CONNELLY LAW OFFICES, PLLC
John R. Connelly, Jr.
Lincoln C. Beauregard
Micah R. LeBank
Nathan P. Roberts
Julie A. Kays
Amanda M. Searle
Evan T. Fuller
Meaghan M. Driscoll
Marta L. O’Brien

Reply to Tacoma Office:
2301 North 30th Street
Tacoma, WA 98403

April 25, 2017

Toll Free: (855) 593-5100
Tacoma: (253) 593-5100
Seattle: (206) 816-3002
Fax: (253) 593-0380
www.connelly-law.com

Via E-Filing
Robert M. Sulkin
McNaul, Nawrot, & Helgren, PLLC
One Union Square
600 University Street, Suite 2700
Seattle, Washington 98101-3143
RE:

Seattle Office:
Smith Tower
506 2nd Ave, 33rd Floor
Seattle, WA 98104

D.H. v. Mayor Edward Murray
King County Superior Court Cause No. 17-2-09152-9 SEA

Dear Robert:
We are in receipt of your motion related to court filings. The purpose of this letter is to
invite you to withdraw your motion, as it violates CR 11. You cited two sources of law, CR 7
and the Rules of Professional Conduct, as supportive of your position. In relation to CR 7,
nothing in the rule prohibits us from making a full record, including filing subpoenas and
attorney correspondence. In relation to the Rules of Professional Conduct, you could not even
provide a pin-cite to an applicable rule. On the merits, your motion’s express purpose is to
intimidate us from making the record that we deem appropriate. By law, you are effectively
asking the Court to seal the files from public view by way of unlawful strong arm tactics – which
is the only illegal behavior occurring here. Your motion is violative of CR 11.
As noted, you have a reputation of being nasty. Our filings have been in full accord with
the civil rules, and filed for a proper purpose – including public/media view. If it was not clear
enough, we have elected to file all relevant information, in part, hoping that it would cause you
to be civil and focus on the merits. Thus far, we have been unsuccessful. You really should
focus your efforts on defending Ed Murray, and not attacking our law firm. Thank you.
Very truly yours,
Lincoln C. Beauregard
Lincoln C. Beauregard
LCB:vs