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io] <br />12 <br />13 <br />14 <br />15 <br />16 <br />17 <br />1s <br />1 () <br />20 <br />,1 <br />2� <br />,a <br />Andersons, through their agent, the unknown defendant Doe, did trespass upon the lands <br />of Chris Chase and Todd Chase. The property of the defendant Andersons remains on <br />the Chase properties without pennission of the Chases. Chris Chase and Todd Chase <br />have asked and demanded that the Andersons remove their property from the Chase <br />properties, and particularly the tree refuse and the topsoil and underlying soil, as well as <br />the drain pipes, but have yet to see that material removed. <br />19. The plrtintiff Chases are entitled to recover for the trespass upon their property by the <br />defendant Andersons and defendant Doe. <br />COUNT2 <br />REMOVAL OF TREES <br />20. Trees are a protected asset in Washington State. Any party who cuts or damages the <br />on another party's property is liable for treble damages for such injury. The statute <br />Whenever any person shall cut down, girdle or otherwise injure, or carry off any tree, <br />timber or shrub on the land of another person, or on the street or highway in front of <br />any person's house, village, town or city lot, or cultivated grounds, or on the <br />commons or public grounds of any village, town or city, or on the street or highway <br />in front thereof, without lawful authority, in all action by such person, village, town o <br />city against the person committing such trespasses or any of them, if judgment be <br />given firr the plaintiff, it shall be given for treble the amount of damages claimed or <br />assessed therefore, as the case may be. RCW 64.12.030 <br />21. The defendant Andersons and John Doe did cut down trees on the land of another person <br />without lawful authority. In such a case judgment shall be given for treble the amount of <br />damages. They are therefore due to Chris Chase in the amount of $61,530.00 for <br />to his trees. They are due to Todd Chase for $279,660.00 for damages to his trees. <br />COUNT3 <br />DIMINUTION IN VALUE <br />22. The landslide and attendant \wakening, of the hillside has caused a reduction in the value <br />of the plaintiffs' properties. The hillside above the plaintiff's properties has been <br />Complaint - 5 <br />JELSING TRI wESI fi ANDRUS. PLLC <br />Attorneys at Law <br />2926 Colby Avenue <br />Eccrett. \VA 93201 <br />(425)258-2688 <br />