taylor complaint disbarment/prosecution to washington state bar association

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Complaint for Disbarment and referral for prosecution to the Washington State Bar Association and the Washington Supreme Court against JESSICA TAYLOR (REEVES), WSBA #36248, RCW 42.20.030 usurping the office of STEVENS COUNTY DEPUTY PROSECUTOR. JULY 2015

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  • NOTE:On July 13, 2015, the following cover letterwas sent to theOffice ofDisciplinaryCounseloftheWashingtonStateBARAssociationfortheiractionontheComplaintslistedbelowbyUSPSCertifiedMail#70113500000186255639.

    ConnieLaRue1045KittNarcisseRd.

    Colville,Washington99114(509)6842627

    July13,2015OfficeofDisciplinaryCounselWashingtonStateBarAssociation1325FourthAvenue,Suite600Seattle,WA981012539InRe:1. COMPLAINT FOR DISBARMENT AND REFERRAL FOR PROSECUTION OF TIMOTHYRASMUSSEN, WSBA #32105, FOR CRIMINAL IMPERSONATION OF A PUBLIC OFFICIAL,OBSTRUCTIONOFJUSTICEANDVIOLATINGHISSWORNOATHOFATTORNEY.2. COMPLAINTFORDISBARMENTANDREFERRALFORPROSECUTIONOFJESSICATAYLOR,WSBA #36248, FOR CRIMINAL IMPERSONATION OF A DEPUTY PROSECUTOR, OBSTRUCTINGJUSTICEANDVIOLATINGHERSWORNOATHOFATTORNEY.DearClerk:EnclosedwiththisCoverLetterisaComplaintforDisbarmentofTimothyRasmussenandJessicaTaylorandanExhibitPackageinsupport.IhavealsoenclosedthefirstpagesoftheenclosuresforyoutopleaseconformandreturnthemtomeintheenclosedSASE.Thankyou.ConnieLaRue

  • Connie LaRue 1045 Kitt-Narcisse Rd Colville, Washington 99114

    USPS Cert. Mail 701135000001 8625 5585

    TO THE SUPREME COURT OF THE STATE OF WASHINGTON

    COMPLAINT FOR DISBARMENT AND REFERRAL FOR PROSECUTION OF JESSICA TAYLOR, WSBA #36248, FOR CRIMINAL IMPERSONATION OF A

    DEPUTY PROSECUTOR, OBSTRUCTING JUSTICE AND VIOLATING HER SWORN OATH OF ATIORNEY.

    LaRue relies on the following relevant facts, statutes and court rulings from the Washington state and Federal courts in making this complaint.

    FACTS:

    1. JESSICA TAYLOR, WSBA #36248, (hereafter TAYLOR), was "appointed" on December 31, 2014, to the public office of STEVENS COUNTY DEPUTY PROSECUTOR by TIMOTHY RASMUSSEN WSBA #32105. RASMUSSEN failed to duly qualify for the office of STEVENS COUNTY PROSECUTOR and was without authority to appoint TAYLOR to any office.

    2. Although TAYLOR has been acting as DEPUTY PROSECUTOR and blindly executing the illegal "orders" of RASMUSSEN, there exists no evidence that TAYLOR could be duly qualified for the office or perform such duties because RASMUSSEN was illegally impersonating a county prosecutor at the time of TAYLOR's appointment.

    3. RCW 36.27.040 Appointment of deputies - Special and temporary deputies. "The prosecuting attorney may appoint one or more deputies who shall have the same power in all respects as their principal. Each

    COMPLAINT FOR DISBARMENT AND REFERRAL FOR PROSECUTION Page 1 of 15

  • appointment shall be in writing, signed by the prosecuting attorney, and filed in the county auditor's office. Each deputy thus appointed shall have the same qualifications required of the prosecuting attorney... /I

    4. What does not appear does not exist. It is believed that for this very reason, TAYLOR's Appointment was never legitimately filed into the official public records with evidence of Fee Paid (RCW 65.04.015(2), (3) and (4}) for the filing and an Auditor's File Number assigned because RASMUSSEN was without lawful authority to make the appointment and did not want to be accused of filing a false instrument in addition to all his other criminal acts.

    5. It was TAYLOR's duty to vet and verify that RASMUSSEN (her Superior) was in fact a duly-qualified COUNTY PROSECUTOR at the time of accepting her alleged "appointment" and performing the duties of that office.

    6. TAYLOR obediently carried out her Superior's (RASMUSSEN's) illegal orders 1 to prosecute Citizens of STEVENS COUNTY that resulted in deprivations of unalienable rights to life, liberty and property from unlawful imprisonment and/or fines. TAYLOR must accept unlimited liability for her actions in her individual capacity. "Ignorance of the law does not excuse" and blindly following illegal orders of a Superior does not absolve of personal liability.

    7. TAYLOR is a Washington State Bar member with an Oath of Attorney who has ignored the law and its requirements to duly qualify, for which she should be disbarred.

    8. TAYLOR swore an OATH OF ATIORNEY (see RCW 2.48.210) which is on file with the Washington Supreme Court and states in relevant part:

    1 This footnote applies to those who have been allegedly "appointed" and are blindly obeying orders of an illegal usurper of a public office (i.e. "Superior"). Obeying illegal orders did not stop the Nazi subordinates from being held accountable for their crimes at the Nuremburg Trials. The defense of superior orders was no longer considered enough to escape punishment; but merely enough to lessen punishment. H.T. King, Jr., The Legacy of Nuremberg, Case Western Journal of International Law, Vol. 34. (Fall 2002) at pg. 335.e

    COMPLAINT FOR DISBARMENT AND REFERRAL FOR PROSECUTION Page 2 of 15

  • "I am fully subject to the laws of the State of Washington and the laws of the United States, and will abide by the same. "; "I will support the constitution of the State of Washington and the constitution of the United States"; and "I will abide by the Rules of Professional Conduct approved by the Supreme Court of the State of Washington. II

    9. TAYLOR has been knowingly, willfully and criminally impersonating a public officer and usurping a public office since first being illegitimately "appointedll to the position of DEPUTY PROSECUTOR.

    10. During TAYLOR's "tenurell of criminally impersonating a DEPUTY PROSECUTOR and the criminal usurpation of the office of STEVENS COUNTY DEPUTY PROSECUTOR, TAYLOR has conducted hundreds, perhaps thousands, of illegal "prosecutionsll by fraud and deception, passing off a simulated legal process as legitimate legal process, resulting in the deprivation of people's property through unauthorized fines and their lives through illegal imprisonments.

    11. TAYLOR illegally implemented a simulated legal process against Connie LaRue in STEVENS COUNTY DISTRICT COURT, Case No. 5Z0133878 using a false report from a criminal actor impersonating a CITY OF CHEWELAH police officer named JOHNATHAN LLOYD BOWERS who "stopped and ticketed" LaRue outside the jurisdiction of the CITY OF CHEWELAH and that illegal case was dismissed.

    12. TAYLOR knew or should have known from the unauthorized BOWERS "police" report that to illegally prosecute LaRue by the CITY OF CHEWELAH was a violation of LaRue's due process rights and a form of punishment by compelling her to defend against multiple illegal prosecutions. "A court's jurisdiction... may be lost in the course of the proceedings... If this requirement of the... {BiII of Rights] is not complied with the court no longer has jurisdiction to proceed. The judgment... pronounced by a court without jurisdiction is void... 11 Johnson v. Zerbst 304 US 458, 468.

    COMPLAINT FOR DISBARMENT AND REFERRAL FOR PROSECUTION Page 3 of 15

  • 13. TAYLOR has blindly accepted a false ((police report" as grounds for prosecution to punish LaRue through an organized enterprise to use an illegal traffic stop for harassment that resulted in a false arrest, false imprisonment in the county jail and other such illegal acts in conspiracy with other impersonators in public office in STEVENS COUNTY. LaRue was targeted and punished for exercising her right to travel to a safe and well-lighted area because STEVENS COUNTY is renown for its recent rash of rapist "officers of the law".

