The Honorable Barbara Jacobs Rothstein

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UNITED STATES DISTRICT COURT FOR THE
WESTERN DISTRICT OF WASHINGTON
AT SEATTLE

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HUMAN RIGHTS DEFENSE CENTER,
No. 3:24-cv-06068-BJR

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Plaintiff,
DEFENDANTS' OFFER OF
JUDGMENT

V.

PACIFIC COUNTY; PACIFIC COUNTY
SHERIFF'S OFFICE; DANIEL GARCIA,
individually and in his official capacity as
Pacific County Sheriff; and MIKE
PARK.ER, individually and in his official
capacity as Commander of the Pacific
County Jail,
Defendants.

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COMES NOW, Defendant Pacific County, pursuant to Fed. R. Civ. P. 68, and hereby

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offer to settle this matter fully and finally for $40,001.00, plus reasonable attorney's fees and

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costs as subsequently determined by the Court on application of the plaintiff, conditioned on

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the taking of judgment against Defendant Pacific County only and the dismissal of all claims

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against all defendants.

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Fed. R. Civ. P. 68 provides: "At least 14 days before the date set for trial, a party

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defending against a claim may serve on an opposing party an offer to allow judgment on

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specified terms, with the costs then accrued." Fed. R. Civ. P. 68(a) (emphasis added).

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Therefore, this offer is contingent upon the following specified terms:

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FIRST, Plaintiff shall take judgment against Defendant Pacific County only, dismiss
DEFENDANTS ' OFFER OF JUDGMENT - 1
3 :24-cv-06068-BJR

LAW LYMAN DANIEL KAMERRER &
BOGDANOVICH, P.S.
A ITORNEYS AT LA W
2674 RW JOHNSON RD .
TUMWATER, WASHINGTON 98512
PHONE: (360) 754-3480
FAX: (360) 357-3511

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all claims against the individual defendants Daniel Garcia and Mike Parker, and agree to

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execute and authorize the entry of a Stipulation for and Order of Dismissal with Prejudice in

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the form attached hereto as Appendix A. Additionally, as a condition of settlement, Defendant

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Pacific County will agree to subscribe to one copy ofHRDC' s Prison Legal News Publication

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and place said publications in the Pacific County Jail library where it can be accessed by all

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inmates.

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SECOND, pursuant to the rule, an amount of reasonable attorney's fees and costs shall

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be subsequently determined by this Court upon application by the plaintiff. 42 U.S.C. § 1988.

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Defendants reserve their right to object to and contest any such application.

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THIRD, this offer of judgment is a settlement offer, made for the sole purposes

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specified in Fed. R. Civ. P. 68, is meant to amicably resolve this matter without devoting the

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resources that would be necessary to contest the matter and claimed damages, and is not to

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be construed or characterized either as an admission that any Defendant is liable in this action

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or committed any unlawful act, or that the plaintiff has suffered any damages, and that said

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judgment herein will have no effect whatsoever except in settlement of this case.

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This offer shall remain open for a period of fourteen (14) days after service, at which

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time it will be automatically deemed withdrawn. Acceptance of the offer must be indicated

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in writing served on counsel of record below.

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DATED: June 16, 2025
LAW LYMAN DANIEL KAMERRER &
BOGDANOVICH

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Michael Throgmorton, WSBA # 44263
Erin L. Hillier, WSBA #42883
Attorneys for Defendant Pacific County
PO Box 11880
Olympia, WA 98508
Telephone: 360.754.3480
Email: rnthrogmorton@1ldkb.com
Email: ehillier@lldkb.com

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DEFENDANTS ' OFFER OF JUDGMENT - 2
3 :24-cv-06068-BJR

LAW LYMAN DANIEL KAMERRER &
BOGDANOVICH, P.S.
ATTORNEYS AT LAW
2674 RW JOHNSON RD
TUMWATER, WASHINGTON 985 12
PHONE: (360) 754-3480
FAX: (360) 357-3511

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CERTIFICATE OF SERVICE

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I certify, under penalty of perjury, under the laws of the United States, that on this

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date, I caused to be served the foregoing document, and this Certificate of Service, upon the

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parties below via email as noted in accordance with the parties e-service agreement:

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Counsel for Plaintiff:
Jesse Wing
Katherine C. Chamberlain
Nathaniel Flack
MacDONALD HOAGUE & BAYLESS
705 Second Avenue, Suite 1500
Seattle, WA 98104
jessew(a),mhb.com
katherinec(a),mhb .com
nathanielf@,mhb.com

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Counsel for Defendants Garcia and Parker:
Daniel Thenell
Paige Chrz
Thenell Law Group, P.C.
6 Centerpointe Dr., Ste. 450
Lake Oswego, OR 97035-8621
dan<@thenelllawgroup.com
paige<@thenelllawgroup.com

Attorney pro hac vice
Jonathan P. Picard, Fla. Bar# 105477
HUMAN RIGHTS DEFENSE CENTER
P.O. Box 1151
Lake Worth, FL 3 3460
jpicard(cuhurnanrightsdefensecenter.org
DATED this 16th day of June 2025, at Tumwater, WA.

