Document 6bqKvJvNRrvKGELJoQYx0gyNE
1 THE HONORABLE SHARON ARMSTRONG
2
3
4
5
6
7 SUPERIOR COURT OF WASHINGTON FOR KING COUNTY
8 PAULINE JENSEN, Individually and as Personal
9 Representative of the Estate of ALVIN JENSEN,
10 Plaintiffs,
11 v.
No. 04-2-20249-3 SEA
PLAINTIFF'S OBJECTION AND MOTION TO STRIKE SUPPLEMENTAL DECLARATION OF J. MICHAEL MATTINGLY
12 SABERHAGEN HOLDINGS, INC., et al.
13 Defendants.
14
15 Plaintiff vigorously objects to the inclusion of Mr. Mattingly's supplemental declaration
16 filed late in the day on August 30, 2005 and respectfully move to strike it from the summary
17 judgment record.
18 First, a clarification. The documents that this firm re-submitted to the Court as
19 attachments to the undersigned's declaration dated August 29, 2005 was pursuant to a specific
20 request that the Court made from the bench during oral argument on Friday, August 26th.
21 Nothing new was submitted to the Court that was not already in the voluminous summary
22 judgment record that began in this case last January and which was responded to, initially, by
23 this firm on April 15, 2005 in conjunction with a motion to compel the production of documents
PLAINTIFF'S OBJECTION AND MOTION TO STRIKE
SUPPLEMENTAL DECLARATION OF J. MICHAEL
MATTINGLY 1
-
S:\Ciients\Clients_J\JENSEN. Alvin\JensenA_Warren MSJ Aug 05\PLD-PlamtifPs Motion To Strike.doc
Bergman & Frockt
705 Second Avenue, Suite 1601 Seattle, WA 98104
Telephone: 206.957.9510 Facsimile: 206.957.9549
1 from Warren Pumps (a motion that was granted). Any suggestion that this firm was trying to
2 submit new evidence or new arguments to the Court by filing a supplemental declaration
3 (requested by the Court) that simply directed the Court back to the place in the record where
4 certain documents were located and where certain documents were discussed is patently and
5 utterly a misrepresentation of what was filed by this firm on Monday, August 29th. Nothing new
6 was submitted nor were new arguments raised.
7 To that end, Warren Pumps makes the remarkable assertion that it only learned for the
8 first time - on Friday, August 26 - that part of the argument in this case related to the
9 specification of asbestos containing materials by Warren or Quimby in connection with their
10 pumps. Apparently, Warren failed to read this firm's briefing throughout this matter, including
11 the initial one that was submitted back on April 15, 2005. That brief clearly put Warren on
12 notice that part of the argument in this case related directly to the specification of asbestos
13 materials in Quimby pumps, but advised the Court that since Warren had played semantic games
14 and decided not to produce documents, it was unclear what the as yet to be produced documents
15 would reveal. Specifically the brief stated:
16 Second, if Warren does in fact have documents reflecting not only their
purchase of Quimby Pumps, but also their continued maintenance of Quimby
17 pumps on the Hornet or other ships, that information could certainly be
corroborative of Alvin Jensen's testimony about his work with various pumps on
18 the Hornet. They could have documents from the US Navy reflecting repair or
maintenance on these pumps. Technical manuals about Quimby pumps that may
19 be in Warren's possession may show that in the 1940s and 1950s, asbestos
containing materials were being installed with or applied in conjunction with
20 these pumps. Schematic and engineering diagrams related to Quimbyfuel oil
pumps could very well show that these asbestos containing materials were
21 specified by Quimby. Documents relating to maintenance on Quimby pumps
(again Warren continued to provide aftermarket support for Quimby pumps for
22 more than 50 years) could provide information to be relied on by Plaintiff s
experts who are entitled to opine on any ultimate factual issue in the case.
