100187-8 Petition for Review.pdf - Washington State Courts

NO. -------

FILED

SUPREME COURT

STATE OF WASHINGTON

9/8/2021

BY ERIN L. LENNON

CLERK

IN THE SUPREME COURT OF THE STATE OF WASHINGTON

(Division III Court of Appeals Cause Number 376699)

PATRICIA N. STRAND

Petitioner v.

SPOKANE COUNTY AND SPOKANE COUNTY ASSESSOR

Respondents

MOTION FOR DISCRETIONARY REVIEW

Patricia Strand, Pro Se [email protected]

PO Box 312 Nine Mile Falls, WA 99026

(509) 467-0729

100187-8

Treated as a PETITION FOR REVIEW

TABLE OF CONTENTS

A. Identities of Parties .......................................................................... 1

B. Decisions .......................................................................................... 1

C. Issues Presented for Review ............................................................ 2

D. Statement of the Case ....................................................................... 3

E. Argument Why Review Should Be Accepted ............................... 12

F. Relief Requested ............................................................................ 20

APPENDIX

Attachment 1: Decisions for Review .................................................... 1-42

Attachment 2: Court of Appeals 376699 April 27, 2021 oral argument ............................................................... 43-62

Attachment 3: Reconciliation of Assessor Pages ................................ 63-64

Attachment 4: Assessor Cards on Neighborhood 231720 .................. 65-69

Attachment 5: Cards with sales ................................................................. 70

Attachment 6: Analysis of Five Cards For Manipulations CP 730-731 "Printed 02/21/2019" ............................... 71-82 CP 42-43 "Printed 04/25/2018" ................................... 83-97 CP 1043-1046 "Printed 03/15/2019" ......................... 98-103 CP 754-755 "Printed 03/07/2019" ........................... 104-106 CP 956-957 "Printed 03/15/2019" ........................... 107-109

Attachment 7: Portions of the Court Record by CP and RP numbers

Attachment 8: Law

Attachment 9: Commercial Sales

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TABLE OF AUTHORITIES

Boyer v. Morimoto, 10 Wn. App. 2d 506,449 P.3d 285 (2019) .... 29

Cofer v. County of Pierce, 8 Wn. App. 258,261, 505 P.2d 476 (1973) .... 10

Forbes v. City of Gold Bar, 171 Wn. App. 857,288 P.3d 384 (2012) ...... 18

Gipson v. Snohomish County, 194 Wn.2d 365,449 P.3d 1055 (2019) ....... 5

Neighborhood Alliance v. Spokane Co., 172 Wn.2d 702; 261 P.3d 119 (2011) ............................................................................................... 8

Rental Housing Assoc. v. City of Des Moines, 165 Wn.2d 525; 199 P.3d 393 at 399 (2009) ............................................................................. 4

Sahalee Country Club v. Bd. of Tax Appeals, 108 Wn.2d 26, 735 P.2d 1320 (1987) ....................................................................... 5

Sanders v. WA., 169 Wn.2d 827 and 864; 240 P.3d 120 (2010) ................. 6

Sargent v. Seattle Police Dep't, 167 Wn. App. 1,260 P.3d 1006 (2011) .... 5

State v. J.M., 144 Wn.2d 472,480, 28 P.3d 720 (2001) ............................ 16

State ex rel. Morgan v. Kinnear, 80 Wn.2d 400,402,405; 494P.2d 1362 (1972) ..................................................................... 17

Strand v. Spokane County Assessor, 876339, 313409 ............................... 5

Strand v. Spokane County, et al., 946442, 341909 ...................................... 5

Strand v. Spokane County, et al., 971897, 943133, 347222 ........................ 5

Strand v. State of WA. Board of Tax Appeals, et al., 97014-9, 355977 ...... 5

Strand v. Spokane County, et al., 982228, 365387 ..................................... 5

Strand v. State of WA. Board of Tax Appeals, et al., 366979 ..................... 5

West v. City of Tacoma, 12 Wn. App. 2d 45,456 P.3d 894 (2020) ...... 7, 18

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Constitutions

Washington Article 7 Section 1 ........................................................... 15, 17

Statutes

RCW 42.56 (PRA) ....................................................... 2-7, 9, 11, 13, 17, 19

RCW 42.56.080 ..................................................................................... 4, 13

RCW 42.56.520 ........................................................................................... 5

RCW 42.56.550 ........................................................................................... 8

RCW 84.40.020 ......................................................................................... 15

RCW 84.40.030 ......................................................... 2-4, 7, 9-10, 12, 16-17

RCW 84.48.150 ........................................................................................... 2

Codes

WAC 458-07-015 ....................................................................................... 14

RAP

RAP 18.1 .................................................................................................... 20

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A. IDENTITIES OF PARTIES

Petitioner, Patricia Strand (hereafter, "Strand"), asks this court to

accept review of the decisions designated in Part B of this motion. In

2000 Strand purchased real property parcel 17355.9014 in Spokane

County. Respondent is Spokane County, Spokane County Assessor and

agents (hereafter "Assessor").

B. DECISIONS

1. Spokane County Superior Court Order Granting Defendant's Motion

for Summary Judgment with prejudice, filed June 12, 2020.

2. Spokane County Superior Court Briefing Schedule Order and cover

letter ordering Strand's Reply Brief, dated June 16, 2020.

3. Spokane County Superior Court Amended Briefing Schedule Order

and cover letter ordering Strand's Reply Brief, dated June 24, 2020.

4. Spokane County Superior Court Order Denying Petitioner's Motion

for Reconsideration and ordering all pleadings filed after June 12,

2019 not be considered, dated July 20, 2020.

5. Court of Appeals III (hereafter, "COA'') Notation Ruling denying a

change of venue, dated February 23, 2021.

6. COA Unpublished Opinion: (1) affirming summary judgment with

prejudice; (2) denying Strand's Motion for additional evidence; (3)

denying review of all pleadings filed after June 15, 2021.

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7. COA Order Denying Strand's Motion for Reconsideration filed

August 5, 2021.

C. ISSUES PRESENTED FOR REVIEW

1. Since RCW 84.40.030 identifies the cost bases of l 7355.9014's

values as similar sales and factors 1 and itemizes what to value as:

(1) land, (2) structures and (3) total property; then is not the Assessor

required to produce pages2 identifiable as the similar-sales and

factors used for these three items in response to Strand's Public

Records Act (hereafter "PRA") requests for them? If the Assessor

produces no such pages, then is not the PRA violated and summary

judgment improper?

2. Is it not an abuse of judicial discretion for the courts not to review

Strand' s facts, law and evidence of 19 Assessor undisclosed

valuation factors (CP 267-275) and Chief Deputy Assessor

Hodgson's incredibility (CP 614-618; 629-657)? The courts

reviewed and ruled on Strand's facts, law and evidence of PRA

violations as insufficient; the Assessor's 636 pages of documents as

responsive and the Assessor's search as reasonable.

RCW 84.48.150(1) states produce factors and addresses of other properties used in making the determination of value versus 84.40.030 similar sales and factors. Factors are defined by facts of how value is determined and caselaw. 2 The Assessor alleged producing "636 pages ofresponsive documents". CP 709. Strand is conforming to this by replacing the word records with page and document.

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3. Is it not an abuse of judicial discretion for the COA to raise

arguments for the Assessor not raised by the Assessor and deny

Strand's additional evidence proving the Assessor's search

unreasonable since all effect summary judgment?

D. STATEMENT OF THE CASE

a. Assessor's Response to PRA Request

On February 20, 2019, Strand requested Assessor records showing

how 17355.9014 's 2018 assessment3 was detem1ined. CP 3 5. On the 21st

the Assessor produced a 17355.9014 property record card (hereafter,

"Card"). [Attachment 6 page 71--72]. On the 24111 Strand clarified her

request risking for the complete record of this Card: (1) the Pro Val

database the Assessor alleged was downloaded into the Card, (2) the bases

of the five years of assessments on the card, (3) Pro Val code sheets

explaining its specialized language, etc. CP 39-44.

From March 8-22nd the Assessor produced documents: (1)

Assessor's Answer to Real Property Petition & Valuation Information

(hereafter "Answer") and more Cards; (2) Excel spreadsheets, 2015-2018

Neighborhood Final Reviews (hereafter, "Report") and more cards; (3)

website refe1rnls to information; (4) Pages of allegations (CP 742, 1351,

RCW 84.40.030 uses valuation, assessment, appraisal as synonyms.

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1362-1363) about items (1) through (3). From February 24 through March

Strand notified the Assessor their documents were nonresponsive, their

allegations were false and; to connect their documents, allegations and

Strand's requests. This never happened. On April 4th the Assessor closed

Strand' s requests. On April 13, 2019, Strand filed a request with the

County Public Records Officer to review the Assessor's actions. This

response, on April 16th is a closure letter of less than 100 words without a

statement of a search, no names of other parties involved, no identification

of any process ofreview. CP 167.

b. Superior Court Review

Strand filed suit for violation of the PRA. The Complaint cites RCW

84.40.030(3) as identifying responsive records as similar sales and

valuation factors required to be provided Strand. The Assessor produced

one Card from February 20 to March 8, 2019. The Complaint has facts,

law and evidence that this Card produced on February 21st violated RCWs

42.56.520(1), 42.56.080(2) and 84.40.030(3). CP 7-14; CP 37-38.

This Card did not exist on the 20th- unable to be copied or inspected.

Hodgson: The property record cards is not a record that exists in the office. It has to be created. The property record card itself is a -is part of the canned software of Pro Val. And actually we haven't used that property record card all that much until Mrs. Strand's requests came. Not that we haven't used it, but it's something that has to be created. And it is basically date driven. ( emphasis added)

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Gipson v. Snohomish County, 194 Wn.2d 365, 449 P.3d 1055 (2019), An agency must only provide access to public records in existence at the time of the request. An agency is not obligated to supplement responses. Therefore, if a public record is created or comes into the possession of the agency after the request is received by the agency, it is not responsive to the request ...

Sargent v. Seattle Police Dep't, 167 Wn. App. 1,260 P.3d 1006 (2011), The purpose of the PRA is to provide full public access to existing, nonexempt record .... The PRA is a broad mandate for access to records that reveal the workings of government. Generally, public records are available for inspection and copying by anyone who wants to see them for any reason.

This Card has no similar sales nor factors on it. Its sales are of itself,

all are erroneous, all are over twenty years old. Real Estate Excise Tax

Affidavits are parts of this Card because the Assessor has known the

Transfer of Ownership section was erroneous since 2009. [Attachment 6

pages 79-81]. Strand repeats this fact in every proceeding4 because a

17355.9014 Card is the star of every Assessor defense. Spokane County

Archives has records of all these proceedings. Counsel for the County

have records of all these proceedings. Counsel for the County is the

Strand v. Spokane County Assessor, SC 876339, 313409-III, Spokane County Superior Court 122011103, BTA Docket 10-258

Strand v. Spokane County, et al., 132001238 Strand v. Spokane County, et al., SC 946442, 341909-III, Spokane County Superior

Court 142010791 Strand v. Spokane County, et al., SC 971897 and 943133, 347222-III, Spokane

County Superior Court 162010797 Strand v. State of WA. Board of Tax Appeals, et al., SC 97014-9, 355977-III,

Spokane County Superior Court 172014383, BTA Docket 13-179 Strand v. Spokane County, et al., SC 982228, 365387-III, Spokane County Superior

Comt 182039091 Strand v. State of WA. Board of Tax Appeals, et al., 366979-III, Spokane County

Superior Court 182402822, BT A Dockets 16-070 and 17-122

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Assessor's agent. On March 27th the Assessor alleged this Card had

detailed information of its value based on the cost approach. CP 1362.

This card does not have the word cost on it. There is nothing on it about

how its values were determined and where they came from.

This Card is incomplete. The Site Description is blank. It has

specialized language: "1 Fronts Enhancement #1", "Phys Depr", "Obsol

Depr", "% Comp", etc. The Assessor did not provide the records

explaining this language; language created by its Pro Val software. CP

327-330. Strand provided the Assessor the only two Pro Val code sheets

she has ever received from the Assessor. CP 162-163.

The PR ... A. requires the production of an entire record else it is

violated. Strand requested the entire record of the Card on February 24th.

CP 39-44. Strand was denied the entire record violating the PRA.

Rental Housing Assoc. v. City of Des Moines, 165 Wn.2d 525; 199 P.3d 393 (2009), ... Silent withholding would allow an agency to retain a record or portion without providing the required link to a specific exemption, and without providing the required explanation of how the exemption applies to the specific record withheld. The Public Records Act does not allow silent withholding of entire documents or records, any more than it allows silent editing of documents or records. Failure to reveal that some records have been withheld in their entirety gives requesters the misleading impression that all documents relevant to the request have been disclosed. Moreover, without a specific identification of each individual record withheld in its entirety, the reviewing court's ability to conduct the statutorily required de novo review is vitiated.

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The Assessor produced five kinds of documents: (1) 395 pages of

Cards, (2) 11 pages of an Answer, (3) 108 pages of Reports, (4) 13 pages

of Excel spreadsheets, (5) 10 pages of allegations - total 537 not 636.5

Strand's pleadings are facts, law and evidence of 537 nonresponsive

pages.

The Complaint included Thurston County basis of valuation

documents obtained under the PRA that conform to RCW 84.40.030(3).

CP 202-204. Their pages of similar sales and factors are on their website.

CP 303-304. Their documents have no obvious errors, omissions, and

specialized language making them incomprehensible.

Assessor's Summary Judgment

The Assessor's arguments for summary judgment are: (1) Strand

showed no PRA violation, (2) Strand requested unidentifiable records, (3)

Assessor produced 636 pages ofresponsive documents, (4) Assessor did a

reasonable search that produced all responsive documents, (5) these were

undisputed facts. CP 708-709. In oral argument the Assessor added the

(6) argument, they gave Strand everything they had. RP 5 and 26.

West v. City of Tacoma, 12 Wn. App. 2d 45,456 P.3d 894 (2020), The PRA requires an adequate search to properly disclose responsive documents. Neigh. All., 172 Wn.2d at 721. The lack of an adequate search prevents adequate response and production. Neigh. All., 172 Wn.2d at 721. Accordingly, because the PRA considers the failure to properly

Attachment 3 page 63; Attachment 4 pages 64-69

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respond as a violation, the failure to adequately search is also considered a violation.

To prove that its search was adequate, the agency may rely on reasonably detailed, nonconclusory affidavits from its employees submitted in good faith. Neigh. All., 172 Wn.2d at 721. The affidavits "should include the search terms and the type of search performed, and they should establish that all places likely to contain responsive materials were searched." Neigh. All., 172 Wn.2d at 721.

Strand's Other Briefings to Summary Judgment

Strand' s Response presented facts, law and evidence of 19

undisclosed Assessor valuation factors. CP 267-275, 327-330. These

documents are in the Spokane County Archives.4 The Court ignored

judicial review of these documents required under RCW 42.56.550(3) and

ignored them as disputed facts making summary judgment improper.

On June 6 for a June 12 hearing the Assessor filed a Reply and

another declaration. The declaration swore under penalty of perjury the

two Pro Val code sheets, CP 162-163, did not originate in the Assessor's

office. Strand's Supplemental Response was filed on the 12th. It

presented evidence that these documents originated with the declarer, Mr.

Hodgson. CP 523, 528-534. These documents also are in Strand's

proceedings4 and the Assessor never challenged them. CP 309 No. 12.3.

In the June 12th summary judgment hearing the Trial Court asked

Strand two questions about the Assessor's valuation practices in a motion

hearing initiated by the Assessor to dismiss finding out how they valued

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17355.9014. The Trial Court asked, "Let's say that the assessor didn't

follow other statutory criteria and . . . the value of the property basically

based on baseless information. Strand responded her PRA request was

based on RCW 84.40.030 that mandated the Assessor produce the similar

sales and factors used in the requested valuation. "A factor is what are

you going to do to determine value whether it's legal or not." The next

question was asked of Strand as a CPA. "Based on everything that

they've disclosed to you", what did Strand think they based valuation on.6

Question one implies the 19 valuation factors of the Assessor violating the

law shaped this question. Question two implies the Trial Court has no

idea how 17355.9014 was valued but he dismissed a case requiring that be

a settled issue. The Trial Court ruled for summary judgment.

Strand filed for reconsideration. It was ordered by the Trial Court in

Briefing Schedules. [Attachment 1 pages 3-8]. Strand's Reply complies

with that Order. The Reply includes evidence Mr. Hodgson created

records in response to Strand's PRA request and in a proceeding. CP 629-

657. This evidence proves Mr. Hodgson is not credible a basis for

reconsideration since the Assessor case is Mr. Hodgson's allegations.

Boyer v. Morimoto, 10 Wn. App. 2d 506, 449 P.3d 285 (2019), Some principles of summary Judgment encourage reversal of the superior court's summary judgment order. A summary judgment is a valuable procedure for

6 Brief of Appellant page 24

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ending sham claims and defenses. Cofer v. County of Pierce, 8 Wn. App. 258, 261, 505 P.2d 476 (1973). Nevertheless, the procedure may not encroach on a litigant's right to place her evidence before a jury of her peers. Cofer v. County of Pierce, 8 Wn. App. at 261. A reviewing court should reverse a summary judgment order when evidence supports the nonmoving party's allegations.

c. COA Review Opinion [Attachment 11

The COA made four decisions: (1) affirmed summary judgment, (2)

denied Strand's additional evidence and (3) denied consideration of

Strand's post June 12, 2020 pleadings, (4) denied reconsideration. COA

created arguments for the Assessor to support these decisions.

COA Affirmed Summary Judgment Because

RCW 84.40.030 does not apply to the Assessor [page 14] who does

not comply with this RCW. [page 27]. The Assessor creates valuation

basis records contemporaneous with appeals of the valuations [page 27].

Ms. Strand apparently believes the assessor has identifiable records reflecting a process in which staff researched other properties, selected some that were comparable to hers or identified other valuation criteria, and performed arithmetic in order to arrive at the 2018 assessed value of her property. But the record demonstrates that the assessor's annual valuations are generated by a computer assisted mass appraisal process that does not rely on this sort of staff work. [page 14].

As long as ratio studies indicate that an assessor's computer assisted mass appraisal process is performing well, it is reasonable to assume that the assessor will rely solely on that computerized process to generate annual assessed values .... While ratio studies can be evidence that an assessor's mass appraisal process is performing well, an assessor cannot rely on ratio studies or mass appraisal if a property owner challenges the assessed value of her property. By statute, if the assessed value is appealed, an assessor must defend the value produced by its mass appraisal process with an

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individual appraisal. When adequate market data (sales prices of similar property) is available, comparable sales is the most reliable of the three recognized valuation methods (market data, cost, and income capitalization). [page 27].

COA Affirmed Summary Judgment Because

The second declaration ... information on property record cards is data maintained in the Pro Val software, and while the data existed prior to Ms. Strand's request, it was only upon receipt of her request that the card was printed, in order to provide her with the preexisting data. [page 21].

The Assessor likely would have violated the PRA had it failed to print out property record cards containing the preexisting information that was responsive to Ms. Strand's record request. [Page 40].

COA Denied Strand's Additional Evidence Because

Strand's evidence is about one document, CP 163, a Floor Level

Designation. The Floor Level Designation was produced in 2020 because,

Her 2020 request asked the Assessor to produce (among other records) "all Assessor policies and procedures (mechanisms) used to determine values." [page 30].

But given the different scope of her February 2019 request (it did not seek manuals, policies or procedures), the mere fact that the manual and illustration were not searched for or located in Mr. Hodgson's search is not relevant to our review .... Ms. Strand does not demonstrate that additional proof of facts is needed to fairly resolve the issues on review, that additional evidence would probably change the decision being reviewed, or that it would be inequitable to decide the case solely on the evidence already taken in the trial court. [page 32].

COA Denied Strand's Post June 12, 2019 Pleadings Because

The court's order granting summary judgment stated, "[T]his matter is dismissed with prejudice." CP at 573. The materials filed by Ms. Strand thereafter that the court refused to consider were her supplemental response to the Assessor's summary judgment reply memorandum, a motion for an

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order requiring the Assessor to correct captioning on its pleadings, and a motion to dismiss the Assessor's summary judgment motion. [page 33].

d. COA Oral Argument [Attachment 2]

MS. STRAND: The problems -- the many problems with the Property Record Card are that there are a lot of errors in their templet because they are not printing out the data that is actually in the computer. There is no way to know when the errors that are in this templet were created. [Page 54]

I asked for what was in the computer. I specifically asked, just download your computer data about what you're alleging as how my value was determined.

When you put it in the fonnat of the Property Record Card, you are creating data which does not reflect what is, in fact, in your database.

WDGE SIDDOWAY: Well, do you actually think that someone at the County, like, manually inserted that information rather than pressing a button and having a computer software program generate a record?

MS. STRAND: Actually, I know for a fact that what you just said is true. I have two Property Record Cards created on the same day. One has an -- I'm sorry. One does not have an inspection date, and the issue was when the inspection occurred. The second card created on the same date has an inspection date. 7 So as to your question, yes, the Spokane County assessor does manipulate the data that they put on the card.

E. ARGUMENT WHY REVIEW SHOULD BE ACCEPTED

a. RCW 84.40.030 Mandates Disclosures

RCW 84.40.030 is the real property valuation law for 17355.9014

whether the Assessor violates it or the COA thinks violating it is fine.

That law is there to protect Strand. The protection specifically is Strand's

right to know how the numbers on the Official Valuation Notice were

7 The Cards with the different inspection reporting are CP 42-47; Attachment 6 page 85-87 is the analysis of the Card and No. 2 addresses the inspection date

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determined. In this case it is total property value and total land value

because the Cards show structures are total property less total land. 8

The Assessor is not credible; even page counts are wrong. They

alleged producing 636 pages of documents. They produced 537 pages.

The PRA is violated because none of the 395 pages of Cards existed

on its associated PRA request date. This violated RCW 42.56.080(2).

None of the Cards is complete because records to explain Cards' errors,

omissions and specialized language were silently withheld.

The most important Cards are for 17355.9014. Those Cards have

bad sales because of the bad preexisting data. This is proven because CP

317 was printed 04/03/2009 and the bad sales data is exactly the same as

CP 730 printed 02/21/2019. The COA did not define what preexisting

data is and this is the literal fact of it! The only way to prove Cards have

preexisting data is for the Assessor to produce the Pro Val database they

allegedly downloaded into CP 317 and CP 730 from 2009 to 2021. That

did not happen although Strand specifically requested this document.

The Assessor said Strand requested unidentifiable documents. But,

the Assessor said they produced 636 pages of responsive documents.

How did the Assessor define responsive without identifiable documents?

8 Analysis of CP 730-731 pages 71-82. Page 73 shows that Total Improvement Value is the net of total property values less Total Land Value. The card is a circular computation of Total Improvement Value.

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Strand requested the basis of 17355.9014 values from 2015 to 2019.

Strand analyzed the 395 pages of Cards to find their assessment year.

[Attachment 4 pages 65-69]. Only 61 of the 395 pages are Residential and

have assessment years. The other 334 pages are a combination of

Agricultural (50 pages) and Worksheets. Worksheet is that column to the

right on the Valuation Record. Attachment 6 page 104-106 are Strand's

Worksheet analysis that show on 106 the two pages of the Card do not

work together. This Card is not a circular computation like Cards with

assessment year computations and values. Worksheets are for the

Assessor to manipulate values.

The COA asked Strand this question during oral argument, is the

card data manipulated! Strand said yes and recited this example! WAC

458-07-015(4)(a) requires physical property inspections every six years

with appropriate documentation on the Card. Card CP 42-43 is

Attachment 6 pages 83-87 analysis. CP 42 has Strand's notes: pg 1 of 6,

received at 5:41 PM by email. CP 43 states the Assessor's inspection

"appropriate documentation" "Data Collector/Date - 102; 04/15/201 O".

CP-42 is evidence of no inspection in more than six years - Card "Printed

04/25/2018". The creation of this Card is now in the log; it cannot be

ignored. Assessor manipulation! CP 44-4 7 are created after changing the

"Data Collector/Date 119 12/10/2015" and the house. CP-42, -44, -46

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Appraisal Notes are exactly the same. Assessor Alert! The Appraisal

Notes show on 04/26/2016 (JS 119), Jay Sporn new Residential

Supervisor, changed the Assessor's house the diagram and values on

CP-43, -45, 47 - based on appeal photos taken in 2009. Why wouldn't

JSl 19 during his 12/10/2015 inspection write up the changing house?

He's in front of it. Strand's Motion for COA Reconsideration included

pages 83-85. The Cards' errors, omissions, specialized language, circular

computations, withholding of the entire record, etc. are all manipulations

to hide the Assessor's valuation process.

All of the Cards are nonresponsive because they do not disclose the

Assessor does not value sold property at 100% of its sale price. CP 292.

If sold property is not valued at 100% of its sale price, then no property

can be valued at 100% of any sale price? It violates Article 7 § 1 my

constitutional protection. Attachment 5 page 70 is the analysis of Cards

with sales and relevant assessments. None were valued at 100% of the

sale price. RCW 84.40.020 states valuations are on the first of the year.

Washington does not mandate sold property be valued at the sale price on

the first of the year following a sale. It should have it. Attachment 9 are

downloads from the Assessor's website on two commercial sales of banks.

601 Riverside sold 12/14/2018 for $47,740,000 its assessment before the

sale 3 8 million and after the sale 3 8 million. 601 W 1st sold 04/18/2019

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for $24,000,000 its assessment before the sale 21 million after the sale

19.7 million. How many residences have to make up this tax shortfall?

The COA states ratio studies are the gold standard for the Assessor's

secret mass appraisal assessments. Ratio studies are an assessor's

comparison of assessments before a sale to the sale value for all

neighborhood properties. The studies remove outliers - high and low

values. The BTA Decision in Docket 13-179 addressed ratio studies, CP

306 and 312. The Assessor's record in this case has these statements of

mass appraisal, CP 748, 753, 782 (the same on 807, 836, 865). Strand's

undisclosed valuation factors l -4 have an "unauthenticated" allegation of

mass appraisal. (CP 327-330). The COA interjected info not in the record

in their Opinion about ratio studies to affim1 summary judgment?

Sanders v. T-VA., 169 Wn.2d 827 at 864; 240 P.3d 120; 2010 ("'If the statute's meaning is plain on its face, then courts must give effect to its plain meaning as an expression of what the Legislature intended."' (quoting State v. JM, 144 Wn.2d 472,480, 28 P.3d 720 (2001))).

Sahalee Country Club v. Ed. of Tax Appeals, 108 Wn.2d 26, 735 P.2d 1320 (1987) 9

••• The starting point for real property valuation is RCW 84.40.030, which provides that all real property "shall be valued at one hundred percent of its true and fair value in money and assessed on the same basis unless specifically provided otherwise by law." ... Fair market value is determined by one or more of three general methods: market data, cost, and income capitalization. RCW 84.40.030(1), (2). The market data approach involves appraising property by analyzing sale prices of similar property. . . . The second method, cost, can also take the form of cost less depreciation or reconstruction cost less depreciation. RCW 84.40.030(2). This approach

9 I apologize. The "At" designations are omitted. Spokane County and Gonzaga law libraries I rely upon are closed to the public because of the pandemic.

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estimates what it would cost a typically informed purchaser to produce a replica of the property in its present condition. B. Boyce & W. Kinnard, Jr., at 269. The cost approach usually involves adding an estimate of the depreciated reproduction cost of the property's improvements and buildings to an estimated value of the land if vacant.

State ex rel. Morgan v. Kinnear, 80 Wn.2d 400,402,405; 494 P.2d 1362

(1972) found uniformity of valuation (Article 7 Section 1) requires valuing

all property at 100% of true and fair value - the sale price.

Last year, the legislature sought to reduce the valuation of real property by allowing assessors to deduct from the valuation the reasonable cost of sale. Laws of 1971, ch. 288, § 1, p. 1520. The assessor for King County now challenges the constitutionality of this enactment, and the Department of Revenue, in accordance with its duties under the law, seeks to meet this challenge ....

The director of revenue, in accordance with other provisions of the same statute (RCW 84.40.030), thereupon initiated a study to determine the reasonable costs of sale, and we are advised that the studies thus far indicate that such costs will be about 10 per cent of the appraised value ....

Neither the constitution nor the opinions of this court leave any latitude in the legislature to alter, reduce or amend the constitutional concept of true and fair value in money or permit the interposition of an extraneous formula to be employed by the assessing authority in determining true and fair or fair market value

b. The Trial Court's Orders

Comi rules are a problem when the Trial Court tolerates violations of

rules by the Assessor (miscaptioned pleadings) but not a prose Plaintiff.

Strand did not notice the Assessor's 'with prejudice' Conclusions in

their pleadings. CP 710, 13 70. The Assessor's allegation of not violating

the PRA is insufficient for prejudice in a PRA case because it is an issue

17

of facts, law and evidence whether the case was reasonable. CP 710.

Forbes v. City of Gold Bar, 171 Wn. App. 857,288 P.3d 384 (2012)

The COA states dismissal with prejudice is the reason the Trial

Court would not consider Strand's pleadings. The Trial Court Order

states, pleadings after 6/12/20 were improperly filed or noted following

dismissal with prejudice. CP 693. The Trial Court ordered Strand to file a

Reply Brief after 6/12/20 and she did. CP 582, CP 589. Strand filed a

Supplemental Response to Defendant's Reply Memorandum in Support of

Motion for Summary Judgment on June 12, 2020. The COA cites this

pleading in their Opinion.

c. The Assessor's Search and Pro Val Code Sheets

The Assessor's alleged 636 responsive documents make no

statement about a search from February through April 2019 when the 636

originate. The County public records officer makes no statement about a

search in April 2019 either. (CP 167) On April 21, 2020 Mr. Hodgson

states a search included all locations where responsive records could be

located including Department shared drives, Electronic databases, Local

computers and websites. West v. City of Tacoma, says

To prove that its search was adequate, the agency may rely on reasonably detailed, nonconclusory affidavits from its employees submitted in good faith. Neigh. All., 172 Wn.2d at 721. The affidavits "should include the search terms and the type of searcb performed, and they should

18

establish that all places likely to contain responsive materials were searched." Neigh. All., 172 Wn.2d at 721. (emphasis added)

A declaration is not an affidavit. Mr. Hodgson's declaration does not

disclose search terms. His declaration gives no framework of what he was

looking for and why certain locations would have it or not. Failure to

perform a reasonable search violates the PRA.

Mr. Hodgson provided Strand Pro Val code sheets CP 162-163 in

2010 according to the COA. The key word on CP 162 and 163 is Pro Val.

Pro Val is allegedly the Assessor's valuation. CP 327-330. The word

assessor is on neither page nor is the word Spokane. The sheets were not

locally made; they look and read professional. The declaration does not

allege searching the Pro Val database with all that stuff that accompanies a

big software program. The search should not just be for 'Floor Level

Designation'; it should include 'Basement Walkout' (CP 162), '1 Fronts

Enhancement' (CP 42) and the specialized language on the 395 other

pages of Cards. If the Assessor has Pro Val as a software system it came

with all the records to explain its language.

d. F,.ecords Strand Did Not Get

The Assessor's argument they gave Strand everything they got is a

false statement. These are the records they allege exist but did not

produce: (1) complete Pro Val database on 173 parcels in neighborhood

19

231720 [ Attachment 4 page 69], (2) appropriate documentation of all

physical inspections in 231720 from 2015 through 2019, (3) evidence of a

search identified in West v. City of Tacoma, ( 4) the complete record on

395 Cards.

F. RELIEF REQUESTED

The COA and Trial Court made errors of fact and law in ruling for

summary judgment. Strand asks for this court to review these errors and

reverse summary judgment. The COA and Trial Court showed bias

making these errors against Strand as a property owner, as a prose litigant

and as persistent. Strand asks the reversal of summary judgment be made

with prejudice. Strand asks a change of venue from Spokane County

Superior Court to Stevens County. Strand's persistence in Spokane

County is a problem for getting a fair trial. Strand asks to resume

discovery in Stevens County for this case.

Strand requests recovery of all costs and attorney fees pursuant to

RAP 18.1 ( a). Strand asks this court recognize as a pro se citations errors

are to be expected.

SUBMITTED this t 11 of September 2021

Patricia N. Strand, 15iit'itioner

20

F

CERTIFICATE OF SERVICE

I certify that on September 7, 2021, I served a true and correct copy of this

Motion for Discretionary Review:

Court of Appeals - III BY: hand delivery 500 N Cedar Street Spokane, VIA 99201-1905

FOR: Spokane County and BY: hand delivery Spokane County Assessor Civil Division of the Prosecutor's Office Prosecutor Binger 1115 Vv. Broadway Avenue Spokane, Vv A 99260-0010

DATED this 7th of September 2021

21

. . . ,, . '·:,' ......

ATTACHMENT 1

2

3

4

5

6

7

8

9,

10

11

12'

COPY Original FUed

JUN 12 2020

Timothy W, Flt2gerald SPOKANE COUNTY CLERK

IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON 1N AND FOR THE COUNTY OF SPOKANE

PATRICIAN. STRAND, )

Plaintiffs, v.

SPOKANE COUNTY, et al.1

Defendant.

) ) ) ) ) ) ) ) )

No. 20-2-01077-32

ORDER GRANTING DEFENDANT'S MOTION FOR SUMMARY .ruDGMENT

*********"'***** 13 THIS MATTER came before the Honorable Tony Hazel for hearing on June 12, 2020,

'

14 on Defendants' Motion for Summary Judgment.

15 The pleadings filed by the pa1~!es and considered by the Court on this motion are as

16 follows:

17

18

19

20

1. 2. 3. 4. s.

6.

Defendants' Memorandum in Support of Motion for Summary Judgment; DecJaradon of Byron Hodgson, including Attachments; Declaration of Anthony Dinaro, including Attachments; Plaintiffs, Response to Defendant's Motion for Summary Judgment; Defendants' Reply Memorandum in Support of Motion for Summary Judgment; and Second Declaration of Byron Hodgson.

21 WHEREFORE, having considered the above-referenced documents and having heard

22 the arguments of Plaintiff and Defendant's counsel on Defendants' Motion for Sununary

23 Judgment, and being fully advised in the premises, it is hereby:

24 ORDER

Page I of2

SPOl<ANE COUNTY Prosecuting Attorney W. 1 l IS Broadway Avenue Spokane. Washington 99260 (509) 477-5764

1 ORDERED, ADJUDGED AND DECREED: Defendants' Motion for Swnmary

2 Judgment is granted and this matter is dismissed with prejudice.

3

4

5

6

7

8

DA TED this 12th day of June, 2020.

Presented by:

ROBERT B. BINGER, SBA#l0774 9 Sr. Deputy Prosecuting Attorney

Attorneys for Spokane County 10

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13

14

15

16

17

18

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20

21

22

23

24 ORDER

Page2 of2

SPOKANE COUNTY Prosecuting Attorney W. 1115 Broadway Avenue Spokane, Washington 99260 (509) 477-5764

Spokane CoWJty Court House

June 16, 2020

Robert Blaine Binger Deputy Prosecuting Attorney 1115 W Broadway Ave Spokane, WA 99260-2051

Superior Court of the State of Washington for the County of Spokane

Department No. 6

Tony Hazel Judge

1116 W. BROADWAY AVE, SPOKANE, WA 99260-0350

(509)477-4795 • FAX:(509)477-5714 • TDD:(509)477-5790 dept6@spoka necounty .org

Patricia N Strand Po Box 312 Nine Mile Falls, WA 99026-0312

STRAND, PATRICIA N et al vs SPOKANE COUNTY ASSESSOR et al No. 20-2-01077-32

Dear Cu urusel;

The Court received a Motion for Reconsideration from Ms. Strand on June 15, 2020 regarding the above-entitled case. Please respond in writing to this motion no later than 4:00 p.m. on Friday, July 31, 2020. Please file the original documents in the court file and provide a courtesy copy for the Court directly to Department 6, c/o Melanie Morman, 1116 W. Broadway Ave., Room 405, Spokane, WA 99260. I have enclosed the briefing schedule.

Judge Hazel does not hear oral argument on Motion for Reconsiderations. He will issue a written ruling.

If you have any questions, please do not hesitate to contact me.

Sincerely,

Melanie A Morman, Judicial Assistant to Tony Hazel Superior Court Judge

Enclosure Cc: Court File

8 SUPERIOR COURT OF

t \ WASHINGTON ' ' .._, COUNTY OF SPOKANE

Ealmer Strand and Patricia N Strand

Plaintiff/Petitioner

vs.

Sgokane County and Sgokane County Assessor Defendant/Respondent

CASE NO. 20-2-01077-32

BRIEFING SCHEDULE

ORDER

IT IS ORDERED that all parties shall comply with the following schedule:

SCHEDULE DUE Date

•Response Brief 7/31/2020

•Reply Brief 8/14/2020

DATED this 16th day of June, 2020

~.w·····-;.o~":.:~" , , .. •

,, '.

TONY HAZEL SUPERIOR COURT JUDGE

BRIEFING SCHEDULE Page 1 of 2

DECLARATION OF SERVICE

I, Melanie A Morman, certify that on June 16, 2020, I served a copy of this Briefing Schedule to:

[x] E-Mail [ ] US Mail [ ] Hand Delivery

Robert Blaine Binger Deputy Prosecuting Attorney 1115 W Broadway Ave Spokane, WA 99260-2051 [email protected]

[x] E-Mail [ ] US Mail [ ] Hand Delivery

Patricia N Strand Po Box 312 Nine Mile Falls, WA 99026-0312 [email protected]

[ ] E-Mail [ ] US Mail [ ] Hand Delivery

I certify under penalty of perjury pursuant to the laws of the State of Washington that the foregoing Statement is true and correct.

Date: June 16, 2020

BRIEFING SCHEDULE

~~ Melanie A Morman, Judicial Assistant to Tony Hazel Superior Court Judge

Page 2 of 2 :::

5

Spokane County Court Hotc,e

June 24, 2020

Robert Blaine Binger Deputy Prosecuting Attorney 1115 W Broadway Ave Spokane, WA 99260-2051

Superior Court of the State of Washington for the County of S}X)kane

Department No. 6

Tony Hazel Judge

1116 W. BROADWAY AVE, SPOKANE, WA 99260-0350

(509)477-4795 • FAX:(509)477-5714 • TDD:(509)477-5790 [email protected]

Patricia N Strand Po Box 312 Nine Mile Falls, WA 99026-0312

STRAND, PATRICIAN et al vs SPOKANE COUNTY ASSESSOR et al No. 20-2-01077-32

Dear Counsel and Ms. Strand:

I received Ms. Strand's Motion for Court to Correct June 16, 2020 Reschedule Order today, June 24, 2020. I'd like to offer my apologies as I miscalculated the dates when I entered the Briefing Schedule dated June 16, 2020.

Attached is the new Briefing Schedule.

Please do not hesitate to call or email me if you have any questions. Sincerely,


CC: Court file Enclosure

<o

SUPERIOR COURT OF WASHINGTON COUNTY OF SPOKANE

Palmer Strand and Patricia N Strand.

Plaintiff/Petitioner

vs.

Spokane County and Spokane Cmm.t£ Assessor Defendant/Respondent

CASE NO. 20-2-01077-32

AMENDED BRIEFING SCHEDULE

ORDER

IT IS ORDERED that all parties shall comply with the following schedule:

SCHEDULE DUE Date

• Response Brief 7/6/2020

• Reolv Brief 7/13/2020

DA TED this 24th day of June, 2020

TONY HAZEL SUPERIOR COURT JUDGE

BRIEFING SCHEDULE Page 1 of2

1

DECLARATION OF SERVICE

I, Melanie A Morman, certify that on June 24, 2020, I served a copy of this Briefing Schedule to:

[X] E-Mail [ ] US Mail [ ] Hand Delivery

Robert Blaine Binger Deputy Prosecuting Attorney 1115 W Broadway Ave Spokane, WA 99260-2051 rbinger@spokanecou nty. org

[X] E-Mail [] US Mail [ ] Hand Delivery

Patricia N Strand Po Box 312 Nine Mile Falls, WA 99026-0312 [email protected]

[ ] E-Mail [ ] US Mail [ ] Hand Delivery

I certify under penalty of perjury pursuant to the laws of the State of Washington that the foregoing Statement is true and correct.

Date: June 24, 2020

BRIEFING SCHEDULE


Page 2 of 2 :::

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9

IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON IN AND FOR THE COUNTY OF SPOKANE

10

11

Palmer Strand and Patricia N Strand

Petitioner,

V.

Spokane County and Spokane County 12 Assessor

13 Respondent

14

15

) ) ) No. 20201077-32 ) ) ) ) ORDER DENYING PETIONER'S MOTION ON ) RECONSIDERATION ) ) ) )

16 I. BASIS

17 Petitioner filed a motion for reconsideration post ruling on 6/15/20 requestin

18 reconsideration of the decision and dispositive order signed on 6/12/20. The Court determine

19 oral argument is unnecessary. The court has reviewed Petitioner's motion for reconsideratio

20 and Respondent's response.

21 II. FINDING

22 After reviewing the case record to date, the court's finds there is no basis in law nor othe

23 reason(s) to change its original ruling and order. Petitioner's motion for reconsideration i

24 respectfully denied. The Petitioner also filed additional pleadings following the court's dispositiv

25 order.

Ill.ORDER

IT IS ORDERED that: The Petitioner's motion for reconsideration is respectfully denied.

1 All pleadings, other than motion for reconsideration filed after Court's dispositive order signed o

2 6/12/20 shall not be considered as they were improperly filed or noted following dismissal wit

3 prejudice. If the Petitioner seeks to challenge the court's ruling and such appeal is otherwise lawfu

4 and or permitted, such appeal should be directed to the Washington Court of Appeals Division Ill

5 No further pleadings shall be filed under the above cause number unless directed by the Appeal

6 Court or as otherwise as expressly permitted by court rule. The courts order signed 6/12/20 was·

7 final and dispositive order dismissing action with prejudice following denial of reconsideration.

8 DATED this 2oth day of July, 2020.

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A copy of this order shall be sent to both Petitioner and Respondent.

\0

Renee S. Townsley Clerk/Administrator

The Court of Appeals of the

500 N Cedar ST Spokane, WA 99201-1905

(509) 456-3082 TDD #1-800-833-6388

State of Washington Fax (509) 456-4288 http://www. courts. wa.gov/courts

Patricia N Strand PO Box 312 Nine Mile Falls, WA 99026 Email [email protected]

CASE # 376699

February 23, 2021

Patricia N. Strand, et al v. Spokane County Assessor, et al SPOKANE COUNTY SUPERIOR COURT No. 202010779

Ms. Strand:

Pursuant to appellant's motion for change of venue, the following notation ruling was entered:

February 22. 2021 The Motion for Change of Venue is denied at the direction of the assignment judge.

RST:jld

Renee S. Townsley Clerk

c: Robert Blaine Binger Attorney at Law 1115 W Broadway Ave Spokane, WA 99260-2051 Email [email protected]

Sincerely,

RENEE S. TOWNSLEY Clerk/ Administrator

~-1/{1(-kn-Janet L. Dalton, Case Manager

' (

FILED .JUNE 15,2021

In the Office of the Clerk of Court WA State Comt of Appc,als, Division HI

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON DIVISION THREE

PATRICIAN. STRAND,

Appellant,

v.

SPOKANE COUNTY AND SPOKANE COUNTY ASSESSOR,

Respondent.

) ) ) ) ) ) ) ) ) )

No. 37669-9-III

UNPUBLISHED OPINION

SIDDOWAY, J. -Patricia Strand appeals the summary judgment dismissal of her

Public Records Act (PRA) 1 complaint against the Spokane County Assessor. She

accused the assessor of failing to timely and fully respond to her request for all records

showing the basis for its 2018 assessed value of her residential property.

1 Chapter 42.56 RCW.

No. 37669-9-III Strand v. Spokane County, et al.

Ms. Strand apparently believes the assessor has identifiable records reflecting a

process in which staff researched other properties, selected some that were comparable to

hers or identified other valuation criteria, and performed arithmetic in order to arrive at

the 2018 assessed value of her property. But the record demonstrates that the assessor's

annual valuations are generated by a computer assisted mass appraisal process that does

not rely on this sort of staff work.

The assessor has described a reasonable search and provides a plausible

explanation why it has no records responsive to Ms. Strand's request other than those it

has produced. Because Ms. Strand failed to present specific facts creating a genuine

issue of disputed fact, we affirm.

FACTS AND PROCEDURAL BACKGROUND

In summer 2018, Patricia Strand received a notice from the Spokane County

assessor of the 2018 assessed value of her and her husband, Palmer Strand's, residential

property. She appealed the assessment. The assessor and the county board of

equalization agreed that Ms. Strand's appeal could proceed directly to the Washington

State Board of Tax Appeals (BTA).

On February 20, 2019, Ms. Strand received a scheduling letter for the valuation

appeal from the BTA. That afternoon she e-mailed a public record request to the

assessor, asking it to provide "the following records":

2


Regarding DA 18-0071 on parcel 17355.9014.l2l I want all records that show the Assessor's basis for valuation for assessment year 2018 - 2019 taxes.

The request is based on RCWs 84.40.030, 84.40.020, 84.48.150 and 42.56.520.

Clerk's Papers (CP) at 35.

Ms. Strand's PRA request was immediately acknowledged, and the next day

Byron Hodgson, the county's chief deputy assessor, responded to the request by e-mail.

He provided her with a 2-page property record card for parcel number 17355.9014 and

stated, "Expect the second installment on or before March 8th." CP at 729. The

computer-generated property record card, which was printed on the day it was e-mailed

to Ms. Strand, included information on ownership transfers, historical valuation

information, ownership and transfer of ownership information, a site description, land

data and calculations, and improvement data for the parcel.

A few days later, on February 24, Ms. Strand e-mailed Mr. Hodgson a clarified

request. Her e-mail attached three property cards for parcel 17355.9014 printed on April

25, 2018. For a "specifi[ ed] date" within each of five assessment years, Ms. Strand

requested data falling within three categories from which values on the "specifi[ ed] date"

were derived. CP at 732-34. Within each category, she requested between 8 and 13

2 DA 18-0071 is the Spokane County Board of Equalization docket number for Ms. Strand's appeal; 17355.9014 is Spokane County's parcel number for her and Palmer Strand's property.

3


pieces of information, such as "sold properties" and the "arithmetic" used in arriving at

values. Id. She emphasized that for most of the pieces of information being requested

the "items ... should clearly connect each sale to the ... associated records." Id. at

733-34 (boldface omitted).

On the afternoon of March 8, Mr. Hodgson provided Ms. Strand by e-mail with a

second, 19-page installment of records. The records provided included the assessor's

answer to her petition appealing its 2018 assessed value.

The assessor relies on a form answer to petitions that appeal its assessed values.

Among other information, the form answer explains that in order to measure the

reliability of its computer assisted mass appraisal, the county has adopted the

International Association of Assessing Officers' standards for ratio studies. (Ratio

studies are discussed further below.) The answer identified four sales taking place

between January 1, 2017, and April 30, 2018, that it explained were not necessarily

comparable to her property, but that "helped establish market valuation of other

properties within the statistical neighborhood in which you reside." CP at 748. It stated

that "[t]he statistical measures included within this report appear to be supportive of our

initial valuation position" and, "Within 21 days of the scheduled [ appeal] hearing, we

will be also be [sic] providing comparable properties which we feel are reflective of your

property and supportive of market value." CP at 743. Mr. Hodgson provided property

4


record cards for three of the four properties whose sales the answer to the petition

identified as helping establish market valuation.3

Mr. Hodgson's e-mail provided links to the county's website where Ms. Strand

could find photographs for comparable sales and other additional information pertaining

to her request. The e-mail informed Ms. Strand that her request remained open and to

expect the next installment ofresponsive records on or before March 15.

Ms. Strand responded by e-mail to Mr. Hodgson within an hour ofreceiving his,

stating that the records he provided were "[£]rankly ... confusing and totally

nonresponsive." CP at 762. She asked him to provide the records she had requested.

On March 15, Mr. Hodgson e-mailed Ms. Strand a third installment of records.

The third, 581-page installment included more property records cards, neighborhood final

reports, and more links to photos for comparable sales and property sold information

pertaining to Ms. Strand's public records request. The e-mail informed Ms. Strand the

attached information included all relevant sales information for each year, analysis used

to develop values, property characteristics for sold properties, and specific dates when

values were posted. Mr. Hodgson also informed Ms. Strand that her record request

remained open until March 22.

3 It appears that an error was made by providing two copies of property cards for the third property sold and none for the fourth. A property card for the fourth property sold was provided in the third installment ofrecords produced. See CP at 912-13.

5

I Co


On the afternoon of March 22, Mr. Hodgson e-mailed to Ms. Strand a fourth, nine

page installment of records responsive to her request. He attached files from the Online

Services/Parcel Data Downloads for parcels in county neighborhood 231720. He also

provided links to additional information such as the assessor's website. He also

summarized the records provided to Ms. Strand in response to her request.

A couple of hours later, Ms. Strand responded to Mr. Hodgson's e-mail,

complaining that he had failed to "connect everything you have mailed to me" as

requested by her on March 15. CP at 1361. She asked him to "[p]lease immediately

connect what you have mailed to me" with her request and concluded, "[I]f you do not

immediately connect the records you are producing with what I requested I shall not ask

again for this to be done. We will again end up in Court for violations ofRCW

42.56.520." Id.

The following week, Mr. Hodgson sent Ms. Strand an e-mail that itemized the

records she had requested; identified, for each, what he had produced that he considered

responsive; and identified the items he concluded were not an identifiable record: ProVal

code sheets, the arithmetic (formula), and appraisal theory. He concluded:

All identifiable records that you have requested have been provided. An agency is not obligated to create a new record to satisfy a records request. Even if a new record was contemplated, it would be a complicated undertaking requiring the compilation of historical data which would not yield an arithmetic formula (correlation between sold and unsold property) to derive valuation. This request is considered closed.

6

\

No. 37669-9-III Strand v. Spokane County,. et al.

CP at 1363 ( emphasis omitted).

In a reply to Mr. Hodgson's summary e-mail the following day, Ms. Strand

supported her request for what she called "Pro Val code sheets" with two documents she

described as "examples":

BASBIENT WALKO\IT SIJB.TYPc (SWS) (~IO Till'~~~. 74.75.81.SW.!l,,94& 00)

Cata! hoeses Ml~ IY a~~ \IJNJ cpft/ Mio l!l6ll ii loo~~ Oi'tl a lQ!o « yw m too bhemer'4 lol\le!. ~11$8 ol 118 ~ ~ ~and~ IJlXdl etpaan ~to the ~ieYalhlhlslJllile~ flabaleMll lliilo ala! l®nll$ M • pan ol ile Mlg SJea oUiem holl!e. The ~ wffl Stb,Type ai '6ie ~ hOUt,es w111 fiil mi'ifiii ooi,-.-$8U1ehn8/l,f111a1MSolHs ~-M~OO~ hldalt,l~rdappwillltillV!e fut Thettiropc11Wk~~o11hlsdefvlmati»SNJa. ll(ljJc,l~.llOOlilt-~be oo&~IIOOlflel!Ml llidbl':I i!l1II)' ,_ 11,o -· Tho '""O' ~ rM!lolimi tMUl llnMll>O hi .. ~ '

' ll!Ytd Iha OOU!8 mlsld" W!ll1, ~ the l10'.IS9 ~ be m!.wxfed 1$ al'IIO~lll\eO~cri{~Uleiln The~ls~irdls no! flnlied IO@W,1/~ (caled 11111:<ilt raldl), ~ ta 1\1* Is Ille ®It !~lard:

M CQPe QESC/lfllOH

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.2 ::= .. ·-·--no j t/let$$lo/ti\9bB5EiMlll8'/ef I

3 1!81$Dol!11-.C ~ llill1 tl/ l'dlrolA garege. ~1,,1, 1'111,._._-1 ~tqrea .

. 4 ~ooh11lmdef'1\ v.i.,i°'ll\1kuQB!i9£!. dl&llsllid V~&ltlG

P.1$1

7

~~ ... . Willll ..

. -· ·,· .. ··~

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lllill!i..tf\16'Qla'~--~ . . . . ·Lcwllo,ttt,1~---111)1···.i•- :., ..

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CP at 1364, 161-63. The example on the right is referred to hereafter as the "Floor Level

Designations illustration." A label added to the top of both of Ms. Strand's examples

says "Received Jul/20/10 as Assessor Policy/Procedure Record." Id. at 162-63.

Mr. Hodgson sent his last response to Ms. Strand's record request on April 4,

reiterating that he believed Ms. Strand had received a complete response. He informed

her she could contact the Spokane County Public Records Office if she believed a public

record had been missed, provided her with a link to the county's website, and concluded

with a statement of her right to appeal a determination to withhold information. Id.

Ms. Strand appealed, alleging withholding. Spokane County Public Records

Officer Anthony Dinaro met with Mr. Hodgson and Steven Kinn, the county's former

public records officer, to review her appeal. Mr. Dinaro concluded and timely reported to

Ms. Strand, that "[a]fter a thorough review" he concluded that "all identifiable public

records responsive to your request have been produced." CP at 723.

Approximately a year later, Ms. Strand filed suit against the county and the

assessor, alleging violations of the PRA. We refer to the defendants hereafter,

collectively, as "the Assessor." The Assessor responded by moving for summary

judgment the following month. The caption of its motion for summary judgment

erroneously listed Ms. Strand's husband, Palmer Strand, as a plaintiff. In support of its

motion for summary judgment, the Assessor attached the declarations of Mr. Dinaro and

Mr. Hodgson.

8


Mr. Hodgson's declaration described the steps taken in searching for documents

responsive to Ms. Strand's request and clarifications and the history of his

communications with her. It attached and authenticated the county's production of

records.

Mr. Dinaro's declaration described the steps taken in reviewing Ms. Strand's

appeal of the assessor's PRA response. It attached and authenticated his correspondence

with Ms. Strand. He explained that in reviewing her appeal, he satisfied himself that the

county had provided an adequate and prompt response, had performed a reasonable

search, and had produced all responsive records.

Ms. Strand's response to the summary judgment motion attached over 200 pages

of unauthenticated documents. They included copies of records she received from

Thurston County that were different from records she received from Spokane County.

