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1 <br />2 <br />3 <br />4 <br />5 <br />6 <br />7 <br />8 <br />9 <br />to <br />I <br />12 <br />13 <br />14 <br />15 <br />16 <br />17 <br />IS <br />I O <br />20 <br />,4 <br />parcel number 29043500401600 and known as Lots 49 and 50. This parcel is <br />unimproved and has no building site. <br />3. The defendant Andersons are the owners of two parcels of property that have the address <br />of 4704 Harbor Lane in the City of Everett, tax assessor parcel numbers 004171 <br />and 00417100000900 and known as Lots 8A and 9. The Anderson parcels are improved <br />with a house, swimming pool, Jacuzzi, tennis court, and other amenities. <br />4. Defendant John Doe is a person or company that was hired by the Andersons to go onto <br />the property of the Chases and to cut down the trees that are the basis for this litigation <br />5. All the parcels are contiguous to each other. Chris Chase's parcel is northwest of the <br />others. Todd Chase's parcel is southwest, and the Anderson parcel is east of the Chase <br />parcels. <br />6. In 2007 the Chases had their property surveyed. Survey stakes from that survey were <br />evident at that time as the stakes have pink or orange strips attached to them to improve <br />visibility. The stakes were evident in June and July of this year and are still clearly <br />evident on the property today, the time of the drafting of these pleadings. <br />7. On or about June 10. 2009. the Andersons hired defendant John Doe to cut a number of <br />trees on their property and on the Chase properties in order to improve the view from the <br />Anderson honrc to Puget Sound. Between 32 and 38 trees were cut down at that time, <br />three trees on Chris Chase's property, 19 trees on Todd Chase's property, and the balance <br />on the Anderson property. The trees well felled from the base of the tree. The trunks and <br />debris were Ictt on the Chase proper7ies and remain there. undisturbed, at the time of the <br />drafting ofthesc pleadings. <br />S. fhe Chases were never contacted by the Andersons about cutting the trees prior to the <br />cutting being completed. Neither the Andersons nor John Doc, the unknown defendant. <br />l „mplaint - , <br />JELSING TRI WEST & ANDRUS, PLLC <br />Attomevs at Law <br />2926 Colby Avenue t <br />Everett. \VA 98201 �Aq <br />(425) 258-2688 <br />