19 20 21 22 2 4 25 26 eft IN COUNTY cu PIERCE COUNTY| December 19 Keun county NO: 14-24 IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON IN AND FOR THE COUNTY OF PIERCE JOSEPH HAGEMAN, ALICIA HAGEMAN, Case No: KATHERINE KING, GARY FLOWERS, WENDY FLOWERS, LAKEISHA WILSON, AND BOBBY WILSON JR COMPLAINT FOR MONEY DAMAGES Plaintiffs), vs. AHNDREA BLUE; “JOHN DOE’ BLUE; AND [THE MAKING A DIFFERENCE FOUNDATION Defendant(s) COMES NOW, the Plaintiffs, Joseph Hageman, Alicia Hageman, Katherine King, Gary Flowers, Wendy Flowers, Lakeisha Wilson, and Bobby Wilson Jr, by and through their attorney, Jacob B. Smith, and by way of complaint against the Defendants, alleges and avers as follows: 1. PARTIES 1. Atall times material hereto, Plaintiffs Joseph and Alicia Hageman were and are husband and wife and are adult residents of Pierce County, State of Washington. ‘COMPLAINT FOR MONEY DAMAGES - 1 Jacob B. Smit ‘The Law Offices of Jacob B. Smit 1201 Pacific Ave Suite 60 Tacoma, WA 9840; P: 253-271-6618/F: 253-271-661 [email protected] D IRK'S OFFICE WASHINGTON. 14.945 0M jock LERK e15410 ul 2 3B “4 15 16 ” 18 19 20 2 2 23 4 Plaintiff Katherine King is an adult resident of Pinal County, AZ ‘Atal times material hereto, Plaintiffs Wendy and Gary Flowers were and are husband and wife and are adult residents of Snohomish County, WA. Atall times material hereto, PlaintiffS Lakeisha and Bobby Wilson were and are husband and wife and are adult residents of Dallas County, TX. ‘Atall times material hereto, Defendants, Ahndrea Blue and ‘John Doe’ Blue, were and are husband and wife, and all acts alleged herein were done on behalf of the actor individually and the actor(s) marital community. Plaintiffs are without knowledge of whether Ahndrea Blue is in fact married but are alleging that she is so married to ‘John Doe” Blue, whose true name shall be proven at tl time of trial Defendants Ahndrea Blue and ‘John Doe’ Blue are residents of King County and engage in business as owners of the Making a Difference Foundation in Pierce County, WA, Island County, WA, Snohomish County, WA, and Dallas County, TX. ‘The Making a Difference Foundation is allegedly a non-profit organization, though its alleged non-profit status has not been verified, that does business in Washington State in at least Pierce and Island Counties as well asin the State of Texas in at least the county of Dallas, Texas. I, JURISDICTION AND VENUE COMPLAINT FOR MONEY DAMAGES - 2 Jacob B. Smit ‘The Law Offices of Jacob B. Smit 1201 Pacific Ave Suite 60 Tacoma, WA 984 P: 253-271-6618/F: 253-271-661: Jacobsmith@jsmithlaw.2 3 “ 1s 16 Ww 21 2 2B 2s 6 9. Ahndrea Blue, “John Doe" Blue, and The Making a Difference Foundation committed the acts described below in this complaint to Joseph and Alicia Hageman in Pierce County, WA. 10.Ahndrea Blue, ‘John Doe’ Blue, and ‘The Making a Difference Foundation committed the ‘acts to Katherine King described below in the complaint in Island County, WA 1LAbndrea Blue, ‘John Doe’ Blue, and The Making a Difference Foundation committed the acts to Wendy and Gary Flowers described below in the complaint in Snohomish County, wa. 12.Ahndrea Blue, ‘John Doe’ Blue, and The Making a Difference Foundation committed the ‘acts to Lakeisha and Bobby Wilson described below in the complaint in Dallas County, TX, I. STATEMENT OF FACTS a, PLAINTIFFS JOSEPH AND ALICIA HAGEMAN 3 In or around the month of September, 2012, Alicia and Joseph Hageman were renting @ house in Fife, WA which was being foreclosed on. 32 ‘Needing new housing, Alicia and Joseph responded to an advertisement on Craigslist.com, where a company called the Making a Difference Foundation ws claiming to have low income housing for veterans that were homeless or facing homelessness. ‘COMPLAINT FOR MONEY DAMAGES - 3 Jacob B. Smit ‘The Law Offices of Jacob B. Smitty 1201 Pacific Ave Suite 60 Tacoma, WA 9840; 271-6618: 253-271-661 [email protected],W 18 19 20 21 22 23 Pry 2s 6 33 34 b. PLAINTIFF KATHERINE KING 36 Katherine King was living in Arizona in an R.V. without a home when she first saw the Making a Difference Foundation advertisement on Craigslist. 