She identified 19 factors, referred to by her as "valuation factors," that were not applied

to her property in any records produced by the county. CP at 286-94 (boldface and

capitalization omitted). She gleaned her "valuation factors" from sources such as

statutes, case law, and the Assessor's responses to discovery requests and hearing

transcripts from prior assessment appeals dated anywhere from 2009 to 2018. Her

response was largely devoted to arguing that the Assessor wrongly valued her property,

made false statements, and failed to comply with Washington statutes other than the

PRA. Ms. Strand also argued that because the property record cards were printed after

9

=


the Assessor received her request, they were nonresponsive. Finally, Ms. Strand's

response argued the Assessor's inclusion of her husband as a party in the caption of its

pleadings amounted to a "failure of process violating CR 4." CP at 298-99 (boldface and

capitalization omitted).

The Assessor replied, supported by a second declaration from Mr. Hodgson. The

second declaration explained that the information on property record cards is data

maintained in the Pro Val software, and while the data existed prior to Ms. Strand's

request, it was only upon receipt of her request that the card was printed, in order to

provide her with the preexisting data. Mr. Hodgson testified that the "code sheet[s]"

referenced by Ms. Strand in her complaint were of unknown origin. He testified, "I

searched the Assessor's Office and databases and could not locate these documents."

CP at 1373.

When the trial court heard the Assessor's summary judgment motion, it orally

granted it, took a short recess so that an order could be prepared and presented, and

entered its written order dismissing Ms. Strand's complaint that day.

Despite the dismissal, Ms. Strand later filed a supplemental response to the

Assessor's reply memorandum in support of summary judgment, a "Motion to Dismiss

Summary Judgment," CP at 587-88, and a motion for an order requiring the Assessor to

correct the caption on its summary judgment submissions. She filed a timely motion for

reconsideration that was denied, with the trial court ruling that it found "no basis in law

10


nor other reason(s) to change its original ruling and order." CP at 692. The court

indicated it would not consider any materials filed by Ms. Strand following its granting of

summary judgment other than the reconsideration motion it was denying.

Ms. Strand appealed.

' Shortly before this appeal was originally set for hearing, Ms. Strand filed a

"Motion for Additional Evidence" with 63 pages of unnumbered attachments. Mot. for

Addt'l Evid., Strand v. Spokane County et al., No. 37669-9-III (Wash. Ct. App. Feb. 16,

2021) (available from the court). The motion alleged that in response to a record request

that Ms. Strand submitted to the Assessor in October 2020, it made responsive records

available in a drop box, and one of the records produced was the Floor Level

Designations illustration that she had provided to Mr. Hodgson in March 2019 as an

example of a Pro Val code sheet. This was a document that Mr. Hodgson testified in

April 2019 was of unknown origin and could not be located in a search of the Assessor's

office and databases.

We continued oral argument and afforded the Assessor an opportunity to respond

to the motion. Disposition of the motion was referred to this panel.

ANALYSIS

"The PRA's primary purpose is to foster governmental transparency and

accountability by making public records available to Washington's citizens." Doe v.

Wash. State Patrol, 185 Wn.2d 363,371,374 P.3d 63 (2016). "To be a public record

11


under RCW 42.56.010(3), information must be (l) a writing (2) related to the conduct of

government or the performance of government functions that is (3) prepared, owned,

used, or retained by a state or local agency." Nissen v. Pierce County, 183 Wn.2d 863,

879,357 P.3d 45 (2015). The PRA does not require agencies to "'create or produce a

record that is nonexistent.'" Fisher Broad-Seattle TV LLC v. City of Seattle, 180 Wn.2d

515,522, 326 P.3d 688 (2014) (quoting Gendler v. Batiste, 174 Wn.2d 244,252, 274

P.3d 346 (2012)).

A public records request must be for identifiable records. RCW 42.56.080(1 ). A

request for information does not qualify. Belenski v. Jefferson County, 187 Wn. App.

724,740,350 P.3d 689 (2015) (citing Woodv. Lowe, 102 Wn. App. 872,879, 10 P.3d

494 (2000)), rev'd in part on other grounds, 186 Wn.2d 452,378 P.3d 176 (2016);

Bonamy v. City of Seattle, 92 Wn. App. 403, 410-12, 960 P.2d 447 (1998). The PRA

does not require agencies to research or explain public records, but only to make those

records accessible to the public. Id. (citing Bonamy, 92 Wn. App. at 409).

Some background on real property assessment is needed to inform conclusions

about what records assessors are likely to possess about valuation. The records an

assessor is likely to possess will differ depending on whether there is a pending appeal of

a property's assessed value.

12

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Annual valuation process

RCW 84.40.020 and .030 require all real property in the state subject to taxation to

be listed and assessed every year, with reference to its value on the first day of the year,

and provide that "[s]uch listing and all supporting documents and records shall be open to

public inspection during the regular office hours of the assessor's office." RCW

84.40.020.

The Washington State Department of Revenue (DOR) is tasked with the general

supervision and control over the administration of the assessment and tax laws of the

state and over county assessors in the performance of their duties relating to taxation.

RCW 84.08.010(1). In its 2018 report on the 2017 performance of the property tax

appraisal system in Washington, it reported that "Washington has approximately 3.08

million real property parcels," and"[ d]ue to the high volume of assessments, county

assessors must use mass appraisal techniques to determine assessed values." DOR,

MEASURING REAL PROPERTY APPRAISAL PERFORMANCE IN WASHINGTON'S PROPERTY

TAX SYSTEM 2017, at 39 (Feb. 1, 2018) (DOR 2017 Report).4 Mass appraisal

"' systematic[ ally] apprais[ es] groups of properties as of a given date using standardized

procedures and statistical testing.'" 5

4 Https://dor.wa.gov/sites/default/files/legacy/Docs/Reports/2017RatioReport.pdf [https://perma.cc/K 77W-HKZQ].

5 DOR, HOMEOWNER'S GUIDE TO MASS APPRAISAL 2 (July 2014) (citing ROBERT J. GLOUDEMANS, THE MASS .APPRAISAL OF REAL PROPERTY 1 (1999)), https://dor.wa.gov

13

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The DOR 201 7 Report included its own description of the mass appraisal process:

Mass appraisal is the process of valuing a group of properties. This approach is sometimes contrasted with more familiar single-property appraisals (sometimes called fee appraisal). Fee appraisal is the process of valuing a particular property. Both are systematic approaches to establishing property value. However, they differ in scope and method of evaluation. Mass appraisal systems are designed to value many properties and are evaluated by statistical methods. Single-property appraisals are concemed with one property and are evaluated by a comparison to comparable properties.

Id. at II.

The DOR is specifically charged with examining the procedures used by county

assessors to assess real property. RCW 84.48.075( 4). It is required annually to submit to

each assessor a ratio of the assessor's assessed values to market values. RCW

84.48.075( 1 ). A ratio study measures a county's mass appraisal performance. Using

property sales from a recent period, it compares those market prices with the assessed

values that vv.ere established by the assessor's office. DOR 2017 Report, supra, at III.

The closer recent actual sale prices are to an assessor's then-current assessed value, the

better the assessor's performance. In 2018, for 2019 taxes, DOR reported that Spokane

County's real property tax ratio was 95.1 percent. DOR, PROPERTY TAX RATIOS BY

COlJNTY 2018 FOR 2019 TAXES (undated), https://dor.wa.gov/sites/default/files

Is ites/ defaul t/files/1 egacy /Docs/Pubs/Prop_ Tax /Prop TaxMassA ppraisal. pdf [https://perma.cc/GW3D-FYEA].

14

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/legacy/Docs/Reports/2018Com binedlndi catedRati o. pdf [https://perma.cc/QND8-

WS LU].

In a discovery response the Assessor provided to Patricia and Palmer Strand in the

Strands' appeal of the 2009 assessed value of their property, the Assessor described its

mass appraisal process:

Like assessors in other Washington counties, the Spokane County Assessor utilizes Computer Assisted Mass Appraisal (CAMA) in the assessment of property values ....

For this purpose, the Assessor's office uses a computer software program known as Manatron ProVal. Spokane County does not own Pro Val, but uses it under certain terms and conditions set forth in a nonexclusive license with Manatron.

Pro Val features a highly productive, integrated sketch package and an extremely accurate valuation engine for calculating property values. It includes income approach, sales approach, and cost approach models to value property. It also includes models to automatically value land. It is the most widely deployed and, nationally recognized, CAMA software product. The software's internal calibration and embedded object code is proprietary and not subject to public disclosure. Thus, definitive arithmetic formulae cannot be provided. The precise internal relationship between various components of value is not visible, or accessible, by the software user.

The Assessor's staff inputs various data into the Pro Val data base including: (1) information from visual inspections ofthe property; (2) sales and other market data from sources such as the Multiple Listing Source; (3) Real Estate Excise Tax Affidavits; (4) GIS; and (5) building permit information.

With input data and ... embedded Marshall Swift cost tables, the Pro Val software is able to determine the value of a Subject Property.

CP at 327-28.

15


As long as ratio studies indicate that an assessor's computer assisted mass

appraisal process is performing well, it is reasonable to assume that the assessor will rely

solely on that computerized process to generate annual assessed values. Only in the six

year cycle when inspection is required, see RCW 34.41.030( 1 ), would one expect an

assessor to have additional, staff-created records.

Responding to a property owner's appeal of assessed value

While ratio studies can be evidence that an assessor's mass appraisal process is

performing well, an assessor cannot rely on ratio studies or mass appraisal if a property

owner challenges the assessed value of her property. By statute, if the assessed value is

appealed, an a3sessor must defend the value produced by its mass appraisal process with

an individual appraisal. When adequate market data (sales prices of similar property) is

available, comparable sales is the most reliable of the three recognized valuation methods

(market data, cost, and income capitalization). Crystal Chalets Ass 'n v. Pierce County,

93 Wn. App. 70, 77, 966 P .2d 424 ( 1998). By statute, sales of the subject property or of

comparable properties within the preceding five years is the preferred evidence of true

and fair value for taxation purposes. RCW 84.40.030(3)(a).

RCW 84.48.150(1) provides that when a taxpayer petitions her county board of

equalization for review of a valuation dispute the assessor must, upon request:

make available to said taxpayer a compilation of comparable sales utilized by the assessor in establishing such taxpayer's property valuation. If valuation criteria other than comparable sales were used, the assessor must

16


furnish the taxpayer with such other factors and the addresses of such other property used in making the determination of value.

The valuation criteria and/or comparable sales on which the assessor intends to rely at the

appeal hearing must be provided within 60 days of the taxpayer's request but at least 21

business days before the taxpayer's appearance before the board of equalization. RCW

84.48.150(2).

In !data/one v. Hara, BTA Docket No. 71193, 2010 WL 11187619 (Apr. 13,

2010 ), 6 property owners challenging the valuation of their property wanted to rely on

assessed values of other properties anived at by mass appraisal. The BTA rejected their

proposed evidence, repeating an observation it had made in cases for 20 years:

"Computer-Assisted Mass Appraisal techniques are just that, mass appraisal techniques. They are not without flaw. Certainly the value generated by any computer assisted approach should be supported on appeal by standard appraisal processes."

Mata/one, 20 IO WL 11187619, at * 13 (.some emphasis omitted) ( quoting O'Connor v.

Belas, BTA Docket No. 41609, 1992 WL 192195, at *2 (May 6, 1992)). The BTA went

so far as to say that values arrived at by annual mass appraisal were irrelevant to the issue

on appeal:

[I]n Spangenberg v. Baenen, BTA Docket No. 5111977 (1999), this Board explained that the Assessor's mass appraisal work product is not relevant upon an appeal:

6 An unrelated scrivener's error in the decision was corrected by an order of correction available at 2019 WL 5297790 (A pr. 25, 2019).

17

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No. 37669-9-IU Strand v. Spokane County, et al.

While an understanding of the Assesso( s mass appraisal techniques is helpful, the focus of this appeal is whether the Assessor's methodology produced a reasonable value for the property under review. This Board has one goal in all of its hearings: the acquisition of sufficient, accurate evidence to support a determination of true and fair value as defined by statute (RCW 84.40.030) and the Washington Administrative Code (WAC 458-12-301) ....

. . . Appraisal theory guides us in our determination.

Accordingly, the Assessor himse)f must, as he did here, defend his valuation based on market sales, which are independent of the mass appraisal techniques that produce the assessed values that the Assessor certifies to the assessment rolls.

id. (emphasis added) (alterations in original).

Accordingly, if a taxpayer appeals an assessed value to the county board of

equalization, assessor staff will engage at that point in an individual appraisal process.

Records in addition to those created by its computer assisted mass appraisal software can

be expected to exist.

With that background, we tum to the issues presented by the appeal: Ms. Strand's

motion for the taking of additional evidence and her assignments of error to the dismissal

of her complaint.

l. Ms. STRAND HAS NOT DEMONSTRATED THAT WE SHOULD ORDER THE TAKING OF

NEW EVIDENCE

Under RAP 9.11, we may direct that additional evidence on the merits of a case be

taken before our decision on review if ( 1) additional proof of facts is needed to fairly

resolve the issues on review, (2) the additional evidence would probably change the

18

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decision being reviewed, (3) it is equitable to excuse a party's failure to present the

evidence to the trial court, ( 4) the remedy available to a party through postjudgment

motions in the trial court is inadequate or unnecessarily expensive, (5) the appellate court

remedy of granting a new trial is inadequate or unnecessarily expensive, and (6) it would

be inequitable to decide the case solely on the evidence already taken in the trial court.

Only if all six conditions are met will we order the taking of new evidence. State v.

Ziegler, 114 Wn.2d 533,541, 789 P.2d 79 (1990).

Ms. Strand's proposed new evidence is a Floor Level Designations illustration that

was produced by the Assessor in response to a record request she made in 2020, after this

action was dismissed. Her 2020 request asked the Assessor to produce ( among other

records) "all Assessor policies and procedures (mechanisms) used to determine values."

Mot. for Addt' 1 Evid., Attach. 1, at 2. One of what appears to be a dozen or more

manuals produced in response includes the Floor Level Designations illustration as its.

page 27. Id., Attach. 3 at 27. The manual's cover identifies its source and date as

"1/1/2020, Spokane County Assessor's Office." Id., Attach. 3 at 1.

19

30


Seen here, page 27

of the 2020 manual is the

same Floor Level

Designations illustration

Ms. Strand provided to the

Assessor in March 2019 as

an example of what she

called "Pro Val code

sheets." The oniy

difference with the

illustration she provided as

an example was that a

label on her example reads,

"Received Jul/20/10 as

Assessor Policy/Procedure

Record.'' CP at 163.

20 Section 5: Estimating Value

~~~1'illlfldflJ.ltl'at-M~81ldll'llll9~~

~9-t Ful~~\l'fb,sOftOOll&du

~lffl lillt~~'<dl-~~all-.-.dillleoofltM(, Fo.NW'1dlllilft1,~lnj~l'lt'dltfpt'-

It turns out that the Floor Level Designations illustration Ms. Strand provided to

Mr. Hodgson in March 2019 as an example was a record the assessor's office produced to

her in 2010. In February 2010, the Assessor identified to .Ms. Strand 13 or more binders

or manuals, collectively comprising more than 1,500 pages, as policies and procedures

20


responsive to one of her requests. Mr. Hodgson assisted in identifying the list of binders

and manuals. On July 20, 2010, Ms. Strand traveled to the assessor's office to review the

binders and manuals and marked pages she wanted copied. One page she wanted copied

was the Floor Level Designations illustration.

We can infer from Ms. Strand's proposed new evidence that some version of a

manual containing the Floor Level Designations illustration might have been in the

Assessor's possession at the time of her February 20, 2019 records request, since the

Assessor had such a manual in 2010 and 2020. But given the different scope of her

February 2019 request (it did not seek manuals, policies or procedures), the mere fact that

the manual and illustration were not searched for or located in Mr. Hodgson's search is

not relevant to our review.

Ms. Strand does not demonstrate that additional proof of facts is needed to fairly

resolve the issues on review, that additional evidence would probably .change the decision

being reviewed, or that it would be inequitable to decide the case solely on the evidence

already taken in the trial court. 7 Her RAP 9.11 motion is denied.

7 Ms. Strand argues that the 2020 production proves Mr. Hodgson committed perjury when he testified in his second declaration that her example of a "Pro Val Code Sheet" was of

unknown origin and was not located in his search of the Assessor's office. Mot. for Addt'l Evid. at 9. But Mr. Hodgson testified that in responding to her request he searched "all locations where responsive records could be located," including "Department shared drives: Electronic

databases: Local computers: and Websites." CP at 727. He never testified that he searched all of the Assessor's policy and procedure manuals. Even if he had, his mistake about a manual that

was not responsive to the February 2019 record request would be irrelevant to the issues on review.

21


II. THE TRIAL COURT PROPERLY LIMITED ITS CONSIDERATION OF Ms. STRAND 's SUBMISSIONS FOLLOWING DISMJSSAL OF HER MOTION FOR RECONSIDERATION

Before turning to the assigned errors we remind Ms. Strand of our rules, including

RAP 10.3(a)(5), which requires the statement of the case to be "[a] fair statement of the

facts and procedure relevant to the issues presented for review, without argument."

(Emphasis added.) Ms. Strand' s statement of the case is almost entirely argument. It

includes argument about matters that are not assigned as error and addressed in her

argument section. Pro se litigants are expected to comply with the Rules of Appellate

Procedure. State Farm Mut. Auto Ins. Co. v. Avery, 114 Wn. App. 299, 310, 57 P.3d 300

(2002).

We will forgive Ms. Strand's failure to comply with RAP I 0.3(a)(5). But we will

not search her statement of the case for issues other than those raised by her assignments

of error and that are addressed in her argument section.

Ms. Strand's third assignment of error cha.llenges the trial court's refusal to

consider any submissions filed after summary judgment was granted other than her

motion for reconsideration. We address this alleged error first.

The court's order granting summary judgment stated, "[T]his matter is dismissed

with prejudice." CP at 573. The materials filed by Ms. Strand thereafter that the court

refused to consider were her supplemental response to the Assessor's summary judgment

22 =


reply memorandum, a motion for an order requiring the Assessor to correct captioning on

its pleadings, and a motion to dismiss the Assessor's summary judgment motion.

CR 7(a) identifies the only pleadings that are permitted, and Ms. Strand's

postdismissal submissions were not permitted pleadings. CR 7(b) permits the filing of

motions, which are "application[s] to the court for an order." CR 59(a) identifies a legal

basis on which a plaintiff whose complaint has been dismissed with prejudice can apply

for an order: it can ask that the order of dismissal be vacated. CR 60 also identifies a

legal basis on which such a plaintiff can apply for an order: it can ask that a clerical

mistake in a judgment or order be corrected or that it be relieved from a final judgment.

The three submissions by Ms. Strand that the court refused to consider were

properly ignored either because they violated the terms of the applicable rules or because

there was no order being requested for which she had a legal basis.

Her supplemental response to the Assessor's reply memorandum was not a

permitted submission under CR 56, which sets a specific timeline for summary judgment

procedure. Keck v. Collins, 181 Wn. App. 67, 83,325 P.3d 306 (2014), aff'd, 184 Wn.2d

358, 357 P.3d 1080 (2015).

Her motion for an order requiring the Assessor to correct its identification of the

parties on some of its submissions was unsupported by a legal basis for the order. 8 It is

8 In the trial court, Ms. Strand cited Deggs v. Asbestos Cmp. Ltd., 186 Wn.2d 716, 719 n.1, 381 P.3d 32 (2016), but in that case there was a misspelling in the complaint,

which-being controlling-needed to be corrected.

23


apparent that the Assessor's initial inclusion of Palmer Strand as a plaintiff was a

mistake-presumably the result of the county z.ttomey' s knowledge that Palmer Strand

had joined his wife in litigation with the county in the past.9 Court rules are clear that as

between the plaintiffs and the defendants' pleadings, it is the complaint that establishes

the parties to the action. See CR lO(a)(l) ("In the complaint the title of the action shall

include the names of all the parties."). After the Assessor's misidentification of the

parties was pointed out, and beginning witb its summary judgment reply, it identified Ms.

Strand as the only plaintiff.

Ms. Strand identified no legal basis for obtaining an order "dismissing" the

Assessor's summary judgment motion after it had already been granted.

The trial court properly refosed to consider the three motions.

II. SUMMARY JUDGMENT WAS PROPERLY GRANTED

Ms. Strand's first and second assignments of error raise the issue of whether

summary judgment was proper. The purpose of summary judgment is to "avoid a useless

trial when there is no genuine issue of any material fact." LaPlante v. State, 85 Wn.2d

154, 158, 531 P.2d 299 (1975). The moving party bears the burden of proving by

9 E.g., Strand v. Spokane County, No. 36538-7-III (Wash. Ct. App. Dec. 12, 2019)

(unpublished), https://www.courts.wa.gov/opinions/pdf/365387 _ unp.pdf; Strand v. Spokane County, No. 34722-2-III (Wash. Ct. App. Apr. 11, 2019) (unpublished), https://www .courts.wa.gov/opinions/pdf/34 7222 _ unp. pdf; Strand v. Spokane County, No. 34190-9-III (Wash. Ct. App. Apr. 11, 2017) (unpublished), https://www.courts.wa

.gov/opinions/pdf/341909 _ unp.pdf.

24

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No. 37669-9-III · Strand v. Spokane County, et al.

uncontroverted facts that no genuine issue of fact exists. See Regan v. City of Seattle,

76 Wn.2d 501,458 P.2d 12 (1969).

Once the moving party meets its initial burden of proof, the burden then shifts to

the nonmoving party to show that a genuine issue of fact exists. See LaPlante, 85 Wn.2d

at 158. When a motion for summary judgment is supported by evidentiary matter, the

adverse party may not rest on mere allegations in the pleadings but must set forth specific

facts showing that there is a genuine issue for trial. W.G. Platts, Inc. v. Platts, 73 Wn.2d

434, 442; 438 P.2d 867 (1968). Summary judgment shall be granted if no genuine issue

of material fact exists and the moving party is entitled to judgment as a matter of law.

CR 56(c).

Appeals courts review the grant or denial of a motion for summary judgment de

novo. Keck, 181 Wn. App. at 78. All facts and reasonable inferences from the facts are

to be construed in the light most favorable to the nonmoving party. Id. at 79.

The Assessor provided a reasonable estimate of time,fullest assistance, and most timely possible action on Ms. Strand' s request

RCW 42.56.100 requires that an agency responding to public records requests

provide "the fullest assistance to inquirers and the most timely possible action on requests

for information." "The government agency receiving a request for public records must

respond within five business days by (1) providing the records, (2) denying the request,

25

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No. 37669-9-III I

Strand v. Spokane County, et al.

or (3) providing a reasonable estimate of the time within which to respond to the

request." Andrews v. Wash. State Patrol, 183 Wn. App. 644,651,334 P.3d 94 (2014)

(citing RCW 42.56.520).

Undisputed facts establish that the Assessor promptly and adequately assisted Ms.

Strand. Mr. Hodgson responded to Ms. Strand's request by e-mail one day after

receiving it. In his several responses, Mr. Hodgson informed Ms. Strand whether

additional installments of production were anticipated and when she could expect to see

them. Despite widespread business interruption being caused by the COVID-19

pandemic, Mr. Hodgson delivered the installments as projected, delivering the fourth and

final installment on March 22, a little over a month after receiving Ms. Strand's record

request. No facts creating a genuine issue of material fact as to the timeliness of the

Assessor's response were shown.

The Assessor conducted an adequate search

On summary judgment, the agency bears the burden of proving it conducted an

adequate search for records. Block v. City of Gold Bar, 189 Wn. App. 262,271, 355 P.3d

266(2015). "To establish that its search was adequate in a motion for summary

judgment, 'the agency may rely on reasonably detailed, nonconclusory affidavits

submitted in good faith.''' Id. ( quoting Neigh. All. of Spokane County v. County of

26

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No. 37669-9-lll Strand v. Spokane County, et al.

Spokane, 172 Wn.2d 702,721,261 P.3d 119 (2011)). These affidavits "should include

the search terms and the type of search performed, and they should establish that all

places likely to contain responsive materials were searched." Neigh. All., 172 Wn.2d at

721. "Purely speculative claims about the existence and discoverability of other

documents will not overcome an agency affidavit, which is accorded a presumption of

good faith." Forbes v. City of Gold Bar, 171 Wn. App. 857, 867, 288 P.3d 384 (2012).

The declarations of Mr. Hodgson and Mr. Dinaro on which the Assessor relied

were reasonably detailed and nonconclusory, as the law requires. We accord them the

presumption of good faith.

Ms. Strand argues that the Assessor's failure to produce the press releases, court

transcript testimony and state auditor statements that she attaches to her opposition

memorandum proves its search was inadequate. But she does not explain how her

documents, some going back almost a decade, have anything to do with her record

request. She also fails to explain how or why court transcripts and press releases would

be in the Assessor's possession. The Assessor relies on computer assisted mass appraisal

to generate its annual assessed values, and court transcripts, statutes, and press releases

are not inputs in that process. As was explained to her in 2010, the inputs are things like

27


observed characteristics of a property, sale3 and other market data, real estate excise tax

affidavits, geographic information system data: and building pennit information

information available from the type of records that Mr. Hodgson either produced or

directed her to.

The Assessor's declarations are evidence of an adequate search and Ms. Strand

does not respond with facts raising a genuine issue of material fact.

Property record cards printed after receipt of the re,uest were responsive

Ms. Strand contends that property record cards provided by Mr. Hodgson are

nonresponsive because the cards were created after he received her record request. A

record must exist at the time of a request to be subject to required disclosure. Fisher

Broad., 180 Wn.2d at 522. An agency is not required to create a record to respond to a

PRA request. Id.

"Public record'' is broadly defined, however, and includes "existing data

compilations from which information may be obtained" "regardless of physical form or

characteristics." RCW 42.56.010(4), (3). "This broad definition includes electronic

information in a database." Fisher Broad., 180 Wn.2d at 524 (citing RCW 42.56.010(4),

(3); WAC 44-14-04001). "Merely because information is in a database designed for a

28 =

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different purpose does not exempt it from disclosure. Nor does it necessarily make the

production of information a 'creation' of a record." Id.

The Assessor likely would have violated the PRA had it failed to print out

property record cards containing the preexisting information that was responsive to Ms.

Strand's record request. In any event, the fact that a record did not exist when a request

for records was made is a defense to a failure to produce it. For an agency to do a

requestor the favor of creating a record or providing a later-created record is not a

violation of the PRA. It is not something a typical requestor would complain about.

No violation of the PRA is shown.

Ms. Strand's main argument is that none of the records produced by the Assessor

is a comparable sale used to arrive at its assessed value as of January 1, 2018, or appears

on its face to be other criteria used to value her property as of that date or the other dates

she specified. But unless Ms. Strand made a request under RCW 84.48.150 for the

information the Assessor would rely on in her future appeal hearing, and the deadline for

producing that information was approaching, there is no reason to believe the Assessor

would have responsive documents. For her specified dates that were unrelated to

assessed value appeals, there was no reason to believe the records she was looking for

existed or ever would exist.

29

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Ms. Strand offered only speculation that re3ponsive records existed that were not

produced. No facts creating a genuine issue of rr..aterial fact were shown. Summary

judgment was proper.

Affirmed.

A majority of the panel has determined this opinion will not be printed in the

Washington Appellate Reports, but it wiil be filed for public record pursuant to RCW

2.06.040.

WE CONCUR:

S2 . ..,.-A.. ' '-. "37 Pennell, C.J.

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FILED AUGUST 5, 2021

fo the Office of the Clerk of Court \\'A Stale Court of Appeals, Division m

COURT OF APPEALS, DIVISION III, STATE OF WASHINGTON

PATRICIAN. STRAND,

Appellant,

V.


Respondents.

) ) ) ) ) ) ) ) ) )

No. 37669-9-111

ORDER DENYING MOTION FOR RECONSIDERATION

THE COURT has considered Appellant's motion for reconsideration and is of the

opinion the motion should be denied. Therefore,

IT IS ORDERED, the motion for reconsideration of this court's decision of

June 15, 2021, is hereby denied.

PANEL: Judges Siddoway, Fearing, Pennell

FOR THE COURT:

REBECCA L. PENNELL Chief Judge

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-----·------· ........ ~-~-.----------------IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON

IN AND FOR THE COUNTY OF SPOKANE

PATRICIA STRAND, ) )

Plaintiff; ) )

VS. )

)

SPOKANE COUNTY AND ) SPOKANE COUNTY ASSESSOR, )

) Defendant. )

SPOKANE COUNTY SUPERIOR COURT No. 20-2-01077-32

COURT OF APPEALS NO. 37669-9

THE VERBATIM REPORT OF THE PROCEEDINGS THE. HONORAaLE BEBECCA PENNELL, THE HONORABLE LAUREL SIDDOWAY,

AND THE HONORABLE GEORGE FEARING April 27, 2021

A P P E A R A N C E ~ FOR THE PLAINTIFF: PATRICIA STRAND

Pro Se

FOR THE DEFENDANT: ROBERT BINGER Deputy Prosecuting Attorney 1115 W. Broadway Avenue Spokane, WA 99260

Tracie Blocker, Official Court Reporter #3457 Spokane County Superior Court, Spokane, Washington

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-------------~-·,-----·---------------

Argument by Ms. Strand

Argument by Mr. Binger

INDEX

The Court Reporter's Certificate

Strand vs. Spokane County et al.

Index

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This is a Verbatim Report of the Proceedings (Apr i 1 2 7 , 2 0 2 1 )

JUDGE PENNELL: Good morning. The case on

this morning's calendar is Patricia Strand versus

Spokane County. I know Ms. Strand is participating,

sort of, in a hybrid over the telephone.

MS. STRAND: No, no. I'm sorry.

JUDGE PENNELL: Ms. Strand, are you there?

I know you're participating over the telephone. I

appreciate your efforts at trying to get your computer

to work. I'm sorry tha~ your video isn't working, but

it sounds like we can hear you. You will be starting

things off as the appellant and if you could let us know

how much time you would like for rebuttal.

the video? Can you see the clock?

Can you see

MS. STRAND: Yes. I have the video up.

JUDGE PENNELL: Great.

see how much time you have left.

So you'll be able to

I know that our court

staff went over how the timer works for you but just

keep an eye on that.

rebuttal?

How much time would you like for

MS. STRAND: None.

JUDGE PENNELL: None? Okay.

MS. S'TRAN D: Exactly.

JUDGE PENNELL: Well, if for some reason you

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finish early, we'll let you keep the rest of your time

for rebuttal. And after Mr. Binger goes 1 you would have

a chance for rebuttal. You may proceed.

MS. STRAND: May it please the Court. I'm

appellant Patricia Strand. This is the de novo review

of my request for the public records for how the

Spokane County assessor determined my 2015 to 2019 real

pr-operty values. The case was dismissed with prejudice

under summary judgment. Summary judgment was improper.

My request stated that it was based on RCW 84.40.030 the

valuation statute. That s.t~tute identifies the records

required to be provided owners requesting the basis of

their real property values. The records are the similar

sales and factors actually used to determine my values

because the assessor alleged a cause base valuation

method at CT-159.

Factors are the assessor's practices that

actually affected my values. The assessor's summary

judgment memorandum stated these bases: One, I failed

to identify the public records I requested. My request

cited the valuation code which identifies the public

records. Two, that the assessor provided 636 pages of

responsive records of four types: Property Record Cards

and answer to my appeal of value, neighborhood reports,

and spread sheets. Three, that I failed to show a PR

stiand vs. Spokane County et al.

April 27, 2021

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violation. My complaint at CP--7 No. 12 is a PR

violation with details of facts, law, and evidence.

Four, the declaration of Chief's Deputy Assessor

Hodgson, their public record officer, the memorandum

presented no evidence. So the memorandum was based on

this affidavit -- these affidavits. The affidavits of

the county public record's officer I don't think are

material to the facts. And, five, if the assessor

performed a reasonable and thorough search for all

responsive records.

Summary .j,udgment:,,was improper because the

assessor violated every provision of the Public Records

Act 42.56.520, part one, the 100 -- I'm sorry, the

636 pages are nonresponsive by law. They do not satisfy

84.40.030. Not a single page defines what a similar

sale is to my property or states it isn't -- it is a

similar sale to my property or states it was used to

value my property. And no state, no page identifies the

factors used to value my property.

I included Thurston County valuation records

84.40.030 is a state law. All states have to present

essentially the same records. Thurston County's records

are what responsive records look like. The four types

of records the assessor presented are not right,

Thurston County's records. Second the assessor's

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..._. ____ ........ ________ ,._.. __ '" _____ ,_, ---..-----------------1 Str~nd vs. Spokane County et al.

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470 pages of Property Record Cards are nonresponsive

because they violate the law. 42.56.080, part two,

every card was created after the request was filed with

the assessor. So no card, no page of these cards, could

be copied or inspected on the date the request was

filed.

this.

I'm citing Gipson versus Snohomish County for

Three, the assessor's website referrals are

nonresponsive because they are not the records of

similar sales and factors, their two records of

information.

JUDGE $IDD0WAY: .. Ms. Strand?

MS. STRAND: Yes?

JUDGE SIDDOWAY: Ms. Strand, can I interrupt

you for a moment with a question? This is

Judge Siddoway.

MS. STRAND: Yes.

THE COURT: The Thurston County records, I

know one of the records that you identified that you

thought was responsive and you should have gotten

similar records from Spokane County was what you refer

to as the ProVal Code Sheets, but what other records can

you point me to or describe for me the other records

that you got from Thurston County that you think should

have existed in the records of Spokane County?

MS. STRAND: The most important records are


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the list of the similar sales, and they are identified

as the similar sales used to value the subject property.

I'm the subject property. The assessor gave me every

property in rny neighborhood, sold, unsold;

Avista Utilities; Park and Rec. These are clearly not

the similar sales used to value my property.

Does that answer your question?

JUDGE SIDDOWAY: Well

MS. STRAND: I'm sorry, Your Honor.

JUDGE SIDDOWAY: You were provided with the

answer to the petition, I know that you went straight

to the Board of Tax Appeals, but there was an answer to

your petition to the Board of Equalization, and it did

identify four sales that the County treated as

comparable did it not?

MS. STRAND: No, it did not. The face of

that report says that report supports the valuation. It

is not the sales used to valuation. Additionally,

within the report, I believe on page 4 it states in very

small print that the assessor will at a future date give

me the specific sales used to value my property. So

nothing in that report is relevant to how my value is

determined.

Does that answer your question, Your Honor?

THE COURT: Well, I mean, what if it's a

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!.---...---------"'""'' "'"'' '""'""""'"">&-""""' --w~,..,w=_,...,, _________________ ......I


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Public Records Acts claim, so all they can produce is

documents that they have? What if in preparing the

original valuation, they did not prepare a document that

identified the properties that they were looking at?

Then they would have nothing that they could produce.

MS. STRAND: Your Honor, 84.40.030, first

off, valuations are annual, and the valuation that I

first asked for had been prepared just, I believe, four

months before I requested it. It's incomprehensible

that an annual process is a black hole of recorded

documents to support it( .. But .tb.e fact

JUDGE ?EARING: Ms. Strand, this is

Judge Fearing. I'm wondering if your complaint is more

that the County failed to follow the tax statutes as

opposed to the County failed to produce records that are

in existence. Can you answer that?

MS. STRAND: Yes, Your Honor. I can. I

included in my evidence factors I believe 19 undisclosed

valuation factors. Mr. -- one of those valuation

facto rs 1-1 a s the s t a t em en t o f Ch i e f De put y Ass e s so r

Hodgson on April 2019, approximately a few weeks after.,

saying there were no records of the -- how -- I'm sorry,

that they had produced all responsive records.

I'm going to make a jig here. The assessor

produced 417 -- 470 pages of Property Record Cards.

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9 ___ _.. __ .,_._. ____ ....._~----...... ~.... ' ' -~-----------------i

Every card was created after the request was filed.

Those cards are nonresponsive by law. That leaves

eliminating those cards. ·The records the assessor

produced was a report, and that report lists every

property, ·every residential property, in my

neighborhood. Every property in my neighborhood was,

every residential property, whether it sold or not is

not the basis of my valuation. But the assessor's

presentation of that document means that's what they're

stating.

This case is .about .. what is -- what -- what

did the assessor use to valuate my property. Not a

single record that was produced identifies what was used

to value my property. The language this was used to

value your property is critically important here.

can give me a telephone book and say every address,

You

every phone number, every property in that telephone

book was use to value my property.

Wellr in many respects that's what the

assessor did by giving me every property in my

neighborhood. By giving me Avista, I mean, why should I

just rely on the Avista in my neighborhood? Why not the

Avista all over the entire northwest? Avista is a

corporation. How do I say which Avista property is

relevant to my valuation? So the neighborhood report


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10 __________ -......._._, .... ,.,~--........,-~-;srlr-,....._----•-+-· --------------

with a list of all the residential properties,

reasonably, is not how my property was valued. The

sales -- the answer to the petition on the face of it,

it says it is not how my property was valued. The

website referrals are not how my property was valued

because they are the information that I may find useful.

There is -- this request was for very specific

information that the assessor does annually.

Where did my land structure and total

property values come from? Those records were not

produced. Yes, wb~ther the assessor is violating the

law is incredibly relevant because the evidence is the

assessor is violating the law, and that's the reason to

not produce the accual records. But the law doesn't

give the assessor that advantage. The law says whatever

you're doing, Assessor, the records of that have to be

disclosed to this person who has the right to know where

these values came from.

Does that answer your questions, Your Honor?

JUDGE SIDDOWAY: Judge Fearing, does that

answer your question?

MS. STRAND: I'm sorry were you asking me,

Your Honor?

,JUDGE SIDDOWAY: No. I was asking my

colleague.


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MS. STRAND: Oh, thank you.

JUDGE SIDDOWAY: If it did answer his

question, I have another question or a point that I want

to make about your concern about the fact that the

property cards were printed on the day they received

your request or on the day after the County received

your request. You know, like many agencies, our court

is going to all electronic records. So, if someone

wanted to have, for instance, copies of some of the

documents that have been filed with our court, we would

not have a hardcopy on site th.at we could provide them

that preexisted their request. We would have to print

it out, and it would have printout date of today. And

it appears to me that that's what's happening with the

County. They only had the information in electronic

form and had to print it out in order to provide you

with the information that was preexisting.,

In that circumstance, wouldn't you want them

to print out the data that they had in a preexisting

form so that you would be able to see what their records

showed?

MS. STRAND: Your Honor, I specifically

asked them to print out the actual computer download.

The Property Record Card is a templet that is created

and filled in with specific data by the assessor. So


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the Property Record Card is not the actual computer

data. It's computer data that has been presented in a

specific way.

The problems -- the many problems with the

Property Record Card are that there are a lot of errors

in their templet because they are not printing out the

data that is actually in the computer. There is no way

to know when the errors that are in this templet were

created.

I asked for what was in the computer. I

specifically ask~d, Just dQwnload your computer data

about what you're alleging as how my value was

determined.

When you put it in the format of the

Property Record Card, you are creating data which does

not reflect what is, in fact, in your database.

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JUDGE SIDDOWAY: Well, do you actually think

that someone at the County, like, manually inserted that

information rather than pressing a button and having a

computer software program generate a record?

MS. STRAND: Actually, I know for a fact

that what you just said is true. l have two Property

Record Cards created on the same day. One has an -- I'm

sorry. One does not have.an inspection date, and the

issue was when the inspection occurred. The second card

------~-----------------·-----------------Strand vs. Spokane County et al.

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created on the same date has an inspection date. So as

to your question, yes, thi Spokane County assessor does

manipulate the data that they put on the card.

15 minutes is up.

THE COURT: Thank you, Ms. Strand.

My

We

appreciate your input,

Mr. Binger.

MR. BINGER: Good morning to the Court and

Ms. Strand.

Attorney.

I'm Robert Binger, Deputy Prosecuting

I represent the County in this matter.

Ms. Strand opened up with the Counties violated every

provision of the Public Records Act which I think that,

kind of, underscores the significant difference in

opinion that we have. We believe that we have met all

the requirements of the act.

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And Judge Fearing, with his question, really

capsulated the issue of Ms. Strand's concern throughout

all these cases, not the public records themselves, is

that they don't reflect how she believes the office

should run. She believes it doesn't run in accord with

84.40, and she doesn't think it runs in accord with

Thurston County. It may not. I don't know.

But, so far as the records go, all we can

provide her is what we have, and that's what we've done.

Her request came in in 2019. We had three

Sttand vs. Spokane County et al.

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installments -- actually, four installments and then

provided a summary after that of our efforts. She filed

a new formal appeal with our public record's officer.

So it got -- it got scrubbed through that process.

the public records officer believed we acted

And

appropriately. We~t to Superior Court with Judge Hazel,

he believed we acted appropriately.

And I don't really -- I guess, I'm kind of

open for questions from the Court if you have any. We

feel very comfortable. I didn't really hear any issues

that Mrs. Strand raised that ,.aren't covered in my brief

or if they needed to be covered at all.

JTDGE SIDDOWAY: I have a question for you.

I mean, it does not knowing how your office operates,

it does seem to me that my assumption would be that when

an annual assessment is done, and because state law says

that the preferred method bf arriving at the assessment

is using comparable sales, that your person who is

responsible for preparing the assessment would be

looking at some comparable sales, identifying sales,

that they believe were comparable and arriving at a

valuation based on those sales. And I would think that

there would be some record of what sales were looked at,

but apparently that's not the case because no record

like that was produced. So can you describe for me how

----------,~----------·---* ___ , ____________ _ Strand vs. Spokane County et al.

April 27 1 2021

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that process ta.kes place and why those record -- a

record like that isn't created.

MR. BINGER: So to the extent that's what

Ms .. Strand requested, that information is contained on

the property card.

JUDGE SIDDOWAY: The property card

identifies the comparable sales that were relied upon?

MR. BINGER: To the extent that we have

records on that, that's where it would be correct. And

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it 1 s not -- she would suggest we 1 re withholding records

which is simply ppt the case ... There would be -- there's

no -- obviously, no reason to do that. It would be

unlawful, and we've made every effort throughout the

years with Ms. Strand to provide her everything that

she's requested.

JUDGE SIDDOWAY: I guess, I did have one

question in response to the motion to submit additional

evidence which has been referred to this panel for

decision. You responded to Ms. Strand's motion by

pointing out that the document that she produced, page

27 of a 2020 draft manual from the assessor's office, is

identical to a document that she had provided as an

example of what she called ProVal coding sheets that she

obtained from Thurston County. Do you have an

explanation for why that wasn't identified in responding


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to her original request?

MR. BINGER: 'I don't .. It wasn't -- it

wasn't discovered ~hich is, as the Court knows, doesn't

mean the search wasn't thorough, but, in fact, it wasn't

disclosed. But I think the point is it was in the

record. It was attached to her complaint. It was not

new evidenc~, and she could have raised that issue

before Judge Hazel had s~e chosen to.

JUDGE SIDDOWAY: Well, I think what she

didn't know until she submitted subsequent public record

request is .that th~ .document;.. actually existed as page 27

of a draft manual that was in the County's possession.

Although, I have to say, it 1 s not clear that it was in

the County's possession back in 2019 when it responded

to her record request since the cover of the manual

indicates that it was -- it bears the date of

January 1st, 2020.

MR. BINGER: I share that question,

Your Honor. I don't know the answer to that. I didn't

understand though that Ms. Strand had gotten that from

Thurston County. l\re we --

JUDG~~ SIDDOWAY: Well, my understanding is

when she provided Mr. Hodgson, back in the spring of

2019, with an example of what she thought was a ProVal

code sheet, she was providing l1im something she had


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received in 2010 from Thurston County. And her

complaint in asking to submit additional evidence is

that then she submitted subsequent public records

request last year in which -- in response to which she

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o·f the draft manual is the same document that

Mr. Hodgson previously said he didn't recognize.

MR. BINGER: Right. And I'll start at the

end of your question. Mr. Hodgson did indicate he could

not locate that document not withstanding his search,

but I believe Ms. Strand did acquire that from

Spokane County at some earlier date, not

Thurston County.

JUDGE SIDDOWAY: Oh, okay.

MR. BINGER: And then I just circle around

that it was in the record. She, you know, she'd asked

for it. She didn't get it, and she attached it to her

complaint to Judge Hazel. So it's certainly not new

evidence now.

JUDGE SIDDOWY: Okay. Well, then you've

corrected me if she had obtained that from

Spokane County. I was under the impression she had

obtained it elsewhere.

MR. BINGER: I don't have anything further.

I'd be glad to answer any other questions.


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J.UDGE SIDDOW}\Y: Just one other question, as

f a r a s t h e f a ct o :r s , s he I s a· r g u i n g the 1 9 f a ct o r s t h a t

she has identified from other proceedings, press

releases, case law, hearing transcripts, my

understanding of applicable law is that before she goes

before the County Board of Equalization if she

challenges the valuation of her property, the County is

required to disclose the factors it's relied upon. And

the County actually does not have to rely upon anything

other than comparable sales. It can rely on other

factors. And, if.so,.it has to .. disclose those, but it 1 s

not required to consider other factors.

do you agree with that?

Is that your --

MR. BINGER: Your Honor, I don 1 t practice in

front of that board, and I'm not that familiar with it.

But I do -- from what I understand from that board, I

believe you're correct.

JUDGE SIDDOWAY: Okay. Well, I have no

other questions of you.

MR. BINGER: All rtght. Thank you.

JUDG8 PENNELL: If there's no other

questions, we can submit this matter. I appreciate both

parties's submissions and their helpful answers to

questions today.

Ms. Strand, thank you for your diligence in

._ ______ ,,_-~ ..... .--__.,.....=--,_wi_=••-• ----...--.. •-,a~""'·-------------'


April 2'7 1 2021 0

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19 __________ ......__.:......,......,., - •' - M_£_...,.... ________ _.... ____ _

participating with our technology. This matter is

submitted.

MR. BINGER: Thank you.

JUDGE PENNELL: Thank you.

MS. STRAND: Thank you.

(This conciudes the matter.)


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STATE OF WASHINGTON

COUNTY OF SPOKANE CERTIE'ICATE

I, TRACIE N. BLOCKER, an official court reporter in and for the State of Washington, do hereby certify:

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That I am a certified and official court reporter for Spokane County Superior Court at Spokane, Washington;

That th2 foregoing hearing was taken on the date and at the time and place as shown on Page 1 hereto;

That my foregoing is a true and correct transcription of my shorthand notes of the requested hearing transcribed by me or ~nder my direction, including any changes made by the trial judge reviewing the transcript, pursuant to LCR 80;

That I am in no way related to or employed by any party or counsel in this matter;

That I have no financial interest in the outcome of said litigation.

WITNESS my hand and seal this 30st day of July, 2021.

Tracie N. Blocker Certified Court Reporter #3157 Spokane Superior Court Department #11

SEAL OF OFFICIAL COURT REPORTER ~-~-------:---------1 Strand vs. Spokane County et al.

The Court Reporter's Certificate

TTACHMENT 3 ,

RECONCILIATION OF ASSESSORS PAGES

NON-CARD PAGES

Description

Assessor 2/20/19 acknowledgemt

(alpha is cverlu::iping page)

".Assessor-Page#

1

Strand 2/24/19 PRA request (incomplete) .

Assessor 4/21/19 cover

Assessor 3/8/19 Cover & An~wer

Strand 3/8/19 PRA complaint

Assessor 3/15/19 Cover

Stran~ 2/24/19 PRA request (incomplete dupe) ..

Assessor 2/21/~9 cover_(.9upe)

Assessorspreadsheets(3/15/19)

Assessor Final Rwreports (3/15/19)

Assessor. 3/22/19 cover (internet referr~lsL

" " information -···-- ..... _ ...... ,-........ _ ......... .

Stran.d .3/??L~~R~.cCJr11_plaint

Assessor 3/27 /19 allegations

Strand 3/28/19 complaint

Assessor 4/4/19 allegations

Description

Assessor 2/21/19 card

Strand 2/24/19 cards

Assessor 3/8/19 cards -'····· -----······-- ···----

Assessor 3/14-15/19 cards

CARDS

4-6 (a) 6-7 (a) 14-25

34

35-36

37-39 (b)

39-40 (b) 41-53

54-161 622-623

Page Count

1 3

Page Count

2 6

8

460

47.6 .,.......,~,r,~W'Y""

160

476 636

From: To: Subject: Date: Attachments:

/~j'.[Q!J rmstrand@hotmai!.com Strand PRR 2-20-2019 3 Friday, March 15, 2019 3; 19:00 PM

e&B 2-20-19-Strand c1arification.Qdf !and tvae and method couoiii,~J.sx ;!31720 201S,pdt 231720 2016.odf 180071: I of 8 pages CP 7 54-761 == ------- 2015: I of 8 pages CP 890-897 strandPRR201SSales.odf -- -- 2016: l of32 pages CP 898-929 StrandPRR20.l6Sa1es.12ctr ~ 2017: I of36 pages CP 930-965 ™:r __ ___.: 2018: I of 378 pages CP 966-1344

lZ~:U~arnci: - l 7355.9014PRC: l OF 6 pages CP 1345-1350

RE: Strand PHR 2-20-2019 3

Patricia Strand

Attached is installment 3 of your referenced request for public records. The Property Records

Cards contain information pertaining to your clarification of your original request, i.e.; sold

property sale dates; sold property address; sold property parcel number; sold property land

type and building characteristics. Note: Photographs for comparable sales are on the

Assessor's website under parcel information. https://www,sookane~nty.orn/219/Assessor;

Aerial photos for each property and sold information display on Spokane County SCOUT

MAPS: h!tQs;[LcQ.SQQ.fill.D.e.CQUOtY..org/scQUt~gL7elQ=lZ276,9111.

Clarification: Were you requesting Pictometry aerial images? These images display on SCOUT

but not all angles. If more angles are needed, please contact us. Item B-13, "PROVAL code

sheets identifying and explaining Market Adjustment and Obsolescent Depreciation." It isn't

clear what your requesting. These are common appraisal terms covered in appraisal theory.

Additional information: Real estate excise affidavits are linked to the assessor's website under

Parcel Information using the parcel number. h!w:LLwww.soQkg_necouruv.org/219L8ss~s:&r:;

Additional information, such as sales, is available on the Assessor's parcel Online Services

parcel downloads: b.llgs:LLgisda~og-spokan_fcounty.opeociilta.arcgj_u;gmLoage.sL,oarcel:

data-file-dowol~

The attached files include Property Record Cards for all sold parcels; Neighborhood Final

Review Reports (sales analysis pertaining to value conclusions)

The attached information includes clil relevant sa!es inforrr.ation for each year; analysis used to

develop values, property characteristics for sold prnperties; Specific dates when values were

posted;

ASSESSOR - PAGE 35 G,L\

ATTACHMENT 4

=

ASSESSOR CAHDS ON NEIGHBORHOOD 231720

1

2

3

Owner

!Strand

) (new date - no$ change, picture)

(new date, new values, no picture)

(new values and dupe: 1349-1350)

! Martin (dupe: 1263-1264)

Thies 17355.9012

(new date - no$ change)

(changed dates & new$)

(changed, dat_es & .old$)

4 _ !Eberle (Dupes: 7(;0-761,}087-1088) lwarne

5 (changes dates & values)

6

7

8

9

ts1Jll!van 17354.0201

(changed values)

(changed dates & values)

(changed values) ·


(ch.:ir1~t:!d values) Henington 17273.9113

(Dupes: 908-909)

10 Cummings 17353.9048

(Dupes: 910, 942, 1111)

11 Cummings 17355.9049

Rippy

12 (changed values)

13 Fryett 17363.9043 (928)


14 Fryett 17363.9044


15

16

McDaniel


(changed data to picture)

Funke

(changed dates & val1..1e.s)

Kurtz 17361.0101 17


18 Kurtz 17361.9049

·Mechling

19 (changed dates & values)

Name (duplicate CP pages)

-· ---·~-·-~i~"·---------------! Printed CP No. l Assessmt Year Property CP Quantity

2/21/2019 730-731

3/15/2019 1173-1174

3/12/2019 1345-1346 1347-1348

I 3/7/2019 754-755

3/7/2019 756-757

3/14/2019 920-921

3/15/2019 958-959

3/15/2019 1169-1170

3/15/2019 758-761

3/14/2019 890-891

3/15/2019 956-957

3/15/2019 1073-1074

3/14/2019 892-895 914-917

3/15/2019 960-963

1129°1132

3/14/2019 896-897 924'-925

'•

3/15/2019 946-947 1233-1234

898-899

3/15/2019 i 987-988

i 3fi412019 I 900

Worksheet

Worksheet

05/02/2015

06/12/2017

Worksheet

Worksheet

Worksheet

06/12/2017 Worksheet

Worksheet

05/02/2015 06/12/2017 Worksheet

05/02/2015 05/04/2016


05/02/2015 05/04/2016


Worksheet

2016-2018

13/15-12019 I

'1 3/15/2019 I 1199 2013-2018 f .................. ··-·····-, ---~-- ---·---· i 3/14/2019 I . 902-903 05/04/2016 i : 1 , 948-949 06/12/2017 ' ' I 3/15/2019 [ 1235-1236 Worksheet ; ............ ,_ . .. .. ... ~

/ 3/14/2019 [ 904-905 05/04/2016

j 3/15/2019 ! 950, 1238 ! (page 1 only)

13114120191 906-907 I 05/04/2016 I 3/15/2019 I 952-953 I_ 06/12/2011

-r 3/14/2019 r 912-913 05/04/2016

i 3/15/2019 ! 954-955 I Worksheet ' , I i 1 1309-1310 I ! 3/14/2019 / 918-919 -- /

_ J~/~5/2019 \ 1157-115?\ Worksheet

! 3/14/2019 \ 922-923 : 05/04/2016

\ 3/15/2019 i 1203-1204 i [ 3/15/20-19 I 1223 ·-· I .. ,-

: 3/14/2019 I 926-927

i 3/15/2019 I .

L -

Worksheet

2013-2018

05/04/2016

06/12/2017

R

R

R

R

R

R

R

R

R

Agri

R

R

R

R

R

R

Agri

R

8

2

8

2

6

16

8

2

2

1

6

3

4

6

4

4

1

6

1

:=

(;5

Owner

Gorst 20


21 Hopper

(changed dat~s & values)

22 Edwards (936-937)

, (changed dates &y~l~es)

;;--·: Aitken

_ J_Jc~a,~~-e-~date~_~yalue~) Matson 17361.0109

24 (~~~~jed dates & values)

25 ; Matson 17361. 9071 ...... , .. ·;·· ..... ····---···'"'"'······"'···· ....... - - ...

26 /Volz 17271.9067 i-

27 '•Volz 17271.9068

28 ishaffer ETAL 17271.9069

29 lshafffer, Terry 17275.9079

30 ·Mor~an

Olsen

Utilities Ost #1

34 1Cutler 17272.9043

35 1 Cutler 17273.9095

36

Brown

41 : FoS!E:!!!IirnothyJ 42 FostE:!rtStephen 17373.9107

43 : Foster, Step~~~ _17373.9108

44 Foster, Matthew 17355.9037

45 :Noble 46 'Shaw

47 Burgi 48 O' hara

49 Crowston

50 Phillips

51 Bond

Margitan 17274.90?6

54 1Margitan 17274.9108

55 iMargitan}7274:9110

56 . Haynes

57 Figg Collee~17274.9091

58 Figg Living Trust 17274.9091

59 Ryken 60 Hanna 17274.9109

ASSESSOR CARDS Oi'l NEIGHBORHOOD 231720


Printed CP No. i Assessmt Year Property CP Quantity i

I 3/14/2019 930-931 I 06/12/2017

: 3/15/2019 966-967 Worksheet I - ... ·-- - ·•

i 3/14/2019 932-933 06/12/2017

: 3/15/2019 1007-1008 ····\······--······

' 3/14/2019 934-935

, 3/15/2019 1017-1018 , Worksheet ············· · ·rii;i4;2019· 938-941 ·1o611212017

1 3/15/2019 1077-1078 Worksheet ....... --···-· ·-·-··.,···-"' --- ·! .................. , ......... .

.3/15/2019 944-945 ' 06/12/2017

i 3/15/2019'

...................... , ... 3/15/2019

3/15/2019 . 3/15/2019

3/15/2019

3/15/2019 . ' 3/i5/2019 :

••••--•---· .. ·-· -',[ ..

3/15/201_~j_ 978 3/15/2019 981

' 3/15/2019 i 9.8.3 ----·· '. -·/ -

' 3/15/2019 I 1011-1012 , · 3/15/2019 I · 985-986

3/15/2019 989-990

. 3/15/2019, 991-992 · :;j/is/2019·; 993-994 . I··--"···-····

/ 3/15/2019 995-996

' 3/15/2019 I 997-998 . ····················!·····················

l 3/15/2019 i 1013 '{··· , i· -·- ·-······r--

/ 3/15/2019 1015-1016 ····· n/15/2019

3/15/2019

3/15/2019 3/15/2019

Worksheet

2016-2018 .2013-2018

Worksheet

2018

Worksheet

Worksheet

Worksheet 2013-2018 !

Worksheet Worksheet Worksheet

. -

3/15/2019 Worksheet

3/15/2019 1019-1020 Worksheet

3/15/2019 [_ 1023-1024. _ Worksheet

3/15/2019: 1025-1026 .

3/15/2019_ 1027-1028

?/15/2019 1

1029-1030 ~j15/201( .. 1039-1040

3/15/2019 1043-1046

3/15/2019 1031-1032

3/15/2019

3/15/2019· 1035 3/15/2019 1037-1038 3/15/2019 1041-1042

~ ·-(· senseless I

........ --··-······-···--···· - t·--· Worksheet

2013-2018 2013-2018 Worksheet Worksheet

R

R

R

R

R

R

R

R

R

R

R

R

Agri Agri

R R

4

4

4

6

4

2

1

1

2 2

2

r=

Owner

61 I Hanna 17275.9078 62 /Else

1

63 j~ramer 64 ! Kuhar-Pitters

1

65 !Hartman i

66 iCrusch

67 I ~~yne _ 68 I Nydegger

1

69 jWheeler

70 /,Klein 71 Keegan 72 fDibler 17352.9006 73 liibler 17355.9030 74 I Dibler 1_!355.9031 75 \Anderson ...... .. -1···

76 !Brakel 77 !Annanie 78 jSchuyler 79 !Davis 17352.9022 80 !Davis 17352.9023 81 !Schlosser 17352.9025 82 ]Schlosser 17352.9045 83 I Ludwig ---

84 !Thorne ,'--·

85 )KaI~Y 17352.9044 86 jKaley 17353.9054

87 !Kaley 17355.9055 I ----

88 I Bjork 17353.9034 89 /Bjork 17355.9032

90 \ ~jork ~ 7355.9033_

91 jKau!rr1~n 92 !Talley

·i·-·

93 !Tannehill 94 iHillyard

I --

95 jDoran __

96 J!'JClrdstrom 97 !Ehrler 9il- !stokes

·(

99 1 Spoerhase + -- --·---100 !Gifford

l

101 IEby t "'

102 iMiller i

103!Lund . i·

104 '!Akers 105 1 Kiberash

106IH~ndershot

ASSESSOR CARDS ON NEIGHBORHOOD 231720


Printed I CP No. I Assessmt Year I i

-3/15/2019 1051-1052 Worksheet 3/15/2019 1047-1050 Worksheet

!~~!~I6~: I ~6!~~~6:: :~;~:~::: !~~:~~~i: I ~~:~:i6:~ :~~~:~:::

Property CP Quantity

2

4

2

2

2 --- I 3/15/2019f1063-1064 Work~heet ---------+------- -- - --------- - _______________________ , _____ _

_ i 3/15/20!_~ 1065-10_~6 Worksheet [ 3/15/2019 1067-1068 Worksheet

-1 ---

-) t}!~icii: 1071-1072 Worksheet

I 3/15/2019 1075-1076 Worksheet Fi/15/2019 1183-1184 Worksheet

----+--

!1-_-~_1_1 __ 5_ /2-019 3/15/2019

--13/15/2019

Worksheet

j 3/15/2019 1083-1984 Worksheet I 3/15/2019 1085-1086 Worksheet i 3/15/2019 1089-io'~n Worksheet

········!····

! 3/15/2019 1093-1094 Worksheet

i 3/15/2019 1095-1096

_ --- - -- -l 3/15/2019 i 3/15/2019

1103 1097

Worksheet 2013-2018 2013-2018

13/1.5/2019 1099-1100 Worksheet ···-········-

I 3/15/2019 1101 2013-2018 i 3/iS/2019 I -

_3/15/2019

[3/15/2019 i·······---~ -

/ 3/15/~919

1113 1201

1105 1189

senseless senseless 2013-2018

2013-2018

j 3/15/2019 1191-1192 Worksheet i 3/15/2019 1107-1110 worksheet +---13/15/2019 1115-1116 worksheet 131is12019 1111-1118 \~~~k;h-eet

, 3/15/2019 1119-1120 worksheet

! 3/15/2019 1121-1124 1 worksheet I I 3/15/2019 1125-1128 worksheet I -----------

I 3/15/2019 \ " --- - ·" ··-··

/ 3/15/2019 I 3/15/2019 1137-1138 worksheet 1---- ----------------- ----

13/15/2019 ! 3/15/2019 1141-1144

) 3/1?/?Q19 1145-1146 \ 3/15/2019 1147-1148

worksheet worksheet worksheet

---1 3/15/2019 1149-1152 worksheet

3/15/2019 1153-1154 worksheet

3/15/2019 1155-1156 worksheet

R

R

R

R

R

R

2 2

2

2

2

2

4

R

R

R

r--- ·-- 2

I 2 I

! 4 R j

RI 2

2 Agri i -- 1

- - -------1-~

Agri i 1

-~-------- L___ 2 Agri 1 1

Agri I ' ~~ri l

1

1 Agri I

.,J'.ligri ) 1 _

1

R I ! --

{ I ~ R

R

R

R

I --\ :

2

2

3

ASSESSOR CARDS ON NEIGHBORHOOD 231.720


107 lstreet '

108 JCraig

109 !Long !>····-·-·-···

110 tX()cum 111 Oconnor

112 Barker

113 iZinn [·····

114 :Abeyta 17355.9028 •P•••t••• h•-••"•" ,. •••

115 iAbeyta17355.9029

116:,Hogan 1·· .... '

117 !Tolman

118 jGilles 17361.0102

119 i Gilles 17361.3048 j - . --

120 !Angel

121 ;Dressel 17361.0111 - '

122 iDressel 17361.9046 -· 1

123 i Olson 17361.9001

124 ]0lson 17361.9003

125 icordill

126!Avista Corp 17361.9064 /· - ---···-·-- -

127 \Avista Corp 17361.9065

128 IAvista~C>rpl 7363.9069

129 jRowe

130 i Collins

~~l!Vvhippl~--132 : Pham 17363.9052

133 · Pham 17363.9054

134 1, Morton

1:3?]Wallender

136 Thain

137 !Wallen

138 iThompson ' -

139 ! Wash Dept Parks & Reel 7364.0101 I ,,------··-- ,

140 I Wash Dept Parks & Rec 17364.0201

141 (Wash Dept Parks & Rec 17_3_64.0202

142 iWash Dept Parks & Rec 17364.0203

143 )w~sh D~pt Parks & Rec 17364.0301 -------------!--------- --- --- - -- - -144 i Wash Dept Parks & Rec 17364.0401

~ , .. - - . .. . '"

145J\Nash Dept Parks & Rec 17364.0502

l~§.\Nash [)~pt~arks & Rec 17364.0601

14 7 \ Wash Dept Parks & Rec 17364.0603 I

148 ;Wash Dept Parks & Rec 17364.0701 l --- -

149 ! Wash Dept Parks & Rec 17364.0801

150 iWash Dept Parks &Hee 17364.0802

151 Poss 17364.0508

152 Poss 17364.0512

1281-1282 i 1289-1292

worksheet

2013-2018 -

Worksheet

2013-2018

Worksheet

2013-2018

2013-2018

-

Worksheet

Worksheet

2018

2013-2018

2013-2018

2013-2018

2013-2018

2013-2018

2013-2018

2013-2018

2013-2018

2013-2018

\/Vorksheet

Worksheet

R

Agri

R

R

R

R

R

R

Agri

R

R

R

Agri

R

R

Agri

,l\~ri Agri

Agri

Agri

_t-~ri Agri

R

R

R

Agri

Agri

R

R

R

R

Agri

Agri

Agri

Agri

Agri

.t\gri

Agri

Agri

Agri

Agri

Agri

Agri

Agri

R

R

1 1

1

2

4

4

ANALYSIS OF ASSESSOR CARDS;QN NEIGHBORHOOD 231720

II.Jame (duplicate CP pages)

Owner, Parcel, (facts about cards) I Printed ! CP No. I Assessmt Vear Property / CP Quantity

153 Ellifritt

154 ;Belknap

155 IWade

156!West

157 I Dietzen

158 j Morse 17364.0906 • I

159 i Morse 17364.0907 -' .. -.....

160 \ Larkin 17364.9019

161 Larkin 17365.9074

162 Brodrick

163 Whicker

164 Bell

165 Howes 17364.9042

166 Howes 17364.9068

167 Hedin

168 i Mahan 17364.9060

169 ! Mah~n 17364.9067 ( ,.

170 ,Ostrom l ---·-·--

171 iBuell j-··········-•-·-··········"'······

172jRussell

1731 Evans

' 3/15/2019) 1283-1286

3/isiioigJ 1281-1288

3/15/201911295-1296

3/15/2019 1305-1306

3/15/2019; 1307-1308

3/15/2019 i 1311-1312

3;1s/2q~~Jn13-1314 3/15/2019 1 1315-1316

Worksheet

Worksheet

Worksheet

Worksheet

3/15/2019 1339-1340 Worksheet

3/15/2019 I 1317-1318 Worksheet

3/is).2oi9 I 1319-1320 Worksheet

3/15/201911321-1322 Worksheet

3/15/2019 I 1323 . 2016-2018

3/1512019 l 1331-1332T ·2013-201s '. f"

3/15/20191 1325 I 2013-2018 ,}/~s/2019' - 1321 --········-··- 2016-2018

! 3/15/2019

· · I !Ji:)~~i: I 3/15/2019

I 3/15/2019

R At::ri Agri

R ------··---~

R

R

R

4

2

2

2

2 2

2

2

2

2

1 1

2

2

4

2

2

395 TOTAL CARD COUNT: 173

(2-4 CP pages per card) R is residential; A is Agricultural

The Assessor alleged "636 pages of responsive documents" -- Assessor-Page 1 through 636. The 636 ·

pages included 476 pages of property record cards ("Card"). This analysis of those 476 pages prove

Cards are not responsive and the 636 number is erroneous!

1. The 636 pages include 53 blank pages. Blank pages are nonresponsive: CP: 901, 911,

929,943,951,969,982,984, 1006, 1014, 1034, 1036, 1054, 1098, 1102, 1104, 1106, 1112, 1114, 1164, 1182,

1189, 1200, 1202, 1214, 1216, 1218, 1220, 1222, 1224, 1226, 1228, 1230, 1238, 1248, 1252, 1258, 1266,

1268, 1270, 1272, 1274,1276,1278, 1280, 1294, 1298, 1300,1302, 1304,1324,1326,1328=53

2. The 636 pages include Strand's PRA requests, clarifications and complaints. These are not the Assessor's

documents:

a. 2/24/19: CP (732-734) + (765-767) + (736-741) = 12 pages

b. Complaints: 762 + 1361 + 1364 = 3 pages. . . . . Total 15 pages

3. Chief Deputy Assessor Hodgson's email writings were an acknowledgement and allegations about the pages he

produced. These are not responsive because they are not responsive and did not exist before request/

clarification filed. ,

a. CP 729 azcknowledgement = 1 page b. CP 735 = 1 page

c. CP 742, 763-764, 768, 1351-1352, 1362-1364, 1365 Allegations: = 10 pages

4. Duplicates are shown next to name. This analysi5 shows 9 dupes.

5

TTACHMENT

* Strand inspected pages for sales and reported them here. RCW 84.40.020 requires assessments as of

1/1/annually. RCW 84.40.030 requires value at 100% of sale. If sold property is not valued at 100% of sale

uniformity (Article 7 Section 1) means noone is to be valued at 100% of sold properties values.

**No. 22 -- Violates Article 1 Section 7 of Constitution -- Privacy -- per notes on card for 9/10/2018.

Owner Clerks Paper I

Sale Date : Sale$ Value Date: Value$ Value Date: Value$ Sold

1 Martin 754 03/13/18 ; $670,000 07 /01/18 ; $584,400 I R-lmp I

Thies 10/17/17 ; $405,000 07 /01/18 ; $382,700 ' 2 756 l R-lmp . I

3 Eberle 758 08/30/17 j $450,000 07/01/18 ; $448,300 07/31/18 j $489,000 R-lmp

4 Warne 890 01/08/14 j $134,500 05/04/14 I $128,920 05/02/15 1 $132,020 R-lmp

5 ! McKee 896 04/06/15 I $255,000 05/02/15 j $231,400 05/04/16 j $246,900 R-lmp

Henington 898 10/12/15 I $165,500 05/04/16 I $154,600 I

R-lmp 6 I

7 Cummings. , 900 • 1 03/31/16 i $50,000 05/04/16 j $47,500 07/01/18 j $47,500. Agland ..

' I I

8 Rippy 902 09/09/15 I $135,000 05/04/16 I $135,900 I R-lmp

9 Fryett 17363.9043 904 10/26/15 j $180,000 02/01/16 j $169,800 05/04/16 I $110,000 R-lmp

10 Fryett 17363.9044 906 10/26/15 j $220,000 05/04/16 I $214,770 06/12/17 I $219,770 R-lmp

11 McDaniel Trust 912 08/25/15 I $297,500 05/04/16 I $289,900 I R-lmp

12 Gorst 930 09/14/16 I $404,500 06/12/17 I $382,900 I R-lmp

13 Hopper 932 09/30/16 I $373,000 06/12/17 I $361,220 I R-lmp

14 Edwards-Kevin 934 06/23/16 ! $326,900 06/12/17 ! $297,360 I R-lmp . 15 Aitken I 938 12/20/16 ! $403,000 06/12/17 I $370,000 I R-lmp

I I -10/22/15 ! $302,000 05/04/16 ! $288,800 16 Matson 944 I R-lmp

I

17 Volz 968 06/07/17 ! $300,000 06/12/17 ! $126,500 07/01/18 ! $126,500 Ag land

18 Heidt 993 06/02/16 ! $149,100 06/12/17 ! $98,290 I R-lmp I

19 Phillips 1023 08/06/18 ! $250,000 Worksheet ! $213,870 I R-lmp ' Annanie 1083 09/07/16 ; $499,900 06/12/17 ! $488,800

I R-lmp 20 I

21 .. Schuyl~r . < lQ&S 04/27/16 ! $29'4,000 ', . . . . . . '• ' 05/04/16 : $336,600 ... 06/12/17 ! $374,900 R-lmp

Tannehill 06/15/18 : $392,000 07 /01/18 : $412,200 I

22 1117 I R-lmp I I

07 /05/18 ; $520,000 I

23 Street 1159 Worksheet ; $453,700 I R-lmp I

24 Thomps(m 1265 07/17/17 : $157,000 07/01/18 f $141,120 ' Ag Land .. I

25 West 1305 07/25/17 ; $140,000 07 /01/18 j $145,900 • R-lmp I

26 Russell 1341 01/23/19 1 $270,000 Worksheet 1 $212,400 • R-lmp I

R-lmp is residential improved; Ag is Agricultural; All data is taken from Assessor's property record cards

"[l,

0 \

ATTACHMENT 6

"ll_,

17355.9014 STRAND, PA TRICIA N 13206 W CHARLES RD ADMINISTRATIVE INFORMATION

P.l\R•'.:EL NUMBER 17355. 901<1

~ Parent Parcel Number

Property Address 13206 W CHARLES RD

Neiohborhood 23i720 SHORS: RNGE ~.REA 35-27-41

Property Class 511 S- Household, single famil/

TAXING DISTRICT INFORMATION

Jurisdiction COD

Area 001

Corporation USA

Dis~rict 0920

R0utin9 Numter 6

Site Description

T-::>pogra~hy:

Pub, ic: ,~r: l, ~ ~ r~s V

st. ""e,? t or f:;:oad:

Ncighbvr.h<,,:,od: :;_,and Type

2-::ining: 1 fronts Enhancement #1 Legal f.;.cres; 5~0000

OWNERSHIP STRAND, ?ATRICJA N PO BO>: 312 NINE MILE f.l',LLS, v/A 9902E-

RESIDENTIAL Assessment Year 0Si03/2013 05/04/20:4

Reason for Chang~

~ 20~~v;~ :tev?l

VALUATION 200000 Posted True Ta.x 183700 182300

383700 382300 VALUATION L 200000 200000 Assessed Valus e 183700 182300

'(!) 383700 382300

of TRANSFER OF OWNERSHIP

Printed 02/21/2019 card i;o. 1

Date

09/05/2000

09/01/:?000

08/1611999

BARKER, ROBERT & PATRICIA J

STRAND, PALMER D

WANG, GEORGE & CEAN ,J

VALUATION RECORD 05/0212015 05/04/2016 06/12/2017

Reval Peval Reval

175000 150000 150000 192700 195700 216000 367700 345700 366000 175000 150000 150000 192700 195700 216000 367700 345700 366000

Bk/Pg: D, SlOOOOO

Bk/Pg: D, so

Bk/Pg: 0,. $17.DC\OO

07/01/2018 ,1orksheet. @

~eval

