10 a 12 13 4 a5 16 7 18 19 20 aa 2 23 24 25 26 27 28 copy Original Filed APR 20 2017 Timothy Wi ita . Fitgeroia SPOKAWE COUNTY CLERK SUPERIOR COURT, STATE OF WASHINGTON, COUNTY OF SPOKANE CITY OF SPOKANE, a municipal corporation, w 17201476. Plaintiff, Vv. AFFIDAVIT OF KEITH CLER LIDIA ARICH, individually and as Trustee of ITHE LYDIA ARICH FAMILY TRUST, property lowners of 548 E. Central, Spokane, Washington; JOHN KOVTUSCHENKO, party in possession of 548 E. Central, Spokane Washington; and DIANE D. HAGGLUND, a lien holder, Defendants. STATE OF WASHINGTON County of Spokane KEITH CLER, being first duly swom upon oath, deposes and says: 4. | state the following based upon my personal knowledge. ‘AFFIDAVIT OF KEITH CLER— PAGE 7 ‘Wichael J Piccolo, tari Cy Atorney (OFFICE OF THE CITY ATTORNEY. 3 Floor Municipal Bulging ‘spokane, WA. 99201-3328 (600) 625-6225 FAK (508) 625-027710 a 12 13 evs 15 16 7 18 19 20 an 22 23 24 25 26 2 2a 2. Lam over the age of eighteen, not a party to this lawsuit, and | am competent to testify to the matters set forth below. 3. lam employed by the Spokane Police Department and have been so employed since February 1994. 4. As a patrol officer, | have had extensive experience in the investigation of a wide variety of crimes including crimes associated with neighborhood disputes, nuisance locations and drug related investigations. 5. | am currently assigned as a Neighborhood Resource Officer (NRO) for the Nevawood area of Spokane. | was assigned to this position on January 10 2016. 6. My main function as an NRO Is to identify significant problem areas within my assigned geographic area. 548 E Central is within my assigned geograpic area. 7. For over a year, 548 E Central has been one of the main problem houses in my area. My attention was first drawn to 548 E Central when | began getting numerous police officer and neighborhood complaints regarding drug activity and other criminal activity at that address. 8 Property records show the home is owned by Lidia Arich at 3411 W Wellesley, Spokane. | spoke with Lidia Arich and she stated that her son, John Kovtuschenko lives at 548 E Central and he will inherit the house after her passing, but she is the current owner and tax payer. ‘AFFIDAVIT OF KEITH CLER- PAGE 2 Wichae! J, Piccolo, interim Gy Atorney ‘OFFICE OF THE CITY ATTORNEY $5 Floor Municipal Bulding ‘Spokane, WA 89201-3328 (500) 625-6225 AK (500) 625-027710 a 12 13 aa 15 16 28 as 20 2 22 23 24 25 26 ar 28 9. Areport of police calls for service for the dates between 1/1/15 to 4/12/17 revealed there have been 151 calls for service directly tied to and related to ithe address. See Exhibit 1, Calls for Service Log, attached hereto and incorporated herein as if fully set forth. This number does not take into account any calls made from neighbors not directly linked to the address and/or officer initiated contacts in the area that also weren't directly linked to the address. In addition, there have been le complaints of the ongoing nuisance activity at the address. See Exhibit 2, Neighborhood Nuisance Activity Logs, attached hereto and incorporated herein as if fully set forth. The following is evidence that 548 & Central is a drug and chronic nuisance: ‘« 15-381918 on 10/29/15, John Kovtuschenko called to report an assault between 2 people, David Donahoe & Kristopher Stump, staying at his house. Officer establish PC for 4” assault on Stump, who was later arrest the next day at 548 E Central. Kristopher Stump is a convicted felon and has a lengthy criminal record to include, Possession of a controlled substance, 2 degree possession of stolen property, Theff, vehicle prowling to name a few. David Donahoe is a convicted felon and has a criminal record of, Felony harassment, theft etc. © 2015-45191 on 12/24/15, complainant called in a Hit-and-Run; that a van that was parked behind 548 E Central backed into her fence and left without leaving any information. * 2016-00006057 on 1/6/16, Officers arrested Aeriel Menard and Tashan Highpine at 548 E Central for DOC warrants, ‘* 2016-00010799 on 1/10/16, John called police stating that 2 guest in his home were fighting, Paul Stihl and Alexandria Rouse. Radio was able determine that ‘AFFIDAVIT OF KEITH OLER — PAGE 3 ‘Wichael J. Piecoo, interim City Atorney ‘OFFICE OF THE CITY ATTORNEY 3 Floor Municipal Bulling ‘Spokane, WA, 99201-3228 (508) 625-6225 AX (500) 625.627710 a 12 33 a4 1s 16 uv 18 19 20 an 22 23 24 25 26 27 28 Rouse had warrants for his arrest. Patrol arrested him on his warrants and booked him into jail. © 2016-00032802 on 1/28/16, John called police to report transient friends are banging on his door. He believes they have drugs on them. Officers contacted the 2 suspects, Anthony Stine and Thomas Still. One of them had a warrant for their arrest and was booked into jail « 2016-00045230 on 2/7/16, Officer arrested Tashan Highpine for Stolen Vehicle, Warrant Arrest, Resisting arrest, Obstructing and Malicious Mischief at §48 E Central. Tashan Highpine is a convicted felon for Possession of a controlled substance and Robbery 2” he also has a criminal record of theft, burglary, stolen vehicle, assault and many more. As of 4/17/17, Highpine shows an active DOC escape warrant for his arrest. Paul E. Still was also contacted during this incident, at 548 E Central, where he told the officer(s) that he lived