter of a Million Dollars of
public resources on a fundamentally un-democratic consensus based process which has

PLAINTIFF’S ARTHUR WEST, 120 State Avenue N.E.


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ORIGINAL COMPLAINT Olympia, Washington 98501
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failed to produce any viable policy to prevent the extinction of the Spotted Owl, and
has instead resulted in increased destruction of habitat.
1.2 Plaintiff seeks to compel DNR, the Forest Practice Board, and the Policy
Group to comply with the State Environmental Policy Act, NEPA, the ESA, and the
Open Public Meetings and Public Records Acts. Plaintiff seeks penalties for violations of
the Open Public Meetings and public records Acts, and associated relief for negligence,
for negligent hiring, training, supervision, contracting, and retention, for unconscionable
contracting, and for conspiracy and collusion resulting in the deliberate concealment from
the public of the actions and procedure of the Northern Spotted Owl Work Policy Group,
and its Caucuses and facilitator. Declaratory and injunctive relief are also sought in
regard to preventing further violations and requiring a viable strategy be developed in a
legitimate public process to ensure the adoption of reasonable measures to address the
degredation of protected species habitat.

II PARTIES AND JURISDICTION


2.1 At all times relevant Arthur West resided in Thurston County, State of
Washington. He is a citizen, landowner, and voter with full civil rights, and has standing
to maintain this action in all particulars. He is an avid birdwatcher, with a demonstrated
connection to both the environment and the Northern Spotted Owl, as well as open
Government in the State of Washington.
2.2 Defendant Northern Spotted Owl Policy Work Group and its caucuses are
legislatively created “sub-agencies” and “governing bodies” of the DNR and the Forest
Practices Board as these terms are defined in RCW 42.30.020, and as such they, and
their facilitator are required to comply with the OPMA, PRA, and other laws noted here.
2.3 At all times relevant, the Washington State DNR was a State Agency required
to comply with all laws and regulations of the State of Washington, including the OPMA,
PRA, and other laws and constitutional provisions of Washington and the United States .

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ORIGINAL COMPLAINT Olympia, Washington 98501
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2.4 At all times relevant, defendant Washington State Forest practices Board was a
State Agency required to comply with all laws and regulations of the State of
Washington, including the PRA, OPMA, and other laws noted here.. The State of
Washington is a necessary party to a just adjudication of this action.
2.5 At all times relevant, defendants Lois Schwennesen, and Schwennesen and
Associates were contractually and lawfully compelled to act as the functional equivalent
of State Officers or Agencies required to comply with all laws and regulations of the
State of Washington, including the PRA, OPMA, and other laws noted here.
2.6 The State of Washington is a necessary party to a just adjudication of this
action.
2.7 Defendants Ken Berg, Shawn Cantrell, Vicki Christiansen, Mark Doumit,
Kevin Godbout, Don Halabisky, Chris Lipton, Bob Meier, Bridget Moran, Vic
Musselman, Miguel Perez-Gibson, Tom Robinson, Lois Schwennesen, Paula Swedeen,
Chuck Turley, Josh Weiss, Patricia Anderson, Vicky Christiansen and Lenny Young are
members or associates of the NoSOPWoG who deliberately violated the OPMA, PRA,
SEPA, and other “sunshine laws”, and conspired to conduct the affairs of government in
secret for private interests.
2.8 Defendants Swennesen and Associates LLC, Seattle Audubohn, Washington
Forest Protection Association, Weyerhaeuser, Sierra Club Cascade Chapter, Longview
Timberlands LLC, Rayonier, Washington Department of Fish and Wildlife, Audubon
Washington, WSAC, Swedeen Consulting, and the Washington Department of Natural
Resources are the government and corporate entities responsible for the conduct of their
agents on the NoSOPWoG under the doctrines of respondent superior and principal and
agent, and pursuant to the law of conspiracy.
2.9 All individual defendants are named in their personal, official, and
personal/official capacities.
2.10 The Thurston County Superior Court has jurisdiction over the parties and
subject matter of this claim by virtue it being a forum county, due to the jurisdictional

