Amended Final Response

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

THE SUPERIOR COURT OF THE STATE OF WASHINGTON

IN AND FOR THE COUNTY OF PIERCE

US BANK NATIONAL ASSOCIATION, N.D., a national banking association

Plaintiff,

vs.

HEATHER A. TUCCI-JARRAF (fka. Heather Tucci) individually and her marital community, YOUSSEF JARRAF, individually and his marital community,; OCCUPANT/RESIDENTS

Defendants

CASE NO.: 10-2-11410-1

DEFENDANTS' AMENDED RESPONSE TO PLAINTIFF'S COMPLAINT FOR UNLAWFUL DETAINER

(CLERK’S ACTION REQUIRED)

TRIAL BY JURY DEMANDED

I. Introductory Certification

Plaintiff's named alleged Defendants, Heather A. Tucci-Jarraf and Youssef Jarraf,

hereinafter referred to as “Defendants” (for organizational purposes only and is not intended

and should not be relied upon as a statement of law, fact, acquiescence, or otherwise) comes

now before this Court, through their Attorney, Heather Ann Tucci-Jarraf, for peaceful

resolution of any and all matters claimed, alleged by Plaintiff in Plaintiff's Complaint

(Complaint) and Defendants hereby file their response, notwithstanding lack of jurisdiction,

DEFENDANTS AMENNDED RESPONSE Heather Ann Tucci-JarrafTO PLAINTIFF'S COMPLAINT - 1 Attorney at Law

8805 N. Harborview Dr., Suite 201 Gig Harbor, WA 98332

+253.509.4597 phone

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

supported by the Sworn Affidavits of Heather A. Tucci-Jarraf and Youssef Jarraf, filed

concurrently with this Response, attached herein as Exhibits A and B, respectively, and

incorporated herein as if set forth in full.:

I. PLAINTIFF'S NAMED PARTIES

Plaintiff U.S. Bank National Association N.D. (“Plaintiff”), is the party that filed a Complaint in

Pierce County Superior Court.

Defendants, Heather Ann Tucci-Jarraf and Youssef Jarraf, were named by the Plaintiff as

Defendants.

II. PLAIN STATEMENT OF FACTS AND LAW

A. The following “Negative Averments and Conditions Precedent” AND all sections and

subsections hereafter, are based on the Sworn Affidavits of Defendants, Heather Ann Tucci-

Jarraf and Youssef Jarraf (“Sworn Affidavits”), filed concurrently and incorporated herein as

if set forth in full, whereas said Affiants have personal knowledge of the alleged transaction,

and any and all underlying relevant documents, executed and/or not executed, including but

not limited to, an alleged credit agreement with U.S. Bank hereinafter “Agreement”,

applicable Washington Statutes, and relevant case law.

B. For and on the record, Defendants herewith provide open and notorious notice to all,

sundry, and to whom it may concern that Defendants are not aware of any documentary

material evidence established on the record of this instant matter by competent witness under

affidavit notarized true, correct, and complete verifying and validating with completeness

and particularity in law and fact proof of claim that any of the following negatively averred

(denied as existing until proven to exist) items is untrue, non-existent, unethical, frivolous,

argument, or in any manner invalid, and requires as conditions precedent, hereinafter

“Conditions Precedent,” for any cause of action whatsoever to be legitimately heard and



+253.509.4597 phone

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

entertained re this instant matter, the setting into evidence as non-exculpatory, non-hearsay

evidence by competent witness in form fully compliant with all provisions of the Revised

Codes of Washington and Washington Rules of Evidence ER 601, 602, 603, 802, 901, 902,

904, 1002, proof of claim of invalidation of all of the following matters, which, without said

proof of claim, are unconditionally stipulated by all parties whatsoever involved in this

instant matter, hereinafter “Involved Parties,” as the truth and judgment of the law re this

instant matter, whereby it is herewith affirmed that:

1) RCW 5.40.010, of Evidence Title 5 RCW, declares that pleadings sworn to by either

party in any case shall not be deemed proof of the facts alleged therein, nor require other

or greater proof on the part of the adverse party.

2) A court may not assume the truth of allegations in a pleading which are contradicted by

affidavit. Data Disc, Inc. v. Systems Tech Assoc., Inc., 557 F.2d 1280 (9th Cir. 1977).