37 ‘The advertisement claimed that this “program” helped repair future renters” credit, ent was income-based, and thatthe program would assist the renter to ultimately purchase the home they were renting, 38 ‘After talking with Ahndrea Blue about a house in Washington State, Ms. King visited the house all the way from Arizona, ‘COMPLAINT FOR MONEY DAMAGES - 4 Jacob B. Smit ‘The advertisement claimed that this “program” helped repair future renters” credit, rent was income-based, and that the program would assist the renter to ultimately purchase the home they were renting. ‘The Hagemans were ultimately charged for money they did not owe, were evicted from the house without proper notice, harassed by Ms. Blue, their credit reports were damaged by Ms. Blue and her wrongful accusations, and ultimately were sued in small claims court among other things. MSs. Blue’s behavior caused The Hagemans to experience much emotional trauma, financial devastation, and damaged their credit and renter history with an] eviction that did not meet the requirements of the Residential Landlord Tenant Act (RLTA). ‘The Law Offices of Jacob B. Smit 1201 Pacific Ave Suite ‘Tacoma, WA 984 P: 253-271-6618/F: 253-271-661 Jacobsmith @jbsmithlaw.com10 2 3 4 1s ” 8 19 20 21 2 23 25 26 3.10 Bul 3.12 33 34 3.13 ¢. WENDY AND GARY FLOWERS 3.16 COMPLAINT FOR MONEY DAMAGES - 5 Jacob B. Smit When Katherine arrived, the house was in shambles with rodent damage among other things that made the home unlivable. ‘Andrea Blue promised Katherine that she would “fix everything” before she moved ‘The hope of one day owning her own home was such a powerfull motivator for Ms, King that she decided to trust Ahndrea Blue and so Ms. King packed up all of her possessions and drove all the way to Washington from Arizona. Nothing had been fixed by the time Ms. King arrived. After a very long time of begging Abndrea Blue to make her house livable, Ms, King was forced to move to another house she could not afford and had to sell her car to pay for a deposit. Ms. King was ultimately charged for money she did not owe, was harassed by Ms. Blue, her credit report was damaged by Ms. Blue and her wrongfl accusations, and ultimately was sued in small claims court among other things. Ms. Blue’s behavior caused Katherine King to experience much emotional trauma, financial devastation, and damaged credit and renter history, and used tactics and committed acts against Ms. King that are not permitted under the Residential Landlord Tenant Act (RLTA). ‘Wendy and Gary Flowers lost their home after a hurricane destroyed it, ‘The Law Offices of Jacob B. Smit 1201 Pacific Ave Suite 60 Tacoma, WA 98407 P:253-271-6618F: 253-271-661 [email protected]}10 u a “4 1s v 18 19 20 a 2 2B 24 25 6 37 318. 319 3.20 3.21 3.22 COMPLAINT FOR MONEY DAMAGES - 6 Jacob 2 Su ‘Wendy and Gary Flowers responded to an advertisement on Craigslist.com, ‘where a company called the Making a Difference Foundation was claiming to have low income housing for veterans that were homeless or facing homelessnes: ‘The advertisement claimed that this “program” helped repair future renters? credit, rent was income-based, and thatthe program would assist the renter to ultimately purchase the home they were renting. Ms. Blue used the Flowers to repair a very dilapidated house she moved them into and had them buy a refrigerator with their own money. ‘After that, she evicted them without abiding by the Residential Landlord Tenant Act (RLTA) because they did not come to a meeting she set up in Seattle on very short notice. ‘The Flowers were in a dire financial situation and they did not have the