E-FILED IN COUNTY CLERK'S OFFICE PIERCE COUNTY, WASHINGTON May 22 2018 11:57 AM KEVIN STOCK COUNTY CLERK 1 NO: 18-2-08238-8 2 3 4 5 6 IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON IN AND FOR THE COUNTY OF PIERCE 7 8 CITY OF LAKEWOOD, WASHINGTON, a municipal corporation, 9 Plaintiffs. 10 COMPLAINT FOR WRIT OF V. MANDAMUS; AND 11 12 13 14 STATE OF WASHINGTON; DEPARTMENT OF SOCIAL AND HEALTH SERVICES; WESTERN STATE HOSPITAL; AGING AND LONG-TERM SUPPORT ADMINISTRATION; WOODVILLE ADULT FAMILY HOME, LLC. DECLARATORY AND INJUNCTIVE RELIEF MARGARET W. KARIMI, Registered Agent, Defendants. 15 16 17 18 COMES NOW the Plaintiff, City of Lakewood ("City"), seeking a Writ of Mandamus; Declaratory Judgment and Injunctive Relief against Defendants, State of 19 Washington ("State"); Department of Social and Health Services ("DSHS"); Western 20 State Hospital; Aging and Long-Term Support Administration (ALTSA); Woodville, AFH, 21 22 LLC; Margaret Karimi, registered agent and sole proprietor of Woodville, AFH, LLC. 23 L PARTIES. 24 25 26 LI Plaintiff. The City of Lakewood, Washington is a municipal corporation org£inized under the laws of the State of Washington operating in Pierce County, 27 COMPLAINT FOR WRIT OF MANDAMUS AND DECLARATORY AND INJUNCTIVE RELIEF - 1 City of Lakewood Legal Department 6000 Main Street S.W. Lakewood, Washington 98499 1 2 3 4 5 Washington. The City of Lakewood is responsible for the public health and safety of approximately 60,665 citizens residing within the City. 1.2 Defendant State of Washington. The State of Washington is a governmental entity. 1.3 Defendant DSHS. The Washington State Department of Social and Health 6 Services (DSHS) is responsible for managing many subordinate state agencies and 7 programs including Aging and Long-term Support Administration; Behavioral Health; 8 9 Children's Administration; Developmental Disabilities; Economic Services; Financial 10 Services; Rehabilitation; and Service and Enterprise Support. DSHS licenses and regulates 11 Adult Family Homes, Enhanced Services Facilities and other outpatient treatment and care 12 13 facilities. 1.4 Defendant Western State Hospital. Western State Hospital (WSH) is a 14 state mental health facility operated by DSHS's Behavioral Health Administration and 15 located in the City of Lakewood, Washington. WSH provides care for the mentally ill, and 16 17 18 19 20 21 upon discharge from the hospital, conducts care assessments of patients and facilitates out patient housing and care for those patients. 1.5 Defendant Woodville Adult Family Home, LLC. Woodville Adult Family Home, LLC is a business located at 6909 Topaz Dr. SW in Lakewood, Washington, licensed as an Adult Family Home by DSHS. 22 1.6 Defendant Margaret W. Karimi. Ms. Karimi is the owner, operator and 23 24 registered agent of Woodville Adult Family Home, LLC. 25 //// 26 /// 27 COMPLAINT FOR WRIT OF MANDAMUS AND DECLARATORY AND INJUNCTIVE RELIEF - 2 Cityof Lakewood 6000 Main Street S.W. Lakewood, Washington 98499 j 2 3 ^ II. 2.1 JURISDICTION AND VENUE Jurisdiction. This Court has jurisdiction over this matter pursuant to RCW 4.28.020 and RCW 4.28.080. 2.2 Venue. Defendants reside and/or do business in Pierce County and venue is proper pursuant to RCW 4.12.010. III. 3.1 g 10 FACTS AND ALLEGATIONS Incorporation by reference. The City here re-alleges and incorporates by reference all the statements alleged in Paragraphs 1.1 through 1.6 and 2.1 through 2.2. 3.2 City's Police Power. Washington State Constitution Article XI vests the 11 City of Lakewood with police powers to provide for the public health, safety and welfare. 12 Pursuant to its police powers, the City regulates land use planning, development and the 13 operation of businesses within its jurisdictional boundaries. 14 3.3 The Growth Management Act, (GMA) chapter 36.70A RCW, requires the 15 City to adopt a Comprehensive Plan, including a process for identifying and siting 16 jy 18 essential public facilities. 3.4 GMA - Essential Public Facilities. The GMA defines essential public 19 facilities as those facilities that are typically difficuh to site, such as airports, state 20 education facilities and state or regional transportation facilities, regional transit authority 21 facilities, state and local correctional facilities, solid waste handling facilities, and inpatient 22 facilities including substance abuse facilities, mental health facilities, group homes, and 23 24 25 26 secure community transition facilities. 3.5 Fair Distribution - County-Wide Planning Policies. The GMA requires each county, in cooperation with cities and towns, to adopt county-wide planning policies. 27 COMPLAINT FOR WRIT OF MANDAMUS AND DECLARATORY AND INJUNCTIVE RELIEF - 3 of Lakewood L 6000 Mam Street S.W. Lakewood, Washington 98499 ^ The City participated in the development and adoption of the Pierce County County-Wide 2 Planning Policies. 3 The Pierce County County-Wide Policies call for fair distribution of essential ^ public facilities among jurisdictions. Exhibit A, Declaration of Dave Bugher, Assistant City Manager, providing excerpts from the Pierce County County-Wide Planning Policies, July 27, 2014, at p.l and 64-67 in Exhibit A-1. The policies relevant to this matter are substantively the same since originally adopted in 1992. Exhibit A-2, excerpts from the g originally adopted Pierce County County-Wide Planning Policies (1992). 10 11 3.6 Fair Distribution - Multi-County Planning Policies. The Puget Sound Regional Council (PSRC) develops policies and coordinates decisions about regional growth, transportation and economic development planning within King, Pierce, 13 Snohomish and Kitsap counties. .... The PSRC is composed of over 80 jurisdictions, 14 including Pierce County, as well as the cities and towns, ports, state and local 15 transportation agencies and tribal governments within the region. 16 ly The PSRC also calls for fair distribution of essential public facilities among 18 jurisdictions so that no one jurisdiction becomes unduly burdened by them. Exhibit A-3, 19 excerpts from the PSRC Multicounty Planning Policies, Vision 2040, at p. 29; 89; and 94- 20 21 95. 3.7 State Agencies - Required to Comply with Policies. Defendants WSH, 22 DSHS, and ALTSA, as state agencies, are required to comply with county and city 23 24 comprehensive plans and regulations pursuant to RCW 36.70A.103. Defendants WSH, 25 DSHS, and ALTSA, are also, as state agencies, required to adhere to the County-wide 26 Policies pursuant to RCW 36.70A.210(4). 27 COMPLAINT FOR WRIT OF MANDAMUS AND DECLARATORY AND INJUNCTIVE RELIEF -4 City of Lakewood 6000 Mafnl^ers.W. Lakewood, Washington 98499 ^ 3.8 Notice to Agencies. GMA requires local jurisdictions to submit plans and 2 policies to the State Department of Commerce sixty days before adoption. RCW 3 36.70A.106. The same state department monitors progress and the development of county- 4 wide planning policies. RCW 36.70A.210. The state and its agencies have notice of the adoption of county-wide planning policies and an opportunity to appeal adopted countywide planning policies. RCW 36.70A.210(6). State agencies had notice that they were to fairly distribute essential public facilities, including Adult family Homes within Pierce County, as early as 1992. IQ 11 3.9 State Violation of Policies. Defendants have violated and continue to violate the above GMA policies by failing to fairly distribute essential public facilities, including Aduh Family Homes, in Pierce County. For example, and as more fully described 13 below, the population of the City is roughly 7 percent of the total Pierce County population, 14 but the City has 29 percent, almost a third, of all the Adult Family Homes in the County. 15 Exhibit A. 16 3.10 Adult Family Homes are a type of group home and are considered 17 jg essential public facilities pursuant to the GMA. Aduh Family Homes are licensed and 19 regulated by DSHS. Only DSHS may revoke or suspend Adult Family Home licenses. 20 RCW 70.128.160. 21 22 Adult Family Homes are meant to be an essential component of the state's longterm care system and to reduce institutionalization of "vulnerable" people with "functional 23 limitations" pursuant to RCW 70.128.005. 24 25 25 27 3.11 "Vulnerable" as used above is not defined in statute. 3.12 People with "functional limitations" is defined as people who need "personal and special care." RCW 70.128.007 (1). COMPLAINT FOR WRIT OF MANDAMUS AND DECLARATORY AND INJUNCTIVE RELIEF - 5 City of Lakewood 6000 Mam Street S.W. Lakewood, Washington 98499 ^ 3.13 "Personal care" is not specifically defined by statute, but DSHS's rules state 2 that it "means both physical assistance and/or prompting and supervising the performance 3 of direct personal care tasks as determined by the resident's needs and does not include ^ assistance with tasks performed by a licensed health professional." WAC 388-76-10000. 3.14 "Special care" is defined in statute as "care beyond personal care as defined by the department, in rule" (RCW 70.128.010(8). DSHS's rule, repeating the statute, defines "special care" as "care beyond personal care services" (WAC 388-76-10000). ^ 3.15 Aduh Family Home operators must adhere to certain requirements 10 including that they "promote the health, safety, and well-being of each resident" and 11 "ensure that any volunteer, student, employee, or person residing within the adult family home who will have unsupervised access to any resident shall not have been convicted of a 13 crime listed under RCW 43.43.830 or RCW 43.43.842, or been found to have abused, 14 neglected, exploited, or abandoned a minor or vulnerable adult as specified in RCW 15 74.39A.056(2)." RCW 70.128.130 (2) and (13) in part and emphasis added. 16 jy 18 3.16 imprisonment, and sexual exploitation. 3.17 20 21 Crimes listed under RCW 43.43.830 include: rape, assault, unlawful Adult Family Homes must be considered a residential use of property as well as a "permitted use in all areas zoned for residential or commercial purposes" pursuant to RCW 70.128.140. Adult Family Homes are listed as a permitted use in the 22 City's residential zones. Exhibit A. 23 24 3.18 Enhanced Services Facilities are also considered to be an essential public 25 facility pursuant to the GMA. Unlike Adult Family Homes, Enhanced Services Facilities 26 are not required to be considered a residential use. 27 COMPLAINT FOR WRIT OF MANDAMUS AND DECLARATORY AND INJUNCTIVE RELIEF - 6 ^ity of Lakewood , 6000 Mam Street S.W. Lakewood, Washington 98499 j 3.19 Enhanced Services Facilities are designed to assist people with serious 2 issues of substance abuse, mental illness, dangerous behavior or a combination thereof 3 pursuant to chapter 70.97 RCW. The admission criteria is as follows: RCW 70.97.030 Admission criteria. 5 7 A person, eighteen years old or older, may be admitted to an enhanced services facility if he or she meets the criteria in subsections (1) through (3) of this section: (1) The person requires: (a) Daily care by or under the supervision of a mental health professional, chemical dependency professional, or nurse; or g (b) assistance with three or more activities ofdaily living; and 10 (2) The person has: (a) A mental disorder, chemical dependency disorder, or both; 11 (b) an organic or traumatic brain injury; or (c) a cognitive impairment that results in symptoms or behaviors requiring supervision and facility services; [and] 13 14 (3) The person has two or more of the following: (a) Self-endangering behaviors that are frequent or difficult to manage; (b) Aggressive, threatening, or assaultive behaviors that create a risk to the 15 health or safely of other residents or staff, or a significant risk to property 16 and these behaviors are frequent or difficult to manage; (c) Intrusive behaviors that put residents or staff at risk; jy (d) Complex medication needs and those needs include psychotropic medications; 18 (e) A history of or likelihood of unsuccessful placements in either a licensed facility or other state facility or a history of rejected applications for admission to other licensed facilities based on the person's behaviors, history, or security needs; (f) A history of frequent or protracted mental health hospitalizations; 20 21 (g) A history of offenses against a person or felony offenses that created substantial damage to property. 22" 3.20 Based on the above admission criteria, residents of Enhanced Services 23 2^ Facilities have needs beyond "personal care" or "special care" offered by Adult Family 25 Homes. 26 27 COMPLAINT FOR WRIT OF MANDAMUS AND DECLARATORY AND INJUNCTIVE RELIEF - 7 City of Lakewood 6000 Mam Street S.W. Lakewood, Washington 98499 j 3.21 Adult Family Homes and Enhanced Services Facilities are Different 2 Facilities. Aduh Family Homes are not only different from Enhanced Services Facilities, 3 they are statutorily opposite; Adult Family Homes provide services for the "vulnerable," ^ while Enhanced Services Facilities provide services for those with "dangerous behavior.' Enhanced Services Facilities require specialized facilities above and beyond those required for Adult Family Homes. Enhanced Services Facilities are built as secure institutional facilities like some hospitals and prisons. Adult Family Homes are built to g residential standards. Exhibit B, Declaration of the City of Lakewood Building Official, 10 Nancy Craig. Specifically, the homes used for Aduh Family Homes must meet building 11 criteria adopted in the International Residential Code (IRC). RCW 70.128.040 and WAC 51-51-0325. Id. The IRC includes specifications for things like wheelchair ramps and 13 grab bars. Id. The building requirements for Enhanced Services Facilities, by contrast, are 14 established by the Department of Health and are more similar to secure, institutional 15 facilities than they are to residential homes. RCW 70.97.060; WAC 388-107; and Exhibit 16 17 18 B. 3.22 Adult Family Homes and Enhanced Services Facilities have Different 19 Staffing. Enhanced Services Facilities require specialized staffing above and beyond those 20 required for Adult Family Homes. Adult Family Homes require only one "qualified" staff 21 member, asleep or awake, to be at the home with a maximum of six residents. Enhanced 22 Services Facilities require at least two staff members to be awake at all times; a registered 23 24 25 and/or licensed nurse present on-site at all times and a mental health professional to be on site at least eight hours each day and on-call at all times. Id. 26 27 COMPLAINT FOR WRIT OF MANDAMUS AND DECLARATORY AND INJUNCTIVE RELIEF - 8 Cityof Lakewood 6000 Mam Street S.W. Lakewood, Washington 98499 j 3.23 Converting Adult Family Homes into Enhanced Services Facilities. 