    14. While still criminally impersonating a county prosecutor, TAYLOR has taken the lead to again ((charge" LaRue by naming the STATE OF WASHINGTON as the Plaintiff (STEVENS COUNTY DISTRICT COURT No. P7944) which has resulted in LaRue remaining under threat, duress and coercion, and the continuing deprivation of LaRue's time, energy and meager finances.

    15. TAYLOR has filed false documents. She has given four different locations where the supposed crime occurred. The arresting "policeman" gave a fifth location, but the dash cam and Dispatch call give a sixth location.

    16. TAYLOR has filed documents sworn by the involved "policeman" that were replete with lies.

    17. TAYLOR claims that a form distributed by WASPC, allegedly signed by usurper STEVENS COUNTY ((SHERIFF" KENDLE ALLEI\l on 12/21/2010, gives police powers to all general authority agencies in WASHINGTON STATE. ALLEN cannot be granted or grant to himself power the people themselves do not possess. This fraudulent unconstitutional ((document" is not "filed" or ((recorded", and yet TAYLOR says it is law and this is her stated source of jurisdiction for the arresting "policeman". Even legitimate and duly-qualified sheriffs do not make law.

    18. LaRue attempted to file an Application for Writ of PrOhibition, Injunction and Show Cause Order with the WASHINGTON SUPREME COURT and was rejected because a "state officer" was not a party to the complaint.

    COMPLAINT FOR DISBARMENT AND REFERRAL FOR PROSECUTION Page 4 of 15

  • 19. LaRue re-filed the same Application for Writ of Prohibition, Injunction and Show Cause Order with different heading to the STEVENS COUNTY SUPERIOR COURT demanding a duly-qualified SUPERIOR COURT JUDGE hear the case and giving the CLERK OF COURT 20 days to find and assign a duly-qualified judge.

    20. More than 20 days have passed and LaRue's efforts have been stifled (obstructing justice) by a non-qualified "judge" named ALLEN C. NIELSOI\I. NIELSOI\I is holding hostage LaRue's in forma pauperis application. Nielson has no authority to grant LaRue's application to proceed without costs because he is not a duly-qualified SUPERIOR COURT JUDGE. NIELSON's action is obstructing LaRue's ability to have her Application for a Pre-emptory Writ of Prohibition, Injunction, and Show Cause Order heard before a competent and duly-qualified judge.

    21. Although LaRue has been unable to obtain justice in the STEVENS COUNTY COURTS, the WASHINGTON DEPARTMENT OF LICENSING has continued to move forward by issuing a NOTICE OF SUSPENSION of LaRue's license and NOTICE OF DELINQUENCY. TAYLOR's participation in this STEVENS COUNTY RIC0 2 enterprise could result in LaRue being stopped, assaulted, kidnapped and falsely imprisoned again, in spite of the fact that LaRue has not been found guilty of anything and has not had her day in court.

    22. TAYLOR has illegally usurped and criminally impersonated a public official and her illegal conduct has been protected by one or more persons in STEVENS COUNTY that have not duly qualified to occupy and perform the lawful duties of certain public offices. An honest audit of STEVENS COUNTY by the STATE AUDITOR's OFFICE would expose that thousands of Citizens have been deprived of their unalienable rights of life, liberty and property through illegal fines and/or incarceration.

    23. It is believed that TAYLOR is participating in a STEVENS COUNTY RICO enterprise, with illegal assaults (and assaults with a deadly weapon),

    2 The Racketeer Influenced and Corrupt Organizations Act, commonly referred to as the RICO Act or simply RICO, is a United States federal law that provides for extended criminal penalties and a civil cause of action for acts performed as part of an ongoing criminal organization.

    COMPLAINT FOR DISBARMENT AND REFERRAL FOR PROSECUTION Page 5 of 15

  • false arrests, kidnapping, false imprisonment, extortion and other crimes against the people happening on a daily basis.

    24. TAYLOR has repeatedly violated her sworn OATH OF ATTORNEY.

    25. TAYLOR's occupation of an office she was not authorized to possess is prima facie evidence that she is an illegal usurper into public office.

    26. Every action taken by TAYLOR while impersonating a public officer is a criminal act for which she has yet to be held accountable.

    RELEVANT LAW RELIED UPON IN SUPPORT OF THIS COMPLAINT:

    "We have no officers in this government from the President down to the most subordinate agent, who does not hold office under the law, with prescribed duties and limited authority. And while some of these... exercise powers in some sense left to the more general definitions necessarily incident to fundamental law found in the Constitution, the larger portion of them are the creation of statutory law, with duties and powers prescribed and limited by law." [Pierce v. United States] THE FLOYD ACCEPTANCES, 74 US 666 at 676-677; (7 Wall. 666), Supreme Court 1868, Washington Law Reporter, Vol. XLII Page 297.

    Maxim of Law: "What does not appear does not exist."

    Maxim of Law: Ignorantia juris non excusat: "Ignorance of the law does not excuse."

    Black's Law 6th Edition states: "Duly Qualified" - Being Ilduly qualijiedN to fill an office, in the constitutional sense and in the ordinary acceptation of the words} means that the officer shall possess every qualification; that he shall in all respects comply with every requisite before entering on duties of the office; and that he shall be bound by oath or affirmation to support the Constitution} and

    COMPLAINT FOR DISBARMENT AND REFERRAL FOR PROSECUTION Page 6 of 15

  • to perform the duties of the office with fidelity. Black's Law Dictionary 6th Edition.

    RCW 42.20.030 (in relevant part) - Intrusion into and refusal to surrender public office. Every person who shall falsely personate or represent any public officer, ... or who shall willfully exercise any of the functions or perform any of the duties of such officer, without having duly qualified therefore, as required by law, ... shall be guilty of a gross misdemeanor.

    "The fact that the candidate is qualified at the time of his election is not sufficient to entitle him to hold the office it at the time of his commencement to his term of Office, or during the continuance of the term, he ceases to be qualified. Eligibility to public office is of a continuing nature, and must subsist at the commencement of the term, and during the occupancy of the office. " Washington Attorney General Opinion - AGO 63-64, no. 17.

    LEGISLATIVE MANDATES TO DULY QUALIFY FOR PUBLIC OFFICE SUPPORTED BY WASHINGTON COURT RULINGS

    1. RCW 2.48.210 Oath on admission requires an Oath of Attorney before authorization to practice law in Washington stating: "Every person before being admitted to practice law in this state shall take and subscribe the following oath/!.

    2. RCW 36.27.040 Appointment of deputies - Special and temporary deputies. "The prosecuting attorney may appoint one or more deputies who shall have the same power in all respects as their principal. Each appointment shall be in writing, signed by the prosecuting attorney, and filed in the county auditor's office. Each deputy thus appointed shall have the same qualifications required of the prosecutinq attorney, except that such deputy need not be a resident of the county in which he or she serves.

    COMPLAINT FOR DISBARMENT AND REFERRAL FOR PROSECUTION Page 7 of 15

  • The prosecuting attorney may appoint one or more special deputy prosecuting attorneys upon a contract or fee basis whose authority shall be limited to the purposes stated in the writing signed by the prosecuting attorney and filed in the county auditor's office. Such special deputy prosecuting attorney shall be admitted to practice as an attorney before the courts of this state but need not be a resident of the county in which he or she serves and shaJl not be under the legal disabilities attendant upon prosecuting attorneys or their deputies except to avoid any conflict of interest with the purpose for which he or she has been engaged by the prosecuting attorney. The prosecuting attorney shall be responsible for the acts of his or her deputies and may revoke appointments at will. "

    3. Right to hold public office is subject to qualifications imposed by legislature.// State ex reI. Carroll v. Simmons (1962) 61 Wash.2d 146, 377 P.2d 421, cert, denied 83 S. Ct. 1698, 374 U.S. 808, 10 L. Ed.2d 1032

    4. "Use of word "shaW~ in statute imposes mandatory duty/~ Waste Management of Seattle, Inc. v. Utilities and Trans. Com'n, 869 P.2d 1034, 123 Wash.2d 621, reconsideration denied (1994).