there. Paul Still is a convicted felon who has past arrests for possession of a controlled substance, theft, and criminal trespassing to name a few. It should be noted that Paul Stil was just recently arrested on 4/15/17 (2017-20068190) on 2 felony warrants, burglary 2nd and a DOC escape warrant. During that arrest he was charged with a new charge of resisting arrest. © 2016-00048127 on 2/9/16, patrol had information that Michael L. Pierce was Staying at 548 E Central and had a warrant for his arrest. He was located there and arrest for an 4" Assault DV warrant. © 2016-00059034 on 2/18/16 Served Lidia Arich a Chronic Nuisance Notice ‘She was given an extra copy of the chronic nuisance to give to John, which | later confirmed he got when | serve him the below chronic nuisance abatement agreement, 2016-00059034. John told me that he got the copy from his mother. See Exhibit 3, SPD incident no. 16-00059034, attached hereto and incorporated herein as if fully set forth * 2016-00059034 on 3/1/16 Lidia Arich & John Kovtuchenko both entered into a Chronic Nuisance Abetment Agreement, both signing the agreement. When served them with the abetment agreement I read it to them and explained to them both that if the agreement was not followed it could result with the city of Spokane taking them to court to abate and board up their house. They both said they understood. See Exhibit 4, SPD incident no. 16-00059034, attached hereto and incorporated herein as if fully set forth. ‘AFFIDAVIT OF KEITH CLER — PAGE 4 ichael J. Piccolo, interim Gity Atorney ‘OFFICE OF THE CITY ATTORNEY. ‘8° Floor Munleipal Bullding ‘Spokane, WA 99201-3326 (soo) 625.6225 AX (808) 625-627710 a a 13 1 15, 16 v 18 19 20 2a 22 23 24 25 26 27 28 2016-00104710 on 3/25/16, officers had probable cause for 1st-degree robbery DV and attempted to contact John at his residence at 548 E. Central twice. His car was in the back but they did not see or hear any signs of someone inside. The neighbors all stated that if his car was there he would be there. 2016-00151859 on 4/29/16, officers arrested John at his residence for city malicious mischief-DV for breaking his mother's window that had a estimated damage of the $750. He was given a criminal citation #620549729 2016-00271224, on 7/23/16, officers arrested John at his residence for, Felony DV protection order violation (16-1-024422-1), DV assault, 1st Burglary, interfering with the reporting of a DV, 2nd Robbery, and DWLS 3rd. 2016-20014539 on 10/25/16, there was a call for service that John had let a motorhome and its occupants move into his backyared and live out of the motorhome. The neighbor reported to seeing 6 different people come and go from the RV in the past 20 minutes and belives they were selling drugs. 2016-20046915 on 12/14/16, Code Enforcement issued a citation for people living / camping in the motorhome. See Exhibit 8, Code Enforcement Chronology of Events, attached hereto and incorporated herein as if fully set forth. On 12/15/16 a neighbor called my office and brought it to my attention that the activity at 548 E Central was active again. After further research | discovered that John was arrested and booked into jail at the end of July 2016. He stayed in jail until the begening of October 2016. During the time John was in jail his house was vacant and there was no activity. When he was released from jail the activity started up again. 2016-20047445 on 12/15/16, a neighbor was reported that a male stole a package from a porch of another neighbor and went to 548 E. central. | spoke to the neighbor and she stated that she saw a male carrying a large package and either went into the residence of 548 E. Central are to the motorhome parked in back. She said the package was definitely not delivered to 548 Central. 2017-20001883 on 1/4/17, | issued John Kovtuschenko a citation for Failure to Abate Nuisance (Citation # 720153492). ‘AFFIDAVIT OF KEITH CLER ~ PAGE 5 ichae! J, Piecoo, iierim Gy AoTiey “OFFICE OF THE CITY ATTORNEY 3 Floor Municipal Bulding ‘Spokane, WA 992013326 (00) 625.6225 AX (500) 625.627710 an 12 43 4 15 16 17 18 19 20 ar 22 23 24 25 26 27 28 © 2017-20001883 on 2/13/17, | served Lidia Arch at 3411 W. Wellesley a ‘Second Chronic Nuisance Abatement Agreement, which she signed. This was recorded on my body camera. See Exhibit 5, Second Abatement Plan, attached hereto and incorporated herein as if fully set forth « 2017-20001883 on 2/14/17, | served John Kovtuschenko a new abatement agreement (which he signed) and on camera John again admitted to using Meth the day before 2/13/17. He stated that he had a roommate, Tonya and then her boyfriend Jeff who moved in shortly after. John said he smoked meth with them the night before and that Jeff may be selling it out of the house. He also said there was an Art, living in the motorhome off and on in the backyard. asked John if he thought this was fair for the neighbors to have to live next to this and he responded that it was not fair to the neighbors and he knows getting kicked out of the house is most likely going to happen. See Exhibit 6, SPD incident no. 17-20026866, attached hereto and incorporated herein as if fully set forth. « 2017-20026865 on 2/15/17, | issued John Kovtuschenko a 2" citation for Failure to Abate Nuisance (Citation # 720405090) based upon him admitting to using Meth and his roommates