2 Residents of Enhanced Services Facilities and Adult Family Homes require substantially 3 different levels of care and facilities, nonetheless Adult Family Homes may be converted ^ into Enhanced Services Facilities. RCW 70.97.060 (Adult Family Homes "that become licensed as facilities under this chapter (ESF) shall be deemed to meet applicable state and local rules, regulations, permits, and code requirements.") and WAC 388-107-0710 (Conversion of a currently licensed facility to an enhanced services facility). g 3.24 Conversion of an Aduh Family Home into an Enhanced Services Facility 10 requires the facility to, among other things: 1) ensure previous construction does not 11 jeopardize resident health and safety; and 2) meet enhanced services facility construction 19 13 requirements before being converted. Id. 3.25 Enhanced Services Facilities are permitted in the City, but only in non- 14 residential areas because the City has determined that Enhanced Services Facilities, unlike 15 Adult Family Homes, are incompatible with residential zones. Chapter 18A LMC. 16 jy Enhanced Services Facilities are a more intense land use because the target residents 18 require more care and treatment in far more secure facilities than those served in Aduh 19 Family Homes. 20 21 Aduh Family Homes are permitted in residential areas to allow integration of the residents into the community. See, chapter 70.128 RCW. There is no such goal of 22 community integration with residents of Enhanced Services Facilities either in statute or in 23 24 25 practice; the facilities are secure, institutional buildings constructed like other institutional facilities that do not allow, no less encourage, community integration. 26 27 COMPLAINT FOR WRIT OF MANDAMUS AND DECLARATORY AND INJUNCTIVE RELIEF - 9 City of Lakewood , 6000 Mam Street S.W. Lakewood, Washington 98499 j 3.26 Currently, there are two licensed and operating Enhanced Services Facilities 2 in Washington State. Exhibit A, Declaration of Dave Bugher. Both are located in non- 3 residential areas. Id. ^ 3.27 Washington State Department of Social and Health Services (DSHS) ^" has the duty of issuing licenses and regulating Adult Family Homes pursuant to chapter 70.128 RCW and particularly RCW 70.128.060. DSHS also licenses and regulates Enhanced Services Facilities pursuant to chapter 70.97 RCW. g 3.28 Aging and Long-term Support Administration (ALTSA) is a division of 10 DSHS. ALTSA and WSH place, or facilitate the placement of, patients into less-restrictive 11 alternatives to in-patient hospital care, including Aduh Family Homes and Enhanced 10 Services Facilities. 3.29 DSHS, ALTSA and WSH are under pressure by both legal requirements 14 and the volume of people needing care to offer placements in facilities that offer the least 15 „ restrictive alternatives to institutional care; e.g., RCW 71.34.740. 16 jy 3.30 Adult Family Homes in Lakewood. Pursuant to the state's Adult Family 18 Home regulatory scheme, operators must submit an application to the City to begin 19 operating a home. Specifically, the state has adopted the International Residential Code, 20 adding a section on Adult Family Homes at IRC Chapter 3, Section R325. The state 21 legislature directed DSHS to adopt rules to regulate Adult Family Homes which DSHS did 22 at WAC 388-76 (Adult Family Homes - Licensing) and WAC 51-51-0325 (repeats 23 24 International Residential Code as amended by the state with Adult Family Home 25 I provisions). The State rules require Adult Family Homes to be "inspected and approved" 26 by the "local building official" before DSHS issues a license. WAC 388-76-10700. 27 COMPLAINT FOR WRIT OF MANDAMUS AND DECLARATORY AND INJUNCTIVE RELIEF - 10 Cityof Lakewood 6000 Mam Street S.W. Lakewood, Washington 98499 ^ Therefore, while the City "inspect(s) and approve(s)" Adult Family Homes, it does 2 so only at the state's direction, using state building requirements. State law preempts and 3 precludes any attempt by the City to regulate or otherwise control the licensing, operation ^ orplacement ofresidents into Adult Family Homes. 3.31 The City has identified Adult Family Homes in Pierce County on a map. Exhibit A-4, Declaration of Dave Bugher, attaching and incorporating a map of Adult Family Homes. The City has compared the number of Adult Family Homes located throughout Pierce ^ County to those located within the City. As of May 2018, there are 266 Adult Family Homes in Pierce County and 77 of those are located in the City. Id. Of the 77 Adult Family Homes in jI the City, 35 of those are located in the Oakbrook neighborhood of the city. Id. While the City 12 of Lakewood is one of 23 cities within Pierce County, 31 percent of Adult Family Homes are 13 located within its jurisdictional boundaries. Id. Stated another way, while the population of the City is roughly 7 percent of the total 15 16 Pierce County population, the City has 29 percent of the Adult Family Homes, almost a third of them, most of which are located next to the State's largest mental health facility, which is 17 also within the City's jurisdictional boundaries. Id. 18 3.32 Placement of Alleged Murderer in Adult Family Home. The State 19 2Q recently attempted to place, or otherwise release, at least one resident in an Adult Family 21 Home after that resident had spent most of his adult life at WSH; has a history of violence 22 including murder and assault; and is considered at risk of future danger to himself and others, even when compliant with medications. Exhibit C, Declaration of Chief Zaro. For 24 purposes of this case, and in an effort to respect patient privacy, the City will refer to this 25 person as "Resident A.' 26" 27 COMPLAINT FOR WRIT OF MANDAMUS AND DECLARATORY AND INJUNCTIVE RELIEF - 11 City of Lakewood 6000 Mam Street S.W. Lakewood, Washington 98499 3.33 Public Safety Review Panel. The release and/or placement of Resident A 2 intothe community should have been reviewed by the Public Safety Review Panel (PSRP). 3 It was not. ^ The PSRP was created in 2010 (Chapter 263, Laws of 2010) to independently ^• assess and provide advice to DSHS and to the courts, "regarding potential risk to safety related to the proposed Conditional Release or Final Discharge of patients found Not Guilty by Reason of Insanity (NGRI) committed to Western State Hospital (WSH) or g Eastern State Hospital (ESH)." PSRP Website. The jurisdiction of the PSRP was 10 expanded in 2013 "to include patients civilly committed to WSH or ESH after the court 11 found the criminal defendant not competent to stand trial for a violent offense." Id. 12 13 RCW 10.77.270 provides: DSHS "shall establish an independent public safety review panel for the purposes of advising the secretary and the courts with respect to 14 persons who have been found not guilty by reason of insanity, or persons committed under 15 the involuntary treatment act where the court has made a special finding." 16 jy RCW 7I.05.280(3)(b) provides: "At the expiration of the fourteen-day period of 18 intensive treatment, a person may be confined for further treatment... if.. .(3) Such person 19 has been determined to be incompetent and criminal charges have been dismissed pursuant 20 to RCW 10.77.086(4), and has committed acts constituting a felony, and as a result of a 21 mental disorder, presents a substantial likelihood of repeating similaracts ... or (b) For any 22 person subject to commitment under this subsection where the charge underlying the 23 2^ 25 26 finding of incompetence is for afelony classified as violent." 3.34 Defendant WSH violated RCW 71.05.280 because it did not provide PSRP review of the planned release of Resident A from WSH. 27 COMPLAINT FOR WRIT OF MANDAMUS AND DECLARATORY AND INJUNCTIVE RELIEF - 12 City of Lakewood 6000 Mam Street S.W. Lakewood, Washington 98499 j 3.35 Registered Sex Offenders in Adult Family Homes. The State, through 2 WSH, DSHS and/or ALTSA, is aware or should be aware that at least four registered sex 3 offenders have been placed or conditionally released into an Adult Family Home in the ^ City, namely Woodville Adult Family Home, LLC. Exhibit A-5 (Secretary of State - ^ registration); Exhibit A-6 (DSHS disclosure for Woodville AFH, LLC); Exhibit C 6 I (DeclarationofchiefZaro); andExhibit D,excerptoftestimonyofferedby Mr. Kamari. ^ The names of the registered sex offenders in the Woodville Adult Family Home gj are: Chris Lee Benson; Ernest Chappell; Steven Leroy Jordan; and Shawn Tanzy. Exhibit 101 C, Declaration of Chief Zaro. Mr. Chappell was convicted of rape with force and threat in 11 December of 1983 and kidnapping in the first degree in August of 1984. Id. He is 12 reportedly disabled. 13 Mr. Benson pled guilty to second degree child molestation in November of 2014. Id. Mr. Jordan has two convictions for possessing child pornography; 14 one in 2002 and another in 2015. Id. Mr. Tanzy was convicted of child molestation in the 15 third degree in 2000; possession of drug paraphernalia in 2000; assault in 2000; and 16 jy 18 criminal trespass in 1999 and 2013. Id. 3.36 More than "Personal" or "Special" Care Required. Even if Resident A 19 and the registered sex offenders identified above may be described as "vulnerable' 20 pursuant to the Adult Family Home statute, they do not otherwise fit the criteria for 21 residents of an Adult Family Home because they require far more than personal and/or 22 special care. RCW 70.128.010. 23 24 Adult Family Homes are not required to have, and do not have, the staff, resources 25 or secure facilities needed to accommodate residents like registered sex offenders, who 26 have a history of violence and/orpredation. Placement of registered sex offenders in Adult 27 COMPLAINT FOR WRIT OF MANDAMUS AND DECLARATORY AND INJUNCTIVE RELIEF - 13 City of Lakewood Department 6000 Mam Street S.W. Lakewood, Washington 98499 j Family Homes foreseeably risk the safety and security of other Aduh Family Home 2 residents, current and prospective, and the general public. 3 ^ 3.37 Failure to Disclose - Registered Sex Offenders. Woodviile AFH, LLC has seven bedrooms. Exhibit E (Assessor Treasurer Data). Adult Family Homes may accept up to six residents so there are two potential vacancies in this particular home. Publicly available documents about Woodviile AFH, LLC, however, do not disclose the fact that four registered sex offenders reside in the home. Exhibit A; A-5 and A-6. ^ A prospective resident of that and any other Aduh Family Home would have no 10 way to know if registered sex offenders currently reside or may later be admitted to reside 11 in a home licensed and regulated by the state. Exhibit A and C. 12 13 3.38 Violation of the Adult Family Home Law - Operator. As noted above, operators of Adult Family Homes are required to "promote the health, safety, and well- 14 being of each resident" and "ensure that any ... person residing within the adult family 15 home who will have unsupervised access to any resident shall not have been convicted of a 16 jy crime listed under RCW 43.43.830 or43.43.842, or been found to have abused, neglected, 18 exploited, or abandoned a minor or vulnerable adult as specified in RCW 19 74.39A.056(2)." RCW 70.128.130. 20 21 Defendant Woodviile AFH, LLC has violated the above statutory requirements for Adult Family Homes by admitting registered sex offenders into their home because such 22 admissions are inherently unsafe. By state law, registered sex offenders pose a risk of re23 24 25 I offending. Admitting those with a risk of reoffending into a home meant for vulnerable adults does not "promote the health, safety and well-being ofeach resident.' 26 27 COMPLAINT FOR WRIT OF MANDAMUS AND DECLARATORY AND INJUNCTIVE RELIEF - 14 ^ity of Lakewood , 6000 Mam Street S.W. Lakewood, Washington 98499 Defendant Woodville AFH, LLC has violated the above statutory requirements for 1 n 2 Adult Family Homes by admitting the particular registered sex offenders into their home. 3 The crimes committed by those offenders are the types of crimes referenced in RCW 80.128.130 (rape, assault, unlawful imprisonment, and sexual exploitation) which necessarily disqualifies them from residing in this or any Adult Family Home. 3.39 Violation of the Adult Family Home Law - State. By releasing, placing and/or facilitating the placement of the above registered sex offenders in the Woodville g AFH, LLC, Defendants WSH, DSHS and ALTSA have failed to properly care for them as 10 mentally ill citizens of the state and have failed to properly license and/or regulate the 1 home. 12 13 3.40 Illegal Conversion: Adult Family Home to Enhanced Services Facilities. Their status as registered sex offenders, together with any functional limitations, suggest 14 that the above registered sex offenders require a more secure setting than what is available 15 in an Adult Family Home. The placements by WSH, DSHS and/or ALTSA of Resident A 16 jy and the registered sex offenders fit the admission criteria for Enhanced Services Facilities 18 in that they have a history of violence and/or predation and/or otherwise meet the 19 admission criteria of RCW 70.97.030. 20 21 3.41 The above referenced placements and the operation of the Woodville AFH, LLC, unlawfully attempt to convert Adult Family Homes into Enhanced Services Facilities 22 without the due and proper process; violate the City's code; and ignore the City's lawful 23 2^ exercise of its zoning and regulatory authority. As a result, these placements fail to 25 provide the kind of secure facilities and staffing levels required of them, putting at risk the 26 27 COMPLAINT FOR WRIT OF MANDAMUS AND DECLARATORY AND INJUNCTIVE RELIEF - 15 of Lakewood j 6000 Mam Street S.W. Lakewood, Washington 98499 j health, safety and welfare of other Aduh Family Home residents, themselves and the 2 general public. 3 3.42 The City has attempted to learn if WSH, DSHS and/or ALTSA has made or ^ intends to make other such placements like the above referenced placements through a ^ public records request pursuant to chapter 42.56 RCW. In one installment of the state's 6 response to the City's request for public records, the state produced a matrix of the 7 placement of some 407 residents from WSH to other facilities. Exhibit F, State Matrix. 8 ^ The matrix demonstrates that residents, even if given the exact same classification, 10 are shown to have been placed in Adult Family Homes, Enhanced Services Facilities and 11 in-patient hospital care, which are vastly different facilities from each, rendering such ^^ classifications meaningless for purposes ofplacement and treatment. 3.43 WSH, DSHS and/or ALTSA have ignored the substantially different 14 admission criteria for Adult Family Homes, Enhanced Services Facilities and in-patient 15 treatment by placing those with a history of violence and/or predation into Aduh Family 16 Yj Homes. These action not only violate the state's statutory criteria, it violates the City's 18 code and is dangerous. 19 WSH, DSHS and/or ALTSA have placed and/or may potentially place, those with a 20 history of violence and/or predation in communal living groups with residents who are 21 considered, by state statue, to be vulnerable to abuse, and have done so without ensuring 22 that proper staffing and facilities are provided. 23 IV, 24 25 26 4.1 CAUSES OF ACTION Writ of Mandamus pursuant to chapter 7.16 RCW. A writ of Mandamus may be issued by any court, except a district or municipal court, to any inferior tribunal. 