Stay of Enforcement Request (Administrative Agency) - Washington

STAY OF ENFORCEMENT REQUEST — WASHINGTON

TABLE OF CONTENTS

1. Stay Request Cover Letter
2. Petition/Motion for Stay of Enforcement
3. Statement of Facts
4. Legal Standard for Stay
5. Grounds Analysis (Four-Factor Test)
6. Bond/Security Provisions
7. Emergency Stay Procedures
8. Opposition Response Template
9. Proposed Order
10. Appeal of Stay Denial
11. Document Checklist
12. Practice Tips
13. Sources and References

1. STAY REQUEST COVER LETTER

[FIRM NAME / ATTORNEY NAME]
[________________________________]
[________________________________]
[________________________________]
Telephone: [________________________________]
Email: [________________________________]
WSBA No.: [________________________________]

[__/__/____]

[☐ [Agency Name], [________________________________]]
[☐ Clerk, [________________________________] County Superior Court, [________________________________]]

Re: Petition for Stay of Enforcement
Case/Docket No.: [________________________________]
In the Matter of: [________________________________]

Dear [________________________________]:

Enclosed please find the Petition for Stay of Enforcement filed on behalf of [________________________________] ("Petitioner") in connection with the above-referenced matter. Petitioner respectfully requests that the [Agency / Court] stay enforcement of the [Final Order / Decision / Agency Action] of [Agency Name] dated [__/__/____] pending [☐ agency review under RCW 34.05.467 / ☐ judicial review under RCW 34.05.550].

This petition is being filed with [☐ the agency / ☐ the reviewing court] because [________________________________].

Respectfully submitted,

________________________________________
[Attorney Name], WSBA No. [________________________________]
Attorney for Petitioner

2. PETITION/MOTION FOR STAY OF ENFORCEMENT

A. PETITION TO AGENCY FOR STAY (RCW 34.05.467)

BEFORE [AGENCY NAME]

STATE OF WASHINGTON

In the Matter of:

[________________________________],
Petitioner.

Docket No.: [________________________________]

PETITION FOR STAY OF EFFECTIVENESS OF FINAL ORDER

Petitioner [________________________________], by and through undersigned counsel, petitions [Agency Name] for a stay of effectiveness of the Final Order entered on [__/__/____], pursuant to RCW 34.05.467 and [applicable agency rules], and in support thereof states as follows:

I. INTRODUCTION

1. On [__/__/____], [Agency Name] entered a Final Order (the "Order") in this matter that:

☐ Revoked Petitioner's [license / permit / certification / registration]
☐ Suspended Petitioner's [license / permit / certification / registration] for [____] [days / months / years]
☐ Imposed a civil penalty of $[________________________________]
☐ Ordered Petitioner to [________________________________]
☐ Denied Petitioner's application for [________________________________]
☐ Other: [________________________________]

2. This petition is filed within ten (10) days of service of the Final Order, as required by RCW 34.05.467.

3. Petitioner requests that the Order be stayed [☐ in its entirety / ☐ in part, as described below] pending [☐ administrative review / ☐ petition for judicial review / ☐ reconsideration].

II. PARTIES

4. Petitioner [________________________________] is a [individual / corporation / limited liability company / partnership / licensee / permit holder] with a principal [address / place of business] at [________________________________], Washington.

5. [Agency Name] is a state agency of the State of Washington, with offices at [________________________________].

III. TIMELINESS

6. The Final Order was served on Petitioner on [__/__/____].

7. This Petition for Stay is filed on [__/__/____], which is within ten (10) days of service, as required by RCW 34.05.467.

B. MOTION TO REVIEWING COURT FOR STAY (RCW 34.05.550)

IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON

IN AND FOR [________________________________] COUNTY

[________________________________],
Petitioner,

v.

[________________________________],
Respondent.

Cause No.: [________________________________]

MOTION FOR STAY OF ENFORCEMENT PENDING JUDICIAL REVIEW

Petitioner [________________________________], by and through undersigned counsel, moves this Court for an order staying enforcement of the [Final Order / Decision / Agency Action] of [Agency Name] dated [__/__/____] pending judicial review of the Order pursuant to RCW 34.05.550, and in support thereof states:

I. INTRODUCTION

8. On [__/__/____], Petitioner filed a Petition for Judicial Review of the Final Order of [Agency Name] with this Court pursuant to RCW 34.05.510 et seq.