23
The point is: we do not know what information or documents Warren has
PLAINTIFF'S OBJECTION AND MOTION TO STRIKE SUPPLEMENTAL DECLARATION OF J. MICHAEL MATTINGLY 2
S:\Clients\Clients_J\JENSEN, A)vin\JensenA_Warren MSJ Aug 05\PLD-Plaintiffs Motion To Strike.doc
Bergman & Frockt
705 Second avenue, Suite 1601 Seattle, WA 98104
Telephone: 206.957.9510 Facsimile: 206.957.9549
1 on all of these issues because of their entirely inadequate discovery responses. Given that the discovery cutoff is more than four months away, it would be
2 grossly unfair to dismiss a very serious wrongful death claim without making Warren adhere to its reciprocal discovery obligations.
3 See Plaintiff's April 15th brief at pp. 6-7 (emphasis supplied).
4 Moreover, the April 15th brief also included a discussion of Warren specifications
5 of asbestos containing materials on the emergency feed pump on the CV 12 - a steam
6 reciprocating pump similar to the fire and bilge pumps that Alvin Jensen worked on.
7
This document was discussed on p. 12 of the April 15th brief - four months ago: 8
Documents produced by Warren Pumps in the previous litigation also 9 indicate that Warren manufactured emergency feed pumps on Essex class
carriers, such as the CV 12. A materials section in the diagram specifically 10 lists "asbestos metallic cloth" and 85% Magnesia insulation, which is an
asbestos insulation. Thus, Warren specifically specified the use of 11 asbestos containing materialsfor its pumps. Shipboard personnel
working in the fireroom would have likely been exposed to that material 12 as well as asbestos packing, when it was disturbed during routine
maintenance on emergency feed pumps. 13
See April 15th brief at pp. 12, fh. 8 (emphasis supplied). This document was referenced in 14
Everett Cooper's original declaration in this case (the April 15th declaration) at 116. 15
Similarly, in Plaintiffs' August 15th brief, the Plaintiff discussed - extensively -- the 16
evidence derived from documents finally produced by Warren only after this Court directed 17
Warren to produce documents last April. Again, Warren's assertion that they "didn't know" that 18
Plaintiffs would argue that they or their predecessor in interest, Quimby, specified the use of 19
asbestos materials on or within their equipment shows either a non-awareness of what Plaintiffs 20
argued or a brazen attempt at revisionist history, both of which should be rejected wholesale by 21
22
23
PLAINTIFF'S OBJECTION AND MOTION TO STRIKE SUPPLEMENTAL DECLARATION OF J. MICHAEL MATTINGLY 3
S:\CHents\Gients_J\JENSEN. Alvin\JensenA_Warren MS) Aug 05\PLD-Plaindffs Motion To Strike.doc
Bergman & Frockt
705 Second Avenue, Suite 1601 Seattle, WA 98104
Telephone: 206.957.9510 Facsimile: 206.957.9549
1 this Court.1 The August 15th brief (to which Warren has already been granted by right - an
2 opportunity to reply to) stated as follows:
3 In point of fact, correspondence produced by Warren Pumps indicates that Quimby contracted with the Crane Co. for Crane to provide Quimby with dozens
4 of high pressure globe valves for incorporation into the Quimby pumps that were installed on Essex class carriers including the CV 12. Frockt Dec., Ex. 14
5 ("Supplemental Cooper Declaration dated Aug. 15, 2005 - "Cooper Dec.") at 14.2 3The material specifications for these globe valves indicate that they were
6 specified to use braided asbestos packing and that the Crane valves were incorporated into fuel oil service, booster and transfer pumps typically located
7 in thefirerooms on these ships, including the CV 123 Cooper Dec, at ^[14 & 16; Frockt Dec. Ex. 15 JEN 000410, 000411, 000420, 000422, 000001, 000016,
8 000019, 000033, 000919-922).
9 See August 15th brief at pp. 32. Indeed, JEN 000411 is correspondence from Crane Co back to
10 Quimby related to materials to be supplied in connection with valves for Quimby Pumps. The
11 correspondence implies that it was Quimby's requirements that asbestos packing be used. It
12 states, "We now wish to quote you the material which we propose to furnish, showing our
13 interpretation ofyour [Quimby's] requirements. " This document was produced by Warren after
14 the first summary judgment hearing in April.