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ORIGINAL COMPLAINT Olympia, Washington 98501
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section of the personal services contract, the OPMA, the PRA, Article III, section 24 of
the Constitution of the State of Washington, and the Longarm statute.
2.11 All defendants, by their actions pursuant to a portion of the conspiracy, are
jointly and severally liable for the actions of all of the other defendants pursuant to the
ongoing conspiracy, regardless of their knowledge or participation in all of the events.
ALLEGATIONS
3.1 At all times relevant, the Washington State DNR was an Agency of the State
of Washington. The DNR has a policy, custom and usage, and a regular business practice
of fostering corporate insider policy formation and unconscionable contracts with private
entities such as Schwennesen and Associates and the WSAC to subvert the letter and
intent of the OPMA, the PRA, SEPA, the ESA, and the laws and regulations pertaining to
the forest practices board-to say nothing of the ancient and hallowed principles of
democratic government by the people. These business practices serve to allow the DNR,
the Forest Practices Board, and its agent the Northern Spotted Owl Work Policy Group to
conceal the operations of government in the formation of forest policy from the public in
an unlawful and unconscionable manner. Other similar DNR policy boards are also
defective and will be the subject of subsequent litigation.
3.2 Pursuant to this policy of insider policy formation and unconscionable
contracts in derogation of public policy, the DNR, on July 7, 2008, created by legislative
act the Northern Spotted Owl Policy Work Group. Subsequently, on December 1, 2008,
DNR, pursuant to a “partnership” agreement between the WFPA and Seattle Audubohn,
entered into an unconscionable contract (PS 09-135) to spend nearly a quarter of a
million dollars on a private “Facilitator” whose main responsibility was to veil the
operations of the NoSOPWoG from legitimate public oversight necessary for the sound
governance of a free society, and to subvert the traditional democratic adversarial
practice with a “new paradigm” of “facilitated” government and corporate consensus

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ORIGINAL COMPLAINT Olympia, Washington 98501
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strangely reminiscent of the “facilitated” “profitable cooperation” between political and
economic interests in a totalitarian regime1.
3.3 At all times relevant, Lois Schwennesen was a de facto public officer and a
“person” deliberately acting under color of law to conceal records and violate the OPMA,
PRA, ESA, and SEPA in order to conduct the affairs of the Northern Spotted Owl Policy
Work Group, and its caucuses, secretly and without public oversight on behalf of a small
group of insider politicos whose fanatical devotion to the religion of consensus was not
shared by the public at large.
3.4 At all times relevant, the individual defendants were Northern Spotted Owl
Task Force members acting pursuant to an undemocratic dogma of consensus and in
violation of the spirit and letter of the Open Public Meetings, Public Records Acts, and
other laws noted herein.
3.5 At all times relevant since May 26 of 2008, plaintiff West has been requesting
records concerning WSAC operations and the relation of WSAC to DNR. Since
November 24, 2010, he has been requesting records from DNR regarding WSAC. Since
February 1 of 2010 he has requested records from both DNR and Schwennesen and
Associates concerning the activities of the NoSOPWoG. All this time, defendants
WSAC, DNR, and Schwennesen and Associates have conspired to violated the PRA,
SEPA, and other “sunshine laws” in regard to reasonable disclosure by veiling their joint
activities under a screen of delay and private corporate involvement in DNR policy. At
all times relevant DNR and Schwennesen have unreasonably delayed disclosure, failing
to disclose records with the intent and effect of obstructing justice and denying due
process of law, since action has been taken by DNR in the absence of full disclosure.

1 See Nazi Culture: Intellectual, Cultural and Social Life in the Third Reich, edited by G.L. Mosse, 1966, at P.
328-332, and A. Hitler. "Mein Kampf," Munich: Franz Eher Nachfolger, 1930, Volume II, Chapter 4, ...As a
matter of principle, the folkish state does not tolerate asking advice or opinions in special matters -... It,
therefore, divides its representative bodies from the start into political and professional chambers. In
order to guarantee a profitable cooperation between the two a special senate of the elite always stands
over them.