27 COMPLAINT FOR WRIT OF MANDAMUS AND DECLARATORY AND INJUNCTIVE RELIEF - 16 Lakewood c" 6000 Mam Street S.W. Lakewood, Washington 98499 j corporation, board or person, to compel the performance of an act which the law especially 2 enjoins as a duty resulting from an office, trust or station, or to compel the admission of a 3 party to the use and enjoyment of a right or office to which the party is entitled, and from ^ which the party is unlawfully precluded by such inferior tribunal, corporation, board or person. 4.2 Declaratory relief pursuant to chapter 7.24 RCW (The Uniform Declaratory Judgment Act). Courts of record within their respective jurisdictions shall g have power to declare rights, status and other legal relations whether or not further relief is 10 or could be claimed. An action or proceeding shall not be open to objection on the ground 11 that a declaratory judgment or decree is prayed for. The declaration may be either affirmative or negative in form and effect; and such declarations shall have the force and 13 effect of a final judgment or decree. 14 4.3 Injunctive relief pursuant to chapter 7.40 RCW Injunctions and CR 65 15 Injunctions. Injunctions may be granted by the superior court. When it appears by the 16 Iy complaint that the plaintiff is entitled to the relief demanded and the relief, orany part 18 thereof, consists in restraining the commission or continuance of some act, the commission 19 or continuance of which during the litigation would produce great injury to the plaintiff; or 20 when during the litigation, it appears that the defendant is doing, or threatened, or is about 21 to do, or is procuring, or is suffering some act to be done in violation of the plaintiffs 22 rights respecting the subject of the action tending to render the judgment ineffectual; or 23 24 where such relief, or any part thereof, consists in restraining proceedings upon any final 25 orderor judgment, an injunction may be granted to restrain such act or proceedings imtil 26 the fiarther order of the court, which may afterwards be dissolved or modified upon motion. 27 COMPLAINT FOR WRIT OF MANDAMUS AND DECLARATORY AND INJUNCTIVE RELIEF - 17 City of Lakewood 6000 Mam Street S.W. Lakewood, Washington 98499 J V. PRAYER FOR RELIEF 2 WHEREFORE, Plaintiffrespectfully prays for the following relief: 3 A. For an Order Mandating that DSHS revoke Woodville, LLC's Adult Family 4 Home license pursuant to RCW 70.128.160 because the home: 1) has not adhered to the ^ statutory requirements for such homes and 2) has attempted to illegally convert the home 6 into an Enhanced Services Facility. 7 B. For an Order Mandating that DSHS properly license and regulate Adult 8 ^ 10 11 Family Homes to ensure that those with a history of violence and/or predation are not placed with vulnerable residents with functional limitations in Aduh Family Homes. C. For an Order Mandating that Western State Hospital discharge patients with chronic mental illness only when those patients have adequate housing and care, commensurate with their illness. 14 D. For an Order Mandating that the state fairly distribute essential public 15 facilities, including Adult Family Homes and Enhanced Services Facilities, throughout 16 jy Pierce County in compliance with the Pierce County County-Wide Planning Policies and 18 the Puget Sound Regional Council's Policies. 19 20 21 E. For a Declaration that those with a history of violence and/or predation do not fit the definition of residents eligible for residential treatment and placement in Adult Family Homes, who are, by statute, considered to be vulnerable people with functional 22 limitations. 23 24 F. For a Declaration that Defendants have violated the GMA by failing to 25 comply with the Pierce County County-Wide Planning Policies because they have not 26 fairly distributed essential public facilities among jurisdictions, but have licensed and 27 COMPLAINT FOR WRIT OF MANDAMUS AND DECLARATORY AND INJUNCTIVE RELIEF - 18 City of Lakewood 6000 Mam Street S.W. Lakewood, Washington 98499 j otherwise approved a disproportionate number in the City relative to other Pierce County 2 jurisdictions. 3 ^ G. For Injunctive Relief restraining all Defendants from hosting, placing and/or facilitating the placement of those with a history of violence and/or predation in Aduh Family Homes. 6 H. For Injunctive Relief restraining all Defendants from converting Adult 7 Family Homes into Enhanced Services Facilities without complying with both state statute 8 g 10 11 and the City's code. I. For a Moratorium on licensing or otherwise siting Adult Family Homes in the City until all existing Adult Family Homes in the City are fiilly investigated to ensure that the residents meet the criteria for Adult Family Homes and until Defendants have 13 established a comprehensive plan to provide and equitably distribute essential public 14 facilities, including Aduh Family Homes and Enhanced Services Facilities, throughout 15 16 jy 18 Pierce County. ^ J. For Judgment for the reasonable attorneys' fees and costs incurred by Plaintiffs in this lawsuh; and 19 K. 20 DATED this 22nd day of May, 2018. 21 For such other relief as the court may deemjust or equitable. CITY OF LAKEWOOD, WASHINGTON 22 23 By Heidi di Afrfi Aim Wachter, WSBA #18400 #18 25 Attorney for Plaintiff 26 27 COMPLAINT FOR WRIT OF MANDAMUS AND DECLARATORY AND INJUNCTIVE RELIEF - 19 City of Lakewood u, 6000 Mam Street S.W. Lakewood, Washington 98499 EXHIBIT A KDOO-JCH THE SUPERIOR COURT OF THE STATE OF WASHINGTON IN AND FOR THE COUNTY OF PIERCE CITY OF LAKEWOOD, WASHINGTON, a municipal corporation, Plaintiffs, DECLARATION OF DAVE BUGHER, ASSISTANT CITY MANAGER, CITY OF v. STATE OF DEPARTMENT LAKEWOOD OF SOCIAL AND HEALTH WESTERN STATE AGING AND LONG-TERM SUPPORT WOODVILLE ADULT FAMILY HOME, LLC, MARGARET W. KARIMI, Registered Agent, Defendants. David Bugher, declares and states: 1. I am the Assistant City Manager for the City of Lakewood and responsible for overseeing the Community and Economic Development Department of the City. 2. I am over the age of eighteen and competent to testify to the matters herein. 3. The Growth Management Act, (GMA) chapter 36.70A RCW, requires the City to adopt a Comprehensive Plan, including a process for identifying and siting essential public facilities. 4. GMA Essential Public Facilities. The GMA defines essential public facilities as those facilities that are typically dif?cult to site, such as airports, state education facilities, state or regional transportation facilities, regional transit authority DECLARATION OF BUGHER, City Of Lakewood Legal Department ASSISTANT CITY MANAGER - 6000 Main Street 3w. Lakewood, Washington 98499 ?summariesfacilities, state and local correctional facilities, solid waste handling facilities, and inpatient facilities including substance abuse facilities, mental health facilities, group homes, and secure community transition facilities. 5. GMA County-Wide Planning Policies Fair Distribution. The GMA requires each county, in cooperation with cities and towns, to adopt county?wide planning policies. The City participated in the development of the Pierce County County?Wide Planning Policies. The Pierce County-Wide Policies call for fair distribution of essential public facilities among jurisdictions. A true and correct excerpt of the Pierce County County- Wide Flaming Policies (2014), at pages 1 and 64-67, is attached and incorporated herein as Exhibit A-l. The relevant policies related to essential public facilities have not been substantively changed since 1992 when they were ?rst adopted. A true and correct excerpt of the original Pierce County County-Wide Flaming Policies (1992), at pages 38?41, is attached and incorporated herein as Exhibit 6. Puget Sound Regional Council Fair Distribution. The Puget Sound Regional Council (PSRC) develops policies and coordinates decisions about regional growth, transportation and economic development planning within King, Pierce, Snohomish and Kitsap counties. It is composed of over 80 jurisdictions, including the above counties and other cities and towns, ports, state and local transportation agencies and tribal governments within the region. The PSRC also calls for fair distribution of essential public facilities among jurisdictions so that no one jurisdiction becomes unduly burdened. A true and correct DECLARATION OF BUGHER, Eity ega epa men ASSISTANT CITY MANAGER - 2 6000 Main Street SW. Lakewood, Washington 98499 excerpt of the PSRC Multicounty Flaming Policies, Vision 2040, at pages 29; 89; and 94- 95, are attached and incorporated herein as Exhibit 7. State Agencies - Required to Comply with Policies. Defendants Western State Hospital (WSH), Department of Social and Health Services (DSHS), and Aging and Long-Term Services (ALTSA), as state agencies, are required to comply with county and city comprehensive plans and regulations pursuant to RCW 36.70A.103. Defendants WSH, DSHS, and ALTSA, are also, as state agencies, required to comply with the County-wide Policies pursuant to RCW 8. Adult Family Homes are a type of group home and are considered essential public facilities pursuant to the GMA. Adult Family Homes are licensed and regulated by DSHS and only DSHS may revoke or suspend Adult Family Home licenses pursuant to RCW 70.128.160. Adult Family Homes must be considered a residential use of property as well as a ?permitted use in all areas zoned for residential or commercial purposes? pursuant to RCW 70.128.140. Adult Family Homes are listed as a permitted use in the City?s residential zones. 9. Enhanced Services Facilities are also considered to be an essential public facility pursuant to the GMA. Unlike Adult Family Homes, however, Enhanced Services Facilities are not required to be considered a residential use. Enhanced Services Facilities are designed to assist people with serious issues of substance abuse, mental illness, dangerous behavior or a combination thereof pursuant to chapter 70.97 RCW. DECLARATION OF BUGHER, City Of Lakewood ASSISTANT CITY MANAGER - 3 Legal Department 6000 Main Street S.W. Lakewood, Washington 98499 LushAccording to the Department of Health website as of May 16, 2018, there are only two Enhanced Services Facilities operating in the state. Both are sited in non-residential areas. 10. Washington State Department of Social and Health Services (DSHS) has the duty of issuing licenses and regulating Adult Family Homes pursuant to chapter 70.128 RCW and particularly RCW 70.128.060. DSHS also licenses and regulates Enhanced Services Facilities pursuant to chapter 70.97 RCW. 11. Adult Family Homes Lakewood. Using the Adult Family Home Locator, I have identi?ed and charted Adult Family Homes on a map, a true and correct copy of which is attached and incorporated herein as Exhibit A-4. Using DSHS data, I have compared the number of Adult Family Homes located throughout Pierce County to those located within the City. A true and correct table recording Pierce County Adult Family Homes is attached and incorporated herein as Exhibit A-5. As of May 2018, there are 266 Adult Family Homes with a total of 1,513 beds located within Pierce County. As of May 2018, there are 77 Adult Family Homes within the City with a total of 451 beds. Of the 77 Adult Family Homes located within the City, 35 of the homes are located within the Oakbrook neighborhood which is adjacent to Western State Hospital. While the City is only one of 23 cities within Pierce County, 29 percent of all Adult Family Homes are located within the City. Lakewood has one of the highest number of Adult Family Homes per capita in all of Pierce County. Stated another way, while the population of the City is roughly-7 percent of the total Pierce County population, the City has 29 percent of the Adult Family Homes, most of which are located next to the state?s largest mental health facility, which is also within the City?s jurisdictional boundaries. DECLARATION OF BUGHER, City Of Lakewood Legal Department ASSISTANT CITY MANAGER - 4 6000 Main Street SW. Lakewood, Washington 98499 12. Woodville AFH. I have searched publicly available documents related to the Woodville Adult Family Home located at 6909 Topaz Dr. SW Lakewood, WA 98498. I found documents on file with DSHS and the Washington Secretary of State?s of?ce related to Woodville AFH LLC, true and correct copies of which are attached hereto as Exhibits (Secretary of State) and (DSHS disclosure). None of the publicly available documents provide notice that four of the residents of the home are registered sex offenders. I declare under penalty of perjury under the laws of the State of Washington that the foregoing is true and correct to the best of my knowledge, information and belief. EXECUTED 1111519111 day of May, 2018 at Lakewood, Washington. Dave Bugher \3 Assistant City Manager ity of Lakewood DECLARATION OF BUGHER, City Of LakeWOOd Legal Department ASSISTANT CITY MANAGER 5 6000 Main Street SW. Lakewood, Washington 98499 EXHIBIT A?l Countywide Planning Policies for Pierce County, Washington As Amended Effective July 27, 2014 Siting of Essential Public Capital Facilities COUNTYWIDE PLANNING POLICY ON SITING OF ESSENTIAL PUBLIC CAPITAL FACILITIES OF A COUNTYWIDE OR STATEWIDE SIGNIFICANCE Background - Requirements of Growth Management Act The Washington State Growth Management Act requires that the comprehensive plan of the County and of each municipality in the County include a process for identifying and siting essential public facilities ?Essential" public facilities include, but are not limited to, those facilities that are typically dif?cult to site, such as airports, state education facilities, state or regional transportation facilities, state and local correctional facilities, solid waste handling facilities, and in? patient facilities, including substance abuse facilities, mental health facilities and group homes The State Of?ce of Financial Management is required to maintain a list of essential state public facilities that are required or likely to be built within the next six (6) years. Facilities may be added to the list at any time. The Growth Management Act further mandates that no local comprehensive plan or development regulation may preclude the siting of essential public facilities Countywide Planning Policy The County, and each municipality in the County, shall adopt a policy its comprehensive plan, on the siting of essential public capital facilities of a Countywide or statewide nature. 