selling drugs. * 0n 2/23/17, the Office of the City Attorney issued a Final Warning Letter to the Lydia Arch Family Trust. See Exhibit 7, Final Warning Letter, attached hereto and incorporated herein as if fully set forth. © 2017-20036324 on 2/27/17, the owner, Lidia Arich Family Trust, was cited by Code Enforcement for a litter rubbish violation. See Exhibit 8, Code Enforcement Chronology of Events, attached hereto and incorporated herein as if fully set forth « 2017-20036886 on 3/1/17, neighbor called in reporting a white male that appears high, waving his arms around, who went to 548 E Central and was handed something through the window. Neighbors believe it was drugs. « 2017-20037387, on 3/2/17, officers responded to a traffic hazard at Nevada and Everett on a report of a white male walking northbound in the southbound lanes, walking in the roadway against traffic. He was yelling and appears high on drugs. Officer noted in the call, “When | walked up Kristopher Stump he was dancing around on the sidewalk. Obviously very high. He said he was waiting for his friend Brittany to come pick him up. Gave him a warning to stay out of the streets. He said he will be out of the area soon. Said he has been staying at 548 E Central Ave with a John and Jeff.” This is the same ‘AFFIDAVIT OF KEITH CLER— PAGE 6 Michael J, Piccolo, Interim City Attorney ‘OFFICE OF THE CITY ATTORNEY 's" Floor Municipal Building ‘Spokane, WA 99201-3326 (508) 625-6225 FAX (509) 625-627710 a 22 2B 1a 15 16 a ae 19 20 2 2 23 24 25 26 20 26 Kristopher Stump that was staying / arrest at 548 E Central on 10/29/15 (15- 381918). He was also just recently staying at another drug house (1014 E. North). 2017-20037465, on 3/2/17, John Kovtuschenko called in stating there are 2 guys at his front door. Thinks the will try to break into his house through the broken window. He knew them by name, Christopher J Warren and Bart J Ottosen, 6/17/72, who has 6 felony warrants for possession of a controlled substance and 2 misdemeanor warrants for a total of 8 warrants for his arrest. He also shows prior convictions for drugs and criminal mischief-deadly weapon. 2017-20039701, on 3/5/17, Neighbor called in 2 white males rummaging through the yard, both appear high. They are climbing up on the roof and going through items in the yard. 2017-20040770, on 3/7/17, Neighbor called in that there is a male who looks very high, throwing his arms around, acting erratic, coming in and out of §48 E Central. 2017-20043113 on 3/10/17, Neighbor called in that there was a male in his 20's standing in front of the window naked. 2017-20043599, on 3/11/17, John called police wanting to file a stolen vehicle report because his friend stole his keys out of his pocket while he was sleeping and took his vehicle. 2017-20052511, on 3/24/17, John called police reporting a former friend of his, Tanya Meyers, broke his vehicle window with an ashtray. 2017-20084652, on 3/27/17, Lidia Arich Family Trust was cited by Code Enforcement for Litter / Rubbish violation at 548 E Central 2017-20059732, on 4/3/17, John called police stating that there was a male trying to kick in his door. Officer state that John said the male was, Ronald Jones Jr., who sleeps at the residence once in a while. John wanted police to {ry and locate Jones and tell him not to come back. 2017-20059869, on 4/3/17, John called crime check and reported that his roommate, Jeff Landahll and his girlfriend, Tanya Myers (see 2017-20052511 above) are selling Meth and Heroin out of John’s home (548 E Central). He TDAVIT OF KEITH CLER = PAGE T Wichadl J, Pesolo, incor Gly Morey ‘OFFICE OF THE CITY ATTORNEY ‘5° Floor Municipal Bulling ‘Spokane, WA 90201-3328 (509) 625-6225 FAK (808) 625-627710 a 12 13 14 15 16 uw 18 19 20 21 22 23 24 25 26 2 28 also said they are a part of a group of suspects responsible for residential burglaries on the north side of Spokane. « 2017-20064381, on 4/10/17, Neighbor called in that John threatened to kill his mother, Lidia Arich and brother, Alex Kovtuschenko, and pushed his mother. Lidia and Alex left, Officer contacted Lidia at her residence and she stated they were arguing about John allowing unauthorized people to live at 548 E Central. She denied any assault. 40. Based on the amount of calls for service and police contacts since John Kovtuschenko and Lidia Arich entered into an abatement agreement on 3/1/16 and again on 2/13/17, itis apparent they have not been making an effort to abate the criminal nuisance and drug related activity. The neighbors have continued to report short stay pedestrian and vehicle traffic to crime check and tome. There have been several people frequenting the house who have active warrants for their arrest, many people with criminal history to include unlawful drug possession, burglary, vehicle theft, etc, 11. Based on my training and experience in dealing with chronic drug nuisance properties, there is a clear pattem of both criminal and drug activity at 648 E, Central. Under SMC 10.08A.020(D), 648 E. Central is clearly a chronic nuisance property, Based on the amount of short stay traffic and self-admission of drug use occurring there, 548 E, Central is clearly a drug house under RCW 7.43. 