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1 Additionally,neighbors have seen unknown people entering the house. The Property <br /> 2 <br /> generates a much higher than average number of 911 calls for trespassing or suspicious activity.23 <br /> 3 Yost herself has complained of trespassers using the Property for unlawful dumping and stealing <br /> 4 her personal property from the Property.24 It is suspected that individuals unlawfully occupying <br /> 5 the house led to a fire on April 13,2015 (a little over a year after the Examiner issued his <br /> 6 Decision)zs The fire occurred in the second story of the house and did extensive damage. <br /> 7 <br /> Although the fire was a horrible event,Yost,now more than a year later,has not even begun to <br /> 8 <br /> repair the fire damage 26 and the damage contributes the deteriorated state of the house. Tarping of <br /> 9 <br /> 10 the fire-damaged roof has blown off making the interior of the house susceptible to rain and other <br /> 11 weather.27 Nonetheless,since the fire has occurred,neighbors continue to report trespassers <br /> 12 accessing the yards and house.28 <br /> 13 E. Nuisance Abatement Lawsuit <br /> 14 After waiting over a year(from the most recent code enforcement matter)for Yost to <br /> 15 <br /> eliminate the nuisance conditions on her Property and bring it into compliance with City codes,the <br /> 16 <br /> City served Yost with this lawsuit on June 24, 2015,to deal with increasing nuisance conditions 29 <br /> 17 <br /> To date,Yost has made very little progress to properly bring the Property in to compliance with <br /> 18 <br /> 19 City codes. This Court should issue the City a warrant of abatement to abate the nuisance <br /> 20 conditions at Yost's expense(including demolishing the house)and enter an injunction to prevent <br /> 21 Yost from maintaining similar nuisance conditions on the Property in the future. <br /> 22 <br /> 23 29 Bosman Dec.,p.1-2. <br /> 24 Keirsey Dec.P.9. <br /> 2s Goforth Dec.,p.1-2. <br /> 24 26 The City can assume no work to repair the fire damage has begun because building permits would be required to <br /> repair the damage and Yost has not obtained any in the past two years. Keirsey Dec.,p.9. <br /> 25 27 Keirsey Dec.,p.9. <br /> 21 Exhibit Q—Keirsey Dec. <br /> 29 See Declaration of Service of Kathryn Rathbun on file with this Court. <br /> Yost Summary Judgment Motion OFFICE OF THE CITY ATTORNEY <br /> Page 8 of 23 CITY OF EVERETT <br /> 2930 Wetmore Avenue,10-C <br /> Everett WA 98201 <br /> (425)257-7000 <br />