E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON
February 06 2019 2:42 PM

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KEVIN STOCK
COUNTY CLERK

NO: 19-2-05249-5

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SUPERIOR COURT OF WASHINGTON FOR PIERCE COUNTY

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Everstrong, LLC, a Washington
limited liability company,
Plaintiff;

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Veterans Independent
Enterprises of Washington, a
Washington public benefit
corporation,

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Defendant.

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Complaint for Unlawful Detainer

v.

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Case No.

Plaintiff Everstrong, LLC brings this action against Veterans Independent
Enterprises of Washington for unlawful detainer and alleges as follows:
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Plaintiff is the owner and Landlord of the real property at the address

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commonly known as 6919 24th Street W, University Place, Washington (the

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“Premises”) which is located in Pierce County, Washington.

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Complaint for Unlawful Detainer - 1

CHIANGLIN LAW FIRM, PLLC
10-148th Avenue N.E. Suite 202
Bellevue, Washington 98007
Tel: 425-451-4945
Fax: 425-451-4318

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2.

Defendant Veterans Independent Enterprises of Washington has occupied

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the Premises as Tenants under the Lease Agreement with the Plaintiff dated

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October 5, 2018 (the “Lease”).

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3.

Under to the Lease, Defendants have an obligation to pay monthly rent of

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$9800.00 as defined in the Lease. The first day of each Lease month is the first day

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of the month. Rent is due on the first day of the month.

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4.

Defendants failed to pay rent since the inception of the lease on October 1,

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2018. Defendants are currently in arrears for the period October 1, 2018 through

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the present of $40,670.00.

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5.

On or around January 7, 2019, a five day notice to pay rent or vacate (“Five-

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Day Notice”) was personally served on Rosemary Hibbard, the Registered Agent of

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the Defendant at the Premises.

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6.

More than five days have elapsed since the service of the Five-Day Notice

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and Defendants have neither paid the amount owed nor vacated and surrendered

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the Premises.

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Plaintiff prays for judgment:

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A. That the tenancy of the Defendants on the Premises be declared terminated and

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that possession of the Premises be restored to Plaintiff;

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B. That a writ of restitution be issued to the Sheriff of Pierce County, Washington,

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directing the Sheriff to deliver possession of the Premises to the Plaintiff and

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allow the Sheriff to break and enter the Premises if necessary;

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C. That Plaintiff be awarded judgment against Defendants for unpaid rent, plus late

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charges, along with unpaid deposits, fees, and other charges and money due

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26]

Complaint for Unlawful Detainer - 2

CHIANGLIN LAW FIRM, PLLC
10-148th Avenue N.E. Suite 202
Bellevue, Washington 98007
Tel: 425-451-4945
Fax: 425-451-4318

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according to the Lease, the sum of which to be determined at a later date, until

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Defendants surrender Premises or until possession is restored to Plaintiff;

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D. That Plaintiff be awarded judgment against Defendants for Plaintiff's costs,
disbursements and for attorneys’ fees;
E. That Plaintiff be awarded any other damages or remedies available to the
Plaintiff.
DATED this 16th day of January 2019.

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CHIANGLIN LAW FIRM, PLLC

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/s/ Dave Bandstra
Dave Bandstra, WSBA #40544
Steve Chianglin, WSBA #36582
10 – 148th Avenue NE, Suite 202
Bellevue, Washington 98007
425.451.4945
dave@chianglinlawfirm.com
steve@chianglinlawfirm.com
Attorneys for Plaintiffs

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Complaint for Unlawful Detainer - 3

CHIANGLIN LAW FIRM, PLLC
10-148th Avenue N.E. Suite 202
Bellevue, Washington 98007
Tel: 425-451-4945
Fax: 425-451-4318