12. The activities at 548 E Central have created an adverse impact on this neighborhood. The surrounding neighbors are in significant danger from both the homeowner and the people associated with the homeowner. In order to effectively abate the criminal and drug nuisance activity occurring at 548 E Central, itis my ‘AFFIDAVIT OF KEITHCLER - PAGES Wichasld. Picea, itor Ciy Attorney ‘OFFICE OF THE CITY ATTORNEY ‘Floor Municipal Bulging ‘Spokane, WA, 99201-3926, (508) 625.6225 | FAK (500) 625.627710 a 12 3 a4 15 16 vv 18 19 20 21 22 23 24 25 26 27 28 opinion that 48 E. Central must be physically closed and secured. Only by vacating, closing, and securing the property will the criminal nuisance and drug activity stop, and only then, will this neighborhood retum to its ordinary and safe environment. ‘AFFIDAVIT OF KEITHCLER - PAGE 9 TWichael J. Pieeao, itor Gy Attorney (OFFICE OF THE CITY ATTORNEY ‘BP Floor Municipal Bulding ‘Spokane, WA 99201-2328 (500) 625.6225 AK ($08) 625-627710 a 2 3 14 15 16 ru 18 19 20 2 22 23 24 25 26 2 28 hi Ob # FeO KEITH CLER, #400 n oa SUBSCRIBED AND SWORN to before me this 20" day of Acpiv| Notary Public Qondio OCou— 2017. State of Washington Sancta 0 Connor Notary Public in and for the State of Commission Expres 1001-17 Washington, residing in ELK , WA. s iON. ‘AFFIDAVIT OF KEITH CLER - PAGE 10 ‘Wichael J. Piecolo,nierim Cty Atorney ‘OFFICE OF THE CITY ATTORNEY 3 Floor Municipal Bulging ‘Spokane, WA. 09201-3328 (500) 625-6225 FAX (500) 625-8277INDEX OF EXHIBITS TO AFFIDAVIT OF OFFICER KEITH CLER RE: 548 E, CENTRAL Exhibit 1, Calls for Service Log Exhibit 2, Neighborhood Nuisance Activity Logs Exhibit 3, SPD incident no. 16-59034 and Chronic Nuisance Notice Exhibit 4, SPD Incident Number 16-59034 and 2016 Chronic Nuisance Abatement ‘Agreement Exhibit 5, SPD Incident Number 17-20001883 Second Chronic Nuisance Abatement Agreement Exhibit 6, SPD incident no. 17-20026865 2017 Abatement Plan Violation Exhibit 7, Final Warning Letter Exhibit 8, Code Enforcement Chronology of EventsEXHIBIT 1$48 E CENTRAL Incident # Requested Date: O1/01/15-10/05/16 Prepared By: Crime Analysis Date Recieved Time Received CES Type Disposition ee eee ‘548 CENTRAL, 50164800 1150859708, 160012015 60151887 ‘548 € CENTRAL AV 150002665 150008097 150019972 150013948 150017116 150022383 50095251 150039827 150089072 150058128, 150074304 ss0077i28 150077574 ‘50004409 150091834 150095296 150098269 Wednesday, April 12,2017 siaz0%5 oy122018 viv2ot8 arzaro1s svareo1s ‘yer2015 2015 visors 2015 ‘2012015 arveots 2182015, 2je2015 rears ave201s siez01s e018 anazors srznz01s sraaro1s 352015, 1501 see 10:09 82 14687 1628 318 y049 eat 25:40 47 a4 722 a9 ss12 2.02 ess 132 20105 FoULow FouLow FOLLOW cc WARRANT epics meDics susoin WeELFAR, WELFAR. SUSPER uauesr cc pvors. WELFAR, suscIR SUSVEH SUSPER WELFAR SURV SUSPER 0 10 10 140 140 10 0 140 120 10 1 5 sD 40 140 16 110 “Page TofSIncident # Date Recieved Time Reecived CFS Type Disposition 150131298 az22015 {14 SUSPER ‘can 150157686 51192015 a2 Ov 16 180162100 51772015, yast SLT 1” ‘50172234 2512015, 1100 BURGR 1" 150172812 5252015, 1827 ov 1” 150176161 282015 sido WELFAR 190 50182588 e015 742 pRUGS ‘sr 50185038, 92018 2198 DOMST rr 150184746 e1s2015 W750 ov 1 150184965 er32015 1254 PERBOT can sores e1e2015 2102 PEREOT 120 ‘50186581 e1sz01s 2259 SUSPER 10 150189960 e705 1739 SUSPER. 140 ss0191246 eaz015 1724 suscIR 0 s50191280, ere05 1749 suscIR 10 1150190645, e1e2018 954 THEFT 158 50192819 6192015 180 WELFAR 130 ssot9a884 eriozo1s 1421 THEFT 158 15020888 enei2015 1919 ASLT 10 150215850, er262015, 1855 WELFAR “0 ‘0005564 712015 19:12 oc 120 150202277 71182015, 1893 THEFT 188 180242628 7672015 07 SUuSPER 16 150248080 mni20s 157 SUSPER 130 50246412 re201s 1829 TRESP 10 Wednesday, April 12, 2017 ~ 7 ~ Page 2 ofSIncident # Date Recieved Time Received CRS Type Disposition 190248069 72072015 1782 ORUGS 50 150248670 712018 1794 RUGS 1st 150051988 71222015, 1390 VEHTET 8 50260141 72912015 298 SUSPER 40 150276369 artv20% 1838 WELFAR 190 150208888 12572015, font cc 50 150201280 2202015 $7.04 MALMS 188 5001249 eran2015 1650 MALS = 160807675 sra01s 1420 SUSPER 1st 150013716 eri201s 1028 TRESP 50 150290973 rea018 1808 PERBOT 140 150307338, sora015 20.4 SUSPER 1D 150048474 0792015 1910 GW 1.N ss0asera7 sorra2018 22 ARGUE 1 150985061 10782018 3746 WELFAR 8 150957503 rorro2015, 1987 ARGUE 1 150388800, ron 2018 tet PERW 0 15060104 sana2015, yr ARGUE "0 150350615 sonz20ts sit suscIR 190 ‘0360488 rait2015, 290 SUSCIR 1 150075993, sos2015 058 SUSPER 190 15088085 1ov282015, 4158 PROWL 18 +sosea4es sors02015, 1208 SUuSPER 18 150080268 ‘orsare01s 23st WARRANT 1B 50800360 sws2015 18:01 PROWL “0 Wednesday, April 2, 2017 i ee Page 30f5Incident # Date Recieved Time Received CFS Type Disposition 150300646 Hees 1827 FOULOW 10 150438859 1232015, za1e ov 10 160006087 ‘We2016 958 FOLLOW 16 160010788 sviowo1s 2A8 ARGUE 18 60011199 snoi20%8 1431 WELFAR 80 100019275 iarot6 nia FOLLOW 10 eo014002 wiaro18 2398 PERBOT e00s2802 sve02016 1102 TRESP wN 60030043, 2raz016 toad SuSPER 10 0045290 arn016 1548 BURGA 18 190048127 2raz016 2320 SUSPER 16 160089058 ariaeo16 yor susciR 50 ‘0083868, piazore 1446 ORUGS 80 190053983, 2iao1s 1502 SUSPER 40 60084085 arraraor6 te:19 SUSPER 50 e0086856 prewzote 2020 MALS. 158 180073861 sivz016 1128 FOLLOW 10 60081474 72018 1209 SUSPER io 60084548 giar016 1643 MALMS 188 190086828 sr0r2016 1401 BUAGR 1 soo103823 srzazots 1250 TRESP 10 se0105047 1252016 1800 FOWOW 100 ‘e0104a08 91252016 1285 FOLLOW or) 