9. The Order is currently in effect [☐ and enforcement is underway / ☐ and enforcement is scheduled for [__/__/____] / ☐ but the agency has not yet begun enforcement].

10. [☐ Petitioner previously petitioned the agency for a stay under RCW 34.05.467, and the agency [denied the petition on [__/__/____] / granted a partial stay / failed to act within the statutory period] / ☐ Petitioner did not petition the agency for a stay because: ________________________________]

11. Petitioner now seeks a stay from this Court under RCW 34.05.550.

3. STATEMENT OF FACTS

A. Background

12. [Provide detailed factual background regarding the regulated activity, Petitioner's history, and the circumstances of the case.]

[________________________________]
[________________________________]
[________________________________]

B. The Administrative Proceeding

13. On [__/__/____], [Agency Name] [initiated proceedings / issued a statement of charges / served a notice of violation] against Petitioner regarding [________________________________].

14. [☐ An adjudicative proceeding (hearing) was conducted on [__/__/____] before [an administrative law judge / hearing officer / presiding officer / agency head] / ☐ The matter was decided on the record without a hearing / ☐ Petitioner waived the right to a hearing].

15. On [__/__/____], the [ALJ / presiding officer / agency head] entered the Final Order. A true and correct copy of the Order is attached as Exhibit [____].

C. Impact of Enforcement

16. If enforcement is not stayed, Petitioner will suffer the following:

☐ Immediate loss of [license / permit / certification] effective [__/__/____]
☐ Obligation to pay $[________________________________] in penalties by [__/__/____]
☐ Cessation of [business / professional practice / operations] effective [__/__/____]
☐ Other: [________________________________]

17. The expected duration of judicial review is approximately [____] months.

4. LEGAL STANDARD FOR STAY

A. Agency Stay — RCW 34.05.467

RCW 34.05.467 provides that any party may submit to the reviewing officer a petition for stay of effectiveness of a final order within ten (10) days of its service. The agency may grant a stay if it determines that justice requires it.

Key provisions:

• The petition must be filed within 10 days of service of the final order
• The agency has discretion to grant or deny the stay
• The agency may impose conditions on any stay it grants
• If the agency does not act on the petition, the stay is denied by operation of law

B. Judicial Stay — RCW 34.05.550

RCW 34.05.550 provides that after a petition for judicial review has been filed, a party may file a motion in the reviewing court seeking a stay or other temporary remedy. The statute sets forth different standards depending on the nature of the agency action.

Standard for Stay of Agency Action Based on Public Health, Safety, or Welfare:

If judicial relief is sought from agency action taken on the basis of public health, safety, or welfare, the court shall not grant the stay unless the court finds:

1. Likelihood of success — The applicant is likely to prevail when the court finally disposes of the matter.

2. Irreparable injury — Without relief, the applicant will suffer irreparable injury.

3. No substantial harm to others — The grant of relief to the applicant will not substantially harm other parties to the proceedings.

4. Public interest — The threat to the public health, safety, or welfare relied upon by the agency is not sufficiently serious to justify the agency's action in the circumstances.

Standard for Stay of Other Agency Action:

For agency actions not based on public health, safety, or welfare, the court has broader discretion and generally applies the traditional four-factor balancing test.

C. Agency Authority to Stay — RCW 34.05.550(1)

Agencies may grant a stay, in whole or in part, or other temporary remedy, unless precluded by law. This authority exists independently of the court's authority.

D. Court's Authority to Review Agency Stay Decisions — RCW 34.05.550(3)

If the court determines that relief should be granted from the agency's action granting or denying a stay, the court may remand the matter to the agency or may enter its own order granting or denying the stay on appropriate terms.