    5. RCW 36.16.040 Oath of office. "Every person elected to county office shall before he or she enters upon the duties of his or her office take and subscribe an oath or affirmation that he or she will faithfully and impartially discharge the duties of his or her office to the best of his or her ability. //

    6. RCW 36.16.060 Place of filing oaths and bonds. "Every county officer~ before entering upon the duties of his or her office~ shall file his or her oath of office in the Office of the county auditor and his or her official bond in the office of the county clerk... Oaths and bonds of deputies shall be filed in the offices in which the oaths and bonds of their principals are required to be filed."

    7. RCW 65.04.030 Instruments to be recorded or filed. The auditor or recording Officer must, upon the payment of the fees as required in RCW 36.18.010...

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  • (3) All such other papers or writing as are required by law to be recorded and such as are required by law to be filed.

    8. RCW 65.04.130 Fees to be paid or tendered. Said county auditor is not bound to record any instrument or file any paper or notice, or furnish any copies, or to render any service connected with his or her office, until his or her fees for the same, as prescribed by law, are if demanded paid or tendered.

    NProvision requiring payment of fees in advance is mandatory. 1/ State v. Nelson (1940) 6 Wash.2d 190, 107 P.2d 1113.

    NWhen papers are received by officer for filing, filing will not become effective until necessary fees have been paid." State v. Conners (1942) 12 Wash.2d 128, 120 P.2d 1002; State v. Nelson (1940) 6 Wash.2d 190, 107 P.2d 1113.

    NStatutes relating to compensation of public officer must be strictly construed in favor of government, and such officers are entitled only to what is clearly given by law. N Murphy v. State Dept. of Licensing (1981) 28 Wash. App. 620, 675 P.2d 732.

    "Day on which oath of office is signed and filed by judge of superior court is day on which he assumes office for purposes of pension benefits, and day of Governor's announcement of proposed appointment is immaterial." Jordan v. O'Brien (1971) 79 Wash.2d 406, 486 P.2d 890.

    9. RCW 65.08.150 Duty to Record: A recording officer, upon payment or tender to him or her of the lawful fees therefor, shall record in his or her office any instrument authorized or permitted to be so recorded by the laws of this state or by the laws of the United States.

    10. "When legislative body provides definitions for statutory terms, it is that definition to which the person must conform his

    COMPLAINT FOR DISBARMENT AND REFERRAL FOR PROSECUTION Page 9 of 15

  • conduct." City of Seattle v. Koh, 26 Wash. App. 708, 614 P.2d 665 (1980).

    "Where an act uses the word in a special sense which it defines, definition by average man or by ordinary dictionary is not substitute for the definitions contained in the act." National Homeopathic Hospital Ass'n of District of Columbia et.al. v. Britton, Deputy Com'r., 147 F2d 561.

    11. Legislative Definitions (summation) of NFILE"J NFILEDIIJ or NFILINGII and NRECORD", NRECORDEDII or NRECORDINGII

    RCW 65.04.015(2} FILED for Nrecording into the official public record" RCW 65.04.015 (3) RECORD Nafter filing to incorporate the instrument into the public records ll

    RCW 65.04.015 (4) NRECORDING NUMBERII Assignment of an Nauditor or recording officer file numberllNthat identifies the storage location ll "of each instrument in the public records ll Naccessible in the same recording office where the instrument containing the reference to the location is found. 11

    12. RCW 5.44.040 Certified copies of public records as evidence. Copies of all records and documents on record or on file in the offices of the various departments of the United States and of this state or any other state or territory of the United States, when duly certified by the respective officers having by law the custody thereof, under their respective seals where such officers have official seals, shall be admitted in evidence in the courts of this state. [NOTE: If the fees for filing and/or recording are not paid in advance, an oath of office cannot be made a part of the official public record.]

    13. RCW 42.20.100 Failure of duty by public officer a misdemeanor. Whenever any duty is enjoined by law upon any public officer or other person holding any public trust or employment, their wilful neglect to pedorm such duty, except where otherwise speciallv provided for, shall be a misdemeanor.

    COMPLAINT FOR DISBARMENT AND REFERRAL FOR PROSECUTION Page 10 of 15

  • 14. RCW 9A.80.010 Official Misconduct (l)(a) ...intentionally commits an unauthorized act under color of law (b) .. .intentionally refrains from performing a duty imposed upon him or her by law. (2) OffiCial misconduct is a gross misdemeanor, defined at RCW 9.92.020.

    15. RCW 42.12.010 Causes of vacancy, Every elective office shall become vacant on the happening of any of the following events: (5) ... any offense involving a violation of his or her official oath; (6) His or her refusal or neglect to take his or her oath of office~ or to give or renew his or her official bond~ or to deposit such oath or bond within the time prescribed by law.

    16. RCW 42.20.030 -Intrusion into and refusal to surrender public office. Every person who shall falsely personate or represent any public officer~ or who shall willfully intrude himself into a public office to which he has not been duly elected or appointed, or who shall willfully exercise any of the functions or perform any of the duties~ without having duly qualified as required by law, ..., shall be guilty of a gross misdemeanor.

    17. RCW 9A.56.130 Extortion in the second degree. (1) A person is guilty of extortion in the second degree if he commits

    extortion by means of threat as defined in RCW 9A.04.110(28)(d) through (j).

    (2) Extortion in the second degree is a class Cfelony.

    RCW 9A.04.110 - Definitions. (28) "ThreatN means to communicate directly or indirectly the intent: (h) To take wrongful action as an official against anyone or anything, or wrongfully withhold official action, or cause such action or withholding;

    The Washington Legislature enacted two laws, one which was enacted in 1866 and another that was enacted in 1909, both of which are still on the books and are now recodified as RCW 42.12.010 and 42.20.030.

    COMPLAINT FOR DISBARMENT AND REFERRAL FOR PROSECUTION Page 11 of 15

  • RCW 42.12.010 originally enacted in 1866 and to date, remains almost unchanged, allows no grace period under subsection (6) for any refusal or neglect (to duly qualify] within the time prescribed by law.

    RCW 42.20.030 was originally enacted in 1909 and has never been changed and contains four different offenses that constitute the act of intrusion into public office and one for refusal to surrender public office.

    Three of these offenses require certain acts to be performed "willfully" in order to be a crime, but two of the offenses only require that certain acts be performed.

    The first element states, "Every person who shall falsely personate or represent any public officer, or ... " Notice that no intent is required.

    The second element states, "who shall willfully intrude himself into a public office to which he has not been duly elected or appointed, or ... " Wilfullness is established by knowledge (RCW 9A.08.010) and "duly" is defined in Black's Law Dictionary 6th Ed. as "In due and proper form or manner; according to legal requirements....; according to law in both form and substance."

    The third element states, "who shall willfully exercise any of the functions or perform any of the duties of such officer, without having duly qualified therefor, as required by law; or... "

    "Being duly qualified to fill an office, in the constitutional sense and in the ordinary acceptation of the words, means that the officer shall possess every qualification; that he shall in all respects comply with every requisite before enterinq on the duties of the office; and that he shall be bound by oath or affirmation to support the Constitution, and to perform the duties of the office with fidelity." Black's Law Dictionary 6th Ed

    The fourth element states, "Who, having been an executive or administrative officer, shall Willfully exercise any of the functions of his office after his right to do so has ceased, or ..."

    The fifth element states, "wrongfully refuse to surrender the official seal or any books or papers appertaining to such office, upon the demand of his lawful

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  • successor shall be guilty of a gross misdemeanor. "See RCW 9A.60.040 Impersonating a Public Officer and RCW Chapter 7.56 Quo Warranto.

    RCW 9a.60.040 Criminal impersonation in the first degree. (1) A person is guilty of criminal impersonation in the first degree if the person:

    (a) Assumes a false identity and does an act in his or her assumed character with intent to defraud another or for any other unlawful purpose; or

    (b) Pretends to be a representative of some person or organization or a public servant and does an act in his or her pretended capacity with intent to defraud another or for any other unlawful purpose.

    (2) Criminal impersonation in the first degree is a class Cfelony.

    CONCLUSIONS RELIED UPON FOR THIS CRIMINAL COMPLAINT:

    First, if the fees for filing are not paid in advance, an oath of office cannot be made a part of the official public record. see RCW 5.44.040.

    Second, if the official oath is not made part of the official public record, it grants no lawful authority.

    Third, if the oath is not filed as defined in RCW 65.04.040, it is not part of the official public record.