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3.6 The Northern Spotted Owl Policy Work Group is an unlawful entity resulting
from an unconscionable contract in violation of public policy, and from a sham
settlement agreement entered into by parties without actual adverse interests, as
demonstrated by the “Partnership Principles” agreement entered into between Seattle
Audubohn and the Washington Forest Practices Association.
3.7 The Northern Spotted Owl Policy Work Group, (and its caucuses) are products
of a deliberate strategy by defendants to evade the OPMA, PRA, SEPA, ESA, and other
environmental and sunshine laws, and to allow a small circle of insiders to dictate forest
policy by consensus without adequate representation of adverse interests and public
oversight necessary to ensure that the proceedings were actually representative of the
public.
3.8 The 3 caucuses of the NoSOPWoG are further sub-agencies and boards subject
to the OPMA and these laws, that were created for the purpose of allowing secret
deliberations and action, as well as private consensus based policy in the absence of
public oversight and review.
3.9 The “private” facilitator of the NoSOPWoG is an unlawful feature of the group
designed to facilitate violations of the OPMA and the PRA and to keep the activities of
the work group out of the public eye. The agreement by Audubohn and the WFPA to
destroy evidence and waive their rights to request records about the policy group
demonstrates the unconscionable nature of the contract that authorized Schwennesen and
Associates to unlawfully act as a private front group to coordinate public process from
behind a veil of secrecy to prevent public accountability.
3.10 The contract to retain Schwennesen and to spend nearly a quarter of a million
dollars of public funds was unconstitutional and illegal and relied upon an improper
waiver of the moratorium on personal service contracts by DNR.
3.11 The Northern Spotted Owl Policy Work Group, as well as its caucuses, on
numerous occasions including December 16, 2008, January 9, 2009, Jan 12, Jan 13,
February 13 meeting, Feb 14, and Feb 17, violated the OPMA by meeting, deliberating or

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taking action outside of the context of a public meeting conducted with notice to the
Public. Many more violations will be shown when the records of DNR and Scwhennesen
are disclosed. In the absence of such records it is asserted that the Task force unlawfully
took action on each day that Schwennesen acted as a facilitator outside of the context of
an open meeting, on each and every day between January of 2009 and February 10, 2010.
3.12 On February 17, 2009, the NoSPOPWoG received a formal notice of their
responsibilities under the OPMA from AAG Wehling, Significantly, they continued to
violate the OPMA by acting and allowing their facilitator to act in violation of the law.
3.13 On many occasions that will be shown after discovery is complete and the
records of Schwennesen and Associates are disclosed, the NoSOPWoG members
attended and conducted meetings where action was taken in violation of the Open Public
Meetings Act, in that deliberations were not conducted openly, and the spirit and letter of
the act were otherwise violated. The NoSOPWoG also violated the act by unlawfully
excluding plaintiff by conducting their meetings at Weyerhaeuser headquarters when
RCW 42.30.030 requires that “All meetings ... shall be open and public and all persons
shall be permitted to attend.”
3.14 On or about December of 2008, and until the present day, defendant Lois
Schwennesen violated the OPMA by taking action on behalf of the NoSOPWoG secretly
in the false capacity as a “private” entity. During all of this time Schwennesen, the
NoSOPWoG, and DNR deliberately colluded to conceal public records of the policy
group with the intent of these deliberate illegal and concerted actions of defendants were
taken in combination and conspiracy.
3.15 At all times relevant, the corporate and agency defendants were guilty of
negligently hiring, training, supervising, and retaining their employees and contractors,
including the individual defendants.
3.16 At all times records have been withheld by the defendants with the intent and
effect of obstructing justice and denying due process of law.