60108833, srea016 1556 SUSPER 140 60108966 28/2018 20.88 SUSPER 109 ‘Wednesday, April 12, 2017Incident # Date Recieved Time Received CFS Type Disposition reesei an enn ns 60110744 ‘ar9072016 6:17 SUSPER 120 190124388 azote 2a10 SUSPER 40 100149453, arz22016 2823 WARRANT 10 60144520 2016 2401 DisoRD 100 seov447e7 apazo16 123 SUSPER 140 160159976 sr2016 2508 BURGR 110 160178956 srar2016 1298 suSPER 50 60208207 ea018 16:14 MEDICS 140 so022s472 2272016 1840 DISORD 140 60725830, 227016 602 suSPER 10 190229102 eraz016 1501 ARGUE 10 90231842 eez016 1328 TRESP 1N 100287613, es02016 600 PROWL =D so0240187 72018 1999 TRESP N 160244169 mis2018 2048 SUSCIR 10 160287199, Tie2016 718 TRESP 5 160250871 7rez018 502 SUSPER 40 ro02546t4 7112018 2084 SUSCIR 50 160255760 mi22018 1709 TRESP 140 ‘0088271 me2016 608 suScIR 140 60270594 rzae018 728 SUSPER " 160270625, 7rea2016 807 TRESP = seos16828 arasz016 9:26 TRESP. 50 60828168, sr22016 1145 suscin or Wednesday, April 12, 2017 Page 5 of S548 E CENTRAL AVE Incident # Date Recieved ‘S40 © OENTRALAVE: 2016-20014539 2016-20020821 2016-20026516 2o016-20081388 2016 20087645 o16-20084807 2017-20001883 2017-20005828 2017-20006158 ‘2017-20012750 2ov7- 20012781 2o17-20n22010 2ot7-20022624 2017 20028287 217 20098742 2017 -20036888 2017-20087465 2017-20099701 2017-20040770 2017 20088118 2017-20049500 2017 2004658 Wednesday, Aprit 12,2017 102572018, wa2016 suirer016 rans2016 svaa017 ‘v9r017 wvi2017 sreorai7 vean017 21672017 2rri0\7 anae017 21282017 a017 seea17 52017 anor? anoor7 aiie07 ansreo7 Requested Date: 10/06/16-04/12/17 Time Received 1954 1798 zo2t a2 eo 1789 on? 2198 958 1201 1529 144s: vat 54 s70 1929 1625 oa wae 1036 1816 a Type SUSPER Disturbance - Non D Vehicle Prowl FIRE THEFT FoLLow FOLLOW SUSPER, Special Detal Disordety Gonouct Disorderly Conduct oRucs susciR FOLLOW susvEH prUGS SUSPER SUSPER, isoRD Lewo Venter susvEH Prepared By: Crime Analysis Disposition ‘86 Refored interna VIVES; E9 Arrest Warn: A1 Cicer Contact: RS |A19 Cancel NUA; As Retered External A12Canea M Ofcer Contac: [ES NO}-NoniHaz: R2 Set Inatod; Pt por: VIDYES: A Officer Contact: RS ‘AsisUBackup; A12 Cancel PO \VIONO: Re Soft iano Att Nothing Found: \ViONO; Call for Service; AL Nothing Found ‘13 Cancel NUA; Cosme Check Report Tip Sheet; [At Otcar Contact; A Calor Senveo: 90 No Papo VIDYES; Re Sonate: PO No Repent VIDYES; Rt Calor Seice: PO No Repos, 1 Rtered Internal ‘yiono, vinves: Ra AesiavBackup; Fi Calor 12 Cancel [Ast Nothing Found: At2 Cancel ‘cme Chack Repon Tip Sheet VIDYES; At Oficer Contact |g Rerod Intnl Page of? Ageney ORT waoszo400 ‘wans204o0 wa0se0400 ‘wans20400 wa0320400 waaseo4o0 waos20400 wanseodo0 wa0se0400 waase04o0 waas20400 waoaz0400 ‘wanse0o0 ‘waosz04o0 ‘wana20400 waoaz0400 waas20400 wa0ae0400 ‘waose04o0 waoseo4oo ‘wans20400 waose0400Incident 9 Date Recieved Time Received CFS Type Disposition Agency ORT zovrzonsest1 242017 922 MALNS ats Broadcast; ‘waasz0400 eovr-20nsest4 — areaz017 925 MALMS ‘ime Check Report-Entooc WADB@0400 2017-2005798 39112017 1650, DISORD {Ag Refered internal wa0s20400 2017-20058859 aps2017 owe ORUGS Crime Cheek Roport-Tip Sheet; WAnaz20400 2017-20080782 svara0t7 se0z —TRELU VIDYES: As Assistance wags20400 Rendered: At Oicer Contact; porr-2ooeasat ——_4/1012017 3080 ov VIOYES;At Ofcer Contact; WA0B20400 48 CENTRAL povr-2ongsees §— 2/14/2017 1239 FOLLOW VIDYES: Re Seltniiaed; PO WADG20400 Ne Report 2017-20086611 aot? 4109 FOLLOW \VIONO; Re Se-ntated: PONe waAos20400 Repo Wednesday, Aprit 12,2017 Page 20f?2EXHIBIT 2py sar PAE pouiis 2014) Zr sereea: z au remy uorSUTYsEA JO AIEIS ayP Jo SweT atp spun Aanttad Jo Ayjeusd spun (exojoop 10) yna9 © 7. 1 Tr bor ver oe ery ae Ee aR oe af STEEF 77 Phe PS ni as pre Oe 3B zy > 18 bees LA Tr Par SAO Pr ae roe es EP TR | EO SAS Tey Re aap ed we Lae ors Wa SUR a area ap Faas TY poet os Poe, ya i Gap =P a c TE RS Por ee BP AIS we Sy Se Per [E74 ep ‘oil au uemp a1ou asn AR TOA) ON A #poday L744 NOA MOH PUe CAVH “AVS ‘nok yeyAy :uonduosoq, akvaaere | #asuecr7 | weAHo}oD PW 32D | SUT aed [Suodougsouesnn 3 sePV] ‘punose pure ut :1Anoe Jo suopeAlosgo jeuosiad kw uodn paseg s1 Sutsof}oy 31] ne DOTALIALLOV SONVSINN GOOHYOSHOIANST PRPS ws aoetd) pstss ough EBT onal PT tomers wp wap uoxTanyse Jo sve1g ayp Jo sie] a4p z9pun Afi Jo Ayeuad sopun (axefoap 46) AyH09 © PEFBG) Sed Fe aR A 3 Ft Det asst ee 2 Pmy| Sopa ae AIPA) Bey SE] Tee aer Sop, ror peg pry? 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Cavenna Wone Ve 7 Gir au0 Ue Si0UN aan Kuno, nS astiaary | maa snojoa/e¥eW se | aunt | eC gyodoy L744 NOA MOH Pue CRIVAH ‘AVS nod YM woRduEseg | ALWAdTY [earedorg souvsinn 30 ssouppv] punose pue 1 Kilanie Jo suonearasqo teuosiad Aw uodn paseg st Suymol}o} aU, DOT ALIALLOV AONVSINN COOHYOEHOIN. a Howry, WTA BSTpoudts o7¢{d] © fora) £ [eunweudis) —“yau09 pure ann s} aaoge omy Ip UoHBuySeAA Jo 91EIS 9Up Jo sae] axp sopUN Amnfiad Jo Ayjeued sopun (oxEI>eP 30) 4}3H9 ot pt] > [el = Jars SER ee se awe’ rai ZING NA OYE ea) (oui ou woIp szour asn ABUT A) ON SA yvodoy | ITAA NOA MOH Pu CUVSH ‘MVS NOK rem VoNduoseG | ALVAGAY | if 95UPK seo {yrojo3/o¥e 380 | aus | ved [éurodorg 2ouestan so ssoupPV] ‘punoue pe ut {lAnoe Jo suorreaiasqo peuosiad Aw wodn paseq s} Sulmoy}O} aL) DOTATIALLOV aONVSINN GOOHYOEHDIEN Adouyrony PI aang BYEXHIBIT 3eee Reer. & Ie- $9034 NOTICE OF CHRONIC NUISANCE PROPERTY SMC 10.08A. ‘To the following