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had permission or authority to go onto the Chase properties or to cut trees on the Chase <br />2 11 properties. <br />3 <br />4 <br />5 <br />6 <br />7 <br />8 <br />9 <br />10 <br />11 <br />12 <br />13 <br />14 <br />15 <br />16 <br />17 <br />IS <br />19 <br />20 <br />21 <br />22 <br />�4 <br />9. On or about June 30 or July 1 the Andersons experienced a water leak on their property <br />while they were away from home. It appeared that a pipe from their lawn sprinkling <br />system had burst and had saturated the yard with water. It is estimated that 250,000 <br />gallons of water escaped the pipe into the yard. <br />10. Immediately subsequent to the water leak and ground saturation the hillside that makes <br />up the western side of the Anderson parcel, and the eastern sides of the Chase properties, <br />collapsed, causing a landslide on the Anderson and Chase properties. All of the topsoil <br />and a great deal of the underlying soil on the hillside, as well as all remaining plants, <br />small trees, bushes and other vegetation, released from the hillside and flowed down onto <br />the Chase parcels and towards Merrill and Ring Creek. In all, approximately 6,333 <br />square feet of the hillside was impacted by the slide activity, as stated by Weiland <br />Resources, Inc. The resulting scarp is now several feet deep. <br />11. The removal of the trees, vegetation, and dirt from the hillside revealed that the <br />Andersons had one or more drainage pipes that had been buried on the Chase properties. <br />and particularly on Chris Chase's property. Neither of the plaintiffs is aware of any right <br />or perniission that was given to the Andersons for these drainage pipes. <br />12. The plaintiffs have had an arborist. Scott C. Baker, RCA, of Tree Solutions. Inc. evaluate <br />the tree damage. It is his opinion that Chris Chase lost trees worth $20.510.00. and that <br />Todd Chase lost trees worth $93,220.00. <br />13. The City of Everett was requested to issue a pennit for the construction of it wall un the <br />Anderson property and also to permit restoration of critical areas. These permits were <br />issued in violation of the city ordinances for the City of Everett and are dune to the <br />prejudice of the plaintiffs. <br />Complaint - 3 <br />JELSING TRI WEST & ANDRUS. PLLC <br />Attomeys at Law <br />2926 Colby Avenue <br />Everett.\VA 98201 <br />(425) 258.2688 <br />