3) Plaintiff has the burden to establish jurisdiction. KVOS, Inc. v. Associated Press, 299

U.S. 269, 278, 57 S.Ct. 197, 81 L.Ed. 183 (1936).

4) A Plaintiff's obligation to provide the grounds of his entitlement to relief requires more

than labels and conclusions and factual allegations must be enough to raise a right to

relief above the speculative level. Bell Atlantic Corp. v. Twombly, 550 U.S. 544, at 554

(2007).

5) RCW 59.12.032 requires that “[a]n unlawful detainer action, commenced as a result of a

trustee's sale under chapter 61.24 RCW, must comply with the requirements of RCW

61.24.040 and 61.24.060.”. See RCW 59.12.032. Defendants do not understand how

Plaintiff could have complied with RCW 61.24.060 and 61.24.040, and absent Plaintiff's

prior absolute proof, subject to authentication and admissibility under the Washington

Rules of Evidence, Plaintiff has not complied with RCW 61.24.060 and 61.24.040. See

Sworn Affidavits.

(a) Defendants reassert 1-4 herein as if set forth in full.



+253.509.4597 phone

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

(b) RCW 61.24.060(2) states that a “Purchaser” shall provide written notice to the

occupants and tenants at the property purchased in substantially the form provided in

RCW 61.24.060(2). If Plaintiff was a “Purchaser” then Plaintiff was required to send

said notice to Defendants. Plaintiff has not provided Defendants or this Court with

prior absolute proof that Plaintiff did comply with RCW 61.24.060a Notice of

Purchase as required by RCW 61.24.060(2). See Sworn Affidavits. If Plaintiff was a

“Purchaser”, then they failed to comply with RCW 61.24.060(2).

(c) Defendants do not understand how Plaintiff claims Plaintiff is a “Purchaser” pursuant

to RCW 61.24.070. Under RCW 61.24.070(2) a “beneficiary” may request the

trustee to credit the monetary obligations secured by the deed of trust toward the

beneficiary's bid at a trustee's sale.

1) On page 2, section 4(A), the deed of trust for the Property requires the specific

identification of the debt that is to be secured by said deed of trust. There is no

specific debt specifically, or otherwise, identified, although it explicitly states that

said identification is required to be made. See Sworn Affidavits.

2) Defendants do not understand what alleged monetary obligation the trustee

determined, if any, was secured by the deed of trust for Property when the alleged

debt was not specifically identified as required. See Sworn Affidavits.

3) Defendants do not understand how the trustee determined what alleged monetary

obligation, if any, was secured by the deed of trust, when the required

identification of the debt was not stated. See Sworn Affidavits.

4) Defendants do not understand why the trustee determined any alleged monetary

obligation was secured when the deed of trust for the Property did not specifically

identify the debt to be secured as required. See Sworn Affidavits.

5) Defendants do not understand how trustee could apply a credit of an alleged

monetary obligation secured by a deed of trust to Plaintiff's alleged bid, when the



+253.509.4597 phone

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

deed of trust for the Property was expressly void of the identification of a debt to

be secured by said deed. See Sworn Affidavits.

6) Plaintiff has not provided Defendants and/or this Court with Plaintiff's prior

absolute proof of claim of an alleged “debt” and/or “monetary obligation” that

Principle owes/did owe Plaintiff, with full authenticated, verified and verifiable

accounting pursuant to GAAP and FAS provided by a competent witness with

firsthand personal knowledge stated under a verifiable sworn and notarized

affidavit as true, correct, and complete with unlimited commercial liability, to

show an alleged debt that Plaintiff could request be applied towards a bid for the

purchase of the Property at trustee's sale, and that said alleged debt could lawfully

be applied as a credit for a bid pursuant to RCW 61.24.070, which upon said prior

absolute proof and successful bid at a trustee sale, would have otherwise rendered

the Plaintiff, it Plaintiff was a “beneficiary”, a “purchaser” under RCW 61.24.060,

entitled to summary proceedings under RCW59.12. See RCW 61.24.060, RCW

61.24.070(2), RCW 61.24.040, RCW 61.24.030, RCW 59.12.032 and Sworn

Affidavits.

