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2 <br />3 <br />4 <br />5 <br />6 <br />7 <br />8 <br />9 <br />10 <br />I <br />12 <br />13 <br />14 <br />15 <br />16 <br />17 <br />IS <br />19 <br />20 <br />'_1 <br />,2 <br />,4 <br />disturbed and is more likely to slide again. Todd Chase's property has gone from an <br />asset to a liability now that a future landslide is more likely. Chris Chase has s,tt7'ered a <br />greater loss due to the landslide. Chris Chase's property contains a building site with a <br />view of Puget Sound. Now, due to the Andersons' landslide, and its effect on Chris <br />Chase's property, Mr. Chase must now disclose the landslide on any "Form 17" the form <br />that is required to disclose known defects with a property. The diminution in value of <br />Chris Chase's property is estimated at 25% to 33% of the value of the lot. The lot in total <br />was valued by the county assessor at $200,000.00. Chris Chase has had his property for <br />sale but has not been able to sell the lot since the landslide. <br />23. Todd Chase is entitled to be compensated for his loss to the value of his land. His land <br />was valued, for tax purposes, at $25,000.00. Todd's loss is the full value of his lot. <br />Chase is entitled to be compensated for the loss to the value of his land in an amount <br />between $50,000.00 and $67,000.00. <br />COUNT d <br />ORDER FOR ABATEMENT <br />24. The trespasses of the Andersons are continuing and will continue until they have <br />removed their property front the Chase properties. The Andersons are obligated to <br />remove their property that has been unlawtidly placed upon the Chase properties and to <br />remain off of the Phase properties unless and until they have pennission to enter onto the <br />Chase properties. <br />25. If not removed belbre this litigation is brought to urial. the Andersons must receive an <br />order of the tour! rcquiring then, to rcnwve their property from the Chase properties, and <br />particularly the topsoil and other soil, the drain pipes. and the trees and debris that now <br />liner the Chase properties. <br />l'ampl:um - o <br />ALSING ml WEST S ANDRUS. YLLC <br />Attorneys at Lase <br />2926 Colby Avenue <br />Everett, WA 98201 <br />(425)258-2688 <br />