Maas Complaint

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

GYONGYI MAAS, and MICHAEL MAAS, a married couple,

Plaintiffs, v.

KING COUNTY, a county corporation; MARYANNE HUNZIKER and JOHN DOE HUNZIKER and the marital community comprised thereof; DANIELLE M. PULLIAM and JOHN DOE PULLIAM and the marital community comprised thereof; SKYLAR K. GRIFFIN and JANE DOE GRIFFIN and the marital community comprised thereof, Defendants.

NO. COMPLAINT FOR DAMAGES

Plaintiffs make the following claims and allegations:

I. PARTIES

1.1 Plaintiff GYONGYI MAAS is a married woman, wife to Plaintiff MICHAEL MAAS and at the time of the dog attack giving rise to these claims, both resided in King County, Washington. Gyongyi Maas and Michael Maas were married at the time of the dog attack that forms the basis of this complaint.

1.2 Defendant KING COUNTY is a county corporation organized under the laws of the State of Washington. It is responsible for code enforcement, law enforcement, and animal control operations within its boundaries. The Regional Animal Services of King County (RASKC) is a department of King County as is the King County Sheriff’s Officer (KCSO)

1.3 On February 22, 2022, Defendant MARYANNE HUNZIKER was the owner of the residential property located at 28905 45th Place South in Auburn, Washington. Defendant MARYANN HUNZIKER was also the keeper and/or harborer of the dogs that attacked Gyongyi Maas on this same date.

1.4 On February 22, 2022, Defendant DANIELLE M. PULLIAM was an owner, keeper, and harborer of the dogs that attacked Gyongyi Maas on this same date. At all relevant times Defendant DANIELLE M. PULLIAM resided in King County, Washington.

1.5 On February 22, 2022, Defendant SKYLAR K. GRIFFIN was an owner, keeper, and harborer of the dogs that attacked Gyongyi Maas on this same date. At all relevant times Defendant SKYLAR K. GRIFFIN resided in King County, Washington.

II. JURISDICTION AND VENUE

2.1 The Superior Court of King County, State of Washington, has subject matter jurisdiction over this action pursuant to RCW 2.08.010.

2.2 Jurisdiction is proper in the State of Washington pursuant to RCW 4.28.185.

2.3 On October 26, 2022, plaintiff Gyongyi Maas served a Claim for Damages upon Defendant King County. On December 26, 2022, plaintiff Michael Maas served a Claim for Damages upon Defendant King County. The County has not responded to either Claim for Damages. Copies of the Claims are attached as Exhibits A and B to this Complaint.

2.4 Venue is proper in King County, Washington pursuant to RCW 4.12.020.

III. FACTS

“Is another person going to get killed or critically wounded? What is it going to have to take to wake up and get these people out of this house?” – Neighbor Kristin Purvis.

3.1 On February 22, 2022, a nightmare unfolded on 45th Place South, a residential street in Lakeland North, (unincorporated Auburn, King County, Washington). While the event itself was sudden and violent, the event was a culmination of years of ignored problems surrounding a trashed and hazardous residential property in this neighborhood. For years, the residents of Lakeland North repeatedly implored King County to act to remove this nuisance and hazard from their neighborhood. Despite having knowledge of the hazards this property and its human and animal occupants repeatedly posed to the community, King County did too little, too late. It made promises it did not keep. Until a tragedy occurred, nearly killing an innocent woman, out on a jog in her neighborhood, in her new running shoes.

History of the Property:

3.1 The Hunziker residence (“subject property”) is located at 28905 45th Place South.

3.2 Starting as early as 2020 and likely earlier, families living near 28905 45th Place South complained about the condition of the subject property:

It was not properly maintained. It exuded a stench you could smell from the street. Access points to the home (both doors and windows) were damaged or missing. Garbage and broken-down vehicles piled up in the driveway and on the street nearby The house was not properly boarded up and the fencing around the yard was broken and unsecure allowing unrestricted access to and use of the subject property by trespassers and squatters and allowing animals kept on the subject property to leave the property and run at large.

3.3 The house was a known haven for squatters and vagrants. Drug and criminal activity were a regular occurrence, all of which were repeatedly reported to King County. Vicious dogs living on the property routinely escaped the subject property and ran at large, threatening and attempting to attack neighbors on their own property and in the public streets and sidewalks in the neighborhood, all of which were repeatedly reported to King County.

3.4 Although numerous squatters passed through the subject property, the residents at issue at the time of the February 22, 2022 incident were Defendants Danielle Pulliam and Skylar Griffin. Defendant Griffin has been described as a “caretaker” of the subject property. Both Pulliam and Griffin resided at the subject property on a regular basis and kept multiple vicious dogs on the subject property.

3.5 On May 20, 2021, the King County Department of Local Services, Permitting Division, finding the building to be a substandard dwelling, issued a Notice and Order to Defendant Hunziker ordering her to correct multiple code violations on the property or to vacate the residence by June 1, 2021, and maintain the residence closed to entry and occupancy until King County approved the building for occupancy again. King County also ordered Hunziker to remove all rubbish, salvage, and debris from the premises by June 1, 2021. King County determined that these violations posed “significant and immediate risks to public health and safety, and to the subject

property.” King County was aware and took the position that the hazards on the property were a result of “squatters unlawfully occupying the subject property.”

3.6 June 1, 2021, came and went. Hunziker did not remedy the condition of the subject property or access to the property to eliminate the “significant and immediate risks to public health and safety” caused by the squatters on the subject property.

3.7 On November 3, 2021, King County posted a Do Not Occupy notice on the subject property. The squatters continued to access and occupy the property and continued to pose significant and immediate risks and hazard to public health and safety. King County knew about the continued occupation of the property by the squatters. It also knew the condition of the subject property had worsened.

3.8 Because the subject property continued to pose significant and immediate risks to public health and safety, the neighborhood organized a block watch to attempt to address the issues on their own. They invited King County to participate. The first block watch meeting was scheduled to occur in the evening on February 22, 2022.

History of Complaints to Law Enforcement:

3.9 King County has a lengthy history of law enforcement contact and involvement with the subject property and its occupants, including Defendants Danielle Pulliam and Skylar Griffin.

3.10 On March 17, 2015, a burglary was reported to King County, involving the subject property. A responding King County Deputy wrote “Hunziker’s house has been vacant for several years. It has become well known to the transient community (as far away as Portland, OR) as a place to sleep.”

3.11 Starting around May 2020, neighbors sent multiple text messages to King County Sheriff’s Deputies, who had provided their contact number to neighbors, reporting suspicious people and vehicle around the subject property.

3.12 On November 24, 2020, Defendant Skylar Griffin was arrested for an outstanding felony warrant when King County Sheriff’s Deputies responded to a vicious dog complaint at the subject property.

