1 EXPEDITE No Hearing Set Hearing is Set Date: Time: 2 3 C, : 2 2 2017 4 5 EX PAST=E 6 7 STATE OF WASHINGTON THURSTON COUNTY SUPERIOR COURT 8 STATE OF WASHINGTON, NO. 17-2-04616-34 9 Plaintiff, 10 STIPULATION AND AGREED JUDGMENT V. 11 12 13 PIERCE COUNTY DEMOCRATIC CENTRAL COMMITTEE, a Washington registered political committee, Defendant. 14 15 16 17 JUDGMENT SUMMARY (RCW 4.64.030) A. B. JUDGMENT CREDITOR: JUDGMENT DEBTOR: C. PRINCIPAL JUDGMENT: $31,780 with $15,890 suspended for a period of years contingent on no findings of violations of RCW 42.17A committed during the period of suspension D. INTEREST: No prejudgment interest is owed. Principal judgment amount(s) due and owing shall not bear interest unless the principal judgment is unpaid by the due date specified herein E. COSTS AND FEES: $5,000 in attorney fees; $1,500 in investigation costs, and $240 in court costs F. ATTORNEYS FOR JUDGMENT CREDITOR ROBERT W. FERGUSON, Attorney General LINDA A. DALTON, WSBA No. 15467 Senior Assistant Attorney General 18 19 20 21 22 Plaintiff, STATE OF WASHINGTON PIERCE COUNTY DEMOCRATIC CENTRAL COMMITTEE, a Washington registered political committee 23 24 25 26 STIPULATION AND AGREED JUDGMENT I ATTORNEY GENERAL OF WASHINGTON Campaign Finance Unit PO Box 40100 Olympia, WA 98504-0100 (360) 753-6200 1 G. 2 ATTORNEY FOR EVELYN FIELDING LOPEZ, WSBA No. 18900 JUDGMENT DEBTOR LOPEZ LAW PLLC 3 STIPULATION 4 The parties to this stipulation, Plaintiff, STATE OF WASHINGTON (STATE), and the 5 Defendant, PIERCE COUNTY DEMOCRATIC CENTRAL COMMITTEE, a Washington 6 registered political committee, desiring to resolve all claims arising out of the State's 7 complaint, hereby enter into the following stipulation: 8 1. Defendant PIERCE COUNTY DEMOCRATIC CENTRAL COMMITTEE agrees to pay 9 the State within 30 days of the date of entry of this Judgment an assessed civil penalty in 10 the amount of $31,780 with one-half suspended for four years, for its violations of RCW 11 42.17A for failing to timely disclose contribution and expenditure reports for election years 12 2015, 2016, and through the date of this agreement for 2017. 13 14 2. The parties agree that $15,890 of the assessed civil penalty will be suspended based on the following terms and conditions: 15 a. The suspension will be in effect for four years from the date of execution of the 16 Judgment. During the period of suspension, Defendant PIERCE COUNTY 17 DEMOCRATIC CENTRAL COMMITTEE agrees that it will not violate any 18 provision of RCW 42.17A. 19 b. In the event Defendant PIERCE COUNTY DEMOCRATIC CENTRAL 20 COMMITTEE is found by the Public Disclosure Commission or a court to have 21 committed a violation of RCW 42.17A during the suspension period, the suspended 22 penalty of $15,890 will immediately become due and payable within. 30 days of 23 such finding without further intervention of the Court. 24 25 c. If Defendant PIERCE COUNTY DEMOCRATIC CENTRAL COMMITTEE is not found to have committed violations of RCW 42.17A by the Public Disclosure 26 STIPULATION AND AGREED JUDGMENT 2 ATTORNEY GENERAL OF WASHINGTON Campaign Finance Unit PO Box 40100 Olympia, WA 98504-0100 (360) 753-6200 1 Commission or a court for conduct during the suspension period, then the 2 3 4 5 6 7' 8 9 suspended portion of the penalty will be set aside. 3. Defendant PIERCE COUNTY DEMOCRATIC CENTRAL COMMITTEE agrees to pay the State the total amount of $5,000.00 as attorney fees, $240 in court costs, and $1,500 in investigation costs in this action. 4. Defendant PIERCE COUNTY DEMOCRATIC CENTRAL COMMITTEE agrees to pay the State the unsuspended portion of the civil penalty ($15,890) and fees and costs ($6,740) in installments of $3,000 on January 1 and July 1 each year starting in 2018 until paid in full. Failure to timely make any installment will result in the remainder of the unpaid 10 portion to be due within 30 days of the missed installment. 