15 Additionally, Plaintiff discussed again in the August brief the very same document
16 related to lagging on the emergency feed pumps on the CV 12 that it discussed last April but
17 related that document to the new evidence it had acquired about Warren manufactured fire and
18 bilge pumps being located on the same ship. Thus, it cannot be said that the issue of
19 specifications was raised for the first time on August 26th (at oral argument):
20
21 1 Warren's argument that it was "unaware" until last Friday that material specifications were at issue reminds one of
the famous line from Casablanca wherein Humphrey Bogart was "shocked" to learn that gambling was occurring in
22 the hotel.
2 At the initial oral argument on this motion, the Court indicated from the bench that it was not going to strike Mr.
Cooper's expert declaration pursuant to a motion by Warren.
23 3 Braided asbestos packing also appears to have been a material specified for use in the stuffing box on Quimby
designed vertical gear in head screw pumps. See JEN 000921. PLAINTIFF'S OBJECTION AND MOTION TO STRIKE SUPPLEMENTAL DECLARATION OF J. MICHAEL MATTINGLY 4
S:\Clients\Clients_J\JENSEN. AlvinVJensenA_Warren MSJ Aug 05\PLD-Plaintiffs Motion To Strike.doc
Bergman & Frockt
705 Second Avenue, Suite 1601 Seattle, WA 98104
Telephone: 206.957.9510 Facsimile: 206.957.9549
1 Mr. Jensen also testified that he worked with bilge pumps in the fire room on the Hornet on several occasions and that he disassembled those pumps and
2 worked with packing including the removal of packing from those pumps. Id. at 338. The bilge pumps were also manufactured by Warren. Cooper Dec. *|f 21;
3 Frockt Dec. Ex. 17. Additionally, Plaintiffs previously submitted to the Court document
4 WP24-000086, a Warren produced document from other litigation that specifies asbestos lagging on emergency feed pumps on Essex class carriers, including the
5 CV 12. See Frockt Dec. Ex. 16. This is a reciprocating pump and Warren specifically calledfor the use ofasbestos cloth and 85% Magnesia insulation on
6 it The bilge pumps on the Hornet are also steam reciprocating pumps and it can easily be inferred that the same type of insulation would have been specified for
7 this equipment. To this end, Mr. Jensen testified that the bilge pumps were insulated to his recollection. Id. at 337.
8 See August 15th brief atpp. 37 (emphasis supplied).4
9 CONCLUSION
10
11 The Court requested that this firm submit a supplemental declaration on Monday
12 pertaining to evidence already in the record. We did so. In response, Warren has, sua sponte,
13 submitted new evidence never before presented in this case.
14 This Court has now been briefed to death on this case. Accordingly, Plaintiffs are not
15 going to add anything else to the record but felt the need to clarify for the Court what was argued
16 below since Warren has at the eleventh hour submitted brand new evidence on the issue of
17 materials specification - evidence not submitted in their initial motion for summary judgment
18 nor any of the several reply briefs it has filed as of right in this case.
19 Accordingly, this supplemental declaration should be stricken from the summary
20 judgment record. Even if the Court considers it, at best, it creates issues of material fact since it
21 will be established at trial that the Navy never prevented any contractor from warning about
22 asbestos hazards.
23
4 Warren has never denied that its fire and bilge pumps were installed on the CV 12. PLAINTIFF'S OBJECTION AND MOTION TO STRIKE SUPPLEMENTAL DECLARATION OF J. MICHAEL MATTINGLY 5
S:\CIients\Clients_J\JENSEN. Aivin\jensenA_Warren MSJ Aug 05\PLD*Piaintiffs Motion To Strike.doc
Bergman & Frockt
705 Second Avenue, Suite 1601 Seattle, WA 98104
Telephone: 206.957.9510 Facsimile: 206.957.9549
1 The extensive record in this case demonstrates that there are numerous issues of material
2 fact related to Mr. Jensen's exposure to and work with both Warren and Quimby pumps on the