3.13 On April 14, 2021, Defendant Skylar Griffin was arrested at the subject property after a six-hour standoff with SWAT.

3.14 On June 17, 2021, King County Sheriff’s Office responded to a report of a loud verbal argument between a male and a female inside the resident on the subject property

3.15 On June 29, 2021, King County Sheriff’s Office received a call from Defendant Pulliam that she was having an argument with Defendant Griffin and was worried he would “come after” her.

3.16 On July 15, 2021, a stolen utility trailer was recovered from the driveway of the subject property. It does not appear from the documents that arrests were made.

3.17 On September 16, 2021, King County Sheriff’s Office responded to a noise complaint at the subject property, reporting that an “illegal squatter living at location” was playing loud music for over an hour.

3.18 On November 30, 2021, King County sent deputies to the subject property following a citizen call concerning the residence.

3.19 King County had notice of repeated criminal activity, trespass, and civil disturbances often involving Defendants Pulliam and Griffin, and involving potentially other unidentified individuals, at the subject property.

History of Animal Control Complaints:

3.20 On March 21, 2019, Kent Police Department responded to a suspicious vehicle call and found Defendants Skylar Griffin and Danielle Pulliam sleeping in a stolen vehicle in a parking lot. Buddy, a black pit bull or mix, was also present with the Defendants. King County Animal Control responded and was on scene for this call. Buddy acted aggressively toward officers on the scene and can be observed growling and lunging at first responders.

3.21 On November 24, 2020, King County responded to an animal control complaint involving dogs Sebastien (described as a shepherd-pit bull mix), Sammy (described as a German Shepherd or mix), and Buddy (described as a black pit bull or mix) Two of the dogs were running at large and aggressively charging neighbors, who contacted animal control. King County issued citations for animals running at large, vicious animals, animals running in packs, and unlicensed animals. King County also issued a Notice and Order for Confinement, requiring that the dogs be kept contained on the subject property. The dogs were not impounded.

3.22 Video from King County shows two of the dogs, freely moving in and out of the residence on the subject property on November 24, 2020.

3.23 On or about April 14, 2021, the black pit bull Buddy was tased by King County Sheriff’s deputies, who had entered the subject property to execute on a warrant against Defendant Skylar Griffin. Buddy attempted to jump through a broken window and attack the deputies. The dog was impounded, but then returned to Defendants Danielle Pulliam and Skylar Griffin at the subject property.

3.24 On or about April 14, 2021, King County received another report of “two very aggressive “German Shepherd” type dogs loose and chasing people in the street after the warrant was served” the night prior. A neighbor sent King County a video of the aggressive dogs, but again the dogs were not impounded.

3.25 On or about June 25, 2021, King County received another report that Sammy the German Shepherd was loose again. The dog was not impounded.

3.26 On June 28, 2021, King County received another report that Sammy and Sebastien were loose, running in a pack, and exhibiting viciousness toward neighbors. The dogs were not impounded.

3.27 On June 29, 2021, King County issued a notice and order for removal of both Sammy and Sebastien, requiring that the dogs be removed from King County within 48 hours of the notice, proof to be submitted to King County verifying the residence of the new owner outside of King County, and that the dogs be microchipped for identification. The dogs were not impounded.

3.28 On July 4, 2021, the dogs were reported running at large again. Defendants Pulliam and Griffin were again cited for violations of animal control laws. The dogs were not impounded.

3.29 On August 23, 2021, the dogs were again reported running at large, and had approached neighbors walking their dog; the dogs were barking, snarling, and baring their teeth. Pulliam and Griffin were cited for more animal control violations. The animal control officer responding to the report finally impounded both dogs and their six puppies after the dogs charged the officer as well.

3.30 On August 30, 2021, the King County Hearing Examiner ruled that “at no point will the dogs [Sammy and Sebastien] be allowed back in King County, upholding the June 29 notice and order of removal. The Examiner noted that King County must take specific steps to verify the dogs were permanently removed from the county and verify “the new living situation is not simply a set up for more failure.”

3.31 King County released the dog Sebastien to Danielle Pulliam The dog was supposedly to be removed to Oregon. On September 11, 2021, King County noted it had “phone authorization” for transfer of custody to Angela Pulliam. No address of the transfer location is contained in the records. There is no record that Sebastien was microchipped before he was released from King County’s custody. On September 15, 2021, King County reportedly spoke to Angela Pulliam, who stated “she hasn’t heard from Danielle.”

3.32 King County made express assurances to neighbors that the vicious dogs were removed from the subject property permanently and would no longer pose a threat in the neighborhood.

3.33 King County had notice and was very aware of the continued presence of vicious dogs on the subject property dogs that “repeatedly attacked innocent persons in vicinity of the subject property, constituting a nuisance under KCC 11.04.230.”

3.34 Prior to February 22, 2022, Sebastien was brought back into King County, and was living in the subject residence prior to and at the time of the February 22, 2022, dog attack.

3.35 Contrary to King County’s public statements following the dog attack, Sebastien was one of the two dogs involved in the attack.

3.36 King County officials removing the second dog from the subject property on February 22, 2022 after the attack:

3.37 On January 23, 2022, officers were dispatched to an assault that occurred on the subject property. A woman named Mandy punched the victim in the face several times and accused her of sleeping with Defendant Griffin. Mandy also had the black pit bull or pit bull mix “Buddy” attack the victim. The investigation went pending after the victim told officers she was fearful of the repercussions of assisting in prosecution. No follow up has occurred to date.

3.38 The dog Buddy was not permanently removed from the property or confiscated on January 23, 2022, or at any time prior to the February 22, 2022, mauling.

3.39 As of February 22, 2022, the squatters Danielle Pulliam and Skylar Griffin had

amassed over $11,000 in unpaid citations for their repeated violations of King County’s animal control ordinances, involving the above-identified dogs. King County failed to enforce payment of the outstanding citations it had issued Defendants Pulliam and Griffin simply continued to rack up penalties and citations while their dogs menaced the neighborhood.

February 22, 2022 Dog Mauling:

3.40 On February 22, 2022, Gyongyi Maas left her home for a jog around her neighborhood. She was just getting back into her jogging routine, having focused on raising her young children for the few years prior. Her husband Michael Maas had surprised her with a new pair of running shoes to support her new goals. She was also looking forward to returning to the workforce now that her children were in school.

3.41 Ms. Maas left her home and jogged along S 288th Street, past Thomas Jefferson High School. She then turned right onto 45th Place South.

3.42 Ms. Maas jogged on the side of the road opposite 28905 45th Place South. As she approached the subject property around 11:15 am, two large dogs ran out from the property, crossed the street, and started viciously attacking her in the street.

