HomeMy WebLinkAboutStipulation & Order of Dismissal 1
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7 IN PROCEEDINGS BEFORE THE CITY OF RENTON HEARING EXAMINER
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9 IN RE THE WILLIAM FOREMAN CODE COMPLIANCE Code Case No. CODE-17-000526
MATTER
10 Stipulation and Agreed Order of
(401 PeIly Avenue North, Renton, Washington) Dismissal [Proposed]
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STIPULATION
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The parties stipulate as follows.
16 The Property at Issue Is Developed with Two Single Family Dwellings
17 Mr.William Foreman ("Mr. Foreman") owns property addressed as 401 Pelly Avenue
18 North, Renton, Washington, and designated as King County Assessor Parcel Number 722500-
19 0005 (the "Property"). The Property is situated within the limits of the City of Renton (the
20 "City");accordingly,the Property is subject to applicable provisions of the Renton Municipal
21 Code ("RMC").
22 The Property is developed with two residential structures, each of which is classified in
23 City records as a "single family dwelling" land use. Under the RMC, a single family dwelling can
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CODE-17-000526 Renton City Attorney
Stipulation and Agreed Order of Dismissal[PROPOSED]-1 ` 1055 South Grady Way
"IN Renton,WA 98057
Phone: 425.430.6480
Fax: 425.430.6498
1 be occupied by no more than one "family." See RMC 4-11-040,4-11-080.1 In turn,the RMC
2 defines a "family"as follows:
3 Any number of related individuals,or not more than four(4) unrelated
individuals, living together as a single household.
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RMC 4-11-040.
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Taking these provisions together, under the current provisions of the RMC, a single
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family dwelling is subject to the following occupancy restriction:
• An unlimited number of related individuals; or,
8 • No more than four(4) unrelated individuals.
9 (This restriction is hereinafter referred to as the "Residential Occupancy Restriction.")
10 Here, because the Property is developed with two single family dwellings,the current
11 language of the RMC would ordinarily limit each of the two single family dwellings on the
12 Property to the Residential Occupancy Restriction.
13 The City Issues Two Warnings of Violation and a Finding of Violation
14 In or before September 2017,the City's Lead Code Compliance Inspector, Donna Locher
15 ("Ms. Locher"), became aware of complaints made to the City regarding the Property. The
16 complaints raised concerns that convicted sex offenders were living at the Property within close
17 proximity to a proposed school (the under-construction Sartori Elementary). In response,the
City obtained records indicating that at least some of the tenants were registered as convicted
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sex offenders; but, because each of them had completed probation,the State law prohibiting
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convicted sex offenders from living near a school did not apply to them. RCW 9.94A.703, .709.
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In addition, State law also prohibits the City from establishing its own locational residency
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restrictions for convicted sex offenders;only the State may establish and enforce such
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1 At RMC 4-11-040,a"single family dwelling"is defined as a"detached dwelling"which is comprised of a single
"dwelling unit." Also in RMC 4-11-040,a"dwelling unit"is occupied by a"household."At RMC 4-11-080,a
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"household"is defined as a"family."
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CODE-17-000526 Renton City Attorney
Stipulation and Agreed Order of Dismissal [PROPOSED]-2 ` 1055 South Grady Way
'SYS Renton,WA 98057
Phone: 425.430.6480
Fax: 425.430.6498
1 restrictions. RCW 9.94A.8445.
2 However,the records obtained by the City also indicated that as many as eight
3 unrelated individuals were registered as residing at the Property, exceeding the Residential
4 Occupancy Restriction. On September 8,2017,the City issued a "Warning of Violation"to Mr.
5 Foreman, directing him to bring the Property into compliance by September 15, 2017,or to
advise that additional time was needed. A copy of the Warning of Violation is attached as
6
Exhibit A.
7
In response to the Warning of Violation, Mr. Foreman contacted Ms. Locher and
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provided additional information about the Property's occupancy. Specifically, Mr. Foreman
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asserted that the Property was occupied by tenants with disabilities—which could, by operation
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of state law, exempt the Property from the Residential Occupancy Restriction. But, Mr.