5. GROUNDS ANALYSIS (FOUR-FACTOR TEST)

A. Likelihood of Success on the Merits

18. Petitioner is likely to prevail on judicial review because:

☐ The Order is not supported by substantial evidence when reviewed in light of the whole record. RCW 34.05.570(3)(e).
☐ The agency erroneously interpreted or applied the law. RCW 34.05.570(3)(d).
☐ The Order was made upon unlawful procedure or failure to follow a prescribed process. RCW 34.05.570(3)(c).
☐ The Order is outside the statutory authority of the agency. RCW 34.05.570(3)(b).
☐ The Order violates constitutional provisions. RCW 34.05.570(3)(a).
☐ The Order is arbitrary or capricious. RCW 34.05.570(3)(i).
☐ The agency action is clearly erroneous in view of the entire record as submitted. RCW 34.05.570(3)(e).
☐ The Order is inconsistent with the agency's own rules or prior decisions without adequate explanation.
☐ Other: [________________________________]

19. Specifically, [________________________________]
    [________________________________]
    [________________________________]

B. Irreparable Injury

20. Petitioner will suffer irreparable injury without a stay because:

☐ Loss of Petitioner's [license / permit / certification] will eliminate Petitioner's ability to engage in [his/her/its] [profession / trade / business], which cannot be adequately compensated by monetary damages
☐ Petitioner's business will be forced to close, causing permanent and irreversible loss of [employees / customers / goodwill / market position / vendor relationships]
☐ The monetary penalty of $[________________________________] will cause [insolvency / bankruptcy / inability to continue operations / inability to fund the judicial review]
☐ Petitioner will suffer permanent reputational harm in [the community / the profession / the industry]
☐ Enforcement will trigger [collateral consequences / additional regulatory actions / loss of related licenses or permits]
☐ Petitioner will lose [time-sensitive contracts / professional affiliations / certifications] that cannot be recovered after judicial review
☐ Other: [________________________________]

21. The injury is irreparable because: [________________________________]

C. No Substantial Harm to Other Parties

22. Granting the stay will not substantially harm other parties because:

☐ The agency will suffer no material harm from a temporary delay in enforcement
☐ No third parties have identified specific harms from a stay
☐ Petitioner is willing to comply with conditions that protect third-party interests
☐ The status quo can be maintained without creating new risks
☐ The underlying enforcement action does not involve identified victims or injured parties
☐ The regulatory objectives can be addressed through interim conditions
☐ Other: [________________________________]

D. Public Interest / Threat Assessment

23. The stay is consistent with the public interest because:

If the agency action was based on public health, safety, or welfare:

☐ The threat to public health, safety, or welfare relied upon by the agency is not sufficiently serious to justify the agency's action in the circumstances because: [________________________________]
☐ The alleged threat has been [mitigated / resolved / overstated] because: [________________________________]
☐ Conditions of the stay can adequately address any residual threat: [________________________________]

For all other cases:

☐ No immediate threat to public health, safety, or welfare exists
☐ The public interest is served by judicial review before enforcement of a contested order
☐ Petitioner provides valuable services to the community: [________________________________]
☐ Enforcement pending review would [eliminate access to services / harm consumers / reduce competition / have other adverse consequences]
☐ Other: [________________________________]

6. BOND/SECURITY PROVISIONS

A. Court's Authority to Impose Conditions

RCW 34.05.550 authorizes the court to grant a stay "on appropriate terms," which may include the posting of bond or other security.

B. Petitioner's Bond Proposal

24. Petitioner [☐ offers / ☐ does not offer] to post bond or other security as a condition of the stay:

☐ Surety bond in the amount of $[________________________________]
☐ Cash deposit with the Clerk of the Court in the amount of $[________________________________]
☐ Irrevocable letter of credit in the amount of $[________________________________]
☐ Other form of security: [________________________________]
☐ Petitioner requests waiver of bond because: [________________________________]

C. Bond Amount Considerations

25. In setting the bond amount, the Court should consider:

• The nature and amount of any monetary penalty imposed
• The potential harm to the agency or third parties during the stay
• Petitioner's financial capacity
• The likelihood of success on the merits
• The expected duration of the judicial review
• The availability of other conditions to protect against harm

D. Proposed Conditions

26. Petitioner is willing to comply with the following conditions during the stay period:

☐ Continued compliance with all applicable statutes, rules, and regulations not at issue in this review
☐ Practice or operational restrictions: [________________________________]
☐ Supervision or monitoring by [________________________________]
☐ Periodic reporting to the agency at [____]-day intervals
☐ Maintenance of [insurance / financial reserves / safeguards]
☐ Limitation on [scope of practice / business activities]: [________________________________]
☐ Cooperation with agency inspection or monitoring
☐ Other conditions: [________________________________]