~~~~gg@® 150000 247900 397900 399600@ 150000 150000 247900 249600 397900 399600©

LAND DATA AND CALCULATIONS

Ea.tir.:g Measured Soi 1 ID Acreage

-or- -or-Actual Effective

Fl."ontage F:ront.ase

S.OOOG

Table Prod. .Facto.r -vr

Depth Factor E.ffecti ve -or-

Depth Square Feet

1.00

Base Rate

AdJUSted Rate

30000.0D 30000.0G

Extended Value

1SOOOO

1nilu.ence F2r:to:r Val1;e

1:?00VD

511

0 M t-c.

ul

)

~ -= \ \;--\ls

(~

L C\~u.::-> Do~~ ~ o-r \j D {Z.X'._ Q vJ

Appr: Appraisal Not.es 04/26/2016 (JS119i P.eVal inspection update. Adjusted land tables. Lower level removed based on owners appeal photos, changed to walkout basement. Added lean-tos, can't measure shed by waterfront. from overheads. Land changed with t.he ne:iv 59/2:> tables. 7/13/10 Consider resket.ching as sfr/basement. w/o with full basement finish. 6/9/10 jh [98) BE-09-0265 Reviewed transcripts from past BTA ,;:ase~ provided by the appellant., and taxpayers admi t.ted in testimonry they have a "full finished basement•' O!'

basement/J.ower level, by our defini ti ion. ls ( l 02) placed 1900 sf of basement/11 finish for the 2009/2010 app~al. This information/transcript is retain1cd in Mr. Ark.ills fl.le for further r.r:::view. ::'28-/l(J ··t:(98) BTJ; --~;:,:,s. o0 -~:-.:, .S.dTr:-. :wleu ,:, <1ssE-,ss:;,:::':.~

Sup?lemental Card$

MEASURED ACREAGE 5.0000

Supplemenc31 Cards

TRUE TA_"'. VALUE

Supplemental Cards TOTAL LAND V,!\LUE

150000

E'JCOQ ®

-~ PHYSICAL CHARACTERISTICS

Style: 49 Ranch lSD0-2299 Occupancy: Single family

Story Height: 1.0 finished Area: 3848 Attic: NOnC!:. Easement: Full

ROOFING Material; Type:

Metal Gable

Framing: Pitch:

Std for class Nc1t. available

FLOORING Slab F,

Sub and joists 1.0 Ba$€ Al!owHnce 1.0

EXTERIOR COVER Virtyl 3.i.di ~g

INTERIOR FINISH

ACCOMMODATIOUS finished Rooms Oedrocros family Rooms :?orrr:al 0ining Rooms

B, J ,C,

HEATING AN~ AIR CONDITIONING Primary Heat.: Forced h(:tt air-elec

Lo;...:S:r Full ?a rt /Bsr:1:: 1 Upper Upper

l?LUMBING

S Fixt, f:.3.t~,.:; i:; :""ixt. B-~!:h~

F'i~:t.. C.ath:s Kit Sit;k Hatier: 1-:-=:-at Ext rB fixt

7:)TAL

l J 2 J 1

5 4 G

l 18

REMODELIHG 1-.'\lu KODERNIZATION ~..mount Gate

\-\ov0

32

L

[rolwFJ

IMPROVEMENT DATA

12

B EFP j ~\ !g51 I~

1 sFr Q --- ~ B-wo

@ 04

i

FrG

(576)

I ~ ~1 24

@

, 11

~:?~:: .. s-01-:1 Cl;:;s..;..

Cor:stru.::tion Woo,j frame

Concrete block

Exterior Feat8res DescriµtiO!:. EfP

1:alue 5::30

!-lS2.5ilO":;j

Base Area Floor Area Sq Ft 2048 l.D 2048

2048 8smt 0 Crawl

TOTAL BASE

Fow Type Adjusunent SUB-TOTAL

1800

0 Interio:-- Finish 0 Ext Lvg Uni ts 0 Basement finish

fireplace (s) Heating Air Condition Frame/Sidina/Roof ?lumbing Fi;t; 1&

Vt.her Features

SUB-TOTAL ON£ um 1 SllB-'!'OTAJ, 0 UNITS

Garages 0 Inteoral

$76 Atr. Gar;;ge O · At t. Carports

~:H;>J::.r.;::s 8: r

Value 176220

51480 0

227700

1.00% 22-1'"'(;~1

156:;G 0 !}

0 17·10

~OBS.S

\

2S00

2%785 ,..;:"'\ 296~8!;, ~

0 ~-\

0 0 Bsmt Ga,cage ~· ,

£:<t. features 5 IY '\

-,})";

SUB-T01'Af "-cg- _ Class/Grade •.· ' C'iJ,. ..::..:.-~--:--=c

?95:.t..i, ~

(LCM: :;oc.CC:)

SPECIAL FEATURES c@ 67 SUMMARY OF IMPROVEMENTS @@1 6§)

L'e~;crip-tion

D :BASIC DJ :C 02 :3SO 03 :3SO

VC>lue

2800 0

-3 -3

\ t-\-l_S:,

,-., JD ;--0.!J ti.&O:

Stry Const Hgt Type Grade

C ""D<IELL 0.00 A';/g-GOl ATTGAP. 0.00 01 POLSBLDG 10.00 Fai.r 02 Lf.P.NTO 10.00 0 fa::r 03 L£}l,NTO 10.00 C: Facr

Year Eff Const Year Cond

2002 2002 AV Alf

2006 2006 AV 2006 2006 AV 2006 2006 AV

Base Rate

O.QO 26.86 10. 80 8.05 8.B3

CA(LD \)Q\z__.S, .____,

Collector/Date Appraiser/Date

110 :?:,uno:o Tl S Ct!0~;:::01E

Fea'!'_-1_1res

1 N 'I. y

Adj Size or Rate Area

Computed Value

PhysObsol Market 1 Depr Depr Adj Comp

0 .00 4096 '£1f5540 10 s 93 26. 86 24x 24 0 0 0 11. 88 30;,; 40 1S 0 00

5.49 12x 4D .:,C 30 0 DD

100 100 100 100

y 6.02 Bx 20

Q;g 60 30 0 00 100

)

N 0-C Wo-<2-~

Neighborhood Supplemental Cards TOTAL IMPRQV!:MENT VALUE

Neigh 231720 AV

Val~8

235000 0

12100 moo :-oa

@

rl ('I") [""

Pi u

"""' ~

How 17355.9014 card "Pl'inted 02/21/2019" (CP 730-731) Works

Ref. Icard label(s) Pat's explanation: Values Pat's Explanation

1 !Assessment Year Worksheet [

$399,600:

- 150,00Qi

CP 730

CP 730 2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

4

I

IT total property value: ' ... ,·--··

[ L, Total Land Value

Te/T~t~I Improvement Value r ········ .... ·-················--· ... s.249.s£ii CP 730 and 731

CP 731 I EFP1.E~~losed Framed Porch

I 1 s Fr ?? Framed: I iB-wo !·,.····· I Fr G . I ..... )SUB-TOTAL ;

Basement walkout:

Framed Garage: :+

!Quality Class/Grade Avg- (-7% x Line 9):

! Grade Adjusted Value

! Dwell, Phys Depr !

(-10% x Line 10):

j ------i Dwell, Obsol Depr '

Dwell, Market Adj

Value

Polebld~,Value ..

Physical Depreciation::

(Marshall & Swift Value):

(-5% x Line 12):

Obsolescent Depredation:

(Manipulated Value):

(-7% x Line 14): , .... 1 =

(Manipulated Value):! .. i . -+

Leanto(s)ValuE: JManip~l~~~~--~~lue): J ~ B, Total Improvement Value I

5,530!

I 296,7851

I

154701. $317,7851

·-·-r-.fL.245 ·

$2~5,?40~

29,554 !

$265,9861 i

CP 731

CP 731

CP 731

CP 731

CP 731

11_2

99[ SUMMARY OF IMPROVEMENTS

· , CP 731 .,

$252,687 1

I 1L_688i II -1

··-···-·--·1·· .. -• ·-··--··--1 $234,999 1 CP 731; rounded to 235000. j

12,100 j CP 731 i

2,~~o; cp 131 (1800+700) . . ·;.1

t2~9,S.~!!l/ CP 731; . roundedto 249600

PROBLEMS ON CARD (CP 730-73Jl

1. "TRANSFER OF OWNERSHIP" statement is 100% incorrect. Strand notified the Assessor on May 9, 2009, during a physical inspection their card had the errors shown on CP 317 . The Assessor received a copy of CP 317 in each of the following proceedings based on the Assessor's allegation cards were the basis of 17355.90 l4's ;·ea! property ·,;alue and their card of 17355.9014 was erroneous:

• Strand v. Spokane County Assessor, SC 876339, 313409-m, Spokane County Superior Court 122011103, BIA Docket 10-258 (4 proceedings)

• Strand v. Spokane County, ct al., 132001238 (1 pro(:eeding) • Strand v. Spokane County, et al., SC 946'1-42, 34 i 909-Hl, Spokane County Superior Court

142010791 (3 proceedings) • Strand v. Spokane County, et al., SC 971897 nnd 943133,. 347222-III, Spokane County Superior

Court 162010797 ( 4 proceedings)

PROBLEMS ON CARO, CP 1m-731 continued 1-

• Strand v. State of WA. Board of Tax Appeals, et al., SC 97014-9, 355977-III, Spokane County Superior Court 172014383, BT A Docket 13-179 ( 4 proceedings

• Strand v. Spokane County, et al., SC 98222S, 365387-·IH, Spokane County Superior Court 182039091 (3 proceedings) ·

• Strand v. State of WA. Board of Tax Appeals, et al., 366979-III, Spokane County Superior Court 182402822, BT A Dockets 16-070 and 17-122 (3 proceedings)

• Strand v. Spokane County, et al., 376699-III, Spokane County Superior Court 20201077332 (2 proceedings)

The only sales on cards are in the Transfer of Ownership section which is 100% erroneous. The

Assessor's record of not correcting this section's errors means their following statement is false.

The Property Records Cards contain information pertaining to your clarification of your original request, i.e.; sold property sale dates; sold property address; sold property parcel number; sold property land type and building characteristics. CP 49

CONCLUSION: The card, CP 730-731, is not credible because of its errors. CP 730-731 is the

card this case is about. CP 730-'73 l is not a stand-alone record; it is part of a set of records that include Real Estate Excise Tax Affidavits ("REETA"). CP 186-188. These REET As compensate for CP 730-731 's errors. The Assessor silently withheld these records violating RCW 42.56 et seq. 1

2. WAC 458-07-015(4)(a) requires appropriate documentation of physical inspections on this card. CP

731 shows a "Data Collector/Date 119; 12/10/2015". This is the only documentation of this inspection there are no notes. This is not appropriate documentation of a physical inspection.

Patricia is a diarist. The Strands are retired and garden. In 2015 we built a chain-link fenced garden of 1500 sq feet - planting beds, ba1Tels, shed, trellises, etc. On December 14th we returned the extra fencing because in the prior days we cleaned up the garden. It was finished. There was no inspection! The garden is on the driveway to the property. This card shows these notes about changes in physical characteristics of 17355.9014,

Appr: Appraisal Notes 04/26/2016 (JS 119) Re Val inspection update. Adjusted land tables. Lower level removed based on owners appeal photos, changed to walkout basement. Added lean-tos, can't measure shed by waterfront from overheads. Land changed with the new 59/25 tables, CP 730.

JSl 19 is Jay Sporn the appraiser assigned 17355.9014. These notes do not explain the Assessor recharacterizing the card's house from a Lower Level and unfinished-partial basement to a full-finished basement and raising the value. These notes do not explain reducing the land value in two steps from

$200,000 to $150,000. The only "owners appeal photos" are Strand's on CP 320 of her house taken in 2009 and used in every proceeding listed in No. 1 above. The Assessor's first reference to 59/25 tables

is CP 782 dated 4/28/2015.

Comments: ... This area is located on both sides of Charles Road north of Nine Mile Falls

with nearly all properties east of the road exhibiting water frontage on Long Lake. Overall the current total values looked pretty good but it appears there are some allocation issues. Analysis suggested that the 59/25 land tables were overly influenced by properties with reasonable low bank access to the waterfront, whereas only 11 of the 53 parcels coded this way had the more desirable low hank access. The land codes were revised downward resulting in an approximate 12 .5% reduction to land values for the high bank properties. The 11 properties with the low bank amenity were given a positive land influence for their

t Rental Housing Assoc. v. City of Des Moines, 165 Wn.2d 525; 199 P.3d 393 at 399 (2009), Silent withholding would allow an agency to retain a record or portion without providing the required link to a specific exemption. Brief of Appellant page 7

PROBLEMS OI':{ CARD, C~ 7J0-731 continued

superior water access, with the result being a 1-3% increase in their land values for the coming year. Note that this neighborhood is scheduled for inspection next year (Cycle 6).

These Comments are about over-valuing high bank properties. 17355.9014 is high bank. These Comments are not about a December 10, 2015 inspection. They are not about a 25% change in land value. These Comments are not on the Card!

The Initial Decision in BTA 13-179 (the appeal of the 2013 assessment) for Strand dated May 9, 2017, changed Strand's land and house values. This Decision was based on Strand facts, law and evidence filed in 2015. The Decision cites Strand's photos, ProVal code sheets on a walkout basement (CP 309) and an unvalued private road. (CP 311 ). Strand connects the BT A pleadings, CP 782 and

this card. Nothing about this Decision is on the card. CONCLUSION: Another part of the set of records silently withheld by the Assessor are

inspection documentatioli'. If it exists.

3. CP 730-731 is a Worksheet card! It is not what the Assessor alleged - a basis of 2018 assessment card! CP 31 is the Official Valuation Notice for 2018 and states Land $150,000, Building $247,900 and Total Value $397,900 as shown on CP 730 under 07/01/2018. The value on CP 730 for land is $150000 (circled 3). But; the value on CP 731 for TOTAL IMPROVEMENT VALUE is 249600 which appears in the "Worksheet" column of the "VALUATION RECORD"!

Valuation Record

Worksheet 07/01/2018

2018 assessment

$399,600 $397,900 Total

..:.15..Q...QQQ ..:15.Q,.000 Land -

S.24~\600 $.247,900 Buildings

CONCLUSION: CP 730-731 's statements and values have nothing to do with the 2018

assessment.

4. On February 24, 2019 Strand requested the Assessor's complete card - the Pro Val code sheets and other records explaining the specialized language, errors and omissions on the card. ·

In the Appraisal Notes on CP 730 Mr. Sporn states creating a walkout basement on 04/26/2016. CP 162-163 are the Assessor's Pro Val code sheets explaining what a walkout basement is because CP 731 shows "B-wo". "B'wo" is the specialized language of the Assessor's Pro Val software. CP 327-330. So, the Assessor has these code sheets that explain the specialized language on the cards: "1 Fronts Enhancement# l ", "I Residential Acreage", "PoleBldg", "Lean To", "l Tract Irregular# I", "lsFR OH", "1 Tract Irregular #2", l Fronts Enhancement #2", "l Riverfront Navigable", "l Bulk Land Value Unit", "Current use Land", "l Large Lot (usually acres)", "Obsol Depr", "Market Adj","%

Comp", etc. but silently withholds it. In response to this request the Assessor provided CP 145 and stated,

#1: The land type codes and dc:scriptions were provided to you. Example #59 Fronts Enhancement# l; The formula (rate, value, and other factors) are on the Property Record Card for each parcel. CP 165

· CONCLUSION: The card has no explanations, no descriptions and no characteristics on it. The

silent withholding of the complete set of records documenting all the specialized language, errors and ··

omissions on the card violates RCW 42.56 et se~. 1

PROBLEMS ON CARD, CP .. 7:J0-731 continued. 1~

5. Why does the CP 731 cards' house built al1egedly in 2002 have these anomalies: Interior Finish 0 Basement Finish 43690 Plumbing Fixt: 18 20855

CONCLUSION: This card makes no sense

; r

17355.9014 STRAND PATRICIAN 13206 W CHARLES RD 511 iWMIN.IsrRrl.:rIVE INFOIIMA'llON

PARCEL NUMBER l7)S5.90t4

Parent Parcel Numb<lr

E:'coperty Mdress 13206 W Cfl.RRI.86 RO

Neighborhooa 231120 SROE!S: RNGE Al"IO\ 35·-21-41

Pi:operty Class 511 5- llousehul.O, si.ngi.e fm•il~

TI\X~G OIS'rRICT INFORWITION

Jurisdiction Dll

Area 001 Corpout.lon u~ Routing Nlll!'.ber t

atte Deat:1'iption

Topc,grap!ly:

Public 0tiliti¢S:

~Street or i<oa,d: = Neighborhood<

... Zoning: Land Type

~ ££gal Aetes: .,,o;oooo l Front" E:nbancement ill

°" --..J

AP?r: · .App.calsel Note& 6/29/07-101 AlldGd 30x40 shop for

'"C raoo, ~.ield aookB 000::iui. RC£ FIRE~ S

N

'° co

..J _j

!MP: 5

~ly

~

07/08.

OfflQtR.SRI.P

STRA~D PATRICIAN 13206 W CHARLES RD SPOKJ\NE, WA 9920 7 3

"--" ------r-A-\..1..S

l'V\r-.J(i:. kl&..-r- ·

'1.°1.0 "-4=>

RESIDE.

, TRANSlrnR 01" ORNRRSHl:P

Det.,;

Printed 04/03/2009 card no. l of

w (4:),:} c,-1 09/05/2000

~,-,;r11..> 09/01/2000

08/16/199g

TIAL

SA1lE(£R, ROBl::R'I' & PA1'RlCIA J

StRANO, PALMER D

lfl<NG, GEORGE: & CEAN J

VALUATJ:ON RECORD

Doc: t: 2000126_15 $100000

1loc f: 200012816 $0

Ooe f, 990012721 &120000

Assessment rear 01/01/2000 03/15/:zOH 05/H,/2004 DS.flB/2006 0$/08/2001 OS/Of>/2008

Mason for Change ,.,,,,..nd A.sat IC .. jf;.~ Rev&l

Re-val VALIIATIO!I L 32500 3250~ 100000 fooooo 100000 Po:n::eCI True Ta,B 0 13610-0 142300 114200 206100

T 32500 168600 242300 2·14200 306100 VALUIITION L 32500 0 0 0 0 1'8$e88<tCI Value B 0 136100 142300 114200 206100

T 32500 136100 142300 174200 206100

LJmD DMA AND CALCUL.\.T,tONS

R>itlng Heasur&Cl Soll ID Acreage

-or- -or-Actuel £ft&ctive

Frontage Frontage

'lll!'E 5.0000

Table Pre~. Fact<1r -or-,

Depth F"actor EJ'.factive -or-

Dept:h Squ,re F'cet

1.00

Supple111ent.al c,rd.5

MEASUR&O ACREA.,6

~se AdjU!JteCI Extended Rar.c Rota v .. 1ue -

2.0000.00 20000.00 100000

5.0000

"ork:sheet

Reval 200000 100000 21:'7'100 142300 417100 242300

0 --o 217100 142300 217100 142300

Influence E',,.et.or

Suppt~ncal Card~

TRUfl TAX \17\LU&

SapplemAnt~l Cards mTAI. ~ VhI.IJE

v .. 1u..,

100000

100000

PRYSZCAL ~TERISTICS I ---~-~~---Style: 42 Ronch l000-l~9g O bsmt

n..f'P~~'Mli!NT DA'l'll. () «f t, OS°" .:.---

.\ l

11350.9011 Propsrcy Claes: $11 13206 W Clll\.RLES RD

Con,.,,truction Wood f.ra .. e Wood frame

Ba!le Are~ 996

2048

finished floor Area Sq Ft

I, 380 1. D 2048

Value l3G30 52720 Occup~ncy: Single £am!ly

Story Ketght: 1.0 Fini,ohed Areo: 2t2B J\ttlc: None

1:Fr ---] ! ~ ~

Ba0ereent: l/2

ROOFING Material: Type:

Metal Gat::le

Framing: ?Heh:

Std fo~ Cl<lSS Not .;av.3.il-3bl a

i'l.OClil.l:NC: SUb 0, L Sub and joi3t8 l.O !lase hl lowance B, J..,

~RIO.El COVER Vinyl B!.d.:.ng B-, L,

JlffJl;ftJ;CJR l'l:NXSII Drywall 1.0

AC~TIONS l:in laheo RoO!nll Oedroom.s Form.il Dining Rooms Pi rep 111-ceg: i

l.()

t.O

i 3 l

~

ATI:NG AND AIR CONDITIONING :timary Heat: E'creed lmt. .oir-elec

1.ower F\ll 1 Part /D9:!>t l Uppa~ Uppo:r

~!NG

c::,\ ,i~t. aaths

~ Fixt. Bath$ tl>it. Baths

il !l!r:k &ter !!e"t:

£xt.a fixi:: TOTAL

k 1 S l 4 2 6 l 1 l 1

l 18

REMODELINC AND MODERNJ::::A'l'YON !"1'.ount Date

-0 r. ~u '° '° -~

~ dJ

SPECIAL FEATURES

Descdpti.on V1>lue

0 :1STLFLOE 2~0 l)l Sl'OS!,'.ll. 190

~ I 16

l FrG

(§) 24

2~

f /,/ \

i W(lO~G

t-\ au s. tz,..

~ f--0r-Jl.9 ·<l -- .}A"'?, f-' '-~,R\ 'i::::.\-z..-.-

l (; Concrete

Cxtezior Features Description Value

1152 asmt: 0 Crawl

TOT!\L MSE

!(c,,., Typ<a Adjust.nu,nt. SUB-'l'O'l'/1.l,

O Int~rlor finish 0 E>:t Lvg Un.i. ts 0 easement Fin!eh

Fireplace l"l fleiltinG

Q

A.1 r Condit 1 on Frame/Sid!ng/Rooi Plumbing fix!.: 18

Olher features

S!JB-TOTAL ONE UNIT sun-TOTAL. UNITS

Garage11 0 lntegrill

576 Att Gar .. ge O Att Carport6 O Bsmt GarBge

£><t Features

SO!l-T01'At. Quality Cla&e/Gracle

GRAD£ ADJUSTED VALU£

uorn 0

109190

1,001 109190

10360 0 0

240 6370

0 au:;o,

J.1880 \

no \

lH210 lU2)0

<)

8600 0 0 0

l:rJOla .1'.v,;-

H2JQO

\ I I

l SUMMARY OF IMPROVEMENTS

I \

Value ) l !ti .!>'try Con&t Year E:ff Const Year Cond U,oe Ilg!: 'rype Gude

11 D l»IEL!,

GOl AT'l'GAR

I 0.00 0.00

iData Collector/Date

1102 03111120M

i

1 Avg- 2002 200:1

.Appraiso.r/oate

102 0311512004

VG AV

Ba!!C Rate

0.00 15.29

restures

Adj Si,e er Co,.put.ed fe'hyr;Ob«olMackct I Rate Area Value Depr Oepr Adj Comp

y ll

0.08 15.29

Nei.ghborllood

Neigh 231"120

40':lb 2h H

H2:!00 8810

0 0

D 0

100 100

100 H2'.l00 100 0 /

I /'!'

,./., .. /·,.

_,i:: . ,V

..:PC?/ ) o' 4---,..,

..y< A....,/. y . V I/~ ~~~-'J $

1, '1)0 .9 ~·.,,.~ ... '"'T

.auwl...,...ntal Corda 'l':lV<L~VALUE

<-/'- ./'t\s> ~ \.:

H:2300 lW

once OP CONTl~(ltCW 84.!1 Oil Rew 11.14) ...:,..,

-llrl•) ollatw! ~ ia ot,,,,,i,nid .,,.~od 111 ~ -at~'-',,..bto~u.a.-,~"""""vnorall'l'P""'oi.-ch l:alsd. 11:,a...,., c,,wllG111) mllllfl NIil ~-. W th.: - ~1) 4.o IIOC di!...., u,~•ht.l£11ii!N11DOOG11~.t11ll ~~ar ~m<llkul..i1~ 40 RCW M.33.120-S 140 or RCW g.i, ~.108 llb.llt r... • -4 ~14 I>)' me ,die, OH ll"l,ll&fwra,r st th1a WIii of.-re,ThecCll.lll'4y-111111111~ifl.bei..rond.......t'and ~ lo ~11111 cS-ltlCll#>l!'II f/8 ~ilJ!Wiol:l 111"1 muc ,c, indl,;:m: below. ~ do OIOt ~>'- tlle ltlld 'IIWiQ -• in di11114'iliialliim, ot............, ll' ll a.o 1~· Q<llllll'l11, il will be "3M\lad and Iba ""'2:IP!lilNdlll l/lllllla "lill bs a;ipfimll. AU -. ~ ll'.NIII -

Thi• laud O d.oeii O <11oG lli!l'I qulify (Of Olll'llin.i..i~.

IJUUa _____ _

llEY 1CII0$1a(U-'.l!l·!ll)<fi> 14'1-~)

p -;M)'S'f;/:.) .:.r,~

U.e1W11jl/ticl>I! oliliirnN. !in WAC Ii~ mtd UJl,!autio<i.

I WAC Nit. C!>"ISl!b) -·-------------~--

: £~~fl.8.twll& ~~-----~-----~~~--

Twe oto1>,:a.anffl!r ~~d Oau of l),,.;um<=01t :i'?:f & -:"llj'

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fu11ble S111H11s: P!iCt' 1.Z ,..1,.,..lwOu,,.,MOOO:w,ii;~· Owo _____ _ l!.>.ciR TIil!:: Stale ll,_...:2::..:21.::1;.:;l:.;;6:.;:•.::0.::0-----

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Attachment: Mar 15, 2019 No. 11- Land type and method counts (excel) ~ Land Types

'lj' D..

land_type tand_type_desc count land_type land_type_desc count u

11 Primary Commercial Land 8,332 86 Utilities 51

13 Leased land / no value 113 88 Drainage Easement 13

14 Undeveloped Unusable C/1 Land 79 9 Standard Lot #1 88,347

15 Commercial Rural 1,179 90 Res Waterfront 592

2 Current Use Land 30,014 91 Res Extra Land 398

21 Designated Forest 7,636 92 Tract Std Lot (TlSL) 2,673

22 Primary Industrial Land 4,106 93 Tract Std Lot (PlSL) 3,173

23 Multi-Family Land 5,100 9V View Property 1,965

24 Residential Office 1,010 C Condo Land & Amenities Alloc 3,724

25 STRP-Narrow Strip of Land 2,133 CA PUD Common Areas· (PCCM) 1,173

26 RIRR-lrregular Lot 5,159 CD Single Comm Condo Unit (CD01) 406

27 Culdesac 1,069 DV PUD Common Areas - (PUDC) 273

28 Standard Lot #2 12,229 F Condo/Res Comm Area - (RCCM) 386

29 Fronts Enhancement #2 1,843 FC Incremental Values 9,963

3 REOS-End of Block 125 FD Site Value 184

31 Bulk Land Value Unit 7,901 FL lake Front 258

32 Near Enhancement 1,517 FO Common Wall Standard Lot 180

33 Irregular with View 103 FR Riverfront Navigable 26 F

4 BKIA-Bulk Improved Acres 13 FS Future Subdivision 98

41 Oversize lot 704 FT Residential Acreage 34,432

42 Undersize lot 1,:216 FU Riverfront Unn;wigable 16

43 Residential Small 1,075 FV View Property 1,502

44 Unbuildable 6 FW Water Front Lot 432

45 Fronts Detriment 5,442 GC Fronts Golf Course 495

46 Difficult Access 405 LH DOR Part Exemption 2

47 Limited Access 304 LK Land Locked 99

s BKUA·Bulk Uni mp Acres 302 LL DOR Exempt Property 161

51 .Standard lot w Loe Adj 24 LS Minimum Value 30

52 Large Lot (usually acres) 1,506 PU Plat - Preliminary Undeveloped 117

53 Standard Lot #3 5,117 R Subservient Value 508

54 Single Condo Unit 306 WW WRP - Wetlands 46

55 Near Detriment 520

56 Tract Irregular # 1 2,011

59 Fronts Enhancement #1 748

62 Near Enhancement #1 390

66 Tract Irregular #2 1,337

72 Near Enhancement #2 193 l 73 Flood Plain/Underwater 207

76 UNDR - Comm I Underwater 39

8 Qualifying Farm & Ag Home Site 985 82' Right of Way 32

83 Under Power Line 43

85 Easement Right 21 ·=

v'L P-142

17355.9014 STRAND, PA TRICIA N ADMINISTRATivt; INFORJ.><.ATION

?71.RCE:L NUMEE:R 1-JJS5.9014

?arent ?ar<:~l NOJ.mb.zr

l'ropert;• AOdr~ss 13206 W C:HARLES RD

N~ighbOrhacd 231720 SHORS: P.NGE AREA 3:.-21-·ll

Propect~{ Class

OWNERSHIP S1'RAND, ?ATRJCIA N PO aox :;12 NWE: tHt.£ PAL.LS, WA 99076-

13206 W CHARLES RD Printed 04/25/20 I 8 <:arc! No, I

TRANSFER OF OWNERSHIP

natl?

09/05/iOO,,

09/01/2000

Olc/16/1999

BARKER, R03E:RT & PATRICIA J

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Elk/Pg: 0, S1.00CVO

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TAXING OIST?.ICT U1F0RHA1'I0N RESIDENTIAL Jur"isd:ctt•n C-OU

Ar'€?, 00:. VALUATION RECORD

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~-.'-J~U~g Numcer 6.

Site Description

Topoq:apn·,, ·

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V/\WA-U0,'1 .. ·;..~ 200000 ---· 200000· 200000 175000 ~© 1.soocio ~"seed Twe Tax 3~ 187700 1.83700 182300 192700 _. 195700

T 381'700 383700 382300 367700 345700 V.!..:.lIATior - 200000 200000 200000 1"5000 150000 .~sse-s~M "..-'a.la~ s - 187700 183700 182300 19270~ 195700

,:.,..(}.) 38 77 00 3133700 382300 36770 · 345700


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l.75000 192700 367700 i75000 192700 367700

Va:1ve

; T:r_;nn

~{OW C~"L()S WO~\( (? µ JI._,, --( -l-----

hppr- App::ais:a l Notes 0-1/26/2010 (JSll~i R.eVa:1 in~p,ection update. Ad;usted l;;ir.ct tJb}es. Lo~..-e-c: ~eve-l r-=.mo~:-ed b.a.s-ed orr Cy1;te.r~ ~pp<eal photos, ct~anged r;o

::~~~~~o~~~~~~~c;v~~:!_d~~a~~~s~~~;~~ :1~~u~~B~~::. ~t/?S cables. _, ~

7113/10 C.onsid~t reskE-tCt-,ing es .:sfr/basemen1: w/o with ruli t;a,strnent f i rti.Sh, 6/9/lO Jhl98l 6E-09-0265 Re~iewed transcr,pcs fcom past STA case, provided by the appellant4 and caxpoyers admitted ln testimonry they have a ··tull f1.111shed basem" .. mr..'' or ba.seme.r.t/lo~Er lt::-veL by our de(initiion. ls{t021 placed 1900 sf o( basem~nt/ll fi<1ish for th-e 2009/2010 appt1~L Th1.s in f.o!:mation/transcn.pt. 1::; reta1 nect 1n Mc. hr};i lls ft le for f>..irther review.

Suppl"E~entr-l Carct~

MEASU?.EO ACP.£.AGE. s DOC.J

surpler..ei,:al ca.c,:is

"1 ~ti£ :-tt .. "": ';JI..LUE:

Supplemental. Cards TOTAL IJ>JJ0 VlU.tJE

17!.<00

n;,ooo

511 i;''l cD

PHYSICAL CHARACTERISTICS Style: 19 r~..:.mr:h l E00-22'19 occupaney; S1ngle tam11y

Story tt<eignt: Lo finished Area~ 3948 Attic: NCM2 Bas~~~nt: 1/2

ROOFING t-lateri3:l: Type: ,,aming: Pitch:

FLOCRING

Metal Gable Std for. class Net a .. 1ail.able

Slab tl, !. Sub a~d ioists 1.0 Base All.C~an·:~ B, L, l.D

I:XTERIOR COVER ~11~y1 siding B. !,. l. ,J

INT&RIOR FH!lS!{ Ory·,,.1.u 11 1 . ,:,

ACCOMMODATIONS f1r.1shed Roi:;r.,s 9 Bed:..·c.:·m!. ) rarni l 'l Ro{,,il1S 1 fo.r-rr.t, l Oin5n9 £oor.1.::

HEATING AtTO AIR COND!TIONING Pr1ro3;ri :·!t:.'it; r-c;·ced ho<:: ::!::-~€:"lie...:

::...1Y.·1<:::r Fu! t F'=.;r ~ /i:s:r.t

PLUl1EING y

t.- Fi.-:1".'. e.ac~.s :1 , f i:-:,.. &alhs 3 1-·j :d .. e"J.t}~S <'",,.,

T\t t: 3.triY: ~-J.;!,ii:C He:it

E>-:tra Fi:.:t :-OTAL lG

l:J~B-: l\::-):)'?r

REMODELING AND MODERlll ZATION .l'\rn::,uru: :>:::i,:.. e

1 :35$_ 901 •

II

firc~·r-~\;.····cr~zs: ···s1.1 u,o& 1,; CH7,RLES FD

IMPROVEMENT DATA

12

~:-;;_-,.J,_---------, ,---'---'C_-.;,;· e<>

1 s.Fr

{~61 1---

L (3)~~:, <fr

@iJ

SPECIAL FEATURES

FrG

/----~)

Z•

0 ~ ~-

,.

18

5l

24

! s-v1· -/.- Us'> fi,,',' '-_?OS t

O c,,£L·;· · · '"'"" Grecl-e .., 0.00

DE-Sc:?'~ pr:: on va:;,>:s I::

0- : C.IS?GSER 2,iO f\..<,_,q· ,)l :C 0 GO] ATT{;A@.

01 f@L£BLY.:::

i U.:JQ l

tO 00 A·1g

M Rs' (?..::, """ ,;- ,.__,,._ ,

:;;,..,.._. ' Ir"" "t

-"f" P,-(3, ~

L-.AD

Fi.nl!i,hCJ

Con!itru,::cion Base- K:::~a F~oor Areo :;4 E't value ?Jocd fc-al"J)~ wood ft:'"amE:

::::on~:ret<:i

6% L 800 23620 20-ce l,O 20~8: lfl400

1152 3.srr.::: fl cc.oiwJ

T01';~L &ASE

R0H T:n:e P..djustm-ent SUB-TOTAL

11.00

0 :r~tE.·,,r-,;.::,:-: f1r.ish ;) t-~:- t..·:-q r;m. :.s 0 53:s{:;;,::,.e(tt tin.1.sr.

:-·1 c<::-;.:!.ccci:- {s, t..eat1nq .::i: Cv,d!. r ~<A) fra:(!':e/SHI i ng/Koof P1.wmb1.A9 Vi.-...:":: Vi.