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Isl Tam Truong
Tam Truong, Legal Assistant

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DEFENDANTS' OFFER OF JUDGMENT - 3
3 :24-cv-06068-BJR

LAW LYMAN DANIEL KAMERRER &
BOGDANOVICH, P.S.
A ITORNEYS AT LAW
2674 RW JOHNSON RD.
TUMWATER, WASHINGTON 98512
PHONE: (360) 754-3480
FAX: (360) 357-3511

APPENDIX A

THE HONORABLE BARBARA JACOBS ROTHSTEIN
Trial Date: January 26, 2026
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UNITED STATES DISTRICT COURT FOR THE
WESTERN DISTRICT OF WASHINGTON
AT SEATTLE

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ffiJMAN RIGHTS DEFENSE CENTER,
No. 3:24-cv-06068-DWC
Plaintiff,

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[PROPOSED]
V.

PACIFIC COUNTY; PACIFIC COUNTY
SHERIFF'S OFFICE; DANIEL GARCIA,
individually and in his official capacity as
Pacific County Sheriff; and MIKE
PARKER, individually and in his official
capacity as Commander of the Pacific
County Jail,

STIPULATION FOR DISMISSAL
[CLERK'S ACTION REQUIRED]

Defendants.

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STIPULATION
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It is hereby stipulated and agreed by and between Plaintiff Human Rights Defense
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Center and Defendants Pacific County, Daniel Garcia, and Mike Parker, that all of Plaintiffs

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claims may be dismissed with prejudice as the parties have reached a settlement in this matter.

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Dated: - - - - - -

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LAW LYMAN DANIEL KAMERRER &
BOGDANOVICH, P.S.

Michael J. Throgmorton, WSBA #44263
Erin L. Hillier, WSBA #42883
Attorneys for Defendant Pacific County
2674 RW Johnson Rd. Tumwater, WA 98512
P.O. Box 11880 Olympia, WA 98508-1880
STIPULATION AND ORDER OF DIS:MISSAL - 2
No. 3:24-cv-06068-BJR

LAW LYMAN DANIEL KAMERRER &
BOGDANOVICH, P.S.
ATTORNEYS AT LAW
267 4 RW JOHNSON RD.
TUMWATER, WASHINGTON 98512
PHONE : (360) 754-3480
FAX: (360) 357- 3511

Dated:

MacDonald Hoague & Bayless

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By: _ _ _ _ _ _ _ _ _ _ _ _ _ __
Jesse Wing, WSBA #27751
Katherine C. Chamberlain, WSBA #40014
Nathaniel J. Flack, WSBA #58582
Attorneys for Plaintiff HRDC
705 2 nd Avenue Ste 1500
Seattle, WA 98104-1745

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Dated:

Thenell Law Group, P.C.

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By: _ _ _ _ _ _ _ _ _ _ __
Dan Thenell, WSBA #3 7297
Paige Chrz, WSBA #60512
Attorneys for Defendants Garcia and Parker
6 Centerpointe Dr. Ste 450
Lake Oswego, OR 97035-8621

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STIPULATION AND ORDER OF DISMISSAL - 3
No. 3:24-cv-06068-BJR

LAW LYMAN DANIEL KAMERRER &
BOGDANOVICH, P.S.
ATTORNEYS AT LAW
2674 RW JOHNSON RD
TUMWATER, WASHINGTON 9851 2
PHONE : (360) 754-3480
FAX: (360) 357-35 11

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UNITED STATES DISTRICT COURT FOR THE
WESTERN DISTRICT OF WASHINGTON
AT SEATTLE

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HUMAN RIGHTS DEFENSE CENTER,
No. 3:24-cv-06068-DWC

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Plaintiff,
[PROPOSED]
V.

PACIFIC COUNTY; PACIFIC COUNTY
SHERIFF'S OFFICE; DANIEL GARCIA,
individually and in his official capacity as
Pacific County Sheriff; and MIKE
PAR.KER, individually and in his official
capacity as Commander of the Pacific
County Jail,

ORDER OF DISMISSAL
[CLERK'S ACTION REQUIRED]

Defendants.

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ORDER
Pursuant to the foregoing stipulation, IT IS ORDERED that Plaintiff's claims against
Defendants Pacific County, Daniel Garcia, and Mike Parker, are dismissed with prejudice.
DATED this _ _ _ day of _ _ _ _ _ _ _ _ , 2025.

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BARBARA JACOBS ROTHSTEIN
Senior United States District Court Judge

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STIPULATION AND ORDER OF DISMISSAL - 4
No. 3:24-cv-06068-BJR

LAW LYMAN DANIEL KAMERRER &
BOGDANOVICH, P.S.
A TIORNEYS AT LAW
2674 RW JOHNSON RD
TUMWATER, WASHINGTON 98512
PHONE: (360) 754-3480
FAX: (360) 357-3511

Presented by:
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LAW LYMAN DANIEL KAMERRER &
BOGDANOVICH, P.S.

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By:
Michael J. Throgmorton, WSBA #44263
Erin L. Hillier, WSBA #42883
Attorneys for Defendant Pacific County

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Copy received, approved as to form, and
Notice of Presentation waived:

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MacDonald Hoague & Bayless

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By:
Jesse Wing, WSBA #27751
Katherine C. Chamberlain, WSBA #40014
Nathaniel J. Flack, WSBA #58582
Attorneys for Plaintiff HRDC
Thenell Law Group, P .C.

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By:
Dan Then ell, WSBA #3 7297
Paige Chrz, WSBA #60512
Attorneys for Defendants Garcia and Parker

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STIPULATION AND ORDER OF DISMISSAL - 5
No. 3:24-cv-06068-BJR

LAW LYMAN DANIEL KAMERRER &
BOGDANOVICH, P.S.
A TIORNEYS AT LAW
2674 RW JOHNSON RD.
TUMWATER. WASHINGTON 98512
PHONE: (360) 754-3480
FAX: (360) 357-3511