Professional Documents
Culture Documents
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7 for two weeks, and I am covering in her absence. On July 6th, Cindy sent me an email which
8 included the current service distribution list. I opened the service distribution list, clicked
9 Save and Closed and assumed it saved into my contacts because when I went back into my
10 contacts, there was a WSDOT service distribution list and that was the list that I used to serve
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the parties on July 12th. What I did not realize is that I had an old distribution list in my
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contacts with nearly the same name. The only difference was that the distribution list Cindy
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sent me was titled *WSDOT STP Great Lakes Global Service List (Thurston and
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15 King) Updated 5-8-17 and the old distribution list previously saved in my contacts was
16 titled *WSDOT STP Great Lakes Global Service List (Thurston and King)
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22 This is a screenshot of the distribution list I received in the above email which reflects that it
23 is read only.
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9 3. I did not realize until late in the day on July 12th was that the distribution list Cindy
10 forwarded to me was a read only list so it did not save to my contacts as I had thought it
11 had done. It was not until Ms. Dunningtons email at 4:30 p.m. that I realized the
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distribution list I thought I had saved to my contacts was not the most current, up-to-date
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service list and that I had not served all of the parties.
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4. I am making this declaration of my own free will to apologize to the Court and to the parties
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16 for my mistake. There was nothing intentional or willful in my actions, it was a simple
17 mistake where I thought I was using the most current service list.
18 I declare under penalty of perjury under the laws of the State of Washington that the
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foregoing is true and correct to the best of my knowledge and belief.
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DATED at Seattle, Washington this 13th day of July, 2017.
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Katie Dillon
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2 I hereby certify that on this day I caused a copy of the foregoing to be served upon the
following counsel of record:
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Daniel W. Galvin, WSBA #18334 ( ) By U. S. Mail
4 Assistant Attorney General (X) By E-mail agreement
Transportation and Public Construction ( ) By Facsimile
5 Division ( ) By Messenger
7141 Cleanwater Drive SW
6 PO Box 40113
Olympia WA 98504-0113
7 360-753-1626
danielg2@atg.wa.gov
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Karl F. Oles, WSBA #16401 ( ) By U. S. Mail
9 David R. Goodnight, WSBA #20286 (X) By E-mail agreement
Bart W. Reed, WSBA #45005 ( ) By Facsimile
10 Rachel L. Dunnington, WSBA #47021 ( ) By Messenger
Christopher N. Weiss, WSBA #14826
11 Stoel Rives LLP
600 University Street, Suite 3600
12 Seattle WA 98101
206-624-0900 (phone)
13 karl.oles@stoel.com
david.goodnight@stoel.com
14 bart.reed@stoel.com
rachel.dunnington@stoel.com
15 chris.weiss@stoel.com
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9 I declare under penalty of perjury under the laws of the state of Washington that the
foregoing is true and correct.
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DATED this 13th day of July, 2017.
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PACIFICA LAW GROUP LLP
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13 By s/ John Parnass
John Parnass, WSBA # 18582
14 1191 Second Avenue, Suite 2100
Seattle, WA 98101
15 Telephone: (206) 245-1700
john.parnass@pacificalawgroup.com
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