3.43 The dogs almost immediately dragged Ms. Maas to the ground. They bit her legs, torso, arms, head, and face. They broke the bones in her arm. The ripped flesh from her leg. They ripped the hair from her head. They ripped off her pants and shirt.

3.44 Terrified neighbors emerged from their homes near the subject property and saw the dogs attacking Ms. Maas and dragging her through the street. They attempted to assist Ms. Maas. One of the two attacking dogs turned on a neighbor and bit him. This neighbor retreated to his home, and returned with his vehicle, driving it as close to the dogs as possible, honking the horn. Their attempts to get the dogs to stop mauling Ms. Maas failed. The dogs did not relent.

3.45 The dogs then dragged her lifeless body like a ragdoll back toward the subject property. A neighbor’s ring camera captured some of the horror on video.

3.46 Around 11:20 am, multiple neighbors witnessing the attack called 911 for help.

3.47 King County Sheriff’s deputies arrived on scene at around 11:30 am. Deputy Roland Gervacio initially attempted to stop the attack verbally, as he could not safely shoot the dog when it was so near Ms. Maas’s body. Per Deputy Roland’s report, “I yelled for the dog to get away. The dog stopped biting the female for about a second and stood next to her. The dog then turn[ed] towards the female again and took another bite at the female’s head area. … I yelled for the dog to stop and the dog came charging toward me.” As the dog charged Deputy Gervacio, he shot it. The shot caused the second dog to run back to the subject property. The wounded dog did not die immediately and rose again to charge first responders and Ms. Maas’ body lying unresponsive in the street. Deputy Gary Berrien fired a second shot, killing the dog and finally ending the attack. The dead dog was identified as “Buddy,” the black pit bull.

3.48 While waiting for medical aid to arrive, Ms. Maas lay naked in the middle of the street, bleeding from multiple severe lacerations to her arms, legs, torso, and head. Broken bones were protruding from her forearm. It was February, and exposure to the elements caused hypothermia on top of the life-threatening injuries she endured from the dog attack.

3.49 Ms. Maas was transported by ambulance to the Harborview Medical Center in Seattle for emergency care.

3.50 Michael Maas was at work when he received an unexpected telephone call. The call was confusing and did not identify his wife by name. It was unclear to him at this point exactly what happened and whether it happened to his wife. Still the call was concerning enough that Mr. Maas left work and headed toward his home. On the way, he saw the sirens and emergency vehicles at the scene of the attack. He stopped and tried to get information. He was finally able to confirm that his wife had been involved in this horrific event, and that she was at Harborview. Mr. Maas immediately drove to Harborview, where he first saw his wife, disfigured, swollen, and covered in bandages. She could not speak to him. Mr. Maas has spent the last year of his life assisting his wife in her recovery and medical treatments and taking the laboring oar with their young children and in the home.

3.51 Gyongyi Maas nearly lost her life. She underwent extensive surgical intervention and medical treatment and suffered life-threatening, widespread, and permanent injury. She has a significant future care plan that includes additional surgeries.

IV. CAUSES OF ACTION

A. CAUSES OF ACTION AGAINST KING COUNTY

4.1 Defendant King County knew or should have known that Defendants Pulliam and Griffin were illegally occupying the subject property, creating immediate and serious risk, hazard, and danger to the residents of King County.

4.2 King County had a duty of reasonable care to refrain from causing foreseeable harm by or through its interactions with Defendants Pulliam and Griffin and their vicious dogs and a duty to refrain from directly causing harm through its affirmative acts of misfeasance.

4.3 King County public officials and agents, including but not limited to officials and agents of the King County Sheriff’s Office and Regional Animal Care Services, failed to exercise reasonable care in their response to and interactions with the subject property and Defendant squatters Danielle Pulliam and Skyler Griffin and their vicious dogs, and acted in a way that negligently, willfully, and recklessly exposed community members, including Plaintiff Gyongyi Maas, to harm from the foreseeable conduct of third parties, specifically Defendant squatters Danielle Pulliam and Skylar Griffin and the vicious dogs they kept on the subject property.

4.4 King County’s actions demonstrate a failure to use even slight care.

4.5 Despite actual knowledge of the ongoing risk to community safety and hazards posed by the presence of squatters on the subject property, Defendant King County failed to act appropriately and within its authority to remove these known hazards from the subject property.

4.6 Defendant King County also had express statutory obligations to enforce ordinances regarding control of dangerous or potentially dangerous animals in King County, and to protect residents from said dangerous and vicious animals.

4.7 Defendant King County knew or should have known of the dangerous and vicious propensities and conduct of the dogs involved in the February 22, 2022, dog mauling.

4.8 Defendant King County was negligent in the supervision, classification, and control of dangerous or potentially dangerous dogs in King County and failed to establish and operate an efficient and effective animal control system. Defendant King County also failed to enforce its own ordinances regarding the control of dangerous or potentially dangerous dogs, and specifically

regarding the dogs that attacked plaintiff Gyongyi Maas on February 22, 2022.

4.9 Defendant King County knew or should have known that Defendants Pulliam and Griffin were harboring dangerous and vicious dogs, were unable to control and contain their dangerous and vicious dogs to avoid injury of King County citizens, and that the Defendants and their dogs threatened and continued to threaten the safety and lives of residents of King County. Yet King County failed to take proper and required action, according to its policies, local civil codes, and otherwise, to ensure vicious dogs owned or kept by Defendants Pulliam and Griffin were not a threat to the safety and lives of residents of King County.

4.10 King County made express assurances to neighbors regarding their actions to permanently remove the vicious dogs from the subject property.

4.11 King County public officials and agents knew of the continuing and inherently dangerous and hazardous condition of the subject property, were under a duty to correct the problems, and failed to meet this duty.

4.12 King County public officials and agents had actual knowledge of the continuing statutory and code violations on the subject property well before the dog mauling but failed to take proper corrective action and care commensurate with the risk involved, despite the duty to do so.

4.13 As a direct and proximate result of the fault and negligence of Defendant King County, Plaintiff Gyongyi Maas suffered severe bodily injury, pain and suffering both emotional and physical, mental anguish, disability, loss of enjoyment of life, medical expenses, lost earning capacity, and other damages. Plaintiff Gyongyi Maas has suffered permanent injuries and extensive future damages.

4.14 As a direct and proximate result of the fault and negligence of Defendant King County, Plaintiff Michael Maas has been deprived of the love, affection, services, and support of

his spouse, Gyongyi Maas.

B. CAUSE OF ACTION AGAINST DOG OWNERS: STRICT LIABILITY

4.15 Pursuant to RCW 16.08.030, as the owners of the dogs that mauled Gyongyi Maas, Defendants Danielle Pulliam and Skylar Griffin are strictly liable for the dog bite injuries inflicted upon Gyongyi Maas by their dogs.