1.1 Essential public facilities must have a useful life of 10 years or more and be either: 1.1.1 a Countywide facility which has the potential for serving the entire County or more than one jurisdiction in the County; or 1.1.2 a statewide facility which serves or has the potential for serving the entire state, or which serves less than the entire state, but more than one county. EFF-2. The County, and each municipality in the County, shall identify lands useful for public purposes and incorporate such designations in their respective comprehensive plans. EFF-3. The County, and each municipality in the County, shall incorporate a policy and process in their respective comprehensive plans to identify and site essential public facilities. The process and policy shall include the following components: 3.1 a requirement that the state provide a justifiable need for the public facility and for its location in Pierce County based upon forecasted needs and a logical service area, and the distribution of facilities in the region and state; July 27, 2014 64 3.2 Siting of Essential Public Capital Facilities a requirement that the state establish a public process bv which the residents of the Coimtv and of affected and "host" municipalities have a reasonrablemfir opportunity to participate in the site selection process. The County and municipal policies shall be based upon the following criteria: 4.1 4.2 4.3 Speci?c facility requirements: 4.1.1 4.1.2 4.1.3 4.1.4 4.1.5 4.1.6 4.1.7 4.1.8 4.1.9 minimum acreage; accessibility; transportation needs and services; supporting public facility and public service needs and the availability thereof; health and safety; site design; zoning of site; availability of alternative sites; community-wide distribution of facilities; 4.1.10 natural boundaries that determine routes and connections. Impacts of the facility: 4.2.1 4.2.2 4.2.3 4.2.4 4.2.5 4.2.6 4.2.7 4.2.8 4.2.9 land use compatibility; existing land use and development in adjacent and surrounding areas; existing zoning of surrounding areas; existing Comprehensive Plan designation for surrounding areas; present and proposed population density of surrounding area; environmental impacts and opportunities to mitigate environmental impacts; effect on agricultural, forest or mineral lands, critical areas and historic, archaeological and cultural sites; effect on areas outside of Pierce County; effect on designated open space corridors; 4.2.10 ?spin-off? (secondary and tertiary) impacts; 4.2.11 effect on the likelihood of associated development being induced by the siting of the facility. Impacts of the facility siting on urban growth area designations and policies: 4.3.1 4.3.2 4.3.3 4.3.4 4.3.5 urban nature of facility; existing urban growth near facility site; compatibility of urban growth with the facility; compatibility of facility siting with respect to urban growth area boundaries; timing and location of facilities that guide growth and development. July 27, 2014 65 EFF-6. Siting of Essential Public Capital Facilities The County and municipal policies shall ensure that the facility siting is consistent with the adopted County and municipal comprehensive plans; including: 5.1 the future land use map and other required and optional plan elements not otherwise listed below; 5.2 the identification of lands for public purposes in the land use element; 5.3 the capital facilities plan element and budget; 5 .4 the utilities element; 5.5 the rural element; 5.6 the transportation element; 5.7 the housing element; 5.8 the comprehensive plans of adjacent jurisdictions that may be affected by the facility siting; 5.9 regional general welfare considerations. The County and municipal policies may include standards and criteria related to: 6.1 the time required for construction; 6.2 property acquisition; 6.3 control of on? and off?site impacts during construction; 6.4 expediting and streamlining necessary government approvals and permits if all other elements of the County or municipal policies have been met; 6.5 the quasi~public or public nature of the facility, balancing the need for the facility against the external impacts generated by its siting and the availability of alternative sites with lesser impacts; 6.6 zoning of area around site to protect against encroachment. The County and municipal policies may include standards and criteria related to: 7.1 facility operations; 7.2 health and safety; July 27, 2014 66 Siting of Essential Public Capital Facilities 7.3 nuisance effects; 7 .4 maintenance of standards congruent with applicable governmental regulations, particularly as they may change and become more stringent over time; 7.5 sustainable development practices. The County and municipal policies on facility siting shall be coordinated with and advance other planning goals including, but not necessarily limited to, the following: 8.1 reduction of sprawl development; 8.2 promotion of economic development and employment opportunities; 8.3 protection of the environment; 84 positive ?scal impact and on-going benefit to the host jurisdiction; 8.5 serving population groups needing affordable housing; 8.6 receipt of ?nancial or other incentives from the state and/or the County or other municipalities; 8.7 fair distribution of such public facilities throughout the County and state: 8.8 requiring state and-federaLlLroiects to be consistent with this policy. July 27, 2014 67 EXHIBIT A-2 PLANNING POLICIES FOR PIERCE COUNTY, WASHINGTON Pierce County Approved by the Pierce County Steering Committee May 28, 1992 NOTE: See the ERRATA SHEET following Exhibit for minor corrections to this document. COUNTY-WIDE PLANNING POLICY ON SITING OF PUBLIC CAPITAL FACILITIES OF A OR STATE-WIDE NATURE - Requirements of Qm?wth Management The Growth Management Act requires that the comprehensive plan of the County and of each municipality in the County include a process for identifying and siting essential public facilities "Essential" public facilities include, but are not limited to, those facilities that are typically dif?cult to site, such as airports, state education facilities, state or regional transportation facilities, state and local correctional facilities, solid waste handling facilities, and in-patient facilities, including substance abuse facilities, mental health facilities and group homes The State Of?ce of Financial Management is required to maintain a list of essential state public facilities that are required or likely to be built within the next six (6) years. Facilities may be added to the list at any time. The Growth Management Act further mandates that no local comprehensive plan or development regulation may preclude the siting of essential public facilities County-Wide Planning Policy 1. The County, and each municipality in the County, shall adopt a policy and incorporate same in its comprehensive plan, on the siting of essential public capital facilities of a County-wide or state-wide nature. 1.1 In addition to essential public facilities, other capital facilities included must be for a public use, must have a useful life of 10 years or more and must have a value of at least $25,000 and be either 1.1.1 a County-wide facility which has the potential for serving the entire County or more than one jurisdiction in the County; or 1.1.2 a state-wide facility which serves or has the potential for serving the entire state, or which serves less than the entire state, but more than one county. 2. The County, and each municipality in the County, shall identify lands useful for public purposes and incorporate such designations in their respective comprehensive plans. 3. The County, and each municipality in the County, shall incorporate a policy and process in their respective comprehensive plans to identify and site 38 May as, 1992 essential public facilities on the list maintained by the State Of?ce of Financial Management. The process and policy shall include the following components: 3.1 a requirement that the state provide a justi?able need for the public facility and for its location in Pierce County based upon forecasted needs and a logical service area; 3.2 a requirement that the state establish a public process by which the residents of the County and of affected and "host" municipalities have a reasonable opportunity to participate in the site selection process. The County and municipal policies shall be based upon the following criteria: 4.1 Speci?c facility requirements 4.1.1 4.1.2 4.1.3 4.1.4 4.1.5 4.1.6 4.1.7 4.1.8? 4.1.9 minimum acreage accessibility transportation needs and services supporting public facility and public service needs and the availability thereof health and safety site design zoning of site . availability of alternative sites community-wide distribution of facilities 4.2 Impacts of the facility 4.2.1 4.2.2 4.2.3 4.2.4 4.2.5 4.2.6 4.2.7 4.2.8 4.2.9 4.2.10 land use compatibility existing land use and development in adjacent and sur- rounding areas existing zoning of surrounding areas existing Comprehensive Plan designation for surrounding areas present and proposed population density of surrounding area environmental impacts and opportunities to mitigate environmental impacts effect on agricultural, forest or mineral lands, critical areas and historic, archaeological and cultural sites. effect on areas outside of Pierce County effect on designated open space corridors "spin-oft" (secondary and $111.31?) ijaCt-S 39 May 23, 1992 4.3 4.2.11 effect on the likelihood of associated development being induced by the siting of the facility Impacts of the facility siting on urban growth area designations and policies 4.3.1 urban nature of facility 4.3.2 existing urban growth near facility site 4.3.3 compatibility of urban growth with the facility 4.3.4 compatibility of facility siting with respect to urban growth area boundaries The County and municipal policies shall ensure that the facility siting is consisrent with the adopted County and municipal comprehensive plans, including; 5.1 the future land use map and other required and optional plan elements not otherwise listed below 5.2 the identi?cation of lands for public purposes in the land use element 5.3 the capital facilities plan element and budget 5.4 the utilities element 5.5 the rural element 5.6 the transportation element 5.7 the housing element 5.8 the comprehensive plans of adjacent jurisdictions that may be affected by the facility siting 5.9 regional general welfare considerations The County and municipal policies may include standards and criteria related to: 6.1 the time required for construction 6.2 property acquisition 6.3 control of on? and off~site impacts during construction 6.4 expediting and streamlining necessary government approvals and permits if all other elements of the County or municipal policies have been met. 6.5 the quasiwpublic or public nature of the facility, balancing the need for the facility against the external impacts generated by its siting and the availability of alternative sites with lesser impacts. 40 May 28, 1992 The County and municipal policies may include standards and criteria related to: 7.1 7.2 7.3 7.4 facility operations health and safety nuisance effects maintenance of standards congruent with applicable governmental regulations, particularly as they may change and become more stringent over time. The County and municipal policies on facility siting shall be coordinated with and advance other planning goals including, but not necessarily limited to, the following: 8.1 reduction of sprawl development 8.2 promotion of economic development and employment opportunities 8.3 protection of the environment 8.4 positive ?scal impact and on-going benefit to the host jurisdiction 8.5 serving pepulation groups needing affordable housing 8.6 receipt of ?nancial or other incentives from the state and/or the County or other municipalities 8.7 fair distribution of such public facilities throughOLILmQCounty 8.8 requiring steam federal projects to be consistent with this policy. 41 May 28. 1992 TO BE NUMBERED BY THE CLERK OF THE COUNCIL PROPOSED ORDINANCE 0R RESOLUTION Proposal DATA SHEET No, INSTRUCTIONS: Direct questionsto Gerri Ralnwaler. Clerk CI The Council. al591 -7777. Proposed ordinances and resolutions mus! be submitted Iolhe Clerk oi the Council. Room 1046 County-City Building. by the deadline. 1. DATE PREPARED a SIGNATURE 3. PRIME SPONSOR. (COUNCILMEMBER Mav 29 . 1992 Pierce Countv Council 4. DATE RECEIVED s. REQUESTING DEPARTMENT COUNCIL CLERK 5 OFFICE Pierce CountLCouncil 6. DEPARTMENT SIGNATURE PHONE II 73" 7.0RAFTED BY 8. DEPARTMENT) PHONE II Ed McGuire/Council 591-7789 8.0FIDINANCE Ix} Adoption set for June 30 I a. EFFECTIVE DATE DESIRED ORDINANCEOR RESOLUTION: - as Required bv RCW to be Used Solelv for Establishing a Framework from which the Comprehensive Plans of Pierce Countv and the Cities and Towns within [fierce minty Are Developed and Adopted; Adopting a New Section 19.02.050 of the Pierce Code; and Adopting Findings of Fact. 1 I. LIST ANY SPECIAL ADVERTISING OR POSTING REOUIREMENTs INVOLVED IN PROCESSING THIS mi 1 Advertise in TNT. Disoatch. and Gateway at least two weeks Drier to 6130 final action date. 12. CODE STATUS: 1) SHOULD NOT BE CODIFIEDI 2) SHOULD BE PLACED IN PIERCE COUNTY CODE AS CHAPTERISECTION PCC 1?9 02 050 a) memo (Code. Ordinance Resoimion Numbers) 4] REPEALS (Coda. Ordinance Resolution Number-Isl 13. EXPLAIN THE INTENT OF THIS LEGISLATION Adoption of County-wide policies to be used solely to establish a framework _Tg_hj the comorehensive plans for the (301.111thr and the cities and towns within the Countv are developed and adopted. 14. SOURCE DOCUMENTS: LIST ALL MATERIALS INCLUDED AS BACKUP INFORMATION NIAI A 15. FISCAL IMPACT: A. TOTAL COST OF LEGISLATION FOR CURRENT FISCAL YEAR: COUNTY FEDERAL STATE 5 B. ESTIMATED COST OF LEGISLATION IN FUTURE YEARS: COUNTY FEDERAL STATE 5: C. COSTS INVOLVED ARE FOR: 0. ESTIMATED INCREASE IN REVENUE AS RESULT OF LEGISLATION FOR CURRENT YEAR: E. ESTIMATED INCREASE IN REVENUE AS RESULT OF LEGISLATION IN FUTURE YEARS: F. SOURCEISI OF REVENUE: THIS LEGISLATION HAS NO FISCAL IMPACTI I 18. A COPY OF THIS IN FINAL FORM SHOULD BE SENT TO THE FOLLOWING: Executive Fred Anderson Planning Commission members Eileen McKain. P.A. Don Perry Chair of the CAG Chuck Garden Jan Wolcott - Debby Hyde John Trent . . ml him*? 