Property Owner: Lidia Arich “Toth following Person in Charge ofProperiy: SS “This will serve as notice thatthe following property i declared to bea chronic muisance Proper: 548 E Central Spokane, WA 99207, the Spotane Police Deparment hs dvumented he or or of te following muses ates ate above property within a 60-day period: 1. Date: _29/16 ‘Time: _2520 hes. Incident: _16.48127 Description: Sammie 2. Date: 2716 ‘Time: _1545 brs, Incident: _16-45230 Description: Stolen vehicle, warrant arrest, ‘Fesisting arrest, obstructing and malicious ‘mischief ast 3, Date: _U28/16 ‘Time: _1102 hours Incident: _16-32802 Description: Drugs and warrant arrest ‘You must respond within 10 days ofthis notice to diss a plan to abate the chronic muisanoe actives aon tis propery. You mat respond to th police afc noted below. If you fil to respond 0 Tar enis you othe person in charge of the property wil be issued a Class I Civil Infraction, “Adéivionaly failure to shat the conditions giving ise to this notice may subject this property to farther fog action suchas closure ofthe property. You may also be subject o civil penalties that may ncade wp to $100.00 per day from the date of this notice... « ‘Spokane Police Officer: Keith Cler #400 ‘Telephone Number: 509-625-4267 ‘Spokane Police Department, 1100 W. Mallon Avenue ‘Spokane, Washington 99260 ‘certify under penalty of perjyry under the laws of the state of Washington that the foregoing is true and comet. Ofticers Signature: “eth CL. pu: Q11/ le piace: spans, WA (CE: My Delivered personally to: Lidia Arich ‘Whois the: [=] Owner. [[] Aivatfor the owner of subject property Mailed to: 7 which é the last address Usted In the property tax records. For property tax information, 6: ‘Spd/adm/word:patrolsecretaryReew. 16-SAO34¢ Time: _0420 hs. Incident: _16-14002 5. Date: 1/10/16 ‘Time: _1431 brs. Incident; _16-11193 Description: _ Drugs 6, Date: _1/0né ‘Time: _0215 hrs. Incident: _16-10799 Description: _ Assault and warrant arrest " eS 7. Date: _1/6/16 ‘Time: _0958 hrs. Incident: _16-6057 Description: _Warrant arrest 8 Date: 12/24/15 ‘Time: _2309 hrs. Incident: _15-451911 Desctiption: 9. Date: 1029/15 ‘Time: _2338 hrs Incident: _15.381918 Description: Assault T_T 10, Date: 10/07/15 Tine: 0212 brs. Treldeatt _15-352747 Description: _Assault — —_ It should elso be noted that for te time period of 1/1/15 to 2/16/16 there has been a total of 86 cals for service to this address.EXHIBIT 4RE pr db le-S9 TF SPOKANE POLICE DEPARTMENT NUISANCE PROPERTY ABATEMENT PLAN Plan between Spokane Police and: Lidia Arich & John Kovtuschenko (son) (Property Owner / Person in Charge) Nuisance Property Address: 548 E, Central Spokane, WA 99207 Date of initial police notice to above person: 2/18/2016 Date of abatement plan: 3/1/2016 ‘Summary of Nuisance Activity: From 1/1/15 to 2/16/16 there has been a total of 86 calls for service to S48. Centra. These calls for crue include but nt limited to, Stolen vehicle recovery, mulitpal warrant arrest, resisting arrest Shotructing a potice officer, malicious mischief, drugs and assaults. In summery criminal and drug related activity vou & John wl mmediately remove from your home any and al indviduals associated with rial verity and/or drug atv involving the use, posession o see af controled substances which are not presaibed by 8 pysilan You &John wil immediatly cease any and al criminal atvty occurring at oF esocited with your home at $48 E Central. That fora period of1 year You & John will not allow anyone acacia with eriminal activity to lve or stay in 48. Centra. John wil obey all municipal and county state laws. John will not use/possess/consume controlled substances except | pursuant to lawfully issued preserigtions.fJohn does nat abide bythe above you will evctJohn and alloccupants from 548 E Central. Date action to be completed by: 3/1/2016 JEM fen fpf \ Signature of Property Owner/Person in Charge Ze. fx> Officer Signature Date:3/1/2016 _Location: Spokane, WashingtonEXHIBIT 5SPOKANE POLICE DIVISION CRAIG N. MEIDL CHIEF OF POLICE ‘Date of Abatement Agreement 2/13/2017 Report Number: 201; CHRONIC NUISANCE ABATEMENT AGREEMENT ~ SMC 10.084 Department and the person in charge of the property in danger of belng ‘This is a contract between the Spokane Poll declared a chronic nuisance property. Person in charge and address: Lidia Arch & John Kovtuschenko (son] Nuisance Property Address: __ $48 € Central Spokane, WA Description of the Nuisance Activity (0 3/1/16 you both entered into an Abatement Agreement for a period of 1 year (2016-00059034). John Kovtuschenko violated that agreement by braking code enforcements laws by letting people live / campina motorhome at 548 £ Central, code enforcement issued a citation. On 4/29/46 John was arrested at 548 £ Central for Malicious Mischief-DV & on 7/23/16 John was arrested at 548 E Central for Violation of a DV order (felony), DV- ‘assault, 1" burglary, interfering with the reporting of a DV, 2" Robbery and DWLS-3%, This isa violation of the original Chronic Nuisance Abatement Agreement so this agreement willbe extended for a period of 1 year from the date this agreement is signed. Necessary Corrective Action: You & John will immediately remove from your home any and all individuals associated with criminal activity and/or drug activity involving the use, possession or sale of controlled