3 USS Hornet (CV 12). Summary judgment must, accordingly, be denied.
4 DATED this 31st day of August, 2005.
5 BERGMAN & FROCKT
6
7
8 Counsel for Plaintiff
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PLAINTIFF'S OBJECTION AND MOTION TO STRIKE SUPPLEMENTAL DECLARATION OF J. MICHAEL MATTINGLY 6
S:\CIients\Clients_J\JENSEN, Alvin\JensenA_Wairen MSJ Aug 05\PLD-Plaintiffs Motion To Strike.doc
Bergman & Frockt
705 Second Avenue, Suite 1601 Seattle, WA 98104
Telephone: 206.957.9510 Facsimile: 206.957.9549
1 THE HONORABLE SHARON ARMSTRONG
2
3
4
5
6 SUPERIOR COURT OF WASHINGTON FOR KING COUNTY
7
8 PAULINE JENSEN, Individually and as
NO. 04-2-20249-3 SEA
Personal Representative of the Estate of ALVIN
9 JENSEN,
DECLARATION OF SERVICE
10 Plaintiff,
11 v.
12 SABERHAGEN HOLDINGS, INC., et al.
13 Defendants.
14
I, Wil John Cabatic, declare and state as follows: 15
1. Iam and at all times herein was a citizen of the United States, a resident of King 16 County, Washington, and am over the age of 18 years.
17 2. On the 31st day of August, 2005,1 caused to be served true and correct copies, of: (1) Plaintiffs Objection and Motion to Strike Supplemental Declaration of J. Michael Mattingly;
18 and (2) Declaration of Service, on the following:
19 I. Via Fascimilie:
20 Counsel for Saberhagen Holdings. Inc. Timothy Thorson
21 CARNEY, BADLEY & SPELLMAN 700 Fifth Avenue, Suite 5800
22 Seattle, WA 98104
23
DECLARATION OF SERVICE-1
S:\Clients\Giients_J\JENSEN, AJvin\JensenA_Pleadings\_JensenA_PLD_wic_DecOfService.doc
BERGMAN & FROCKT
705 SECOND AVENUE, SUITE 1601 Seattle, WA 98104
Telephone: 206.957.9510 Facsimile: 206.957.9549
1 Counsel for Dana Corporation Diane Kero
2 GORDON, THOMAS, HONEYWELL, MALANCA, PETERSON & DAHEIM, PLLC 600 University Street, Suite 2101
3 Seattle, WA 98101
4 Counsel for Borg Warner Corporation Christopher W Tompkins
5 Steven W Block BETTS PATTERSON & MINES, P.S.
6 701 Pike Street, Suite 1400 Seattle, WA 98101
7 Counsel for Honeywell International, Inc.
8 James F. Williams PERKINS COIE
9 1201 Third Avenue, Suite 4800 Seattle, WA 98101
10 Counsel for Warren Pumps, Inc.
11 J. Michael Mattingly STEVEN V. RIZZO, P.C.
12 Lincoln Place, Suite 350 1620 S.W. Taylor Street
13 Portland, OR 97205
14 I declare under penalty of peijury under the laws of the State of Washington that the
15 foregoing is true and correct.
16 DATED at Seattle, Washington this 31st day of August, 2005.
17
18 Wil John Cabatic
19
20
21
22
23
DECLARATION OF SERVICE- 2
S:\Clients\Ciients_JVIENSEN, AlvinUensenA_Pleadings\_JensenA_PLD_wjc_DecOfService.doc
Bergman & Frockt
705 Second Avenue, Suite 1601 Seattle, WA 98104
Telephone: 206.957.9510 Facsimile: 206.957.9549
Bergman & Frockt
Telephone: 206.957.9510 Facsimile: 206.957.9549 E-Mail: mail@bergmanlegal.com
705 Second Avenue, Suite 1601 Seattle, WA 98104
Fax Transmission
To: Timothy Thorson Diane Kero Christopher W Tompkins James F Williams J Michael Mattingly
August 31, 2005
Fax: 467.8215 676.7575 343.7053 583.8500 503.229.0630
Phone:
Matthew P. Bergman
Also Admitted In Oregon
J. Conard Metcalf
Admitted in Colorado
David S. Frockt
LeAnn McDonald
From: Wil John Cabatic
Fax: (206) 957-9549
Phone: (206) 957-9510
Re: Pages:
Alvin Jensen v. Saberhagen Holdings, Inc., et al.
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8/31/2005
1 THE HONORABLE SHARON ARMSTRONG
2
3
4
5
6 SUPERIOR COURT OF WASHINGTON FOR KING COUNTY
7
8 PAULINE JENSEN, Individually and as
NO. 04-2-20249-3 SEA
Personal Representative of the Estate of ALVIN
9 JENSEN,
DECLARATION OF SERVICE
10 Plaintiff,
11 v.