    RCW 65.04.040 Method for recording instruments - Marginal notations - Arrangement of records. Any state, county, or municipal officer charged with the duty of recording instruments in public records shall record them by *record location number in the order filed, irrespective of the type of instrument, using a process that has been tested and approved for the intended purpose by the state archivist. In addition, the county auditor or recording officer, in the exercise of the duty of recording instruments in public records, may, in lieu of transcription, record all instruments, that he or she is charged by law to record, by any electronic data transfer, photographic, photostatic,

    COMPLAINT FOR DISBARMENT AND REFERRAL FOR PROSECUTION Page 13 of 15

  • microfilm~ microcard~ miniature photographic or other process that actually reproduces or forms a durable medium for so reproducing the origina/~ and which has been tested and approved for the intended purpose by the state archivist. If the county auditor or recording officer records any instrument by a process approved by the state archivist it shall not be necessary thereafter to make any notations or marginal notes~ which are otherwise required by law~ thereon if, in lieu of making said notations thereon~ the auditor or recording officer immediately makes a note of such in the general index in the column headed "remarks~" listing the record number location of the instrument to which the current entry relates back. Previously recorded or filed instruments may be processed and preserved by any means authorized under this section for the original recording of instruments. The county auditor or recording officer may provide for the use of the public~ media containing reproductions of instruments and other materials that have been recorded pursuant to the provisions of this section. The contents of the media may be arranged according to date offiling~ irrespective of type of instrument or in such other manner as the county auditor or recording officer deems proper.

    Fourth, if the oath of office is not actually made part of the official public record, as defined in law, it cannot be admitted into evidence under ER 902(d} or ER 1005 to support a lawful claim for salaries or benefits [or for any other purpose] relating to a public office.

    Fifth, as shown by the case law already supplied to you, all filing fees are mandatory and are to be paid in advance and your [STATE AUDITOR] examiners are supposed to know that an oath of office. an appointment to a public office. and an official bond are required by law to be filed and/or recorded into and made part of the official public record. requiring a paid receipt for those transactions. AUDITORs know that there can be no lawful occupation of the intended office by a person impersonating a public official or usurping a public office.

    Sixth, there are several sections in RCW 43.09 that would cover your [STATE AUDITOR'S] department responsibility to verify that the bonds, appointments and

    COMPLAINT FOR DISBARMENT AND REFERRAL FOR PROSECUTION Page 14 of 15

  • oaths were filed, as required by law, such as RCW 43.09.200, 43.09.210, 43.09.230, and 43.09.245 but, under 43.09.260 your department has specific information as to what is required pursuant to subsection (5). RCW 43.09.260(5) "On every such examination, inquiry shall be made as to the financial condition and resources of the local government; whether the Constitution and laws of the state, the ordinances and orders of the local government and the requirements of the state auditor have been properly complied with, and into the methods and accuracy of the accounts and reports. II

    IN CLOSING

    For the foregoing reasons supported by facts, relevant law, statutes, and Washington court rulings, JESSICA TAYLOR WSBA #32105 should be disbarred and referred by this body of examiners and mandatory reporters for criminal prosecution before the appropriate authorities, state or federal.

    I declare under penalty for perjury that the foregoing facts, relevant laws relied upon, legislative mandates relied upon, and conclusions to support this COMPLAINT FOR DISBARMENT AND REFERRAL FOR PROSECUTION OF JESSICA TAYLOR, WSBA #32105, FOR CRIMINAL IMPERSONATION OF A PUBLIC OFFICIAL, OBSTRUCTION OF JUSTICE AND VIOLATING HER SWORN OATH OF ATIORNEY are true and correct to the best of my knowledge, understanding and belief.

    All Rights Reserved ' l .~( l O-'AyuP \.yq t:; L-L~

    Connie LaRue, Affiant JURAT

    Washington State} Stevens County } ss.

    I, (] flKLfJ Y72 tioed! , a Washington Notary Public, do certify that Connie LaRue appeared before me and swears under penalty of perjury. that the.,

    a a ,. t t t \; r'l J , .~ j ... foregoing IS true. . ~~. ~.,\ h,~")JJ

    /IV y' ""'"" JOn this, the ~!::day of 3W1e ,2015. ;I"! .'.l~:' ....:.:y \ C.dRJA!l2;;~\ ~. ' =-". ~";'~ ; .....

    Washington Notary ~ubUc - y"': :" ';lrR~"" ~""i :"._' ~

    My appointment eXPltzs:~4;~9:~::~(;1' ";r., " (...:::~, -1 : ....":"\ ~r:.~ "1 I \ I .., .. ".

    " l f J1 ~ n !' ~ ~ ~ ~ ~', . COMPLAINT FOR DISBARMENT AND REFERRAL FOR PROSECUTION Page 15 of 15

  • INDEX OF EXHIBITS EXHIBIT 1: TIMOTHY RASMUSSENs various non-compliant-with-state law Oaths of Office impersonating a COUNTY PROSECUTOR in STEVENS COUNTY and his OATH OF ATTORNEY.

    EXHIBIT 2: JESSICA TAYLORs illegal Appointment as an alleged DEPUTY PROSECUTOR in STEVENS COUNTY by usurper TIMOTHY RASMUSSEN. EXHIBIT 3: First two charging instruments CITY OF CHEWELAH v. CONNIE LARUE Case No. 5Z0133878 & Case No. 5Z0133879. EXHIBIT 4: MOTION AND MEMORANDUM FOR DISMISSAL showing TAYLOR conducted an illegal prosecution and violated LaRues rights. EXHIBIT 5: Order for dismissal of cases No. 5Z0133878 & No 5Z0133879 EXHIBIT 6: New Charge STATE OF WASHINGTON v. Connie LaRue, Case No. P7944 using the same illegal police report to justify re-prosecuting LaRue to extort over $1062. EXHIBIT 7: WASHINGTON DEPARTMENT OF LICENSING NOTICE OF SUSPENSION NOTICE 8: WASHINGTON DEPARTMENT OF LICENSING NOTICE OF DELINQENCY

    NOTICE There is no evidence that any of the below-named impersonators of a public official and criminal usurpers of a public office are compliant with state law. None have an oath of office or appointment properly filed and incorporated into the official public records. This blatant disregard for Washington State Law has deprived LaRue of her right to Justice through Due Process of Law at minimum.

    TIMOTHY RASMUSSEN JESSICA TAYLOR SAUNDRA RICHARTZ NICHOLAS FORCE KENDLE ALLEN TROY ANDERSON

    JOHNATHAN BOWERS GINA A. TVEIT

    LLOYD B. NICKEL ALLEN C. NIELSON PATRICK A. MONASMITH

    Page 1 of 1

  • Exhibit 1 Under this Exhibit are TIMOTHY RASMUSSENs invalid, non-filed, non-compliant with Washington State Law alleged Oaths of Office but they do not make him duly qualified. Also find his Oath of Attorney where he swore he was fully subject the laws of the State of Washington and will abide by same. A properly Filed Document will contain evidence of an Auditor File Number, number of pages, amount of Fee Paid, and where the document can be located for review.

    Any document required by law to be recorded or required by law to be filed must contain evidence as viewed to the right.

  • Text BoxThe STAMP to the right does not comply with state law as defined in RCW 65.04.015(2), (3) and (4). There is no Auditor File #, No evidence of required Fee Paid, etc. This "oath" has not been made a part of the official public record. This "oath" is just a worthless piece of paper.

  • STATE OF WASHINGTON}

    COUNTY OF STEVENS }

    OATH OF OFFICE

    I, ~""'- 1

  • ~~~~Fo~~.S~f~e: , SS. ~. (}-" ~-'_. J

    I, JI.tn.t(7}f.Y.. ~('('Jtd~ , , do solemnly declare: 1. 1 am fully subject to the laws of the State of Washington and the laws of the United States and will abide by

    the same.

    2. I will support the constitution ofthe State ofWashington and the constitution of the United States.

    3. 1 will abide by the Rules ofProfeSSional Conduct approved by the Supreme Court of the State of Washington.