4.16 Under Washington common law, because the dogs both had a known history of dangerous and vicious propensities, as the owners, keepers, and harborers of the dogs, Defendants Pulliam and Griffin are strictly liable for the dog bite injuries inflicted upon Plaintiff Gyongyi Maas.

4.17 As a result of the dog bite injuries inflicted by defendants’ dogs, plaintiff Gyongyi Maas suffered serious and permanent damages, consisting of both physical and emotional trauma

4.18 As a direct and proximate result of the dog bite injuries inflicted by defendants’ dogs, Plaintiff Michael Maas has been deprived of the love, affection, services, and support of his spouse, Gyongyi Maas.

C. CAUSE OF ACTION AGAINST DOG OWNERS: NEGLIGENCE

4.19 Defendants Pulliam and Griffin owed a duty of reasonable care regarding the care, supervision, management, and conduct of their vicious dogs.

4.20 Defendants Pulliam and Griffin were negligent in the care, supervision, and management of their vicious dogs. As a result, the dogs attacked and severely injured Gyongyi Maas in a public roadway.

4.21 Defendants’ negligence was a proximate cause of Plaintiffs’ damages.

D. CAUSE OF ACTION AGAINST DOG OWNERS: NUISANCE

4.22 According to King County Code 11.04.180 all violations of Chapter 11.04 (Animal Control) are detrimental to the public health, safety, and welfare and are public nuisances.

Specifically, nuisances regarding animals identified in King County Code include, nonexclusively: allowing a dog to run at large within the county; any domesticated animal that habitually snaps, growls, snarls, jumps upon, or otherwise threatens persons lawfully using the public sidewalks, streets, alleys or other public ways; any vicious animal or animal with vicious propensities that runs at large at any time; any domesticated animal that enters upon a person’s property without permission of that person; and animals on any public property not under control by the owner or other competent person.

4.23 Defendants Danielle Pulliam and Skylar Griffin, having allowed their vicious dogs to run at large on public property and private property without permission, have interfered with the free use and comfortable enjoyment of the life and property of their neighbors and community members, and have created an actionable nuisance.

E. CAUSE OF ACTION AGAINST PROPERTY OWNER MARYANNE HUNZIKER: NEGLIGENCE

4.24 As the legal owner of the subject property, Defendant Maryanne Hunziker was negligent in her failure to properly secure and maintain her property to be free of known and expected hazards, including the presence of the squatters and their vicious dogs on her property.

4.25 Defendant Maryanne Hunziker had the legal duty to keep her property in a condition that complied with local building and safety codes.

4.26 Having allowed her property to reach and maintain a condition that violated multiple building and safety codes, Defendant Maryanne Hunziker had the legal duty to comply with King County notices to remedy the condition of the property or secure the property until approved for occupancy by the county.

4.27 As the legal owner of the subject property, Maryann Hunziker was a keeper or harborer of the vicious dogs residing on her property that attacked Plaintiff Gyongyi Maas on

February 22, 2022.

4.28 Defendant Hunziker’s negligence in failing to meet her duties as described above was a proximate cause of Plaintiffs’ damages.

F. CAUSE OF ACTION AGAINST PROPERTY OWNER MARYANN HUNZIKER: NUISANCE

4.29 Pursuant to King County Code 23.02.030, “all civil code violations are hereby determined to be detrimental to the public health, safety and environment and are hereby declared public nuisances.”

4.30 Defendant Maryanne Hunziker, having allowed the subject property to exist in a hazardous and substandard condition, and having allowed the property to remain unsecured and become inhabited by squatters and their vicious dogs, in violation of multiple civil codes, interfered with the free use and comfortable enjoyment of the life and property of her neighbors and community members, and has created an actionable nuisance.

V. DEFENDANTS ARE JOINTLY AND SEVERALLY LIABILE FOR THE PLAINTIFFS’ DAMAGES

5.1 The negligence and/or fault of each and every defendant was a proximate cause of Plaintiff Gyongyi Maas’s injuries.

5.2 Each defendant is jointly and severally liable for the damages of Plaintiffs

Gyongyi and Michael Maas, caused by their collective negligence and/or fault.

VI. PLAINTIFF GYONGYI MAAS IS NOT A PARTY AT FAULT

6.1 Plaintiff Gyongyi Maas bears no legal fault or contributory negligence for the February 22, 2022 dog mauling

6.2 Ms. Maas was lawfully on a public roadway at the time of the dog mauling

6.3 Ms. Maas did not provoke either dog to maul, attack, or bite her

VII. PRAYER FOR RELIEF

7.1 Plaintiffs Gyongyi Maas and Michael Maas pray for judgment against Defendants King County, Maryanne Hunziker, Danielle Pulliam, and Skylar Griffin collectively and jointly and severally, as follows:

1. For general damages, both past and future, in a reasonable amount to be proven at the time of trial;

2. For such special damages, both past and future, as Plaintiffs are able to prove at the time of trial, including but not limited to lost wages, lost earning capacity, medical expenses, and other out of pocket expenses;

3. For Plaintiffs’ costs and disbursements herein, to be taxed according to law; and

4. For such other and further relief as the Court may deem just and equitable in the premises.

DATED this 16th day of March, 2023

STRITMATTER KESSLER KOEHLER MOORE

s/ Gemma Zanowski

Gemma Zanowski, WSBA #43259

A. Melanie Nguyen, WSBA #51724

Co-counsel for Plaintiffs

3600 15th Ave West, Suite 300

Seattle, WA 98119

Telephone: 206.448.1777

Fax: 206.728.2131

Email: Gemma@stritmatter.com

Melanie@stritmatter.com

LAW OFFICES OF ANTHONY ALFIERI

s/ Anthony Alfieri

Anthony Alfieri, WSBA #24036

Co-counsel for Plaintiffs

13220 NE 80th St

Redmond, WA 98052

Telephone: 425-497-8000

Fax: 425-497-8066

Email: Tony@alfierilawoffice.com

EXHIBIT A

Instructions

Claim for Damages

Complete bothsides of this form. Give specific details about your damage or loss. Include witnesses and supporting documents.

Department of Executive Services

Office of Risk Management Services

Phone: 206-263-2250

TTY: 800-833-6388

8:30am - 4:30pm

Monday – Friday

Be sure to sign your completed claim form.

You may submit your completed claim form either of these ways: Emailyoursigned,completedclaimformto fileaclaim@kingcounty.gov

Mailordeliveryoursigned,completedclaimformto: KingCountyOfficeofRiskManagementServices King ,Suite320 Seattle,WA98104

form.