12 SABERHAGEN HOLDINGS, INC., et al.
13 Defendants.
14
I, Wil John Cabatic, declare and state as follows: 15
1. Iain and at all times herein was a citizen of the United States, a resident of King 16 County, Washington, and am over the age of 18 years.
17 2. On the 1st day of September, 2005,1 caused to be served true and correct copies, of: (1) Plaintiffs Objection and Motion to Strike Supplemental Declaration of J. Michael
18 Mattingly; and (2) Declaration of Service, on the following:
19 I. Via Fascimilie 108.31.051 and Legal Messenger:
20 Counsel for Saberhagen Holdings. Inc. Timothy Thorson
21 CARNEY, BADLEY & SPELLMAN 700 Fifth Avenue, Suite 5800
22 Seattle, WA 98104
23
DECLARATION OF SERVICE-1
S:\Clients\Clients_JUENSEN, AlvinUenseriA_Pleadjngs\_JensenA_PLD_wjc_DecOfService.doc
,, 0_
BERGMAN & FROCK.T
705 Second Avenue, Suite 1601 Seattle, WA 98104
Telephone: 206.957.9510 Facsimile: 206.957.9549
1 Counsel for Dana Corporation Diane Kero
2 GORDON, THOMAS, HONEYWELL, MALANCA, PETERSON & DAHEIM, PLLC 600 University Street, Suite 2101
3 Seattle, WA 98101
4 Counsel for Bore Warner Corporation Christopher W Tompkins
5 Steven W Block BETTS PATTERSON & MINES, P.S.
6 701 Pike Street, Suite 1400 Seattle, WA 98101
7/ Counsel for Honeywell International, Inc.
8 James F. Williams PERKINS COIE
9 1201 Third Avenue, Suite 4800 Seattle, WA 98101
10 I. Via Fascimilie 108.31.051 and U.S. Mail:
11 Counsel for Warren Pumps, Inc.
12 J. Michael Mattingly STEVEN V. RIZZO, P.C.
13 Lincoln Place, Suite 350 1620 S.W. Taylor Street
14 Portland, OR 97205
15 I declare under penalty of peijury under the laws of the State of Washington that the
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YOUR ABC ACCT. NO
430
DATE
9/1/2005
RETURN CONFORMED COPY
CONFORM ORIGINAL DO NOT FILE
1 Diane Kero GORDON, THOMAS, HONEYWELL, MALANCA, PETERSON & DAHEIM, PLLC 600 University Street, Suite 2101 Seattle, WA 98101
3
o z COUNTY
SUPERIOR COURT
DISTRICT COURT (INDICATE DISTRICT)
AUDITOR
APPEALS
l-SEA
11-
TAC
FEDERAL COURT
CIVIL
BANKRUPTCY
SEA
STATE SUPREME
COURT
SEC STATE CORP.
THIS FORM NOT FOR PROCESS
ABC Legal Services, Inc. (ABC) assumes no liability for errors caused in whole or in part by the improper filling out of this messenger service request form, including but not limited to, omission of a last day date/time, filings not marked in the proper and designated filing boxes, illegible print or script, etc. All messenger requests are double-checked for accuracy and completion prior to returning
to the requestor, however; it is the responsibility of the requestor to also check the completed request form for accuracy and to notify us immediately if there are any questions or discrepancies. Usage of this form constitutes a contract between the requestor and ABC and acknowledgment and acceptance by the requestor of the terms set forth above.
ABC Legal Services ABCSIip 3.0
OOQ
LEGAL SERVICES
abclegaljcooi
SEATTLE 910 5TH AVE. SEATTLE, WA 98104 PH: 206-623-8771 206-682-1675 1-800-736-7295 FAX: 206-625-9247
TACOMA 943 TACOMA AVE. SO.
