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1 1.3 Defendant Golden Eagle Farms Ltd is a Washington corporation authorized to <br /> 2 <br /> do business in Washington state. <br /> 3 <br /> 1.4 This Court has jurisdiction over the subject matter of this case pursuant to <br /> 4 <br /> 5 RCW 2.08.010. <br /> 6 1.5 Venue is proper in Snohomish County pursuant to RCW 4.12.020 because the <br /> cause of action arose in Snohomish County. <br /> 8 <br /> 9 IL FACTUAL ALLEGATIONS <br /> 10 2.1 Lowell-Larimer Road is a City right of way containing City street and utility <br /> 11 improvements. <br /> 12 2.2 Defendants own real property adjacent to Lowell-Larimer Road. Defendants' <br /> 13 <br /> real property include Snohomish County parcel numbers 28050800101700 and <br /> 14 <br /> 15 28050800101400. <br /> 16 2.3 In 2018,defendants excavated a large drainage ditch. This excavation caused <br /> 17 damage to Lowell-Larimer Road and City utility infrastructure within the Lowell-Larimer <br /> 18 <br /> Road right of way. This damage came to the City's attention on September 7,2017. <br /> 19 <br /> 20 2.4 By letter dated September 20,2017,the City provided written notice to <br /> 21 defendants that the City would require reimbursement for the damage caused by defendants' <br /> 22 excavation. A true and correct copy of the notice letter is attached to this Complaint as <br /> 23 <br /> Exhibit A. <br /> 24 <br /> 25 2.5 By letter dated November 19,2018,the City provided a second written notice <br /> 26 to defendants,stating that the damage cost was$512,724.32. A true and correct copy of the <br /> 27 second notice letter,without its enclosures,is attached to this Complaint as Exhibit B. <br /> 28 <br /> Complaint-2 CITY OF EVERE1T <br /> Office of the City Attorney <br /> 2930 Wetmore Ave Suite 10-C <br /> Everett,WA 98026 <br /> (425)257-7017 <br />