gas ‘money to attend on such short notice. ‘The Flowers were ultimately charged for money they did not owe, were evicted ‘rom the house without proper notice under the RLTA, harassed by Ms. Blue to such an extent that the Flowers had to change their phone mumbers and their children were scared of Ms. Blue because of stalking behavior, thei credit reports were damaged by Ms. Blue and her wrongful accusations, and they were ultimately sued in small claims court among other things. ‘The Law Offices of Jacob B. Smit 1201 Pacific Ave Suite 60 Tacoma, WA 98409 P: 253-271-6618/F: 253-271-661: [email protected]10 nl 2 B “4 15 19 20 21 2 23 4 25 26 3.23 4, PLAINTIFFS LAKEISHA AND BOBBY WILSON JR 3.24 Lakeisha and Bobby Wilson Jr were tired of living in apartments with their children and hired a realtor by the name of Linnea Lavell to help them find a rental house in the Dallas, Texas area. 3.25 Ms. Lavell convinced the Wilsons to contact Ahndrea Blue and the Making @ Difference Foundation. 3.26 Afraid they made too much money to qualify, Ms. Wilson relayed her concerns to Ms, Blue, 3.27 Ms. Blue told the Wilsons to “apply anyway” and that their rent payments would bbe determined by their income and that they would be provided with credit repair services, credit counseling, financial budgeting counseling, and that these services would enable the Wilsons to purchase the home in two years’ time. 3.28 The Wilsons moved into the house on March 1, 2013. 3.29 Upon moving in the Wilsons discovered that the heat and air conditioning did not work. COMPLAINT FOR MONEY DAMAGES -7 Jacob B. Smit ‘Ms. Blue’s behavior caused the Flowers to experience much emotional trauma, financial devastation, and damaged credit and renter history with an eviction that did not meet the requirements of the Residential Landlord Tenant Act (RLTA). ‘The Law Offices of Jacob B. Smit 1201 Pacific Ave Suite 60 ‘Tacoma, WA 98407 P: 253-271-6618/F: 253-271-661! "[email protected]10 2 B 4 15 16 18 19 20 2 22 23 24 25 6 3.30 331 3.33 a. Negligence 4d PlaintiffS re-allege the paragraphs set forth above and below this complaint. 42 Defendants had a duty to use ordinary care not to harm Plaintiffs physically, emotionally, financially, or otherwise. 43 Defendants breached that duty as can be seen from the facts described above and below in this complaint. COMPLAINT FOR MONEY DAMAGES - 8 Jacob B. Smit ‘Ms, Blue threatened to evict the Wilsons unless they accepted the unit without heat or air conditioning and ultimately forced them to partake in a scheme devised by Ms. Blue to defraud a warranty company or face eviction. Because of the condition of the house and because Ms. Blue did not keep her word that the Wilsons’ rent payments would be based on income, they were forced to move back into apartments. ‘The Wilsons were ultimately charged for money they did not owe, harassed mercilessly by Ms. Blue, their credit reports were damaged by Ms. Blue and her wrongful accusations, and they were ultimately sued in small claims court among] other things. MS. Blue's behavior caused the Wilsons to experience much emotional trauma, financial devastation, and damaged credit and renter history IV. CAUSES OF ACTION ‘The Law Offices of Jacob B. Smit 1201 Pacific Ave Suite ‘Tacoma, WA 984 : 253-271-6618/F: 253-271-661 [email protected]{10 uu 2 B “4 1s 16 ” 18 19 20 21 2 23 24 25 26 44 b. Negligent Infliction of Emotional 43 Plaintiffs re-allege the paragraphs set forth above and below 46 ‘Abndrea Blue and the Making a Difference Foundation recklessly caused and continues to cause every plaintiff in this case to receive severe emotional distress by Ms. Blue’s extreme and outrageous conduct. 4r ‘Ms, Blue and the Making a Difference Foundation had a duty not to engage in reckless conduct which caused severe emotional distress to the plaintifs 48 MSs, Blue's and the Making a Difference Foundation’s actions directly and indirectly caused and still cause the plaintiffs to experience severe emotional distress and such results were easily foreseeable based on Defendants’ extreme and reckless conduct. 