7. EMERGENCY STAY PROCEDURES

A. Emergency Motion for Temporary Stay

When enforcement is imminent, file the following:

EMERGENCY MOTION FOR TEMPORARY STAY OF ENFORCEMENT

Petitioner [________________________________] moves this [Court / Agency] on an emergency basis for a temporary stay of enforcement of the [Final Order / Decision] of [Agency Name] dated [__/__/____], and in support thereof states:

27. The Order takes effect on [__/__/____], which is [____] days from today.

28. There is insufficient time to obtain a full hearing on the Motion for Stay before the Order takes effect.

29. Petitioner will suffer immediate and irreparable harm if the Order is not temporarily stayed, specifically: [________________________________]

30. There is a substantial likelihood that Petitioner will prevail on judicial review.

31. A brief temporary stay will not cause harm to the agency, to other parties, or to the public.

32. Petitioner requests [☐ an emergency hearing / ☐ a temporary restraining order under CR 65 / ☐ immediate consideration of this motion].

B. Temporary Restraining Order Under CR 65

In emergency situations, Petitioner may seek a temporary restraining order under Washington Superior Court Civil Rule 65:

☐ Application showing specific facts demonstrating immediate and irreparable injury
☐ Security/bond as required by CR 65(c)
☐ Certification of efforts to provide notice to opposing party
☐ TRO limited to 14 days (extendable for additional 14 days for good cause)
☐ Hearing on preliminary injunction scheduled within 14 days

C. Agency Emergency Stay

Under RCW 34.05.467, Petitioner may petition the agency for a stay within 10 days of service of the Final Order. For emergency situations:

☐ File the petition immediately upon service of the Order
☐ Request expedited consideration by the reviewing officer
☐ Identify the specific urgency and irreparable harm
☐ Propose conditions that address the agency's concerns
☐ If the agency does not act promptly, proceed to the reviewing court

D. Ex Parte Application

33. If ex parte relief is sought, Petitioner must demonstrate:

☐ Immediate and irreparable harm will result before the adverse party can be heard
☐ The applicant or counsel certifies the efforts made to give notice and the reasons notice should not be required
☐ Security/bond as directed by the Court

8. OPPOSITION RESPONSE TEMPLATE

IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON

IN AND FOR [________________________________] COUNTY

Cause No.: [________________________________]

RESPONSE IN OPPOSITION TO MOTION FOR STAY OF ENFORCEMENT

Respondent [________________________________] ("Agency"), by and through its attorney, [________________________________], respectfully opposes Petitioner's Motion for Stay of Enforcement and responds as follows:

I. FACTUAL RESPONSE

34. The Agency's Final Order was based on the following findings: [________________________________]

35. The enforcement action [is / is not] based on public health, safety, or welfare. The specific basis is: [________________________________]

II. ARGUMENT

A. No Likelihood of Success

36. Petitioner is unlikely to prevail on judicial review because: [________________________________]

B. No Irreparable Injury

37. Petitioner's alleged injury is [speculative / compensable by monetary relief / self-inflicted / the ordinary consequence of lawful enforcement] because: [________________________________]

C. Substantial Harm to Other Parties

38. A stay would substantially harm [consumers / patients / the public / other parties] because: [________________________________]

D. Public Interest Requires Enforcement

39. (If action based on public health, safety, or welfare): The threat to public [health / safety / welfare] is sufficiently serious to justify the agency's action because: [________________________________]

(For all cases): The public interest requires enforcement because: [________________________________]

III. RELIEF REQUESTED

40. The Agency respectfully requests that the Motion for Stay be denied [☐ in its entirety / ☐ or, in the alternative, conditioned upon ________________________________].

9. PROPOSED ORDER

IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON

IN AND FOR [________________________________] COUNTY

Cause No.: [________________________________]

ORDER ON MOTION FOR STAY OF ENFORCEMENT

THIS MATTER having come before the Court on Petitioner's Motion for Stay of Enforcement pursuant to RCW 34.05.550, and the Court having considered the motion, [the Agency's response], [the administrative record], and [arguments of counsel / declarations submitted], the Court finds and orders as follows:

FINDINGS

1. The agency action [is / is not] based on public health, safety, or welfare.
2. Petitioner [has / has not] demonstrated a likelihood of success on judicial review.
3. Petitioner [will / will not] suffer irreparable injury absent a stay.
4. Granting the stay [will / will not] substantially harm other parties.
5. [If applicable:] The threat to public [health / safety / welfare] [is / is not] sufficiently serious to justify the agency's action in the circumstances.