substances. You & John will Immediately cease any and all criminal activity occurring at or associated with your home at 548 E Central. That for a period of 1 year you & John will not allow anyone associated with criminal activity to live or stay in 548 E, Central. John will obey all municipal and county state laws. John will not use/possess/consume controlled substances except pursuant to lawfully issued prescriptions. If John does not abide by the above you will evict John and all occupants from 548 E. Central Page 1 of 2SPOKANE POLICE DIVISION CRAIG N. MEIDL CHIEF OF POLICE Date coryective action is to be completed: Immediately rho South. ‘Signature of Property ad in Charge j/ 7? LC SED Officer Signature Date: _2/33/37 Location: 3411 W. Wellesley Spokane, Washington Page 2 of 2SPOKANE POLICE DIVISION CRAIG N. MEIDL CHIEF OF POLICE 2/33/2017 Date of Abatement Agreeme CHRONIC NUISANCE ABATEMENT AGREEMENT ~ SMC 10.080 “Thisis a contract between the Spokane Police Department and the person in charke of the property in danger of being, declared a chronic nuisance property. person in charge and address: Lidia Arch & John Kovtuschenko (son) Nuisance Property Address: __ 548 £ Central Spokane, WA Description of the Nuisance Activity: on 3/1/16 you both entered into an Abatement Agreement fora period of 4eat :2016-00059034). John Kovtuschenko violated that agreement by raking code enforcement aws by letting people live / camp ina wevtothome at 548 € Central code enforcement issued a citation._On 4/29/16 John was arrested at 548 £ Central for Malicious tischie-DV & on 7/23/16 John wasarrested at 548 £ Centra for Violation of @ DV order (felony), DV: tesault, 4" burglary, interfering with the reporting ofa DV, 2™ Robbery and DWIS-34, This isa violation of the tvzinl Chronic Nuisance Abatement Agreement sothis agreement wil be extended for a period of 1 year from the date this agreement is sign [Necessary Corrective Action: You & John wil immediately remove from your home any and all individuals associated with criminal activity andor drug activity involving the use, possession or sale of controlled substances You &John will vmumediately cease any and all criminal activity occurring o or associated with your home 3 548 € Central. ‘That for a period of 1 year you & John will not allow anyone associated with criminal atity to live or stayin cag. Centra, John will obey all municipal and county state laws. Jn will not use/possess/consvime cavtoled substances except pursuant to lawfully issued prescriptions. John does not abide by the above ‘you will evict John and all occupants from 548 E. Central Poge 1 of 2SPOKANE POLICE DIVISION CRAIG N. MEIDL CHIEF OF POLICE Date corrertive action Is to be completed: Immediately Patio oper Owrer/eron in Gare Yl Ce fer Srature Date: _2/33/17 Location: $48 £ Central Spokane, Washington Page 2 of 2EXHIBIT 6‘SPOKANE POLICE os 2017-20026865 FIELD CASE REPORT seroma osrmcr. 3 Neva Wood pa2017 12:33 _ [Civil Infraction ™ o_o [Eb woe CENTRAL AVE ‘W-10.06A.045 1 mi or Chronic Nuisance Properties-Penalties 1 Gomentt i Is 5 }02/21/1957, 59 '@ |White- \Gray |Brown fe ee ae aa Senn maT . — ‘400 Cler 2i1ai2017 | Anderson, Jon D 02/15/2017 TosSPOKANE POLICE ess 2017-20026865 CASE REPORT NARRATIVE Rept. #2017-20026865, Infraction # 720405090 348 E Central - Failure to Abate Nuisance (Subsequent Nuisance) On 2/18/16 I served John Kovtuchenko & his mother, Lidia Arich a Notice of Chronic Nuisance (2016- 100059034), Lidia Arch isthe owner of the house, but John Kovtuchenko is the person in charge of the house and is currently living in the house. Lidia lives at 3411 W, Wellesley and according to Lid John gets the house in her will. 0n 3/1/16 Lidia Arich & John Kovtucheriko both entered into a Nuisance Property Abetment Plan, both signing the agreement (2016-00059034). The agreement of the plan sas follows and was agreed upon for the period of 1 year. You & John will immediately remove from your home any and all individuals associated with eviminal activity andlor drug activity involving the use, Possession or sale of controlled substances which are not prescribed by a physician, You & John will inmediately cease any and all criminal activity occurring at ee associated with your home at 548 E Central. That for a period of 1 year you & John will not allow tnyone associated with crininal activity t0 live or stay in 548 E. Central. John will obey all municipal ‘and county state laws. John will not use/possess/consume controlled substances except pursuant 10 lanfutly issued prescriptions. If John does not abide by the above you will evict John and all accupants from 548 E. Central John violated this abatement nuisance agreement on 1/4/17 and was cited for it (Infraction #720153492, Rept, #2017-2001883). I wrote up a new abatement agreement extending it for another yeat and served itto John on 2/14/17. The old plan was stil in effect when I served the new agreement. While talking to John | asked him if he had relapsed with the drugs. He stated that he smoked Meth. the day before and his roommate, Tonya, gave it to him. He also said Tonya’s boyftiend, Jeff, moved in and he was probably selling it out of his house (see body camera video). It should be noted that the new agreement he signed that day is as follows (see attached copy): You & John will immediately remove from your