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3.17 On February 10, 2010, defendants DNR and the Forest Practices Board took
action on recommendations by the NoSOPWoG, and adopted rules and policies in
violation of SEPA. Every recommendation of the NoSOPWoG and the other Forest
Practices policy boards has violated SEPA.
3.18 The defendants have a custom, policy, and usage of a system of unlawful
prior restraints, which is designed to prevent the exercise of federally protected rights of
freedom of expression, assembly, and petition for redress, access to information, and
public discussion of issues in accord with rights protected under the 1 st and XIV
Amendment and Article I of the State Constitution. This demonstrates extreme bad faith.
3.19 Defendant Weiss, individually, and as counsel for both WSAC and the
WFPA has orchestrated and participated in a pattern of secret policy formation designed
to evade the OPMA, PRA, and other laws noted herein, and has arranged for secret
meetings of policy making officials during working hours, and has acted to deny
disclosure of the public records necessary to bring the violations in this complaint to
light.
3.20 Defendant DNR has repeatedly entered into unlawful contracts with private
or quasi private corporations to allow the Forest Practices Board to conduct the public's
business behind a veil of secrecy and improper corporate influence Josh Weiss, Tom
Robinson, and WSAC have been instrumental in these illegal contracts, and WSAC and
Robinson have benefited from illegal contracts in violation of public policy.
3.21 Defendant DNR and the other public and private entities were negligent in
hiring, training and retaining, and are liable for the actions of their agents and employees,
which violated the OPMA, PRA, SEPA, NEPA, ESA, and the Forest Practices Act, as
well as the applicable regular and elevated standards of care applicable to environmental
organizations, attorneys and public counsel acting as representatives of the environment
or in a fiduciary capacity. All acts were taken pursuant to policy and under color of law.
3.22 In all of their acts and omissions, defendants and the No Spotted Owl Left
Alive Work Group acted deceptively, damaged plaintiff in the use and enjoyment of his

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ORIGINAL COMPLAINT Olympia, Washington 98501
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real property, violated a statute that contains a specific legislative declaration of public
interest impact; and/or Injured other persons; had the capacity to injure other persons; or
has the capacity to injure other persons.
3.23 Defendants jointly conspired to violate Article III, section 24 of the
Constitution of the State of Washington, by removing or causing the public records and
papers of the office of the Commissioner of Public Lands to be retained outside of the
seat of Government.

IV CAUSES OF ACTION
4.1 PUBLIC RECORDS ACT CLAIM
By their acts and omissions, the defendants WSAC, Swennesen Associates and DNR
violated, conspired to violate, and failed to act to prevent violation of the 1st Amendment,
Article 1, Sections 1, 4 and 5 of the State Constitution, Article III, section 24 of the State
Constitution, and RCW 42.56, the Public Records Act. Defendants failed to disclose,
and/or unreasonably delayed disclosure of WSAC, DNR and NoSOPWoG related records
with the intent and effect of violating RCW 42.56, and creating an interlocking system of
prior restraints, for which they are liable to plaintiff for the relief requested below.

4.2 OPEN PUBLIC MEETINGS ACT CLAIMS


By their acts and omissions, Lois Schwennesen, as a facilitator, and the individual and
corporate defendant members of the NoSOPWoG and its caucuses violated the Open
Public Meetings Act, by meeting, acting and deliberating outside the context of a proper
public meeting, and by a policy of acting by and through Schwennesen and associates for
which they are liable for the relief requested below.

4.3 UNCONSCIONABLE CONTRACT IN VIOLATION OF PUBLIC POLICY

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ORIGINAL COMPLAINT Olympia, Washington 98501
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By their acts and omissions, the defendants entered into, ratified, acquiesced to and/or
accepted benefits of unconscionable contracts between the DNR and the WSAC and
Schwennesen and Associates, for which they are liable for the relief requested below.

4.4 NEGLIGENT HIRING, TRAINING, SUPERVISION, CONTRACTING AND


RETENTION
By their acts and omissions defendants created a cause of action for negligent hiring,
training, supervision, contracting, and retention, in that they employed the NoSOPWoG
members after their unlawful propensities were apparent, damaging plaintiff, the public,
and the public's environment, and violating elevated standards of care necessary to
protect the Spotted Owl (and required by the ESA listing) which the defendants
voluntarily assumed, by their affirmative actions described in this case, for which they
are liable for the relief requested below.