C-r.::r,e:r f'?'ec;;rt>s·

29~90 ()

2[~511)

t. OfJl :!115>10

tB451) (j

::.'.Sl30

0 0 0

J:22!.} 11)48('

Sxte-t· :or f'<•~•t' .ures 3CB-T01'A!.. Ot~ t:-Jll SS3-i0T:1.L G CNfTS

2-10

;;a0010 ?EOQ30

;Jes.Cd pt lGr",

;:FP '/a h:>i~ Gari:!ce.:i

.'.i~':O D- !11t:~-gc~1l 57 '6 An: l1~.::i .c.c:.9e

0 ~"'- r .::. (';., ::f.r().c:· ::.

<.,.> 2-srnt '~.rtr=i-''!?. '.:':;'\.:- f"ea':.t:..::..e-s

SU3-TO,A:. ~J•ME 1_ •1 C!. ... 1s5A;::.~.;.-::ie

SfUI.[>~ t,..C\J'JS7L~ VJ°l.!JJ£

0 ;};-'C

C

,,91~~

-----·;~~ -,:-~,:~ @"

-.V .. "1~: :{),J. 00'.

SUMMARY OP IMPROVEMENTS

0@@ J I/ ;//3

;·,a:ur ;:1-t ans.::: Fe"S,i;:- AdJ 51:-.f'· m: r:0nst Ye..;.r CcnC ?:a:t~ U!.'.'Ds Hate A:-,eo

2002 201)2 i"-'! ~) 00 '{_ A'J '.;,',, 66 N

2006 !GOO ;i,.v '9.Sil

<0% 2 f.C ?,~;,: 2:•l

-~ 5 .J0~-: :0-

C:Otl:tf·Ut<S":d Pr1ys Ob:';..vl ~.;~kf!'. \ ·1a1 ue- t.~: [~pr it:1J CO$p

IS:->,) (j

J.G

s 7.~ ·;·:; 7'

lCG 100 ::;c,

\:'f>.1 ~0

,,!i.00 f-- 'T~' 5 0 RJ);,/

: 1::.;..09

T 5:)

~u_) ~--f\1\_,D -5 wo t'---K 9~fL( _lL

~ Oat.a. ecllector/Oate

102 04/l'.:>/2010

Appraise=/Date

1C2 0~!2212010

Neigt,borl'>ood Supplemental Ca,:,ds TOTAL JM!?ROVEHENT VALUE

~J.;:i,:;h 211 ·,20 ::...'-J

o•-·o ~ __ t_r!; C.9

How 17355.9014 card "Printed 04/25/201811 (CP 42-43) Works

(CP 732-741 is not an accurate copy of CP 39-47)

Ref. card label(s) Pat•s explanation: Values Pat's Explanation

1 1Assessment Year i

2015:

2 IT total property value: $367,700 i

3 ··········1

1

L:r~t~1L~~dV~lue i - 175,0ooi

CP 42

4:. ~-:~,Total Improvement Value / ~~2,I~j 5 i EFP, Enclosed Framed Porch ! 4,930 i CP 43

CP42-43

6

7

8

9

10

11

i1 s Fr ?? Fram;~q 225 41

11CP 43; SUM: 23620+161400

I L Lower Level:1 1

O +18450+3220+18480+240 · ]··-. ·- 1

,

1

11 s Fr ?? Framed: ! : · 54,620!

Bsmt, Basement:! 1 I B 1····

iFr G

/suB-TOTAL .

jQuality Class/Grade Avg··

[Grade Adjusted Value r········· .. ! Dwell, Phys Depr

I

F;~med Ga rag~: J + 15370 I ! . - $300,3301 {.. ~- , . '

(-7% x Line 9): - 21,023; , ·!

$279,307 i 22,3451

(8% X Line 11)

CP 43; SUM: 29490+25130

CP 43

i 13 I

Physical Depreciation:

(Marshall & Swift Value):, $256,962i

14

15

16

17

18

·-, 1owell, Obsol Depr (-5% x Line 13): j : Obsolescent Depreciation:

(Manipulated Value):

Dwell, Market Adj (-27% x Line 15] ·

Value

Pole.~.1~~1.':,!alue

I -(Manipulated Value):

B,Total lmprovementValue

I SUMMARY OF IMPROVEMENTS 12,8481

_ .. . . j CP 43

$244,1141

65,911!

$178,203

14,500

$192,703

CP43; roundedto178200

CP 43

CP 43; rounded to 192700

.PROBLEMS ON CARD CP 42-43

THIS CARD SHOULD BE COMPARED TO CP 730-731 PRINTED 02/20/2019

1. "TRANSFER OF OWNERSHIP" statement is exactly the same as on CP 730-731 - 100% incorrect. SEE: CP 730-731 page I of analysis.

CONCLUSION: This card shows the consistency of cards errors since CP 317 in 2009. WAC 458-07-015( 4 )(b) is about the necessity to maintain records of accurate property characteristics and uniform assessment practices. REET As are part of the complete record of the card. The Assessor silently withheld REETAs that would have flagged the errors on cards TRANSFER OF OWNERSHIP.

This silent withholding violated RCW 42.56 et seq. 1

I Rental Housing Assoc. v. City of Des Moines, 165 Wn.2d 525; 199 P.3d 393 at 399 (2009), Silent withholding would allow an agency to retain a record or portion without providing the required link to a specific exemption. Brief of Appellant page 7

PROBLEMS ON CARD Cl' 42-43 copied at Cy 736-737 2

2. WAC 458-07-015(4)(a) requires appropriale documentation of physical inspections on this card.

111 CP 4 3 was created 04/25/2018 and shows u "Data Collector/Date 04/ 15/201 O". This date means

the mandated six-year inspection required in RCW 84.41.041 ( 1) did not occur. The date is the only documentation of any inspection on this card because the Appraisal Notes on CP 42, 44, 46,

have no inspection observations. These cards have substantially the same Appraisal Notes except for the cutoff line of space available for printing on the card.

• CP 45 and 47 also created 04/25/2018 show a "Data Collector/Date 12/10/2015". This date means

the mandated six-year inspection was timely. The date is the only documentation of any inspection on these cards because the Appraisal Notes on CP 42, 44, 46 are substantially the same except for

the cutoff line of space available for printing on the card.

How do three cards created the same day have different inspection dates? One answer is someone changed the date because they can and because it served the appearances of complying with the law for the office! (emphasis added) Strand asked for the cards in April 2018 because she

knew the last physical inspection of 173 55.9014 was in May 2009. On April 27, 2021, in the oral argument in 376699-III, Strand stated the facts about the cards and

the changing date as an example of manipulating the cards.2

CONCLUSION: The physical inspection reporting on cards is not credible. Strand's clarification

of February 24, 2019, requested the download of the Pro Val database record on 17355.9014. The request for the database was based on statements in CP 327-330. CP 39-47. If these statement are true the database of parcel information exists and is'part of the card. 1 Strand has never seen a download from the Pro Val database on anything. Strand's statement about Pro Val as the Assessor's database for cards relies on Chief Deputy Assessor Hodgson's testimony about cards. CP 7

3. This card is a lie! The above analysis presents the circular arithmetic of the card. (emphasis added)

• Ref. 1, the Valuation Record, CP 42, column 05/02/2015 Strand assumes this means the 2015 assessment year.

• Ref. 2, the total property value, 36Tl00, makes one appearance, on the card on CP 42 under 05/02/2015. Nothing explains where 367700 came from or how it was determined. The appearance means another record(s) exist to account for where 367700 came from and how it was

derived. • Ref. 3, the total land value, 175000, makes one appearance in the card on CP 42 under 05/02/2015.

Nothing explains where 175000 came from or how it was determined. The appearance means another record(s) exist to account for where 17500 came from how it was derived.

• Ref 4. the total improvement value, 192700, is 367700 minus 175,000. The Valuation Record

implies by its presentation that the total property value is computed by adding land and improvements. It was not! The Valuation Record is the computation of the total improvement

value. Two unknowns generate another unknown. • The Circular Arithmetic is Ref. 5-9 are reconstructions of the assumed Marshall & Swift values

of the house and only the house to generate a "Grade Adjusted Value". The "Grade Adjusted Value" is chipped away to with adjustments (Physical Depreciation, Obsolescent Depreciation and Market Adjustment) to reduce it to the 192700 (total property less total land value).

Comparing the analysis of CP 730-731 to 42-43 shows the percentages of: Physical Depreciation, Obsolescent Depreciation and Market Adjustmenl have no consistency over time. In 2015 (CP 42-43) the values are 8%, 5% and 27% in the Worksheet (CP 730-731) they are 10%, 5%

and 7%).

2 Attachment , Verbatim Report of the Proceedings 376699-111, April 27, 2021 page 11-13

ERQBLEMS ON CARD CP 42-43 copied at CP 736-737 3

• The Circular Arithmetic appears to have limits for Physical Depreciation, Obsolescent Depreciation and Market Adjustment. CP 731 shows the Assessor also created new structures,

Leantos, to bridge the gap in the circle arithmetic.

CONCLUSION: the blocks of complicated computations - Valuation Record, Marshall & Swift

Cost Table ladder and Summary of Adjustments are deceptions.

4. CP 43 and CP 731 have two completely different house with unusual features.

CP 43 CP 731

Assessment Year 2015 Worksheet after 2015

Interior Finish 18450 0 -. Basement Finish 25130 43690

Plumbing Fixt 18 18480 20855

Heating 0 0 -

6~-9( \(V ~ K e._o,1Z--

,;::

,.-

....

17274.9110 I\1ARGITAN, ALLAN & GINA T 14404 W CHARLES RD ADMINISTRATIVE INFORMATION

PARCEL W.JHBER 17174.9110

Par.ent Parcel Number 172'•1. 9106

Property Address ]4404 W CHPJ\LES RD

Neigh.b0rhood 231720 SHORS: RNGE AREA 35-27-41

Prooertv Class 51i 5- Household, single family

Ti'.XING DISTRICT INFORMATION

Jurisdiction COU

Area 001

District 0920 -----.,

OWNERSHIP MP.RGITAN, ALLAN & GINA T PO BOX 328 NIN£ MILE FALLS, WA 99026-0328

RESIDENTIAL 01/29/2015 05/02/2015

Printed 03/15/2019 card No. I TRANSFER OF OWNERSHIP

D2te

02/01/2010 KONDAUR CAPITAL CORP Bk/Pg: 0, S250000

08/21/2007 WILSON, TRICIA Bk/Pg: O. so

DS/10/2007 BOND, DREW A & CAROL A Bk/Pg: 0, S555000

09/18/2002 BOND, MARION G Bk/Pg: 0, ~o

09i18/2002 BOND, MA ... P.!ON G Bk/Pg: 0, $0

VALUATION RECORD (U 10/02/2015 05/01/2015 06/12/2017 07/01/2018

II

,.f 2

Routing N~mber 6

~ Assessment Year Worksheet.

Sita Description

Topography:

Public U~ilities:

St.reet -vc Ro.ad:

Neightorhcod:

Zoning:

Leqal ;,1,c~e-s: 6.i81JO

Land Type

1 Fronts Enhancement #1

Reason for Change

VALUATION Posted True Taz

V1\LUA.TI0N

P,ssessed Va}_ue

R.at.ing Soil !D

-or-Actual

Frontage

STIP L 200090 B 57000 T 257090 L 200090 B 57000 T 257090

Measured Tabl2 A.creage

-or-Effecti;,e Effective frontage Dept.h

6.1800

Reval Correction Reval Reval

204500 200090 200100 200100 59400 57000 57000 57000

263900 257090 257100 257100 204500 200090 200100 200100

59400 57000 57000 57000 263900 257090 257100 257100


Prod. Fa~tor -01:-

Depth factor -or- Base Adjusted Extended

square feet Rate P.<1t.e Value

1.00 28090.61 28090.61 173600

.Keval 200100

57000 257100 200100

57000 257100

Influenc2 Fact.oz

~-A-~A.R0 \~~ \ til~ Nul l/0 0 [(_/c:...

Appr: Appraisal clot.es 04/26/2016 (JS119) ReVal inspection update. Per Vicki H. th~s value is to remain frozen. 10/2/2015 jh(98) Conversations with vb & bh indica,es that, based upon vh{97}in.specticn crn this property, that. additional back year 13/14 & a 15/16 valuation change was necessary. on the basis of the inspection. 14/15 was unnecessary as th$.2 changes were made during the aFpeal process. Processed ATC's for both years and fo(237) will be sending out confidential letter to memorilize these changes. Th12:se values have been overriden and locked until the issues relating to the "clouds" to the title have been rsmoved. 0-1/27/2015 (JS119) Changed 9/2S land tables to lm-.<er b.::e.nk waterfrcnt. values. Tri s is low-b.ank and lo:>s of valt:e ,.,,,as :3dded back. { r-emc. 1!ed -15% nfluence).

Supplem€ntal Cards


Supplemental Cards

TRUF; TAX VALUF;

Supplem~ntal Cards TOTAL LAND VJ>.LUE

200100 57000

257100 200100

57000 257100

Value

173600

173600

173600 @

'.)11

ij:) er

tf') ~ Q -~ u

·::r

PHYSICAL CHARACTERISTICS

IMPROVEMENT DATA

SPECIAL FEATURES St.ry

D<Sscription Value, I ID Dse Hgt

01 :E C, 01 Dl':TGAR 0.00

Data Collector/Date

119 12/1~/201~

@:i]

SUMMARY

Const Year Hf Type Grade Const YBar Cond

Avg 2002 2002 lW

Appraiser/Date

119 01/01/2016

17274.9110

17274.9110

1~41h!CAARLE:S RD

OF IMPROVEMENTS

Base Rd.te

0.00

Feat- P.dj Size or ur:es Rate Area

y 22.00 36:-: 58

Neighborhood

Ne1gh 231120 AV

Computed Phys Obsol Market. Value Depr Depr Adj

45940 15 sv 100

Supplemental Cards TOTAL Il1PROVEMENT VALUE

% Comp

100

II

Pcopsrty Class: 511 "l'i404 W C.HA.?.LSS RD

~ ~ 0 n ~ u

0-()-'-

(1CM: 100.Qt})

Value

11700

11?GG

>Lit:

i 7274.9110 MARGITAN, ALLAN & GINAT ADMINISTRATIVE INFORMATION OWNERSHIP

~

J\.ssessment Year

Reason for Change

VA!.W\TIOH

Site Description

P.ating S01.l ID

-or-Actual

Land Type Frontage

Appr; Appraisal Notes added back. ( removed -15% influence). 01/29/2015 (JS119) Received signed Stip from Allan. Posted. 01/26/2015 (JS119) Resketched home after Vicki's inspection. Repriced and the additional linear feet of railings, the d~cks, and RFXs inc.r-eased value by S25K+. Reworked economic obsolescence and increased it from -70% to -BO% for the new home/garage. Existing detached garage remained at -70% economic obsolescence. Sent to Joe for review. 01/09/2015 (JS119i Sketched ne,-1 home from plans reviewed by Vicki H. Put at 62-% complete per Vicki's instuctions. \Vorked

values w/ Joe reflecting the economic obsolesc>2nce p.:esent due to cloud~d title~ ongoing litigation. 09i09/2014 (,JS119} Got dat.a from Tim and corrected {no .ci.nish on rr.ain or upper floor). Toot:. to BS;i,: comp1-et.e for the

Measured Table Acreage

-or-£ffective Effecti~,e frontage Depth

14404 "\V CHARLES RD

TRANSFER OF OWNERSHIP Printed 03/15/2019 card No. 2

Date

VALUATION RECORD


Prod_ Factor -or-

Depth factor --or- Sasse Adjusted Extended Influence

Factcr Square Feet Rate ?ate Value

Supplemental Cards TOTAL LAl><'D VALUE

H,,

of 2

·...._ __

Value

If) ~ = -~ u

) lJ.

0 ~ ---

. ...) PHYSICAL CHARACTERISTICS

Style: 58 l+ Story 1800-2299 Occupancy: Single family

St.Ory H~ight; l. 5 Finished P,rea: 3756 Attic: None Basement.: 1/2

ROOFING Material: Type: ,~am.ing: Pit:ch:

FLOORING Slab

Comp sh medit..:..."'n Gable Std for class N'.jt. avail able-

B Sub and joists 1 .01 1. 5 Base Allowance 1.0,

EXTERIOR COVER Cement. fiber {Ha!:"di. 1. 0, Masonry B

INTERIOR FINISH ACCOMMODATIONS Finished Rocrns Sedrooms Family Rc-c1ns

l. 5

1.5

2

HEATI,<G AND ATR CONDITIONING ?r-ir,t2.1·y Ee.J:t; H.;;at -pump

I..0wtT ':\:.ll f·art /Bsr,1t. 'Gpi;~r Up:::,.er

PLt.'N.SING

5 FL--:··. Bar !"1£

l-':i t. ~":: -,k l>".i::;.~2: Heat c.-:.-xt~~ f..i:v.t

'.;: .... :;7,;:_:,

2

9

REMODELING AND MODER.~IZATION P..mm;mt. :Jate-

TnLS l

JC 32

l

RFX Wd Dk-r . @ 12

~-I ~

IMPROVEMENT DATA

Dock

68

so

1-1/2 s Fr ---8-wo (Fin)

----....... (~

50

28

RFX

Wd Dk-r 4

@1 12

Boat House

Cone @

II Estimated From

Aerials

RFX_ I Conc-r j

I ,,

@!

Cons.1.:ruction Wood frame Wood frame

Concr+~te block

l! .•

V,' CHP..fi U::.S ?D

f"i;'"_iiS(i,,:;c'

Base Area floor Area Sq Ft 1600 LO 16DQ 1600 1.5 SS6

1600 Bsmt 1600 0 Crawl

TOTAL BAS£

Row Type Adjust.ment SUS-TOTAL

0 Interio= Finish O Ext Lvg Uni ts 0 Basement Finish

fi. replace ( s I Heating Air Condition Frame-/Sidino/Hoof ?l~mbing fi;t: 9

sus...-:!OTA4 CilE: UNiT SUB-'?OI'AI. 0 f.L'J!TE

......_ value A

n9900 l'-.) 27700

52450 0

:60030

1.GO~ 260050

23800 0

57950 Q

i390Q 0

2740 1470G

---

,,~ FrG 12 jB.fL 26 26 ,WllD~

f::xteri or Features Descripti~n Val~e Ga'Cages

0 lr.t.egral C

[email protected] < I

i

I SPECIAL FEATURES

Description Value I TD {)

I --::--,----D I D C¥JELL Gv2:£

u~0

1 G02 .4'!""'G~R

(_t=\i

@) 12

4

RFX ,~ WdOk~r ,~)

Str:y Con.st ~:gt. Type 1:;rade

0. oo Good D.00 <:2,,c,::5

,,

StJMMARY OF IMPROVEMENTS

Ye.;;r £ff B2~e f.;;at- Adi .Siz~ ot Cons~ :te;;.:- Cond ~at<? ur~s R2tE! 4.r~a

2012' 2012 VG O. ~O N 0.00 <BOC! ?.OJ2 ?012 VG 33.21 '": 33-:?l 267. 2~

VoE-S' ("00 --z

C:cmi:n1t~ci V~lue

:n,110

D Att G<..1ragf! 0 Att Carp.ores 0 asmt Ga r2ige

Ext. features

S1JE-TOTAL Q:i$li ty (:1ass/Gcad~

GRh.D£ AD.;1JST£D VAU1£.

@® f)@ F~iYZ Ob~-;:ol Market l Oep!' Depr AO) Cui\}:

}j 02 :!nsc, l G lilG

~

cucJYc1c1

Data Collector/Data Appraiser /Date Neighborhood Supplemental. Cards

J19 j_//14/201:- 119 01101;:01& TOTAL IMPROVEMENT VALUE

Neigh 23l?LO AV

0 ;)

{ LC~·i: 0;) - ~-,r,.

c0 1:(f;,)C@

U)

~ 0 rt

p.. u

5430(: ~

How 17274.9110 card "Printed 03/15/2019" (CP-1043-1046) for ???? Does Not Work

Ref. card label(s) Pat's explanatior Values Pat's Explanation

1 ;Assessments Year n? i CP 1043; "VALUATION RECORD" I AND VALUES DO NOT AGREE

2

3

,, •,, ,, ....... ,,, .. ,,,~,,--,_,,,L____ -- ' ... , --···'

'Total Land Value i _ _ __ 173,6001 CP 1043 not in "Valuation Record 11

.Total Improvement Value I / -66))001 CP 1046 Not in 11 Valuation Record 11

4 j .... .. . --- -- ~. ~9t~Ie~~e~rty __ va.~~~,::L~ feiicp[_i~·~YALUE N-~·~~-CARo-·---·

5

6

7

8

9

11

12

13

14

jsUB-TOTAL O UNITS

Quality Class/Grade Good

Dwell, Phys Depr

I

i· (3% x Line 5): I


(MarshaU 8t Swift Value)!

f Dwel!, Obsol Depr 20% ((1-.8) x 361946)/

Obsolescent Depreciation: 1

Dwell, Market Adj

Dwell,% Comp

Dwell Value

AttGar, Phys Qep.r:

AttGar, Mkt Adj

DetGar, Phys Depr

i Manipulated Value:;

(.93 X 289557): r I •

Market Adjustment: i

Manipulated Value:

(.62 X 20269) ???:

Manipulated Value:

(16% X 24180):


(.62 X (24180-3869))

Manipulated Value:

(.15 X 45940): I

- I t· ----- ------- --- _,, ___ ----- -- -,---ic

!Total lmprovemt Value (Lines 10+12+13):J

373,140 i CP 1046

11119;l SUMMARY OF IMPROVEMENTS

CP 1046 [Computation

$361,946 I reconstructed by working

· ! backwards: 316946 x .2 x .93 x .62 = 72,389\ 41740 rounded 41700] Card does

$ not explain: (1) why a house built in 289

•557

2012 is 20% obsolete in ??? year; (2)

269,288 J why 20% obsol is presented at 11 80";

i (3) why the house is then inflated

il9+llil 93%, (4) then% Comp'd (whatever

that is) 62%.

41740 rounded 41700

$3.869 I I

CP 1046

S.12,5931

I $1li,700 I CP 1044; ERROR - .15 X 45940 =

---=-~-- L ______ 6891;_ 11700/45940=.2SS_ .... _

CP 1046

12593 rounded 12600

$66,000 CP 1044, 1046

THIS VALUE NOT ON THIS CARD

PROBLEMS ON CARD (CP 1043-1046]

1. CP 1043 "TRANSFER OF OWNERSHIP" states owner as of 02/01/2010 is "KONDAUR CAPITAL CORP". CP 1043 "OWNERSHIP Margi tan, Allan & Gina T" does not agree. These conflicting

statements prove an independent record is required to account for the Assessor's poor documentation

of sales and ownership. That record is the Real Estate Excise Tax Affidavit. The Assessor's cards

show the Assessor unable to correctly record ownership information. CONCLUSION: Cards are not credible because of their errors. The REETA is essential to cards;

it is silently withheld by the Assessor in violation 42.56 et seq.! 1

1 Rental Ho11sing Assoc, v. City of Des Moines, 165 Wn.2d 525; 199 P.3d 393 at 399 (2009), Silent withholding would allow an

agency to retain a record or portion without providing the required link to a specific exemption. Brief of Appellant page 7 ;oi

PROBLEMS ON CAfi;I), Ctl~-1046 continut1 2

2. WAC 458-07-015(4)(a) requires appropriate documentation of physical inspections on this card. CP 1041 shows a "Data Collector/Date 119; 12/14/2015" with a picture of a closed gate and this date on it.

This is not appropriate documentation of a physical inspection. These notes do not document the inspection. ·

Appr: Appraisal Notes 04/26/2016 (JSl 19) ReVal inspection update. Per Vicki H. this value is to remain frozen. 10/2/2015 jh(98) Conversations with vh & bh indicates that, based upon vh(97)inspection on this property, that additional back year 13/14 & a 15/16 valuation change was necessary, on the basis of the inspection. 14/ 15 was unnecessary as the changes were made during the

appeal process. Processed A TC's for both years and fo(23 7) will be sending out confidential letter to memorilize these changes. These values have been overriden and locked until the issues relating to the "clouds" to the title have been removed. 04/27/2015 (JSI 19) Changed 59/25 land tables to lower high-bank waterfront values. This is low-bank and loss of value was added back. ( removed-15% influence).

JS 119 is Jay Sporn the appraiser assigned neighborhood 231720. These notes do not explain the freezing of values in the "VALUATION RECORD" from 04/29.2015 to 07/01/2018" These notes do

not explain ·what is "confidential"! The notes reference 59/25 land tables. CP 782 dated 4/28/2015,

Comments: ... This area is located on both sides of Charles Road north of Nine Mile Falls with nearly all properties east dfthe· road exhibiting water frontage on Long Lake. Overall the current total values looked pretty good but it appears there are some allocation issues. Analysis suggested that the 59/25 land tables were overly influenced by properties with

reasonable low bank access to the waterfront~ whereas only 11 of the 53 parcels coded this way had the more desirable · 1ow bank access. The land codes were revised downward resulting in an approximate 12 .5% reduction to land values for the high bank properties. The

11 properties with the low bank amenity were given a positive land influence for their superior water access, with the result being a 1-3% increase in their land values for the

coming year. Note that this neighborhood is scheduled for inspection next year (Cycle 6).

Comments are about over-valuing high bank properties. 17274.9110 is low bank land with 6.18 acres

valued at $200,xxx. Comments are not a schedule inspection in 2016 not December l 0, 2015. CONCLUSION: Another part of the set of records silently withheld by the Assessor are

inspection documentation. 1 If it exists.

3. None of the values in the "VALUATION RECORD" (CP 1043) appear on any other page of this card.

This card not only has nothing to do with 17355.9014 assessment year 2018 it has nothing with any of

the assessments on 17274.9110. CP 1044-1046. CONCLUSION: This card's pages make no sense as a cohesive record!

4. CP 1046 in the Summary oflmprovements shows "DwelF' column and "Features" column. The Attached garage is a feature shown by a "Y". The Dwell is not a feature shown by a "N". The value of the dwell (house) is Grade Adjusted at $373,140 but reduced to $41,700. No reason is given on this

card for this. CONCLUSION: This card is hiding a lot of facts!

/0

::

ll

17363.9081 MARTIN, ERIC 14701 N OXFORD RD ADMINISTRATIVE INFORMATION

PARCEL NUMBEP 17363.9081

Parent Parcel Number ~ see Ascend ....

Property P-.ddress 14701 N OXFORD RD

Neighborhood 231720 SHOPS: RNGE AREA 35-27-41

Property Class 511 5- Household~ single family

T.4XING DISTRICT INfORMATI01-.J

Jurisdiction cou Ar:e2 C,01

Corporation USA

Ci strict 0920

Routing Number 6

Site Doscription

Topography:

OWNERSHIP M-1',RTIN, ERIC 14701 N OXFORD RO NINE MILE FALLS, WA 99026

RESIDENTIAL Assessment -fear 09/29/2016 06/12/2017

Reason for Change ~ Seg BLAdi Reval

VALUATION : 150000 150000 Posted True Tax E @197700 229300

1 347700 379300 VALUATION L 150000 150000 Assessed Value e :-----. 197700 229300

, Q:,} 347700 379300

Printed 03/07/2019 ca rd No. I of TRANSFER OF OWNERSHIP

Date

03/l3i201B

03/13/2018

WALLMARK, JOANNE M/TAGGAPT, CAROL

SADLIK, KAPJ,

VALUATION RECORD ........ 07(01/2018 / · ...

Worksheet ~ Reval

250000 250000@ 349700 334400 (i) ...,.© 599700 584400 '2. 250000 250000 349700 334400 599700 584400

Doc tt: 201803512 .$670000

Do,:: tt: 201803513 $0

Fublic Utilit~es: LAND DATA AND CALCULATIONS

s:.r':-~>::t. ""'r P.oa.d:

tJeighbctt·ho,:i.d:

Zoning: LEt;r'3.i .t',::.res: 10.00GC

Land Type

Frcnt.5 Enhancement #1

Ratinq Measured Tabli2 Prod. factor Soil r°D Acreaoe -or-

-or- -or-- Depth Factor Actu.2:l Effective Effective -or-

Front:age Frontage Dep~~ Square F~~t

10.0000 LOO

Bas8 Rate

Adju.st-sd Rate

25000.00 25000.00

40VJ ~tS G(LD bo~

Appr: ~~~~~ copied from 17363.9075 ~~~~~ Appra..:sal Notes 06/20/2018 (JS119) Applied 130% P.DF for mid century c.toderne design. OS/03/2018 (SM127) Sold at. S670K. Upped condj tion to GD, based on int.ernet virtual tour. Took off -40% on land for access. 09/29/2016 {JS119) Posted BIA. 04/25/2016 (JS119) ReV2l inspection update. Uppec! q,aality r.o GC·-, condit1on lowered to FR. : - : : : : : : : . ~ : : : : : : : : : : : : : .

Supplemental Cards


Extended Value

250000

/~cY\.

lrdll!0nce F5c~o:- ·J?il:..:e

Luo (\_, 1c:._

Supplemental Cards

TRUE TAX V!,LUE

2:0000['

250000

511

~ 0

...,. l() r--. ~ u

--.;;.

PiS.£G; Segregation Notes 9/27/2016 214 ACO 20160430 BLA moving common property line t.o reverse sizes betweer, parcels; pare-el with improvement ls the 10 ac-:~ parcel: apprais-:r to revie'..,./' .& post

east n-C•\s1

Supplemental Cards TOTAL Ll\llD VALUE 250000 ©

8()£: ?..,,p;;.22i Info~·rnat.:..on

PHYSICAL CHARACTERISTICS ~ Style: 38 Large Ranch 2300+ 0 bsmt Occupancy: Single family

Story Height: 1 Finished Area: 3390 Attic: None Basement: None

ROOFING Material: Built-up Type: Framing: Pitch:

Flat or Shed St.d for class Not available

FLOORING Slab 1.0 Base Allowance l . C

EXTERIOR COVER Wood siding 1.0

INTERIOR FINISH Pa11eling 1.0

ACCOMMODATIONS Finished Rooms 6 Bedrooms 3 Formal Dining P.0oms 1 Fireplaces:

HEATING AND AIR CONDITIONING ~rim3.ry Heat: Fcrced hot air-propane

Lower full ?art I /Bsmt 1 Upper Upper.

PLUMBING

3 Fixt. Baths Kit Sink Water Heat. Extra Fixt.

TOTAL

n 2 6

2 10

REMODELING AND MODERNIZATION P..mount Date

SPECIAL FEATURES

De.script.ion

D :DTSHWSHR DISPOSER FF CVENCMBD

Value

920 335

5200 12.55

IMPROVEMENT DATA

1 s Fr Slab

@]) ~

-.5~.;

Construction Wood frame

Exterior Fe3tures Descriptic~ Value

H.L

fiDl Sh'2"d Base J'.l.r->?"a floor lire.a Sg Ft

3390 l. 0 3390

0 Crawl

TOTAL BASE

P.ow Type Adjustment SUB-TOTAL

0 Interior finish 0 £xt Lvo Ur.its 0 BasemeDt Finish

Fi n:;place { s} Heat.ino Air Co;.dition Frame/Siding/Roof Plumbing Fixt: 10

Other 2e2t1.1res

.SU.B-TOTtiL CNE ONI".:' SlJB-TOTAT, 0 UNITS

Garages 0 Int.egral 0 ,0.tt ('yJretq<O O At.t Carports 0 Bsmt Garag<e

Ext feature!:

r.; :>.F\

Vali..:.e 347190

'J) 0

-18480

328710

1.()0~ 328710

0 0 0

52:)0 0 V

,, 100 16600

;;s10

~$;;20 "5' :;S'/320 \:V

0 0 C

0

SUB-TOT},L 35 l32C ~ Qu<l1it.y C1:.a.;3s/Grade- Geo~-~ -··-···------···--·-·-······---- C', GRADE P.DJGST£D VALUE 3215% ~

[LCM: ; 00. 00,

SUMMARY OF IMPROVEMENTS

Stry Const: Year Eff ID Use Hgt Type Grade Const Year Cond

D 01

:J'rtSt.L DETGAR

1.00 l. 00

Data Collector/Date

11s 12:10120:s

Good Avg-

1%0 1960 G 1960 1960 AV

Appraiser/Date

119 01/01/2016

Base Feat- ;,,_dj Size or Comput~d Phy;; C,bsclNwrket % Rate t:res Rate Area Value Dept Depr Adj Cr;,mp

0.00 29. 7B

y N

0.00 27. 70

Neighborhood

3390 "'.t~ A

2-1:- 2~ (-1;~:g

CV

J.& ~c

1 J

Supplemental Cards TOTAL ll-iPROVE:MENT V1\.LUE

Neigh 231720 ;'".!,'J

2.20 1cc

100 100

V,ctue@J

3Z330C ,fr', lllOO 1...:.:,/

LI) LI) t""

Ill u

33~~00

How 17363.9081 carcl "Printed O'J/07/2019" (CP 754-755} Does Not Work

Ref. !card label(s) Pat's explanation: Values Pat's Explanation

!Assessment Year I Worksheet i i :T i

total property value: $584,400 I 2so,ooo!

i•·'----;-s·-- ---{ IL, Total Land Value

CP 754 1

2

3

4 Ja, Total Improvement Valu.e 11 s Fr ---

. ... .... J. .~~!~PPL ... 5 ,-- ?? Framed: I l

357,320i ·slab

6 _JQuality Class/Grade Good {~10% x Line 5)+·. -.

7 !Grade Adjusted Value

/Dwell, Phys Depr {16% x 321590): : 8

; Physical Depreciation: 11 -

9 (Marshall & Swift Value): j - -·1

10 J Dwell, rvlarket Adj (20% x 270134): i +

~1·-~talue {Manipulated Value):

: DetGAR {Detached Garage $15960): I

!DetGar, Phys Depr {30% x 15960 = 4788):

12 i (depreciated value $11172): · I

I

4 I . 1B, Total Improvement Value

i

i 35,732 1

................................. ! $321,5881

.. . I

I 51,4541

$270,134: --- - I

2.1i_027j '

$323,300! , ,,,,, , ... _,,,•-.,C,'

11,172'

I I

$334,4001

CP 755

CP 755; rounded to 321590

CP 755

ERROR - Phys Depr is not 16% or

Market Adjust is not 20% because

lines 7-10 produce 324161 not

323300 {difference 861)

CP 755; ERROR - 11172 rounds to

11200 not 11100

AVERAGE COMPUTER PROGRAMS DO NOT MAKE THESE KINDS OF

ERRORS

(J)

II.

17276.9111 WARNE, VANES SAD 15507 W CHARLES RD ADMINISTRATIVE INFORMATION

PARCEL HUMBER 17276. 9111

Parent Parcel Number NIN£ MI LS f.~LLS

Property Address 15507 W CHARLES RD

Neighborhood 231720 SHORS: RNGE AREA 35-27-41

Property Class 518 5- Personal property MH's

TA.XING DISTRICT INFORMATION

Jurisdiction COU

Area 001

Corporation

District

USA

0920

Routing Number 6

Site Oescr1ption

Topography:

OWNERSHIP WARNE, VANESSA D ,SOS H ALTAMOt1T ST SPOY.ANE, WA 99217-

RESIDENTIAL ® Assessme'.lt Year 05/03/2013 05/04/2014

R€:ascn for Change ?"'i Reval Reval

VALUATION l 35120 35120 Posted True Tax E ~· 91300 93800

T 126420 128920 VALUATION 1 35120 35120 Assessi?d Value

E ttJ 91300 93800 7 126420 128920

TRANSFER OF OWNERSHIP

Date

Printed 03/15/2019 Card No. 1 of

01/08/2014

04/24/1997

BARNARD, EDELGARD Bk/Pg: 0, Sl34500

MCCOt1BS, LANE R & MARY L Bk/Pg: 9700, 5007 $22000

VALUATION RECORD 05/02/2015 05/04/2016

Reval Re-val

35120 35120 91400 96900

126520 132020 35120 35120 91400 96900

126520 132020

07/01/2018

Raval

3512~~·-,, ~ '1 35120 111100 ., 122900 146220 'h' 158020

35120 1111 0 0 tr"\ 146220\.bl

35 20 122 00 158 20

Worksh-::::et

35120 111100 14 6220

35120 111100 146220

Public Utilities: LAND DATA AND CALCULATIONS

Street or Road:

Neighborhood:

Zoning:

Legal Acres: 5. 0400

Land Type

Residential Acreage

Rating Measured Soil 10 Acr12age:

-or- -or-

Table Prod_ Factor -or

Depth Factor Actual Effective Effective -or-

Frontage Front.age Depth Square feet

5. 04 00 1. 00

Base Rat:e

6968.25

µov0 ·\~\s C A/2- \)

!:BOO: Field BookU 00033A RGE 04/21/2015 (JS119) ReVal/int.ernet. re,,iew. #201320995 sale at $134,500. 174 DOM. Lowered quality to FR, added heat pump. Home has been moved twice not. eligible for financin9 so it was a cash sale. fIRE: 5 IMP: l. 38 MIMP: 1999: MDG l'frl LIBERTY-GLENOAKS [BGB8/8/97} MOBH: LIBERTY. Proj Po: 97004407, Serial: ORE259740, Doc: MC97-184 !JNI!1: 3.66

Supplemental Cards


AdJU.Sted Rate

6968. 25

Extended Value

35120

Influence Fact.or

\-JO IL~

Supplemental Cards

TRUE TAX VALUE

Supplemental Card~') TOTAL Ll\ND VALUE \.:J!;

Value

35120

35120

35120

)US

~ 0

-.e Vl O'\

~ u

PHYSICAL CHARACTERISTICS Scyle: 91 Double Wide Occupancy: Single family

Story Height: 1.0 Finished Area: l56B Attic: None Basement: None

ROOFING Material: Comp sh medium Type: Gable ~

Framinc: Std for class Pitch:- Not available

FLOORING Sub and joists 1.0 Base Allowance 1.0

EXTERIOR COVER Wood siding 1.0

INTERIOR FINISB Di·ywall J. .O

ACCOMMODATIONS ?inished Rooms Bedrooms

5 3

HEATING AND AIR CONDITIONING 11·

Prir.,ary Heat: Heat rump l,ow<cr ?uil ?art I / Bsmt 1 Upper Uppe:r

PLUMBING

- I 3.Fixt. Baths - 6 Kit Senk 1 Water Heat l 1 Extra Fixt 1 1

TOTAL 9 '

REMODELING AND MODERNIZA7·ION I Amount Dat.e

I

I

1--+QJ '

IMPROVEMENT DATA

I <if) I 'i D@)' I 22_J

--56

I ~Fe@) 2

1

8 C

I @ [ _____ _

ii

1 ·1 L. .'S. '::" l l l

Construction \'Jood frame

£x~erior Features Description Value

W CHP.RL£S P.~

finished Base Area floor Area Sq ft

1568 LO 1568

1568 Crawl

TOTAL BASE

Row Type Adjustment SUE-TOTA!,

O Interior Finish 0 Ext Lvg Uni ts 0 Bosement Finish

Fireplace(sl Heat.ing Air Condition Frame/Siding/Roof Plurrbing Fixt: 9

Other ?eatures

SUB-TOTAL ONE UNIT SUB-TOTAL O UNITS

Garages 0 Integral 0 Att Garace 0 1-\tt CarpOrts 0 Bsmt Garage

Valui>6 l174SOr:)

0

117450

1.ooi l l '"'-150

0 0 0 0

5000 0

2·1BO 7280

2200

ii!1;g@) J 0

J £:-:t Fi:::atures 0

SUB-TOTAL Quality Class/Grade

,--... --==-~~~-;----;u~;'!~i~;@/ GRADE ADJUSTED '!ALUE 13,1410

CLC~1: 100. 00)

SPECIAL FEATURES SUMMARY OF IMPROVEMENTS &) ~ Descripti:::n

D :BASIC 01 :AUTOOPEN

E

Value

2200 580

1 I ID

D 01

cQ Use

:.:-11112.1.:t

Strv Const. Ye-a:.- Eff Hgt Typ<>: Grade Const Year Cond

0.00 fair 1994 1994 IW 0.00 l Avg 1991 1994 AV

Base teat- Adj Size or Computed PhysObsclMa,!"ket i Rat.e ures Rate, Area Value- Depr Depr Ad Comp

0.00 0.00 1568 134410 12 0 83 100 29.82 y 31.07 22x 26 111350 30 0 100 100

-c-k \_Is '

C.-A,~O l00(l\<S

Data Collector/Date

119 Li/l4/201S.

Appraiser/Date

'19 Ql/01/2016

Neighborhood

Heigh 231720 A'l

Supplrame...~ta1 cards TOTAL IMPROVEMENT =UE

V3lue

Ag~@ ®

[' LO O'I

P4 u

1.11100 ~

How 17276.9111 card "Printed 03/15/2019"" {CP-956-957) for 2017 Assessment Year Work

Ref. I card label(s) Pat's explanation: Values Pat's Explanation

1 tssessments Year 06/12/2017 i CP 956

2 total property value: $146,220/ !T CP 956 3 l L, Total Land Value 35,1201

4 la, Total Improvement Value *~i~.~r CP 956 and 957 - j - ---- ----------

J1 s Fr ?7 Framed: I ,_

5 I C Crawl (Space): CP 957, SUB-TOTAL I 134,410 I ' - I 'Quality Class/Grade Fair

6 Dwell, Phys Depr (-12% x Line 5):

16,1291 Physical Depreciation: I

$118,281!! SUMMARY OF IMPROVEMENTS

7 (Marshall & Swift Value): CP 957 - I

8 Dwell, Market Adj (-17% x Line 7):

20.10~1 Market/.\~j~~tment: I , ........

9 Dwell Value Manipulated Value: $98,173! CP 957; rounded to 98200

DetGar (Detached Garage $18350):

10 DetGar, Phys Depr (-30% x 18350=5505): i!b.845 CP 957; rounded to 12900

(depreciated value $12845): !F _.,,~ ... -·-··-·-~-

4 B, Total Improvement Value $111,018 CP 957; rounded to 111100

\DC,

ATTACHMENT 7

2

3

4

5

6

7

8

9

10

1 I

12

13

14

15

16

17

18

19

20

21

1 1)

12)

What the Assessor's records are of their basis of value are prescribed by the above

laws as the foundation of an appeal of that value. These prescribed records are

required to be produced upon Strand's request by the above laws! (emphasis added)

The Property Record Card does not comply with any of the required responses listed in

RCW 42.56.520( 1 ).

a) The Property Record Card is not a responsive record. P-34 to -35 at (8)3 states

'1Printed 02/21/2019". It was created by the Assessor on February 21, 2019- one

day after the request.

The property record cards is not a record that exists in the office. It has to be created. The property record card itself is a - is part of the canned software of Pro Val. And actually we haven't used that property record card all that much until Mrs. Strand's requests came. Not that we haven't used it, but it's something that has to be created. And it is basically date driven.4 (emphasis added)

Gipson v. Snohomish County, 194 Wn.2d 365, 449 P.3d 1055 (2019), An agency must only provide access to public records in existence at the time of the request. An agency is not obligated to supplement responses. Therefore, if a public record is created or comes into the possession of the agency after the request is received by the agency, it is not responsive to the request ... (emphasis added)

The Property Record Card is also not a responsive record because nothing on

this record satisfies any provision of RCW 84.40.030(3). The only sales on it are of

17355.9014 and are not within five years of the 2018 valuation. The sales at P-34

(A) are reported incorrectly.5 This record has no similar sales. This record does not

3 Strand annotated the appraisal by alpha character proximate to relevant information 4 P-172-182 are attribution and excerpts from testimony of Chief Deputy Assessor Byron Hodgson in Cause 142010791 in January 2015.

• P-174 to -175 Direct testimony about not being required to produce records that do not exist • P-176 to -178 Cross examination testimony about his training on the PRA • P-182 Direct testimony on the creation of Property Record Cards

5 P-183 to -185 are the Real Estate Excise Tax Affidavits: 8/20/1999 Wang sold to Barker; 9/6/2000 Barker to sold to Strand; 9/6/2000 Strands assigned property to Patricia.

Complaint PN Strand, Plaintiff P-7

CP-7

2

3

4

5

6

7

8

9

10

1 I

12

13

14

15

16

17

18

19

20

21

Complaint

disclose the factors used to value the land, structures and total property for any of

the seven valuations on it. The words cost and phrase comparable sales do not

appear on this record. The record is also not intelligible. Why is the "Site

Description" not filled out. This is acreage property. Strand paid thousands of

dollars for a water well, septic system and electrical power. None of them are on

this record. If Strand had not paid for these structures and if they were not

functional this land would be worthless because it is peculiarly unattractive land.

( emphasis added) This jargon is senseless:

• Land Type is "1 Fronts Enhance #1"

• Appraisal Notes 04/26/2016 (JS 119) Re Val inspection update. Adjusted land tables Lower level removed based on owners appeal photos, changed to walkout basement. Added lean-tos, can't measure shed by waterfront from overheads. Land changed with the new 59/25 tables.

• Obsol Depr

• Market Adj

• % Comp

What do these things mean? This card does not explain these things. P-35 shows

the LEANTOs as constructed in 2006. Why are they added on 04/26/2016? Where

do the values come from? What are "lean-tos" versus "LEANTOs"? Why is a

house constructed in 2002 obsolete as of February 21, 2019? Why does Strand 's

house have no values for Interior Finish and Heating? This is Spokane with a

winter and fall temperature that can drop below zero and stay there. What is a "land

PN Strand, Plaintiff P-8

~-

CP-8

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

table"? How can the Assessor use Strand's photos to change Strand's house? Did

the Assessor notify Strand of any of this?

The above facts and caselaw mean P-34 to -35 do not satisfy RCW

42.56.520( 1 )(a).

b) P-33 to -35 do not show an internet address and link to the requested records. This

record does not satisfy RCW 42.56.520( 1 )(b ).

c) P-33 to -35 do not give an estimate of the time required by the Assessor to

produce the first responsive record - the 1st installment. ( emphasis added)

Health Pros Nw., Inc. v. Dep't of Corr., 10 Wn. App. 2d 605,449 P.3d 303 (2019),

The Court DECLARES that [former] RCW 42.56.520(3), as construed by the Court of Appeals in Hobbs v. [Washington] State [Auditor's Office], 183 Wn. App. 925, 335 P.3d 1004 (2014), only requires an agency to provide an estimate of when it will produce its first installment of records responsive to the public records request . ..

The above facts and caselaw mean P-33 to -35 do not satisfy RCW

42.56.520(1 )(c ).

d) P-33 to -35 do not state records are being denied. But, the fact that this record is

not responsive means responsive records have been withheld without disclosing

what was withheld, why the withholding and a statutory exemption for the

withholding. Rental Housing Assoc. v. City of Des Moines, 165 Wn.2d 525; 199

Complaint

P.3d 393 (2009),

Silent withholding would allow an agency to retain a record or portion without providing the required link to a specific exemption, and without providing the required explanation of how the exemption applies to the specific record withheld. The Public Records Act does not allow silent withholding of entire documents or records, any more than it allows silent editing of documents or records. Failure to

PN Strand, Plaintiff P-9

CP-9

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

reveal that some records have been withheld in their entirety gives requesters the misleading impression that all documents relevant to the request have been disclosed. Moreover, without a specific identification of each individual record withheld in its entirety, the reviewing court's ability to conduct the statutorily required de novo review is vitiated.

The plain terms of the Public Records Act, as well as proper review and enforcement of the statute, make it imperative that all relevant records or portions be identified with particularity. Therefore, in order to ensure compliance with the statute and to create an adequate record for a reviewing court, an agency's response to a requester must include specific means of identifying any individual records which are being withheld in their entirety. Not only does this requirement ensure compliance with the statute and provide an adequate record on review, it also dovetails with the recently enacted ethics act.

The above facts mean P-33 to -35 does not satisfy RCW 42.56.520(l)(d).

CONCLUSION: The Assessor violated the PRA with the production of P-33 to -35

- a nonresponsive record. It is apparent Chief Deputy Assessor Hodgson intentionally

violated the PRA by producing this record. He was notified in 2009 and annually

thereafter by Strand that the sales on their Property Record Cards were wrong. He never

corrected the error. He testified4 to his extensive training in responding to PRA requests

in January 2015. He testified that the Assessor would not produce records that do not

exist in 2015. 6 He created this record after the request. This record does not satisfy

RCWs 84.40.030 and 84.48.150.

13) On February 24, 2019 Strand clarified the request in response to P-33 to -35. (P-36 to -

44) This change is after the Assessor violated the PRA. The change was Strand's

attempt to get responsive records for her appeal.

• Strand expanded the years requested from 2018 to 2015 through 2019. (P-36)

6 Id., Hodgson will not produce records that do not exist

Complaint CP-10

I

PN Strand, Plaintiff P - 10 \

• Strand asked for electronic records to be .downloaded directly from the Pro Val

2 database in lists or tables of sales for land, structures and total property. (P-36) The

3 request was to produce the sales with their: addresses, parcel numbers,

4 neighborhoods, dates, etc. (P-36 to -38) This is the simplest and most obvious

s presentation of proof that the Assessor used relevant sales as the basis of value. P-33

6 to -35 was a download from the database allegedly showing the sales on 17355.9014

7 are in the database. The production of Property Record Cards takes time and Strand

8 believes it requires use of specialized programs. (P-39 to-44) The compilation of the

9 sales data into lists or tables would appear to be simpler and more timely. The

IO Assessor compiles database sales into Property Record Cards, reports and websites.

11 (P-106, -148, -150, -154) But, sales on these various writings are not an Assessor's

12 statement of using specific sales to determine l 7355.90I4's specific values! What

13 these writings show is the Assessor's constant downloading from the Pro Val

14 database for all sorts of reasons. What is the difference in producing such

15 records for Strand! (emphasis added)

16 Lowy v. PeaceHealth, 174 Wn.2d 769, 280 P.3d 1078 (2012), a database

17 download is one record. The Assessor produce + 368 separate records as Property

18 Record Cards. WAC 44-14-05001 does not distinguish between paper and electronic

19 records. WAC 44-14-05001 is Access to electronic records. The PRA explicitly

20 includes electronic records within its coverage. RCW 42.56.0 l O defines a "public

21

Complaint PN Strand, Plaintiff

CP-11

P - 11 \

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

Complaint

record" to include a 11 writing,'1 which in tum includes "existing data compilations

from which information may be obtained or translated."

Mitchell v. Dep't of Corr., 164 Wn. App. 597 at 604 and 607,277 P.3d 670 (2011), .. . Nothing in the PRA obligates an agency to disclose records electronically ... but rather provide useful guidance to agencies. Mechling v. City of Monroe, 152 Wn. App. 830, 849, 222 P .3d 808 (2009). WAC 44-14-0500 l suggests that agencies should provide records in electronic format when requested in that format. It further provides that agencies need not provide records electronically if it is not technically feasible to do so.

Mechling v. City of Monroe, 152 Wn. App. 830 at 850,222 PJd 808 (2009), Although the City has no express obligation to provide the requested e-mail records in an electronic format, consistent with the statutory duty to provide the fullest assistance and with the model rules, on remand the trial court shall determine whether it is reasonable and feasible for the City to do so.

John Doe v. Benton County, 200 Wn. App. 781 at 788, 403 P.3d 861 (2017), Although the model rules in chapter 44-14 WAC are advisory, the legislature has instructed agencies to consult the model rules when establishing local ordinances for PRA compliance. RCW 42.56.570(4).

Spokane County's Public Records Act Rules Background state the County

consistent with the provisions of RCW 42.56.100 and RCW 42.56.070, desires to

adopt the model rules ... (P-186 to Pl91) Section 2 No. 3 states the County will

provide the "fullest assistance" to requesters. Section 4 No. 5 states exemption

claims will state the specific exemption and provide a brief explanation of why the

record or portion is being withheld. Records requesters will have the opportunity to

promptly inspect records.

Strand requested electronic data from an electronic database because it is

reasonable, feasible and the most logical and efficient production method. Strand did

not receive a single electronic record.

PN Strand, Plaintiff

CP-12

P - 12

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

14)

• Strand asked for Proval code sheets to explain the jargon on P-34 to -35 that appears

to be valuation factors for land and structures. Chief Deputy Assessor Hodgson

responded that the Property Record Card is self-explanatory. (P-162)

• Strand asked for the factors the Assessor used to value land, structures and the total

property. The Assessor disclosed nothing.

• Strand ask the Assessor to connect the values to the sales. The Assessor connected

nothing. The Assessor connected nothing.

• Strand asked the Assessor to provide a statement of the time required to produce these

records. The Assessor produced none.

CONCLUSION: Strand did not receive a single record she requested when the

Assessor knew this was an imminent appeal of value. Strand received no assistance.

Strand received records the Assessor knew were erroneous and nonresponsive.

Strand did not receive a single database record - the original format of the

Assessor's records. (emphasis added) WHY!

Gipson v. Snohomish County, 194 Wn.2d 365,449 P.3d l 055 (2019), The PRA was enacted to facilitate government transparency through the disclosure of public records. In furtherance of that goal, the PRA requires agencies to publish rules and regulations to promote ease of access for public records requests. See former RCW 42.56.040 (2014). Because the people have a right to remain informed of government instruments, this chapter's provisions are to be "liberally construed and its exemptions narrowly construed." Former RCW 42.56.030 (2014). The PRA requires agencies to "provide for the fullest assistance to inquirers and the most timely ... action on requests for information.'' Former RCW 42.56.100 (2014). (emphasis added)

The Assessor produced unresponsive records from March 8 to 22, 2019. Strand tried to

use these records. Strand first had to reformat them for optical character recognition - a

Complaint CP-13

P- 13 PN Strand, Plaintiff

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

computer search for letters. Next Strand did word searches for the words sale and cost

and the phrase comparable sale. (emphasis added) Some of the records could not be

reformatted and so could not be searched electronically. Searching by eye was less

successful because Strand is old. The word sale appeared often but without sales

transactions. The word cost appeared less often and never appeared with relevant cost

statements. The phrase comparable sale did not appear. Nowhere was there anything

connecting any of these records to Strands valuations. But trying to use these records

was very time consuming and frustrating. Strand's search showed these records

unresponsive to RCW 84.40.030. These are the unresponsive records the Assessor

produced.

• March 8, 2019: The Assessor's Answer to Real Property Petition & Valuation

Complaint

Information is labeled (P-46 to -58),

"7. Attached are the following maps, pictures, letters, appraisals or other data to substantiate the present full market value of the property as stated in item No. 2.