home any and all individuals associated with eriminal aerivity andor drug activity involving the use, possession or sale of controlled substances: You & Jel wl inmediately cease any and all criminal activity occurring at or associated with your home at 548 E Central. That for a period of 1 year you & John wil not allow anyone associated with eriminal activity to live or stay in 548 E. Central. John will obey all municipal and county state laws. John will not te/possess/eonsume controlled substances except pursuant to lavfully issued prescriptions. If John does not abide by the above you will evict John and all occupants from 548 E. Central {am citing John for violating the abatement agreement from his own statements to me that he smoked 400 Cler 2/14/2017 _ | Anderson, Jon D 02/15/2017 Bos roca 1 sts Page 2083SPOKANE POLICE os 2017-20026865 CASE REPORT NARRATIVE (continuation) Meth, and his roommates boyfriend is selling drugs out of the house. ‘The Infraction was sent to John by 1* class mail 1 certify under the penalty of perjury under the laws of the State of Washington that all statements made herein are true and accurate and that | have entered my authorized user LD and password to authenticate it. Keith Cler #400 400 Cler 2/14/2017 _| Anderson, Jon D 02/18/2017 coryEXHIBIT 7Par J. Datron RIA price or THE Cry ATTORNEY Sunion Assistanr Crry ATTORNEY SPOKANE 808 w. srosave Fans Bu roxas, WashIncrON 99201-3326 509.625.6225 509.625.6277 FAK Assistant Crry Arronneys SSavarons J. Facouno — Naruaviet J. ODte Marni M, Rousox Jes A, Rictncan Maur F Mumwarsu. —-Euzasom L. ScHOEDEL Mannan F Oots Taye B, SzAsELt Host M, Wausy Micuars J. PrccoLo Tnvreny Cri AYTORNEY February 23, 2017 VIAU.S. FIRST CLASS AND CERTIFIED MAIL Lydia Arich Family Trust Lydia Arich John Kovtuschenko 3411 W. Wellesley Ave. ‘Spokane, WA 99205-1778 RE: Property at 548 E. Central, Spokane, Washington 99208 Dear Lydia Arich Family Trust (Lydia Arich) (John Kovtuschenko): You are in eceipt of ths letter because the property located at 548 E. Cental, ‘Spokane, Washington, is in danger of being declared a chronic nuisance property as it continues to astare with the quiet enjoyment of the surrounding neighborhood. The City of Spokane is preparing to go to court to close and board up your property unless Immediate corrective action is taken. ‘The Spokane Police Department has received eighty ix (86) calls for serdce betwen January 01,2015 and January 16, 2016 to your property, 548 E. Centra Spokane, Washington. On February 18, 2016, you were served a Chronic Nuisance Notice, Spokane Police Department (SPD) incident no. 2016-68034, On March 01, 2016 you entered into a Chronic peers Property Abatement Agreement where you agreed fo "immediately remove all teieatais associated with criminal activity and drug activty..and...mmediately cease ary and all criminal activity...at 48 E. Central.” ‘On January 4, 2017, John Kovtuchenko violated this agreement admitting to smoking meth at 548 E. Central and that a roommate was selling meth out of the property. Furthermore, recent reports indicate an increase in criminal and nuisance activity and a violation of SMC 10.08A, NOW THAT YOU HAVE BEEN ADVISED of the illicit drug activity at this address and have knowledge of the activity, it is imperative that you take immediate action to eliminate the drug activity at this property. This property willbe sublect fo seizure and forfeiture by the ity of Spokane ifthe illegal drug activity continues beyond the date of this notificationLydia Arich Family Trust Lydia Arich & John Kovtuschenko February 23, 2017 Page 2 of 2 ‘Asa property owner, itis your responsibility to end the criminal. drug and nuisance activity Cecurring at 848 E, Central, Spokane, Washington. Please contact me immediately to discuss your intentions regarding this property. Sincerely, Matthew M. Folsom Assistant City Attorney (09) 625.4429 Encl: Chronic Nuisance Notice (2.18.17); Abatement Agreement (3.1.16); Abatement Agreement (2.13.17) c: Craig Meidl, Chief, SPD Justin Lundgren, Assistant Chief, SPD Captain D. Torok, SPD Captain B. Arleth, SPD Lieutenant D. Erin, SPD NRO Keith Cler, SPD Mike Piccolo, City Attomey Mary Muramatsu, Assistant City AttorneyEXHIBIT 8Chronology of events 548 E. Central 12-29-2014 Complaint of living in RV — Notice sent. 1-20-2015 — closed file — no further evidence showing RV use. 9-2-2015 RV use/Parking in front yard/Litter complaints Notices sent 9-21-2015 Sent second notices. 10-1-2015 Cited for failure to comply W044605 12-1-2015 Cited for continued violation W044111 1-14-2016 Cited for continued violation W 047106 2-12-2016 Sent another Notice: Litter / Rubbish 3-2-2016 Cited for continued violation W047100 4-4-2016 Cited for continued violation W041458 5-5-2016 Cited for continued violation W041470 6-6-2016 Cited for continued violation W041474 Sent another Notice 7-15-2016 Cited for continued violation W047911 8-15-2016 Cited for continued violation W047924 9-14-2016 Cited for continued violation 048790 10-19-2016 Cited for continued violation W048850 11-02-2016 Sent Notice: Litter / Rubbish 11-16-2016 Sent Notice: RV Use / Garbage / Exterior Storage 12-14-2016 Cited for continued violation W049154 1-30-2017 Cited for continued violation W049171 2-27-2017 Cited for continued violation W049241 3-15-2017 Sent Notice: Garbage / Storage