TACOMA, WA 98402 PH: 253-383-1791 1-800-383-1791 FAX: 253-272-9359 tac@abclegal.com
BELLEVUE 10655 NE 4th
Suite LI 01 BELLEVUE, WA 98004
PH: 425-455-0102 FAX: 425-455-3153 bel@abclegal.com
EVERETT 2927 ROCKEFELLER EVERETT, WA 98201
PH: 425-258-4591 1-800-869-7785
FAX: 425-252-9322 eve@abdegal.com
OLYMPIA 119 W LEGION WAY OLYMPIA, WA 98501
PH: 360-154-6595 1-800-828-0199
FAX: 360-357-3302 oly@abclegal.com
MESSENGER SERVICE
LAST DAY
FIRM NAME
Bergman & Frockt
DATE/TIME
ADDRESS
705 Second Avenue, Suite 1601
09.01.05
CASE NAME
ALVIN JENSEN V. SABERHAGEN, ET AL.
CAUSE NO.
CLIENT MATER #
ALVIN JENSEN
DOCUMENTS
Pis Objection and Motion to Strike Supp Dec of Mattingly;
Dec Of Service
SIGNATURE REQUIRED ON DOCUMENTS OTHER INSTRUCTIONS
RETURN CONFORMED ABC SLIP ONLY
X
PHONE
206.957.9510
EXT.#
EMA L (SECRETARY)
wil{5&bergmanlegal.com
ATTY
SECRETARY
Wile
YOUR ABC ACCT. NO
430
DATE
9/1/2005
RETURN CONFORMED COPY
CONFORM ORIGINAL DO NOT FILE
1 Christopher W Tompkins Steven W Block BETTS PATTERSON & MINES, P.S. 701 Pike Street, Suite 1400 Seattle, WA 98101
3
o z COUNTY LL
SUPERIOR COURT
DISTRICT COURT (INDICATE DISTRICT)
AUDITOR
APPEALS l-SEA TAC
FEDERAL COURT
CIVIL
BANKRUPTCY
SEA
TAC
STATE SUPREME
COURT
SEC STATE CORP.
THIS FORM NOT FOR PROCESS
ABC Legal Services, Inc. (ABC) assumes no liability for errors caused in whole or in part by the improper filling out of this messenger service request form, including but not limited to, omission of a last day date/time, filings not marked in the proper and designated filing boxes, illegible print or script, etc. All messenger requests are double-checked for accuracy and completion prior to returning
to the requestor, however; it is the responsibility of the requestor to also check the completed request form for accuracy and to notify us immediately if there are any questions or discrepancies. Usage of this form constitutes a contract between the requestor and ABC and acknowledgment and acceptance by the requestor of the terms set forth above.
ABC Legal Services ABCSIip 3.0
006
LEGAL SERVICES
abcleg&ljcom
SEATTLE 910 STH AVE. SEATTLE, WA 98104 PH: 206-623-8771 206-682-1675 1-800-736-7295 FAX: 206-625-9247
TACOMA 943 TACOMA AVE. SO.
TACOMA, WA 98402 PH: 253-383-1791 1-800-383-1791 FAX: 253-272-9359 tac@abclegal.com
BELLEVUE
10655 NE 4th Suite LI 01
BELLEVUE, WA 98004 PH: 425-455-0102 FAX: 425-455-3153 beJ@abclegal.com
EVERETT 2927 ROCKEFELLER EVERETT, WA 98201
PH: 425-258-4591 1-800-869-7785
FAX: 425-252-9322 eve@abclegal.com
OLYMPIA 119 W LEGION WAY OLYMPIA, WA 98501
PH: 360-154-6595 1-800^28-0199
FAX: 360-357-3302 oty@abclegal.com
MESSENGER SERVICE
LAST DAY
FIRM NAME
Bergman & Frockt
DATE/TIME
ADDRESS
705 Second Avenue, Suite 1601
09.01.05 5:00pm
CASE NAME
ALVIN JENSEN V. SABERHAGEN, ET AL.
CAUSE NO.