ORDER

IT IS HEREBY ORDERED that:

☐ STAY GRANTED: The [Final Order / Decision] of [Agency Name] dated [__/__/____] is STAYED pending [judicial review / final resolution of this matter / further order of this Court], subject to the following terms:

• Duration: The stay shall remain in effect until [final judgment / [__/__/____] / further order of this Court].
• Bond: Petitioner shall post a [surety bond / cash deposit] in the amount of $[________________________________] within [____] days.
• Conditions: [________________________________]

☐ STAY DENIED: The Motion for Stay is DENIED for the following reasons: [________________________________]

☐ STAY GRANTED IN PART: [________________________________]

☐ REMANDED TO AGENCY: The Court remands this matter to [Agency Name] to [grant / reconsider] the stay on the following terms: [________________________________]

DATED this [____] day of [________________], [________].

________________________________________
Judge, Superior Court
[________________________________] County, Washington

10. APPEAL OF STAY DENIAL

A. Options After Denial of Stay

If the Motion for Stay is denied, Petitioner may consider:

☐ Motion for Reconsideration — File within the time period allowed by local court rules, presenting additional evidence or arguments.

☐ Discretionary Review by Court of Appeals — Under RAP 2.3, seek discretionary review of the interlocutory order denying the stay. This requires demonstrating that the trial court committed obvious error that renders further proceedings useless, or that the order involves a controlling question of law.

☐ Emergency Motion to Court of Appeals — In extraordinary circumstances, seek emergency relief directly from the Court of Appeals.

☐ Modified Stay Application — File a renewed motion with additional conditions, a larger bond, or a more limited scope.

☐ Expedited Review — Request expedited briefing and hearing on the merits of the petition for judicial review.

☐ Return to Agency — If the court denies the stay but identifies conditions under which a stay would be appropriate, petition the agency to grant a stay with those conditions.

B. Court of Appeals Review

41. Under RAP 2.3, the Court of Appeals accepts discretionary review of interlocutory orders in the following circumstances:

☐ The trial court committed obvious error that renders further proceedings useless (RAP 2.3(b)(1))
☐ The trial court committed probable error and the order substantially alters the status quo (RAP 2.3(b)(2))
☐ The order involves a controlling question of law as to which there is substantial ground for difference of opinion (RAP 2.3(b)(4))

11. DOCUMENT CHECKLIST

Filing with the Agency (RCW 34.05.467)

☐ Petition for Stay of Effectiveness of Final Order — filed within 10 days of service
☐ Supporting declaration or affidavit
☐ Copy of the Final Order
☐ Proof of service on all parties
☐ Proposed conditions for the stay

Filing with the Reviewing Court (RCW 34.05.550)

☐ Motion for Stay of Enforcement — completed and signed
☐ Memorandum/brief in support of stay
☐ Declaration or affidavit of Petitioner detailing irreparable harm
☐ Petition for Judicial Review (filed or to be filed concurrently)
☐ Copy of the Final Order being challenged
☐ Copy of the agency's denial of stay (if applicable)
☐ Proposed order granting the stay
☐ Bond or security documents (if offering)
☐ Certificate of service
☐ Filing fee (if applicable)

Supporting Documentation

☐ Declaration of Petitioner with specific facts showing irreparable harm
☐ Financial records demonstrating economic impact
☐ Business records showing revenue, employees, contractual obligations
☐ Evidence of compliance history
☐ Expert declarations (if applicable)
☐ Evidence of efforts to resolve the matter with the agency
☐ Copies of relevant statutes (RCW 34.05.467, 34.05.550, 34.05.570)
☐ Copies of applicable agency rules (WAC)
☐ Administrative record (or relevant portions)

Service Requirements

☐ Serve the agency (through the Attorney General's office for state agencies)
☐ Serve all other parties of record
☐ File proof of service
☐ Comply with Washington Superior Court Civil Rules for motion practice
☐ Comply with local court rules

12. PRACTICE TIPS

Timing and Strategy

• 10-day agency stay deadline: Under RCW 34.05.467, the petition for stay of a final order must be filed with the agency within 10 days of service. This is a strict deadline. File as early as possible.