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Foreman did not provide documentation. He further described the two single family dwellings
12 as"clean &sober" houses, but he did not provide documentation. Furthermore, Mr. Foreman
13 stated that he could redistribute the tenants residing at Property the p rty such that no more than
14 four unrelated individuals would reside at each of the two single family dwellings (bringing the
15 occupancy into compliance with the Residential Occupancy Restriction), but he did not state a
16 plan to do so.
17 Because the information that he supplied did not assure the City that the code concerns
18 were resolved, on October 10, 2017,the City issued to Mr. Foreman a second "Warning of
19 Violation" requiring him to submit further information by October 17,2017. The second
20 Warning of Violation is attached as Exhibit B.
21 In response to the second Warning of Violation, Mr. Foreman submitted an October 12,
22 2017 letter to Ms. Locher. (The letter is attached as Exhibit C.) In the letter, Mr. Foreman
reiterated that several tenants at the Property have disabilities, but he did not attach
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documentation. In addition, Mr. Foreman described that several tenants were in transition and
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CODE-17-000526 Renton City Attorney
Stipulation and Agreed Order of Dismissal[PROPOSED] 3 ‘ft 1055 South Grady Way
' Renton,WA 98057
Phone: 425.430.6480
Fax: 425.430.6498
1 that empty bedrooms at the Property might or might not be reoccupied in the future with
2 tenants having disabilities, leaving the City without certainty as to the Residential Occupancy
3 Restriction. The letter concluded that Mr. Foreman would be available to further discuss the
4 issues after October 19, 2017.
5 After a month had passed,the City had not received documentation supporting Mr.
Foreman's assertion that one or more of the tenants at the Property had a disability. Thus, on
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November 30, 2017,the City issued a "Finding of Violation" ordering that the Property be
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brought into compliance, ordering the provision of adequate documentation of compliance,
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and imposing a fine of$250.2 A copy of the Finding of Violation is attached as Exhibit D.
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On December 11, 2017, Mr. Foreman responded to the Finding of Violation by
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requesting a hearing.
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Mr. Foreman Provides Documentation of Tenants' Disabilities Protected by State Law
12
In response to Mr. Foreman's request for a hearing,the City scheduled a code
13 compliance hearing with the Hearing Examiner for February 20, 2018. Approximately one week
14 before the scheduled hearing, Mr. Foreman's attorney, Mr.James Herr("Mr. Herr") contacted
15 the City.
16 Over the course of ensuing discussions,the City and Mr. Foreman (through Mr. Herr)
17 agreed that if Mr. Foreman supplied adequate documentation that tenants at the Property
le have protected disabilities, state law prohibits the City from enforcing the Residential
19 Occupancy Restriction against the Property. Specifically,the City and Mr. Foreman agreed that
20 the following housing protections set forth by the State Legislature apply within the City:
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2 The City has not attempted to collect the$250 fine.
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CODE-17-000526 Renton City Attorney
Stipulation and Agreed Order of Dismissal [PROPOSED]-4 'i 1055 South Grady Way
'4'7% Renton,WA 98057
Phone: 425.430.6480
Fax: 425.430.6498
No city may enact or maintain an ordinance, development regulation,zoning
1
regulation or official control,, policy,or administrative practice which treats a
2 residential structure occupied by persons with handicaps differently than a
similar residential structure occupied by a family or other unrelated individuals.
3 As used in this section, "handicaps" are as defined in the federal fair housing
amendments act of 1988(42 U.S.C.Sec. 3602).
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RCW 35A.63.240.
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In other words,the City and Mr. Foreman agreed that, if Mr. Foreman provided
6 adequate documentation that tenants at the Property have disabilities(expressly, "handicaps"
as that term is used in RCW 35A.63.240),the statute prohibits the City from enforcing the
8 Residential Occupancy Restriction at the Property.
9 For the next several months, Mr. Foreman gathered documentation regarding his
10 tenants' disabilities. In May 2018, he submitted (through Mr. Herr)a compilation of the
11 gathered documentation. The compilation is attached as Exhibit E.3 The compilation provides
12 the following information:
13 • Nine (9) unrelated individuals reside at the Property. Exhibit E,p. 2.