Informationand documents you submit aresubject to public recordslaws. Do not send sensitive personal or medical recordswith your claim form. Our investigator will request your personal or medical recordsif needed.

kingcounty.gov/claims

The Office of Risk Management Services will investigateyour claim. Our investigation begins when we receive your claimform. Your investigator may request supporting documents. They will provide an email address where you can submit thesedocuments.

Your claim may result in one of three outcomes in which King County will:

1.Pay a sum of money.

2.Tender or transfer the claim to a different responsible party or entity.

3.Deny a claim whenthere is no evidence of King County liability.

If you have questions please call the Office of Risk Management Services at 206-263-2250.

Claimant information

Preferred language:________________________

Claimant name:____________________________________

Mailing address: Street address-City-State-ZIP

360015thAve.W.#300,Seattle,WA98119

gemma@stritmatter.com;melanie@stritmatter.com

Email address:_____________________________________

206-448-1777

Preferred phone:______________Alternate phone: ______________

Date of birth:____________

Are you represented byan attorney? Yes No

06/05/1984 ✔ GemmaZanowski

Attorney name:____________________________________

Mailing address: Street address-City-State-ZIP

360015thAve.W.#300,Seattle,WA98119

gemma@stritmatter.com

Email address: _____________________________________ Phone: ______________

206-448-1777

Incident information

Incident date:____________Incident time: ________ AM PM

Where did theincident occur?______________________________________________________

Name of street or road:__________________Nearest intersection:___________________

Describewhat happened(attachmorepages as needed).

Were you injured? Yes No

Describe any damage or injuries.

2870137thPl.St.Auburn,wa98001 Seeaddendum. Seeaddendum.

How was King County involved?____________________________________________________

Witnesses and othersinvolved:

Name-Phone/Email-How was this person involved?

Was your vehicle involved or damaged? Yes No

License plate: ____________ Make: ____________ Model: ____________ Year: ______

Owner name: ________________________

Insurance company: ________________________

Insurance policy number: ________________________

Insurance claimnumber: ________________________

Was a MetroTransit bus involved? Yes No

Route: ___________ Vehiclenumber: ___________ License plate: ____________

I was a: Bus passenger Driver of another vehicle Pedestrian Passenger in another vehicle Owner of another vehicle Bicyclist

I claim damages in the amount of $______________.

Seeaddendum. Seeaddendum. ✔ ✔ Seeaddendum.

I declare under penalty of perjury under the laws of the State of Washington that the foregoing is true and correct.

King County Claim for Damages Addendum

Please direct all contact through the claimant’s attorneys:

Gemma Zanowski (gemma@stritmatter.com)

Melanie Nguyen (melanie@stritmatter.com)

Stritmatter Kessler Koehler Moore

3600 15th Ave W #300

Seattle, WA 98119

Phone 206-448-1777

206-728-2131 Fax

Anthony Alfieri (ava@alfierilawoffice.com)

Law Office of Anthony V. Alfieri

13220 NE 80th St

Redmond, WA 98052

Phone: 425-497-8000

Fax: 425-497-8066

Summary of Claims:

On February 22, 2022, 38-year-old Gyongyi Maas was on a run in her neighborhood in unincorporated King County when she jogged past a home (address 28905 45th Place S, Auburn WA 98001) inhabited by squatters Skylar Griffin and his girlfriend Danielle Pulliam and their multiple vicious dogs. Prior to February 22, repeated law enforcement and animal control complaints had been made by neighbors regarding the property, the squatters, and their dogs. The property had previously been condemned as a nuisance by the county. And it was located within a quarter mile of a high school, in a school zone.

As Gyongyi jogged by the condemned home on February 22, two dogs, later identified as a “pit bull mix” and a “shepherd pit bull mix,” charged Gyongyi. The dogs dragged her down to the ground and then started dragging her back to the condemned property while viciously attacking her, biting her head, face, legs, and arms. Neighbors including Michelle Provan and “Roger” (two separate houses) observed the mauling. Part of the mauling is also captured on Michelle’s security camera footage. Neighbor Roger attempted to hit the attacking dogs with a metal bat until one of the dogs turned on him and bit him; he then retreated to his home, got into his vehicle, and attempted to end the attack by driving up to the attacking dogs and honking his horn. The dogs were unfazed and continued to maul Gyongyi, who now appeared lifeless.

The attack went on for several minutes while courageous neighbors attempted to help Gyongyi and distract the dogs by honking their car horns and hitting their fences with bats. These neighbors thought they were witnessing her gruesome death in front of their eyes Multiple 911 calls were made asking for immediate law enforcement help. King County Sheriff arrived on the scene minutes into the attack. An officer shot one of the attacking dogs. The dog then rose and attempted to attack again. The officer shot the dog dead this second time. The other dog fled back inside the condemned home.

Gyongyi was transported to Harborview Medical Center where she stayed six days in the ICU and then another week under regular hospital care. Her injuries are systemic and horrific. She has endured multiple surgeries and will need multiple additional surgeries to help restore function and form to her arms, legs, head, face, and torso. The fact that she survived the attack is miraculous. Gyongyi is mother to two young children and married to Michael Maas.

The condemned home is owned by Maryanne Hunziker. She did not occupy the home on February 22, 2022. But she knew about and allowed squatters to occupy the property. King County also knew about these squatters, due to the multiple complaints from the neighbors over the period between 2018 and the attack. Nevertheless, these squatters were not removed from the property. In May of 2021, King County issued an order to Ms. Hunziker, requiring her to correct multiple code violations on the property by June 1, 2021 or vacate and close the property to human habitation. The violations were not corrected, the property was not vacated, and the property remained out of compliance with the Civil Penalty Order on February 22, 2022. King County took no action to address the violations or enforce the Civil Penalty Order.

Dogs owned by Skylar Griffin and Michelle Pulliam (the squatters) were the subjects of longstanding and frequent complaints by neighbors to King County that the dogs were at large and aggressive King County repeatedly returned the dogs to the squatters and otherwise allowed multiple dogs to continue to reside illegally in the condemned home, endangering neighbors in the community, despite the dogs’ demonstrated pattern of vicious behavior and the complete ineptitude of the dogs’ owners to control or care for the dogs. By example:

• On November 24, 2020, neighbors called to report dogs circling a repair man and acting aggressively. The repair man had to defend himself with a hammer. The dogs were determined to be vicious and were subject to an order of confinement but were not impounded.

• On April 14, 2021, neighbors called animal control again to the property upon report that the squatters’ vicious dogs were again loose and again acting aggressively. These dogs were not impounded. A third dog was tased when it tried to jump through a broken window in the home, was impounded and then released back to the squatters.

• On June 25, 2021, neighbors again reported that a dog from the property was loose. A citation was issued but the dog was not impounded.