132 3? . . .. WHITECOUNCILOFFICE 25?; . d. 7H 05.2% Dob: - aw 6,wa I "Inc. EXHIBIT The muln?countv planning policies provide on integrated from ework for addressing fond use, economic development, transportation, other infrosrructure, ond environn'ierno! plonning, ?l?l?iese policies ploy river-,5) key roies: give direction to implementing the Riarigrionrrl Growth Strategy create a cor?nrnon framework for planning various lev fits within the fourucour'rry region, including countywide planning, local plans, transit agency plans, and others, on cl provide the policy structure for the Regional Council '5 function plans (the rVieiropo/iton 'lronsportorion Plan and the Regionoi ii'concvnic Strategic). Overview impiement?ng the ?egionai mow/ti: Strategy? The multicounty planning policies call for concentrating growth within the region's designated urban growth area and limiting development in resource and rural areas. The policies address land use, including urban, rural, and resource lands, urban growth area designa? tions, target?setting for population and employment, and focusing development in centers, They also ad- dress the important related issues of providing needed infrastructure and services to manage growth, includ? ing transportation facilities. Finally, they recognize the link between development, mobility, the environment, and the economy, and have been designed to provide an integrated approach to sustainability, development, economic prosperity, and the provision of services. A ?ommon Framework. Under the Growth Manu agement Act, multicounty planning policies provide a common regionwide framework for countywide and local planning in the central Puget Sound region. The uni?ed structure established by the multicounty policies has both practical and substantive effects on city and county comprehensive plans. The multicounty policies provide a mechanism for achieving consistency among cities and counties on regional planning mat? ters. They also guide a number of regional processes, including the Regional Council?s policy and plan review process, the evaluation of transportation projects seek? ing regionally managed funding, and the development Puget Sound Regional Council VISION 2040 Goal: The region will support development with adequate public facilities and services in a coordinated, efficient; and cost-effective manner that supports local and regional growth planning objectives. Having adequate services and facilities ensures that the region can maintain the health, safety, and economic vitality ot'our communities. Key urban services include sar?ritary and storm sewer syster?ns, water supply energy, telecon'imunicatior'is, public safety and er'nergency services, schools, libraries, and other com tn unity ties. New cleveloprn en needs new or expanded public services and infrastructure. At the same time, existing facilities require ongoir?rg maintenance and tit?igrading. Taking advantage ofrenevvaole resources and using efficient and en vir?onrn entally sensitive technologies can curh some of the need for new infrastructure. A cornrnitrnerit to sustair?rat?rle in fros truc titre ensures the least possible strain on the region ?s resources and the environment, while contributing to healthy and cor'r?rrnunities. The Growth Management Act distinguishes between urban and rural services. For instance, certain services, such as sanitary sewers, are allowed only in the urban area with very few exceptions. The Act also requires local jurisdic? tions to determine which facilities are necessary to serve the desired growth pattern and how they will be ?nanced. These provisions are intended to ensure timely provision of adequate services and facilities. Conservation is key to meeting many ofour service and facility needs today and will be even more essential in the future. Reducing waste is more ef?cient and cost~effective than disposal or clean?up. Reusing materials minimizes the demands for and effects on limited resources. Recycling prevents pollution and helps to protect the environment. Conservation and more ef?cient use ofservices are a vital part of sustainability and are important to ensure that resources will be there for future generations. They can also provide bene?ts for the climate, particularly in the area of energy ef?ciency. VISION 2040 encourages improving infrastructure to support development and maintain healthy and livable com? munities. Having reliable power, telecommunications, and water supply, along with other services and infrastructure, contributes to quality oflife and the region?s economic well?being. VISION 2040 promotes strategic investment in services and facilities to support the Regional Growth Strategy. Examples of strategic investments include siting major public amenities, such as libraries and community centers, in centers and compact urban communities. VISION 2040 emphasizes the use of existing and planned facility capacity and investing in facilities and services that reinforce cities as primary locations for growth, Taking advantage of existing infrastructure and services is both ef?cient and cost?effective. VISION 2040 also stresses that new public facilities, whether land?lls, libraries, or schools, be located in a manner consistent with the proposed growth pattern. These facilities must be constructed and operated in ways that minimize adverse impacts to both people and the environment, and maximize bene?ts. Policies are included for the following areas: (1) general services and special service districts, (2) the provision of key regional services, which include solid waste, sanitary sewer, septic, and stormwater, energy, public safety and emer? gency services, and telecommunications, (3) water supply, and (4) siting facilities, including schools, institutions, and other community facilities. Ef?ciency and conservation are common themes throughout. Pugel Sound Regional Council VISION 2040 89 Siting Facilities Regional capital facilities are transportation, recreation, education, human services, water, sewer, and similar facilities. While capital facilities are essential to our communities, our commerce, and our quality of life, they often affect the environment and adjacent areas. It is often dif?cult to locate major facilities, such as airports and land?lls, due to the potential for substantial impacts on residences and other nearby uses. Less intensive facilities, such as libraries and schools, are not always located in a manner that supports key growth management principles. VISION 2040 calls for strategically locating major capital facilities so that they support the Regional Growth Strategy, It stresses the importance ofinvestment in capital facilities and amenities to support urban centers and manufactur? ing/industrial centers. For example, adding amenities that attract people, such as performing arts centers, plazas, parks, and other recreational facilities, is an excellent way to support the vitality of urban centers. VISION 2040 discourages the placement of urban facilities in rural and resource areas. VISION 2040 stresses eouitv to ensure that the bene?ts of reoinnal canital facilities are manna hv rnmmi inifipg throughout the region. Facilities that Generate adverse impacts should not be sited In a manner that tindiilv burdens certain communities or noniilatlnn Ins, Rediirinn ran be addressed not Qn v bV avoiding them, but also by previdind amenities, such as collocatino parks with Wastewater treatment plants. Siting School facilities, In the central Puget Sound Scheei Siting and Transportation region, school districts own, operate, and maintain the . public schools. School district boundaries have been long Overthe postsevertri decades, it has been the practice of established and, in many instances, districts that were many schooi districts in areas across the historically what have become major suburban education United States to site new schools on large, undeveloped providers, with a host of buildings, facmtiesl and programs. ocreages ti'zatare neither easy to wcrik to nor accessible As a result, there are some throughout the four . by transit. Districts then either operate iarge prograrris counties that provide 5Ch00 services to both urban and to transportstudents to schooi sites, or end up requiring rural populations. students to drive or be driven to schooi. A careful examination of resources and their optimal Source: issue Paper on Euro/Areas allocation could lessen adverse effects of and to schools. In some cases, this could mean reassessing current school district boundaries. Schools should be encouraged to become the cornerstones oftheir communities by locating in more urban settings and designing facilities to better integrate with their urban neighborhoods. Other institutions and Community Facilities. Other cuiturai, civic and religious facilities including libraries, performing arts centers, sports facilities, and houses of worship also contribute to creating a sense of community. They better serve their populations when they locate in more centralized places, which people can reach by walking, biking, or using transit. in the long?term, there is increased ef?ciency and cost-effectiveness by siting and operating facilities that serve a primarily urban population within the urban growth area. At the same time, those facilities and services that primarily bene?t rural populations provide a greater bene?t when they are designed and scaled to ?t within an adjacent town or established rural community. SWING FACILETIES Site schools, institutions, and other community facilities that primarily serve urban populations within the urban growth area in locations where they will promote the local desired growth plans. Locate schools, institutions, and other community facilities serving rural residents in neighboring cities and towns and design these facilities in keeping with the size and scale ofthe local community. VISION 2040 PugelSound Regional Council Site or expand regional capital facilities in a mannerthat reduces adverse snrial. environmental and economic impacts on the host community, (2) equitably balances the location of new facilities. and (Bi addresses reoional plannino obiectives. Do not locate regional capital facilities outside the urban growth area unless it is demonstrated that a non?urban site is the most appropriate location for such a facility. VISION 2040 Public Services Actions The following VISION 2040 actions have been developed to help implement the public services policies. Detailed information on speci?c measures that will be used to monitor implementation and performance is contained in Port il/: implementation. SERVICES ACTIONS Communication with Legisioture Regarding Special Service Etistricts: P?wActiond The Puget Sound Regional Council, on behalf of its memberjurisdictions, will communicate to the Legislature that special service districts should be required to comply with the Growth Management Act. Short-term through 6, 21 through 24 ., Results and Products: letterior other reporting) to Legislature Water issues: PSwAction?z The Puget Sound Regional Council will determine its role in addressing regional water issues including water supply. . Midterm through 20 . Results and Products: report and recommendations to Growth Management Poiicy Board and Executive Board Communication with Energy Providers: P?witction? The Puget Sound Regional Council will relay to energy providers the goals and objectives ofthe regional vision. Providers are encouraged to identify tools and practices to address energy supply and conservation for localjuris- diction planning purposes, Shortwterm i3 - Resuits and Products: ierrer {and/or other correspondence) to energy providers Toiecomrnunications Report: Actionmp?mo The Puget Sound Regional Council will work with its memberjurisdictions and telecommunication providers to monitor the availability of high?speed data communication services. - Midwterm MPP-PS-M - Results and Products: report and recommendations to policy boards LOCAL ACTIONS Speciai Service ?tstricts manning: P?mitotionw? Counties, in their review ofspecial service districts? plans, will identify any inconsistencies with local growth man? agement goals and objectives, as well as the regional vision. As part of this review, counties, in consultation with pertinent cities, will work with special service districts to provide guidance for facilities and service planning to ensure that districts develop long?range plans that implement the regional vision. . Shortmterm through 6, 21 through 24- Results and Products: (1) consistency report (or similar? to special districts, (2) recommendations and examples to districts concerning the regional vision Siting and Design: PS?Aotiowt?: Counties and cities will collaborate with special service districts to review district location and design criteria for new schools, libraries, and other such public facilities to ensure that growth management goals and the regional vision are addressed. . Snortwterm through 24 Resuits and Products: report iorsimilor) and recommendations on siting and design criteria Pugel Sound Regional Council 2040 EXHIBIT 'uogauuom 13mm; m; sew-5354592 "23 'uogelgdmoa leug?yo s3! ueu; 135m 5512:2513 umoqs aq ?aw deLu no 2320 'saomos snopen Aq slana Anemone zuazamme pamauoo eJaM 3:332:90 'Aaluns a mu 5; 5qu "mesajd aq 3,35 Rem ?43ng sapwnaoeug?ue ?ue swlepsgp ? ssadee pa A113 '319 Aug Kq 9.13:: Law paJedaJd seM 5m; mun Alla POOMGXET awOH mules unpv SEIWOH JfIfl?V [9004432119ij ((113 QLDZ :91. 53W :ala? dew 3.717 - -- :0 1-.- '$15; gtjimgia?iau g; [r g, mung-.3 rx?i?: I I :stw f. . was; I 33.911201 I A it; f? womb??king sam ST) 5270 - SHHEIWVH.) 0 EXHIBIT Population 2017 Number of AFHs Number of beds Number of AFHs per AFH Beds per Carbonado 665 Capita Capita 0.00 DuPont 9,385 0.00 Enumclaw, part 0 0.00 Fife 10,100 0.00 Pacific, part 55 0.00 Ruston 975 0.00 South Prairie 435 0.00 Wilkeson 490 00000000 00000000 0.00 Auburn, part 9,900 0.00 Roy 815 12 407.50 67.92 Gig Harbor 9,560 17 101 562.35 94.65 Lakewood 59,280 77 451 769.87 131.44 PuyaHup 40,500 34 191 1191.18 212.04 Eatonville 2,925 11 1462.50 265.91 Milton, part 6,705 23 1676.25 291.52 University Place 32,610 16 92 2038.13 354.46 Buckley 4,670 11 2335.00 424.55 Tacoma 208,100 74 413 2812.16 503.87 Sumner 9,920 16 3306.67 620.00 Fircrest 6,640 11 3320.00 603.64 Edgewood 10,420 17 3473.33 612.94 Orting 7,835 3917.50 870.56 Bonney Lake 20,500 21 5125.00 976.19 Steilacoom 6,410 6410.00 1068.33 Unincorporated Pierce County 400,480 23 128 17412.17 3128.75 TotaE Population within Urban Areas 406,890 24 134 16953.75 3036.49 EXHIBIT BUSINESS INFORMATION Business Name: WOODVILLE AFH, LLC UBI Number: 603 167 552 Business Type: WA LIMITED LIABILITY COMPANY Business Status: ACTIVE Principal Of?ce Street Address: 6909 TOPAZ DR SW, LAKEWOOD, WA, 98498, UNITED STATES Principal Of?ce Mailing Address: Expiration Date: 12/31/2018 Jurisdiction: UNITED STATES, WASHINGTON Formation/ Registration Date: 12/27/2011 Period of Duration: Perpetual Inactive Date: Nature of Business: REGISTERED AGENT INFORMATION Registered Agent Name: MARGARET KARIMI Street Address: 6909 TOPAZ DR SW, LAKEWOOD, WA, 98498-0000, UNITED STATES Mailing Address: 6909 TOPAZ DR SW, LAKEWOOD, WA, 98498?0000, UNITED STATES GOVERN 0 RS Title Governors Type Entity Name First Name Last Name GOVERNOR INDIVIDUAL MARGARET KARIMI EXHIBIT Page 1 of 2 12mm1 2090409.? 5 001 3; $230.00 STATE OF WASHINGTON 3 ?0231734 SECRETARY OF STATE 8 LE FILED SECRETARY OF STATE Limited Liability Company DEC 2 7 2911 See attached detailed instructions . STATE OF Filing Fee $180.00 Filing Fee with Expedited Service $230.00 Number: 7- 6:52 CERTIFICATE OF FORMATION Chapter 25.15 RCW ARTICLE 1 NAME OF LIMITED LIABILITY COMPANY: Vi L.LE: (Must contain one of the following designations: Limited Liability Company, Limited Liability Co or one of these abbreviations: L.L.C. or LLC. ii the designation is omitted, it will default to LLC when processed) ARTICLE 2 ADDRESS OF THE PRINCIPAL PLACE OF BUSINESS: StreetAddress Cl 0 Cl Teena. bosw City mil-Exueoh State we Zip :12qu PO Box City State Zip ARTICLE 3 EFFECTIVE DATE OF FORMATION: (Please check me of the following) [3 Upon ?ling by the Secretary of State [3 Speci?c Date: 34' 30 II (Speci?ed effective date must be within 90 days AFTER the Certificate of Formation has been filed by the Office of the Secretary of State) ARTICLE 4 TENURE: (Please check gag of the following and indicate the date if applicable) Perpetual existence El Speci?c term of existence (Number of years or date oi termination) Washington LLC - Formation Washington Secretary of State Revised ll/ll Paggz of 2 ARTICLE 5 THE LIMITED LIABILITY COMPANY IS MANAGED BY: Members or Managers (see instructions) ARTICLE 6 NAME AND ADDRESS OF THE WASHINGTON STATE REGISTERED AGENT: Name: \?Q'Ptlr?tu Mild Ml Physical Location Address (required): (9qu Te PAL mz? Se.) City ee i3 State WA Zip Code CM ??33 Mailing or Postal Address (optional): City State Zip Code CONSENT TO SERVE A8 REGISTERED AGENT: I consent to serve as Registered Agent in the State of Washington for the above named Limited Liability Company. I understand it will be my responsibility to accept Service of Process on behalf of the Limited Liability Company; to forward mail to the Limited Liability Company; and to immediately notify the Of?ce of the Secrets of ate it I resign or change the Registered Office Address. MWT w. KkQ-kM?t pair/4., "Signature of Registered Agent Printed Name Date ARTICLE 7 NAME, ADDRESS AND SIGNATURE OF EACH EXECUTOR: (If necessary, attach additions! names, addresses and signatures) Name: MW Address: ??iecr "Te be Sou City Lena?moot} State WH- Zip Code ?t?u?tg? This ocumont is hereby executed under penalties ofperjury, and is, to the best of my knowledge, true and correct. Meme-T Lo. (Ln?