4.5 CONSPIRACY
By their acts and omissions defendants entered into a conspiracy,damaging plaintiff, as a
taxpayer and citizen, for which they are jointly and severably liable for all of the actions
of each of the defendants, and for which relief should issue as requested below.

4.6 DECLARATORY JUDGMENT


By their acts and omissions defendants created an uncertainty in the conduct of public
officers, and the conduct of the NoSOPWoG, creating a cause of action for declaratory
judgment, for which relief should issue as requested below.

4.7 UNCONSTITUTIONAL EXPENDITURE OF FUNDS


By their acts and omissions defendants unlawfully and unconstitutionally expended
public funds, creating a cause of action for unconstitutional expenditures, for which relief
should issue as requested below. .Prior to filing this suit, plaintiff has requested action for

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this unconstitutional expenditure and the Attorney General has, so far, declined to act on
the request.

4.8 SEPA-CERTIORARI
By their acts and omissions the defendants NoSPOPWoG, its caucuses, the Forest
Practices Board and DNR acted unlawfully and in excess of their powers as an inferior
board or tribunal, and violated SEPA, damaging plaintiff and creating a cause of action
for review of the recommendations and actions of DNR and its sub-agencies by
certiorari and by the APA.

4.9 DECEPTIVE BUSINESS PRACTICES


By their acts and omissions the private defendants engaged in deceptive business
practices, attempting to monopolize forest policy formation, acting in restraint of trade to
promote pilot programs, damaging plaintiff and creating a cause of action for Deceptive
Business Practices..

4.9 42 USC 1983-5-8


By their acts and omissions the private defendants acted pursuant to policy, custom and
usage to deprive plaintiff of federally protected rights, invidiously, damaging plaintiff
and creating a cause of action for violation of federally protected rights, conspiracy to
violate such rights, and failure to act to prevent violation of such rights..

V PRAYER FOR RELIEF


WHEREFORE, plaintiff respectfully requests the following relief:
1. That an order issue under the seal of this Court declaring that the Northern Spotted
Owl Policy Work Group has violated the OPMA and that its facilitator,
Scwennesen and Associates has violated the PRA, pursuant to a deliberate joint
policy of secrecy and concealment perpetrated by all of the named defendants.

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ORIGINAL COMPLAINT Olympia, Washington 98501
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2. That an order issue under the seal of this Court ordering disclosure of public
records and finding that DNR, WSAC and Schwennesen, acting singly and/or in
concert and collusion unreasonably delayed disclosure in order to obstruct public
knowledge of their actions and deny due process of law.
3. That costs and penalties be awarded for the defendants' egregious and continuing
violations of the Public Records Act in regard to the concealment of the records
relating to WSAC, the Northern Spotted Owl Policy Group and DNR.
4. That the funds paid to Schwennesen and Associates, and any grants or
remuneration paid to the other NoSOPWoG participants be refunded to the State
5. That a declaratory ruling issue that the defendants and the NoSOPWoG members

violated the Open Public Meetings Act, that a civil penalty of $100 be assessed
against each individual violator for each meeting or action taken by the group, its
caucuses, or its facilitator found to violate the act, that all actions taken at any such
“meeting” be voided, along with any rules, actions or de-certification of spotted
owl habitat based upon the recommendations of the NoSOPWoG, and that
defendants, and DNR be forever barred from further violations.
6. That an order enter under the seal of this court declaring that the NoSOPWoG has
failed to act in accord with the ESA, and requiring immediate suspension of
federal ESA funding to the State and the immediate adoption of measures to
protect spotted owl habitat.
7. That an order enter voiding any actions taken in respect to recommendations or
approvals of the NoSOPWoG by the Forest Practices Board and/or DNR on
February 10, 2010,.
8. That the defendants be held jointly and severably liable for the OPMA penalties,
and that plaintiff recover his costs and fees.
9. That an order of injunction issue immediately suspending any private timber
harvesting in Spotted Owl Habitat at has been authorized due to the delays or
recommendations of the NoSOPWoG, and forever barring the defendants from

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formulating Spotted Owl government policy by means of illegal contracts with
private entities, and/or in violation of the OPMA and PRA.
10. That plaintiff be allowed to supplement an d amend his complaint when
information becomes available, due to the defendant's policy of concealing
information and the interlocking system of prior restraints noted above.