Substantiation is not how the value was determined; substantiation is after a value is

determined. This is unresponsive per the label. Nothing in this report identifies how

l 7355.9014's valuation was determined. Nothing in this report identifies how the

Assessor values real property - land structures or total property. The report has

another version of the Property Record Card (P-55 to -56) with more Pro Val jargon

that the self-explanatory record does not explain but juxtaposes with values -

Functional Depreciation, Location Adjustment.


CP-14

P • 14

-----~------- ---------~----------------------

~--

Public Records Request From: pat strand Date: . Wed 2/20/2019 3:47 PM To: [email protected]

Please provide the following records:

Regarding DA 18-0071 on parcel 17355.9014. I want all records that show the Assessor's basis for valuation for assessment year 2018 -- 2019 taxes.

The request is based on RCWs 84.40.030, 84.40.020, 84.48.150 and 42.56.520.

Patricia Strand

RECEIVED

Ml~h'O~

SPOKANE COUNTY PUBLIC RECORDS OFFICE

RECEIVED

i--i~

SPOKANE COUNTY PUBLIC RECORDS OFFICE

cC> P- 32

17355.9014 STRAND, PATRICIAN ADMINISTRAT:rl/E rnFORMATION OWNERSHIP

$TR~~D~ PATFl~IA N PO BOX 312 PARCEL NU..~ER

l735S.90l4

?arent Parc~l Nu~..ber N!NS M;LS ~.sL.LSr WA 99026-

II

13206 W CHARLES RD (6) ~nted 02121/2019

511

TRI\NSFER OF Oli'NERSliIP / b._ 1 card No. l of

Date n ,.H' ---

Property Address 13206 W CH~RLES RO

09/()5/2000 BARKER, ROBERT • PATRICL", :J Bk/Pg: I ~~~,<:;.Y

~<;~,eo 0~101/2000 STRAND, f<ALMER D

I.

5 $100000 Bk/Pg: 0,

Ne-ighborhood 231720 $HORS: RNG£ ARE.A 35-27-41

f'rope,rty Class 511 5- Hc~seholC~ single family

T,r:J-:;:nG nr£TRI(.."'f INF'(}fuV.A'!IQ~

Jurisdiction COU

Area 001

Corporation USA

District 0920

Routing ~umber S

S~ts Description

Top-cgraphy;

RESIDENTIAL Assessment Year 05/()3/2013 os;o,1noH

Reason for Chan~e Re"al Eeval

\!ALOATIO,>; L 200000 200000 Posted '.:rue Tax e 183700 182300

"I 383700 382300 VP..1.UATlON" l 200000 200000 A.sses.se:::i t!a.t ue: E 183700 182300

'!: 383700 382300

so 0Bil6l1SS9 'ii'A,'IG, GEORGE & CEAN ,J Ek/Pg: C,

s120000

o/J::=,=\e,\ ~

VALUATION RECORD

--·t t \Y O \ .. A.7-C\4} .. UJ

05/02/201:s 0S/04/20lii Wcrksheet

Reval Revel Raval Re....,.d_l

175000 150000 150000 150000 150000

192700 195700 216000 247900 249600

367700 345700 366000 397900 39960C

175000 150000 150000 150000 :soooo 192700 195700 216000 247900 249600 367700 345700 366000 397900 399600

?ublic U~Lliti€s: LAND DATA AND CALCOLA'!'IONS

Street. vr R·:.ad; Rating Measured SOil IO Acreage

~or- -or-Neighbcrhcr--._.d:

Land Type Actual Effective

From:a;re: Frontage

2:onlng:

Leaa l }\.cres ; 5.0000

J\ppr: Appraisal Notes

1 Fr:c...~ts £.-i.hanc~ment il

04/26/2016 {J5119} SeVal inspection update. Adjusted land tables~ Lower level rer.:-::rved based on owne.zs ·appeal photos,,, changed tu

walko~~ ba~e.~ent. Added lean-tos~ can\~ measure shed by waterfront fram overheads. Land c.~nged 0ith the new 5$!25 tables. 7 /13/'1. 0 Cons.id-er resketc!'...in-o as sfr/basem£..nt w/o- with f:1.l.l basement. fit1ish. ~

6/9/10 3ht38} B£-09-026S Reviewed transcrip~s from past BTA casef provided Cy ~he appellant.. -and taxpayers: admitted in

ta.stimcn:t::y t.hey have. a ufull finished .t-.asement"' or basement./1..owe·r :e~:el, by c.ur <i-etinitiicn. 1s{l02} placed 1900 sf

of basEme.'1.t./1.:. finish fer the: 2009/2010 appeal.. This

infor.:r.ation./~ranscript is ::-e-tained in Mr~ Ar-kills file for furt.:h-e:r. .r-ev.iew. 5-/1B/10 ::-1138J BTA Cass 09-121 SBTA r~:.Bcd in assessor's

5.0000

Table

Effective Depth

Pro-d ~ factor -OI

Depth Facto:: -or-

Square Feet

LOO

Supplemental Cards

ME'..'\SURED A~~EAGS

Base ActjUsted Rate Rat:e

30000.00 30000.00

S~OUOD

£xt.end-ed Value

150000

!nfluence race.or

Supplemental cards

TRUE TAX. VJli . .t.rc

Supple1ricental- Cards TOTAL v.NO VALUE

.. Ja.1-...e

150000

1200(!0

1$0000

N

0 -,-0)

0.

a:: a: a_

.c ,:;: ::, 0

(.) (!) C: {1l ::it:. 0 a_

U)

m E (0

~ a. O} N c<5 C)

0 £:! ..,.. £:! N ::s

s:;_ I-

i (0

E 13 .s <

.... C')

a. (,)

'<!" C')

Q_

PHYSICAL CHARACTEIUSTICS S~y1e: 49 H~c..~ iS00-2299 Occupancy: Singl~ fa~~ly

Story Height: l.0 fini-shed A:-ea ~ 3'&48 P..t:.tic: None. Basement.: fi;ll.

ROOFING :1acerial: r-1eta.: ":'ype: Gable franllng: Std fez: ,::Lass Pitch: N<Jt availsbl~

FLOORING Slat 2 Sub and joists 1. G Base- Al lowanc:.e 1 . D

EXTERIOR COVER Vinyl sicinq

INTERIOR FINISl!.

ACCOMMODATIONS

B, 1.0

Finished Rooms S Be-droc'ilS 3 f~il.-v ~ Roorri.s 1 Formal Pi~~ng Ro,:x"""".S 1

HEATING ANO AIR CONDITIONING ?rim.ar:; Heat:.: t\,rcec: hot :air-e.l ec

Lcwe~ Full Part /8Brot 1 Upper

PLUMBING

5 Fixt.. Bat.h.s 4 Fixt:, 3 f°'i.Yt~ Kit 55..:tK Wat+;:;I heat Extra F:.xt.

TOTAL

,

l ~

5

" 6

1

lS

REMODELING AND MODERNIZATION A.T.l:rur,t. Date

12

17; I l

32[

I

jo3!02jo1}

,,,]L~.

IMPROVEMENT DATA

1 s Fr

B-wo

(§) 64

FrG

@ 2J

' l L 24 I

LL

173SS.S0:4 Prop.art./ Class-~ 511 1320E W CHARLBS RD

Constru<::tion r,.;,:,c,d f r&11.e-

-C.oncre t.e- D-lve~::.

Exterio~ Featu=os ~escr~pcion Value EFS SS30

E'i=:::..she:d Bas& Area Fleer ArEa Sq Ft

204S 1 0 2048

2048 Bsmt 1800 O w:-a;:1

T(,TAL tl~!'..

RO'..~ Type Adjustment SUB-1DTAL

0 Interior Fin£sh 0 Ext. Lvg Uni ts 0 Basement fin~sh

Firepl&ce-{s} tteatin') Aic Contlit::io:o Fran:e/Siding/Rvof Pli.Ul'.bing Fixt: 18

Othei: feat:u:res

SUB-TOTAL 0!.E UNI'!' SUB-TOTAL O ONlTS

Garages 0 L'1teqral

5?6 .ittt. Gacage (! _ll.t.t. carports a B~t Garaqe.

Ext :eat.ure-s

sus-,::.TAL Qual:. t:.y c:as:s/G-r-act€'.

GRP,..DE ADJOSTE.D 'I"~UE

j!,C!1:

Value 176220

S148G (;

227700

l.~O't 227100

{) {)

.,3.,;;;o 0 0 0

1740 20855

2800

29£78S 296?85

~ l:ll C. 0

!)

l:,470 o"" -() 0

5530 N 0)

3: 77S.5 a., Avg- ,0::

295540 CL .;?:.c

:::::l 0

(.) (I)

1 C _oo.oojl

SPECIAL FEATURES

l =~

SUMMARY OF :IMPROVEMENTS

0 ci

(J)

De-:scri p t.-i on

1) ,BASIC -Gl ~c 02. :3SO 03 ,3Sv

Value

2BOO 0

-3 -3

lJSE-

;) U'i'i!ELL GOl ATfGAA O;. POLEBLTXi G;, LEAJJ't.0-1}'.o LE.!>,i'/TO

St..ry Hgt:

OAOO ()_(J()

10-00 :o.oo l(L00

!Data 11:9

COl.l.aetor/Date

i.2/ 10/2D1S

1

COilSt. Year Sff Const. Year Cand Type Gr:act,~

0 0

Avg

fair Fair Fa1.r

2002 2002

2006 2006 200; 2006 zoo;; 2006

Appraiaer/Data

119 0110:.12016

AV AV AV AV AV

Ease F..at.e-

D:.UD 26,St. 10.80

8_0$ $.i33

Siz-e or Ccmpu~ed P-h.ys-Cbsol.Market % F-ea.tur-es

Adj Rate Area V-21:luB DE:~r D€p.r Adj ,:orr.p

y N y y y

0¥00 2f.BG ll.BB 5.49 6_02

Neighborhood

f!e:i git 23172C

4096 2;ix 24 30x {0 l2x ,10

Bx 20

295540 15t..?O 14260

26.3.0 %0

IC V -~

30 30

s 93 () i)

(J 100 a 100 0 10(

Suppl.emantal. cards TOTAL ~ VALUE

AV

10.n 100 100 100 1.00

Value

235000 ()

12100 moo

700

2•l%0(l

I -a; E (l)

~ Cl. 0) N ,;; 0) ..,... § ~

~ :::,

f=. 1= (I)

E .c u tU

cJ?-38

t.O C')

a.

Re: From: Date: To:

Mt'. Hodgson

PRR 2-20-19-Strand 5-Day Letter pat strand Sun 2/24/2019 5:41 PM Hodgson, Byron Attachment: Feb 24, l 9 - Apprnisals attached to clarification of PRR.pdf

Thank you for the appraisal! That you provided an appraisal as the first record to satisfy this l'equest

emphasizes the need to associate my request clearly to the records in your database used to create the

appraisal. I have therefore attached three additional appraisals that in addition to the appraisal you provided are

the basis of this now clarified request. The following table shows the assessment years and specific dates that

this request applies to.

Assessment Year 2015 2016 2017 2018 2019

Specific Date 05/02/2015 05/04/2016 6/12/2017 7/18/2018 Worksheet

Valuation L Land 175,000 150)000. 150,000 150,000 150,000

Posted Tme Improvements 192,700 195,700 216,00 247,900 249,600 Tax B

T Total Property 367,700 345,700 366,000 397,900 399,600

Value

This request has parts A, B and C for electronic records. The request is for the value as of the Specific Dates in

the Table and the 2019 worksheet values on an undisclosed date. This request is for specific records (addresses,

parcel numbers, neighborhoods, sales dates, etc.) i11 your Pro Val database. WAC 44-14-03001 ide11tifies data

compilations (databases) as public records.

WAC 44-14-050 Processing of public records requests-Electronic records.

(1) Requesting electronic records. The prncess for requesting electrnnic pub He records is the same as for

requesting paper public records. (2) Providing electronic records. When a requester requests records in an electronic format, the public

records officer will provide the nonexempt records or portions of such records that are reasonably locatable in

an electronic format that is used by the agency and is generally commercially available, or in a forinat that is

reasonably translatable from the format in which the agency keeps the record. Costs for providing electronic

records are governed by WAC 44-14-07003,

RECORDS REQUEST

A. Please provide the following nine types of records for each year in the table for all sales used to

derive the land values in the above table on the '"specific Date" shown or the

worksheet date. This means I should have 5 separate years of sold properties and specific records on each

sold property, Pro Val code sheets, etc. These records are provide a way to compute the value in the table using

the sales provided or the Assessor's alternative method. These are the records requested:

1. Sold properties sale dates and sale amounts for 5-years of relevant sales to each date,

2. sold property address, 3. sold property parcel number, 4. sold property neighborhood,

CP-39

P- 36

Re: PRR 2-20-19-Strand 5-Day Letter

From: pat strand Date: Sun 2/24/2019 5:41 PM

~-- ~,.··--~d¥son, Byl'on ____ .,.,,._ .. ,. __ .. __ ~··· 2

5. sold property Land Type (on the appraisal Printed 02/21/2019 you show Land Type - 1 Fronts

enhancement #I), and 6. pictures of sold properties.

7. NOTE: items l through 6 should clearly connect each sale to the six asso~iated records,

8. Pro Val code sheet showing identification and explanation of all Land Types in Spokane County,

9. The arithmetic (formula) you used to derive the land values from the individually identified sales [this is

not a request for proprietary information] [are the sales averaged, weighted average, other -- with

specific language ie., sum and divide]. 10, If sales are not the basis for the land value for each assessment year please provide all records by

Specific Date that identifies factors used to value land in this table.

B. Please provide the following l'ecords for each year in the table for all sales used to derive the

improvement values on the 0 specific Date•• shown or the worksheet date. This

means I should have 5 separate years of sold properties and specific records on each sold property, etc.

1. Sold properties sale dates and sale amounts for 5-years of relevant sales to each date (if the same sales

are used for land and improvements then obviously the records only need be produced once,

2. sold property address, 3. sold property parcel number, r

4. sold prope11y neighbot'hood, 5. sold property Quality Class/Grade of house,

6. sold property Style of house with stories and finished area

7. pictures of sold property,

8. NOTE: items 1 through 7 should clearly connect each sale to the six associated i-ecot·ds,

9. Market Adjustment and Obsolescent Depreciation on 17355.9014 are recapped when available in the

following table. Please provide the sold prnperties Lhat are the basis orthesc values for each year. If

sales are not the basis provide the records showing the basis of these adjustments. It is troubling that a

house constructed in 2002 according to yom records is obsolete according to your l'ecords. I want the

records showing the basis fot·

10. Assessment Year 2015 2016 2017 2018 2019

Specific Date 05/02/2015 05/04/2016 6/12/2017 7/18/2018 Worksheet

Improvements 192,700 195)00 216,00 247,900 249,600

Obsol Depr 5 s 5 ') 5 . Market Adj 73 71 79 ? 93

1 l. Pro Val code sheets identifying and explaining Market Adjustment and Obsolescent Depreciation,

12. The arithmetic (formula) you 11sed to derive the improvement values frorn the individually identified

sales [same request as stated in A.9.], 13. If sales are not the basis for the improvement values for each assessment year please provide all records

by specific data that identifies factors used to value improvements in this table. ·

CP-40

P- 37

Re: From: Date:

PRR 2-20-19-Strnnd 5-Day Letter pat strand

To: Sun 2/24/2019 5:41 PM

_l}odgso11, Brro~ pg3 ____ _

C. Please provide the following records for each year in the table for all sales used to derive the

total property values on the "specific Date" shown or the worksheet date. This

means I should have 5 separate years of sold properties and specific records on each sold property, etc. (Again

there is no repeat if land and/or improvement sales are the basis of total property values)

1. Sold properties sale dates and sale amounts for 5~years of relevant sales to each date,

2. sold property address,

3. sold property parcel numher,

4. sold properly neighborhood,

5. sold property pictures, 6. NOTE: items 1 through S shout.a clenrly connect each sulc to the six assodateel recores,

7. The arhhmetic (fomrnla) you used to derive the total property value from the sold property values f san1e

request as stated in i\.9.],

8. If sales are not the basis for the total property values please provide all records by Specific Data that

identifies. factors used to value total property.

I hope this clari!ied what l am requesting. l f you have any questions please stale them.

Please provide a statement of the time required to produce these records. T will immediately provide USB

drives for downloads of the data.

Patricia Strand 509-467-0729

CP-41

P-38

17355.9014 STRAN•, PA TRICIA N 13206 \\' CHARLES RD ADMINISTRATIVE INFORMATION OWNERSHIP Printed04/25!20!8 ca.,'",,,.

;:;•,<r?:-,-:Lt~ t~ TruU.SFER OF O~"ol!;RSH!P ?:) sc:z

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,::1;;1}S-./?.G;J:1;. M.J:'!.Kr?.., ~c-:s:sR: 5: Pl-:.TaP:n~, .; :::,<-·r.;: --}~:'1-f;

p:.:: ,;~ 'G.:J2~:'>i· .s,;:_"f<J,:..rJ-i)., 2'?..:LNE.r":. ...,

:;.::;

02 / ~ ("::_,,·'·t ~·-;J >7'L., ·~ ·~.-:::<:t.,::': ..s .. 1:: sf ili:f?i,;.·.:.

p_~:;r. F.R.SA 3~-:2:·;·~!l

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~,~_;ri~.:-::--::~.:.,:;-.-;:-;- .cw

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RESIDENTIAL V1U,D.ATION RECORD

Ct.:.r; :,..-__ ':!:.:..:);, US?+ ;..::.se!::s>~.nt ·f~.,.,r. t: ... ~<-:. .... .;! ::-.:...i. r,5.-":1:'./?Ci: J JS-, ~2/2-~< .. ': D:../c,"i/2:.1:f.: .. .-~.--

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Site ~scription -::AI.,;..r.;.,T.:et~ :.

"!'::.u-~--,.,.-, ~:r· J,.:.::s~.:::-::;-2--: \.";; ~-.:::t"'

F-t.<.:-r::..1

200000 1877Df. 3BTiOG

3:27700

R~~r::::.l

200000 18370J 3337DO 200000 l ~'?'"'.f{",(';

~,.;,; ,,.y._l

383 700

2 Hl23CO 382300

·.:c:e~~-1:1

li5G~O 1327GO 3s,-:vo 1-;- .';Q00 19~:"0JJ 36770D

t'\:c::tJ:-:: n·.·;.J.~-:~<>~·~ LAND DA'l'A AND CALCULATIONS

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BASEMENT' VVJtLKOtrr sue .. TYPE (BWS) (Applies to Type Codas 4'h85, 74,75,81,82.85,92,94 & 96)

Certain houses are designed for a hillside location wtth quality ffving area in the basement opening onto a patio or yard from the basement level. Because of the outside acooss, windows and above ground exposure available to tha basement level in this hillside design, the basement living area becomes an integral part of the living area of the entire house. The Basement Wa Sub-Type ~W~l code identifies houses with this eature. first two pfctures low are the front and rear views ·of this

type of hillside design. As can be seen, the design is not apparent from the front. The third ploture is 13.nother example of this design from a side angle. Both of 1hese houses appear to be ooe story from the front and two story from the rear. Toa design Is sometimes reversed when the hill slopes up ,

· behind 1ha house Instead of down. causing the house to be. mis .. ooded as a two story when viewed only from the front. The design is popular and Is not l!mHed to one story houses {called walk .. out ranch), etthough this typG Is the most frequently found.'

ElWS CODE DESCRIPTiON

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· No basement ;:.1,

Standard basement i}'

Garage rn basement, but no windows or outside acces$ from .J tho rest of the basement level ,

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finished living area

Basement walkout design, with or without garage, with finished living araa

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20 Section 5: Estimating, .Value

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~, ., SPOKANE COUNTY

April 16, 2019

Ms. Patricia Strand

[email protected]

Public ·aecordS'()ffic~ 1116 W. B.roadw~y Avenue

Spokane, Washington 99260-0270 (509) 477-1721 FAX:. 477-2597

Re: Appeal for Review of Public Records Request 2-20-19-Strand

Dear Ms. Strand:

I am in receipt of your email dated April 13, 2019,. in which you seek a review of a public records

request you submitted to the Spokane County Assessor's O'ffice on February 20, 2019. This

request was assigned reference code 2-20~19-Strand. After a thorough review of the subject

request, as well as your subsequent clarifications, and of the records produced to you by the

Assessor's Office, I am of the conclusion that all identifiable public records responsive to your

request have been produced.

Should you have any further questions or concerns regarding this matter, please do not

hesitate to contact me.

Sincerely,

Tony Dinaro Public Records Officer

(509) 477-2287

cP l<o1

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Index A - 19-0001 BOE Response - pg 2 of 24

COST VALUATION REPORT (CVR) Owner : Knox. Christopher

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Situs Address : 10615 Danica Ln SE, Olympia (1)

Neighborhood : 2401 Property Type : Residential

Parcel Number: 21705221101 Assessment Year: 2019.

4-'0~ 7 Adjustments

Value Method I Adjusted Adjusted

LOI Flag Type Land Size Rate Size Adj. Base Value Type Description Factor Amount Value •

1 A 9150 p 3.890ACRES 31,301.00 1.188 144.652 ,I 144,652 WATER'=1 RATE:3,500 3,500 148,152

SEPTIC=01 RATE= 2,000 2,000 150,152

(2) RESIDENCE (recl0=1) Number of Famllles 1 Main Finished Area 1585 Qualltv GOOD Year Built 1987

Number of Stories 2 UDDSr Finished Area 2054 Condition AVERAGE Effective Year Bullt 1993

Bulldlna Stvle 25TORY Additional Finished Area 0 Addt'I Finished Qualltv 'k Good (Fhvs.fFunc./Econ.) 77195/100

Exterior Wall Type WOOD-SIDING unnnlshad Area 0 Basement Qualltv Percent Complete 100

Description Measurement Cost . Factor RCN RCNSQFT 'k Good RCNLD

Base 2-storv: SldlnQ/Shlnole 3639 105.04 1.00 382.241

Roof COMPOSITION ,

205,4 12.04 1.08 26,709 .

Garage Buillin Gara11e Area 906 33.18 30,061

BasaSooi 439,011 120.64

\.-. Plumblna Number of Plumblno Fixtures 16 2.912.00 46,592

Heatlm HTPUMP/AC 3639 9.22 33,552 ' -~ Flral:l!ace Masonrv FireDlaces 1 8,506.00 B.506

Porch Covered Porch 618 47.97 29,645

Balcony Balconv 91 37.43 3,406

Patio Patio 406 9.96 ·4,044 '

Adlustsd Sum . 125,745 J 34.55

RESIDENCE TOTAL l 564,756 l 155.20 73 412,272

(3) DETACHED STRUCTURES ~ ~- ~ . Description Qualltv CondlUon Class Measurement Cost Year Built RCN RCN SQFT %Good RCNLD

BARN WITHOUT LOFT Fair/averaoe Averaoe D 480 26.99 1993 23,889 49.77 71 16,961

CANOPYICOVER Fair/averaoe Averane D 480 12.-46 1993 5,562 11.59 71 3,949

STORAGE SHED Fair Averaoe D 256 20.59 1993 5,113 19.97 71 3.630

FRAME GARAGE Fair Average D 312 44.89 I 1993 13,586 43.54 74 10,054

STORAGE SHED Low-cost Average D 140 20.59 1990 3,076 21.97 66 2,030

POLE BARN Fair Average D 720 18.69 1990 15,247 21.18 66 10.063

STORAGE SHED Low-cost Avera9e D 240 20.59 1990 4,793 19.97 66 3,163

MACHINE SHED Aver.me Averaoe 336 20.52 1990 12,714 37.84 66 8,391

CONCRETE PAVING Fair Averaoe 1.444 6.51 1990 9,400 6.51 66 6,204 .. _

(4} PARCEL TOTALS BEFORE NEIGHBORHOOD ADJUSTMENTS (5} MARKET VALUE ESTIMATE Land $150,152 .-------------,------.--------,----,------, Resldantlal Buildings -·

$412,272

Moblle Homes $0 Land Detached structures $64,445 Buildings & DetachedStruc:tures

Commercial Bulldlnas so Total Propeny Value

COST ESTIMATE $626,869 Square Feet of Living Area !SrLAl ··-·-··-······

@ ~ ~\J-E'PtlAr°f

ThUi'S({,f ~JIT~9tt!J!;g_~y~202C

Coi¢Est. I __ ~ .. y- . . I NBHD

Amount _A_dj. __ $150,152 o I o.ssoo $476,717 o I 1.1250 $626.869 0

Final Value

}127,600 $536,300 $663,900

3,639

CP-202 PAGE2.

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Index A -- 19-0001 BOE Response - pg 3 of 24 C"\

~ 8 ~ N

0 d. Ratio Statistics Measure Value IAAO Residential Standards

Median 0.931 0.90 to 1.10

Coefficient of Dispersion 0.105 Less Toan 0.200

Price Related Dlfferentlal 1.010 0.98 to 1.03

Neighborhood Sales Listing Nbhd Sale· Sale Building Style Year Bsmnt Fin.

Parcel No. Code Date Price Acres Built Olly Cond SFLA Area Bsmnt

21830440101 24Q1 7/31/2018 $125,000 3.90 " 10430 SI Cfalr Cut Off Rd SE, 0/tmef.a

21831110800 24Q1 7/19/2018 $123,000 0.53 4215 Lake House Ln SE. Olt.mple

79402400200 24Q1 4/25/2018 $109,000 3.48 5412 Peninsula Dr SE, Otyme!._a

55070009600 2401 9/26/2017 $79,000 1.28 9641 38th Ct SE. O~is

21706214704 2401 5/23/2017 $9,000 0.06 Unknown, Tumwater

21832210202 24Q1 3/22/2017 $30,000 0.45 4036 Thornton Rd SE, Olf!71f!.IB

79402400200 2401 3/31/2016 $86,000 3.48 5412 Peninsula Dr SE. Oft.me/a

21706110500 2401 6/3/2014 $130,000 5.35 6120 Lake Saint Clair Dr SE, 0/.r_mpla

55050001900 2401 9/10/2018 $370,000 2.45 11/2STORY 1979 A GD 1808 None 4808 Yorkshire Dr SE, Olympia

21832111100 2401 5/11/2016 $650,000 5.00 11/2STORY 2003 G+ AV 2038 None 4311 Wildhorse Ln SE • OJ.l.me_la

21706214900 2401 4/13/2016 $250,000 1.25, 11/2STORY 1932 A AV 1374 898 None 9725 SE 62nd Av, Olt!!!£.ia

55050001900 2401 6/5/2015 $265,000 2.45 1112STORY 1979 A GD 1808 None 4808 Yorkshire Dr SE, 0/.r_me_la

21706410400 2401 9/16/2014 $429,950 5.85 1112STQRY 2005 A+ AV 3120 None 10401 Kiwa Dr SE, O!Xf!.!ela

36440003100 2401 2/20/2019 $310,000 0.56 2STORY 2002 A AV 1568 None 5934 BralJ!.ood Ln SE, O!z.me.fa

55060005400 2401 5/15/2018 $395,000 2.20 2STORY 1983 A GD 1929 None 9547 Berkshire Ct SE. O(l_mpla

21832430302 2401 5/15/2018 $320,000 5.61 2STORY '- 1999 F AV 1320 None 11138 SE Yelm Hwy • 0/ympis

81050000300 2401 5/10/2018 $390,000 0.27 2STORY 2005 A+ AV 2388 None 10343 Wildwood Ln SE, _Lacel

CP-203

Thi ''"''('P,~l-]J]P!'il t!!;-9~'-·)~2"" PAGE3 t 1i .... ,,~e: .... . • . ./-··-~ ., -) • .,t, ... -..., ... 1 .... t >-··':, x-'L·""'•J <: '

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lnd§X A-- 19-0001 BOE Resgonse- gg 4 of24 T ~

c-.1 ,:--

Neighborhood Sales Listing 0

'b N

' Nbhd Sale Sale Building Style Year Bsmnt Fin. 0..

Parcel No. Code Date Price Acres Built Olty Cond SFLA Area Bsmnt

09610023002 2401 11/8/2017 $370,000 2.07 2STORY 1978 A AV 2028 None 9536 Yelm Hwy SE, OlrJ!!.ef.a

21829440300 2401 10/19/2017 $459,750 5.00 2STORY 2003 A+ AV 2664 None 4238 Wildhorse l.n SE, Oll_mf!!.a

21829440600 2401 10/4/2017 $480,000 5.00 2STORY 2004 G AV 2872 None 4040 Wildhorse Ln SE, O!l_m la

€>09350009000 2401 8/31/2017 $975,000 24.88 Assessor Sale 6 2STORY 1983 G AV 3844 None

9551 Yelm Hwy SE, OIE!£.fa

81050004500 2401 8/23/2017 $250,000 0.25 2STORY 1985 F+ VG 2160 None 5423 SE Ramblewood Ln • OIY.!!9!/f!

21830410300 2401 7/17/2017 $675,000 5.00 Assessor Sate 1 2STORY 2013 G AV 3520 None

10205 SE 35rh lJI , O!l_mpla

55050001700 2401 5/24/2017 $385,500 1.72 2STORY 1986 A GD 2842 None 4606 Meridian Rd SE, Oll!!!JJia

55070008700 2401 4/1/2017 $445,000 0.97 2STORY 1991 A+ GD 2711 None 9536 SE 40th Ct • Lacer_

21706130109 2401 2/24/2017 $453,000 3.18 2STORY 2016 A+ AV 2860· None 6910 Thoroughbred l.n SE. OtymB_la

21706130107 2401 11/14/2016 $475,000 3.18 2STORY 2016 A+ AV 2860 None 6822 Thoroug_hbred Ln SE, Olympia

55060004200 2401 612/2016 $380,000 2.86 2STORY 1983 A VG 2272 None 9708 Bedcshire Ct SE. Olyme_ia

21832430302 2401 5/2/2016 $287,950 5.61 2STORY 1999 F AV 1320 None 11138 SE Yelm Hwy. Olt_mpia

36440003100 2401 4/13/2016 $258,000 0.56 2STORY 2002 A AV 1568 None 5934 Bra}Wood Ln SE , Otrm ia

55060005400 2401 3117/2016 $300,000 2.20 2STORY 1983 A GD 1929 None 9547 Berkshire Ct SE. OtymeJa

nooo100000 2401 10/14/2015 $399,900 0.95 2~0RY 2006 A+ AV 2670 None 6547 Lake Saint Clair Dr SE. Ollfl'pia

36440002200 2401 5/5/2015 $263,500 0.94 2STORY 2002 A AV 2176 None 5524 Braywood Ln SE. O!l_m ·a 21832110300 2401 3/26/2015 $325,000 5.00 2STORY 2003 A+ AV 2664 None 4238 Wildhorse Ln SE, O!Y_mela

77000700000 2401 1218/2014 $365,000 0.95 ' 2STORY 2006 A+ AV 2670 None 6547 Lake Saint Clair Dr SE. Otl_mpia

55060004800 2401 7/1712014 $265,000 2.08 2STORY 1976 A AV 1957 None " 4103 SE Yorkshire Dr. Ott.me!!!_

55060003000 2401 4/28/2014 $330,000 329 2STORY 1989 A GD 1977 None 9918 Berkshire L~ SE, 0~

36440000500 2401 2/19/2019 $342,400 0.39 RAMBLER 2001 A AV 1798 None 5939 Brs_ywood Ln SE, O!l!!J la

/v.f'G-A-1~ CP-204

"l,urst,J':~'tffA9~sll!i~~~r2D2C PAGE4

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

A.

received evidence from the Assessor of a sold property used to value 17355.9014. I

Allegations are not evidence. ( emphasis added)

III. UNDISCLOSED VALUATION FACTORS

h. Proof Denied Records Exist

On January 25, 2010 in BTA Docket 09-121 the Assessor's respond to discovery with

these records (P-308 to -312): (Factor 1) residences are alleged to be valued using

Pro Val Marshall & Swift cost tables; (Factor 2) land is alleged to be valued using Pro Val

models of neighborhood 231720 sales based on topography, soil, view, lot configuration;

(Factor 3) land is valued using appraiser judgment; (Factor 4) the "Market Adj" on cards

is alleged based on the local real estate market implying an analysis; (Factor 5) Assessor

has alleged authority under RCW 84.40.025 to enter every structure on 17355.9014.

There is no allegation of how total property value is determined.

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•

(Factor 1) alleged use of Marshall & Swift cost tables to value structures (Factor 2) alleged use of Pro Val land model with criteria for land values (Factor 3) land value is appraisers' judgment (Factor 4) is alleged use of local real estate market analysis for cards "Market Adj" (Factor 5) is RCW 84.40.025's statutory authority to enter private structures

(Factor 3) appraiser judgment is confirmed in preceding paragraph that Plaintiff

realleges and incorporates as proof of (Factor 3).

(Factor 5) is a false statement. RCW 84.40.025 is not an assessor statutory

authority to enter any structure. It is statutory authority to go onto land and inspect the

exterior of structures for valuations. Entering structures to value real property violates

Response to Defendant's Motion for Summary Judgment PN Strand, Plaintiff P- 267

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the 4th Amendment to the U.S. Constitution and Article 1 Section 7 of the Washington

Constitution.

Seymour v. Dep 't of Health, Dental Quality Assurance Comm 'n, 152 Wn. App. 156; 216 P.3d 1039 (2009) states disciplinary agencies with specific statutory authority to enter structures, without a warrant, predicate warrantless searches (inspections) on the agencies having evidence that meets probable cause of breaking the law that is submitted to review panels that have to weigh the evidence and authorize the warrantless search. ( emphasis added)

(Factor 5) was confirmed as a value factor in decisions in BTA Dockets 09-121 and 10-

258 (P-313 to -345). Strand denied the Assessor access to her home and the BTA refused

to hear Strand evidence for mischaracterization of her basement and no sales to support

land value. (Factor 5) was confirmed when Appraiser Laura Vazquez used it in appeal

BE-17-0190. The Assessor's Answer to Real Property Petition has Ms. Vazquez's story

about invading the home of Steve Morse to find things to counter his appeal of a $54,000

valuation increase. (P-346 to -353) (Factor 5) worked. Mr. Morse settled for a one-time

reduction in value of $5,000 in a stipulated agreement

In February 2012 and on November 22, 2013 Mr. Hodgson stated and testified to the

Assessor's policies and procedures to not list and value docks, driveways, in-property

(private) roads, electric utility service, water wells, septic systems, sidewalks, etc. (Factor

6) He also testified to (Factor 4)-the Assessor does no local market analyses but relies

completely on Marshall & Swift cost tables. (P-354 to -361) Strand has repeatedly made

PRA requests for a complete list of all structures that are not listed and valued and market

analysis. The requests were denied by the Assessor.


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(Factor 6) violates the plain language of RCW 84.40.030 to list and value all

structures that affect 100% of true and fair value ofreal property. (Factor 6) hides

structure values in land values that may or may not have these structures or these values.

This practice violates WA. Constitution Article 7 Section 1 - uniformity of valuation.

RCW 84.40.030 Basis of valuation, assessment, appraisal-One hundred percent of true and fair value ... (3) ... following criteria:

( c) In valuing any tract or parcel of real property, the true and fair value of the land, exclusive of structures thereon must be determined; also the true and fair value of structures thereon, but the valuation may not exceed the true and fair value of the total property as it exists ....

Sanders v. WA., 169 Wn.2d 827 and 864; 240 P.3d 120 (2010) - ('"If the statute's meaning is plain on its face, then courts must give effect to its plain meaning as an expression of what the Legislature intended."' ( quoting State v. J.M, 144 Wn.2d 472, 480, 28 P.3d 720 (2001))).

Appraiser Sporn in BTA Docket 16-070 and 17-122 affirmed (Factor 6) Docks,

boat lifts and slips, septics and wells were on Assessor evidence for market value (MLS

Residential Public Handout ... - second kind of factors). Strand entered cards into

evidence. These structures are not on cards. (P-362 to -407)

• (Factor 6) Assessor policies and procedures to not value specific structures

On January 22, 2016 Appraiser Sporn in the hearing for BTA Docket 13-179 testified

land is valued based on raw land sales (Factor 7) not the alleged Pro Val model (Factor 2).

(P-408 to 413) He testified there were no raw land sales for the $200,000 land value for

17355.9014 and other high-bank waterfront properties in neighborhood 231720 that

existed from 2008 to 2015. (Factor 8) In BTAs 09-121 and 10-258 Strand reported and

provided the records proving there were no land sales. Valuations were based on

Response to Defendant's Motion for Summary Judgment PN Strand, Plaintiff P-269

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valuations that probably originated with appraiser judgment (Factor 3). There are also no

raw land sales for the $175,000 and $150,000 17355.9014 and similar high-bank

waterfront parcels - 2016 and 2017 values. The bases of those values have been

requested and nothing produced as shown with the current responses that ignore valuing

land and structures in total.

• (Factor 7) raw land sales are alleged as determinative of land values

• (Factor 8) there are no raw land sales to support land values in neighborhood 231720 from 2008 to the present

On May 9, 2017 the Decision in BTA Docket 13-179 stated for the 2013 value year the

Assessor had mischaracterized and over-valued Strand's basement based on Strand's

analysis of basement value using (Factor 9) Department of Revenue ("DoR") Marshall &

Swift Cost Tables that Strand entered into evidence, (Factor 10) (P-414 to -418); Strand's

building permit (Factor 11) (P-419); Pro Val code sheets from the Assessor (P-159 to -

160) and (Factor 12) Strand's 2009 appeal photos of her house.

In this Decision the BTA decided Strand's land was over-valued by $50,000

based on the Assessor's land valuation that included the value of a road Strand never had.

The evidence for the road value was (Factor 13) Strand's analysis of cards on two similar

parcels that owned the road. (P-420 to -427) Appraiser Sporn notes of his physical

inspection and his shifting of approximately $50,000 of land value between the owners

were the key facts. (Factor 13) A recorded agreement from 1993 for payment and

ownership of the private road was the final evidence this was about the road (Factor 14)

Response to Defendant's Motion for Summary Judgment PN Strand, Plaintiff P-270

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(P-428). The Assessor never listed or assessed the road but it was valued solely for the

owners - not for similar properties violating WA. Constitution Article 7 Section 1.

This transaction is about (Factor 6) and how it violates uniformity of valuations!

• (Factor 9) DOR Marshall & Swift cost tables used to value Strand basement • (Factor 10) Strand's building permit describing basement • (Factor 11) Assessor's Pro Val code sheets describing walkout basement • (Factor 12) owner's house photos from 2009 BTA 09-121 • (Factor 13) valuing a private road whose value is buried in land value only for

owners; $50,000 increase in land value for owner with road on their property, $50,000 decrease in land value for owner without road on their property

• (Factor 14) Recorded Agreement on structure

(Factor 15) the Assessor's policy and procedures to not correct errors on cards. Assessor

Vicki Horton testified the card is alleged as the only record on real property and

everything on that parcel. (P-429 to -431) Strand notified Assessor Ralph Baker through

the physical inspection process about card errors on May 7, 2009. Strand repeatedly gave

notice more than annually thereafter. Strand sued the Assessor multiple times. Strand

appealed the over-valuations a lot. The BTA for the 2013 value decided the value and

facts were wrong on the card. The card was not corrected and Strand 's property was

over-valued. The card was not corrected because Strand was being over-valued. WAC

458-07-015( 4 )(b) requires the Assessor keep accurate records. Plaintiff realleges the

preceding paragraphs and incorporates them by reference into (Factor 15) proof.

• (Factor 15) Assessor policies and procedures to not correct erroneous cards

On December 20, 2017 in BTA Docket 16-070 and 17-122 Strand motioned for

discovery for the basis of the 2017 and 2017 values of 17355.9014. On March 2, 2018

the Assessor responded with an email alleging, (P-432 to -441)

Response to Defendant's Motion for Summary Judgment PN Strand, Plaintiff P - 271

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1. The sold properties used to establish the value for 17355.9014 can be found In the 2015-2017 final review reports for neighborhoods 221700, 221710, 221730, 230700, 230710, 231700, 231720, and 231730. We provided property record cards to show how we valued parcel 17355.9014.

(Factor 16) are the Assessors' practices of false statements about records that are

determinative of a parcel's value. Records determinative of 17355.9014's values satisfy

RCWs 84.40.030 and 84.48.150. They are records of similar sold properties and factors

that are clearly stated as being determinative of 17355.9014's values ofland, structures

and total property at specific times. The Assessor has never produced such records and

Strand has requested them continuously since February 2009.

Another proof of these false statement are Assessor allegations to February 20 and

24th 2019 PRA requests that Neighborhood Final Review, Batch Pricing, Value

Calibration Analysis by Neighborhood, etc. ("reports") were responsive to the requests.

This allegation directly conflicts with the allegation for the same records made another

time. On March 15, 2019 the Assessor alleged one report from neighborhood 231700

determined the 2015 value. On March 2, 2018 the Assessor alleged eight different

neighborhoods' reports were the basis of the 2015 value. The content of the reports is the

same; the content is nonresponsive. Appraiser Sporn is the interpolater of all of the

reports.

Factor 16 is predicated on the Assessor complying with Constitutional

Articles and Sections, Title 84 and Title 458 on valuing real property! The

documented factors of Assessors' evidence, policies, procedures, practices, etc. prove

the Spokane Assessors do not comply with these laws. ( emphasis added)


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• (Factor 16) Assessor policies and procedures to make false statements about disclosure of records that are determinative of a parcel's value

On April 27, 2019 Mr. Hodgson stated in the Spokesman Review, (P-442)

The way the county determines home value is governed by state law, which states that property "must be valued at one hundred percent of its true and fair value in money." That's generally "interpreted as fair market value," Hodgson said, noting that state law prohibits using a home's sale price as its assessed value.

Instead, appraisers use statistical analysis to calculate assessed value, drawing from a number of sources, including comparable home sale prices in a neighborhood, what type of house it is and the neighborhood's character. The county's analysis even divides residences up by ranchers, split-level two stories, small houses and large houses.

State ex rel. Morgan v. Kinnear, 80 Wn.2d 400,402,405; 494 P.2d 1362 (1972)

(SC No. 42123), found uniformity of valuation (Article 7 Section 1) requires valuing all

property at 100% of true and fair value - the sale price. Kinnear,

The law strives for certainty but has developed few, if any, absolutes. Even in the field of valuing and taxing real estate, it has failed to achieve more than a moderate degree of exactitude. Since statehood and earlier, in the hope of attaining a fair measure of certainty, uniformity and equity, land has been valued for tax purposes in this state at its fair cash market value an idea made a part of the constitution by the Seventeenth Amendment. The goal has always been: real-estate taxes fairly assessed and uniformly applied.

Last year, the legislature sought to reduce the valuation of real property by allowing assessors to deduct from the valuation the reasonable cost of sale. Laws of 1971, ch. 288, § 1, p. 1520. The assessor for King County now challenges the constitutionality of this enactment, and the Department of Revenue, in accordance with its duties under the law, seeks to meet this challenge ....

The director of revenue, in accordance with other provisions of the same statute (RCW 84.40.030), thereupon initiated a study to determine the reasonable costs of sale, and we are advised that the studies thus far indicate that such costs will be about 10 per cent of the appraised value ....

Neither the constitution nor the opinions of this court leave any latitude in the legislature to alter, reduce or amend the constitutional concept of true and fair value in money or permit the interposition of an extraneous formula to be employed by the assessing authority in determining true and fair or fair market value

Response to Defendant's Motion for Summary Judgment PN Strand, Plaintiff P - 273

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(Factor 17) the Assessor does not value sold properties at their sale price, violating

RCW 84.40.030 Basis of valuation, assessment, appraisal-One hundred percent of true and fair value .. (1) All property must be valued at one hundred percent of its true and fair

value in money and assessed on the same basis ... (3) The true and fair value ofreal property for taxation purposes ... must be

based upon the following criteria: (a) Any sales of the property being appraised

The Assessor has produced thousands of pages of sales records with values as allegedly

determinative of strand's total property values. (P-443 to -467) Those pages support Mr.

Hodgson's statement. The sale prices are not the values. RCW 84.40.020 states

valuations are as of the pt of the year. This means the sold price should be the value as

of the pt of the following year. In Spokane that does not happen.

Mr. Hodgson states, "appraisers use statistical analysis to calculate assessed

value". His statement means that calculated value is a function of a secret formula. If

sold properties are not valued at the sale price uniformity of valuations means unsold

properties are not valued based on sold properties sale prices. There is no evidence of

any kind of statistical analysis!

• •

(Factor 17) the Assessor does not value sold properties at their sale price Factor 18) the Assessor has a secret formula for valuing real property

H. Accredited appraisers violate the Uniform Standards of Professional Appraisal Practice

by complying with the preceding Factors that violate the WA. Constitution and statutes. 5

(Factor 19) (P-468 to -469) Spokane County contractually requires appraisers know the

Accreditation of state appraisers RCW 36.21.015, WAC 308-125 et seq, WAC 458-07-030(5)

Response to Defendant's Motion for Summary Judgment PN Strand, Plaintiff

c__P L'l s P- 274

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A.

B.

law as a condition of their employment. (P-470 to -478) Assessors Horton and Kanis

were accredited appraisers.

• (Factor 19) the appraisers are violating the law, their contracts for hire and USPAP

IV.FRIVOLOUS PLEADING

a. A Frivolous Memorandum

The Defendant's Memorandum in Support of Motion for Summary Judgment gives this

statement as the Standard of Review,

As the moving party, defendants bear the initial burden, however, a "moving defendant may meet the initial burden by 'showing' ... that there is an absence of evidence to support the nonmoving party's case."

This standard is allegedly met with this argument,

The Plaintiff has failed to show a PRA violation.

ln responding to Mrs. Strand's requests all locations where responsive records could be located were searched including: • Department shared drives; • Electronic databases: • Local computers; and • Websites (Declaration of Hodgson)

b. The Complaint Proves PRA Violations

Strand's Complaint contains eight Causes of Action of PRA violations. The Causes of

Action are proven making judicial review proper by the facts, evidence and law. The

Complaint took Strand two weeks to write and research. Strand believes it is well written

and authoritative! Strand believes it presents the facts, evidence and law accurately and

completely. It uses the specific language to summarize the facts of PRA

o (? ,-1 C(I._\

Response to Defendant's Motion for Summary Judgment PN Strand, Plaintiff

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p - 275

Thurston County Property System Page l o! t)

Search criteria used: Neighborhood of: 2170S221101

Sale year >= 2015

Neighborhood Sales Search_

• Included are all property transfers in your neighborhood that traded for greater than $0.

• Some property transfers shown are not considered valid for the purpose of determining market value.

• Verify codes that are typically used in determining market value are AA, LO, and SI. Click here for an explanation of the verify codes used by our office.

• Transactions that have been used to determine the most recent assessed values in your neighborhood are marked with "***Yes***".

• Any Sales marked "No11 have not been used to determine the most current assessed values. These could include sales that were used in past years to determine assessed values or that will be used in the next valuation year. These sales could also include sales that have been reviewed and found not to be representative of the market.

Click Here for Print Friendly Report

Cancel

l . Used For Neighborhood

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Situs Address 'Property Type Date of Sale Sale Price Verify Code Analysis ,

I ----------- L __ OMULLEN RDSETRLRG 18 - OTHER-RESID 1/23/2020 $182,000 AA No I 0 38TH CT SE 91 - UNDEVELOPED-LAND 1/6/2020 $164.000 AA No

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$399,900

$90,000

$296,000

$280,000

$243,745 $527, -

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THE BOARD OF TAX APPEALS ST A TE OF WASHINGTON

PALMER STRAND and PA TRICIA STRAND,

Appellants,

V.

VICKI HORTON, Spokane County Assessor,

Respondent.

) ) ) ) ) ) ) ) ) ) )

---------------)

Docket No. 13-179

RE: Property Tax Appeal

INITIAL DECISION

9 This matter came before Alejandro Sanchez, Senior Tax Referee, presiding for the Board

lO of Tax Appeals (Board) on January 22, 2016, for a formal hearing pursuant to the rules and

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procedures set forth in chapter 34.05 RCW (the Administrative Procedure Act) and chapter 456-

09 Washington Administrative Code (WAC). The Appellant, Patricia Strand (Owner), appeared

prose. Ronald Arkills, Deputy Prosecuting Attorney for Spokane County, represented the 13

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Respondent, Vicki Horton, Spokane County Assessor (Assessor). Jay Sporn, Residential

Appraiser with Spokane County, testified on behalf of the Assessor.

The Board heard the testimony, reviewed the evidence, and considered the arguments

made on behalf of both parties. The Board now makes its decision as follows:

VALUATION FOR THE 2013 ASSESSMENT YEAR

DOCKET NO. AND PARCEL

NO.

13-179 17355.9014

VALUATION OF THE ASSESSOR AND COUNTY BOARD

Land: $200,000 Im.._..pr.....,..: _ _.$ ..... 1 ..... 83 ....... , 7 .... 0 ..... 0 Total: $383,700

INITIAL DECISION - Page 1

CONTENDED V ALU A TI ON OF

THE OWNER

Land: Impr: Total:

$150,000 $175,000 $325,000

VALUATION OF THEBOARDOFTAX

APPEALS·

Land: $1'58~~ -.Impr.:,c $U1~.:GOO .. ·_ To,tal: -.. $3~~~ ·

,-, ' "~ ·,

Docket No. 13-179 P-286

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NATURE OF THE CASE

The Owner appeals to this Board the unfavorable decision of the Spokane County Board

of Equalization (County Board), which sustained the original assessed value of the subject

property for the 2013 assessment year. The subject is a single-family residence with waterfront

along the Spokane River.

For her case, the Owner argues generally that the Assessor's valuation of the subject

property violates Washington's constitution, and its valuation statutes and .administrative

provisions. Chiefly, the Assessor fails to properly describe or give effect to certain

characteristics of the subject property. For instance, the Assessor values the subject's basement

as a "lower level" when it is instead a walkout basement. Moreover, the Assessor fails to give

appropriate consideration to the value of improvements like docks and in-property roads. By not

including these and other improvements in her valuation methodology, especially when the

subject property is not, like its neighbors, similarly disposed, the Assessor has overstated the

subject's assessed value.

In addition, the Owner argues that the Assessor failed to comply with her request for the

valuation criteria used to assess the subject property .1 Specifically, the Assessor did not provide

the Owner with the Marshall & Swift cost ti:!.bles used in the Assessor's mass appraisal model;

the land sales used to value the subject's lot; or the improved sales that support the subject's total

value.2 In the Owner's view, her contended value of $325,000 properly accounts for the

subject's physical characteristics and is otherwise supported by sales she supplied to the County

Board.

In response, the Assessor relies primarily on three sales ofresidential properties within

the subject's market area. According to the Assessor, unlike the Owner's sales, hers are the best

comparables available, and their adjusted sale prices, which range from $379,400 to $416,100,

fully support her assessed value. To corroborate the reliability of her mass appraisal model, the

Assessor also supplies a ratio study of sales within the subject's market area. The study· shows

that the Assessor has valued residential properties within 11 percent or less of their eventual sale .

prices.

1 RCW 84.40.020 mandates that assessors make available for public inspection the listing of taxable real property

and all supporting documents and records. RCW 84.48.150 mandates that, in anticipation of a county board hearing,

assessors provide owners with comparable sales or other valuation criteria used to value the subject property upon

request. 2 The Assessor does supply sales, but the Owner argues that they are not valid as comparables for the subject.

INITIAL DECISION - Page 2 Docket No. 13-179 P-287

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ISSUE

Does the Owner meet her burden of proving that the Assessor erred in her original

assessed value for the subject property for assessment-year 2013?

BRIEF ANSWER

Yes. The Owner establishes that the Assessor's original assessment for the subject

property I) overstates the value of its basement space, 2) fails to account for valuable waterfront

improvements to the Assessor's comparable sales, and 3) improperly omits from her analysis a

sale of a similar property also located on the Spokane River.

FINDINGS OF FACT

PROCEDURAL HJSTOR Y

1. The Owner appears before this Board after timely appealing the decision of the

County Board, which sustained the original assessed value.of the subject property, $383,700.

The Owner now seeks a value of $325,000. The Assessor asks the Board to sustain the County

Board's determination.

2. Prior to the County Board hearing, the Owner requested, pursuant to RCW

84.48.150, the factors used by the Assessor to value the subject property.

3. On or around September 30, 2013, the Assessor supplied to the Owner and the

County Board her response to the Owner's County Board petition. Contained within were four

sales but not the cost parameters used to set the subject's original assessed value.

4. To initiate the Owner's subsequent appeal to this Board, a prehearing conference

was held on April 3, 2015. The Board then issued a prehearing order, which set forth the

deadlines for the parties' submittals.3

5. On August 17, 2015, the Owner moved for summary judgment,4 and a hearing on

the motion was held on September 14, 2015. In its order denying the Owner's motion, the Board

concluded that genuine issues of material fact remained in dispute. 5

6. On January 22, 2016, the Board held an evidentiary hearing, by telephone. The

Owner appeared prose. Spokane County Deputy Prosecuting Attorney, Ronald Arkills,

3 Order Establishing Procedural Dates . 4 Appellants' Motion for Summary Judgment. 5 Order Denying Appellants' Motion for Summary Judgment, at 5.

INITIAL DECISION - Page 3 DocketNo. 13-179 P- 288

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: represented the Assessor and called one witness, Jay Sporn, a residential appraiser with the

Assessor's office.

7. Mr. Sporn has been licensed as a residential appraiser since August 1993 and has

been employed by the Assessor since July 2012.6

8. Prior to the hearing, the Owner filed supplemental exhibits (Exhibits A8-1

through A8-22).7 The Assessor objected to the January 19, 2016, filing as being untimely.

Because exhibits were due by August 17, 2015, the Board sustained the Assessor's objection and

disallowed their entry into the record.

VALUATION OF THE SUBJECT PROPERTY

9. The subject property, Parcel No. 17355.9014, is located at 13206 West Charles

Road in Nine Mile Falls, Washington.