(aw tel?tu 263396 833g, Signatu of Executor Printed Name Date Phone Name: Address: City State Zip Code This document is hereby executed under penalties ofperjury, and Is, to the best of my knowledge, true and correct. Signature of Executor Printed Name Date Phone Washington LLC - Formation Washington Secretary of State Revised 11/? Received Adult Family Home Disclosure of Services DEC 31 2014 amen-he came? Required by RCW 70.128.280 RCS/Public Disclosure HOME 1 PROVIDER LICENSE NUMBER WOODVILLEAFH, LLC (Margaret Kariml) 752347 NOTE: The term ?the home? refers to the adult family home I provider listed above. The scope of care, services, and activities listed on this form may not reflect all required care and services the home must provide. The home may not be able to provide services beyond those disclosed on this form, unless the needs can be met through ?reasonable accommodations.? The home may also need to reduce the level of care they are able to provide based on the needs of the residents already in the home. For more information on reasonable accommodations and the regulations for adult family homes, see Chapter 388-76 of Washington Administrative Code. Table of Contents About the Home Personal Care Medication Services ?killed Nursing Services and Nursing Delegation Specialty Care Designations Staf?ng Cultural or Language Access Medicaid Activities 1.. PROVIDERS STATEMENT (OPTIONAL) The optional provider?s statement is free text description of the mission, values, and/or other distinct attributes of the home. - 2. INITIAL LICENSING DATE 3. OTHER ADDRESS OR ADDRESSES WHERE PROVIDER HAS BEEN LICENSED: 12/04/2012 NONE 4. SAME ADDRESS PREVIOUSLY LICENSED AS: 5. OWNERSHIP Sole proprietor Limited Liability Corporation (So?owned by:_ Other: ADULT FAMILY HOME on SERVICES REQUIRED av 70128280 Page 1 of 4 cans 10-503 (REV. 09/2014) "Personal care services? means both physical assistance and/or prompting and supervising the performance of direct personal care tasks as determined by the resident's needs, and does not include assistance with tasks performed by a licensed health professional. (WAC 388?76?10000) 1. EATING if needed, the home may provide assistance with eating as follows: Setting ant feeding 2. TOILETING if needed, the home may provide assistance with tolleting as follows: 100% assistance 3. WALKING if needed, the home may provide assistance with walking as follows: Stand by assist and as per Residents care plan. 4. TRANSFERRING if needed, the home may provide assistance with transferring as follows: One or two person assist hoyer lift or sit to stand lift. 5. POSITIONING if needed, the home may provide assistance with positioning as follows: Every two hours assistance. 6. PERSONAL HYGIENE If needed, the home may provide assistance with personal hygiene as follows: Ali ADLS assistance. 7. DRESSING if needed, the home may provide assistance with dressing as follows: Complete dressing assistance from ciothing selection to complete dressing assistance. 8. BATHING if needed, the home may provide assistance with bathing as follows: From setting to complete body bath . i? 9. ADDITIONAL COMMENTS REGARDING PERSONAL CARE a? is ?Egg 5 residents wh need medication assista ce medication administration services by a legally authorized person, the home must have systems in place to ensure the services provided meet the medication needs of each resident and meet all laws and rules relating to medications. (WAC 388?76-10430) The type and amount of medication assistance provided by the home is: Assist with medication from reminding to RN delegated tasks like insulin injection and topical creams application. ADDITIONAL COMMENTS REGARDING MEDICATION SERVICES Complete medication assistance as per Physicians orders except iV fluids and other hospital tasks. ADULT FAMILY HOME DISCLOSURE OF SERVICES REQUIRED BY ROW 70.128280 Page 2 0f 4 DSHS 1 0-508 (REV. 09/201 4) if the home identi?es that a resident has a need for nursing ca and the Is not able to prowde the cars per chapter 18.79 RCW. the home must contract with a nurse currently licensed in the state of Washington to provide the nursing care and service, or hire or contract with a nurse to provide nurse delegation. (WAC 388-76-10405) The home provides the following skilled nursing services: Nurse deggated tasks only. The home has the ability to provide the following skilled nursing services by delegation: Monitor and record vital signs; Monitor blood sugar levels and administer insulin as delegated by RN delegater. ADDITIONAL COMMENTS REGARDING SKILLED NURSING SERVICE AND NURSING We have compietecl DSHS approved training for the following specialtv care deslonations: Developmental disabilities Mental illness Dementia ADDITIONAL COMMENTS CARE DESIGNATIONS I The home's provider or entity representative must live in the home, or employ or have a contract With a reSIdent manager who lives in the home and is responsible for the care and services of each resident at all times. The provider, entity representative, or resident manager is exempt from the requirement to live in the home if the home has 24-hour staffing coverage and a staff person who can make needed decisions is always present in the home. (WAC 388-76-10040) The provider lives in the home. - A resident manager lives in the home and is responsible for the care and services of each resident at all times. The provider, entity representative, or resident manager does not live in the home but the home has 24-hour staf?ng coverage, and a staff person who can make needed decisions is always present in the home. The normal staffing levels for the home are: Registered nurse, clays and times: Licensed practical nurse, days and times: Certi?ed nursing assistant or long term care workers, days and times: There is CNA on site always. Awake staff at night Other: ADDITIONAL COMMENTS REGARDING STAFFING We maintain a hi Staff/Resident ratio at all times There are at least two CNA start at all times he oe must serve meals that accommodate cultural and ethnic backgrounds (388-76-10415) and provide informational materials in a language understood by residents and prospective residents (Chapter 388-76 various sections) The home is particularly focused on residents with the following background and/or languages: English language is the official language of the home. ADDITIONAL COMMENTS REGARDING CULTURAL OR LANGUAGE ACCESS ADULT FAMILY HOME DISCLOSURE OF SERVICES REQUIRED BY ROW 70.128280 Page 3 Of 4 DSHS 10-508 (REV. 09/2014) The home must fully disclose the home?s policy on accepting Medicaid payments. The policy must clearly state the circumstances under which the home provides care for Medicaid eligible residents and for residents who become eligible for Medicaid after admission. (WAC 388-76-10522) The home iS a private pay facility and does not accept Medicaid payments. The home will accept Medicaid payments under the following conditions: ADDITIONAL COMMENTS REGARDING MEDICAID ate fund run The home must provide each resident with a Net of activities customarily available in the home or arranged for by the home (WAC 388-76-10530). The home providesvthe foliowing:- -. When we admit private pay residen ?E?wel? Cards, Bingo games, walks in the neighborhood forthose who are able. ADDITIONAL COMMENTS ACTIVITIES ADULT FAMILY HOME DISCLOSURE OF SERVICES REQUIRED BY 70.128.280 Page 4 of 4 DSHS 10-503 (REV. 09/2014) EXHIBIT IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON IN AND FOR THE COUNTY OF PIERCE CITY OF LAKEWOOD, WASHINGTON, a municipal corporation, Plaintiffs, DECLARATION OF NANCY CRAIG, BUILDING OFFICIAL, CITY OF LAKEWOOD V. 3 STATE OF DEPARTMENT OF SOCIAL AND HEALTH WESTERN STATE AGING AND LONG-TERM SUPPORT WOODVILLE ADULT FAMILY HOME, LLC, MARGARET W. KARIMI, Registered Agent, Defendants. Nancy Craig, declares and states: 1. I am the Building Of?cial for the City of Lakewood and responsible for the Building Department of the City of Lakewood. 2. I am over the age of eighteen and competent to testify to the matters herein. 3. Adult Family Homes are built to residential standards. Enhanced Services Facilities are built as secure institutional facilities like some hospitals and prisons. 4. The homes used for Adult Family Homes must meet building criteria adopted in the International Residential Code (IRC). RCW 70128040 and WAC 51-51- 0325. WAC 51?51-0325 includes speci?cations for things like wheelchair ramps and grab bars that are speci?c to Adult Family Homes. The intent appears to be keeping Adult DECLARATION OF CRAIG, 51W flgL?kftWOOf ega epa men BUILDING OFFICIAL 1 6000 Main Street S.W. Lakewood, Washington 98499 Family Homes integrated within a residential setting with little impact on the surrounding neighborhood. 5. The building requirements for Enhanced Services Facilities are established by the Department of Health and are more similar to secure, institutional facilities such as nursing homes or assisted living facilities than they are to residential homes. RCW 70.97.060 and WAC 388-107. For example, WAC 388-107?0710 discusses conversion of currently licensed facilities to an Enhanced Services Facility and the need for meeting resident health and safety requirements for speci?c new construction requirements. WAC 388?107?0720 discusses speci?c requirements for electrical ?xtures or systems, mechanical equipment or systems, ?re sprinkler ?xtures or systems, ?re alarm ?xtures or systems and speci?c requirements for interior finishes and kitchens and laundries. These requirements are not typical for single-family residences and are not part of the International Residential Code. In addition WAC 388-107?0420 discusses physical restraints for medical purposes. A single-family residence would not meet the requirements of the International Building Code for basic life safety where any type of restraint is used and could not meet minimum code requirements. I declare under penalty of perjury under the laws of the State of Washington that the foregoing is true and correct to the best of my knowledge, information and belief. EXECUTED this th day of May, 2018 at Lakewood, Washington. Wank/?u. . Nancy Cri Building f?e al, City of Lak 0d DECLARATION OF CRAIG, Eity fgLakretwoocg ega epa men BUILDING OFFICIAL 2 6000 Main Street SW. Lakewood, Washington 98499 EXHIBIT THE SUPERIOR COURT OF THE STATE OF WASHINGTON IN AND FOR THE COUNTY OF PIERCE CITY OF LAKEWOOD, WASHINGTON, a municipal corporation, Plaintiffs, DECLARATION OF MIKE ZARO, CHIEF OF POLICE, CITY OF LAKEWOOD V. OF SOCIAL AND HEALTH WESTERN STATE AGING AND LONG-TERM SUPPORT WOODVILLE ADULT FAMILY HOME, LLC, STATE OF DEPARTMENT MARGARET W. KARIMI, Registered Agent, Defendants. Mike Zaro, declares and states: 1. I am over the age of eighteen and competent to testify to the matters herein. 2. I am the Chief Law Enforcement of?cial for the City of Lakewood, Washington, and it is my duty to ensure public safety in the City of Lakewood. 3. In my capacity as Chief of Police, I receive notices from the Washington State Department of Social and Health Services/Western State Hospital when certain patients are scheduled to be released. Typically, the above notices are provided 30 days in advance of a release. 4. Placement of Alleged Murderer in Adult Family Home. On August 24, 2017, WSH sent the City notice that it intended to release a suspected murderer, referred DECLARATION OF ZARO, City Of Legal Department CHIEF OF POLICE 1 6000 Main Street sw. Lakewood, Washington 98499 herein as Resident A, from the hospital. The hospital identi?ed September 6, 2017 as the intended release date, which is less than 30 days from the date of notice. 5. I reviewed the following: a. An October 25, 2016 DSHS Inspection report of ?Alpha Palace House? a true and correct copy of which is attached and incorporated as Exhibit b. A July 20, 2017, DSHS Forensic Mental Health Report; 0. An August 24, 2017, letter of Community Noti?cations Of?cer Leslie Holloway, a true and correct copy of which is attached and incorporated herein as Exhibit d. An August 24, 2017, DSHS Noti?cation of Release, a true and correct copy of which is attached and incorporated herein as Exhibit and e. A September 1, 2017 letter from Pierce County Prosecuting Attorney Mark Lindquist, a true and correct copy of which is attached and incorporated herein as Exhibit C-4. 6. Based on the above information, I learned that Resident A had been institutionalized most of his adult life, except for a brief period in which he is alleged to have murdered his roommate; he was not tried for the murder because he was found incompetent to stand trial; and his mental condition is dif?cult to treat and supervise even when he is compliant with medications in the hospital, but he has not always been compliant with taking those medications. 7. DSHS planned to release Resident A to an Adult Family Home. By statute, Adult Family Homes are residential uses, meant to provide ?an alternative to institutional care and promote a high degree of independent living for residents.? RCW 70.128.005. DECLARATION OF ZARO, Eity ega epa men CHIEF OF POLICE 2 6000 Main Street sw. Lakewood, Washington 98499 01th \10The particular Adult Family Home DSHS intended to release Resident A to is called ?Alpha Palace House.? Based upon public records, ?Alpha Palace House? had been in business less than two years and had already been de?cient in administering medications to residents when DSHS planned to place Resident A there. 9. Given Resident A?s condition and history, together with the type of independent living expected in Adult Family Homes, 1 had grave concerns about plans to release him from the hospital to this home. 10. After the above release and placement was brought to the attention of state and the City?s leaders, DSHS canceled Resident A?s release and placement. To date, DSHS has not explained the basis or grounds for the planned release and placement. 