7) Defendants do not understand how Plaintiff claims it was a “beneficiary” entitled

to request a credit under RCW 61.24.070(2). RCW 61.24.005 defines a

“beneficiary” as “the holder of the instrument or document evidencing the

obligations secured by the deed of trust...”. Plaintiff has not provided Defendants

or this Court with authentic documentary evidence of standing as a “Beneficiary”

as defined per RCW 61.24.005, in order to have standing to foreclose on Affiant's

Property, and/or request a trustee to credit an alleged obligation towards a bid

pursuant to RCW 61.24.070(2). Plaintiff has not provided Defendants, this Court

or otherwise entered into evidence the original wet-ink signature promissory note,

agreement, account contract, and/or instrument, if one exists, unaltered,

unendorsed, in pristine condition in which to invoke or enforce Plaintiff’s



+253.509.4597 phone

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

standing as a holder-in-due-course and any authority to claim a credit pursuant to

RCW 61.24.070(2), and thus be rendered a “Purchaser”. Even if the original

wet-ink signature promissory note, agreement, account contract, and/or

instrument, if one exists, unaltered, unendorsed, in pristine condition, it was not

specifically identified under Section 4(A) in the deed of trust for the Property, and

therefore would said alleged obligation would not have been secured by said

deed.

8) Plaintiff has not provided Affiant and/or this Court with Plaintiff's prior absolute

proof of claim as “beneficiary as purchaser” pursuant to the requisites of RCW

61.24.070(2), with full authenticated, verified and verifiable accounting pursuant

to Generally Accepted Accounting Principles (GAAP) and Federal Accounting

Standards (FAS) provided by a competent witness with firsthand personal

knowledge stated under a verifiable sworn and notarized affidavit as true, correct,

and complete with unlimited commercial liability, evidencing a debt and amount

available for credit available to be applied towards a bid for the purchase of the

Property at trustee's sale, and, therefore, showing Plaintiff is a “purchaser” under

RCW 61.24.060, entitled to summary proceedings under RCW59.12. See RCW

61.24.060, RCW 61.24.070(2), RCW 61.24.040, RCW 61.24.030, RCW

59.12.032 and Exhibits A and B. Therefore, Defendants do not understand how

Plaintiff is a “Purchaser” under RCW 61.24.070, and, thus, entitled to possession

of Defendants' Property, and/or summary proceedings provided by RCW 59.12

under RCW 61.24.060.

9) Defendants do reassert C(1)-(8), herein incorporated as if set forth in full, and

Defendants do not understand how trustee could have lawfully issued a Trustee's

Deed to Plaintiff, and absent Plaintiff's prior absolute proof as identified herein,

the trustee's deed was not lawfully executed and the trustee did wrongfully

convey, deliver, or otherwise issue a trustee's deed to Plaintiff.



+253.509.4597 phone

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28


Defendants do not understand how trustee could have lawfully filed a Notice of

Trustee's Sale, and absent Plaintiff's prior absolute proof as identified herein, the

Notice of Trustee's Sale was not lawfully executed and the trustee did wrongfully

convey, deliver, or otherwise issue a trustee's deed to Plaintiff.


Defendants do not understand how trustee could have found that the “power of

sale” clause was operable as required by RCW 61.24.030 in order for a trustee to

issue a Notice of Trustee's Sale, and absent Plaintiff's prior absolute proof as

identified herein, the foreclosure was not lawfully executed and the trustee did

wrongfully convey, deliver, or otherwise issue a trustee's deed to Plaintiff.

12) Defendants do reassert A-B and all there sub-parts, herein incorporated as if set

forth in full, and Defendants do not understand how trustee could have complied

with its duty of good faith as required by RCW 61.24.010(4), and absent

Plaintiff's prior absolute proof as identified herein, the Trustee did violate RCW