49 Plaintiffs” have experienced much pain and anguish due to the conduct of Defendants and have incurred damages asa result, in an amount to be proven at ¢. Negligent Misrepresentation 4.10. Plaintiffs re-allege the paragraphs set forth above and below ‘COMPLAINT FOR MONEY DAMAGES -9 Jacob B. Smit Because of Defendants’ breach of these duties, Plaintifis' incurred many injuries in an amount to be determined at trial. ‘The Law Offices of Jacob 8. Sm 1201 Pacific Ave Suite 60 Tacoma, WA 9840 P:253-271-6618IF: 253-271-661 jacobamithGjbsmithlav.con}10 u 2 B “4 16 ” 18 19 20 2 2 2 4 25 26 4 42 413 414 4as 4.16 d. Consumer Protection Act (RCW 19.86) 447 COMPLAINT FOR MONEY DAMAGES - 10 Jacob B. Smit ‘Ahndrea Blue and the Making a Difference Foundation misrepresented the natur of the Making a Difference Foundation, misrepresented what it could do to help the Plaintiffs, what it would do to help the Plaintiffs, the costs ofthe program, the legal structure of the program, the integrity of the program, and many more aspects of the program to be proven at trial. ‘Al ofthese misrepresentations were made by Ahndrea Blue and the Making a Difference Foundation in their business and professional capacities. Andrea Blue and the Making a Difference Foundation owed the Plaintiffs @ duty not to misrepresent the aspects of the company or the alleged program. ‘Ahndrea Blue and the Making a Difference Foundation breached their duties to plaintiff by engaging in the behavior described above and below in this complaint ‘The Plaintiffs justifiably relied on Ahndrea Blue’s representations because she ‘was the owner of the Making a Difference Foundation and is or was a licensed, attomey in the State of Washington. ‘Ahndrea Blue’s and the Making a Difference Foundation’s misrepresentations caused the Plaintiffs to be harmed in an amount to be proven at tral. Plaintiffs re-allege the paragraphs set forth above and below ‘The Law Offices of Jacob B. Smit 1201 Pacific Ave Suite 6 ‘Tacoma, WA 984 $3-271-6618/F: 253-271-661 [email protected]10 2 B 4 15 16 v7 20 ai 23 2s 26 4.18 419 420 421 422 e. Outrage (Intentional Infliction of Emotional Distress) 423 Plaintiffs re-allege the paragraphs set forth above and below in this complaint. COMPLAINT FOR MONEY DAMAGES - 11 Jacob B. Smit ‘The Law Offices of Jacob B. Smit 1201 Pacific Ave Suite 6 ‘Tacoma, WA 984 Abndrea Blue and the Making a Difference Foundation engaged in unfair and or deceptive acts or practices as shown by the facts set forth above and below complaint. ‘Alndrea Blue and the Making a Difference Foundation are and were engaging in trade or commerce in that the Making a Difference Foundation was advertised as a program and a non-profit company instead of a typical landlord/tenant relationship and Ahndrea Blue explicitly told all the plaintiffs that the Making a Difference Foundation was a program and she is not their landlord in the typical sense and that they were instead participants in a company program. negatively affects the public interest by taking advantage of this country’s veterans who are often in their most vulnerable state after serving the country in the armed forces, both financially and mentally. fs were injured by Ahndrea Blue and the Making a Difference Foundation’s actions both financially and mentally/emotionally. ‘Abndrea Blue and the Making a Difference Foundation’s unfair and or deceptive ‘cts caused the injuries to Plaintiffs described above and below in this complaint in an amount to be proven at trial :252-271-6618/F 253-271-661 [email protected]10 2 B 4 16 i 18 19 20 21 2 2B 4 25 26 4.24 4.25 4.26 f. Intentional Misrepresentation 427 Plaintiffs re-allege the paragraphs set forth above and below 428 _Abndrea Blue and the Making a Difference Foundation misrepresented the nature of the Making a Difference Foundation, misrepresented what it could do to help the Plaintiffs, what it would do to help the Plaintiffs, the costs of the program, the legal structure of the program, the integrity ofthe program, and many more aspects of the program to be proven at trial 4.29 This misrepresentation materially affected the Plaintiffs’ decisions concerning, “the program.” 