11. Placement of Registered Sex Offenders in Adult Family Homes. There are currently four registered sex offenders living in the ?Woodville Adult Family Home, an Adult Family Home in the Oakbrook neighborhood of the City. 12. The names of registered sex offenders in Woodville Adult Family Home are: Chris Lee Benson; Ernest Chappell; Steven Leroy Jordan; and Shawn Tanzy. 13. Mr. Benson pled guilty to second degree child molestation in November of 2014. He is a Level 1 sex offender. 14. Mr. Chappell was convicted of rape with force and threat in December of 1983 and kidnapping in the ?rst degree in August of 1984. He is a Level 2 sex offender. 15. Mr. Jordan has two convictions for possessing child pornography; one in 2002 and another in 2015. He is a Level 2 sex offender. DECLARATION OF ZARO, City of Lakewood Legal Department CHIEF OF POLICE 3 6000 Main Street sw. Lakewood, Washington 98499 16. Mr. Tanzy was convicted of child molestation in the third degree in 2000; possession of drug paraphernalia in 2000; assault in 2000; and criminal trespass in 1999 and 2013. He is a Level 3 sex offender. 17. While the public may access general information about registered sex offenders, only law enforcement has ?access to exact residential addresses. I declare under penalty of perjury under the laws of the State of Washington that the foregoing is true and correct to the best of my knowledge, information and belief. EXECUTED this th day y, 018 Lakewood, Washington. Police City of Lakewood DECLARATION OF ZARO, City Of Lakewood Legal Department CHIEF OF POLICE - 4 6000 Main Street sw. Lakewood, Washington 98499 EXHIBIT C-l EJEPARTMENT ANB HEALTH AMI) LONG-JERM Ft?) 303 963992, Lakawmd, WA 98495 Getubar 25, .2016 Atpha P313806: Mame LLC . Alpha Pal-ace: Home} LLC ?402 Cora} Ln 8W Lakawwd, WA RE: Alpha Paiam Hnme Ligemaa #753004 7 Qatar vaEdA-r: The Qamrtmamt gamma-ad a foimwwup 0f yam-r Adult- F?am?y Harrie cm 2Q, 263163?er the ?a?rziency d-A?ciem?iA-a citrad in the; mpmt/S gated Aug-amt .22, 2018 and faurtd At) defi?cf-A?niag. 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R3 1333311. 1331111- 1113 31111111131113.1333 {?13 ?1313d?dI 111311333 11113331333113 1111333 11311: 3133333353 I13 131113113 1333111131113. 3311113133 Ail In?ammation was 71111333166131 11.133311 13313111133 ?1??l1?d1ng . ?33133 PRN 111ed1?1?111?1113 far ?31333313 1313sz 1111111231311 13111 13311131331111}; 1133311 113133311. ?33 3311333133 31311311333; R3 31111:! .1111: needed any if I311 11133331133113 ?in3 113113333311 heme m1 6, 31:1 11131111 the {3333333 Imm ?313 1111331113331: 33.3331113113 1. 3111311333 ?3131 ?I??1t I ?31333 ?11113 I13113 13.3311 ?31: ?3311 1111111311 1111113313333 "?31 I333 IIlkI?g 3113011 Alpha LLIZI 13 ?13 3113.11 31311113113119: with this 11111? and 1? 1.1110311111111111 ?311 I $11161) ?g i 3 I31 31133131313a I 11111331111111: ?1 312111111 ?11 1111111331" and 11131311 Icznp?anw with ?3113 1113' (11311011. 15/131? 1 3313111611.:3 {131* EXHIBIT STATE or WASHINGTON DEPARTMENT OF SOCIAL AND HEALTH SERVICES WESTERN STATE HOSPITAL 9601 Steiiacoom Blvd. S.W. Tacoma WA 98498n7213 (253) 532?8900 August 24, 2017 Mark Lindquist, Prosecuting Attorney Pierce County Prosecuting Attorney?s Office 930 Tacoma Ave. 5., Room 946 Tacoma, WA 98402 RE: Lawrence Butterfield Pierce County Cause No. for Murder in the 15" Degree Dear Prosecutor Lindquist, On June 23, 2017, Western State Hospital (WSH) notified your of?ce of our intent to release Mr. Butter?eld on a civil conditional release. At that time your office refiled charges. The re-tiie - resulted in the charges being dismissed due to incompetence to stand trial and he was referred be ck for civil commitment. This letter is to inform you that this patient continues not to meet the 71.05 detainment criteria and WSH plans to move forward with the original plan for a civil conditional release to Alpha Palace Adult Family Home located in Lakewood, Washington. So far the owners of this facility have been holding a bed for him. We would like to thank you for waiving the 30 day notification timefrarne to allow Mr. Butterfield to release on September 2017, so he can secure this supported and supervised placement. Please see the attached list of conditions for details of this placement. Persons detained under RCW 71.05 have the right to be represented by an attorney per RCW 71.05.360i11). This representation is provided to patients by the Department of Assigned Counsel (DAG) located at WSH. Should your office decides to refiie charges please proceed with the refile as soon as possible, and in addition to serving WSH, piease provide DAC with a copy of the intervening petition. Again, we appreciate your waiver of the noti?cation timeframe in this case. If you have any questions, feel free to contact Mr. Butterfield?s assigned social worker, Jill Olszewski, at (253) 984-4144, or you can email her at: Respectfully, Le oiioway, Community Noti?cations cer cc: Michael Werner, LICSW, MHP, Manager of Social Work Ward Cha rt-Forensic Section I ?3 3} Conditions of Release for MR. LAWRENCE DAVJD BUTTERFIELD Mr. Butteriield will remain in residence at Western State Hospital (WSH) until discharged under a Civil Conditional Release on or about 09/06/2017. Mr. Butterfleld will reside at Alpha Palace Home, 7402 Coral Lane 5W, Lakewood, WA, 98498; telephone: (253) 292?8033; or any other residence as approved by his Expanded Community Service/Multi-Care Behavioral Health Treatment Team. Mr. Butter?eld will follow all applicable rules and regulations of the Alpha Palace Home, and he will allow his Expanded Community Service/Multi~Care Behavioral Health Case Managerto visit Mr. Butter?eld?s place of residence at will. . Mr. Butter?eld will participate in follow?up mental health care through the Expanded . Community Services (ECS) program as administered by Multi-Care Behavioral Health located at 325 East Pioneer Avenue, Puyallup, WA 98372; telephone: (253) 697?8574. Mr. Butter?eld will keep all mental health related appointments and follow all mental health treatment recommendations as assigned by his ECS Multl-Care Behavioral Health Treatment Team, his assigned Multi-Care Behavioral Health Case Manager or any other designated Multi-Care Behavioral Health care provider. Douglas Wornell, MD will be Mr. Butterfleld?s identi?ed prescriber. Douglas Worneli, Multi-Care Behavioral Health general telephone office number is (253) 697?8574. Mr. Roger Reeve will be the ECS Treatment Coordinator/Case Manager and his Multi-Care Behavioral Health telephone number will be (253) 69743574. Mr. Butterfleid will meet with Mr. Roger Reeve on the day of his discharge from WSH. At that meeting, Mr. Laurence Butterfield will be given an appointment with Douglas Wornell, MD, his assigned prescriberfor Multi~Care Behavioral Health located at 325 East Pioneer Avenue, Puyallup, WA 98872; telephone: (253) 697?8574. Mr. Butterfleld will take all of his medications exactly as prescribed each and every day and Mr. Laurence Butter?eld will copperate with all laboratory work as requested. Mr. Butter?eid will abstain from the use of all alcohol products, all cannabis products, all legally obtainable recreational substances (eg. ?Spice?, "Bath Salts?, et al), all mind? altering substances sold or obtained illegally or illicitiy, all prescribed medications used illicitly to induce an altered state of consciousness, and all common substances used illicitiy to achieve an altered state of consciousness. Mr. Butterfield will comply with and complete all aspects of a comprehensive drug and alcohol assessment as well as fully completing any and all treatment aspects recommend by the drug and alcohol assessment. 9) Mr. Butter?eld will comply with any and all urinary drug screens as requested by his Muiti-Care Behavioral Health ECS Case Manager, and his Multi?Care Behavioral Health prescriber or any other member of the Multi-Care Behavioral Health Treatment Team located at 325 East Pioneer Avenue, Puyallup, WA 98372; telephone: (253) 697?8574. 10) Mr. Butterfield will attend drug and alcohol education groups and [or self-help groups as recommended by his Muiti~Care Behavioral Health ECS Case Manager, his Multi?Care Behavioral Health prescriber or any other member of the Multi?Care Behavioral Health Treatment Team located at 325 East Pioneer Avenue, Puyallup, WA 98372; telephone: (253) 697?8574. 11) Mr. Butter?eld will refrain from any threats or acts of harm to self, others, or property. 12) Mr. Butter?elcl will maintain own health and safety in the community and not substantially deteriorate in routine level of functioning as established on the day of his discharge from clay of admission to Alpha Palace Home LLC. 13) Mr. Butterfield will attend all scheduled mental health appointments as instructed by his Multl~Care Behavioral Health ECS Case Manager, and his Multi?Care Behavioral Health prescriber or any other member of the Multi~Care Behavioral Health Treatment Team. if Mr. Butter?eld has a need for an unscheduled appointment, Mr. Butter?eld will call MultinCa re Behavioral Health at (253) 691-8574 and establish a special appointment. 14) Mr. Butter?eld will work with his ECS Multi-Care Case Manager, Mr. Roger Reeve to resolve any outstanding fees or ?nes, if any, issued out of any other court orjurisdiction including but not limited to Municipal Court, District Court or Superior Court. I EXHIBIT NOTIFICATION DATE. 0F greet: Health Services 09/06/2017 TO: FROM: SUBJECT: RELEASE TYPE: Chief of Police. City of Lakewood and Puyallup Sheriff. County of Pierce Tribal Law Enforcement Agencyis) Department of Social and Health Services Jill M. Olszewski MSW CONTACT PERSON Western State Hospital FACILITY NAME 9501 Steilacoom SW, Lakewood, WA 98493; FACILITY ADDRESS Lawrence David Butterfield NAME El Discharge/release Conditional release Transfer to community placement El Authorized leave Release to a less restrictive setting El Furlough Other: Civil onditional Release For parole or transfer to community of a sex offender, use form DSHS 09-747A. 253-984-4144 TELEPHONE NUMBER (INCLUDE AREA CODE) D?Parole Escape (followup information) Expiration of sentence OFFENDERJNFORMATIDN, NAME Lawrence David Butterfield 361682 SOCIAL seounn'v NUMBER 538~62e9256 STATE ID NUMBER WA10334701 JRA NUMBER SOC NUMBER FBI NUMBER Doc NUMBER 951558 ALIASES Butterfield, Larry D. and Butterfield, Laurence neourRrNo . Dismissal due to incompetence for the charge of Murder in the First Degree. COUNTY Pierce County CAUSE NUMBER 10-1-04934?9 . DATE on BIRTH AGE eves HAIR HEIGHT 08/17/1955 62 BLU 511 WEIGHT 180 GENDER RACE oescniprloif?? OTHER PLANNED EMT ADDRESS Alpha Palace Home AFI-I: 7402 Coral In SW Lakewood, WA 98498 RELEASE SUPERVISING AGENCY AGENGYADDRESS Mum-Care Behavioral Health CITY ZIP CODE 325 E. Pioneer Ave Puyallup 98372 SUPERVISING PERSON ECS Case Manager, Roger Reeve andfor assigned TELEPHONE (INCLUDE AREA CODE) 253~697-8574 DSHS 09-747 (REV. 0212004) PAGE 1 Released ONLY on approvalrrevlew of facility superintenden?admlnietrator or designee. NOTIFICATION OF RELEASE . . .. .. . SPECIFIC ITINERARY Lawrence Butter?eld will reside at the Alpha Palace Adult Family Home. He will discharge on a Conditional Release(CR). He will receive follow up mental health services through Multi-uCare ded Communitv Services (ECSI. Alpha Palace AFH: 7402 Coral In SW Lakewood, WA 98498 . ADDITIONAL-OFFENDER INFORMATION 7 MUST ea APPROVED BY mommsupeswsoa oa-eesmnEeI: RISK FACTORS (LE, TARGET POPULATIONS, SUBSTANCE ABUSE, HISTORY OF TREATMENT THAT IS PERTINENT TO RELEASE, ETCJ. LIST ANY PRIOR SEX OFFENSE HISTORY INCLUDING RISK LEVEL CLASSIFICATION IF AVAILABLE.) No Past or current sex offense(s). No other conviction data other than the Gross Misdemeanor listed below. He has a history of substance abuse, but nothing current. RETURN DATEITIME CRIMINAL HISTORY antenna) DISPOSITION Dare 1 GROSS aisonMEANORw) saopmecme 06/l9/1975 0 MISDEMEANOR (S I CLASSIFICATION (S) UNKNOWN CONDITIONS OF RELEASE WHICH ARE OF INTEREST T0 LAW ENFORCEMENT GEOGRAPHIC RESTRICTIONS, NO CONTACT ORDERS) Mr. Butterfield will reside at the Alpha Palace Adult Family Home located: 7402 Coral in SW Lakewood, WA 98498. Contact person at Alpha Palace is Joseph Muriu 253-292-8033. He will receive follow up mental health services through Multi-Care Behavioral Health and have Expanded Community Services (ECS). Multi-Care Behavioral Health, 325 E. Pioneer Ave. Puyallup, WA 98372, 253-697?8574. ECS Case Manager, Roger Reeve and/or assigned. ECS Provider, Dr. Doug Wernell and/or assigned. Mr. Butterfield will discharge on a Conditional Release (CR). Mr. Butterfield will take medications as prescribed. Abstain from alcohol and/or non-prescribed drugs. Obey all laws and maintain own health and safety while in the community. Refrain from any threats or acts of harm to self, others, or property. Comply with any anti?harassment, no contact, or protections orders, if applicable. Mr. Butterfield will comply with the conditional release as required upon discharge from WSII. Mr. Butterficld will voice any questions or concerns that could indicate decompensation with his mental health and will work cooperatively with his assigned 24 hour a day 1:1 support, peers, and the staff at Alpha Palace Adult Family Home. neHs 09-747mm. 0212009 PAGE.2 PHOTOGRAPH (ATTACH HERE IF AVAILABLE) Pe?s'o' FORM cobra) Jill M. Olszewski, MSW - 253?984-4144 osns 09-747 (REV. among PAGE 3 EXHIBIT C-4 1} @rce County so of the Prosecuting Attorney MARK LINDQUIST Prosecuting Attorney 930 Tacoma Avenue South, Room 946 Tacoma, Washington 98402?2171 Main Of?ce: (253) 798-7400 Administration: (253) 798-7792 1-800?992-2456 FAX: (253) 798-2968 Valid only within Washington State September 1, 2017 The Honorable Jay Inslee Governor of Washington PO Box 40002 Olympia, WA 98504-0002 Re: WSH proposed release of Lawrence David Butter?eld Dear Governor Inslee: I am asking you to intervene to prevent of?cials at Western State Hospital (WSH) from conditionally releasing a schizophrenic, intellectually disabled man with a long history of violent behavior. The last time Lawrence Butter?eld was conditionally released, it resulted in my of?ce charging him with murder in the ?rst degree. Although we originally ?led the casein 2010, we have been unable to prosecute it because Mr. Butter?eld is so mentally ill that he has never been found competent to stand trial. Mr. Butter?eld has a long history of violent behavior. WSH records indicate that two armed assaults against his father were dismissed due to his lack of competency. In 1977 he was charged again, with assault with intent to kill, and was found not guilty by reason of insanity. This resulted in his commitment to WSH in 1980. In 2002, WSH conditionally released him into Pierce County despite him having no prior connection to this county. In 2010, my of?ce charged him with murder for stabbing his roommate to death. Mr. Butter?eld told the arresting of?cer he had been hearing voices that told him to kill so he went out and acquired a hunting knife. The murder charge against Mr. Butter?eld was dismissed in 2011 when he was found not competent and not restorable. The charge