10. The subject is a five-acre lot with a significant portion of the lot perched

approximately 150 feet above the Spokane River. The only access to the waterfront is a long,

winding deer trail.8 At the subject's waterfront is a 72 square foot dock, self-built using $3,000

12 worth ofmaterials.9

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11. The subject is improved with a single-family residence built in 2002. The

residence has an above-grade living area of 2,048 square feet, and its construction quality is

graded "average minus." 10

12. The subject's residence also has a 2,048 square foot walkout basement, 1,900

square feet of which is finished as living area. 11 No part of the subject's basement is properly

described as a "lower level."

12.1. The subject's building permit describes the below-grade space as a

finished basement. 12

12.2. Images of the exterior of the subject property confirm that the front half of

the subject's residence has no visible lower level. The basement emerges as the

· ages move from the front to the back of the. residence. 13

6 Exhibit RS-I. 7 Appellants' Supplemental Exhibits. 8 Testimony of Ms. Strand; Respondent's Trial Brief at 2. 9 Testimony of Ms. Strand. 10 Exhibit BE 13-0 I 03, Appendix 4-2, page 2. 11 Exhibit R2-1; BE 13-0 I 03, Appellant's Answer, page 5. 12 Exhibit A2-82. 13 Exhibit A 7-16.

, INITIAL DECISION - Page 4 i

Docket No. 13-179 P-289

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12.3. Pro Val, the software used by the Assessor to derive her mass appraisal

values, 14 characterizes a walkout basement as having "full doors and windows on one

side." 15 The subject's layout falls squarely within this description.

13. The Asse'ssor' s mischaracterization of the subject's basement in her mass

appraisal model establishes that the subject's original assessed value is overstated.

13 .1. Pro Val uses the cost approach to value, i.e., the software adds to the value

of the subject's land the depreciated cost of construction of the subject's

• 16 improvements.

13.2. Marshall & Swift, a known construction-cost service that serves as the

basis for the Pro Val computations, reports significantly different cost estimates based

on whether space is characterized as a basement or a lower level. According to the

Owner's unchallenged calculations using the Marshall & Swift tables, the Assessor's

overvaluation of the subject's basement is $23,769. 17

13.3. Although the Marshall & Swift tables used by the Owner are from

December 2006-they therefore cannot be used to accurately value the subject in

2013-there is no evidence showing that basement costs have increased dramatically

since 2007. The tables, then, still serve to demonstrate the material discrepancy

between the value of lower level and basement space.

14. When the two most comparable sales in the record are considered, their prices

indicate a value for the subject of$325,000, not $383,700.

14.1. Owner's Sale No. 1, the September 2012 sale of 6597 Long Lake Drive

for $340,000, is superior to the subject and therefore supports the Owner's contended

value.

14.1.1. The Assessor's argument that the sale property has significantly

inferior construction quality is not corroborated. 18 The Stevens County Assessor

rates the sale property's construction as average, 19 a grade higher than the

Spokane Assessor's rating for the subject property. In addition, the property's

14 Exhibit A2-33. 15 Exhibit A2-48.

_ 16 Respondent's Trial Brief at I 0. 17 Exhibit A2-46. 18 See Exhibit R7-J. 19 BE 13-0103, Appellant's Answer, Appendix 7-2.


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marketing flier states that the property is very well maintained, has a newer

roof, and has new carpeting and tile on the main floor. 20

14. ! .2. The Assessor's testimony that properties on the Stevens County

side of the waterfront (where the sale property is located) typically sell for less is

unsubstantiated. Both the sale property and the subject are located along the same

body of water and are otherwise in close proximity to one another.

14.1.3. The sale property appears to have lower-bank waterfront, making

access to the water easier?

14.1.4. The sale property has a larger above-grade living area and a dock

with a boat house.22

14.1.5. The fact that the sale was listed for 562 days before selling

suggests that earlier list prices were above market, not, as the Assessor argues,

that the final sale price is unreliable. This is the case even though the sale's

marketing flier stated that the seller was very motivated.

14.2. Assessor's Sale No. I is the December 2012 sale of 13012 West Charles

Road for $345,000. The sale, which was given more weight by the Assessor,23 also

supports the Owner's contended value.

14.2. l. The sale property is the best comparable due to its close proximity

to the subject and its similar land attributes. Mr. Sporn offers credible testimony

to that effect.

14.2.2. Mr. Sporn's adjusted price for the sale of $379,400 reasonably

captures the value impact of the characteristics he considered: he is a qualified

appraiser, and his appraisal judgment is credible.

14.2.3. Mr. Sporn offers credible testimony that, even though the sale was

seller-financed, no circumstances affected the ultimate selling price.

14.2.4. Mr. Sporn's gross adjustments amounting to 30.3 percent do not

undermine the probative value of the sale.

20 BE 13-0 l 03, Appellant's Answer, Appendix 7- l. 21 Id. The images on the flier do not show any significant elevation change to reach the waterfront. 22 /d 23 Exhibit R2-2.

INITIAL DECISION - Page 6 Docket No. 13-179 P - 291

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14.2.5. Mr. Spom's adjusted price does not consider the value impact of

the sale property's significantly larger dock and boat lift,24 its road down to the

waterfront (an improvement not found at the subject property), 25 and its superior

construction quality (average, compared with the subject's average-minus

construction).26 The Assessor's office does not value docks,27 and not one of

these factors appears on Mr. Spom's comparable sales grid.28

14.2.6. In response to a 2012 audit of the Assessor's office, Byron

Hodgson, the Chief Deputy Assessor at the time, stated that "the cost of most

dock construction is around $10,000."29

14.2.7. The Assessor does account for the value of in .. property roads on

other properties. The assessed values of Parcel Nos. 17352.9006 and .9007,

properties that are in close proximity to the subject, shifted by almost $50,000

when an in~property road was re-assigned from one parcel to the other. 30

14.2.8. A conservative factoring of waterfront improvements, waterfront

access, and construction quality could readily yield an additional downward

adjustment of $50,000 to the Assessor's initial adjusted price.

15. Owner's Sale No. 2, the February 2012 sale of 13103 West Shore Road, and

Assessor's Sale No. 2, the July 2012 sale of21303 North Byrne Lane, are both considerably

superior to the subject property and are therefore less comparable.

15.1. Owner's Sale No. 2 has significantly better construction quality,31 a

medium, not high-bank waterfront,32 and a 912 square foot dock with a.boat lift and

canopy.33

15.2. Assessor's Sale No. 2 has a larger above-grade living area, significantly

better construction quality,34 and a dock with two boat slips.35

24 Exhibit AS-26; testimony of Ms. Strand. 25 Testimony of Ms. Strand. 26 Exhibit AS-28. 27 Exhibit A2-28. 28 Exhibit R2-1. 29 Exhibit A2-80. 30 Exhibit A2- l4. 31 BE 13-0103, Appellant's Answer, Appendix 7-3. 32 id. The bank height is an estimate based on images in the marketing flier and the flier's statement that access to

the water is easy. 33 Id. 34 Exhibit R3-S.


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16. Assessor's Sale No. 3, the December 2012 sale of 17304 North Westshore Road

for $375,000, is the only sale that is more supportive of the Assessor's value than the Owner's.

Its superior quality of construction is offset by its smaller lot size and living area, making the sale

somewhat similar to the subject property.

17. Assessor's Sale No. 3 does not, on its own, undermine the remainder of the

evidence favoring the Owner's position.

18. Neither Owner's Sale No. 3, the January 2012 sale of 13305 West Shore Road,

nor Assessor's Sale No. 4, the May 2013 sale of 23210 North Westlake Drive, factors into the

Board's analysis. Both transactions were REO sales, i.e., sales by a fmancial institution after

foreclosure.36 No evidence of mitigating circumstances ensuring that the sale transferred for fair

market value is contained in the record.

19. As part of her evidence, the Owner offers four land sales that transacted in 2007.

20. The Assessor provides a ratio study, but it contains no evidence related to the

subject's fair market value.37

CONCLUSIONS OF LAW

JURISDICTION AND STANDARD OF PROOF

1. Under RCW 82.03.130(1)(b) and RCW 84.08.130(1), the Board has the authority

in this appeal to determine the fair market value of the subject property.

2. In order to adjudicate a property valuation appeal, the Bo.ard holds a de novo, or

new, hearing and relies on the materials filed with the county board of equalization and any

additional documents timely filed with the Board. 38

3. In a valuation appeal, the Board is authorized to determine the market value of the

subject property, based on the available evidence, and issue an order accordingly .39

4. The Board is not authorized to grant damages or other relief in the event an

assessor fails to provide an owner with the criteria used to value the subject property under RCW

35 Testimony of Ms. Strand. 36 BE 13-0 I 03, Appellant's Answer, Appendix 7-5 (the sale is described as a Fannie Mae HomePath property);

Exhibit R2-2. 37 Exhibit R3-5. 38 See Ridderv. McGinnis, BTA Docket No. 33754 (1988), at 4 (citing AGO 1986 No. 3, at 8-9). 39 See RCW 82.03.130(1)(b), RCW 82.03.200, and RCW 84.08.130(1).

INITIAL DECISION· Page 8 Docket No. 13-179

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84.40.150. The Board therefore does not addressthe Owner's arguments related to the

sufficiency of the Assessor's September 30, 2013, filing.

5. Under RCW 84.40.030 l, the Assessor's valuation is presumed correct, and the

Owner must provide '1clear, cogent and convincing evidence" to challenge a value successfully.40

Washington courts have explained that the ''clear, cogent, and convincing" standard of proof

means "a quantum of proof that is less than 'beyond a reasonable doubt,' but more than a mere

'preponderance"'; evidence is "clear, cogent, and convincing" ifit shows "that the fact in issue is

'highly probable. "'41 "Nonnally, clear, cogent[,] and convincing proof of a correction includes

evidence of both the assessor's error and the correct value."42

VALUE CONCLUSION

6. Uniformity of taxation, as required by Washington's Constitution,43 is reached

when all properties are valued at 100 percent of their fair market values. 44

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7. As defined in WAC 458-07-030(1), the fair market value of the subject property

' "is the amount of money a buyer of property willing but not obligated to buy would pay a seller

of property willing but not obligated to sell, tal<lng into consideration all uses to which the

property is adapted and might in reason be applied."

8. RCW 84.40.030(1) provides that "(t]he true and fair value ofreal property for

taxation purposes ... shall be based upon ... [a]ny sales of the property being appraised or

similar properties with respect to sales made within the past five years."

9. Among the key factors for determining whether a sale property and the subject

property are similar are (1) their locations; (2) the age, size, construction quality, and condition of

their improvements; and (3) any special features the sites share (such as their views or waterfront

footage ).45 Greater weight is accorded to properties similar to the subject that sold closer to the

assessment date.46

40 RCW 84.40.0301. 41 Tiger Oil Corp. v. Yakima County, 158 Wn. App. 553,562,242 P.3d 936 (2010) (quoting Davis v. Dep't of Labor

& Indus., 94 Wn.2d 119,126,615 P.2d 1279 (1980), and In re Welfare ofSego, 82 Wn.2d 736,739,513 P.2d 831

}1973)). 2 Weyerhaeuser v. Easter, 126 Wn.2d 370,381,894 P.2d 1290 (1995).

43 Const. art. 7, § l . 44 Duwamish Warehouse Co. v. Hoppe, 102 Wn.2d 249,256,684 P.2d 703 (1984). 45 See Appraisal Institute, The Appraisal of Real Estate, 141,301,364 (13th ed. 2008). 46 See WAC 458-14-087(4) (requiring the Board of Equalization to assign "(rn}ore weight ... to similar sales

occurring closest to the assessment date which require the fewest adjustments for characteristics").


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10. Whether the totality of gross adjustments to a sale comparable exceeds a certain

threshold, be it 20 percent, as described in certain appraisal texts,47 or any other amount, does not

automatically invalidate a sale. Neither Washlngton law nor the Uniform Standards of Professional

Appraisal Practice (USP AP) endorses such a'. bright-line rule.

11. Sales by financial institutions are not invalid, per se. In order to be given weight,

however, the offering party must establish that the sale property was adequately exposed to the

market prior to selling. 48 In so doing, the party will have provided evidence mitigating the risk of a

below-market sale.

12. Sales with seller financing are not invalid, per se. But by statute, the offering party

must take into account "the extent, if any, to which the stated selling price has been increased by

reason of the down payment, interest rate, or other financing terms. "49

13. The Owner's land sales are excluded from consideration due to their occurrence

more than five years before the assessment date under appeal. so

14. Owner's Sale No. 3 and Assessor's Sale No. 4 are excluded from consideration. The

12 parties fail to establish that the properties were adequately exposed to the market prior to sale.

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15. Assessor's Sale No. 1 is not excluded from consideration because she establishes

that the sale conditions did not affect the selling price.

16. In addition to comparable sales, "consideration may be given to cost, cost less

depreciation, [or] reconstruction cost less depreciation" to value a subject property. 51

17. The cost approach derives a property's value "by adding the estimated value of

the site to the current cost of constructing a reproduction or replacement for the improvements

and then subtracting the amount of depreciation. "52 The cost approach is well suited to the

valuation of "new or nearly new improvements and properties that are not frequently exchanged

in the market."53

47 See Walt Huber et al., Real Estate Appraisal Principles & Procedures, 281 (3'd ed. 2001). The text is excerpted at

A2-86. 48 See, e.g., Lefton v. Hara, BTA Docket Nos. 84904, et al., at 11 (2016). 49 RCW 84.40.030(3)(a). 50 Jd 51 RCW 84.40.030(3)(b). 52 The Appraisal of Real Estate, supra, at 142. s3 Id.


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18. Ratio studies and the assessed values of other properties cannot be·considered:

neither is outlined in RCW 84.40.030(3) as a methodology for determining market value.54

19. The Owner presents clear, cogent, and convincing evidence that the Assessor

overvalued the subject property for the 2013 assessment year.

such.

19.1. The Owner establishes Assessor error by showing that the Assessor

mischaracterizes the subject's basement as a lower level, thus materially overstating the

cost of its construction.

19.2. The Owner establishes the accuracy of her value with the usable sales in

the record. Once all property characteristics are considered, a value of $325,000 for the

subject property is supported.

19.3. The Owner's use of the assessed values of other properties to demonstrate

the Assessor's failure to evaluate waterfront improvements is not improper. Had those

assessments been used to directly support a value, they would not have been considered.

In this case, however, the change in the assessed values of Parcel Nos. 17352.9006 and

. 9007 creates a inference that the Assessor considers waterfront improvements to be

valuable.

19.4. That the Owner assigns most of her requested value reduction to the land

component of the subject's assessment when the most significant error is found in the

improvement value is immaterial. The Board's ultimate concern is the total fair market

value of the subject property.55

Any Finding of Fact that should be deemed a Conclusion of Law is hereby adopted as

From these conclusions, this Board enters this

54 See M. Riggen, LLC, v. Ave,y, BTA Docket Nos. 78678-79, at 6 (2014); Mata/one v. Noble, BTA Docket No.

71193, at 15-25 (2010). 55 Because "appraisals are, at best, estimates of value and , .. valuation of the components could lead to an excessive

value of the property as a whole, [RCW 84.40.030(3)(c)] necessarily contemplates the potential adjustment of

component values in order to keep their sum within a property's total assessed value." University Village Ltd.

Partners v. King County, 106 Wn. App. 321,326, 23 P.3d 1090 (2001).


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DECISION

In accordance with RCW 84.08.130, this Board sets aside the determination of the

Spokane County Board of Equalization anq orders the value as shown on page one of this

decision.

The Spokane County Assessor and Treasurer are hereby directed that the assessment and

tax rolls of Spokane County are to accord with, and give full effect to, the provisions of this

decision.

DATED this 9th day of May i 2017.

BOARD OF TAX APPEALS

ALEJANDRO ANCHEZ, Senior Tax Referee

Right of Review for the Initial Decision

Please see WAC 456-09-930 for complete instructions on filing a petition

for review of this Initial Decision. Subsection (2) of the rule requires that you file

an original and four copies of the petition for review with the Board of Tax

Appeals within 20 calendar days of the date of mailing of the Initial Decision; you

must also serve a copy of the petition on all other parties or their representatives.

Subsection (3) provides that your "petition for review shall specify the portions of

the initial decision to which exception is taken and shall refer to the evidence of

record which is relied upon to support the petition." Subsection (4) permits a .

party to reply to a petition by submitting to the Board four copies of the reply

within 10 business days of the date of service of the petition; the reply must be

served on all other parties. The Board will then consider the matter and issue a Final Decision.

If no petition for review is filed, the Initial Decision becomes the Board's

Final Decision 20 calendar days after the date of mailing of the Initial Decision.

Please be advised that a party petitioning for judicial review of a Final

Decision is responsible for the reasonable costs incurred by this agency in

preparing the necessary copies of the record for transmittal to the superior court.

Charges for the transcript are payable separately to the court reporter.

INITIAL DECISION - Page 12. Docket No; 13-179 P-297

',..__.,-·

ic"-;,-

BEFORE THE BOARD OFT AX APPEALS

ST A TE OF W ASHJNGTON

PATRICIA STAND and PALMER STRAND,

Appellants.

v.

RALPM BAKER, Spokane County Assessor,

Respondent.

) ) ) ) Formal Docket No. 09-121 ) ) ) RESPONDENT'S ANSWERS TO ) APPELLANT)S JANUARY 12, 2010 ) REQUEST J<'OR DISCOVERY ) ) )

In response to Appellant's January 12, 2010 request for discovery under WAC 456-09, the Respondent answers as follows:

A. General Background. Like assessors in other Washingt9n counties, the Spokane County Assessor utilizes Computer Assisted Mass Appraisal(CAMA) in the assessment of property values. "Mass appraisal" as defined by the International Association of Assessing

\

Officers is: "The process of valuing a group of properties as of a given date, using standard methods, and allowing for statistical testing." This methodology is authorized by Chapter 84.41 of the Revised Code of Washington.

For this purpose, the Assessor's office uses a computer software program known as tvlanatron ProVal. Spokane County does not own ProVal, but uses it under certain terms and conditions set forth in a non-exclusive license with Manatron.

Pro Val features a highly productive, integrated sketch package and an extremely accurate valuation engine for calculating property values. It includes income approach, sales approach, and cost approach models to value property. It also includes models to automatically value land. It is the most widely deployed and, nationally recognized, CAMA software product. The software's internal calibration and embedded object code is proprietary and not suqject to public disclosure.

RESPONSE TO DfSCOVERV REQliEST--1

Spoka11e Cow11y Prosecuting Attorney Civil Division I I I 5 W Broadway Avenue Spokane, WI! 99260 (509)477-5 764

P - 308

Thus, definitive arithmetic formulae cannot be provided. The precise internal relationship between various components of value is not visible, or accessible, by the software user.

The software complies with Washington state law, as well as standards set by the International Association of Assessing Officers.

{

. Embedded in the ProVal software are cost tables compiled by the Marshall Swift valuation service. These cost tables are based on a sampling of final building costs for residences actually built. They are averages of many costs. These cost tables are updated periodically by Marshall Switl

Marshall Swift cost tables are utilized in most assessor offices throughout the United States and Canada. t\.farshall Swift cost data and methodology is the standard for determining the estimated value of commercial and residential structures, improvements and manufactured housing when using the cost approach.

The Assessor's staff inputs various data into the Pro Val data base including: (1) information from visual inspections of the property; (2) sales and other market data from sources such as the Multiple Listing Source; (3) Real Estate Excise Tax Affidavits; (4) GIS; and (5) building permit information.

With input data and the embedded Marshall Swift cost tables, the Pro Val software is able to determine the value of a Subject Property.

The Improvement Data Sheet that you reference was prepared utilizing Pro Val.

The right hand column of that document reflects a computation of value utilizing a cost approach with the following steps: ·

(I) A determination of the Total Base Cost of a structure;

(2) The addition of value adjustments for various features including:

(a) Interior Finish(ltem IC);

(b) Exterior living units;

(c) Basement Finish(ltem ID)

(d) Fireplaces;

(e) Heating(ltem IE)

(f) Air Conditioning;

(g) Frame/Siding/Roof(ltem l F);

(h) Plumbing Fixtures; and

RESPONSE TO DISCOVERV REQUEST-·2

Spokane County Prosec1.1ti11g Allorney Civil Division 1 i 15 W. Broadway !1ve1me Spokane, WA 99260 (509)4 77-5 764

C .. P r.s (2- ''6

P - 309

(i)Other rieatures(Item IG).

Specifies for each of these adjustments are found in the left-hand column under "Physical Characteristics."

(3) The addition of the value of exterior features such as an attached garage and enclosed frame porch;

(4) A Quality Class/Grade Adjustment is applieti to the total of the first three steps to determine the Grade Adjusted Value;

(5) Deductions for physical depreciation and obsolescence.

n. Ans.wt.rs to Apt>ellant's Specific Questions:

l. A. Base Cost is calculated for a particular type of residence using Frame type and embedded Pro Val software tables. Framing is a component of finished square footage. 1152 and 896 square foot portions of the structure are wood frame.

8. A concrete frame is indicated. The reason tor any variation--if there is one-is that Building and planning definitions to not correspond to assessment practices.

I

C. A drywall interior finish is indicated. Computer generated values for this--and other items-- are based on Pro Val's licensed software and embedded proprietary tables.

D. The question is ambiguous. Please re-phrase the question.

E. A negative valuation may result from an inferior--or no--heating system. A forced hot aii'--electric system is indicated in your residence.

F. The Improvement Data Sheer indicates: wood and concrete frames; vinyl siding; and a metal gabled roof. Your question is ambiguous. Please re-phrase the question.

G. The question is ambiguous. Pl~.ase re-plll'ase the question.

H. The Improvement Data Sheet indicates an attached frame garage. The questien is ambiguous. Please re-phrase the question.

1. The Exterior Features consist of a 96 square foot enclosed frame porch(''EFP'' on the sketch). The question is ambiguous. Please re-phrase your question; and provide specific examples.

2. Grade A(#usted Value is a term used to describe the value after the quality grade aqjustment has been applied to the base cost of the structure but before depreciation.

RESPONSE TO DISCOVERY REQUEST--3

Spolwne County Prosecuting Attorney Civil Division 11 JS W. !Jroadway ~lvenue Spokane, WA 99160 (509)477-5764

P - 310

\ \ ,_

3. These are definitions of quality types utilized by the l\farshall Swift valuation service to describe the overall quality of construction of a structure based on an appraiser's visual inspection of the property. An "Average" quality house is a house that is encountered more frequently in a market than any other quality of construction; and meets or exceeds building code requirements. The quality of workmanship is acceptable, but does not reflect custom craftsmanship. Cabinets, doors, hardware and plumbing are usually stock items. As noted above, the quality classification is applied to the base cost to determine the value of a structure before depreciation. The numerical amount of the adjustment for quality is based on Marshall Swift cost tables which are imbedded in the ProVal sofiware, and are not known to the appraiser. These tables are trade secrets, and not subject to disclosure. The "minus" is a forther refinement of the quality adjustment based on the judgment of the appraiser. Classification may change based on subsequent appraiser inspections.

An adjustment applied by the appraiser to cost to determine value based on the local real estate market. ln your case, the appraiser determined that such an adjustment was unnecessary.

Appraiser drawings are typically from site inspections of the appraiser utilizing the Sketch Component of the ProVal software. The sketch appearing on the Data Information sheet utilizes uses Pro Val symbols and abbreviations. The abbreviation "l s Fri B" means a portion one-story frame structure over a basement The circled number indicates the area of this portion is 1152 square feet The abbreviation "I s Fri L" indicates a portion of a one-story frame structure that is a lower level finished area of your house. A "lower level" typically is not subterranean, which what distinguishes it from a basement. The area of this portion of the structure is 896 square feet.

6. '.?004 and 20 I 0. There may-but not must-be appraiser inspections based upon sales, demolition, or renovation under a building permit. fn addition to regularly scheduled inspections, inspections may occur as a result of a taxpayer's appeal to the Spokane County Board of Equalization or the Washington State Board of Tax Appeals.

r A land table produces value based sales in your particular neighborhood with adjustments for factors such as topography, soil, view, lot configuration, etc. in accordance with appraiser judgment.

8. Unknown,

The information for each address is available on the Spokane County website at httg://www.sgokanecounty. erg/assessor/content. as 12x?c= l ~ 7?:

DATED this 251h day of January, 2010.

RESPONSE TO DISCOVER)' REQUEST-A

Spokane Coullly Prosecuting Attomey Civtl Division 1115 W. BroadwayAven11e Spokane, WA 99260 (509)477-5764

P - 311

The Spokesman-Review· 04/27/2019 Copy Reduced to 80% from original to fit letter page Page: T09

essed valu

Government spending has greatest impact on what you pay Appraiser Jay Sporn sizes up a newli, built Spokane home.

Bi, Nicholas Deshals Tl!E SPOKESMAl'i-JIEV!l!W

Another year, another levy lid lift.

Okay, not necessarily, but property taxes and the tortured terminology surrounding them leave many homeowners confused. Yes, the process of assessing and distributing taxes is complex, based on stat· istical analyses, elections, neighborhoodcharacterandhomesales. As the Municipal Research and Services Center notes, Wnshing-

---Jon state's property lil!X is "one of ·•,e most complicated in the na.on."

In the end, though, it's pretty simple, Your house is worth II certain amount, which is calculated once a year by county appraisers, and that value determines how much is collected by local govern· men ts, which is based on II set levy rate.

''Our appraisers physically inspectone-sixthof thecountyevery year, and that includes residential, commercial and agricultural. We send assessment notices annually and you get an annual tax bill," Byron Hodgson, Spokane County's chief deputy assessor, said last year. "People say, 'My house isn't worth this.' Even when the market is declining, even when the mnrket

,,, is escalating.''

)

The way the county detennines home valul! is governed by state law, which states that property ''must be valued at one hundred percent ofibl true and fair value in money." That's generally "interpreted as fair market value," Hodgson said, noting that state law prohibits using a home's sale price as its assessed value,

Instead, appraisers use statistical analysis to calculate assessed value, drawing from a number of sources, including comparable home sale prices in u neighborhood, what type of house it is end

, --,,, the neighborhood's character. The ''.ounty's analysis even diyides residences up by ranchers, split-level two stories, small houses und large houses.

Each year, the county places a dollar figure on the nearly 140,000 single-family residences and du-

li'HO'l'OS lllY 'l'YLER 'l'JOMSLAND/fHE SPORESMAN-kEVJBW

Jay Sporn, left, a residential appraisal supervisor with the Spokane County Assessor's Office, measures a newly built home In Spokane with residential appral$1!1' Sam Margulis In Aprll 2018.

plexes that is used by local taxing jurisdictions to figure out how much tax they'll draw from the property owner.

In all, Spokane County has SS taxing districtll within its borders that create 131 different tax areas, because of overlapping boundniies of school districts, fire districts, library districts, cities and towns.

For instance, the county levies funds for the veterans relief fund and programs assisting people with mental health issues or developmental disabilities. It also has a $4.5 million road levy, Conser-1•11tion Futures fund and a library levy. The city of Spokane has a park bond and road levy to pay for,

as well as emergency medical services and a library levy. Airway Heights voters approved a bond to pay for an aquatics center. Spangle property owners are funding police and fire services,

Within these districts, and in the county as a whole, appraisers assess a total of 231,003 parcels.

In 2018, these parcels accounted for more than $49,7 billion In assessed property value, which brought in more than $579 million in taxes to the variousjurlsdktfons

According to a state-by-state compadson by the Lincoln InstitUte, Washington's various governments receive about 21 percent of their revenue from property taxes, a far smaller portion

than Idaho and Oregon, which both collect about 30 percent of total revenue from property tuxes.

HodW)on, with the county assessor's office, said there's no limit on assessed value, and it can go up and down as the market determines, But the levy rate has several limitations to it

First, Washington voters passed Initiative 747 in 200!, which limits property tax increases to l percent a year. Second, the I percent limit also keeps levies to, at most, $10 for every $1,000 of assessed value, unless approved by voters. Lastly, state law keeps the combined state and local property taxes below $10 for every $1,000 of assessed value, referred to as the $10 limit

Even with all these limitations, Hodgson said, what taxpayers pay is largely detenn!ned by govern· mentspending, not assessed value.

''Tax bills depend more on spending than anything," he said. "All things being equal, if there's no increase in spending and prop· erty values go up, the levy rate will drop to compensate for the increaseiQ valu~."

Orginally in tl1e Open House Weekend section last year, this arcick has been updated Jor publicacion here,

CONTACT THI! Wlllfl:11:: (509) 459-5440

nlckd@spokosman,com

Copyright@2019 Spokesman-Review 04127/2019. April 29. 2019 8:40 am (GMT •7:00)

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FILED 1 2020 JUN I 2 p 3: o 1

TIMOTHY W. FITZGFPALD SPOKANE COUNTY,CCEi~f-;

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IN THB SUPERIOR COURTOF THE STATE.ORWASHINGTON

· JUN 12 2020 IN AND FOR THE COUNTY OF SPOKANE

SPOru\i>,ng fJQYNTY -- '' ,r

, ',_, ·-' , '~., '- ,' '

PATRICIAN. STRAND t1WU-! PlV!Sh:JM

No. 20201077-32 . . ~"

Plaintiff. ' ' ' '

v.

9 SPOKANE COUNTY AND SPOKANE COUNTY ASSESSOR,

P~UPPtEMENJAL RESPONSE TO DEFENDANT'S

REPLY MEMORANDUM IN SUPPORT OF MOTION.FOR

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A.

Defendant SUMMARY JUDGMENT

I. HISTORY

a. Complaint

On March 20, 2020 Plaintiff, Patricia Strand, filed a summons and complaint under the

Public Records Act t 4PRA") (RCW 42.56.550) for the unlawful denial of public records

against Defendant, Spokane Cowrty Assessor ("Assessor").

The PRA records requested in February 2019 werewhat_th~ Assessorused to,

determine the value for Strand real property parcel 17355.9014. The request included

this - the records were for a pending appeal to the Washington State Board of Tax

Appeals ("BTA"). The request included relevant laws on real property valuation, RCWs

84.40.030, 84.48.150 and 84.40.020. (P-32, -36 to -44) RCW 84.40.030 requires the

Supplemental Response to Defendant's Reply Memorandum in

Support of Motion for Summary Judgment PN Strand, Plaintiff

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parcel, was created after the request. Mr. Hodgson does not contest this. It is relevant

that Mr. Hodgson did not identify the cards as either the similar sales or factors used for

valuing 17355.9014. The clearly identified Thurston County similar sales and factors are

database downloads. (P-200 to -205 and -284 to -285)

The argument for an exemption citing Gibson v. Snohomish County makes no

sense because the Assessor alleged no exemptions.

CONCLUSION: All of the cards are nonresponsive as proven in Complaint.

Plaintiff response to Declaration No. 4, 'P-159 to -160 (the Pro Val code sheets) did not

originate with the Assessor. Mr. Hodgson alleges P-159 to -160 are of unknown origin

and "I searched the Assessor's Office and databases and could not locate these

documents."Mr. Hodgson then swore in his Declaration,

I hereby declare under the penalty of perjury and the laws of the State of Washington that the following statements are true.

Plaintiff response to Reply No. 2 that Assessor produced 636 pages of responsive records

and websites; searched drives, databases, local computers and websites; P-159 to -160 are

not Assessor records. The reports are nonresponsive. (P-265, V.) Mr. Hodgson's

constant referrals to websites do not comply with RCW 42.56.520(1 )(b ).

a. A False Statement!

History of Pro Val Code Sheets (P-159 to -160)

P-519 to -522 document the motion by Dan L. Catt, Esq. in case 14201079-1 to

enter disks into evidence as counsel of Assessor. He states the disks were used in Judge

Supplemental Response to Defendant's Reply Memorandum in Support of Motion for Summary Judgment

cf 5,_g

P - 507 PN Strand, Plaintiff

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Moreno's case. Chief Deputy Assessor Hodgson testified for the Assessor in both cases. 1

Strand included a screenshot of the first page of each disk's contents (P-523 to -532) to

emphasize the Assessor's form of notation at the bottom of each page on the disks:

- BH # are records from Appraisal Supervisor Byron Hodgson disk - KB # are records from Chief Deputy Assessor Kevin Best disk - RB # are records from Assessor Ralph Baker disk - number in bold print are records from 2009 to 2013 Public Records Requests

disks that are sequentially numbered from 600-to-6661

Mr. Catt's disks include this evidence.

• P-533 - On February 8, 2010 Ronald Arkills, Counsel to the Assessor, in Strand

appeal of the 2008 value of 17355.9014 (BTA 09-121), alleged the Assessor's

policies and procedures were manuals listed herein.

• P-534 On February 9th Mr. Hodgson lists manuals compiled by Assessor's Office:

Compilation of Memorandum, Other Binders, ...

• P-536- On July 14, 2010 Strand request to inspect manuals and make photocopies.

• P-537 - On July 14th Mr. Arkills states Mr. Hodgson compiled the list of manuals for

Strand inspection and "hopefully has the documents ... ".

• P-538 to -539- On July 19th the location and appointment of the Strand inspection of

manuals is finalized.

• On July 20th Strand inspected the manuals and prepared two documents of the

inspection. (1) A list of records to have photocopied. (P-540) (2) A list of

observations about the manuals that were inspected. Strand finished the inspection,

Case 13200123-8 hearing testimony by then Appraisal Supervisor Byron Hodgson (identified at bottom of

pages) is Judge Moreno's case (P-356 to -361). Case 14201079-1 has Hodgson testimony (P-172 to -182).

Supplemental Response to Defendant's Reply Memorandum in Support of Motion for Summary Judgment PN Strand, Plaintiff P - 508

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collected her copies and left. Afterward, Strand typed up list two, "Jul/20/10

Inspection by Strand of Jan/25 and Feb/8/10 Arkills documents". ( emphasis added)

Strand then filed the 50 pages in a binder of all Assessor record interactions tabbed

July 20, 2010.

Strand submitted evidence in Judge Moreno's case 13200123-8 about the denial

of Assessor policies and procedures. (P-541 to -546) Strand considered only P-159

relevant to case 13200123-8. (P-544 right-side) P-543 left-side is Strand list two, headed

"Jul/20/10 Inspection by Strand of Jan/25 and Feb/8/10 Arkills documents". On

February 9, 2010 Mr. Hodgson stated the Assessor's office compiled the Compilation of

Memorandums; Other Binders ... ". List two states in the middle of page,

Compilation of Memorandums Binder 3 inches thick - this was not a compilation of memos and was largely empty. It contained: ( 1) Pro Val pages Exhibits 4 thru 10 are examples of the pages contained. Pro Val is the software the assessor uses to appraise properties and Exhibit 12 and 13 are the assessor's description of Pro Val ...

CONCLUSION: Strand considers this sufficient evidence of Mr. Hodgson as the

origin of P-159 to -160. This is also evidence that Mr. Hodgson committed perjury in his

Second Declaration.

b. Mr. Hodgson Conducted No Search For P-159 to -160

It is unreasonable to believe a search based on P-159 to -160 that are labeled

"Received Jul/20/10 as Assessor Policy/Procedure Record" did not produce P-523 to -

546 - the origin documents. It is unreasonable to believe a search for P-159 to -160 did

not get associated with cases 13200123-8 and 14201079-1. It is unreasonable to believe

Supplemental Response to Defendant's Reply Memorandum in Support of Motion for Summary Judgment PN Strand, Plaintiff P- 509

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a search for P-159 to -160 did not ricochet off all Strand appeals of value to the BTA

after July 2010. The BTA decided in May 2017 in Docket 13-179 (2013 appeal of value

spanning 2013 to 2019) the Assessor mischaracterized Strand's basement based on P-160

( footnote 15),

12.3. ProVal, the software used by the Assessor to derive her mass appraisal values, 14 characterizes a walkout basement as having "full doors and windows on one side."15 The subject's layout falls squarely within this description. (P-290)

This decision was not appealed by the Assessor's alleging P-159 to -160 were of dubious

origin. Strand's sketch of the Assessor's two houses (P-192) is based on P-159 to -160.

This sketch and was used in appeals after and in 2013 value. P-159 to -160 and -192 are

in BTA Dockets 16070-17122. The Assessor did not allege fake records. Ten years after

Strand received this record and its constant use against the Assessor its origin is

questioned!

P-159 to -160 completely and accurately explain the specialized language in the

17355.9014 Pro Val card sketches (P-40, -42). This is why P-192 is an accurate sketch.

This is the reason the Pro Val code sheets are essential to understanding the cards. Mr.

Hodgson did not hypothesize where else Strand could have gotten the Pro Val code

sheets. If Strand faked P-159 to -160 why stop there!

CONCLUSION: Mr. Hodgson alleged he searched the office and databases for

these documents. Did he search by date -the date on the top of the page? Did he search

by the word Policy? Did he search by the work Procedure? Did he search his memory?

It is inconceivable that the Assessor has not compiled a database of every record

Supplemental Response to Defendant's Reply Memorandum in Support of Motion for Summary Judgment PN Strand, Plaintiff P- 510

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connected with Strand because that is what the Catt disks showed - a Strand database

current to the date of case 13200123-8 when it was wheeled out as Assessor evidence

against Strand.

c. Where are the Real Pro Val Code Sheets?

On February 24, 2019 Strand requested Pro Val code sheets. The code sheets

were to explain the specialized language on the Pro Val card. The Assessor alleges using

Pro Val software to value 17355.9014. The card is allegedly everything the Assessor has

on 17355.9014. (P-4 31) Strand cannot understand what that everything is because Strand

has no idea what these things mean because they are Pro Val codes ( specialized language)

for land and structures:

• Land Type: 1 Fronts Enhancement #1 • Rating Soil ID -or- Actual Frontage (blank) • Prod. Factor- or- Depth Factor -or- Square Feet: 1 • Adj Rate • Obsol Depr • Market Adj • 1 Residential Acreage

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1 s Fr 26

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(~~})

RFX OFP

1-3/4 sfr B

(!152)

FrG

(@)

FrCP

(§)

P-159 to -160 explain what the codes mean with pictures and drawings in English. The

Pro Val codes hide valuation factors. The Assessor produced cards for every property in

Assessor statistical neighborhood 231720 with lots of Pro Val codes. The Assessor

alleged 17355.9014's value is based on the values of every property in 231720 but Strand


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cannot understand anything without translations of the codes. What does the Assessor

have to hide? Why does the Assessor not produce the Pro Val code sheets?

CONCLUSIONS: The Assessor's failures to disclose these Pro Val records are

indications of problems not just secretiveness.

d. Alleging a Search After the Fact?

There is nothing on Mr. Hodgson responses to Strand requests alleging a

search by the Assessor. (P-33 to -35; -46 to 65; -67 to -146; -152 to 154; -162).

(emphasis added) There is nothing on Mr. Dinaro's response to Strand requests

alleging a search by Dinaro. (P-167 to -168) (emphasis added) Alleging Mr. Dinaro

who does not work for the Assessor and would have no access, knowledge, or anything

else to support such an allegation conducted a search when the Assessor's public records

person did not conduct a search based on this statement,

After a thorough review of the subject request, as well as your subsequent clarification,

and of the records produced to you by the Assessor's Office. I am of the conclusion that

all identifiable public records responsive to your request have been produced. (P-168)

is unreasonable. This statement does not contain the word search. It does not imply a

search. It does not say Mr. Dinaro did anything but read Strands' requests.

Neighborhood Alliance v. Spokane Co., 153 Wn. App. 241 at 257; 224 P.3d 775 (2009),

"The adequacy of the agency's search is judged by a standard of reasonableness,

construing the facts in the light most favorable to the requestor." Citizens Comm'n on

Human Rights v. Food & Drug Admin., 45 F.3d 1325, 1328 (9th Cir. 1995). An agency

fulfills its obligations under the PRA if it can demonstrate beyond a material doubt that

its search was " 'reasonably calculated to uncover all relevant documents.' " Weisberg v.

U.S. Dep't of Justice, 240 U.S. App. D.C. 339, 745 F.2d 1476, 1485 (D.C. Cir. 1984)

(quoting Weisberg v. U.S. Dep't of Justice, 227 U.S. App. D.C. 253, 705 F.2d 1344,

1350-51 (1983)). Moreover, the agency must show that it "made a good faith effort to

Supplemental Response to Defendant's Reply Memorandum in

Support of Motion for Summary Judgment PN Strand, Plaintiff P - 512

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conduct a search for the requested records, using methods which can be reasonably expected to produce the information requested." Oglesby v. US. Dep't of Army, 287 U.S. App. D.C. 126, 920 F.2d 57, 68 (1990).

CONCLUSION: No search was conducted.

Plaintiff response to Reply No. 3, that the use of a USB drive is the production of the

electronic records requested.

None of the Assessor's records responses in 2019 were provided by USB. They

were provided by e-mail. A USB drive is a storage medium not an electronic record.

Strand requested electronic records directly from the Pro Val database (P-36) to

bypass the errors, specialized language and superfluous data on cards. 2 The cards are

nonresponsive for many reasons all stated in the Complaint and response to summary

judgment. The Thurston County list of similar sold properties and factors comport with

disclosures required in RCW 84.40.030 and 84.48.150. (P-200 to -205)

The Assessor and/or their counsel misunderstand what an electronic record from

the Pro Val database is and this could be because they have never seen one.

CONCLUSION: This is a Defense mishmash of errors and misunderstanding of

technology that make no sense.

Plaintiff response to Reply No. 4 through 8 of No responsive records were withheld and

No Response Necessary. The Complaint and Response are responses.

What is a Reply Memorandum? Why does it contain a new allegation for summary

judgment-P-159 to -160 did not originate with the Assessor? Why is it filed seven days

P-263, T reports errors on 17355.9014 card


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r COPY Original filed

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J\JL 1 3 '2.0'2.0

i\mothj c~J~~e~~~RI< -1 &rt:>K~N~ _

JUL 1 :t 2020 JUL ·13 DEP-r: • "#6

IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON


PATRICIAN. STRAND

v.


Plaintiff,

Defendant

No. 20201077-32

REPLY BRIEF IN SUPPORT OF MOTION FOR RECONSIDERATION

AGAINST RULING FOR SUMMARY JUDGMENT

Defendant, Spokane County Assessor ("Assessor"), response to reconsideration states,

Defendants choose to rely on the briefing, Declai:ations of Spokane Public Records Officer

Anthony Dinaro ("Dinaro") and Chief Deputy Assessor Byron Hodgson ("Hodgson") and

argument considered by the Court on June 12, 2020. This statement encompasses everything

filed and heard.

Boyer v. Morimoto, 10 Wn. App. 2d 506, 449 PJd 285 (2019), Some principles of

summary Judgment encourage reversal of the superior court's summary judgment

order. A summary judgment is a valuable procedure for ending sham claims and

defenses. Cofer v. County of Pierce, 8 Wn. App. 258, 261, 505 P.2d 476 (1973).

Nevertheless, the procedure may not encroach on a litigant's right to place her

evidence before a jury of her peers. Cofer v. County of Pierce, 8 Wn. App. at 261. A

reviewing court should reverse a summary judgment order when evidence supports

the nonmoving party's allegations.

Reply Brief in Support of Motion for Reconsideration

Against Ruling for Summary Judgment PN Strand, Plaintiff P- 563

Strand's evidence proves the county is violating the law. Even if Strand's evidence is what was

2 requested under the PRA so the evidence obviously exists.

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IX. HODGSON'S ROLE IN VIOLATING THE PRA

Summary judgment is frivolous because it depends completely on the.acts, words and

credibility of Hodgson. The following proves all of them are problematic

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He is an accredited appraiser since 1985. (P-598)

He has worked for the Assessor since 1992 .

He has worked with Pro Val since 1999. (P-3, -40 to -41, -51, -599)

He has worked with the PRA since 2009. (P-2, -7 footnote 2, -599) He is the Assessor's

"From" on all responses to Strand's requests. (P-33, -46, -67, -152, -156, -162, 651 to -

665)

He dealt with Strand PRA requests since 2009 by withholding records and disclosing

nothing about Assessor's processes. (P-42 to -49, -51, -599)

He is the Assessor's expert on policies, procedures, practices and the law. (P-173, -268 B,

4) He is the public face and voice of the Assessor's.office since 2010 as shown in the

attached press clippings. (P-442, -6 to -20, -600 to -602,)

On February 24, 2011 Strand made a PRA request for an allegation in an Assessor's

Answer to Real Property Petition to.Spokane County Board of Equalization. (P-603) On

March 11, 2011 Hodgson gave Strand a teeny picture with cute labels. (P-604) It was

such a cute little picture Strand suspected it was fraudulent- not from ProVal. Strand

was appealing 17355.9014's value because the Assessor raised the house value $32,800

Reply Brief in Support of Motion for R«:1Consideration Against Ruling for Summary Judgment

cf (e\'-\

P- 588 PN Strand, Plaintiff

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after an inspection that should have lowered the value. ln July after repeated PRA

requests Strand learned two things. (l) Appraiser Splater assigned 17355.9014 using his

appraiser judgment decided how to label her land on the Petition. (P-603) .• (2) Hodgson

did a cut and paste creation to get Strand off his back about the basis of the. allegation on

the Petition. (P-603) .. He created his little picture after the request. It violated the PRA.

• In January 2015 in case 14201079-1 Hodgson testified to why, when and how cards are

created in Pro Val. (P-7)

• In case 14201079-1 in October 2015, he explained to creating a series of appeal rosters

that he gave to Strand as being from the Spokane County Board of Equalization ("BOE").

This fraudulent act ensnared the BOE Director, Linda Kovick. Ms. Kovick submitted an

Affidavit explaining the roster Hodgson gave Strand was not from the BOE and that

Hodgson should not have been able to create reports from the BOE BEATS database. (P-

606 to -621) Hodgson' s affidavit explains he has no reason to commit fraud by creating

rosters. (P-622 to 631) His evidence of not committing fraud are screenshots of metadata

showing he accessed and manipulated the BOE's database to create records just for

Strand. (P-628 to -631) Strand .had no idea why he did this ..

• In March and April 2019 he gave Strand cards. (P-33, -46, -67) He alleged the cards

responsive. (P-46, 67, 152, 156; 162) It. is reasonable to conclude he knew the cards were

all nonresponsive. He was intentionally making false statements and violating the PRA!

• He stated on March 27, 2019, An· agency is not obligated to create a new record to satisfy

a records reqµ.est. (P-157) But, he created470 pages of new records-cards. (P-33, -46,

Reply Brief in Support of Motion for Reconsideration Against Ruling for Summary: Judgment

PN Strand, Plaintiff P-589 S c_} le \

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-67; Assessor-Page: 2-3, 23; 26-33, 162-621) Strand never requested cards. (P-32, -36

to -38)

He stated on March 27, 2019,

The value conclusion is derived from the sales analysis which is included

in the Neighborhood Final Review Reports. The analysis is interpolated in

the value conclusion by the individual appraiser coupled with the

appraiser's knowledge and experience. (P-157)

Strand assumes only Appraiser Sporn, who printed the reports, is the interpolator who

can connect these reports to real property values. (P-265) Strand has no basis for this

assumption. Strand has no way to know what was interpolated or why .. Strand does not

know what the sales analysis is because it is not obvious. Strand has no idea the purpose

of these reports because it is not obvious. What Strand now knows is Hodgson' s

statement means he knows nothing either.

His responses in March and April 2019 say nothing about a search. (P-276, -504) He

declared doing a search for responsive records on April 20, 2020. 7

His declarations8 of telling the truth are the basis of the Assessor's case. But, he testified

to assessment practices violating Washington's Constitution, statutes and codes -

unlawful practices. These would be practices that he would have to train appraisers to

perform.

The Assessor's actions in this case are the same as in Strand, Palmer D et al vs .. Spokane

County et al; case 18203909-1, 365387- III. In 18203909-1. In 18203909-1 Strand

requested the electronic database :inspection history of all appraisers. (P-632) The

Declaration of Byron Hodgson Filed April 21, 2020 page 4 Declaration of Byron Hodgson Filed April 21, 2020; Declaration of Byron Hodgson Filed June 5, 2020

Reply Brief in Support of Motion for Reconsideration Against Ruling for Summary Judgment

c..Pc..,~ P" 590


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Assessor alleged no identifiable records available (P-648) and the only responsive

records were cards. (P-636, -649) The cards had to be created after the request. Defense

Counsel Binger filed for summary judgment alleging Strand .showed no PRA violation.

The Complaint showed a PRA violation. (P-641) Strand argued the that cards were

nonresponsive because they did not exist and did not contain the requested information.

CONCLUSION: This list is constructive evidence Hodgson deliberately violated

the PRA in this case by creating cards thatwere not requested andwere not responsive to

Strand's request. He created cards he knew violated the PRA because they did not exist

atthe time the request was filed. He created cards because.they.are effective as a record.

It does not matter that they are not the record requested! This list proves a case reliant on

the credibility of Hodgson fails the credibility test. This list proves>summaryjudgment

frivolous!

X. PRAYER FOR RELIEF

a. Relief Requested in Complaint

Wherefore, Plaintiff, Patricia Strand prays for judgment against Defendants as follows:

Order the Defendants to promptly provide Plaintiff the records requested in their PRA

requests discussed herein.

Award Plaintiffs all costs, including reasonable attorney's fees,.incurred in connection

with this action and efforts to obtain the records, as provided inRCW 4256.550(4).

Award Plaintiffs monetary penalties .pursuant to RCW 42;S6.550(4}of $100 per page per

day from the date of the request until the date Defendants proyide all)he requested

Reply Brief in Support of Motion for Reconsideration Against Ruling for Summary Judgment P- 591


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records in unredacted form or with redactions as approved by the court after evaluating

claimed exemptions.

For such other relief as the court.deems just.

b. Relief Requested in Plaintiff Response to. Defendant's Motion (Qr Summary Judgment

The court to Order Defense to amend all pleadings and filings for a .corrected captioning

with no other changes for an accurate Record.

The court to Order the Dismissal of the Defense Motion for Summary Judgment as

Frivolous with Prejudice.

The court to Order the Defense to answer Strand' s Interrogatories when Discovery is

authorized by COVID orders to resume l,lllder CR 33.

The court to Order the Interrogatories Answers to showwho and what was searched and

what records produced for each question.

For such other relief as the court deems just.

c. Relief Requested. in Plaintiff's ,Supple~ntal_Response to Defenda,u's Reply M~nwrqnd11min.S#J!pt,rt of Jdotlon/or

. . . . . ·· Summary Judgment

The court to find the Assessor has violated RC\V 42.56.520(1).

The court to find the. Assessor failed to disclose 19 fact-0rs.

The court to dismiss the Assessor's swnmary judgtllerit as frivolous with prejudice;

The court to order Defense to amend all filings captioned.erroneously.

The court to accept this brief to be filed with the Clerk ofthe Court.

Reply Brief in Support of Motion for Reconsideration Against Ruling for Summary Judgment

P-592 PN Strand, Plaintiff

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From: Sent: To: Subject:

-Hodgson, Byron Tuesday, June 28, 2011 12:18 PM '[email protected]' RE: PRR June 13

Follow Up Flag: Follow up Flag Status: Completed

RE: PRRData

Dear Mrs. Strand,

In reference to your statement below, the data you are requesting is located on the Property Record Card for each parcel. The screen print 1 provided to you (no view, water view, and waterfront) was not an existing report but was for your convenience.

With respect to your question about water view and waterfront property, the appraiser assigned to the area would make that judgment. The difference in value between the property types can be determined using arithmetic.

Sincerely,

Byron Hodgson

-----~

From: [email protected] [mailto:[email protected]] Sent: Thursday, June 23, 2011 7:53 PM To: Hodgson, Byron Cc: Emaclo, James Subject: RE: PRR June 13

NO THIS REQUEST IS NOT COMPLETE!

On Nov/24/10 I requested; • Provide the following numbered items comprising Assessor support for assessment year 2009 7 buildings,

etc (improvements) value of $249,900 2. I want the basis for the following statement and the specific $ amount associated with this status for

parcel 17355.9028, "All comparable sales are ranch style "Long Lake" waterfront or "waterview· parcels ...

• Provide the following numbered items comprising Assessor support for assessment year 2009 7 land value of$200,000

2. I want the basis tor the following statement and the specific $ amount associated with this status for parcel 17355.9028, "All comparable sales are ranch style ''Long Lake" waterfront or "waterview• parcels ... ----------------~---------------------------------------------------

On Dec/8/10 this was your responee, (2) This statement was provide by Joe _________________ ,, ___ ,. __ .,.. ____ ... __ -------- .... -------------------------------

\

On Feb/24/11 I requested:

I. Assessor requested clarification??? I requested, "I want the basis for the following statement and the specific $ amount associated with this status for parcel 17355.9028, "All comparable sales are ranch style "Long Lake" waterfront or ''waterview" parcels ...

This statement appears on page 3 of the Assessor's Answer to Real Property Petition to the Spokane County Board of Equalization Petition No BE-09-0265 (copy on page 2). I run requesting:

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A. The documentary sUpti,!:/; fot thii:'. statement 1Jow does the Assessor prove it is watervie»: property?

B. And, nlease prove the specific additional value attached to the waterview fepture of this property b,1: documentation?

On Mar/11/11 this was your response:

!··----·--·-~-• Puo:.sl I 73>3.9034 (n., view) --.:, i $ w il<.'<11 fdl.t I! .... J'ti'* $ ll'l', lrMI lttl\.di

= = 5

-w.wt~EiJmd,j ~l<il<M f'lj,

Ett-UrA-

= :: : fa1l:cl 1735S.902ll ('1'1&1\ll¥1~.w)

E ; - .w,1 fc.t"": " lol ~ ,lrl'/'4

e e § I = ! l\lr.:~I I 7:15:\.(/014 rw;.i.1.<.rfrr,,11) . ::: u•\'/1UJ£S-• ; <loo! r.,... H""°l\o'.• En,..., - lrl% W\.'lll !r.lM 11.\lk« Pia, i JSIY~U:r) - !HOii . l{l)J . 4~(D) rolll.O ! 20JQW

1. -·-··-··--····-· ... , .. -, .............. ,--,.. tatus for parcel 17355.9028 ..... lot value comparisons and illustrations of waterfront (subject) and water view properties .