11 DATED this aC 'h day of October, 2017. 12 ROBERT W. FERGUSON 13 14 15 16 Attorney General G Ok- au-tbv - A A. DALTON, WSBA No. 15467 Senior Assistant Attorney General Attorneys for Plaintiff 17 LOPEZ LAW PLLC 18 19 20 EVELU4 FIELDING LO~EZ, SBA o. 18900 Attorney for Defendant U 21 22 23 24 25 26 STIPULATION AND AGREED JUDGMENT 3 ATTORNEY GENERAL OF WASHINGTON Campaign Finance Unit PO Box 40100 Olympia, WA 98504-0100 (360) 753-6200 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 JUDGMENT THIS MATTER came on regularly before the undersigned judge of the above-entitled Court. Plaintiff, STATE OF WASHINGTON (STATE), appearing through its attorneys of record, ROBERT W. FERGUSON, Attorney General and LINDA A. DALTON, Senior Assistant Attorney General, and Defendant, PIERCE COUNTY DEMOCRATIC CENTRAL COMMITTEE appearing through its attorney, EVELYN FIELDING LOPEZ, apprised the Court of their agreement to the entry of this judgment for the purpose of settling and compromising this action brought under RCW 42.17A. The Court, having reviewed the records and files herein, and having found the settlement to be a just and proper resolution of this matter, and being otherwise fully advised in the premises, it is hereby ORDERED as follows: 1_ Defendant PIERCE COUNTY DEMOCRATIC CENTRAL COMMITTEE is hereby assessed a civil penalty, under the provisions of RCW 42.17A, in the amount of $31,780 payable to the State of Washington. 2. The amount of $15,890 of the assessed penalty is hereby suspended upon Defendant PIERCE COUNTY DEMOCRATIC CENTRAL COMMITTEE's compliance with the following court-ordered conditions: a. The suspension will be in effect for four years from the date of execution of the Judgment. During the period of suspension, Defendant PIERCE COUNTY DEMOCRATIC CENTRAL COMMITTEE agrees that it will not violate any provision of RCW 42.17A. b. In the event Defendant PIERCE COUNTY DEMOCRATIC CENTRAL COMMITTEE is found by the Public Disclosure Commission or a court to have committed a violation of RCW 42.17A during the suspension period, the suspended penalty of $15,890 will immediately become due and payable within 30 days of such finding without further intervention of the Court. 26 STIPULATION AND AGREED JUDGMENT 4 ATTORNEY GENERAL OF WASHINGTON Campaign Finance Unit PO Box 40100 Olympia. WA 985040100 (360)753-6200 1 c. If Defendant PIERCE COUNTY DEMOCRATIC CENTRAL COMMITTEE is not 2 found to have committed violations of RCW 42.17A by the Public Disclosure 3 Commission or a court for conduct during the suspension period, then the suspended 4 portion of the penalty will be set aside. 5 3. Defendant PIERCE COUNTY DEMOCRATIC CENTRAL COMMITTEE shall pay to the 6 State of Washington the amount of $5,000.00 as attorney fees, $240 in court costs, and 7 $1,500 in costs of investigation as authorized under RCW 42.17A.765. 8 4. Defendant PIERCE COUNTY DEMOCRATIC CENTRAL COMMITTEE shall pay the 9 State the unsuspended portion of the civil penalty ($15,890) and fees and costs ($6,740) in 10 installments of $3,000 each on January 1 and July 1 each year starting on January 1, 2018 11 until paid in full. Failure to timely make any installment shall result in the remainder of the 12 unpaid portion to be due within 30 days of the missed installment. 13 DONE IN OPEN COURT this 14 day of October, CHRISTOPHER LANESE 15 JUDGE CHRIS LANESE 16 Presented by: 17 ROBERT W. FERGUSON Attorney General 18 19 Q& OOt oaiz z/`- 20 INDA A. DALTON, W SBA No. 15467 Senior Assistant Attorney General Attorneys for Plaintiff 21 Approved as to Form: 22 23 24 EVELY' V FIELDING L0/ PZ, BA~. 18900 vv Lopez 'E aw PLLC Attorney for Defendant 25 26 STIPULATION AND AGREED JUDGMENT 5 ATTORNEY GENERAL OF WASHINGTON Campaign Finance Unit PO Box 40100 Olympia, WA 98504-0100 (360) 753-6200