• June 28, 2021, neighbors again reported that vicious dogs from the property were loose in the neighborhood. The dogs were not impounded.

In response to these multiple complaints from neighbors, King County Animal Control issued multiple “vicious animal,” “failure to license,” and “dogs running at large” violations and monetary penalties for dogs on the property. However, the dogs continued to run at large, threatening people and animals in the neighborhood repeatedly. King County did not confiscate the dogs. Finally, on or about June 29, 2021, King County Animal Control ordered the vicious dogs to be removed from the county. After King County ordered the dogs removed:

• On July 2 and July 4, 2021, two more reports were made of the vicious dogs running at large in the neighborhood. The County issues more citations but did not impound the dogs.

• On August 23, 2021, two reports were made of the vicious dogs running at large in the neighborhood, aggressively approaching people. The dogs were impounded after the aggressively charged the animal control officer.

On August 30, 2021, a King County Hearing Examiner ordered that Sebastien (the pit bull shepherd mix) and another shepherd Sammy be removed permanently from King County.

On or about September 11, 2021, King County Animal Control allowed Danielle Pulliam to redeem the vicious dog Sebastien and did nothing to follow up to ensure compliance with the terms of the removal order, including that the dog was never to return to King County.

King County had a duty to ensure the permanent removal of both vicious dogs under K.C.C 11.04.290 and 11.04.230. King County also had a duty to properly implement and enforce the provisions of its county codes regarding these dogs and their problem owners It did not do so and as a result, the squatters’ vicious dogs mauled Gyongyi Maas on February 22, 2022.

Witnesses and others involved:

NAME

Michael Maas

c/o SKKM

3600 15th Avenue West, Suite 300

Seattle, WA 98119

206.448.1777

Skylar Griffin

Danielle Pulliam

4906 221st St. E.

Spanaway, WA 98387

206.293.9491

253.999.1643

Angela Pulliam

1900 Burns Street, #17

Klamath Falls, OR 97603

458.232.7636

Tara Mae

tara_mae_2007@hotmail.com

Case Wilkes

28910 45th Place South

caseylw287@gmail.com

KNOWLEDGE

Mr. Maas is Gyongi’s husband and a plaintiff in this case. He will testify to his personal knowledge of the impact Gyongi’s injuries have had on his life.

Mr. Griffin owns the dogs at issue and has personal knowledge of the dogs and the attack

Ms. Pulliam owns the dogs at issue and has personal knowledge of the dogs and the attack

Mrs. Pulliam is Danielle Pulliam’s mother and was the individual who allegedly took custody of the dog Sebastian after the order of removal was issued.

Ms. Mae is a neighbor of the at issue property and has personal knowledge of the dogs and property at issue in this case.

Mr. Wilkes is a neighbor of the at issue property and has personal knowledge of the dogs and property at issue in this case.

Kristin Purvis 206-351-5795

Ned and Michelle Provan

freezninak@gmail.com

330-827-9678

Tammy Reints 28919 45th Pl S

Auburn, Wa 206-375-0405

Scott Wylie 4229 S 303rd Street

Auburn, WA 98001

253-753-7235

Susan A. Crawford

Animal Control Call Center

Regional Animal Services of King County 21615 64th Ave S

Kent WA 98032

Direct: 206-296-7387 (option 2)

Steve Nickelson

206-263-5963

Steve.nickelson@kingcounty.gov

Tim Anderson

Lead Animal Control Sergeant

Regional Animal Services of King County

(206) 263-5939

Sergeant Eykel

Regional Animal Services of King County 21615 64th Ave S.

Kent, WA 98032

Andrew Skaar

Ms. Purvis is a neighbor of the at issue property and has personal knowledge of the dogs and property at issue in this case.

Mr. and Ms. Provan are neighbors of the at issue property and has personal knowledge of the dogs and property at issue in this case.

Ms. Reints is a neighbor of the at issue property and has personal knowledge of the dogs and property at issue in this case.

Mr. Wylie is a neighbor of the at issue property and has personal knowledge of the dogs and property at issue in this case.

Ms. Crawford is an employee of King County and has personal knowledge of the incident at issue and King County’s investigation.

Mr. Nickelson is an employee of King County and has personal knowledge of the incident at issue and King County’s investigation.

Mr. Anderson is an employee of King County and has personal knowledge of the incident at issue and King County’s investigation.

Aaron Siegrist

King County Animal Control 206-296-7387

Lauren Olson

King County Hearing Examiner’s Office

516 Third Avenue Room 1200

Seattle, WA 98104

Mailstop: KCC-CC-1210

206-477-0860

Mr. Skaar is a detective from the King County Sheriff’s office and has personal knowledge of the incident at issue and King County’s investigation.

Mr. Siegrist is an employee of King County and has personal knowledge of the incident at issue and King County’s investigation.

Ms. Olson is an employee of King County and has personal knowledge of the incident at issue and King County’s investigation.

Shelby Russell

Animal Control Officer

Regional Animal Services of King County

(206)258-0743

Gene Mueller, DVM, MPH

Manager, Regional Animal Services of King County

Records and Licensing Services Division

Department of Executive Services

21615 64th Ave. S.

Kent, WA 98032

206-296-7387

Anthony DeSanto

EMT-Paramedic – 1274

King County Medic One

20811 84th Ave. S. Suite 102

Kent, WA 98032

206-263-2200

Orson Gurney

EMT-Paramedic – 1254

King County Medic One

20811 84th Ave. S. Suite 102

Kent, WA 98032 206-263-2200

Paul Nordenger

EMT-Paramedic – 997

King County Medic One

20811 84th Ave. S. Suite 102

Kent, WA 98032

206-263-2200

Damages amount:

Ms. Russell is an employee of King County and has personal knowledge of the incident at issue and King County’s investigation.

Mr. Mueller is an employee of King County and has personal knowledge of the dogs at issue, King County’s investigation, and the 6/29/2021 Notice and Order for Removal.

Mr. DeSanto is a medic for King County and responded to the scene. He has personal knowledge of the incident and dogs at issue.

Mr. Gurney is a medic for King County and responded to the scene. He has personal knowledge of the incident and dogs at issue.

Mr. Nordenger is a medic for King County and responded to the scene. He has personal knowledge of the incident and dogs at issue.

Claimant Gyongyi Maas’s injuries and damages are ongoing. Investigation and discovery of the full nature and extent of her injuries and damages are ongoing. Ms. Maas has not yet determined the full amount of her special and general damages. Claimant’s spouse, Michael Maas has suffered a loss of consortium because of the devastating injuries suffered by his wife.

Gyongyi Maas’s special damages include, but are not limited to: lost wages, lost employment opportunities and earning capacity, and medical, mental health and other expenses, both past and future. Her current medical bills total over $480,848.