... ----··--------~·---------------·------ .... ---·k---------------------- -----

_____ qn_ f\:1~r(I ~/J ! ! r!ee~~e~ ~1~ f ~b!2_4~1 J !f:.Cl!:11:S~ _ • _______ .. ___________________________ _

On Jun/l l/11 I requested:

Please provid~ the fbl!owing'documentation

2

2530 P- 604

From: Sent: To: Subject:

Categories:

Hodgson, Byron Thursday, July 21, 2011 11 :29 AM '[email protected]' Strand PRR Review

Copied to ADMIN

RE: Public Records Request Clarification and Review of Requests

Dear Mrs. Strand,

I am in the process ofreviewing your pending Public Record Requests. With respect to e-mail and non-e-mail correspondence, the request for all e-mails dated Feb 07, 2011, encompasses e-mails from Jan/1/07 to the date of the request Feb/7/1 t. A request for non-e-mail correspondence dated April 26, encompasses all non-e-mail correspondence from Jan/1/07 to April 26, 2011. Please confirm this is the correct date ranges for these requests.

With respect to your e-mail of July 14th and the assertion of possible fabrication and fraud. The data provided to you on March 11th was a screen print that included headings to assist you. The information itself was not from an existing report or document but information prepared specifically for you. This information was provided to you in that form in an effort to answer your question(s). The data is accurate and matches the report that was provided to you on June 30, 20 l 1 for all parcels on your list and the information is consistent with the data on the Property Record Card(s),

As a reminder, arrangements can be made for you to view copyrighted and proprietary information including Pro Val and Marshall & Swift. Also, polic.y and procedures manuals can be viewed or provided to you at a cost. State manuals, which contain the bulk of laws, codes, procedures, and rules for assessors are available through our office or the Department of Revenue.

Your Public Record Requests will continue to be provided in installments until complete.

Sincerely, Byron Hodgson

You wrote in part:

A. ........ Please provide any/all e-mail dating from Jan/1 /07 wherein any/all of the following are discussed: 1. Parcel 17355.9014; 2. Palmer D and/or Patricia N. Strand; 3. State of Washington Board ofTax AppealsDockets 09-121 and/or 08-2020; Spokane County Board of Equalization- Petition numbers 09-0265 and/or 08-2020 ............... ..

NEW REQUEST B .............. I want copies of any/all non e-mail correspondence dating from Jan/1 /07 through present wherein

any/all of the following are discussed: • Parcel 17355.9014 • Palmer D and/or Patricia f\J. Strand

( . ~ State of Washing Board of Tax Appeals·- Docl<ets 09-121 and/or 10-258 ., • Spokane County Board of Equalization - Petition numbers. 09-0265 and/or 08-2020

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IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON IN AND FOR THE COUNTY OF SPOKANE

-PALMER D. and PATRICIA )

STRAND, ) )

No.: 14-2-01079-1

Plaintiffs,

vs.

) ) ) ) )

DECLARATION OF LINDA KOVICK

SPOKANE COUNTY, and ) )

SPOKANE COUNTY ASSESSOR, ) )

Defendant. ) -·-,-~"-'""""""-----------

LINDA KOVICK hereby declares and states under penalty of perjury as

follows:

1. I am over the age of 18 and competent to be a witness in this matter.

2. I am, and was at all times relevant hereto, the Director of the Spokane

County Board of Equalization ("BOE").

3. Attached as Exhibit "A'' hereto1 is a true and correct copy of an email

message from Pat Strand dated July 21, 2015 at 12:53 PM along with an

attached report entitled SBT A, which includes information about appeals to


Page I of 4

SPOKANE COUNT\' Prosecuting Attorney W. 1115 Broadway Avenue Spokane, Washington 99260 (509) 477-5764

P-606

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the Washington Board nf Ta,-~ Appeals for tax year 2011. Mrs. Strand asked

several questions regarding the attached report.

4. Attached as Exhibit "B" hereto, is a true and correct copy of my response to

Mrs. Strand's email dated July 21, 2015 at 3:55 PM. Therein, I answered

that the report attached to Exhibit "A" "is not produced. This information is

however available in our BEA TS database system." I added that the report

was not produced by the BOE.

j

5. Attached as Exhibit "C" hereto, is a true and correct copy of a Master List

printed from the BEATS database system ..

6. The BOE owns and controls the data base software application program

known as BEATS. This database contains information from various sources,

including the Washington State Board of Tax Appeals, which is inputted into

the system by the BOE staff With one exception noted below in paragraph

7, only BOE staff may input or otherwise change data in the system.

Utilizing specific queries, the database is able to ,produce custom reports

such as the SBTA report attached as Exhibit "A" and the Master List report

attached as Exhibit "C". These custom reports are "living documents" in

that they change over the cour.je of time based upon new information input

into BEA TS, and the immediate needs of BOE.

Other users which are granted special security clearance - including the

Spokane County Assessor - have limited access to BEATS. These limited


Page 2 of 4

SPOKANE COUNTY Prosecuting Attorney W. 1115 Broadway A venue Spokane, Washington 99260 ( 509) 4 77 • 5764

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\,,

users have only "read-r~t(~;(' :::(:1J1.:,r.t Th.?.t is, limited users may access the

data in BEA TS, perform queries, and produce custom reports such as the

report attached to Exhibit "A". However, such limited users have no

authority to input data, or otherwise change the information in the BEA TS

system - except for entries by the Assessor of value stipulation agreements

reached with taxpayers in settlement of pending appeals before the BOE.

8. BOE staff receives information from the Washington Board of Tax Appeals

and inputs it into the database.

9. BOE did not produce the record attached to Exhibit "A"; and, would not

have ever produced such a report in the normal course of business.

However, as noted above, a limited user with access to the BEA TS system

could have produced this report.

I declare under penalty ofperjury under the laws of the State of Washington that

the foregoing is true and correct.

SIGNED at Spokane, Washington this ;:P.;>rd da~ of October, 2015.


Page 3 of 4


P- 608

EXHIBIT "A"

P ~ 609

From: Sent To:. Subject: Attachments:

Ms. Kovick

pat strand .:[email protected]:;. Tuesday, July 21, 2015 12:53 PM Linda Kovick, Director Is this your report? Sep 19, 14 BTA appeals 2011.pdf

Attached ls a report about appeals to the WA. Board of Tax Appeals. Is this report produced by your

office? Was this report produced by your office? If this report was produced by your office when is it

prepared? Who prepares it?

Patricia Strand

1

Tax Year": 2011

Case Complete: ALL

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EXHIBIT "B"

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from: Sent Tf: Subject:

Hello Mrs. Strand,

LKovick@spolc'.ti?;12c::,'.'T,ty.<'i\~

Tuesday, July 21, 2015 3:55 PM

[email protected] RE: Is this your report?

This is acknowledgment of your e-mail inquiry for information. I have reviewed the report as you provided in your

attachment about appeals to the Washington Board ofTax Appeals. Thus, in response to your inquiry please find as

follows:

Q: "Is this report produced by your office?"

A: This report Is not produced. This information is however available in our BEATS DATABASE SYSTEM.

Q: "Was this report produced by your office?"

A: This report was not produced by our office.

Q:. "If this report was produced by your office when is it prepared?"

A: Non-applicable

Q: "Who prepares it?"

A: Non-applicable

I hope this information is of help to you.

Linda

Linda M. Kovick, Director

Spokane County Board of Equalization

[email protected]

417-2250

from: pat strand [mailto:[email protected]] Sent: Tuesday, July 21, 2015 12:53 PM To: Kovick, Linda Subject: Is this your report?

Ms. Kovick

Attached is a report about appeals to the WA. Board of Tax Appeals. Is this report produced by .your

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PALMER D. STRAND, PATRICIAN. STRAND

Plaintiffs,

v.

SPOKANE COUNTY and SPOKANE COUNTY ASSESSOR,

Defondant.

STATE OF WASHINGTON ) ) :ss

County of Spokane , )

) ) ) ) ) ) ) ) ) ) )

No. 14-2~01079-1

AMENDED AFFIDAVIT OF BYRON HODGSON IN SUPPORT OF DEFENDANTS' SECOND MEMORANDUM ON PENALTIES AND FEES

BYRON HODGSON, being first duly sworn upon oath, deposes and

declares:

1. That I am above the age of 181 and am competent to testify to the

matters stated herein, which would be admissible as evidence at the time of hearing.

AMENDED AFFIDAVIT OF BYRON HODGSON · Page 1 of 11


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2. I am an Accredited Appraiser with the Washington Department of

Revenue (since 1985). I have worked in the ad valorem assessme~t since 1979 and

have been a certified appraiser for ad valorem assessment in Idaho and Oregon.

3. I began working for Spokane County Assessor's Office in 1992 as a

Deputy Assessor;! was promoted to Deputy Assessor Appraisal Manager in 1999;

and, I was appointed Chief Deputy Assessor in January of 2011.

4. Since 1999, I have overseen all appraisal software applications and

integrated systems for the Assessor's Office, including the conversion.

5. One of my duties as Chief Deputy Assessor is to respond to public

11 record requests. I have been involved with responding to Ms. Strand's requests for

12 information and public records since 2009.

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6. 1v1s. Strand requests have often seeks non-identifiable records, which

result a s1ream of communications to determine what she is requesting. Our office

has very limited resources and has often been unable to complete searches and

produce responsive records to a pending request before another is .submitted. In ..

2012, because of the number and nature of Ms. Strands pending public record

requests, one of which was for numerous word or phrases in all databases and emails,

I began to search concunently.

AM ENO ED AFFI.DA VlT OF BYRON HODGSON Page 2 ofU

SPOKANE COUNTY Prosecuting Attorney W. 11 JS Broadway Avenue Spokane, Washington 99260 (509) 477-S764

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7. Pertaining to £i pubi~(; Jccor:cfa request submitted to the Spokane County

by Patricia Strand on September 13) 2012, which stated in part, "!'want the roster of

appeals to the Board of Equalization."

8. I acknowledged Ms. Strand's request for Board of Equalization

("BOE") rosters. Because I had previously informed Ms. Stand that the pending

requests involving the search of databases for individual words would take years to

complete unless she changed the search criteria, I included that the current requests

would be completed concnrrently pending requests. Although asked, Ms. Strand

never prioritized her requestg nor amended the search criteria to allow more rapid

fulfillment.

9. The Assessor, s Office has. no need to create or maintain rosters or

13 statistics regarding appeals to the Board of Equalization or Washington State Board

14 of Tax Appeals. The BOE owns and controls database applications know as

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BEA TS, in which BOE catches information from multiple sources. The Assessors ,

have access to the BEATS. generally read-only, and the Assessor's Office relies on: ,, '

the data maintained by the BOE.

10. Property owners who wish to challenge property assessments file a

petition for appeal with the BOE. The BOE either accepts or denies petitions,,

assigns cases numbers, creates hearing schedules, and populates and maintains the

database tracking the statmi of the appeal.

AMENDED AFFTOAVIT · OF BYRON HODG!mN

24 Pagel of H

Sf0KA1'4ii': COUNTY Prosecuting Attorney W. I J15 Broadway A venue Spokane, Washington 99260 (509) 477-5764

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1 11. The BOE also enters :rod maintains data in BEATS to track cases

2 , appealed to the State Board of Tax Appeals.

3 12. Reports generated from BEATS appears to continually change, I

4 believe this is largely due to a steady stream of updated data entries. The State Board

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of Tax Appeals can elect to hear several years of combined appeals during a hearing,

which can result in multiple changes to assessment/tax years in the BOE data base

based on their decision. In addition, under Washington law, assessors have different

assessment. rolls (revaluation, new construction, and business personal property)

which means appeals are being filed at different tlimes during the year.

13. Either party to a BOE appeal, dissatisfied with the decision may file a

12 petition for review with the State Board of Tax Appeals. When accepted, the State

13 Tax Board sends notification to the parties and to BOE. The BOE is required to send

14 a copy of the BOE appeal record to State Board of Tax Appeals.

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14. During the January evidentiary hearing~ the issue of rosters and

statistics was raised> and Plaintiffs offered up a one page, 'Exhibit # 1, 1903, as proof ::, .

the Assessor maintained statistics. I later identified Exhibit 11903, as the last page of

a report generated by me from the BOE BEATS database and provided to Plaintiffs

September 12, 2014.

15. BOE's BEATS is capable of generating reports. It appears to me that

once an appeal is filed with BOE, the BEATS database is populated not only with the

AMENDED AFFIDAViT OF BYRON HODGSON

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assigned case number but other information periinent to the case - this infonnation is

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not entered by the Assessor with one exception. The exception is that when a case is.

resolved prior to hearing through a stipulated value change between the Assessor and

property owner, the assessor enters that information. Read only access to the

BEA TS system includes the permission to request reports, the reports can be for less

than all data maintained by BOE in BEATS.

16. The Assessor's Office goes to BOE's BEATS database when

information is needed to determine the status of an appeal. I believe BOE has a duty

to maintain this information whereas the Assessor does not. BEA TS also the source

of infonnation the Assessor forwards to Washington State Department of Revenue

12 (DOR). DOR then compiles the infonnation from all counties to produce an annual

13 report.

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17. Subsequent to the issuance of the Court's Memorandum Decision dated

June 18, 2015, I detem1ined that some BOE BEATS reports have previously been

provided to Plaintiffs. One prior request wanted all ema~ls searched for certain terms.

or parcel munbers. Included among the responsive documents produced were a few

BOE Master Lists located during the search of archived emails. Again, the Master

Lists were not created or maintained by the Assessor's Office, but they had been

downloaded at some point a.11d were discovered dming the search. The responsive

documents to Ms. S~an.d)s email :request were so large the Assessor's Office set up a .

AMENDED AFFl:OAVIT OF BYRON HODGSON

24 PageS ofll

SPOKANE COUNTY Prosecuting Attorney W. I 115 Broadway Avenue Spokane, Washington 99260 (509) 477-5764

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1 separate l~TP site for her to access the r.ntm-)tfals. 'I'he site was removed after it was

2 confumed Ms. Strand accessed the matedal. .

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18. Plaintiff's requests be<;ame so numerous and expansive that it became

impossible to finish one before the next request arrived. In 2012 Plaintiffs submitted

a request that included a search of all written documents for 32 work or phrases.

While the Assessor's Office does not create or maintain BOE or BT A rosters or

statistics, I was aware that some BOE documents could well be buried in old

electronic files since it is possib]e to download the data from BOE. In fact, searches

for individual words and or parcel numbers have located some downloaded material

from BOE and the documents, namely hundreds of pages of BOE 2009 rosters for tax

year 2010 and 2010 rosters for tax year 201L, were sent to Ms. Strand.

19. Subsequent to issuance of the Court's Memorandum Decision, I

directed Frank Oesterheid who ir, well versed in public records issues, to conduct a

search of the individual assessors for BOE appeal rosters documents that might be

responsive to lvis. Strand's request. No such records were found (See A(fidavit of

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Oesterheld's, dated August 11, 2015).

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20. . Immediately below are three~ metadata screen prints for the Master Lists

I generated from the BOE/s BEATS database on Friday, September 912_', 2014,

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1 My Affidavit dated August 1 ·1, w·1 s containiad r-1 Scribner's error regarding exhibit numbers on page

7 in 1{ 16, which I overlooked - i have showed the specific number errors corrected with strikethrough.

AMENDED AFFH>AVIT , · OF BYRON HODGSON

24 Page 6 of 11

SPOKANE COUNTY Pros~'Uting Attorney W. 1115 Broadway Avenue Spokaue, Washington 99260 (509) 477-S764

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- 1 which were provided as a cou.rtesy to . the Strands by email (Exhibit #6821)

2 attachment on September 12, 2014 as S~andPRR~.2.

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SPOKANE COUNTY Prosecuting Attorney W. l 1 l S Broadway A venue Spokane, Washington 99260 (509) 477-5764

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AMENDED AJ•FmA vn OF BYRON HODGSON

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SPOKANE COUNTY Prosecuting Attorney W. 111 S Broadway A venue Spoknne, Washington 99260 (509) 477-5764

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21. Immediately below is the metadata for BOE's SBTA data which was

generated from the BOE's database on September 1~21, 2014, and provided Strands

by email (Exhibit #6822 attachment the same day as StrandPRR8iJ.

1 My Affidavit dated August 11, 2015 contained a Scrlbne,~s error regarding exhibit numbers on page

8 in ,i i 7, which I overlooked - i have showed the specific number errors corrected with

strikethrough.

AMENDED AFFmAVl1' OF BYRON HODGSON Page 9 of 11

SPOKANE COUNTY Prosecuting Attorney W. 1115 Broadway Avenue Spokane, Washington 99260 (509) 477~5764

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22, The Master Lists and SBTA provided Plaintiffs in September of20l4

were created from BOE's BEATS database for the sole purpose of were providing them

as a courtesy to Plaintiffs ..

SUBSCRIBED AND S\VORN to before me this ;8~day of October 2015, in

Spokane, WA.

of Washington, residing at Spokane. My commission expires: _Lo/~1/Li

SPOKANE COUNTY Prosecuting Attorney W, l 115 Broadway Avenue Spokane, Washington 99260 (509) 477-5764

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216,225 n.l, 770 P.2d 182 (1989) (citing Celotex Corp. v. Catrett, 477 U.S. 317,325

[1986]) (internal quotation marks omitted).

The party seeking summary judgment must show that no genuine issue of material

fact exists and that he is entitled to judgment as a matter of law by showing that there is an

absence of evidence to support the non-moving party's case. Celotex, 477 U.S. at 325. To

determine if summary judgment is appropriate, the court must consider whether a particular

fact is material and whether there is a genuine dispute as to that fact left to be resolved.

These considerations must be made in light of the appropriate standard of proof. Anderson

v. Liberty Lobby, Inc., 477 U.S. ?42, 248 (1986). Factual disputes that do not affect the

outcome of the suit under governing law will not be considered. Id. Where there is a

complete failure of proof concerning an essential element of the non-moving party's case,

all other facts are rendered immaterial, and the moving party is entitled to judgment as a

matter of law. Celotex, 477 U.S. at 324; see also Lujan v. National Wildlife Federation,

497 U.S. 871 (1990) (holding that f~ilure to "make a sufficient showing of an essential

element" of one's case requires dismissal). Summary judgment is an appropriate procedure

for deciding public records cases. Spokane Research & Defense Fund v. City of Spokane, 155

Wn.2d 89, 106, 117 P.3d 1117 (2005).

III. ARGUMENT

1. The Plaintiff Has Failed to Show A PRA Violation

24 MEMORANDUM IN SUPPORT OF SUMMARY .JUDGMENT Page 8 of 11

SPOKANE COUNTY PROSECUTING ATTORNEY 1115 W. Broadway Avenue Spokane, Washington 99260

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The PRA requires agencies to make identifiable public records available for

inspection and copying. RCW 42.56.080. An identifiable public record is "one for which

the requestor has given a reasonable description enabling the government employee to

locate the requested record." Beal v. City of Seattle, 150 Wn. App. 865, 872, 209 P.3d 872

(2009); see also WAC 44-14-04002(2) (an "identifiable record" is one agency staff can

"reasonably locate"). "[A] proper request under the PDA must identify with reasonable

clarity those documents that are desired, and a party cannot satisfy this requirement by

simply requesting all of an agency's documents." Hangartner v. City of Seattle, 151 Wn.2d

439, 448, 90 P.3d 26 (2004). In this regard, the PRA does not require agencies to be mind

readers, or to produce records that have not been requested. Bonamy v. City of Seattle, 92

Wn. App. 403, 409, 960 P.2d 447 (1998). To hold otherwise would put agencies in an

untenable position. Id.

In responding to Mrs. Strand's requests the Assessor's Office provided 636 pages

of responsive documents following a search of all locations where responsive records could

be located including:

• Department shared drives;

• Electronic databases; • Local computers; and • Websites

(Declaration of Hodgson)

The search was reasonable and thorough and provided Mrs. Strand all responsive

documents.

24 MEMORANDUM IN SUPPORT OF SUMMARY JUDGMENT Pnge 9 of 11

SPOKANE COUNTY PROSECUTING ATTORNEY 1115 W. Broadway Avenue Spokane, Washington 99260 c~ .,

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CONCLUSION

Defendants respectfully request that the Court determine Defendants did not violate

the PRA and dismiss this action with prejudice.

DA TED this 21st day of Apri I, 2020

LAWRENCE H. HASKELL Spokane County Prosecuting Attomey

_§~h~·-········'"' ...... ,,, .. ,.,_, ROBERT B. BINGEil~BA # l 0774 Sr. Deputy Prosecuting Attorney Attorneys for Defendants

MEMORANDUM IN SUPPORT OF SUMMARY JtlDGMENT Page 10 of 11

SPOKANE COUNTY l'ROSECUTING ATTORNEY 1115 W. Broadway Avenue Spokane, Washington 99260 (509) 477-5764

·<kl

From: To: Subject: · Date: Attachments:

Hodgson. Byron [email protected] FW: Strand PRR 2-20-2019 2 Friday, March 08, 2019 3:25:00 PM Strand2-20-2019 .pdf 18-0071.pdf

RE: PRR 2-20-19 Strand Installment 2

Patricia Strand

Attached is installment 2 of your referenced request for public records. Files attached include

the Assessor's Answer to real property petition DA 18-0071 and Property Record Cards for

comparable sales referenced in the petition. The Property Records Cards contain information

pertaining to your clarification of your original request, i.e.; sold property sale dates; sold

property address; sold property parcel number; sold property land type and building

characteristics. Note: Photographs for comparable sales are on the Assessor's website under

parcel information. https://www .spokanecounty.org/219/Assessor

This public records request remains open. Expect the next installment of responsive records

on or before the March 15th. Additional information pertaining to your initial request and

clarification of your request will be provided. Some of the information requested is available

on the Assessor's parcel Online Services parcel downloads: https://gisdatacatalog

spokanecounty.opendata.arcgis.com/pages/parcel-data-file-downloads The expectation,

unless additional time is required, is all responsive records will be provided by the next

installment date. Some items may require additional clarification.

Spokane County Assessor's Office

Strand PRR 2-20-2019 2

ASSESSOR- PAGE 14 cf1l\'1-

ASSESSOR'S ANSWER TO REAL PROPERTY PETITION & VALUATION INFORMATION

STRAND, PATRICIAN

S.P<.::>K.A.r----03 C::C..."">U~ Petition No. DA-18-0071

To The Spokane County Board of Equalization

1. PARCEL NUMBER OR LEGAL DESCRIPTION OF PROPERTY: 17355.9014

2. ASSESSOR'S TRUE & FAIR VALUE:

3. GENERAL DESCRIPTION OF PROPERTY:

A.Address or Location

B.Land Use:

C.Zoning & Use

D.Brief description of buildings:

5. HAS PROPERTY BEEN OFFERED FOR SALE?

Listed with a broker?

$150,000

$247,900

$397,900

(Land type,type buildings, use, etc.)

13206 W CHARLES RD

Fronts Enhancement #1

Residential

Single Family or Duplex residence built in

Unknown When and how long?

Asking price $

Land

Improvements

Total

2002

6. HAS PROPERTY BEEN APPRAISED BY OTHER THAN THE COUNTY ASSESSOR? Unknown

By whom?

Appraisal value?

Purpose of appraisal:

(If needed, attach separate sheet for further evidence)

7. Attached are the following maps, pictures, letters, appraisals or other data to substantiate the present

full market value of the property as stated in item No. 2.

EXHIBIT NO.

2 3

4 5

Sustain initial value

BRIEF DESCRIPTION OF EXHIBIT Cover Letter

Representative Sales- to be provided within 21 clays of hearing

Statistical Measures Limiting Conditions Withdrawal/Stipulation (to be included with sales)

The statistical measures included within this report appear to be supportive of our initial valuation position.

lays of the scheduled hearing, we will be also be providing comparable properties which we feel are reflective of your

·· - property and supportive of market value. I \ !.

Petition# DA-18-0071 Parcel # 17355.9014 Petitioner STRAND, PATRICIAN

In connection to House Bill 2479 and an ACT relating to Washington's property assessment appeal procedures (RCW 84.48.150), we will be amending our Appeal Responses to be in compliance with the bill.

*Upon request of the taxpayer who petitioned (RCW 84.48.150(1)) this property at the Board of Equalization we will be providing the verified sales which helped establish the model for which your property was assessed. Such factors utilized in determining your assessed valuation was the CAMA (Computer Assisted Mass Appraisal) and the assessment level metrics provided (Ratio, COD, COY & PRO). It should be noted that not all of the sales provided are comparable to your property. However, these sales helped establish market valuation of other properties within the statisical neighborhood in which you reside. In order to be in compliance with RCW 84.48.150(2), we will be providing direct comparable sales, as a part of this same package, within 21 business days of the scheduled hearing. Please be advised that direct comparable sales may indeed be located within different statistical neighborhoods. These comparable sales will constitute additional evidence, which is supportive of our initial or revised appraisal position.

·*Adjusted Sales Price= Market sales and/or inflation within Spokane County has been very robust over the past 16 months. During the date range 1/1/2017 to 4/30/2018, we have estimated a conservative inflationary level of 1/2% per month or 6% annualized. This figure has been utilized in these calculations and the sales price of these "benchmarks" has been adjusted to the assessment date of 1/1/2018.

..J 14701 N OXFORD RD 17363.9081 SHORS AS430 104.02 511

38 Large Ranch 2300+ G- G 1960 3390 195.35 10 03/13/2018 $662,228 $599,700 0.91

Obsmt 13012 W CHARLES RD 17355.9012 SHORS AS43D 104.02 511 4 7 Ranch 1000-1499 A G 1977 1300 315.46 5.5 10/17/2017 $410,094 $381,400 0.93

13804 W CHARLES RD 17352.9021 SHORS AS430 104.02 511 69 2 Story+ 2300+ G- G 1996 2418 189.96 5.2 08/30/2017 $459,319 $448,300 0.98

14906 N HEDIN RD 17364.0903 SHORS AS430 104.02 518 91 Double Wide F F 1991 1568 91.68 1 07/25/2017 $143,759 $145,900 1.01

ASSESSOR - PAGE 20

*The statements of fact contained in this report are true & correct.

*The reported analyses, opinions, and conclusions are limited only by the reported assumptions and limiting conditions, and are my personal, impartial, and unbiased professional analyses, opinions and conclusions.

*We have no present or prospective interest in the property that is the subject of this report and we have no personal interest with respect to the parties involved.

*We have no bias with respect to any property that is the subject of this report or to the parties involved with this assignment.

*Our engagement in this assignment was not contingent upon developing or reporting predetermined results.

*Our compensation for completing this assignment is not contingent upon the reporting of a predetermined value or direction in value that favors the cause of the client, the amount of the value opinion, the attainment of a stipulated result or the occurrence of a subsequent event directly related to the intended use of this appraisal.

*It should be noted that additional employees of our Residential Staff may have provided mass appraisal assistance in terms of data collection, sales validation, etc. in the comparable sales data provided. These employees may include; Rhodora Capiral, Debi Mason, Ben Delgado, Megan Gray, Deborah Hujus-Strait, Michelle Walker, Sam Margulis, Kerry Walicki, Laura Vazquez, Stephanie McKinney, Nate Lawless, Kimberly Merritt and Jeanna Mann.

*Sam Margulis has been assigned to this neighborhood and has provided significant mass appraisal assistance for this assignment.

If the taxpayer/ appellant has any questions and/ or concerns regarding the contents of this appeal they can call the Appraiser of record.

Appraiser: Sam Margulis Phone Number: 477-5908

Re: Strand PRR 2-20-2019 2 From: pat strand Date: Fri 3/8/2019 4: 16 PM To: Hodgson, Byron

Mr. Hodgson

On February 24, 2019 I provided a clarification .of the February 20, 2019 request for records. I provided this clarification because the appraisal you provided on February 21. 2019 conveyed you did not understand the request. The February 24, 2019 is in your possession it is specific and detailed and is a request for the public records I want What you provided today was not requested. Frankly it is confusing and totally nonresponsi ve.

Please provide the records I requested on February 24, 2019. Please provide immediately a statement of the time required to produce the records requested on Febniary 24, 2019.

Sincerely yours,

Patricia Strand

,-1

ASSESSOR- PAGE 34 (_,Pt(()«-

From: To: Subject: Date: Attachments:

Hodgson. Byron [email protected] Strand PRR 2-22-2019 4 Friday, March 22, 2019 3:24:00 PM StrandNeighborhoodTable.xlsx StrandSALE.XLSX

RE: Strand PRR 2-20-2019 4

Patricia Strand

Attached is installment 4 of your referenced request for public records. In the interest of full

assistance, the attached files are from Online Services/Parcel Data Downloads:

https: //gisd ata cat a I og-spoka n eco u nty. open data. a reg is. com/pages/pa rce 1-d ata-fi le-

down I oa ds; The files are limited to the subject neighborhood 231720. Parcel Data Downloads

contain much of the information you are requesting in EXCEL spreadsheets. The attached files

do not include all information but are an example of downloadable information that can be

arranged and grouped to suit the requirements of individual requestors.

Additional information can be found on the Assessor's Website:

https ://www .spoka necou nty. org/219/Assessor.

Summary of Records Provided:

The Neighborhood Final Review reports contain all sales and analysis used in the valuation

process. The Property Record Card for each sale provides sale information; property

characteristics; and the final value conclusion of each parcel with the posting history. NOTE:

Appeal cases may include sales outside of the subject neighborhood to support a value

conclusion.

NOTE: If you want complete notes, please request appraisal notes for individual parcels or

notes for the entire neighborhood. Most notes display on the Property Record Card, however,

there are some limited situations where the notes fail to display.

The expectation is responsive records for all items in your request ~ave been provided,

however, if a requested item has been missed, please contact us immediately. Documents

cannot be created for individual requestors when the information is available in standard

formats. Sales analysis is included in the Neighborhood Final Review reports which is

interpolated in the value conclusion by the individual appraiser.

This is the final installment for your request. If an item has been missed, please contact the

Assessor's Office or the Spokane County Public Records Office.

ASSESSOR - PAGE 622 c.P \':'.) l

Sent: Friday, March 22, 2019 5:45 PM

To: Hodgson, Byron <[email protected]>

Subject: Re: Strand PRR 2-22-2019 4

Mr. Hodgson

Last week, on March 15, 2019 you e-mailed me 11 groups of records. I requested you connect everything you have mailed to me allegedly responding to my request of 2/20/2019 that was clarified on 2/21/2019.

Please immediately connect what you have mailed to me with the request of 2/21/2019. I do not know the purpose of the records you produced. The records you produced do not have any connection with what I requested. So if you do not immediately connect the records you are producing with what I requested I shaJI not ask again for this do be done. We will again end up in Court for violations of RCW 42.56.520.

Sincerely

Patricia Strand

ASSESSOR - PAGE 632 cf ,·--~Col

From: To: Subject: Date:

Hodgson. Byron [email protected] Strand PRR 2-22-2019 Summary of Responsive Records Wednesday, March 27, 2019 11:34:00 AM

March 27, 2019

Patricia Strand

Re: Responsive Records Summary Strand PRR 2-22-2019

The following information is a summary of the responsive records that were provided to for

Strand PRR 2-22-2019.

1. Regarding DA 18-0071 on parcel 17355.9014. I want all records that show the Assessor's basis for valuation for assessment year 2018 -- 2019 taxes.

Regarding your direct appeal to the State Board of Tax Appeals, appeal information

was provided to you. The Property Record Card was provided to you as it includes

detailed information pertaining to the cost approach to value which is the basis of the

valuation of your property. ProVal property characteristics are itemized on the

Property Record Card. ProVa/ code sheets, etc., is not an identifiable record; however,

ProVal coding is described and detailed on the Property Record Card and was provided

for each sale used in the Assessor's sales analysis.

2. Clarified Request, A,B, and C

A. 1-5. Sold property Information was provided to you on the Property Record Card

which lists all sales information including granter and grantee, address, sale dates,

parcel number, and land type. The Property Record Card lists all posting dates in the

date range requested. The Property Record Card was provided to you for each sale.

Sold property information is summarized in the Neighborhood Final Report. Sales

used in the neighborhood analysis are included in the report and analysis.

6. Photos of property display on the Assessor's Website

7. All requested information is connected on the Property Record Card.

8. Land type and methods, provided in a spreadsheet. (common methodologies for

valuing land)

9. The arithmetic (formula) pertaining to land values is not an identifiable record;

The Neighborhood Final Review Report was provided and includes the analysis to

determine market value. The analysis is interpolated in the value conclusion by the

individual appraiser coupled with the appraiser's knowledge and experience.

10. NA

ASSESSOR- PAGE 633

B. 1-7. Sold property information was provided on the Property Record Card. Photos

display on the Assessor's website. The Property Record Card was provided for each

sale. The property Record Card lists all posting dates for the date range in the

request. Sales summary is included in Neighborhood Final Review Reports. All sales

used in the valuation of the neighborhood are included in the sales analysis and

summary.

8. All requested information connected on the Property Record Card.

9. Sold property information, and sales analysis are included in the Property Record

Card and the Neighborhood Final Review sales analysis.

10,11,&12. Posting dates pertaining to each year are on the Property Record Card

and include other depreciation factors. The Property Record Card was provided for

each sale.

13. Appraisal theory; not an identifiable record.

14. Sales analysis and value conclusion are contained in the Neighborhood Final

Review Report. The analysis is interpolated in the value conclusion by the

individual appraiser coupled with the appraiser's knowledge and experience.

15. NA

C. 1-7. 1-7. Sold property information provided on the Property Record Card. Photos

display on the Assessor's website. The Property Record Card was provided for each

sale. The property Record Card lists all posting dates in the date range in the

request. Sales summary and analysis is included in Neighborhood Final Review

Reports. All sales used in the valuation of the neighborhood are included in the sales

analysis and summary. All requested information is connected on the Property

Record Card. The value conclusion is derived from the sales analysis which is

included in the Neighborhood Final Review Reports. The analysis is interpolated in

the value conclusion by the individual appraiser coupled with the appraiser's

knowledge and experience.

8. NA

All identifiable records that you have requested have been provided. An agency is not

obligated to create a new record to satisfy a records request. Even if a new record was

contemplated, it would be a complicated undertaking requiring the compilation of

historical data which would not yield an arithmetic formula (correlation between sold

and unsold property) to derive valuation. This request is considered closed.

Spokane County ·Assessor's Office

From: pat strand <[email protected]>

ASSESSOR- PAGE 634 cf ) ')C/3»

Re: Strand PRR 2-22-2019 Summary of Responsive Records From: pat strand Date: Thu 3/28/2019 5:49 PM To: Hodgson, Byron

Attachments: (I) ProVal Code Sheets - walkout and lower.pdt: (2) Analysis,ofappraisals.docx

Mr. Hodgson, thank you for providing the 3/27/2019 response. Now l can further clarify any conflicting

information about my request for public records.

I. My 2/24/19 requeston page 3, A, 11 Pr0Val code sheets", examples are attached. Please provide the

Pro Val code sheets for each-and every •iLand Types" you included on the hundreds of appraisals you

produced. 2. l withdraw my requestforphotos at this time because I have been using.the Assessor's website and the

photos previously provided not on the w~bsite. 3. Please specifically associate the appraisals you provided ns "SALES" with the dollar amounts in the

table on page 2 of the request. ln,ean there are dollar amounts in the table - associate the appraisal dollar amoqnts with the tabl.e dollar amounts, Your association of the words "grantor and grantee"

with the table are ridiculous. We you trying to be funny?

RCW 84.40.030 is very specific in requidng the Assessor:provide the basis of value as specific sales. A

specific.sllle has a date, dollar, address, similar feature~ with 17355.9014. Thpse are the specifics.you need to

connect for the (1) land, (2) improvements and (3) total dollar. Jt would be nice if you connect any one of

these three amounts to these hundreds of appraisals. But the law requires you connect all three. I requested

you connect.all three for the five years. ·

I. Please explain what purpose the 3 78· pages ofappraisals you produced on 3/15/2019 serve? Al1ached

is an analysis of the first 8 of the appraisals. The.are.not sales an.d they are not similar to 17355.9014 so again what is their purpose.

2. Please explain the purpose of your Neighborhood reports. Like the 378 pages of a,ppraisals are you trying to be funny?

Patricia Strand

u'( ,rs u '-\ ASSESSOR - PAGE 635

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No responsive records were withheld.

6. Records are Silently Withheld.

No responsive records were withheld.

7. Strand's Right to Judicial Review

No response necessary

8. Strand's Right to Attorney Fees, and Costs, and Penalties

No response necessary

CONCLUSION

Defendants respectfully ask the Court to grant summary judgment and dismiss this

matter with prejudice.

DATED this 5111 day of June, 2020

LA WREN CE H. HASKELL Spokane 'ounty Prosecuting Attorney

~w!f~n ROBERT B. BINGER,~SBA 1110774 Sr. Deputy Prosecuting Attorney Aitorncys J<ff Defendants

23 REPLY MEMORANDUM IN SUPPORT OF SUMMARY JUDGMENT

24 Page 5 ofe

SPOKANE COUNTY PROSECUTING ATTORNEY 1115 W. Broadway 1\vcnuc Spokane. Washington 99260 (509) 477-576•1

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11:1rJT::' 1 '.i:-:: src;'.:.,, :· ,~ ·· ... 1 ·~· .·: ';'

IN Tiffi SUPERIOR COURT OF Tiffi STA TE OF WASHINGTON

IN AND FOR Tiffi COUNTY OF SPOKANE

PA TRICIA STRAND ) ) ) ) ) ) ) )

Plaintiff, v.

SPOKANE COUNTY, et al.

Defendant.

No. 20-2-01077-32

SECOND DECLARATION OF BYRON HODGSON

I, BYRON HODGSON, declare under the penalty of the laws of the State of

Washington that the following statements are true and correct to the best of my knowledge

and belief:

1. I am above the age of 18 and competent to testify to the matters stated herein,

which are based on my own personal knowledge.

2. I am the Spokane County Chief Deputy Assessor.

3. Information on the property record cards is contained in a computer

software program known as Pro Val. The property record cards could not be printed until

21 after Mrs. Strand's request was received.

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24 SECOND DECLARATION OF BYRON HODGSON Page 1 of3 SPOKANE COUNTY

PROSECUTING ATTORNEY 1115 W. Broadway Avenue Spokane, Washington 99260 (509) 477-5764

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4. The "code sheet" as referenced by Mrs. Strand with a date of received

Jul/20/10 (P-159 to P-160) to her Complaint is of unknown origin. I searched the

Assessor's Office and databases and could not locate these documents.

DATED this _5_ day of June, 2020 in Spokane, Washington.

24 SECOND DECLARATION OF BYRON HODGSON Page 2 of3 SPOKANE COUNTY

PROSECUTING ATTORNEY 1115 W. Broadway Avenue Spokane, Washington 99260 (509) 477-5764

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PROOF OF SERVICE

I hereby declare under the penalty of perjury and the laws of the State of Washington that the following statements are true.

On the 5th day of June, 2020, I caused to be served a true and correct copy of the

foregoing document by the method indicated below, and addressed to the following:

Palmer D. Strand Patricia N. Strand P.O. Box 312 Nine Miles Falls, Washington 99026 [email protected] (Plaintiffs Pro Se)

Personal Service _lL U.S. Mail

Hand-Delivered Overnight Mail

__X_ E-Mail

Dated this 5th day of June, 2020, in Sp,o~ane, Washington.

,$/?1:t'~lZ..r ~trnA· ~-<_._, Donna Monroe

24 SECOND DECLARATION OF BVRON HODGSON Page3 of3 SPOKANE COlJNTV

PROSECUTING ATTORNE\' 1115 W, Broadway Avenue Spokane, Washington 99260 (509) 477.5764

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PATRICIA STRAND ET AL,

Petitioner;

vs.

SPOKANE COUNTY SUPERIOR COURT No. 20-2-01077-32

SPOKANE COUNTY ASSESSOR ET AL,) )

COURT OF APPEALS No. 37669-9-III

Respondent. )

MOTION FOR SUMMARY JUDGMENT AND PRESENTMENT HONORABLE TONY D. HAZEL

A P P E A R A N C E S FOR THE PETITIONER:

FOR THE RESPONDENT:

June 12, 2020

Robert Binger Deputy Prosecuting Attorney 1115 W. Broadway Avenue Spokane, WA 99260

Patricia Strand Pro Se

Tracie Blocker, Official Court Reporter #3457 Spokane County Superior Court, Spokane, Washington

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Mr. Binger's Argument

Ms. Strand's Argument

Mr. Binger's Rebuttal

Ms. Strand's Rebuttal

The Court's Ruling

Presentment

Ms. Strand's Argument

The Court's Ruling

INDEX

Court Reporter's Certificate

Strand et al vs. Spokane County Assessor et al

Index

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located. Ms. Strand was provided 636 some pages of

responsive documents and directed to various websites

with additional responsive information.

In this case, Ms. Strand appealed

administratively to our public record's officer which

gave us the opportunity to give it a second look. And

the public record's officer also concluded the

responsive documents had been provided.

Her third argument was failure to provide

electronic records. Her records were provided by email.

Her fourth argument is failure to provide

exemption log or justify withholding. No records were

withheld so this argument goes by the wayside. She says

records and property withheld in their entirety. It's

not correct. According to our declarations, all

responsive records were provided.

Her seventh argument, she has a right to

judicial review. Here we are.

Her eighth argument, rights to attorney's

fees, costs, and penalties. Under some circumstances,

that is correct. In a nutshell, she got everything

we've got. There's nothing else to give.

THE COURT: Thank you, Mr. Binger.

MR. BINGER: Thank you.

THE COURT: And Ms. Strand.


Motion for Summary Judgment

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I'm sorry. I'll take a moment and look at those

specifically to see what they are.

THE COURT: Can I just ask a clarifying

question. Your cause of action alleges a Public Records

Act violation.

MS. STRAND: Yes.

THE COURT: Let me just ask you a

hypothetical question. Let's say that the assessor

didn't follow other statutory criteria and just,

willy-nilly, assessed -- this is all just

hypothetical -- willy-nilly assessed the value of the

property basically based on baseless information.

MS. STRAND: Then they should have disclosed

that.

THE COURT: All right.

MS. STRAND: That's what the law says.

THE COURT: Okay. But let's say that

happened.

MS. STRAND: Uh-huh.

THE COURT: But you then file a Public

Records Act Disclosure and they provide you with

whatever they actually had. How is that cause of

action, under a Public Record's Act, how do you survive

that?

MS. STRAND: First off, I requested what you



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used to determine the value of my property. If you went

to the bathroom on Thursday and used toilet paper,

identify it.

THE COURT: Right. In other words, my

question is couldn't you, in theory, an assessor could

violate, I guess, standards of practice or other

statutes that direct how property is valued?

MS. STRAND: Mm-hmm.

THE COURT: But that doesn't necessarily

mean that they violated the Public Records Act.

MS. STRAND: When I filed my request, the

request assumed compliance with the law. I do not know

what this assessor is using. But I have to make an

assumption. I have to cover that base. So the request

included those three statutes, 84. 40. 030, 84. 48 .150, and

84.40.020, that all records associated with listing and

valuing real property are public. I included those

that -- that's the floor. I do not know where you're

floating above the floor, but the floor says those are

the records you have to provide.

Now, the reason I provided the 19 factors

because those are identified by the assessors in

Spokane County as the actual things they use to value

property. So assessor -- I'm sorry. The prior assessor

was a woman, Vicki Horton. I think it was Vicki Horton.



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Her chief-deputy assessor, Mr. Hodgson, who is the

public records officer who provided these records;

testified; and stated before the Washington State

auditor that they don't value quite a few structures.

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That's a factor they use for valuation. That factor, in

fact, violates the law. But if that's the way you do

it, give me the factors because the factors are

divorced. A factor is what are you going to do to

determine value whether it's legal or not.

Does that answer your question?

THE COURT: I think so. Thank you.

MS. STRAND: Okay. So I identified 19

factors. Quite a few of them are legal, but those are

the factors that are documented by the assessors in

Spokane County since 2009 as the meconisms they use for

valuing real property. So this was back to what the

assessor gave me in response to my public records

request for how did you determine the value. And

initially I asked for one year because this was for an

appeal to

Tax Appeals.

[Inaudible] -- the Washington State Board

I asked for the 2018 assessment year. I

received a Property Record Card on the 21st, a Property

Record Card for my property. So that did not satisfy

the loan. It also did not identify any factors used

whether it's the law or what the assessor's doing, two


Motion for Summary Judgment (l,(>\I

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Here's what we used to determine your land. Here's --

and that's what I asked for. I broke it down. I wanted

to know what you used to determine my land. Here's the

dollar value of my land. Where did this number come

from? What did you use to determine my structure value?

Here's the dollar value of my structures. Where did

this number come from? And then there's a third, where

did this total value come from? A response should

specifically state, there's where these numbers come

from. The 19 factors that I put into evidence to say

here's clear evidence that they didn't give me these

things even if the assessor does not comply with

84.40.030 and use sales.

Factors is that catch all thing that covers

everything else that the assessor does. It's the

definition of what are the mechanisms you used to

determine values. If Jay Sporn is a mechanism, then you

say on there Jay Sporn determined your value.

THE COURT: Let me just ask you this simple

question. Based on everything that they've disclosed to

you, what did they -- what in your opinion -- you're a

CPA --

MS. STRAND: I'm pretty sure Jay Sporn is

where a lot of my values came from, and prior to him,

Larry Spaletto[phonoetic] determined my values.



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THE COURT: Okay. And what do you think they

based it on?

MS. STRAND: Their appraiser judgment.

THE COURT: So, in some ways, do you believe

that -- so the whole purpose of this statute is to

ensure that the public has -- there's transparency that

a citizen could get to the bottom of a government

action.

MS. STRAND: Okay.

THE COURT: Do you think that statute has

done its job?

MS. STRAND: You're going to tell me that in

this Court because I'm asking, and I did ask very

plainly, assessor, for these five years, each year, for

land, for structures, for total value, where did these

numbers come from? And if you're saying that it would

have been satisfied by saying they came from Jay Sporn

for 2018 and structures came from Jay Sporn for 2018,

then that's what they should have written. That should

have been the response. If I'm upset with that fact,

then I would take it to another point. But they didn't

give me that. They gave me a card created a day after

the request or days after the request which on its face

violates the law, violates the Public Records Act Law.

So those are nonresponsive, period. The second thing



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magical. I can't understand them. That might very well

be. That's not -- doesn't mean we didn't provide her

the public records. I think she's offering you

speculation. We're not -- I think she's saying the

assessor's office should do more. Usually we have these

That's for a factors, should be all set forth.

different day, a different argument. She asked us to

give her was everything relative. Everything in her

request, she's gotten it and has offered -- I don't

think offered the Court any material facts that you

could rely on to deny summary judgment.

respectfully that you grant it.

So I would ask

Mr. Binger.

THE COURT:

All right.

MS. STRAND:

THE COURT:

MS. STRAND:

All right. Thank you very much,

First of all

May I rebut that?

Yes, I' 11 allow you to.

First off, my request is quite

simple and -- please provide the following records on

Parcel 17355.9014. I want all records that show the

assessor's basis, for valuation, the first request for

assessment year 2018, 2019 taxes.

I don't know. I don't remember exactly how

Mr. Binger put it. But he seemed to ignore that I'm

saying, where did these numbers come from, the basis of



(UPDATE HTTP://APP.LEG.WA.GOV -MAR 2020)

WASHINGTON STA TE CONSTITUTION Article VII - Revenue and Taxation - Section 1 Taxation. The power of taxation shall never be suspended, surrendered or contracted away. All taxes shall be uniform

upon the same class of property within the te1Titorial limits of the authority levying the tax and shall be

levied and collected for public purposes only. The word 11property 11 as used herein shall mean and include

everything, whether tangible or intangible, subject to ownership. All real estate shall constitute one class:

Provided, That the legislature may tax mines and mineral resources and lands devoted to reforestation by

either a yield tax or an ad valorem tax at such rate as it may fix, or by both. Such property as the legislature

may by general laws provide shall be exempt from taxation. Property of the United States and of the state,

counties, school districts and other municipal corporations, and credits secured by property actually taxed in

this state, not exceeding in value the value of such property, shall be exempt from taxation. The legislature

shall have power, by appropriate legislation, to exempt personal property to the amount of fifteen thousand

($15,000.00) dollars for each head of a family liable to assessment and taxation under the provisions of the

laws of this state of which the individual is the actual bona fide owner.

TITLE 34 ADMINISTRATIVE LAW

~hapter 34.05 Administrative Procedure Act

RCW 34.05.526 Appellate review by supreme court or comi of appeals. An aggrieved party may secure

appellate review of any final judgment of the superior court under this chapter by the supreme court or the

court of appeals. The review shall be secured in the manner provided by law for review of superior court

decisions in other civil cases.

TITLE 36 COUNTIES

Chapter 36.01 General Provisions

RCW 36.01.050 Venue of actions by or against counties. ( 1) All actions against any county may be commenced in the superior court of such county, or in the

superior court of either of the two nearest judicial districts. All actions by any county shall be commenced in

the superior court of the county in which the defendant resides, or in either of the two judicial districts

nearest to the county bringing the action. (2) The determination of the nearest judicial districts is measured by the travel ti me between county

seats using major surface routes, as determined by the administrative office of the courts.

(3) Any provision in a public works contract with any county that requires actions arising under the

contract to be commenced in the superior court of the county is against public policy and the provision is

void and unenforceable. This subsection shall not be construed to void any contract provision requiring a

dispute arising under the contract to be submitted to arbitration.

Title 40 PUBLIC DOCUMENTS, RECORDS, AND PUBLICATIONS

£hapter 40.14 Preservation and Destruction of Public Records

RCW 40.14.010 Definition and classification of public records. As used in this chapter, the term "public records" shall include any paper, correspondence, completed

form, bound record book, photograph, film, sound recording, map drawing, machine-readable material,

compact disc meeting current industry ISO specifications, or other document, regardless of physical form or characteristics, and including such copies thereof, that have been made by or received by any agency of the

state of Washington in connection with the transaction of public business, and legislative records as

described in RCW 40. 14.100. For the purposes of this chapter, public records shall be classified as follows:

Page 1

(1) Official public records shall include all original vouchers, receipts, and other documents

necessary to isolate and prove the validity of every transaction relating to the receipt, use, and disposition of

all public property and public income from all sources whatsoever; all agreements and contracts to which the

state of Washington or any agency thereof may be a party; all fidelity, surety, and performance bonds; all claims filed against the state of Washington or any agency thereof; all records or documents required by law

to be filed with or kept by any agency of the state of Washington; all legislative records as defined in RCW 40.14.100; and all other documents or records determined by the records committee, created in RCW

40.14.050, to be official public records. (2) Office files and memoranda include such records as correspondence, exhibits, drawings, maps,

completed forms, or documents not above.defined and classified as official public records; duplicate copies of official public records filed with any agency of the state of Washington; documents and reports made for

the internal administration of the office to which they pertain but not required by law to be filed or kept with

such agency; and other documents or records as determined by the records committee to be office files and memoranda.

TITLE 42 PUBLIC OFFICERS AND AGENCIES

Chapter 42.56 Public Records Act

RCW 42.56.010 Definitions. The definitions in this section apply throughout this chapter unless the context clearly requires

otherwise. (1) 11 Agency" includes all state agencies and all local agencies. "State agency" includes every state

office, department, division, bureau, board, commission, or other state agency. "Local agency" includes

every county, city, town, municipal corporation, quasi-municipal corporation, or special purpose district, or

any office, department, division, bureau, board, commission; or agency thereof, or other local public agency.

(2) "Person in interest" means the person who is the subject of a record or any representative designated by that person, except that if that person is under a legal disability, "person in interest" means and includes the parent or duly appointed legal representative.

(3) "Public record" includes any writing containing information relating to the conduct of government

or the performance of any governmental or proprietary function prepared, owned, used, or retained by any

state or local agency regardless of physical form or characteristics. For the office of the secretary of the

senate and the office of the chief clerk of the house of representatives, public records means legislative

records as defined in RCW 40.14.100 and also means the following: All budget and financial records;

personnel leave, travel, and payroll records; records of legislative sessions; reports submitted to the· 1 .

legislature; and any other record designated a public record by any official action of the senate or the house of representatives. This definition does not include records that are not otherwise required to be retained by

the agency and are held by volunteers who: (a) Do not serve in an administrative capacity; (b) Have not been appointed by the agency to an agency board, commission, or internship; and

(c) Do not have a supervisory role or delegated agency authority. (4) 11 Writing" means handwriting, typewriting, printing, photostating, photographing, and every other

means of recording any form of communication or representation including, but not limited to, letters, words,

pictures, sounds, or symbols, or combination thereof, and all papers, maps, magnetic or paper tapes, photographic films and prints, motion picture, film and video recordings, magnetic or punched cards, discs,

drums, diskettes, sound recordings, and other documents including existing data compilations from which

information may be obtained or translated.

RCW 42.56.080 Identifiable records-Facilities for copying-Availability of public recorqs. (1) A public records request must be for identifiable records. A request for all or substantially all

records prepared, owned, used, or retained by an agency is not a valid request for identifiable records under

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this chapter, provided that a request for all records regarding a particular topic or containing a particular keyword or name shall not be considered a request for all of an agency's records.

(2) Public records shall be available for inspection and copying, and agencies shall, upon request for identifiable public records, make them promptly available to any person including, if applicable, on a partial or installment basis as records that are part of a larger set of requested records are assembled or made ready for inspection or disclosure. Agencies shall not deny a request for identifiable public records solely on the basis that the request is overbroad. Agencies shall not distinguish among persons requesting records, and such persons shall not be required to provide information as to the purpose for the request except to establish

whether inspection and copying would violate RCW 42.56.070([) or 42.56.240(14), or other statute which exempts or prohibits disclosure of specific information or records to certain persons. Agency facilities shall

be made available to any person for the copying of public records except when and to the extent that this

would unreasonably disrupt the operations of the agency. Agencies shall honor requests received in person during an agency's normal office hours, or by mail or email, for identifiable public records unless exempted by provisions of this chapter. No official format is required for making a records request; however, agencies may recommend that requestors submit requests using an agency provided form or web page.

(3) An agency may deny a bot request that is one of multiple requests from the requestor to the agency within a twenty~four hour period, if the agency establishes that responding to the multiple requests

would cause excessive interference with other essential functions of the agency. For purposes of this subsection, "bot request" means a request for public records that an agency reasonably believes was automatically generated by a computer program or script.