was re?led in 2013, 2014, and 2017, because my of?ce received notice that WSH was again proposing to conditionally release Mr. Butter?eld into the community. Each time we had to dismiss our prosecution when the doctors concluded that Mr. Butter?eld was not competent to stand trial and that it was unlikely competency could be restored. The most recent competency evaluation, dated July 20, 2017, states that Mr. Butter?eld has active auditory hallucinations and that he believes these voices emanate from a microphone that has been placed in his brain. Doctors on the forensic side of WSH have repeatedly found Mr. Butter?eld to be at a ?moderate to high risk for future serious dangerous behavior? provided that he is on his medications. They assess that this risk is signi?cantly higher if he is not on his medications. His history demonstrates a pattern of predictable violent behavior. In short, Mr. Butter?eld is not healthy enough to be out in the community and he poses a severe risk to others. Printed on recycled paper M. .. -lr,?rnr The Honorable Jay Inslee September 1, 2017 Page #2 Nonetheless, doctors on the civil commitment side of WSH have scheduled his release on September 6, 2017, and his release plan will have him residing at the Alpha Palace Home in Lakewood and receiving his mental health treatment at Expanded Community Services in Puyallup. His plan does not specify how he will travel from one location to another. His release plan consists of fourteen detailed conditions. From his competency evaluation, there is no indication that he has the mental capacity to understand, remember, or adhere to these conditions. The July 20, 2017, evaluation states that ?he continues to exhibit disorganized thoughts and confusion and cognitive slowing? and that he ?appeared unable to process The proposed release plan is setting Mr. Butterfield up for failure and placing the community at risk. Mr. Butter?eld suffers from serious mental health issues. He deserves quality treatment in a secure setting. While my of?ce has tried to prevent his release, the criminal justice system was not designed to handle persons so mentally ill that they will never be competent to stand trial. Now it is up to the professionals in the civil commitment arena to protect the public from a mentally ill person who poses a great risk to public safety. The civil commitment doctors at WSH who are proposing Mr. Butter?eld?s release do not seem to be taking the safety of the community into consideration or the risk assessment of their own doctors on the forensic side. The last time Mr. Butter?eld was conditionally released he took a man?s life. Governor, I know you share my commitment to protecting the public and keeping our communities safe. Therefore, I am asking you to intervene and prevent Western State from releasing Mr. Butter?eld into the community. Thank you. incerely, Pros utor Mark Lindquist cc: J. Smith, Executive Director of Communications M. Jones, Interim CEO, Western State Hospital Senator H. Zeiger, 25th District Representative M. Stambaugh, 25th District Representative J. McDonald, 25th District Senator S. O?Ban, 28th District Representative D. Muri, 28th District Representative C. Kilduff, 28th District Senator S. Conway, 29th District Representative D. Sawyer, 291th District Representative S. Kirby, 29th District EXHIBIT THE SUPERIOR COURT OF THE STATE OF WASHINGTON IN AND FOR THE COUNTY OF PIERCE CITY OF LAKEWOOD, WASHINGTON, a municipal corporation, Plaintiffs, DECLARATION OF BRIANA SCHUMACHER, EXECUTIVE i STATE OF DEPARTMENT ??gaAgg?cny 0F V. OF SOCIAL AND HEALTH WESTERN STATE AGING AND LONG-TERM SUPPORT WOODVILLE ADULT FAMILY HOME, LLC, MARGARET W. KARIMI, Registered Agent, Defendants. Briana Schumacher, declares and states: 1. I am an Executive Assistant with the City of Lakewood. 2. I am over the age of eighteen and competent to testify to the matters herein. 3. The following is a true and accurate transcription of public comments made at the City Of Lakewood City Council Meeting of April 2, 2018 by one who identi?ed himself as John Kimari: Thank you Mayor and the Council. And thank you for having us here as providers to speak on behalf of the adult family homes. I have been operating an adult family home here in Lakewood since 1986. And it is one of the most challenging you know professions that you can go into. And it is City of Lakewood Legal Department DECLARATION OF SCHUMACHER 1 6000 Main Street SW. Lakewood, Washington 98499 also one of the most rewarding professions that you can engage in. because it involves dealing with people. This is a profession that you are not dealing merchandise. This is a profession you are dealing with emotions and everything. I would like to relate my comment to the violent offenders because I have been admitting people from Western State Hospital for quite a few years, probably going back to 15 years now. Some of these people have been stigmatized with Mr. Butterfield, some of them have aged. Yes, some of them made a mistake many years, back when they were youth. Now they are in their 703 or close to 80s and they are still in- Western State Hospital. And now they are reformed, they have been rehabilitated. The state does a very good job assessing these individuals to know who can go back into the community. I truly commend their work, throughout my 22 years in the adult family home care profession I have never been involved in a situation where we have admitted somebody, you know, through a wrong assessment or anything like that. So they do a very good job and we also on the other side, these individuals who come to live with you, they are admitted into your home, and they become a part of your family. If you meet some of these people that are being talked about, they are some of these best people that you will ever want to meet. Just because someone has made a mistake and have been rehabilitated and they are good individuals who have been put in an adult family home. Our result is to live with these people. City of Lakewood Legal Department DECLARATION OF SCHUMACHER - 2 6000 Main Street S.W. Lakewood, Washington 98499 Like I said last time I was here, to ask about providers. Either the issue of the money comes last. You have to provide a goal on a basis of compassion. Do you want to live with this individual, you go meet them, and the process for admitting them is so stringent. You cannot make a mistake. Either from our side or the state side. They are professionals who have worked with these people. And somebody who has been institutionalized for some like ten years. I have someone, she was a young lady, now she just want reform, to go back to the community. It is truly wonderful to give that individual an opportunity to go out to the community and live a decent life. Thank you very much. I declare under penalty of perjury under the laws of the State of Washington that the foregoing is true and correct to the best of my knowledge, information and belief. EXECUTED this\l0th day of May, 2018 at Lakewood, Washington. (2)189}th Briana Schumacher Executive Assistant, City of Lakewood City of Lakewood Legal Department DECLARATION OF SCHUMACHER 3 6000 Main Street SW. Lakewood, Washington 98499 EXHIBIT I a 3??ng e?Ami?Stresses;sienna? Buiiding Characteristics for 6430402030 05/08/2018 01:42 PM property Details ;:Tagisayea'asii'g Parcel Number: 6430402030 ggTaxpayer Name: KARIMI MARGARET Site Address: 6909 TOPAZ DR SW giMailing Address: 6909 TOPAZ DR SW Account Type: Real Property LAKEWOOD WA 98498?6419 Category: Land and Improvements Use Code: 1101-SINGLE FAMILY DWELLING Building ID: 1 building(s) on this parcel: i, . . General Characteristics Property Type: Residential SF: 3,184 Fin. Attic SF: 936 Condition: Average Net SF: 0 Total SF: 0 Quality: Average Atch. Garage SF: 0 Fin. SF: 0 Neighborhood: 130701 0 bet. Garage SF: 0 Gar. Door: 0 Occupancy: Single Family Residential Carport SF: 0 Fireplaces: 1 I: iBuilt-As 3 Bed- Bath? Sprinkler Description Year Built Adj. Year Built 5F Stories rooms rooms Exterior Class Roof HVAC Units SF 1 Story 1969 2001 3,184 1 7 2.5 Frame Siding n/a Composition Shingle Forced Air 1 0 g?irt-Iprovement Details Detail Type Detail Description Units Add On Finished Attic Avg 935 Basement Concrete Slab 348 Porch Wood Deck 682 Warning: Appraisal data provided Is for informational purposes only and Is incomplete for determination of value. I acknowledge and agree to the prohibitions listed in RCW 42.56.070(9) against releasing and/or using lists of individuals for commercial purposes. Neither Pierce County nor the Assessor-Treasurer warrants the accuracy, reliability or timeliness of any Information in this system, and shall not be held liable for losses caused by using this information. Portions of this information may not be current or accurate. Any person or entity who relies on any information obtained from this system does so at their own risk. All critical information should be independently verified. Pierce County Assessor-?Treasurer Mike Lonergan 2401 South 35th St Room 142 Tacoma, Washington 98409 (253)798-6111 or Fax (253)798?3142 Copyright 2018 Pierce County Washington. All rights reserved. E- 3531 it" if"; rim Privacy Pceiiw .. . .igiit ixiititices EXHIBIT {James 3m?e??f 53H OH 999 add ?303 sum Emu?: magma mm. ONLir-am??ns} ma W60 my; as: Kmpeg 592mg 1-131: Wim mu 0N aon ?ames: 3mm! massesm mm 0M swan-2 Atlases ans?: H52: W538 WISDH 3 W533 Isms s: 80:53:11 WISGH Limos a mum mmu iVSd um?m term. or: W855 unmzw mug on aim-t 55mg mm: new 2: mu: on W. 553; 19?3511 or: sum muses 35W Riv mam (my; on mam ?rings 3m: mm mm anger?: ?mum NEH We naming: my}. 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Family Hm Na Txibai A??a?m ices ?orthSourdBi-ie ?lachargedwiih Adel: Family Home No T?bai?ffdia?on AdukFamily Rome No T?bai Af?lza' liar; Adult Family Home No Tribai Rf??a?m orth Sound 85-190 HCSEMA Region 2 W133 P: - 365.1% Regina 2 worth O?h 82-50 ACME Family Home N9 Tribai M??atlm eglori 2 North North Sound 8340 AFH Axial: Family Home Ng Tribe: Af?liation msa?s 2m ?mania-m an: Wuasym Ehmd as 281111133? 566 HQ HCS installmemz 0032?? Nu Tr?zai Af?lm? ?m Regimz Nam 522ng Hart}: No Tribai mam No mine: Af?liation Regina 2 Norm Na Tribai Afflii' a?an No Tn'bai Af?iialim No Tribe? Af??a?on Na'mbaihf??abo? ?n Na TribaIAf?iu-am' Na Tribal Aff?tal' ion" No Tuba! Af?na?? ?on EEG T111531 A??a?m Ne Triba! Af?liakc/ Adu? Family Home r636 T?hai?f?iia?m Arm?! Famiiy Home Na Tribal ?f?fa?on Fsyduam'c 8089M Ne Tfihai Af?liation Adah Family Home Nu T?ba? Af?lia?an ?aming Facimg Na Tribe; Af?rm Numg Fading No Y?hai A?i?a?m Adm: Fem Home No "{dba! Af??a?on Add: Family Home No Tn'tal Af?lia?on Fam?y Home No Tisha! Af?iia?cn Wk Fam?y?mve No Tribal mm Adult Family Ham No Tribal Affdialim Psyci?mmc' Hospilai Ne Tribal Af?a?on Haring Facility No Tribal Mn 1976 mam: 323m 195m: Family Hume N9 Tribal .936qu ?an 281?? HOS instailme?ii? GOOZE Mun Residenn'al Care No Tribal Af?lialicn Adult Fam?y Home {in Tribal Watson Harmless) N0 Tribal mm adult Family Home Na Tribal Af?liation index Family Heme ?u Tribal A?'lliation Adm: Family Home No Tribal Adult Family Hume No Tribal Af?lia?on Adm Family Harm?: Na Tribal Af?lia?on Owl-lame Na Ttihai ?f?fia?on chl?akzic Hospital Medial Hospital Na Tribal? Won Adah Farm}? Home N9 Tnbai A?i?a?on Adult Family Hm N0 T?'bai A??a?on Add: Family Hattie Na Tribe} Add: Family Home No Tamal A?llia?cn 1523?? as: Mull Family Ham: Adult Family Home No mm Af?liation Gum Roma {Alena} No ?fribal Af?lim?on A?ultFamilyE-lam Na Tribal Af?rm Adult Fam?yI-?ame No Tribal Mali Family Harm: No Tribal Wu Adlai Fanny Home No Tribal Mimi Famsly Home No Tribal A?iliatim Assisted Living Fading i?o Tribal A?li?aaion {nan-ARC) Adult Famy Home NO Tubal Affiliahm? Own Home (Mam) ?u Tribal Af?rm Na TribaE Af?lia?on A?ullFamiiy Home Suuihwesz Washingtm Disci?larged ml: HMS service; ?rmt?zs 3w: mmunmmw 201?? PRR 5625 HQ HOS illslailme?i 2 0519279 Mai; ResidemiaiCare his Txibat Af?liation 9mm Hospital No "kite: Winn AFR Adan Famiy Home Ne Ttibai Af?liation Adam Famity Hume Ne Tuba? Af?iialim APE mm Farm; Home No TM major: 1-295de No Tribe? Af?iimm 3:31me Home No Tribe; ?i??a?cn Adult Faun}; Home No Tn'ba? Af??a?on ?ameless Na Tribai Af?liation Hosgaitai No imammn mm: Fam?y Home Ma 1?me Own Home 5011mm Wasf?ngmn Add: Famiiy Hm No Tribe! Af??alicn FMC .umm Enhanwd Services ?o Tnbai Af?rm HMO Fadi? Somhwest Washingm mm mm! Care :40 Triba! A??auon RMC EQARC) wthwes! Washington Relatives ?ame ?e Tribal Rm $1512?; 30mm Washinginn mm Living ?a?iity 5k: Tribal A??a?m I RM - {non-ARE} Mail Residenba! Care No T?b?i 3&3le (J 2.. (1th Washingbon FEMS {?15383 Sanhwest Washington F?syduam?: Hosanna Na Tribai Af??a?m FEMS west Washington . Medical Hospi?l Ni: Tzibai Wiz?m Mi: Washington 5mm Services Na T?ba? Af?iia?on HMS - west Washingta? 0% Home No Tuba: Af?iiahon FEMS Sou?mest Washington Adan Faun}? Haame We Tribal A??a?m Region 3 Norm i Hospitas Na T?bal Af?lialinn Region 3 mm: 3mm Washington Disdiargeci Adm: Famiry Home 1 ?5 H: HMS I 335914 7 amass: Washingtm Om Home No mm Af?iiaRegion 3 5081:?! 4* 4 - Add: Family Home No En?bal Affliia?an 32111018123259?? W955 293??! 565 HQ HCS insta?mm? 2 930283 125MB EJWF SSH OH 935% LLALBZ sag was was sz?nm 9 mama! 1mm. 0N ism) 5!on um . A 01-33 Wm was 2 ws?a?g WESOH Wmeam Ham magma-.2 9 momma: 1mm 913; Bum-z we . . 654g unsem @925 La wm mm at: ?zz-saws - 9H3 - 9 . 154mm ?92538 W535 WWAW a-zsv . . "0mm my; on away; was 3mm! 93v . 6H8 9058?: mam 18495. on $1:i?w?n mass 2 901538 warms was V$d mummy my; maximums) mum who . GHQ 893%: misin- Mariam my; 0N 33.13985 max H32: 1 . 0H2 Amos Maw- Ignaz; um?ag} may; mm 0M 96m: ?amtam? uns?ag; m?awe?nw . OHBMHoaamx-w .. W?ie?i?l 6:33 man 35v . . OHS M1903 swarm '43-'03 am?aa WISSH ?Jimmy mm. 9M 33199:: 5w 909593 I . oaa?wnosamoh Lawn ?51.1593; wwsan ?099%? 1311?}. 0N 39-10%! 53mg 11913?! Hi?! I 038 5191100 tam ?@533 mmz-s mama - . ?0921:1141? m; 0N ms: was; 3m . . Amos atm- - more um?aa M593 mam 0M 123150?! 123999: :is unl?uzlzsem mums tunes 3 3095921 Wise}; 53992:: . WV i313]. 0m WW panizequg WHOSE W538 mm 9M ms was um?aa 05: max?.5 Hm??vo?a 20 MEN. Raina: $3.3m Ra. mmamx moan. mo Mag REES: may}? mama? 38mg wanna . magi mam - . . . . has? 3.3% $033 26 ?may. $53 mama: . mommy? A $333 . ?mum gm?m??mg? Eon amen? 3mm .5. a ?gaw?m HQ. 3% . .. ?mama mum?. 3mg wan? Egg ?Wang We?? as: $23. Zn Maw.?? raga: mamas 2355m. 5mg mag?? m8? 20%. 93.. ma 2me go: ?.3"th Wang 29% 2&3 Wynn? mama WEE: mg ?g iguana 20 43mm ?Emacs 3??th mag? Bur Raw? mg 1053 an 4% my? ?#383 299 ??ux bug? mm; Iomum 2m Anumm hum??FER? $383 wg bani hn?m mum?.3? $9.5m 26 Hug? $me $83; moan. aux 3% 33% :93 in mag $.33 ma?a? mamas mac? km.? 055 moan. 20 ?new. b33303 mg; Oi: moan 2o Mada $553 womanly? Mum?. 9,3 H.830 mam; wag: Wana?aa mean? an g: my?? Margamm 30 419m. ?gang ma?a? Bax haw?w? mun?3 $93 20 Hamm? 335mg 30%; 33min 2633 Emma; momma? wg Hum .055? mmamw. I945 20 Mg ham?wow 38E ?mung Moan: "Wane Emma 53 magma 20 3&3 $3?.me mag :88 20 RE 3&6: mgr?? 338: Zea.? ??ea ?g :93 Uranuxmm Emmon mag.? g8: Nu?nuwnn um um.? man ma?a?unuwumwm? ?Ra? umm N633 gamma m0 :8 Enigma? 88%