    4. I will maintain the respect due to the courts ofjustice and judicial officers.

    5. I will not counsel, or maintain any suit, or proceeding, which shall appear to me to be unjust, or any defense except as I believe to be honestly debatable under the law, unless it is in defense of a person charged with a public offense. 1 will employ for the purpose of maintaining the causes confided to me only those means consistent with truth and honor. I will never seek to mislead the judge or jury by any artifice or false statement.

    6. I will maintain the confidence and preserve inviolate the secrets of my client, and will accept no compensation in connection with the business of my client unless this compensation is from or with the knowledge and approval of the client or with the approval of the court.

    7. I will abstain from all offensive personalities, and advance no fact prejudicial to the honor or reputation of a party or witness unless required by the justice of the cause with which I am charged.

    8. I will never reject, from any consideration personal to myself, the cause of the defenseless or oppressed, or delay unjustly the cause ofany person.

    . ~..R~ ~ . _~~..(...S..::'ignature)

    ., ,2c1?~ ..

    Judge

    ."

  • Exhibit 2 Under this Exhibit is JESSICA TAYLORs invalid Appointment by RASMUSSEN to the Office of Deputy Prosecutor. A copy of TAYLORs sworn Oath of Attorney required by RCW 2.48.210 was unable to be procured upon public records request to the Supreme Court. However it is believed that TAYLOR also swore that she was fully subject the laws of the State of Washington and will abide by same. A properly Filed Document (Appointment) will contain evidence of an Auditor File Number, number of pages, amount of Fee Paid, and where the document can be located for review.

    Any document required by law to be recorded or required by law to be filed must contain evidence as viewed to the right.

  • - .-.~~_.-~Ptp---'/ .. '.

    . ._ ..._,

    ._.:.-,,---~.

    '"

    STEVENS COUNTY PROSECUTING ATTORNEY

    State of Washington ) ) ss CERTIFICATE OF APPOINTMENT

    County of Stevens )

    I, Tim Rasmussen, Prosecuting Attorney of Stevens County, State of Washington, having special confidence in Jessica Taylor, do hereby constitute and appoint Jessica Taylor Deputy Prosecutor of said County, State of Washington, until revoked by me, which appointment shall thereafter cease and be null and void.

    IN TESTIMONY WHEREOF, I have hereunto set my hand this 31 day of December 2014.

    Tim Rasmussen Stevens County Prosecutor

    Text BoxThis "Appointment" does not comply with state law as defined in RCW 65.04.015(2), (3) and (4). There is no Auditor File #, No evidence of required Fee Paid, etc. This "Appointment" has not been made a part of the official public record. This "appointment" is just a worthless piece of paper.

  • Exhibit 3

    First two charging instruments CITY OF CHEWELAH v. CONNIE LARUE

    Cases No. 5Z0133878 & No. 5Z0133879.

  • -i

    99114

    RESIDENTIAL PHONE NO.

    COLVILLE

    DNO

    THE UNDERSIGNED CERTIFIES AND SAYS THAT IN THE STATE OF WASHINGTON PHOTO ID MATCHED NAME: LAST

    LARUE DRIVER'S LICENSE NO.

    LARUEC*527LO ADDRESS 1045 KITT NARL:ISSE RD

    M.P.

    CRIMINAL Q]TRAFFIC DNON-TRAFFIC LEA OR! # WA0330100 COURT ORI #: WA033023J 5Z0133878 REPORT # H1500190 o

    ....... ,,,"-','\"................. VLJV" ...VloJ

  • --

    --

    i

    INFRACTION Q]TRAFFIC DNON-TRAFFIC LEA ORI #: WA0330100 COURTORI # WA033023J INFRACTION#: 5Z0133879 REPORT#: H1500190 z IN lHE lZ]DISTRICT DMUNICIPAL COURT OF STEVENS COUNTY DISTRICT COURT " DSTATE OF WASHINGTON D COUNTY OF lZ]CITYITOINN OF CHEWELAH PLAINTIFF VS. NAMED DEFENDANT ::u l>

    THE UNDERSIGNED CERTIFIES AND SAYS THAT IN THE STATE OF WASHINGTON o DRIVER'S L1CE-N-S-E-N-O-.-----~ls,."T,."A",TE~IE,...X...,P-IR-E-S-~I-PH-O'"'T'"'O-IDMATCHED I NAME: LAST FIRST MIDDLE SFX CDL -t

    DID THEN AND THERE COMMIT EACH OF THE FOLLOWING OFFENSES VEH SPEED IN A ZONE I ISMD L~ I IAIRCRAFT 1. VIOLAllONISTATUTE CODE 46. 16A.030. 5. L FL RENEW:-.-'=Eo-!:Xii:p;;ilR=-E=D=-=R-=E'"'G=--.Jrrrl\1'[ Nl\l Ii" (~ I'III'JIII,", IINll[F rlll~t,'\v"'/H IHI-::.I:\rr-nfWr'-IHII,W.I(!t'lllIi\lII-//\V/-I:,,IILn IIII:-.'Jt~ rHI 11/',rlAN[I' i rrll l\j( fI,!tOl\lI\Wl'vE. l"Irr,IIII!\\/1 l'r"')lJi\J"iL[( ~"ll:'( lour til 'II nn {.IJl;1'1 11 .. fllllr'l",~~.i."'1

    iMMl1 rrri 1111 /dJeNI '. if I-[N:! (:-1. :\fH.11 ;'.M l r'~ IIIMlt, ~,Ill ,'\1 IIHUI,'I/[I 11):...1 I,' If 1"\~JlII'.-'\:-,:::v'\.'UI"[1 I OAl.IIIII:Jlrtc /\ll-If ." " ..... L..., ..... -_ ......... ,....,

    ......',' .... 1.."~~~" o TICKET SERVED ON VIOLA TOR D TICKET REFERRED TO PROSECUTOR

    o TICKET SENT TO COURT FOR MAILING NOnCE OF INFRACTION

    This is a non-criminal offense for which you cannol ~o 10 jail. YOU MUST RESPOND WITHIN FIFTEEN (15) DAYS FROM "THE DATE ISSUED.

    Your response must be postmarked bymidnighl of the dayil is due allhe court. II you do not respond or a ,pear for court hearinqs:

    TRAFFIC The court will find Ihal you commilled Ihe infradion.

    You may lose your dnve(s license privileqe. Your penany will be increased.

    Failure 10 pay may rec'Jll in a referral of your case to a

    Website: YMIW.co.stevens.wa.us/distcourVindex.htm To make online payments by credit card, please go to www.stevenstix.com.

    NON-TRAFFIC The court w;1I find Ihat you commilled Ihe Infraclbn.

    II is a crime and will be treated accordingly. Yo..- penally may be increased.

    I Failure to pay may resull in a referral of your case 10 a collection agency. I collection agency.

    Check one orthe 3 boxes to the right, sign, date, and mail this fonn to: My mailing address is: (PLEASE PRINT) Court conlacl information: Name: Phone 1: (5091684.5249 Streel or PO Box At: STEVENS COUNTY DISTRICT COURTI Slate: Zip Code: zICilY:

    215 S OAK. ROOM 213 ;T1Telephone: Home: Work: Dis interpreler needed? Language:

    COLVILLE WA 99114-2861 m NI,

    o

    Ix: oI (SIGNATURE. 5Z0133879 -f:> CO PAGE 1 OF 1

    "

    D I have enclosed a check or money order. ,n U.S funds. for Ihe amounllisted I understand IhlS will go on my dnvmg record If "raffic" IS checked. DO NOT SEND CASH. NSF checks Will be trealed as failure 10 respond.

    o Mitigalion Hearing. I agree' have commilled Ihe infraclion(s). bull wanl a hearing 10 explain Ihe circumslances. Please send me a court dale. and I prom,se 10 appear on that dale. I know I can ask w,lnesses 10 appear bul Ihey are nol required 10 appear. I understand IhlS Will go on my driving record if 'traffic" 's checked. The court may allow lime payments or reduce Ihe penally where allowed by law.

    o Contested Hearing. I wanllo conlesl (challenge) this infraction. I did nol commillhe infraction. Please send me a court dale. and I promise to appear on thai dale. The slate must prove by a preponderance oflhe evidence thai I Lommilled Ihe infraction. 1know I cLln require (subpoena) \"';Inesses. Including the officer who wTole the Iicketto attend lhe heanng. The court wililell me hIM' 10 requesl a witness's appearance. I undersland Ihis V'JiIl ,go on my driving record {I lose and "raffic" is checked.