• Agency first: Washington's APA contemplates that stays will generally be sought from the agency first (RCW 34.05.467) before seeking judicial relief (RCW 34.05.550). While not always required, seeking an agency stay first strengthens any subsequent court application.

• Judicial review petition: File the Petition for Judicial Review within 30 days of service of the final order under RCW 34.05.542(2). The motion for stay in the reviewing court can only be filed after the petition for judicial review has been filed.

• Dual filing: Consider filing the agency stay petition and preparing the court motion simultaneously if the agency is unlikely to grant the stay.

Substantive Considerations

• Public health/safety/welfare actions: RCW 34.05.550(2) imposes a heightened standard for stays of agency action based on public health, safety, or welfare. The court must find that the applicant is likely to prevail, will suffer irreparable harm, the stay will not substantially harm others, AND the public threat is not sufficiently serious to justify the action. This is a difficult standard to meet.

• Other actions: For agency actions not based on public health, safety, or welfare, the court has broader discretion and applies the traditional four-factor balancing test.

• Scope of review: On judicial review, the court may find the agency action unlawful under any of the grounds listed in RCW 34.05.570(3). Identify the strongest grounds when arguing likelihood of success.

• Court remand authority: Under RCW 34.05.550(3), if the court determines that relief should be granted from the agency's denial of a stay, it may remand to the agency with instructions to grant the stay on appropriate terms.

Bond and Security

• Washington's APA does not specify bond amounts for administrative stays. The court has discretion to impose bond as a condition of the stay.
• For monetary penalties, consider proposing a bond in an amount that secures the penalty amount.
• Financial hardship evidence can support a request for reduced bond or waiver.

Common Pitfalls

• Missing the 10-day deadline for filing the agency stay petition under RCW 34.05.467.
• Missing the 30-day deadline for filing the Petition for Judicial Review under RCW 34.05.542.
• Failing to distinguish between the standard for public health/safety/welfare actions and other actions when briefing RCW 34.05.550.
• Neglecting to address all four factors of the stay analysis.
• Filing the motion for judicial stay before filing the Petition for Judicial Review.
• Failing to serve the Attorney General for proceedings against state agencies.

Washington-Specific Considerations

• Venue for Judicial Review: Under RCW 34.05.514, the petition for judicial review must be filed in [Thurston County Superior Court / the county in which the agency action occurred / the county in which the petitioner resides or has a principal place of business], depending on the specific statute.
• Model Rules of Procedure: WAC 10-08 contains model rules that many Washington agencies adopt. Check whether the agency has adopted these rules or has its own procedural rules.
• Attorney General Representation: The Attorney General represents most state agencies in judicial review proceedings. Serve papers on the AG's office and coordinate accordingly.
• Order Effectiveness: Under RCW 34.05.473, an agency order is not effective until it is served on the parties and all prehearing requirements have been met. Verify that the order is actually effective before filing a stay petition.

13. SOURCES AND REFERENCES

• Washington Administrative Procedure Act (RCW Chapter 34.05)
• § 34.05.467: Stay of Agency Action — Administrative Review
• § 34.05.473: Effectiveness of Orders
• § 34.05.510-34.05.598: Judicial Review
• § 34.05.514: Petition for Judicial Review
• § 34.05.542: Time for Filing Petition
• § 34.05.550: Stay and Other Temporary Remedies
• § 34.05.570: Scope of Review
• Washington Administrative Code (WAC) 10-08: Model Rules of Procedure
• Washington Superior Court Civil Rules (CR 65 — Injunctions)
• Washington Rules of Appellate Procedure (RAP 2.3 — Discretionary Review)
• Washington State Legislature: https://app.leg.wa.gov
• Washington Attorney General's Office: https://www.atg.wa.gov
• Washington State Courts: https://www.courts.wa.gov

This template is provided for informational purposes only and does not constitute legal advice. Stay of enforcement procedures under the Washington Administrative Procedure Act are governed by RCW 34.05.467 (agency stays) and RCW 34.05.550 (judicial stays), with different standards applying depending on the nature of the agency action. This template must be reviewed, customized, and approved by a qualified attorney licensed in Washington before use. Statutory citations are current as of the date indicated above but should be verified before filing.