CLIENT MATER#
ALVIN JENSEN
DOCUMENTS
Pis Objection and Motion to Strike Supp Dec of Mattingly;
Dec Of Service
SIGNATURE REQUIRED ON DOCUMENTS OTHER INSTRUCTIONS
RETURN CONFORMED ABC SLIP ONLY
X
PHONE
206.957.9510
EXT.#
EMAIL (SECRETARY)
wil@bergmaniegai.com
ATTY
SECRETARY
Wile
YOUR ABC ACCT. NO
430
DATE
9/1/2005
RETURN CONFORMED COPY
CONFORM ORIGINAL DO NOT FILE
1 James F. Williams PERKINS COIE 1201 Third Avenue, Suite 4800 Seattle, WA 98101
3
o z COUNTY a
SUPERIOR COURT
DISTRICT COURT (INDICATE DISTRICT)
AUDITOR
APPEALS
l-SEA
IITAC
FEDERAL COURT
CIVIL
BANKRUPTCY
SEA
TAC
STATE SUPREME
COURT
SEC STATE CORP.
THIS FORM NOT FOR PROCESS
ABC Legal Services, Inc. (ABC) assumes no liability for errors caused in whole or in part by the improper filling out of this messenger service request form, including but not limited to, omission of a last day date/time, filings not marked in the proper and designated filing boxes, illegible print or script, etc. All messenger requests are double-checked for accuracy and completion prior to returning
to the requestor, however; it is the responsibility of the requestor to also check the completed request form for accuracy and to notify us immediately if there are any questions or discrepancies. Usage of this form constitutes a contract between the requestor and ABC and acknowledgment and acceptance by the requestor of the terms set forth above.
ABC Legal Services ABCSlip 3.0
006
LEGAL SERVICES
abcleg^IjcoiEL
SEATTLE 910 5TH AVE. SEATTLE, WA 98104 PH: 206-623-8771 206-682-1675 1-800-736-7295 FAX: 206-625-9247
TACOMA 943 TACOMA AVE. SO.
TACOMA, WA 98402 PH: 253-383-1791 1-800-383-1791 FAX: 253-272-9359 tac@abclegal.com
BELLEVUE 10655 NE 4th
Suite LI 01 BELLEVUE, WA 98004
PH: 425-455-0102 FAX: 425-455-3153 bel@abclegai.com
EVERETT 2927 ROCKEFELLER EVERETT, WA 98201
PH: 425-258-4591 1-800-869-7785
FAX: 425-252-9322 eve@abclegal.com
OLYMPIA 119 W LEGION WAY OLYMPIA, WA 98501
PH: 360-154-6595 1-800-828-0199
FAX: 360-357-3302 oiy@abclegal.com
MESSENGER SERVICE
LAST DAY
FIRM NAME
Bergman & Frockt
DATE/TIME
ADDRESS
705 Second Avenue, Suite 1601
09.01.05 4:30pm
CASE NAME
ALVIN JENSEN V. SABERHAGEN, ET AL.
CAUSE NO.
CLIENT MATER#
ALVIN JENSEN
DOCUMENTS
Dec Of Service
SIGNATURE REQUIRED ON DOCUMENTS OTHER INSTRUCTIONS
RETURN CONFORMED ABC SLIP ONLY
X
PHONE
EXT.#
EMAIL (SECRETARY)
206.957.9510
wil@bergmanlegal.com
ATTY
SECRETARY
Wile
YOUR ABC ACCT. NO
430
DATE
9/1/2005
RETURN CONFORMED COPY
CONFORM ORIGINAL DO NOT FILE
o z COUNTY ...JAf. KING
SUPERIOR COURT
X
DISTRICT COURT (INDICATE DISTRICT)
AUDITOR
APPEALS
l-SEA
IITAC
FEDERAL COURT
CIVIL
BANKRUPTCY
SEA
TAC
STATE SUPREME
COURT
SEC STATE CORP.
THIS FORM NOT FOR PROCESS
ABC Legal Services, Inc. (ABC) assumes no liability for errors caused in whole or in part by the improper filling out of this messenger service request form, including but not limited to, omission of a last day date/time, filings not marked in the proper and designated filing boxes, illegible print or script, etc. All messenger requests are double-checked for accuracy and completion prior to returning
to the requestor, however; it is the responsibility of the requestor to also check the completed request form for accuracy and to notify us immediately if there are any questions or discrepancies. Usage of this form constitutes a contract between the requestor and ABC and acknowledgment and acceptance by the requestor of the terms set forth above.
ABC Legal Services ABCSIip 3.0