    .AJ NOTICE: You may be able to enter into a payment plan with the court under RCW 46.63.110.

    m

    o o z

    C

  • Exhibit 4

    MOTION AND MEMORANDUM FOR DISMISSAL showing TAYLOR conducted an illegal prosecution and

    violated LaRues rights.

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    RECEIVED

    STEVENS COUNTY PROSECUTING AnORNEY

    COpy ORIGINAL FIL~D

    APR 14 2015 DISTRICT COURT

    STEVENS COUNTY, WA

    IN THE DISTRICT COURT OF THE STATE OF WASHINGTON

    IN AND FOR THE COUNTY OF STEVENS

    CITY OF CHEWELAIL

    vs.

    CONNIE LA RUE DOB: 06/20/1948

    Plaintiff,

    Defendant.

    NO.: 5Z133878

    MOTION AND MEMORANDUM TO SUPPRESS AND TO DISMISS COUNT 1

    MOTION

    COMES NOW the Defendant, by and through the undersigned counsel of record, and

    moves the Court to suppress the traffic stop due to want ofauthority of the arresting officer or, in

    . the alternative, to dismiss for lack ofjurisdiction ofthe City of Chewelah over the Defendant

    with respect to the alleged course of conduct.

    BASIS OF MOTION

    This motion is made pmsuant to the testimony put forward at hearing by Officer Bowers

    on April 9, 2015, the law as set forth below, CrRLJ 3.6, CrRLJ 5.1, and the records herein.

    MOTION AND MEMORANDUM TO SUPPRESS AND TO DISMISS COUNT 1

    GOLDEN LAW OFFICE P.L.LC. 298 S. Main, Ste. 203

    Colville, WA 99114 509-684-6322

    Fax 509-684-3286

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    LAW AND ARGUMENT

    I. Did the arresting officer exercise lawful authority when he arrested the Defendant

    beyond the territorial boundary of the City ofChewelah?

    RCW 10.93.070 expressly limits those occasions when a peace officer operating

    under the laws of the State ofWashington may make an arrest outside the bounds ofhis

    jurisdiction. It is the understanding of defense counsel that the City will rely uPQn RCW

    10.93.070*1) to establish that Officer Bowers had authority to operate outside the city

    limits. That statute permits: "Upon the prior written consent of the sheriffor chief of

    police whose primary territorial jurisdiction the exercise ofthe powers occurs." RCW

    10.93.070(1). ''When an officer's authority to act under subsection (1) has been

    cballenged, it is the [City] which must prove compliance with the statute's requirements."

    Ghaffari v. Department ojLicensing, 62 Wn.App.870, 875, 816 P.2d 66 (Div 1 1991).

    At hearing, the City was not able to provide any evidence in support of the

    proposition that Officer Bowers had authority to operate beyond the bounds of the City 0

    Chewelah. Following the hearing, the City was able to provide via counsel a signed lette

    from the Stevens County Sheriff's Office, issued in December 2010, authorizing all law

    enforcement agencies in Washington State to operate under the Sherriff's authority in

    Stevens County. it would appear that this is sufficient statutorily to render the officer's

    actions lawful and within the bounds of the authority granted him under State law.

    However, it does not permit the City authority to prosecute for actions outside its

    authority or for its municipal court to extend jurisdiction to such actions.

    MOTION AND MEMORANDUM TO SUPPRESS 2 GOLDEN LAW OFFICE P.L.LC. . AND TO DISMISS COUNT 1 298 S. Main, Ste. 203

    Colville, WA 99114 509-084-6322

    Fax 509-684-3286

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    II. May the City ofChewelah prosecute the Defendant for alleged conduct that, by

    undisputed testimony, took place entirely outside the territorial boundaries ofthe

    City ofChewelah?

    "Each county, city, and town is responsible for the prosecution, adjudication, sentencing,

    and incarceration ofmisdemeanor and gross misdemeanor offenses committed by adults

    in their respective jurisdictions." RCW 39.34.180(1),(emphasis added).

    The municipal court shall have exclusive original jurisdiction over traffic infractions arising under city ordinances and exclusive original criminal jurisdiction ofall violations ofcity ordinances duly adopted by the city and shall have original jurisdiction of all other actions brought to enforce or recover license penalties or forfeitures declared or given by such ordinances or by state statutes. A hosting jurisdiction shall have exclusive original criminal and other jurisdiction as described in this section for all matters filed by a contracting city. RCW 3.50.020 (2008).

    ~ the authority ofthe municipal court is directly limited by the Washington

    legislature to violations of the city ordinances, which by definition may only be violated

    within thejurisdictional boundaries of the municipality. Ifa city has not adopted a state

    statute, it lacks the independent authority to prosecute crimes under that statute: "The

    City may not enforce a state law without having first adopted the state law by reference

    or having adopted a compatible ordinance." City ofAuburn v. Gauntt, 174 Wn.2d 321,

    323,274 P.3d 1033 (2012).

    The City ofChewelah has adopted state misdemeanors as follows: "Titles 9 and

    9A ofthe Revised Code ofWashington and all laws enacted which may add to or

    supersede said titles are adopted as the criminal code of the city subject to the restriction

    that only those crimes which fall within the jurisdiction of the District Court of Stevens

    County for the city shall actually be tried by said court." Chewelah, Washington,

    MOTlON AND MEMORANDUM TO SUPPRESS 3 GOLDEN LAW OFFICE P.LLC. AND TO DISMISS COUNT 1 298 S. Main, Ste. 203

    Colville, WA 99114 509-684-6322

    Fax 509-684-3286

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    Municipal Code, 9.04.010. The municipal code also defines the jurisdiction for the city

    as ''the area within the territorial limits of the city of Chewel~ Washington." Chewel~

    Washington, Municipal Code, 1.04.010(A).

    Thus, the City could prosecute for violations ofTitle 9 and Title 9A RCW that

    occurred within its territorial boundaries. However, by law and statute, the City lacks the

    authority to prosecute ordinances and misdemeanors outside the territorial limits of the

    city ofChewelah. Per the testimony at hearing on April 9, 2015, ofOfficer Bowers, he

    did not become aware of the illegal conduct for which he stopped the Defendant until he

    was already past the city limits; he initiated the traffic stop beyond the territorial limits of

    the City ofChewel~and concluded the traffic stop and made the arrest beyond the

    territorial limits ofthe City ofChewelah.

    Even ifOfficer Bowers had the authority to act, the City ofChewelah still lacks

    the authority to prosecute misdemeanors that occur outside the territorial limits of the

    City ofChewelah. Further, the municipal court lacks jurisdiction to hear a case beyond

    those same bounds. The municipal court is created and defined by statute; its limits and

    constraints are defined by the ordinances of the City. The law limits the scope of the

    City's power to its borders. There is no evidence of any criminal activity within the

    City's statutory authority to prosecute; this failure ofevidence places this case finnly

    outside the bounds of the municipal court's jurisdiction to hear and the City's power to

    act. Therefore, the case against the Defendant must be dismissed for want ofjurisdiction.

    RELIEF REQUESTED

    . Based on the foregoing, the Defendant respectfully requests that the Court enter an order

    ofdismissal. MOTION AND MEMORAIlIOUM TO SUPPRESS AND TO DISMISS COUNT 1

    4 GOLDEN LAW OFFICE P.LLC. 298 S. Main, Ste. 203 Colville, WA 99114

    5Q9..684..a322 Fax 509-684-3286

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    DATED this J!i day of11-- 4~ ,2015.