430 All of these misrepresentations were made by Ahndrea Blue and the Making a Difference Foundation in their business and professional capacities and most or all of these representations were false. 431 Defendants knew that their representations were false. ‘COMPLAINT FOR MONEY DAMAGES - 12 Jacob B. Smit Ahndrea Blue and the Making a Difference Foundation engaged in acts described above and below in this complaint that consist of extreme and outrageous conduct. Defendants intentionally and or recklessly caused Plaintiffs’ to suffer severe emotional distress. Plaintiffs were the object of Defendants” actions and such actions caused the PlaintiffS to incur damages of an amount to be proven at trial. ‘The Law Offices of Jacob B. Smit 1201 Pacific Ave Suite 60 ‘Tacoma, WA 98407 P:253-271-6618/P: 253-271-661 [email protected]2 B “4 16 W 18 9 4 25 26 433 434 435 436 437 438 g Residential Landlord Tenant Act (RLTA) 439 Plaintifis re-allege all facts described above and below in this complaint 4.40 Defendants’ had a duty to abide by the provisions of the RLTA statute, 4a Defendants’ broke many laws under the RLTA in their handling of the Plaintiffs’ situations and breached that duty to the Plaintiffs as a result. ‘COMPLAINT FOR MONEY DAMAGES - 13 Jacob B. Si Defendants” representations were intended to induce reliance on the part of the Plaintiffs. Plaintiffs were not aware of the falsity of Defendants’ representations. Plaintiffs" justifiably relied upon Defendants’ representations, ‘Ahndsea Blue and the Making a Difference Foundation owed the Plaintiffs a du not to misrepresent the aspects of the company or the alleged program, ‘Ahndrea Blue and the Making a Difference Foundation breached their duties to plaintiff by engaging in the behavior described above and below in this complain} ‘The Plaintiffs justifiably relied on Ahndrea Blue’s representations because she ‘was the owner of the Making a Difference Foundation and is or was a licensed attomey in the State of Washington, Ahndrea Blue’s and the Making a Difference Foundation’s misrepresentations caused the Plaintiffs to be harmed in an amount to be proven at tral ‘The Law Offices of Jacob B. Smit 1201 Pacific Ave Suite 60 ‘Tacoma, WA 98407 P: 253-271-6618/F: 253-271-661 {[email protected]}“4 1s 16 7 18 19 20 a 2 2B 4 25 6 442 Defendants tried to circumvent the RLTA by having the Plaintiffs sign illegal contracts waiving the provisions of the RLTA which is expressly prohibited by statute, 4.43 Defendants’ breaking of the RLTA rules caused the Plaintiffs to incur many injuries in an amount to be determined at trial. V. PRAYER FOR RELIEF WHEREFORE, Plaintiffs pray for judgment against Defendants jointly and severally as follows: ‘A. For money judgment in an amount to be proven at the time of tral to fairly ‘compensate Plaintiffs for their injuries and damages; B. For Plaintiffs’ attomey fees and costs incurred herei C. For pre-judgment interest atthe statutory rate on all items of special damage including, without limitation, expenses of medical care and treatment, and lost wages| D, For such other relief as the Court deems just and equitable. _18__ day of December, 2014. s/ Jacob Smith ‘Jacob B. Smith, WSBA #45482 Attorney for Plaintiff COMPLAINT FOR MONEY DAMAGES - 14 ‘The Law Offices of Jacob B. Smit 1201 Pacific Ave Suite 60 ‘Tacoma, WA 98404 : 253-271-6618/F: 253-271-661: [email protected]