14 • Four(4)of the tenants provided documentation of disability,or, "handicap" as that
15 term is used in RCW 35A.63.240:4
16 o One tenant(R.W.) is rated by the Department of Veterans Affairs with a
"40%. . .service-connected disability." Exhibit E, p. 3.
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o One tenant(A. D.) has been diagnosed as recovering from alcohol and
18 cocaine abuse. Exhibit E, pp. 6,8.
19 o One tenant(K.A.) reported that he has been diagnosed with "Bipolar 1,
PTSD, and anxiety"and requires alcoholism recovery support. Exhibit E, pp.
20 11, 12.
21 o One tenant(N. L.) has been placed on disability benefits by the Washington
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23 3 Mr.Herr redacted tenants'personal identifying information from the compilation.
'Another tenant(L.N.)was verified by a licensed social worker as simply having a"disability." Exhibit E.,p.4. This
24 verification,alone,does not provide enough information to confirm that the individual has a"handicap"as that
term is used in RCW 35A.63.240.
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CODE-17-000526 Renton City Attorney
Stipulation and Agreed Order of Dismissal [PROPOSED]-5 1055 South Grady Way
`` ° Renton,WA 98057
Phone: 425.430.6480
Fax: 425.430.6498
Department of Social and Health Services related to hepatitis C and severe
1 arthritis. Exhibit E, pp. 13, 15-16.
2 • The compilation reports that one(1)additional tenant(S.A.) is blind in one eye and
3 has mental disabilities but that documentation from his Tribal provider had not been
made available to Mr. Foreman. Exhibit E, p. 1.
4
Mr. Foreman has stated that the four tenants with disabilities(or, handicaps) are
5 distributed between the two single family dwellings on the Property such that neither single
6 family dwelling is occupied by four(4)or more unrelated individuals who do not have a
7 disability.
8 Ordinarily, nine (9) unrelated individuals residing among two single family dwellings
9 would violate the Residential Occupancy Restriction. However, here,the documentation that
10 at least four(and perhaps as many as six)of the tenants have qualifying disabilities in the two
11 single family dwellings triggers the statutory housing protections of RCW 35A.63.240. In other
12 words, under the factual circumstances proved by Mr. Foreman,state law prohibits the City
13 from enforcing the Residential Occupancy Restriction at the Property.
14 The Parties Agree to Dismiss this Code Compliance Matter
15 For the above reasons,the parties agree that the City cannot enforce the November 30,
2017 Finding of Violation and that this code compliance matter should be dismissed.
16
AGREED ORDER
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Based on the foregoing stipulation, the November 30, 2017 Finding of Violation is
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hereby DISMISSED,and this code compliance matter is also hereby DISMISSED.
19 `--
Dated thin/2 day of June, 2018.
20
C� r_
21
Phil A. Olbrechts
22
23 Renton Hearing Examiner
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25
CODE-17-000526 Renton City Attorney
1055 South Grady Way
Stipulation and Agreed Order of Dismissal [PROPOSED]-6
"'3 4. Renton,WA 98057
Phone: 425.430.6480
Fax: 425.430.6498
1 Stipulated and Agreed to by:
2 �� I
,
3
Leslie C. Clark,WSBA No. 36164
4 1055 S.Grady Way
Renton, WA 98057
5 Tel: (425)430-6482
6 Attorneys f ty of 'enton
7 �r
8 Ja .s H-,/'wA No.49811
;0 Law Firm, PLLC
9 '02 Colby Avenue,Suite 302
10 Everett,WA 98201
Attorneys for William Foreman
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CODE-17-000526 Renton City Attorney
Stipulation and Agreed Order of Dismissal[PROPOSED]-7 0 1055 South Grady Way
Renton,WA 98057
Phone: 425.430.6480
Fax: 425.430.6498
EXHIBIT A
\ CY O�
Denis Law Mayor + +
�4 N T 0�
Community&Economic Development C.E."Chip"Vincent,Administrator
Via First Class Mail
and Certified Mail,Return Receipt Requested
September 8,2017
William Foreman
27316 NE 143`d Street
Duvall,WA 98019
RE: WARNING OF VIOLATION
RESPONSE REQUIRED
401 Pelly Avenue North, Renton,Washington
Dear Mr. Foreman:
This letter constitutes a Warning of Violation of the Renton Municipal Code(RMC). This warning is issued pursuant
to RMC 1-3-2.C. Please carefully review;your response is required.