61.24.010(4) and the trustee did wrongfully convey, deliver, or otherwise issue a

trustee's deed to Plaintiff. Plaintiff has not provided Defendants and/or this Court

with a sworn affidavit, made by the Trustee, under the penalty of perjury, of

Trustee's prior absolute proof that Trustee did review the terms and conditions of

the Deed of Trust for the Property, Trustee's prior absolute proof that Trustee did

receive prior absolute proof from Plaintiff of the amount of alleged monetary

obligation that Principle allegedly owed Plaintiff, that said amount was secured by

the deed of trust for the Property, and that the trustee did comply with the statutes

of RCW 61.24 and the terms and conditions of the deed of trust for the Property,

and absent Plaintiff's prior absolute proof as required herein that Plaintiff did

make a loan to Principle, if any, and that the loan was secured by the deed of trust

for the Property as required by RCW 61.24.040 and RCW 61.24030, and lawfully



+253.509.4597 phone

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

credited pursuant to RCW 61.24.070, then said sworn affidavit would be prima

facie evidence of perjury and at the very least prima facie evidence that there are

triable genuine material facts at issue.

(d) Defendants do reassert A-B and all their sub parts, herein incorporated as if set forth

in full, and Defendants do not understand how trustee could have complied with

RCW 61.24 and the terms and conditions of the deed of trust for the Property in order

to lawfully be able to issue a trustee's deed, a notice of trustee's sale, and/or a notice

of default, and absent prior absolute proof as stated herein, trustee did not comply

with RCW 61.24 and the terms and conditions of the deed of trust for the Property

and, therefore, trustee would have violated Washington State, RCW 19.86, Consumer

Protection Act and The Fair Debt Collections Practices Act, RCW 19.16.

(e) Defendants do reassert A-B and all their sub parts, herein incorporated as if set forth

in full, and Defendants do not understand Plaintiff's claim that Plaintiff is entitled to

Defendants' Property.

(f) Defendants do reassert A-B and all their sub parts, herein incorporated as if set forth

in full, and Defendants do not understand Plaintiff's claim that Plaintiff was vested

with title to the Defendants' Property.

(g) Defendants do reassert A-B and all their sub parts, herein incorporated as if set forth

in full, and Defendants do not understand under what standing and authority Plaintiff

is bringing this cause of action.

(h) Defendants do reassert A-B and all their sub parts, herein incorporated as if set forth

in full, and Defendants do not understand under what factual claims and legal

authority Plaintiff is claiming this Court has jurisdiction over the subject matter

and/or Defendants, and absent Plaintiff's prior absolute proof or establishment of

factual and legal authority, the Court does not have jurisdiction over the subject

matter and/or Defendants.



+253.509.4597 phone

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

(i) Defendants do reassert A-B and all their sub parts, herein incorporated as if set forth

in full, and Defendants really do not understand under what authority Plaintiff is

claiming the Court has jurisdiction under RCW 59.18, as Defendants have never had

a lanlord-tenant relationship with Plaintiff, and absent the establishment of such legal

authority, the Court does not have jurisdiction pursuant to RCW 59.18.

(j) Defendants do reassert A-B and all their sub parts, herein incorporated as if set forth

in full, and Defendants do not understand under how Plaintiff could claim that it

complied with RCW 61.24.040 and 61.24.060, and said compliance is required by

RCW 59.12.032 in order to bring an unlawful detainer action that is a result of an

alleged trustee's sale.

6) Defendants do reassert A-B and all their sub parts, herein incorporated as if set forth in

full, and Defendants do not understand how Plaintiff can request this Court issue an order

that Defendants are “unlawfully detaining the Property”, absent Plaintiff's prior absolute

proof of standing as a “Purchaser”, right to claim possession and entitlement to the

summary proceedings provided by RCW 59.12 and that Plaintiff did comply with RCW

61.24.040 and 61.24.060, and as otherwise stated herein, the Court cannot lawfully

adjudge or otherwise issue an order that Defendants' are unlawfully detaining Defendants'

own Property.


full, and Defendants do not understand how Plaintiff can request this Court for damages

against the Defendant for anything, absent Plaintiff's prior absolute proof of standing as a

“Purchaser”, right to claim possession and entitlement to the summary proceedings

provided by RCW 59.12 and that Plaintiff did comply with RCW 61.24.040 and

61.24.060, and as otherwise stated herein, the Court cannot lawfully order and/or grant

damages against Defendants.


full, and Defendants do not understand how Plaintiff can request a writ of restitution for



+253.509.4597 phone

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

the Court to “return” the Defendants Property to Plaintiff, absent Plaintiff's prior absolute

proof of standing as a “Purchaser”, right to claim possession and entitlement to the

summary proceedings provided by RCW 59.12, as stated herein, the Court cannot

lawfully deliver Defendants' Property to Plaintiff.


full, and Defendants do not understand how Plaintiff can request attorneys fees and/or

any other relief in favor of Plaintiff and against Defendants, absent Plaintiff's prior

absolute proof of standing as a “Purchaser”, the Court cannot lawfully grant such a prayer

for relief.