Gyongyi Maas’s general damages include but are not limited to past and future: physical injury, pain, disability, disfigurement, suffering, mental/emotional distress, humiliation, fear,

embarrassment, and inconvenience. She suffered permanent injury as a result of the mauling and will live with the consequences of this attack for the rest of her life.

The purpose underlying the statement of the amount of damages is to provide the government with notice of the type of relief sought. The statue is intended to give the government time to investigate, negotiate, and attempt to settle claims. As a prelude to litigation, the claim filing requirement of a damages statement is not intended to ask the impossible, and the requirement is not equivalent to a final request for relief. In this case, the exact amount of damages is uncertain at the time this notice is prepared. Because the number the claimant is able to provide will likely change as the case progresses, an accurate and complete description of the damages – instead of a number – will adequately supply the information and notice required by the claim filing statute.

The government has an entire department of attorneys who are experienced in the handling of tort cases. They have had many opportunities to assess, settle, and try such cases. Based upon the initial disclosure of information, the government can calculate an approximate base amount of the claim if it so chooses. Even though the government cannot know with certainty the total amount of damages the claimant will ultimately request, there is no reason for this uncertainty to impede its settlement plans. If, after evaluating the merits of this claim, the government decides to pursue settlement, the lack of a non-binding dollar figure will not dissuade the government from initiating such settlement talks.

EXHIBIT B

Instructions

Claim for Damages

Complete bothsides of this form. Give specific details about your damage or loss. Include witnesses and supporting documents.

Department of Executive Services

Office of Risk Management Services

Phone: 206-263-2250

TTY: 800-833-6388

8:30am - 4:30pm

Monday – Friday

Be sure to sign your completed claim form.

You may submit your completed claim form either of these ways: Emailyoursigned,completedclaimformto fileaclaim@kingcounty.gov

Mailordeliveryoursigned,completedclaimformto: KingCountyOfficeofRiskManagementServices King ,Suite320 Seattle,WA98104

form.

Informationand documents you submit aresubject to public recordslaws. Do not send sensitive personal or medical recordswith your claim form. Our investigator will request your personal or medical recordsif needed.

kingcounty.gov/claims

The Office of Risk Management Services will investigateyour claim. Our investigation begins when we receive your claimform. Your investigator may request supporting documents. They will provide an email address where you can submit thesedocuments.

Your claim may result in one of three outcomes in which King County will:

1.Pay a sum of money.

2.Tender or transfer the claim to a different responsible party or entity.

3.Deny a claim whenthere is no evidence of King County liability.

If you have questions please call the Office of Risk Management Services at 206-263-2250.

Claimant information

Preferred language:________________________

MichaelMaas

Claimant name:____________________________________

Mailing address: Street address-City-State-ZIP

360015thAve.W.#300,Seattle,WA98119

gemma@stritmatter.com;melanie@stritmatter.com

Email address:_____________________________________

Preferred phone:______________Alternate phone: ______________

Date of birth:____________

206-448-1777 10/11/1985 ✔

Are you represented byan attorney? Yes No

GemmaZanowski

Attorney name:____________________________________

Mailing address: Street address-City-State-ZIP

360015thAve.W.#300,Seattle,WA98119

gemma@stritmatter.com 206-448-1777

Email address: _____________________________________ Phone: ______________

Incident information

Incident date:____________Incident time: ________ AM PM

Where did theincident occur?______________________________________________________

Name of street or road:__________________Nearest intersection:___________________

Describewhat happened(attachmorepages as needed).

Were you injured? Yes No

Describe any damage or injuries.

2890545thPLS,Auburn,WA98001 Seeaddendum. Seeaddendum.

How was King County involved?____________________________________________________

Witnesses and othersinvolved:

Name-Phone/Email-How was this person involved?

Was your vehicle involved or damaged? Yes No

License plate: ____________ Make: ____________ Model: ____________ Year: ______

Owner name: ________________________

Insurance company: ________________________

Insurance policy number: ________________________

Insurance claimnumber: ________________________

Was a MetroTransit bus involved? Yes No

Route: ___________ Vehiclenumber: ___________ License plate: ____________

I was a: Bus passenger Driver of another vehicle Pedestrian Passenger in another vehicle Owner of another vehicle Bicyclist

I claim damages in the amount of $______________.

Seeaddendum. Seeaddendum. ✔ ✔ Seeaddendum.

I declare under penalty of perjury under the laws of the State of Washington that the foregoing is true and correct.

King County Claim for Damages Addendum

Please direct all contact through the claimant’s attorneys:

Gemma Zanowski (gemma@stritmatter.com)

Melanie Nguyen (melanie@stritmatter.com)

Stritmatter Kessler Koehler Moore

3600 15th Ave W #300

Seattle, WA 98119

Phone 206-448-1777

206-728-2131 Fax

Anthony Alfieri (ava@alfierilawoffice.com)

Law Office of Anthony V. Alfieri

13220 NE 80th St

Redmond, WA 98052

Phone: 425-497-8000

Fax: 425-497-8066

Summary of Claims:

Michael Maas formally makes a claim for loss of consortium, arising from the severe injuries his wife suffered in a near-fatal dog mauling on February 22, 2022. The underlying facts and circumstances that led to the attack are outlined in greater detail in Gyongyi Maas’s tort claim form, served on King County on October 27, 2022. But in summary: On February 22, 2022, 38year-old Gyongyi Maas was on a run in her neighborhood in unincorporated King County when she jogged past a home (address 28905 45th Place S, Auburn WA 98001) inhabited by squatters

Skylar Griffin and his girlfriend Danielle Pulliam and their multiple vicious dogs. Prior to February 22, repeated law enforcement and animal control complaints had been made by neighbors regarding the property, the squatters, and their dogs. The property had previously been condemned as a nuisance.

As Gyongyi jogged by the condemned home on February 22, two dogs charged Gyongyi. The dogs dragged her down to the ground and started dragging her back to the condemned property while viciously attacking her, biting her head, face, legs, and arms. Neighbors including Michelle Provan and “Roger” (two separate houses) observed the mauling. Neighbor Roger attempted to hit the attacking dogs with a metal bat until one of the dogs turned on him and bit him; he then retreated to his home, got into his vehicle, and attempted to end the attack by driving up to the attacking dogs and honking his horn. The dogs were unfazed and continued to maul Gyongyi, who now appeared lifeless. Law enforcement eventually arrived and shot one of the dogs to death. The other dog escaped back to the condemned property and was later seized by animal control.

