FILED 17 MAY 03 AM 9:00 Hon. Veronica Alicea? Galvan Defendant?s agg?sb Noted for Consideration: SUPERIOR COURT OF WASHINGTON FOR KING COUNTY D.H., No. Plaintiff, SURREPLY IN V. SUPPORT OF MOTION FOR SANCTIONS MAYOR EDWARD MURRAY, Defendant. It is unfortunate that Defendant has, once again, been forced to ?le a brief with the Court because of opposing counsel?s ongoing and escalating misconduct. Defendant submits this brief surreply in response to Plaintiff? belated ?ling of a declaration (complete with a bizarre photograph), purportedly ?led With respect to Defendant?s motion for sanctions. Dkt. 36. There can be no argument that this declaration relates at all to the merits of Defendant?s motion for sanctions (and even Mr. Beauregard does not bother to try to make one). It is yet another improper ?ling by Mr. Beauregard only for the purpose of gaining the attention of the press that has nothing to do with Defendant?s motion. It is clear that Mr. Beauregard wants to try the case in the press rather than with due process in the courts, as our constitution and legal traditions require. Only the Court can stop this misconduct that makes a mockery of the judicial system and the RPC. See generally Strait Decl.; Lachman Decl. Notably, even Mr. Heckard himself does not corroborate the account in the just ?led declaration, which appears to be from some sort of claimed jailhouse informant. In LAW OFFICES OF SURREPLY IN SUPPORT OF MCNAUL EBEL NAWROT HELGREN 600 University Street Suite 2700 MOTION FOR SANCTIONS Page 1 Seattle, Washington ?8lOl-3l43 (206) 467-1816 33 COIOO \l O) 01 (20 sworn discovery responses Plaintiff proVided to Defendant dated the same day as this declaration, Plaintiff disclosed all witnesses who he ?believe[s] has or may have knowledge relating in any way to the allegations, claims, or defenses asserted in this lawsuit.? Signi?cantly, he did not mention Mr. Jones. EX. at 1?2.1 Although Mr. Beauregard has claimed publically that he wishes to proceed with a prompt deposition of Mr. Heckard, Mr. Beauregard and his client have produced no documents in response to Defendant?s discovery requests, have demanded that Defendant agree not to file any documents with the Court, and have refused to sign standard medical waivers that would allow Defendant to obtain the documents. Id. at 4, 7, 8, 14; 3rd Eaton Decl. 1i 2. All of this while Mr. Beauregard is claiming to the press and this Court that he is ?ling documents to create a complete public record. I certify that this memorandum contains 366 words in compliance with the Local Civil Rules. DATED this 3rd day of May, 2017. EBEL NAWROT HELGREN PLLC Robert M. Sulkin, WSBA 15425 Malaika M. Eaton, WSBA No. 32837 Attorneys for Defendant 1 Exhibit is attached to the Third Declaration of Malaika M. Eaton in Support of Defendant?s Motion for Sanctions (?3rd Eaton LAW OFFICES OF SURREPLY IN SUPPORT OF MONAUL EBEL NAWROT HELGREN PM 600 University Street, Suite 2700 MOTION FOR SANCTIONS Page 2 Seattle, Washington 98101-3143 (206) 467-1816 3759-001 geOZcr15X8.002 2017-05-03