    Tereno, WSBA# 43245 Defendant

    MOTION AND MEMORANDUM TO SUPPRESS 5 GOLDEN LAW OFFICE P.LLC. . AND TO DISMISS COUNT 1 298 S. Main, Ste. 203

    CoMIIe, WA 99114 509-084-6322

    Fax 509-684-3286

  • Exhibit 5

    Order for dismissal of cases

    No. 5Z0133878 &

    No 5Z0133879

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    FILED IN THE DISTRICT COURT OF THE STATE OF WASHINGTON APR 1 6 2015

    DISTRICT COURT IN AND FOR THE COUNTY OF STEVENS STEVENS COUNTY, WA

    No.5Z0133878 Plaintiff,

    IZJ CITY/TOWN OF CHEWELAH MOTION AND ORDER

    ~ DISMISSING CHARGE(S) vs. [Z] DISMISSING 3.2 CONDITIONS ,

    o DISMISSING DV NO-CONTACT ORDER o DISMISSING AH NO-CONTACT ORDER

    CONNIE LARUE, a/k/a Connie LaRue o EXONERATING OF BAIL Defendant o DISMISSING DEFERRED SENTENCE

    o DISMISSING DEFERRED PROSECUTION The [gJ Plaintiff 0 Defendant 0 Court moved for and the court finds good cause to

    IZJ Dismiss the Charge(s) of Refusal to Give Information to or Cooperate with Officer [gJ Dismiss the Conditions of release set forth in the Rule 3.2 Hearing Order D Dismiss the Domestic Violence No-Contact Order D Dismiss the Anti-harassment No-Contact Order D Exonerate the Bail posted D Dismiss the Deferred Sentence ..J .. ) :.' D Dismiss the Deferred Prosecution . .

    For the following reason(s): Pending Further ReVIew and Determination RE: Venue/Jurisdiction

    NOW, THEREFORE, IT IS ORDERED that: [gJ The charge(s) are dismissed D with prejudice ~ without prejudice IZJ All conditions of release entered in the Rule 3.2 Hearing Order, and any modifications or

    supplements thereto, are hereby dismissed. o The Domestic Violence No-Contact Order is hereby dismissed o The Anti-Harassment No-Contact Order is hereby dismissed o Any bail/bond posted herein shaJ.1 be exonerated. o The finding of guilt is withdrawn and the cause is dismissed with prejudice. D The deferred prosecution herein is terminated and the charge(s) of _ = against the Defendant is dismissed with prejudice

    D The Defendant forfeits any property interests in any evidence seized. DATED this \G~ day of April, 2015.

    . ; I ..l . / DefendantlDefe'ndant's Attorney

    STEVENS COUNTY PROSECUTING ATTORNEY 215 S. Oak Street, Room 114

    Colville, WA 99114 (509) 684-7500 fax (509) 684-7589

    Reviewedc:nd"A

  • --------------

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    IN THE DISTRlCT COURT OF THE STATE OF WASHINGT~~R. J 6 2015 TN AND FOR THE COUNTY OF STEVENS ;'" DI~,! /--:ICT COURT

    STEVEN;:; COUNTY, WA No. 520133879

    Plaintiff, cg] CITY/TOWN OF CHEWELAH

    MOTION AND ORDER ~ DISMISSING CHARGE(S)

    vs. o DISMISSING 3.2 CONDITIONS o DISMISSING DV NO-CONTACT ORDER o DISMISSING AH NO-CONTACT ORDER

    CONNIE LARUE, a/k/a Connie LaRue D EXONERATING OF BAIL Defendant D DISMISSING DEFERRED SENTENCE

    D DISMISSING DEFERRED PROSECUTION The ~ Plaintiff 0 Defendant D Court moved for and the court finds good cause to

    k8J Dismiss the Charge(s) of Failure to Yield Right of Way to an Authorized Emergency Vehicle and Failure to Renew Expired Vehicle License Less than two (2) Months Old

    o Dismiss the Conditions of release set forth in the Rule 3.2 Hearing Order o Dismiss the Domestic Violence No-Contact Order o Dismiss the Anti-harassment No-Contact Order o Exonerate the Bail posted

    D Dismiss the Deferred Sentence D Dismiss the Deferred Prosecution . .

    For the following reason(s): Pending FurtherReview and Determination RE: Venue/Jurisdiction

    NOW, THEREFORE, IT IS ORDERED that: [gJ The charge(s) are dismissed D with prejudice k8J without prejudice 0 All conditions ofreJease entered in the Rule 3.2 Hearing Order, and any modifications or

    supplements thereto, are hereby dismissed. D The Domestic Violence No-Contact Order is hereby dismissed D The Anti-Harassment No-Contact Order is hereby dismissed o Any baillbond posted herein shaJJbe exonerated. o The finding of guilt is withdrawn and the cause is dismissed with prejudice.D The deferred prosecution herein is terminated and the charge(s) of= against the Defendant is dismissed with prejudice o The Defendant forfeits any property interests in any evidence seized. DATED this l~-t' day of April, 2015. . ~O

    Judge/~ !pr-a-\cff\

    # 44789

    Reviewed and Approved br//7 (. ./ ~ ZG/ZEJ

    ant's Attorney Jessica L. Taylor, WSB 36248/ Deputy Prosecuting Attorney

    STEVENS COUNTY PROSECUTING ATTORNEY 215 S. Oak Street, Room 114

    Colville, WA 99114 (509) 684-7500 fax (509) 684-7589

  • Exhibit 6

    New Charge Notification of Infraction

    STATE OF WASHINGTON v. Connie LaRue, Case No. P7944

    using the same illegal police report to justify re-prosecuting LaRue to extort over $1062.

  • -------

    -------

    0RI COPy STEVENS COUNTY DISTRICT COURT GINAL FILED

    215 S OAK ROOM 213 MAY 0520'5 DfSTR ICOLVILLE, WA 99114 STEVEN fCT CaUR

    BUSN: 509-684-5249 FAX: 509-684-7571 TTY: 800-833-6388 I S COUNTY, "c"4

    NOTIFICATION OF INFRACTION Date Mailed: 4/24/2015

    Name/Address NAY 0 t~ ?n- rCase No.: P7944 I v ._'J:]Connie LaRue 1045 Kitt Narcisse Rd Amount Due: $1,062.00 . STEVENS CCJUNTY

    'JHOr'>Er'lJT' ' -'Date Due: 5/9/2015 i ,. ::-> oJ. hG .6,'IORrJE'(Colville, WA 99114

    A notice of traffic infraction has been issued to you by a law enforcement officer and filed with this court.

    To respond you must check one of the boxes below, sign your name, and return this form to the ,court by 5/9/2015

    1. 0 I choose to pay the penalty and have enclosed full payment in the amount of $ 1,062.00

    2. 0 J request a hearing to explain the circumstances. If you agree that you committed the infraction but would like to explain the circumstances, the court will notify you, in writing, of the hearing date. You may not require witnesses to appear at the hearing, but they may attend voluntarily.

    3. 0 I request a hearing to contest this infraction. If you believe you did not commit the infraction, you may request a hearing, At the hearing, the state/city must prove by a preponderance of the evidence (more likely than not) that you committed the infraction. You may require witnesses, including the officer who issued the notice, to appear at this hearing. The court will notify you, in writing, of the,bearing date and how to request that t"'itnesses be present. ' \. (' ~. 'Sa ~ No:t:1.tL cA In.\e\.\ .\0 J\.pr'.M ~ -\-k was\.\;I-.~teN\. S~le.:rt\.e c.o~ -\u( a If you do not respond by 5/9/2015 , the court m\ist add an additional penalty of $52.00 to the original ! bail. In addition, your driving priviledge may be suspended until you have paid all the penalties ~equired ~ bylaw. ~'i~~()"""' l0".~ ,,~ WO~tA-tO"V\.J~~~ ot~ ~h.e~ 0.-a~

    , D"'I'ae.~ Rt-ul 1- \ \., .~

  • Exhibit 7

    WASHINGTON DEPARTMENT OF LICENSING

    NOTICE OF SUSPENSION

  • STATE OF WASHINGTON

    DEPARTMENT OF LICENSING PO Box 9030. Olympia, Washington 98501-9030

    06/09/2015 Notice of Suspension CERTIFIED

    ABFf LA RUE,CONNIE 1045 KilT NARCISSE RD COLVILLE WA 99114-9711 . Lie. # LARUEC*527LO

    On 07/24/2015 at 12:01 a.m. we will suspend your driving privilege because you failed to respond, appear, pay, or comply with the terms of the citation below:

    Citation number Violation date Reason for Citation P00007944 02/0212015 Fail To Yield-Emgy Veh

    What do I have to do? 1. Use the contact information below to find out how to take care of this citation:

    Stevens Co Dist Ct District Court 215 SOUTH OAK Colville WA 99114-2861 (509)684-524.9

    2. Don't wait until the last minute. We must receive and process proof that this citation has been resolved prior to your suspension date. Processing can take 7-10 business days from the date we receive it. Ask the court to notify us as soon as this matter is resolved.