RCW 42.56.100 Protection of public records-Public access. Agencies shall adopt and enforce reasonable rules and regulations, and the office of the secretary of

the senate and the office of the chief clerk of the house of representatives shall adopt reasonable procedures allowing for the time, resource, and personnel constraints associated with legislative sessions, consonant with the intent of this chapter to provide full public access to public records, to protect public records from damage or disorganization, and to prevent excessive interference with other essential functions of the agency, the office of the secretary of the senate, or the office of the chief clerk of the house of representatives. Such rules and regulations shall provide for the fullest assistance to inquirers and the most

timely possible action on requests for information. Nothing in this section shall relieve agencies, the office of the secretary of the senate, and the office of the chief clerk of the house of representatives from honoring requests received by mail for copies of identifiable public records.

If a public record request is made at a time when such record exists but is scheduled for destruction in the near future, the agency, the office of the secretary of the senate, or the office of the chief clerk of the house of representatives shall retain possession of the record, and may not destroy or erase the record until

the request is resolved.

RCW 42.56.520 Prompt responses required. (l) Responses to requests for public records shall be made promptly by agencies, the office of the

secretary of the senate, and the office of the chief clerk of the house ofrepresentatives. Within five business days of receiving a public record request, an agency, the office of the secretary of the senate, or the office of the chief clerk of the house of representatives must respond in one of the ways provided in this subsection

(1 ): (a) Providing the record; (b) Providing an internet address and link on the agency's web site to the specific records requested,

except that if the requester notifies the agency that he or she cannot access the records through the internet,

then the agency must provide copies of the record or allow the requester to view copies using an agency

computer; ( c) Acknowledging that the agency., th~ office of the secretary of the senate, or the office of the chief

clerk of the house of representatives has received the request and providing a reasonable estimate of the time

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the agency, the office of the secretary of the senate, or the office of the chief clerk of the house of representatives will require to respond to the request;

( d) Acknowledging that the agency, the office of the secretary of the senate, or the office of the chief

clerk of the house of representatives has received the request and asking the requestor to provide clarification

for a request that is unclear, and providing, to the greatest extent possible, a reasonable estimate of the time

the agency, the office of the secretary of the senate, or the office of the chief clerk of the house of

representatives will require to respond to the request if it is not clarified; or (e) Denying the public record request. (2) Additional time required to respond to a request may be based upon the need to clarify the intent

of the request, to locate and assemble the information requested, to notify third persons or agencies affected

by the request, or to determine whether any of the information requested is exempt and that a denial should

be made as to all or part of the request. (3)(a) In acknowledging receipt of a public record request that is unclear, an agency, the office of the

secretary of the senate, or the office of the chief clerk of the house ofrepresentatives may ask the requestor to clarify what information the requestor is seeking.

(b) If the requestor fails to respond to an agency request to clarify the request, and the entire request

is unclear, the agency, the office of the secretary of the senate, or the office of the chief clerk of the house of representatives need not respond to it. Otherwise, the agency must respond, pursuant to this section, to those

portions of the request that are clear. ( 4) Denials of requests must be accompanied by a written statement of the specific reasons therefor.

Agencies, the office of the secretary of the senate, and the office of the chief clerk of the house of

representatives shall establish mechanisms for the most prompt possible review of decisions denying inspection, and such review shall be deemed completed at the end of' the second business day following the

denial of inspection and shall constitute final agency action or final action by the office of the secretary of r

the senate or the office of the chief clerk of the house of representatives for the purposes of judicial review.

RCW 42.56.550 Judicial review of agency actions. (1) Upon the motion of any person having been denied an opportunity to inspect or copy a public

record by an agency, the superior court in the county in which a record is maintained may require the

responsible agency to show cause why it has refused to allow inspection or copying of a specific public

record or class of records. The burden of proof shall be on the agency to establish that refusal to permit

public inspection and copying is in accordance with a statute that exempts or prohibits disclosure in whole or

in part of specific information or records . . (2) Upon the motion of any person who believes that an agency has not made a reasonable estimate

of the time that the agency requires to respond to a public record request or a reasonable estimate of the

charges to produce copies of public records, the superior court in the county in which a record is maintained

may require the responsible agency to show that the estimate it provided is reasonable. The burden of proof

shall be on the agency to show that the estimate it provided is reasonable. (3) Judicial review of all agency actions taken or challenged under RCW 42.56.030 through

42.56.520 shall be de novo. Courts shall take into account the policy of this chapter that free and open

examination of public records is in the public interest, even though such examination may cause

inconvenience or embarrassment to public officials or others. Courts may examine any record in camera in any proceeding brought under this section. The court may conduct a hearing based solely on affidavits.

( 4) Any person who prevails against an agency in any action in the courts seeking the right to inspect

or copy any public record or the right to receive a response to a public record request within a reasonable

amount of time shall be awarded all costs, including reasonable attorney fees, incurred in connection with such legal action. In addition, it shall be within the discretion of the court to award such person an amount

not to exceed one hundred dollars for each day that he or she was denied the right to inspect or copy said

public record. (5) For actions under this section against counties, the venue provisions of RCW 36.01.050 apply.

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(6) Actions under this section must be filed within one year of the agency's claim of exemption or the

last production of a record on a partial or installment basis.

TITLE 84 PROPERTY TAXES

~apter 84.40 Listing of Pro,t2er.t}.:

RCW 84.40.020 Assessment date-Average inventory basis may be used-Public inspection of listing, documents, and records. All real property in this state subject to taxation shall be listed and assessed every

year, with reference to its value on the first day of January of the year in which it is assessed. Such listing and all supporting documents and records shall be open to public inspection during the regular office hours

of the assessor's office: PROVIDED, That confidential income data is hereby exempted from public inspection as noted in RCW 42.56.070 and 42.56.210. All personal property in this state subject to taxation shall be listed and assessed every year, with reference to its value and ownership on the first day of January

of the year in which it is assessed: PROVIDED, That if the stock of goods, wares, merchandise or material, whether in a raw or finished state or in process of manufacture, owned or held by any taxpayer on January 1 of any year does not fairly represent the average stock carried by such taxpayer, such stock shall be listed and assessed upon the basis of the monthly average of stock owned or held by such taxpayer during the

preceding calendar year or during such portion thereof as the taxpayer was engaged in business.

RCW 84.40.025 Access to property required. For the purpose of assessment and valuation of all taxable property in each county, any real or personal property in each county shall be subject to visitation, investigation, examination, discovery, and listing at any reasonable time by the county assessor of the county or by any employee thereof designated for this purpose by the assessor.

In any case of refusal to such access, the assessor shall request assistance from the department of ~

revenue which may invoke the power granted by chapter 84.08 RCW.

RCW 84.40.030 Basis of valuation, assessment, appraisal-One hundred percent of true and fair valueExceptions-Leasehold estates-Real property-Appraisal-Comparable sales.

( 1) All property must be valued at one hundred percent of its true and fair value in money and assessed on the same basis unless specifically provided otherwise by law.

(2) Taxable leasehold estates must be valued at such price as they would bring at a fair, voluntary sale for cash without any deductions for any indebtedness owed including rentals to be paid.

(3) The true and fair value of real property for taxation purposes (including property upon which there is a coal or other mine, or stone or other quarry) must be based upon the following criteria:.

(a) Any sales of the property being appraised or similar properties with respect to sales made within the past five years. The appraisal must be consistent with the comprehensive land use plan, development regulations under chapter 36.70A RCW, zoning, and any other governmental policies or practices in effect at

the time of appraisal that affect the use of property, as well as physical and environmental influences. An assessment may not be determined by a method that assumes a land usage or highest and best use not permitted, for that property being appraised, under existing zoning or land use planning ordinances or

statutes or other government restrictions. The appraisal must also take into account: (i) In the use of sales by real estate contract as similar sales, the extent, if any, to which the stated seiling price has been increased by reason of the down payment, interest rate, or other financing terms; and (ii) the extent to which the sale of a similar property actually represents the general effective market demand for property of such type, in the geographical area in which such property is located. Sales involving deed releases or similar seller-developer financing arrangements may not be used as sales of similar property.

(b) In addition to sales as defined in subsection (3)(a) of this section, consideration may be given to

cost, cost less depreciation, reconstruction cost less depreciation, or capitalization of income 'that would be. derived from prudent use of the property, as limited by law or ordinance. Consideration should be given to

any agreement, between an owner of rental housing and any government agency, that restricts rental income,

appreciation, and liquidity; and to the impact of govenunent restrictions on operating expenses and on

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ownership rights in general of such housing. In the case of property of a complex nature, or being used under

terms of a franchise from a public agency, or operating as a public utility, or property not having a record of

sale within five years and not having a significant number of sales of similar property in the general area, the

provisions of this subsection must be the dominant factors in valuation. When provisions of this subsection

are relied upon for establishing values the property owner must be advised upon request of the factors used

in arriving at such value. (c) In valuing any tract or parcel ofreal property, the true and fair value of the land, exclusive of

structures thereon must be determined; also the true and fair value of structures thereon, but the valuation

may not exceed the true and fair value of the total property as it exists. In valuing agricultural land, growing

crops must be excluded. For purposes of this subsection (3)(c), "growing crops" does not include marijuana

as defined under RCW 69.50.101.

Chapter 84.41 Revaluation of Property

RCW 84.41.030 Revaluation program to be on continuous basis-Revaluation schedule-Effect of other

proceedings on valuation. (1) Each county assessor must maintain an active and systematic program ofrevaluation on a

continuous basis. All taxable real property within a county must be revalued annually, and all taxable real

property within a county must be physically inspected at least once every six years. Each county assessor

may disregard any program of revaluation, if requested by a property owner, and change, as appropriate, the

valuation of real property upon the receipt of a notice of decision received under RCW 36. 70B.130 or

chapter 35.22, 35.63, 35A.63, or 36.70 RCW pertaining to the value of the real property.

(2) The department will provide advisory appraisals of industrial properties valued at twenty-five

million dollars or more in real and personal propertt value wl~en requested by the county assessor.

RCW 84.41.041 Physical inspection and valuation of taxable property required-Adjustments during intervals based on statistical data.

( 1) Each county assessor must cause taxable real property to be physically inspected and valued at

least once every six years in accordance with RCW 84.41.030, and in accordance with a plan filed with and

approved by the department of revenue. Such revaluation plan must provide that all taxable real property

within a county must be revalued and these newly determined values placed on the assessment rolls each

year. Property must be valued at one hundred percent of its true and fair value and assessed on the same

basis, in accordance with RCW 84.40.03Q, unless specifically provided otherwise by law. During the

intervals between each physicai inspection of real property, the valuation of such property must be adjusted

to its current true and fair value, such adjustments to be made once each year and to be based upon · ·

appropriate statistical data. (2) The assessor may require property owners to submit pertinent data respecting taxable property in

their control including data respecting any sale or purchase of said property within the past five years, the

cost and characteristics of any improvement on the property and other facts necessary for appraisal of the

property.

Chapter 84.48 Egualization of Assessments

RCW 84.48.150 Valuation criteria including comparative sales to be made available to taxpayer-Change.

( 1) The assessor must, upon the request of any taxpayer who petitions the board of equalization for

review of a tax claim or valuation dispute, make available to said taxpayer a compilation of comparable sales

utilized by the assessor in establishing such taxpayer's property valuation. If valuation criteria other than

comparable sales were used, the assessor must furnish the taxpayer with such other factors and the addresses

of such other property used in making the determination of value. (2) The assessor must within sixty days of such request but at least twenty-one business days,

excluding legal holidays, prior to such taxpayer's appearance before the board of equalization make available

to the taxpayer the valuation criteria and/or comparable sales that may not be subsequently changed by the

assessor unless the assessor has found new evidence supporting the assessor's valuation, in which situation

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the assessor must provide such additional evidence to the taxpayer and the board of equalization at least twenty-one business days prior to the hearing at the board of equalization. A taxpayer who lists comparable

sales on a notice of appeal may not subsequently change such sales unless the taxpayer has found new evidence supporting the taxpayer's proposed valuation in which case the taxpayer must provide such additional evidence to the assessor and board of equalization at least twenty-one business days, excluding

legal holidays, prior to the hearing. If either the assessor or taxpayer does not meet the requirements of this

section the board of equalization may continue the hearing to provide the parties an opportunity to review all evidence or, upon objection, refuse to consider sales not submitted in a timely manner.

TITLE 173 DEPARTMENT OF ECOLOGY

Chapter 173-27 Shoreline Management Permit and Enforcement Procedures

WAC 173-27-030 Definitions. (15) "Structure" means a permanent or temporary edifice or building, or any piece of work artificially

built or composed of parts joined together in some definite manner, whether installed on, above, or below the

surface of the ground or water, except for vessels;

TITLE 308 DEPARTMENT OF LICENSING

Cha12ter 308-125 Real Estate Appraisers

WAC 308-125-010 Definitions. ( 1) Words and terms used in these rules shall have the same meaning as each has in the Certified Real

Estate Appraiser Act, (chapter 18.140 RCW) and the Uniform Standards of Professional Appraisal Practice

(USPAP). (2) "Appraisal foundation'' means a private association of appraiser professional organizations. The

appraisal foundation develops appraisal standards which the regulatory agencies must use as minimum standards for federally related transactions and it develops qualification criteria for appraisers.

(3) "Appraisal subcommittee" means a committee created by Title XI. It monitors all activities related to the implementation of Title XL

(4) 11 Appraisal standards board" means a board established by the appraisal foundation for the

purpose of developing, publishing, interpreting and amending the Uniform Standards of Professional

Appraisal Practice. (5) "The Uniform Standards of Professional Appraisal Practice (USP AP)" means the current edition

of the publication in force of the appraisal standards board (ASB) of the appraisal foundation,. USPAP is the applicable standard for all appraisal practice in the state of Washington regulated under the provisions of

chapter 18.140 RCW. (6) "Appraiser qualifications board" means a board of the appraisal foundation for the purpose of

developing, publishing, interpreting and amending the real property appraiser qualification criteria. (7) "Real property appraiser qualification criteria" means the minimum criteria establishing the

minimum education, experience and examination requirements for real property appraisers to obtain a state certification as established by the appraiser qualifications board (AQB) of the appraisal foundation under the provisions of Title XI of the Financial Institutions Reform, Recovery, and Enforcement Act (FIRREA) of 1989, and any additional qualifying criteria established by the director in accordance with chapter 18.140

RCW. (8) "Classroom hour" means fifty minutes out of each sixty minute hour. (9) 11 Full-time11 means the equivalent twelve-month period in which an applicant works at least one

thousand hours in real estate appraisal. (1 O) "Required core curriculum Ii means a set of appraiser subject matter areas (k;nown as 11 modules 11

)

that require a specified number of educational hours at each credential level as established by the appraiser

qualifications board.

Page 7

(11) ''Module" means an appraisal ~mbject matter area (and required hours of coverage) as identified in the required core curriculum.

( 12) "Residential properties" means one to four single family residential units and lots where the highest and best use is for one to four family purposes.

( 13) "Significant professional appraisal assistance11 shall include but not be limited to the work contributed or performed toward the completion of an appraisal report by either a trainee, state-licensed, or state-certified appraiser, while under the direct supervision of a certified residential appraiser or certified general appraiser as required by the department as qualifying appraisal experience for licensing. Significant professional appraisal assistance shall consist of identifying and analyzing the scope of work, collection of data, analyzing data to derive an opinion of value, or writing the appraisal report in accordance with the Uniform Standards of Professional Appraisal Practice.

WAC 308-125-200 Standards of Practice (1) The standard of practice governing real estate appraisal activities will be the edition of the

Uniform Standar,ds of Professional Appraisal Practice of the Appraisal Foundation in effect on the date of the appraisal report. A copy of the Uniform Standards of Professional Appraisal Practice is available for review

and inspection at the office of the Real Estate Appraiser Unit Office, Olympia, Washington. The Uniform Standards of Professional Appraisal Practice is a copyright document. Copy of the full text may be obtained from the Appraisal Foundation at The Appraisal Foundation, P.O. Box 96734, Washington, DC 20090-6734.

(2) Expert review appraisers as defined by RCW 18.140.010(11) while performing expert reviews

pursuant to chapter 18.140 RCW are required to comply with the Uniform Standar,ds of Professional Appraisal Practice, Standard 3 review provjsipns while performiµg expert reviews for the director. ,_

' ' ' ,' '

TITLE 458 DEPARTMENT OF REVENUE ~

Chapter 458-07 Valuation and Revaluation of Real Property

WAC 458-07-015 Revaluation of real propc:rly. ( 1) Appropriate statistical data defined. The assessor must revalue the property at its current true and

fair value using appropriate statistical data. For purposes of this chapter, ''appropriate statistical data" means the data required to accurately adjust real property values and includes, but is not limited to, data reflecting

costs of new construction and real property market trends. (2) Comparable sales data. In gathering appropriate statistical data and determining real property

market trends, the assessor must consider current sales data. "Current sales data" means sales of real property that occurred within the past five years of the date of appraisal and may include sales that occur in the assessment year. To the extent feasible, and in accordance with generally accepted appraisal practices, the assessor shall compile the statistical data into categories of comparable properties. Comparability is most often determined by similar use and location and may be based upon the following use classifications:

(a) Single family residential; (b) Residential with from two to four units; (c) Residential with more than four units; (d) Residential hotels, condominiums; ( e) Hotels and motels; (f) Vacation homes and cabins; (g) Retail trade; (h) Warehousing; (i) Office and professional service; (j) Commercial other than listed; (k) Manufacturing; (1) Agricultural; and (m) Other classifications as necessary.

Page 8

(3) Appraisal processes. Appropriate statistical data shall be applied to revalue real property to current true and fair valu~ using one or more of the following processes:

(a) Multiple or linear regression; (b) Sales ratios; ( c) Physical inspection; or ( d) Any other appropriate statistical method that is recognized and accepted with respect to the

appraisal of real property for purposes of taxation. ( 4) Physical inspection cycles. (a) For purposes of this chapter, "physical inspection" means, at a minimum, an exterior observation

of the property to determine whether there have been any changes in the physical characteristics that affect value. The property improvement record must be appropriately documented in accordance with the findings of the physical inspection. The assessor must physically inspect all real property at least once within a sixyear time period.

(b) Physical inspection of all the property in the county shall be accomplished on a proportional basis in cycle, with approximately equal portions of taxable property of the county inspected each year. Physical inspections of properties outside of the areas scheduled for physical inspection under the plan filed with the department (see WAC 458-07-025) may be conducted for purposes of validating sales, reconciling inconsistent valuation results, calibrating statistical models, valuing unique or nonhomogeneous properties, administering appeals or taxpayer reviews, documenting digital images, or for other purposes as necessary to maintain accurate property characteristics and uniform assessment practices. All properties shall be placed on the assessment rolls at current true and fair value as of January 1st of the assessment year.

(c) In any year, when the area of the county being physically inspected is not completed in that year, the portion remaining must be completed before beginning the physical inspection of another area in the succeeding year. All areas of the county must be physically inspected within the cycle established in the revaluation plan filed with the department.

(5) Revaluation after a value is certified for the current year. In certain circumstances the assessor is authorized to revalue real property, using appraisal judgment, after a value is certified for the current year. These revaluations must not be arbitrary or capricious, nor violate the equal protection clauses of the federal and state Constitutions, nor the uniformity clause of the state Constitution. The assessor may disregard the certified value for the current year and change a property valuation, as appropriate, in the following situations:

(a) If requested by a property owner, when a notice of decision pertaining to the value of real property is received under RCW 36.7013.130 (Notice of decision-Distribution; l9cal project review), . chapter 35.22 RCW (First class cities), chapter 35.63 RCW (Planning commissions), chapter 35A.63 RCW (Planning and zoning in code cities), or chapter 36.70 RCW (Planning Enabling Act);

(b) When the owner or person responsible for payment of taxes on any real property petitions the assessor for a reduction in the assessed value in accordance with RCW 84.40.039, within three years of adoption of a restriction by a government entity;

(c) When there has been a "definitive change ofland use designation" by an authorized land use authority, and the revaluation is in accordance with RCW 84.48.065;

(d) When a bona fide mistake has been made by the assessor in a prior valuation made within the current valuation cycle. The change in property valuation is not retroactive to the prior year;

(e) When property has been destroyed, in whole or in part, and is entitled to a reduction in value in accordance with chapter 84.70 RCW; or

(f) When property has been subdivided or merged. (6) Change of value notice. Revaluation notices must be mailed or transmitted electronically by the

assessor to the taxpayer when there is any change ·in the assessed value of real property, not later than thirty days after an appraisal or adjustment in value.

WAC 458-07-030 True and fair value-Defined--Criteria-Highest and best use-Data from property

owner.

Page 9

(1) True and fair value-Defined. All property must be valued and assessed at one hundred percent of

true and fair value unless otherwise provided by law. "True and fair value'' means market value and is the

amount of money a buyer of property willing but not obligated to buy would pay a seller of property willing but not obligated to sell, taking into consideration all uses to which the property is adapted and might in

reason be applied. (2) True and fair value-Criteria. In determining true and fair value, the assessor may use the sales

(market data) approach, the cost approach, or the income approach, or a combination of the three approaches

to value. The provisions of (b) and ( c) of this subsection, the cost and income approaches, respectively, shall

be the dominant factors considered in determining true and fair value in cases of property of a complex nature, or property being used under terms of a franchise granted by a public agency, or property being operated as a public utility, or property not having a record of sale within five years and not having a

significant number of sales of comparable property in the general area. When the cost or income approach is

used, the assessor shall provide the property owner, upon request, with the factors used in arriving at the value determined, subject to any lawful restrictions on the disclosure of confidential or privileged tax

information. (a) Sales. Sales of the property being appraised or sales of comparable properties that occurred within

five years of January 1st of the assessment year are valid indicators of true and fair value. In valuing property, the following shall be considered:

(i) Any governmental policies or practices, regulations or restrictions in effect at the time of appraisal that affect the use of property, including a comprehensive land use plan, developmental regulations under the

Growth Management Act (chapter 36.70A RCW), and zoning ordinances. No appraisal may assume a land usage or highest and best use not permitted under existing zoning or land use planning ordinances or statutes or other government restrictions, unless such usage is othe.rwise allowed by law;

(ii) Physical and environmental influences that affect the use of the property; (iii) When a sale involves a real estate contract, the extent, if any, to which the down payment,

interest rate, or other financing terms may have increased the selling price; (iv) The extent to which the sale of a comparable property actually represents the general effective

market demand for property of that type, in the geographical area in which the property is located; and (v) Sales involving deed releases or similar seller-developer financing arrangements shall not be used

as sales of comparable property in determining value. (b) Cost. In determining true and fair value, consideration may be given to cost, cost less

depreciation, or reconstruction cost less depreciation. (c) Income. In determining true and fair value, consideration may be given to the capitalization of

income that would be derived from prudent use of the property, as limited by law or ordinance .. Consideration should be given to any agreement between an owner of rental housing and any government agency that restricts rental income, appreciation, and liquidity and to the impact of government restrictions on operating expenses and on ownership rights in general of such housing.

(d) Manuals. Appraisal manuals or guides published or approved by the department of revenue shall be considered in conjunction with the three approaches to value. The data contained in these manuals or guides must be analyzed and adjusted by the assessor to consider time, location, and any other applicable factors to properly reflect market value in the county.

(3) True and fair value-Highest and best use. Unless specifically provided otherwise by statute, all property shall be valued on the basis of its highest and best use for assessment purposes. Highest and best use is the most profitable, likely use to which a property can be put. It is the use which will yield the highest return on the owner's investment. Any reasonable use to which the property may be put may be taken into consideration and if it is peculiarly adapted to some particular use, that fact may be taken into consideration. Uses that are within the realm of possibility, but not reasonably probable of occurrence, shall not be

considered in valuing property at its highest and best use; , ( 4) Valuation of land and improvements. In valuing any lot, tract, or parcel of real property, the

assessor must determine the true and fair value of the land, excluding the value of any structures on the land and excluding the value of any growing crops. The assessor must also determine the true and fair value of

Page 10

any structure on the land. The total value of the land and the structures must not exceed one hundred percent

of the true and fair value of the total property as it exists at the time of appraisal. (5) Valuation data from property owners. The assessor may require property owners to submit

pertinent data regarding property in their control, including sales data, costs and characteristics of improvements, and other facts necessary for appraisal of the property. ,

Chapter 458-10 Accreditation of Real Prom;;tlY.A.Qpraisers

WAC 458-10-010 Accreditation ofreal property appraisers-Implementation-Definitions. ( l) Implementation of accreditation requirements. The rules in this chapter implement the provisions

of chapter 36.21 RCW dealing with the accreditation of persons responsible for valuing real property for

purposes of taxation. To the extent practical, these rules coordinate accreditation requirements with the requirements for certified and licensed real estate appraisers under chapter 18.140 RCW. The purpose of

these rules is to promote uniformity and consistency throughout the state in the education and experience qualifications and maintain minimum standards of competence and conduct of persons responsible for valuing real property for purposes of taxation.

(2) Accreditation required for persons valuing real property for purposes of taxation. Any person responsible for valuing real property for purposes of taxation must be an accredited appraiser. This

requirement includes persons acting as assistants or deputies to a county assessor who determine real property values or review appraisals prepared by others. This requirement does not apply to persons working

in the county assessor's office who do not exercise appraisal judgment with respect to real property. (3) Definitions. Unless the context clearly requires otherwise, the following definitions apply

throughout chapter 458-10 WAC: . . . (a) "Accreditation" means the act or process b{which persons ·are authorized by the department to

assess real property for purposes of taxation and includes the status o'fbeing accredited. r (b) "Accredited appraiser" means a person who has successfully completed and fulfilled all

requirements imposed by the department for accreditation and who has a currently valid accreditation certificate.

(c) "Appraisal" means the act or process of estimating the value ofreal property; an estimate of value

of real property; or of or pertaining to appraising real property and related functions. (d) "Assessment" means the act or process of estimating the value ofreal property for purposes of

taxation only; an estimate of value of real property for purposes of taxation only; or of or pertaining to

assessing real property and related functions. (e) "Classroom hour" means a minimum of fifty minutes out of each sixty-minute hour spent

attending an approved course. (f) "Department" means the department of revenue. (g) 11 IAA011 means the International Association of Assessing Officers. (h) "Real property" means an identified parcel or tract of land, including any improvements, and

includes one or more defined interests, benefits, or rights inherent in the ownership of real estate. (i) "Transactions involving real property" means any of the following: (i) The sale, lease, purchase, investment in, or exchange of real property. including interests in

property or the financing thereof; (ii) The refinancing of real property or interests in real property; or (iii) The use of real property or interests in property as security for a loan or investment, including

mortgage-backed securities.

WAC 458-10-050 Continuing education requirements-Appraisal practice and ethics. (1) Introduction. This rule provides information about the process for renewing an accreditation

certificate, including detailed information about the continuing education requirements required of renewal

applicants. (2) Renewal of accreditation certificate. An accredited appraiser desiring to renew his or her

accreditation certificate must complete a renewal application and submit it to the property tax division of the

Page 11

department at least two weeks prior to the expiration date of the certificate. In order to receive a renewal of

the certificate, the applicant must provide proof that he or she has attended a minimum of fifteen classroom

hours of approved instruction within the two years preceding the expiration date of the certificate.

(3) Extensions of time for renewal. An applicant may request an extension of time to submit the renewal application and complete the continuing education requirements if the request is submitted prior to

the expiration date of the certificate. The time extension shall only be approved upon a showing of good

cause by the applicant and only for a maximum time period of three months from the original expiration date of the certificate. Good cause may include, but is. not limited to, a showing of long-term illness or extended

absence from work for valid reasons. Excessive workload, insufficient funds, lack of budget allocation, or

other similar reasons are not satisfactory to show good cause. ( 4) Preapproval of courses. All courses, seminars, or workshops must be preapproved by the

department in order to be applied toward the continuing education requirement. The department will use the

following criteria to approve courses, seminars, or workshops: (a) Any course, seminar, or workshop directly related to real property appraising and offered by

qualified personnel will be approved for the full number of classroom hours involved; and (b) Any seminar or workshop directly related to a topic or topics of general interest to an assessor's

office and offered by qualified personnel will be approved for a maximum of three classroom hours. No

more than three hours out of the fifteen classroom hours required may be on a topic or topics of general interest to an assessor's office.

(5) Course examination not required. No examination is required for courses, seminars, or workshops

taken to satisfy the requirement for continuing education classroom hours. (6) Participation in education other than as a student. The continuing education requirement may be

satisfied by participating other than as a student in educational proc~ss and programs approved by the

department including teaching, program development, and authorship of textbooks or other written

instructional materials. Approval of the number of classroom hours will be based upon the subject matter and time spent in preparation or development of the training or materials. In order to meet the continuing

education requirement in this manner, the following criteria must be met: (a) Textbook, course, or presentation materials must originate with and be developed by the textbook

or course author or the presenter; (b) The textbook or course author or presenter must provide the department with a description of the

work involved in preparing the textbook, course, or presentation, together with the amount of time spent in preparation and amount of time, if any, proposed to be spent in actual training or presenting; and

( c) The course author or presenter must provide the department with a copy of the course or

presentation outline showing the amount of time allotted to each topic covered in the course or presentation. (7) Topics covered. Courses, seminars, or workshops taken to satisfy the continuing education

requirement for accredited appraisers must cover topics related to real property appraisal, such as: (a) Ad valorem taxation; (b) Arbitrations; ( c) Business courses related to practice of real estate; ( d) Construction estimating; ( e) Ethics and standards of professional practice; (f) Land use planning, zoning, and taxation; (g) Property development; (h) Real estate law; (i) Real property exchange; G) Real property computer applications; (k) Mass appraisal; . (I) Geographic information systems (GIS); (m) Levy process; (n) Boards 'of equalization; and ( o) Other subjects as are approved by the department.

Page 12

r

1.·

(8) Same or similar content. (a) No applicant will receive approval from the department for courses taken within any four-year

time period that have the same or very similar content and are deemed comparable by the department, even if the course providers are different.

(b) Applicants who request approval from the department for continuing education hours for

preparation and development of textbook, course, or presentation materials that have previously been approved by the department must provide sufficient information and explanation to indicate how the materials differ from the original approved materials and how much preparation and time was involved in the

revision of the original materials. (9) Carry-over of classroom hours. A maximum of five continuing education classroom hours may be

carried over and applied to the following two-year period of accreditation. ( 10) Education requirement for standards of appraisal practice and ethics. Each accredited appraiser

is required to successfully complete fifteen classroom hours of a course or courses approved by the department in standards of appraisal practice and ethics. If the course or courses have not been successfully completed at the time an applicant is accredited, the course or courses attended to satisfy this requirement may also be used to satisfy the general continuing education requirement and are not in addition to the fifteen hours of continuing education required to be satisfied every two years. The requirement for successful completion of fifteen classroom hours in standards of appraisal practice and ethics must be satisfied in any one of the following three ways:

(a) An accredited appraiser had successfully completed the fifteen classroom hours of a course or courses at the time he or she was initially accredited, and can provide proof to the department of such successful completion;

(b) An accredited appraiser who has not yet successf'.4Ily completed the fifteen hours of such course or courses must do so within three years of the effective da~e·ofthis rule; or L

( c) An applicant for accreditation must either: · · (i) Have successfully completed fifteen hours of such course or courses within three years prior to the

date of application; or (ii) Successfully complete fifteen hours of such course or courses within three years of the date of

accreditation. (11) Failure to comply with continuing education requirements. Any accredited appraiser whose

accreditation cerlificate has expired, and who has not received an extension of time under subsection (3) of

this section, is prohibited from appraising real property for purposes of taxation. After the certificate has expired, an applicant must show the following in order to renew the certificate:

(a) For a certificate that expired less than two years prior to the date the renewal application is submitted, an applicant must show that he or she has satisfied the fifteen classroom hours of continuing education requirement within the previous two years. Any application submitted within two years of the certificate expiration that fails to satisfy the continuing education requirement will be denied.

(b) For a certificate that expired more than two years prior to the date the renewal application is submitted, the application will be treated as a new application for accreditation and in addition, the applicant

will be required to show that he or she has satisfied thirty classroom hours of continuing education within the

previous four years.

WAC 458-10-060 Standards of practice. The standards of practice adopted by the department and governing real property appraisal activities by accredited appraisers are the generally accepted appraisal standards as evidenced by the current appraisal standards promulgated by the Appraisal Standards Board of the Appraisal Foundation. A complete text of these appraisal standards is available for viewing during normal working

hours at the property tax division of the department.

Chanter 458-12 Prop® Tax Division - rules for Assessors

WAC 458-12-360 Notice of change in value ofreal property.

Page 13

( 1) Introduction. This rule explains the requirement of county assessors to notify taxpayers of any

change in the true and fair value of real property as provided by RCW 84.40.045. The notice of a change in

the true and fair value of real property is commonly referred to as a change of value notice or revaluation

notice. (2) When must a revaluation notice be provided? All revaluation notices must be mailed within thirty

days of the completed appraisal, except that no revaluation notices can be mailed during the period from

January 15th to February 15th of each year. If the true and fair value of the real property appraised has not

changed, a revaluation notice does not need to be sent to the taxpayer following the completed appraisal.

Also, a revaluation notice does not need to be sent regarding changes in valuation of publicly owned

property exempt from taxation under RCW 84.36.010 or of forest land under chapter 84.33 RCW. The following examples identify a number of facts and then state a conclusion. These examples

should be used only as a general guide. The status of each situation must be determined after a review of all

of the facts and circumstances. (a) Example 1. On January 5th the assessor completes an appraisal of a home and the land on which it

sits. The total value of the land and home increased as a result of the appraisal. The assessor must mail a

revaluation notice to the taxpayer by February 16th; however, the assessor is not allowed to mail the revaluation notice between January 15th and February 15th.

(b) Example 2. The assessor appraises a home and the land on which it sits. The value of the home

decreases, and the value of the land increases; however, the total value of the home and land remain

unchanged. The assessor is not required to mail a revaluation notice to the taxpayer. Under RCW 84.40.045,

revaluation notices are only required when there is a change in the true and fair value of the real property that

is the subject of the appraisal. In this example, ,although there is a change in the true and fair value of the

home and land, there is no change in the overall true and fair value ofthe real property that was the subject of the appraisal. ·

(3) What if an assessor fails to provide a timely revaluation notice? The failure to provide a timely

revaluation notice as required by RCW 84.40.045 does not invalidate the assessment. RCW .84.40.045 does

not affect RCW 84.40.020 which provides, in relevant part, that all real property in this state subject to taxation must be listed and assessed every year, at its value on January l st of the assessment year.

A taxpayer who fails to timely appeal an assessor's determination of value to the county board of

equalization (board) because of the assessor's failure to timely provide a revaluation notice may still petition

the board for a review of the assessor's determination of value. A board may reconvene on its own authority

in certain circumstances as provided in WAC 458-14-127 Reconvened boards-Authority, including upon

request of a taxpayer who has not received a timely revaluation notice. According to WAC 458-14-127, the

taxpayer must submit to the board an affidavit stating that a revaluation notice for the current assessment year was not received by the taxpayer at least fifteen calendar days prior to the deadline for filing the petition

for review of the assessor's determination of value, and the taxpayer can show proof that the value was

actually changed. The request to reconvene and the affidavit must be filed with the board by April 30th of

the tax year immediately following the board's regularly convened session. For additional information about

appealing an assessor's determination of value to the board, refer to chapter 458-14 WAC. (4) Who is entitled to receive a revaluation notice? RCW 84.40.045 requires the assessor to mail

revaluation notices to the taxpayer. For purposes of this rule, "taxpayer" means the person charged, or whose

property is charged, with property tax and whose name appears on the most recent tax roll or has been

otherwise provided to the assessor. If any taxpayer, as shown by the tax rolls, holds only a security interest under a mortgage, contract of

sale, or deed of trust in the real property that is the subject of the revaluation notice, the taxpayer is required

to supply, within thirty days of receiving a written request from the assessor, the name and address of the

person making payments under the mortgage, contract of sale, or deed of trust. The assessor must mail a

copy of the revaluation notice to the person making payments under the mortgage, contract of sale, or deed

of trust at the address provided by the taxpayer. A request from the assessor for this infonnation must be

made during the month of January. If the taxpayer willfully fails to comply with the assessor's request within

thirty days, the taxpayer is subject to a maximum civil penalty of five thousand dollars. The civil penalty is

Page 14

recoverable in an action by the county prosecutor and, when recovered, must be deposited in the county current expense fund.

(5) What information must a revaluation notice contain? A revaluation notice must contain: (a) The name and address of the taxpayer; (b) A description of the real property that is the subject of the revaluation notice; (c) The previous and new true and fair values, stating separately land and improvement values; (d) A statement that the assessed value is one hundred percent of the true and fair value; ( e) If the property is classified under chapter 84.34 RCW on the basis of its current use, the previous

and new current use value of the property, stating separately land and improvement values; (f) A statement informing taxpayers that if they would like to learn more about how their property

was valued for tax purposes and how their property taxes will be determined, they may obtain an information pamphlet describing the property tax system from the assessor's office free of charge;

(g) A statement that land used for farm and agricultural purposes, to preserve open space, or for the commercial growth and harvesting of forest crops may be eligible for assessment based on the land's current use rather than its highest and best use. This statement must also provide information on the method of making application and the availability of additional information on the current use classifications;

(h) A statement informing taxpayers they may be eligible to receive a property tax exemption if: (i) They own and live in a residence in the county, including a mobile home; (ii) Are now or will be sixty-one years of age by December 31st of the current year, are retired

because of a physical disability, or is a veteran of the armed forces of the United States entitled to and receiving compensation from the United States Department of Veterans Affairs at a total disability rating for a service-connected disability; and ,

(iii) Their combined disposable income is under the limits provided in RCW 84.36.381. Although not statutorily required, it is suggested that a revaluation notice contain a statement

informing taxpayers that if they are a senior citizen or a disabled person, or if they meet certain income requirements, they may be able to defer payment of their property taxes. This statement should also include how additional information about property tax deferrals for senior citizens, disabled persons, or persons with limited incomes may be obtained; and

(i) A brief statement of the procedure for appeal to the county board of equalization and the time, date, and meeting place of the board. The following language is suggested: "You may appeal either the true and fair value and/or current use assessed value to the county board of equalization. An appeal petition may be obtained from the board of equalization. Petitions for a hearing must be filed with the board of equalization on or before July 1st of the assessment year, or within (number of days) of the ·date of the revaluation notice, whichever is later. Petitions received after those dates will be denied on the grounds of not having been timely filed, unless a waiver for good cause as described in WAC 458-14-056, is granted. The board of equalization will convene on July 15th, or within fourteen days of certification of the county assessment rolls, whichever is later, in the (name of office) at (name of city or town), Washington, and will continue in session for a period not to exceed four weeks. The board of equalization is to review and equalize the assessments of the current year for taxes payable the following year."

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ATTACHMENT 9 -

r c

6/7/2021

Parcel Number: 35184.2620 Site Address: 601 W RIVERSIDE AVE Printer Friendly (SummaryPrint.aspx)

Owner/Taxpayer

Owner

Owner Name: REDSTONE SPOKANE I LLC Address: #2011-7495132ND ST, SURREY, BC, V3W 1JB

Taxpayer

Taxpayer Name: REDSTONE SPOKANE I LLC Address: #2011-7495 132ND ST, SURREY, BC, V3W 1JB

Photos

Site Address

Perce! Type

R

Site Address City De&c::ription

601 W SPOKANE 61 Service• RIVERSIDE AVE Flnence

Tax

Property Information

Data As Of: 617/2021 SCOUT Map (https://cp.spokaneoounty.org/SCOUT 1Map/?P1D=35184.2620)

Collapse All

0 (Default.aspx?PID=35184.2620)

0 {https:f/ep.spokanecounty.org/SCOUT/Map/?PID=35184.2620)

>

Year Tax Code Area Status

2021 0010 Active (https:llcp.spokanecounty.org/SCOUT/propertylnformation/TaxcodeArea.aspx? TCA=0010)

RES & ADD TO SPOKANE FALLS BLK 21 TOG WI BLK 8 RAILROAD ADD TO SPOKANE EXC N80FT LT 1

Appraisal Contact Appraiser (https://cp.spokanecounty.org/Assessor/ContactAssessors/ContactForm.aspx?P1D=35184.2620)

Parcel Nelghbomood Neighborhood Neighborhood Apprel11er Appraiser

Class Appraiser Code Name Dose Name Phone

61 95 646170 4617C General Office Amber 477-5916 Service (https://cp.spokanecounty.org/Asseasor/Contact.Assessors/Default.aspx?

P1D•35184.2620) Finance

Under Washington State Law (WAC 458-07•015 (https://apps.leg.wa.gov/wac/default.aspx?clte1:458·07•015)) The Assessor's office is required to make an exterior observation of all properties at least once every six years. This property Is scheduled for inspection between October 2026 and May of 2027.

Market Total Land Owelllng/Structure Current Use Land Personal Prop.

44,001,830 3,562,330 40,439,500 0 0

2021 44,121,130 44,121,130 3.562,330 40,558,800 0 0 ···-··--···--------·· ... , ... -.. ·-··-·····-··---·-···-"·•·>·>-••,.,.,,. ,.,_,,. __ ., __ .n_.,Y __ .,.,_,,.,.,,

cp.spokanecounty,org/SCOUT/propertyinformation/Summary.aspx 1/5

6/7/2021

Tax Year Taxable Market Total

42,067,990 2020

2019

2018

42,067,990

38,818,300

38,244,600

Parcel on Property

38,818,300

38,244,600

00.000863 (Summary.aspx?PID=00.000863)

00.001670 (Summary.aspx?PID=00.001670)

00.010606 (Sumrnary.aspx?PID=OQ.010606)

00.011735 (Summary.aspx?PID=00.011735)

00.016277 (Summary.aspx?PID"00.016277)

00.020448 (Summary.aspx?PID"00,020448)

00.024471 (Summary.aspx?PID=00.024471)

00.027237 (Summary.aspx?PID=00.027237)

00.028625 (Summary.aspx?PID,,00.028625)

00.031449 (Summary.aspx?PID=00.031449)

00.032447 (Summary.aspx?PI0=00.032447)

00.034097 (Summary.aspx?PID=OD.034097)

00.034109 (Summary.aspx?PID=00.034109)

70. 011794 (Surnmary.aspx?P1D=70.011794}

70.030206 (Summary.aspx?P1D=70.030206)

70.0317 45 (Summary.aspx?PID=70.0317 4 5)

70.065728 (Surnmary.aspx?P1D=70.06572B)

70.070496 (Sumrnary.aspx?P1D=70.070496)

70.252221 (Summary.aspx?PID=70.252221)

70.~52721 (Summary.aspx?P1D=70.252721)

70.277450 (Summary.aspx?PID=70.277450)

70.311055 (Summary.aspx?P1D=70.311055)

70. 341035 (Summary.aspx?P1D=70. 341036)

70.343148 {Summary.aspx?PID=70. 343148)

70.380630 (Summary.aspx?PID=70.380630)

70.410686 (Summary.aspx?PID=70.410686)

70.480366 (Summary.aspx?PID=70.480366}

70.493875 (Summary.aspx?P1D=70.493875)

Land

3,375,990

3,069,100

3,069,100

Alternate Parcel


Dwelling/Structure

38,692,000

Curl'llnt Use Land

0

0

0

35,749,200

35,175,500

Status Site Address

Inactive 601 W RIVERSIDE AVE


Inactive

Active

Active

Active

Active

Active

Active

Active

Active

601 W RIVERSIDE AVE

601 W RIVERSIDE AVE

510 W RIVERSIDE AVE

601 W RIVERSIDE AVE

601 W RIVERSIDE AVE

601 W RIVERSIDE AVE

601 W RIVERSIDE AVE

601 W RIVERSIDE AVE

Active 601 W RIVERSIDE AVE



Active 601 WRIVERSIDEAVE


Inactive 601 W RIVERSIDE AVE 1000

Active

Active

Active

601 W RIVERSIDE AVE

601 W RIVERSIDE AVE

601 W RIVERSIDE AVE

Inactive 601 W RIVERSIDE AVE 1660


Active

Active

601 W RIVERSIDE AVE

601 W RIVERSIDE AVE

Personal Prop.

0

0

0

City

SPOKANE

SPOKANE

SPOKANE

SPOKANE

SPOKANE

SPOKANE

SPOKANE

SPOKANE

SPOKANE

SPOKANE

SPOKANE

SPOKANE

SPOKANE

SPOKANE

SPOKANE

SPOKANE

SPOKANE

SPOKANE

SPOKANE

SPOKANE

SPOKANE

SPOKANE

SPOKANE

Apartment

1000

1660

·- ... ~-- ·- , .. ,,,., .~.--- • -~·e•,•µ .. ,~.-~--·•"·--,-s-, .. - ~·•------·--·--·•·--,.-,.,~-·--••,,,-,,-

Active 601 W RIVERSIDE AVE SPOKANE

Inactive 601 W RIVERSIDE AVE SPOKANE . '' ....... "~ ........ ~

Inactive 601 W RIVERSIDE AVE 1970 SPOKANE 1970

Inactive 601 W RIVERSIDE AVE SPOKANE

Property Taxes I (https:/lwww.spokanecounty.org/Treasurerl):5! (Notices.asp,:)$ (https://www.invoicecloud.com/Spokanecounty)

Taxes are due April 30!11 and October 31st Total Charges Owing: $261,514.35

cp.spokanecounty.org/SCOUT/propertyinformation/Summary.aspx 2/5

6/7/2021

Levy Name,

State School

Stale School Levy 2

Totals:

I

Spokaoo Geneml SD081 Spoktlne B&J

Stale School

SD081 Spokane Genera County G8oolal

State School Levy 2 Spok1111&EMS

Spokane General Sooior Uft Spokane Bond New

Spokene Bond County General Conll Futures

--· --· ---• 0.00

Levy Rate 2020

1.8394

0.9901

12.30

1.00


Levy Rate 2021

1.8354

0.9878

11.85

2.00

Levy Type

Non-Voted

Non-Voled

3.00

Tax ID

0010

0010

Characteristics (https://cp.spokanecounty.orgtAssessor/ContactAssessors/ContactForm.aspx?PID=35184.2620)

Description

Office

Parking Garage

Commercial Details

Description

All Extensions

Office

Appraiser

95

95

Year Built

1981

1980

Year Remodeled

Area

589,950

Number of Floors

21

9

356,090

233,860 -----·---··-"'-

Parking Garage

Land Numb&r

Sales

Sale Date Sale Price

Soll ID

COiO

Sale Instrument

Acreage

0,73

Excise Number

Sq Ft

54,805

Frontage

0

Depth

181

12114/2018 47,740,000.00 Special Warranty Deed 201819530 (lmageExclse.aspx?ExclsaNumber=201819530&Parce1=35184.2620)

02/08/2007 36,000,000.00 Special Warranty Deed 200701954 (lmageExclse.aspx'?ExciseNumbar=200101954&parcel=35184.2620)

06/30/2003 0.00 Special Warranty Deed 200320803 (lmageExclse.aspx?ExclseNumber-200320803&Parcel=35184.2620) '·"·~··-·---.-------

06/18/2003 40,826,705.00 Special Warranty Deed 200312672 (lmageExcise.aspx?ExclseNumber-200312672&Parcel=35184.2620)

Recorded Documents

Lot(s)

0

Parcel

35184.2620

35184.2620

35184.2620

35184.2620

To view recorded documents related to this parcel, please visit the Auditor's Recorded Documents Portal (https://recordlng.spokanecounty.org/recorder/web/)

cp.spokanecounty.org/SCOUT/propertylnformatlon/Summary.aspx 4/5

6/6/2021

Parcel Number: 35191.2506

Site Address: 601 W 1 ST AVE

Printer Friendly (SummaryPrlnt.aspJ<)

Owner!Taxpayer

Owner

Owner Name: WASHINGTON TRUST BANK

Address: 717 WSPRAGUEAVE, SPOKANE, WA, 99201

Taxpayer Name: WASHINGTON TRUST BANK

Address: 717 W SPRAGUE AVE, SPOKANE, WA, 99201

Site Address

Parcel Type

R

Site Address

601 W 1ST

AVE

City Description

SPOKANE 61 SeNice •

Finance

Tax Vear

2021


Data As Of: 6/6/2021

SCOUT Map (https://cp.spokanerounty.org/SCOUT/Map/?PID=35191.2506)

Collapse All

0 (Default.aspx?PID=35191.2506)

Q (https:1/cp.spokanecou nty.org/SCOUT/Map/?PID=35191.2506)

Tax Code Area

0010

(https://cp.spokanecounty.org/SCOUT/properlyinformallon/TaxCodeArea.aspx?

TCA=0010)

Status

Active

RAILROAD ADD PTN OF LTS 1 -3 BLK 14 OAF: BEG AT NWCOR OF LT 1 TH ELY TO NE COR OF LT 3 TH SLY93.14FT TH WLY 177.88FTTH NLY 92.48FT TO

POB

Appraisal Contact Appraiser (https://cp.spokanecounty.org/Assessor/ContactAssessors/Contactform.aspx?PID=35191,2506)

Parcel Neighborhood Neighborhood Neighborhood Appraiser Appraiser

Class Appraiser Code Name Desc Name Phone

61 95 546170 4617C General Office Amber 477-5916

Service (https://cp.spokanecounty.org/Assessor/ContactAssessors/Default.aspx?

PID=35191. 2506)

Finance

Under Washington State Law (WAC 458-07-015 (hltps://apps.leg.wa.gov/wac/default.aspx?cite=458-07-015)) The Assessor's office Is required to make an exterior

observation of all properties at least once every six years. This property is scheduled for inspection between October 2023 and May of 2024.

Tax Year

2022

2021

Taxable

20,936.100

20,936,080

Market Total

20,936,100

20,936,080

Land

660,500

660.480

cp.spokanecounty.org/SCOUT/propertyinformation/Summary.aspx

Dwelling/Structure

20,275,600

20,275,600

Current Use Land

0

0

Personal Prop.

0

0

1/5

616/2021 PARCEL 35191,2506

Tax Year Taxable Market Total

2020 19,692,680 19,692,680

2019 21,042,200 21,042,200

2018 19,885,700 19,885,700

Parcel on Property

00.031122 (Summary.aspx?PID=OQ.031122)

00.033008 (Summary.aspx?PID=00.033008)


Land Dwelling/Structure

653,880 19,038,800

825,600 20,216,600

826,700 19,059,000

Alternate Parcel Status

Active

Active

Current Use Land

0

0

0

Site Address

601 W 1ST AVE

601 W 1ST AVE

Personal Prop,

0 ·······--·------····-····---·-

0

0

City

SPOKANE

SPOKANE

········-··-··-······--········ .

Apartment

Property Taxes I (https://www.spokanecounty.org/Treasurerl):5 (Notices.aspx) $ (https:l/www.invoicecloud.com/Spokanecountyl

Taxes are due April 30th and October 31st

Total Charges Owing: $124,095.22

Tax Year

2021

2021

2021

2020

2020

2020

2019

2019

2019

2018

2018

2018

Tax Receipts

Tax Year

2021

2020 ·--·····---···-----

2020

2019

2019 ····------·-·---·····-·-

2018

2018

Charge Type

Total Taxes for 2021

AN Property Tax

Soil Conservation Principal CNSV1

Weed Control Principal WCWEED1


AN Property Tax




AN Property Tax



Total Taxes for 201 B

AN Property Tax



Receipt Number

8704997

8509035

8310522

8054722

7924619 ·······-·---·····-····---

7644420

7464248

.... ·······--~···-···

cp.spokanecounty.org/SCOUT/propertyinformation/Summary.aspx

Annual Charges

248,190.44

248,178.60

10.04

1.80

242,296.28

242,284.44

10.04

1.80

250,974.08

250,967.24

5.04

1.80

276,270.83

276,025.68

180.35

64.80

Receipt Date

05/1312021

11106/2020

04/25/2020

10/28/2019

04/22/2019 . ·······-·· ·······----·

10/12/2018

04/16/2018

Remaining Charges Owing

124,095.22

124,089.30

5.02

0.90

0.00

0.00

0.00

0.00

o.oo

0.00

0.00

0.00

0.00

0.00

0.00

0.00

Receipt Amount

124,095.22

121,148.14

121,148.14

125,487.04

125,487.04

138,135.42

5,048.40

2/5

6/6/2021

PARCEL 35191.2506 Levy Name Levy Rate 2020

County General 1.1653

County General Cons Futures o.0391

SDOB1 Spokane B&I 2.5912

SDOB1 Spokane General 1.6042

Spokane Bond o. 1535

Spokane Bond New 0.2763

Spokane EMS

Spokane General

Spokane General Senior Lift

Slate School

State School Levy 2

Totals:

Spolame Gene11ll

SD081 Spokane 88.1

State Sc SD08 I Spok6lle

Counly General

0.4226

2.9215

0.3000

1.8394

0.9901

12.30


Levy Rate 2021

1.0751

0.0359

2.6569

1.5481

0.1373 "-""''""'''''''n,,,, ..

0.2584

0.3855

2.6606

0.2731

1.8354

0.9878

11.85

Stele School Levy 2 Spokane EMS

Spokooe Gaooml Senior Lift Spolmne Bond New.'

Spolrnne Bond - i

County Geoernl Coos Futures 41 l--"---'-..l.---'--·l---'--.L..._.,______.__1--.......... -i...........,,.J.............l--!

1.00 2.00 3:CJO 0.00 Dollars pe1 tbousal1d cl Asse.ued Value

Levy Type Tal(IO

Non-Voted 0010

Non-Voted 0010

Voted 0010

Voted 0010

Voted 0010

Voted 0010 ·-. ··------·-···--·

Non-Voted 0010

Non-Voted 0010

Non-Voted 0010

Non-Voted 0010

Non-Voted 0010

Characteristics (https://cp.spokanecounty.org/Assessor/ContactAssessors/ContactFortn.aspx?PID=35191.2506)

Description Appraiser Year Built Year Remodeled Number of Floors

Office 95 1981 2005 19

Commercial Details

Description Area

All Extensions 256,412 ···········---...... -··········--··--···-····

Office 256,412 .. ----··-----·-·

Land Number Soll ID Acreage Sq Ft Frontage Depth Lot(s)

1 C020 0.38 16,512 0 0

Sales

Sale Date Sale Price Sale Instrument Excise Number Parcel

·-? 04/18/2019 24,000,000.00 Statutory Warranty Deed 201904 703 (lmageEJ<clse.aspx?ExctseNumber=201904703&Parcel=35191.2506) 35191.2506

cp.spokanecounty.org/SCOUT/propertyinformation/Summary.aspx 4/5