Gyongyi was transported to Harborview Medical Center where she stayed six days in the ICU and then another week under regular hospital care. Her injuries are systemic and horrific. She has endured multiple surgeries and will need multiple additional surgeries to help restore function and form to her arms, legs, head, face, and torso. The fact that she survived the attack is miraculous. Gyongyi is mother to two young children and married to Claimant Michael Maas.

Witnesses and others involved:

NAME KNOWLEDGE

Michael Maas

Gyongyi Maas

c/o SKKM

3600 15th Avenue West, Suite 300 Seattle, WA 98119

206.448.1777

Skylar Griffin

Danielle Pulliam

4906 221st St. E. Spanaway, WA 98387

206.293.9491

253.999.1643

Angela Pulliam

1900 Burns Street, #17 Klamath Falls, OR 97603

458.232.7636

Tara Mae tara_mae_2007@hotmail.com

Case Wilkes 28910 45th Place South caseylw287@gmail.com

Kristin Purvis 206-351-5795

Ned and Michelle Provan freezninak@gmail.com 330-827-9678

Tammy Reints 28919 45th Pl S Auburn, Wa 206-375-0405

Scott Wylie 4229 S 303rd Street Auburn, WA 98001 253-753-7235

Susan A. Crawford Animal Control Call Center

Gyongyi Maas is the injured individual and Michael Maas is Gyongi’s husband has a claim based on his loss of consortium. He will testify to his personal knowledge of the impact Gyongyi’s injuries have had on Gyongyi, on his life, and on their lives together as a married couple.

Mr. Griffin owns the dogs at issue and has personal knowledge of the dogs and the attack

Ms. Pulliam owns the dogs at issue and has personal knowledge of the dogs and the attack

Mrs. Pulliam is Danielle Pulliam’s mother and was the individual who allegedly took custody of the dog Sebastian after the order of removal was issued.

Ms. Mae is a neighbor of the at issue property and has personal knowledge of the dogs and property at issue in this case.

Mr. Wilkes is a neighbor of the at issue property and has personal knowledge of the dogs and property at issue in this case.

Ms. Purvis is a neighbor of the at issue property and has personal knowledge of the dogs and property at issue in this case.

Mr. and Ms. Provan are neighbors of the at issue property and has personal knowledge of the dogs and property at issue in this case.

Ms. Reints is a neighbor of the at issue property and has personal knowledge of the dogs and property at issue in this case.

Mr. Wylie is a neighbor of the at issue property and has personal knowledge of the dogs and property at issue in this case.

Ms. Crawford is an employee of King County and has personal knowledge of the

Regional Animal Services of King County

21615 64th Ave S

Kent WA 98032

Direct: 206-296-7387 (option 2)

Steve Nickelson

206-263-5963

Steve.nickelson@kingcounty.gov

Tim Anderson

Lead Animal Control Sergeant

Regional Animal Services of King County (206) 263-5939

Sergeant Eykel

Regional Animal Services of King County

21615 64th Ave S.

Kent, WA 98032

Andrew Skaar

Aaron Siegrist

King County Animal Control

206-296-7387

Lauren Olson

King County Hearing Examiner’s Office

516 Third Avenue Room 1200

Seattle, WA 98104

Mailstop: KCC-CC-1210

206-477-0860

Shelby Russell

Animal Control Officer

Regional Animal Services of King County (206)258-0743

Gene Mueller, DVM, MPH

Manager, Regional Animal Services of King County

Records and Licensing Services Division

Department of Executive Services

21615 64th Ave. S.

Kent, WA 98032

206-296-7387

Anthony DeSanto

EMT-Paramedic – 1274

King County Medic One

20811 84th Ave. S. Suite 102

incident at issue and King County’s investigation.

Mr. Nickelson is an employee of King County and has personal knowledge of the incident at issue and King County’s investigation.

Mr. Anderson is an employee of King County and has personal knowledge of the incident at issue and King County’s investigation.

Sergean Eykel is an employee of King County and has personal knowledge of the incident at issue and King County’s investigation.

Mr. Skaar is a detective from the King County Sheriff’s office and has personal knowledge of the incident at issue and King County’s investigation.

Mr. Siegrist is an employee of King County and has personal knowledge of the incident at issue and King County’s investigation.

Ms. Olson is an employee of King County and has personal knowledge of the incident at issue and King County’s investigation.

Ms. Russell is an employee of King County and has personal knowledge of the incident at issue and King County’s investigation.

Mr. Mueller is an employee of King County and has personal knowledge of the dogs at issue, King County’s investigation, and the 6/29/2021 Notice and Order for Removal.

Mr. DeSanto is a medic for King County and responded to the scene. He has personal knowledge of the incident and dogs at issue.

Kent, WA 98032

206-263-2200

Orson Gurney

EMT-Paramedic – 1254

King County Medic One

20811 84th Ave. S. Suite 102

Kent, WA 98032

206-263-2200

Paul Nordenger

EMT-Paramedic – 997

King County Medic One 20811 84th Ave. S. Suite 102

Kent, WA 98032 206-263-2200

Damages amount:

Mr. Gurney is a medic for King County and responded to the scene. He has personal knowledge of the incident and dogs at issue.

Mr. Nordenger is a medic for King County and responded to the scene. He has personal knowledge of the incident and dogs at issue.

Claimant Michael Maas has suffered a loss of consortium because of the devastating and permanent injuries suffered by his wife. Claimant Michael Maas’ damages for loss of consortium are ongoing. Investigation and discovery of the full nature and extent of his damages are ongoing. Mr. Maas has not yet determined the full amount of his damages. However, Mr. Maas’s claims include the loss of spousal society, companionship, love and affection, emotional support, and aid/services provided by his spouse. Michael has taken leave from work to care for Gyongyi and their children. He has needed the aid of other family members as well. And he has been a primary source of support for his wife as she recovers from this harrowing attack.

The purpose underlying the statement of the amount of damages is to provide the government with notice of the type of relief sought. The statue is intended to give the government time to investigate, negotiate, and attempt to settle claims. As a prelude to litigation, the claim filing requirement of a damages statement is not intended to ask the impossible, and the requirement is not equivalent to a final request for relief. In this case, the exact amount of damages is uncertain at the time this notice is prepared. Because the number the claimant is able to provide will likely change as the case progresses, an accurate and complete description of the damages – instead of a number – will adequately supply the information and notice required by the claim filing statute.

The government has an entire department of attorneys who are experienced in the handling of tort cases. They have had many opportunities to assess, settle, and try such cases. Based upon the initial disclosure of information, the government can calculate an approximate base amount of the claim if it so chooses. Even though the government cannot know with certainty the total amount of damages the claimant will ultimately request, there is no reason for this uncertainty to impede its settlement plans. If, after evaluating the merits of this claim, the government decides to pursue settlement, the lack of a non-binding dollar figure will not dissuade the government from initiating such settlement talks.