    Will DOL notify my state of record? Washington State will notify your state licensing department about this Washington suspension. It is your responsibility to check with your state of record.

    What happens if I don't resolve it? Your driving privilege will be suspended and any Washington driver license or permit, including occupational (ORL) or ignition interlock licenses (IlL), will not be valid. Your license must be returned to Department of Licensing, PO Box 9030, Olympia, WA 98507-9030. You will be charged a nonrefundable reissue fee, along with other applicable fees, to get your license back.

    What other options are available? You can contest this action by returning the enclosed form or a written request postmarked within 15 days from the date of this notice.

    We suggest that you always check the status of your driving privilege before you drive. Find out more at www.dol.wa.gov or by calling Customer Service at 360-902-3900.

    Driver Records Authority: RCW 46.20.289

    The Department a/Licensing certifies that this document was mailed via US post office on 0610912015 to the person named herein at the address shown, which is the last address a/record with the Department.

    We are committed to providing equal access to our services. Ifyou need accommodation, please call 360-902-3900 or TTY 360-664-0116.

    52987085

  • Exhibit 8

    WASHINGTON DEPARTMENT OF LICENSING

    DELINQUENCY NOTICE

  • 414785

    STEVENS COUNTY DISTRICT CO 215 S OAK ROOM 213

    509-684-5249COLVILLE WA 99114

    JuneS 2015

    RE, FAIL TO YIELD TO EMERGENC CONNIE LARUE Case Number: P00007944 SCS IT 1045 Kitt Narcisse Rd Violation Date: 06-05- 15 Colville WA 99114-9711 Balance Due: $ I I 14.00

    DELINQUENCY NOTICE

    YOU MUST PAY IN FULL WITHIN 30 DAYS OF MAILING.

    Your account balance is past due and needs your immediate attention. Ifpayment in full is not received within 30 days, your account will be assigned to Armada Corp. and may be reported on your credit bureau files. In addition, a collection fee will be assessed pursuant to the provisions ofRCW 19.16.500. Depending on your balance, the additional costs may range from 40% to 100% of the current amount due.

    Please remit the full amount owing. Ifyou have any questions regarding your balance you may call 509-684-5249.

    It is suggested that you pay with cashier's check or money order as payment by personal check may cause delays in processing/resolution of this account. Do not send cash.

    USTED DEBE DE PAGAR LA DEUDA ENTERA DENTRO DE 30 DIAS DEPUES DE QUE RECIBAN ESTA CARTA.

    Su saldo de cuenta esta sobre pasada y necesita su atenci n inmediata. Si el pago no es recibido dentro de 30 d as, su cuenta ser asignada a Armada Corp. Y puedemos informales a sus archivos de la oficina del cr dito. Adem s, un honorario de colecci n sera argregara de acuerdo con la ley de RCW 19.16.500. Dependiendo con su balance, los costos adicionales pueden recorrer de 40% a 100% de la cantidad actual debida.

    Remita por favor la cantidad que debe. Nota: Si usted ya tiene un plan de pagos en existencia este nueva multa NO es incluida. Si usted tiene cualquier pregunta sobre su cuenta 0 sobre su balance por favor de llamar al 509-684-5249. Gracias.

    Se Ie sugiere que page por cheque bancario 0 money order por la razon que cheques personales pueden causar retrasos sobre el procesos y resolucion en su cuenta. Por favor no manden dinero en efectivo por coreo.

    427-HWARMA01-252-1/06/10

    *** Please detach the lower portion and return with your payment -k*,.

    Y18C5FBCD8

    111111111111 11111111111 11111111111111111111 ""1111111111111 PO Box 505 Linden MI 48451-0505 ADDRESS SERVICE REQUESTED

    Case #: Balance Due:

    P00007944 SCS IT $1114.00

    June 5 2015

    II, ,'II I, I' 11'1 II 111 11 I' 'II II II'" I II II, 'I 'II, I', ,"I" 111111 0008120024016525855799114971145-1YA1-Y18C5FBC08427 252 - 427

    STEVENS COUNTY DISTRICT COCONNIE LARUE 215 S OAK ROOM 213 1045 Kitt Narcisse Rd COLVILLE WA 99114Colville WA 991 14-9711

  • u.s. Postal ServiceTM . CERTIFIED MAILM RECEIPT Domestic Mail Only; No Insurance Coverage Provided)

    Postage $ I--------j

    Certified Fee r-"l CJ Retum Receipt Fee CJ (Endorsement Required) o Restrtcted Delivery Fee 1---1Iilr--i CJ (Endorsement Required) 1----~/7\----j o U1 Total Postaoe & Fe,,-~

  • 7/10/2015 USPS.com - USPS Tracking

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    Postal Product:

    First-Class Mail Certified Mail

    Features:

    Product & Tracking Information

    DATE & TIME STATUS OF ITEM LOCATION

    July 6, 2015 , 8:01 am Delivered OLYMPIA, WA 98504

    Your item was delivered at 8:01 am on July 6, 2015 in OLYMPIA, WA 98504.

    July 3, 2015 , 6:43 am Business Closed OLYMPIA, WA 98504

    July 3, 2015 , 6:29 am Arrived at Unit OLYMPIA, WA 98501

    July 2, 2015 , 9:32 am Available for Pickup OLYMPIA, WA 98501

    July 2, 2015 , 9:22 am Sorting Complete OLYMPIA, WA 98501

    July 2, 2015 , 2:13 amArrived at USPS OriginFacility

    TACOMA, WA 98413

    July 1, 2015 , 4:16 am Departed USPS Facility SPOKANE, WA 99224

    June 30, 2015 , 8:23 pmArrived at USPS OriginFacility

    SPOKANE, WA 99224

    June 30, 2015 , 5:31 pm Departed Post Office CHEWELAH, WA 99109

    June 30, 2015 , 10:43 am Acceptance CHEWELAH, WA 99109

    Available Actions

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    Tracking Number: 70113500000186255585

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  • r"'1 o ~ o o L.rl rn r"'1

    ~ '-'

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    USE Postage $

    ~-----.......j 0709 08 Postmar1<

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    Retum Receipt Fee (Endorsement Required) ~--ti-+l....--.......j Here Restricted Delivery Fee

    (Endorsement Required) f---,.........,."..--1 07/1312015Total Pocl

  • 7/15/2015 USPS.com - USPS Tracking

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    Postal Product:

    Priority Mail 2-Day Certified Mail Up to $50 insurance includedRestrictions Apply

    Features:

    Product & Tracking Information

    DATE & TIME STATUS OF ITEM LOCATION

    July 15, 2015 , 10:07 am Delivered SEATTLE, WA 98101

    Your item was delivered at 10:07 am on July 15, 2015 in SEATTLE, WA 98101.

    July 15, 2015 , 8:57 am Out for Delivery SEATTLE, WA 98101

    July 15, 2015 , 8:47 am Sorting Complete SEATTLE, WA 98101

    July 15, 2015 , 4:08 am Arrived at Unit SEATTLE, WA 98101

    July 14, 2015 , 8:56 pmDeparted USPS OriginFacility

    FEDERAL WAY, WA 98003

    July 14, 2015 , 8:17 pmArrived at USPS OriginFacility

    FEDERAL WAY, WA 98003

    July 14, 2015 , 4:19 am Departed USPS Facility SPOKANE, WA 99224

    July 13, 2015 , 7:02 pmArrived at USPS OriginFacility

    SPOKANE, WA 99224

    July 13, 2015 , 5:48 pm Departed Post Office CHEWELAH, WA 99109

    July 13, 2015 , 10:13 am Acceptance CHEWELAH, WA 99109

    Available Actions

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    Tracking Number: 70113500000186255639

    On TimeExpected Delivery Day: Wednesday, July 15, 2015

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