10) Defendants do not understand what standing, factual and legal basis Plaintiff's cause of

action is based, and absent pleadings sufficiently explicit for Defendants to understand

the cause of action against them, Defendants cannot defend themselves.

11) When there are properly executed affidavits that are directly conflicting on material

points, it is not possible for a judge to weigh the affidavits in order to resolve disputed

issues. Data Disc, Inc. v. Systems Tech Assocs., Inc., 557 F.2d 1280 (9th Cir. 1977).

12) Plaintiff has “failed to state a claim upon which relief can be granted” in accordance with

RCW 61.24.005, 61.24.060, 59.12.032, and Washington Rules of Evidence, and

Washington State CR 12(b)(6). See Complaint, and Defendants' Exhibits A and B.

13) In the absence of Plaintiff's prior absolute proof of claim and creditor status, with full

verified and verifiable equitable accounting pursuant to GAAP and FAS provided by a

competent witness with firsthand personal knowledge of any alleged account stated under

a verifiable sworn and notarized affidavit as true, correct, and complete with unlimited

commercial liability, then this Affidavit and each and every point herein, stands

uncontested and thereby any and all alleged claims by Plaintiff in this matter are

inherently invalid and constitutes prima facie evidence of Plaintiff's bad faith, fraud,

attempted fraud, theft, and/or attempted theft of the assets that legally and lawfully

belong to Principal, which vitiates all interactions, claims, charges, contracts, and/or



+253.509.4597 phone

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

grounds for any cause of action against Defendant. See RCW 61.24.060, RCW

61.24.070(2), RCW 61.24.040, RCW 61.24.030, RCW 59.12.032 and Exhibits A and B.

14) Even if Plaintiff were to subsequently file with this Court an oath, affidavit, or other

sworn declarations, they are gratuitous at best at this juncture, insufficient to rebut each

point of Defendants' Sworn Affidavits and at the very least prima facie evidence that

triable genuine material facts are at issue exist for the determination of a jury. Not only

would such submissions by Plaintiff be insufficient to rebut the points in Defendants

Sworn Affidavits, but they may be prima facie evidence that Plaintiff was as a matter of

law and a matter of fact a third party debt collector in violation of Washington's Fair Debt

Collection Practices Act, RCW 19.16, in violation of The Washington Consumer

Protections Act, RCW 19.86, and possibly perjury.

15) Each and every act done by Plaintiff, its agents, and/or the trustee, if found by this Court

to have violated Washington law, would be separate and individual violations of The

Washington Consumer Protections Act, RCW 19.86.

16) Each and every act done by Plaintiff, its agents, and/or the trustee, if found to have

violated Washington law, would be separate and individual violations of Washington's

Fair Debt Collection Practices Act, RCW 19.16

17) There is no documentary evidence and authority that the Plaintiff, or any other moving

party making a claim, is not subject to 26 USC § 6065 or the Washington State legal

equivalent, that all evidence of liability must be verified under penalty of perjury or

testimonial oath, and evidence not so verified is excludable under the Washington State

Hearsay Rules, or under other applicable Washington State laws and/or exemptions. See

RCW 61.24.060, RCW 61.24.070(2), RCW 61.24.040, RCW 61.24.030, RCW 59.12.032

and Sworn Affidavits.