DATED this 14th day of February, 2010.

_____________________
ARTHUR WEST

February, 2010
TO: WASHINGTON STATE ATTORNEY GENERAL
AND THURSTON COUNTY PROSECUTOR

RE: REQUEST FOR INVESTIGATION OF


UNCONSTITUTIONAL EXPENDITURE OF FUNDS

FROM: ARTHUR WEST,


120 State Ave. NE # 1497
Olympia, Washington, 98501

Please consider this a complaint for unconstitutional expenditure of funds by the

Washington State Department of Natural Resources in regard to illegal contracts with the

WSAC and Schwennesen and Associates, and a request for you to investigate and

maintain an action to recover the funds unlawfully expended to WSAC for an illegal

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interagency interlocal cooperation agreement, and the funds unlawfully expended in the

contract for personal services with Schwennesen and Associates.

The plain statement of the case is that these contracts are unlawful and in violation of

the laws regulating DNR and the the forest practices Board. In addition, it is very likely

that Northern Spotted Owl Policy Work Group and the rest of the DNR Forest Practices

Policy groups are similarly designed to expend public funds unlawfully, facilitate undue

private influence and violate the OPMA in other portions of their operations. If you

require any further information, please feel free to contact me.

Sincerely,

_________________
ARTHUR WEST

IN THE SUPERIOR COURT OF THE STATE


OF WASHINGTON FOR THURSTON COUNTY
_____________________________________________________________________________
_

_____________________________________________________________________________
_
ARTHUR WEST )
plaintiff )
vs. )
NORTHERN SPOTTED OWL POLICY WORK GROUP, )
LOIS SCHWENNESEN, SCHWENNESEN )
PLAINTIFF’S ARTHUR WEST, 120 State Avenue N.E.
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ORIGINAL COMPLAINT Olympia, Washington 98501
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ASSOCIATES, LLC, WASHINGTON STATE FOREST )
PRACITCES BOARD, WASHINGTON, STATE DNR, )
WASHINGTON STATE, KEN BERG, SHAWN )
CANTRELL, VICKI CHRISTIANSEN, MARK DOUMIT,)
KEVIN GODBOUT, DON HALABISKY, CHRIS )
LIPTON, BOB MEIER, BRIGET MORAN, VIC ) No.
MUSSELMAN, MIGUEL PEREZ-GIBSON, TOM )
ROBINSON, PAULA SWEDEEN, CHUCK TURLEY, ) PLAINTIFF'S
JOSH WEISS, PATRICIA ANDERSON, LENNY ) SUMMONS
YOUNG, SEATTLE AUDUBOHN, WASHINGTON )
FOREST PROTECTION ASSOCIATION, )
WEYERHAEUSER, SIERRA CLUB CASCADE CPT, )
LONGVIEW TIMBERLANDS, LLC, RAYONIER, )
WASHINGTON STATE DEPARTMENT OF FISH AND )
WILDLIFE, WASHINGTON STATE ASSOCIATION )
OF COUNTIES, SWEDEEN CONSULTING, )
AUDUBOHN WASHINGTON, )
defendants )
________________________________________________)

TO THE DEFENDANT:
A lawsuit has been started against you in the above entitled court by Arthur West,
plaintiff. Plaintiff's claim is stated in the written complaint, a copy of which is served
upon you with this summons.
In order to defend against this lawsuit, you must respond to the complaint by stating
your defense in writing, and by serving a copy upon the person signing this summons
within 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 is entitled to what he asks 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 so, the
demand must be in writing and must be served upon the person signing this summons.
Within 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.

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If you wish to seek the advice of an attorney in this matter, you should do so promptly
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. Done February 14, 2010, in Olympia, Washington.

____________
Arthur West

PLAINTIFF’S ARTHUR WEST, 120 State Avenue N.E.


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