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4704 HARBOR LN 2018-01-02 MF Import
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4704 HARBOR LN 2018-01-02 MF Import
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Last modified
2/10/2022 3:06:50 PM
Creation date
2/20/2017 10:23:22 PM
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Address Document
Street Name
HARBOR LN
Street Number
4704
Imported From Microfiche
Yes
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2 <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 />'1 <br />22 <br />23, <br />,4 <br />COUNT5 <br />NEGLIGENT ISSUANCE OF PERMITS <br />26. The City of Everett has negligently issued permits for construction on land abutting the <br />plaintiffs' land. Those permits will cause the plaintiffs further harm •tnd do not take into <br />consideration the drainage requirements of the City of Everett Code, nor the duties to <br />restore critical areas by the Andersons. <br />',VI IA11 <br />INVERSE CONDEMNATION <br />27. By approving building permits over several years that allow for neighboring properties to <br />dump their drainage onto the plaintiffs' properties the City of Everett has taken those <br />properties, in part, fbr a drainage field for the neighbors. This action amounts to inverse <br />conulemnation. <br />WHEREFORE <br />The plaintiffs pray for an order of this court as follow: <br />I. Compensating the Chases for the trespass upon their property by both the Andersons and <br />John Doe in ail amount that would be sufficient to recognize the violation of the plaintiffs' <br />property but also to discourage future trespass; <br />2. Compensating the Chases for the loss of their trees in an amount that is required by law, <br />which in this case would be $61,530.00 for Chris Chase and $279,660.00 for Todd Chase:. <br />3. Compensating the Chases for the diminution in value to their properties due to the <br />destabilization of the hillside in an amount to be detemlined by a jury of their peers; and <br />4. Ordering the abatement of the trespass by requiring the Andersons to remove their <br />property from the Chases' lands; <br />Complaint - 7 <br />1ELSING TRI WEST &- ANDRUS. PLLC <br />Attorneys at Law <br />2926 Colby Avenue <br />Everett. WA 98201 <br />(425) 258-2688 <br />
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