+253.509.4597 phone

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

III. PRAYER FOR RELIEF

WHEREFORE, Defendants pray for the following relief

A. Plaintiff has failed to prove standing by absence of filing prior absolute proof to

the Defendants and/or this Court that Plaintiff is/was a lawful purchaser of the

Property at a trustee's sale who is entitled to the summary proceedings provided

by RCW 59.12, under RCW 61.24.060(1), that it complied with RCW 61.24.040,

and 61.24.060, thus not meeting the requirement of RCW 59.12.032 in order to

bring forth a complaint for unlawful detainer, which would otherwise give this

Court jurisdiction over the matter and/or Defendants. THERFORE, this Court

should find and declare by written order as a matter of law, matter of fact,

and/or matter of public policy, and absent Plaintiff's prior absolute proof as

required to contest each point of Defendants' Sworn Affidavit, that: 1.) that

Plaintiff Bank is/was not a lawful purchaser of Property at trustee's sale, and thus

not entitled to the summary proceedings provided by RCW 59.12 under RCW

61.24.060 and dismiss this case for lack of standing; 2.) that Plaintiff did not

comply with RCW 61.24.040 and 61.24.060; 3.) No lawful mortgage existed

between Defendants and Plaintiff; 4.) Defendants have/had no legal obligations

and/or debts owing to Plaintiff regarding Property by absence of Plaintiff's prior

absolute proof of claim and creditor status, with full verified and verifiable

accounting pursuant to GAAP provided by a competent witness with firsthand

personal knowledge stated under a verifiable sworn and notarized affidavit as

true, correct, and complete with unlimited commercial liability; 6.) The deed of

trust for Property, is invalid, from its inception, as a matter of law; 7.) that

Defendants did not/does not have a debt and or other obligation owning to

Plaintiff that was secured by the deed of trust for the Property; 8.) that, absent

proof that a loan existed pursuant to GAAP, Defendants did not default on any



+253.509.4597 phone

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

alleged obligations and/or debts to Plaintiff; 9.) The foreclosure of Property,

was/is improper and/or illegal and therefore null and void and/or reversed; 10.)

any trustee's sale done by Trustee conveying the Property to Plaintiff, was/is

improper and/or illegal and therefore null and void and/or reversed; 11.) any

Trustee's Deed, made by Trustee conveying the Property to Plaintiff, was/is

improper and/or illegal and therefore null and void and/or reversed; 12.)

Defendants are the lawful owner of Property; and/or 13.) Plaintiff has no standing

and/or valid claim of interest and/or right to possession of Defendants' Property.

B. Furthermore, Defendants request a judgment for Plaintiff to pay all Defendant's

attorney's fees and costs for responding and/or court appearances in this action.

C. For such other relief as the Court deems reasonable and just.

D. For sanctions order and adjudged against Plaintiff under CR 11, and/or as this

Court may deem proper

CLARIFICATIONS

Headings are only for organizational purposes and are not intended, and should not be

relied upon as law, fact, defenses, assertions, and/or allegations made by Defendants,

through their attorney.

DEMAND FOR JURY TRIAL

In the instance where there are disputed matters of fact at issue, Plaintiffs demand trial by

jury of all matters so triable as a matter of right pursuant to CR 39.



+253.509.4597 phone

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

VERIFICATION

Defendants, represented by their Attorney, Heather Ann Tucci-Jarraf, have read the foregoing

response and knows the contents thereof.

Dated: For and on behalf of Plaintiff's named alleged

Defendants identified above.

_________________________

Heather A. Tucci-Jarraf

Attorney at Law,

WSBA # 30281

8805 N. Harborview Dr., Suite 201

Gig Harbor, WA 98332

+253.509.4597 phone



+253.509.4597 phone

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Acknowledgment

State of Washington )

) ss

County of Pierce )

On _______________, before me, ____________________________, notary public in and for

Pierce County, State of Washington, personally appeared Heather Ann Tucci-Jarraf, who proved to

me on the basis of satisfactory evidence to be the party whose name is subscribed to the within

instrument and acknowledges to me that Heather Ann Tucci-Jarraf, set forth the contents hereof in

authorized capacity, and that by signing the instrument Heather Ann Tucci-Jarraf, hereby executes

the instrument.

I certify under penalty of perjury under the laws of the State of Washington that the foregoing

paragraph is true and correct.

Witness my hand and official seal: NOTARY PUBLIC SEAL

____________________________________

NOTARY PUBLIC SIGNATURE

My commission expires ________________



+253.509.4597 phone

Amended Final Response

Documents

Transcript of Amended Final Response