As the City of Renton's Lead Code Compliance Inspector, I have been made aware of an apparent violation of the
RMC occurring at the property you own addressed as 401 Pelly Avenue North, Renton, King County Assessor Parcel
Number 722500-0005(the Property).
Specifically,the Property has been listed in City records as a"single family dwelling"which allows"not more than
four(4)unrelated individuals"to reside at the Property. RMC 4-11-040, .060,.080. The City has received
complaints that more than four unrelated individuals reside at the Property. In response to the complaints,the City
has obtained records which indicate that as many as eight unrelated individuals are registered as residing at the
Property in violation of the RMC.
Pursuant to RMC 1-3-2.C.1.a.ii,within seven days,or by no later than September15,2017,you are directed to both
(1) bring the Property into compliance such that no more than four unrelated individuals reside at the Property and
(2) provide adequate documentation of the compliance. If you require more than seven days to reasonably achieve
compliance,you must contact me at(425)430-7438 no later than September 15,2017,to confirm that you have
initiated the compliance process and to propose a reasonable date by which you will achieve compliance.
Failure to timely respond may result in civil action against you and the Property's residents,criminal prosecution,or
both.
Sincerely,
C• E.
Donna Locher
Lead Code Compliance Inspector
cc: Mayor Denis Law
Jay Covington,Chief Administrative Officer
Shane Moloney,City Attorney
Leslie Clark,Senior Assistant City Attorney
Kevin Milosevich,Police Chief
C.E."Chip"Vincent,CED Administrator
1055 South Grady Way, Renton,WA 98057 • rentonwa.gov
EXHIBIT B
\ Y d *
Denis Law Mayor + +
N7C9
Community&Economic Development C.E."Chip"Vincent,Administrator
Via First Class Mail
and Certified Mail, Return Receipt Requested
October 10, 2017
William Foreman
27316 NE 143rd Street
Duvall, WA 98019
RE: WARNING OF VIOLATION
RESPONSE REQUIRED
401 Pelly Avenue North, Renton,Washington
Dear Mr. Foreman:
This letter is to clarify a few items we've discussed in past conversations and emails.
There are two houses on one parcel lot, one being 401 Pelly Avenue North, the other being 910 North
4th Street.You have explained that there are six unrelated individuals living in the Pelly Avenue North
house and two unrelated individuals living in the North 4th Street house. Please advise if this is not
correct.
You stated that you recently placed all the residents on month-to-month leases. Please provide a copy
of every lease in effect for the Pelly Avenue North house and for the North 4th Street house.
You mentioned there are individuals with disabilities living on the property. Please clarify what
accommodations those individuals are requesting.
You also proposed moving two individuals from the Pelly Avenue North house into the North 4th Street
house so that each house contains four unrelated individuals. Please advise if this is no longer your
proposal.
You described the two houses as "clean &sober" houses. Please describe why you believe this
information to be relevant. For example,are you asserting that the houses qualify as a "Group
Home I (Rehabilitation)" land use as defined at RMC 4-11-070, a use that is not ordinarily allowed in
the houses' R-10 zoning district?
You asked whether the City would allow the two houses to be used for"housing disabled veterans" or
for a "battered women's shelter." The residential uses that are allowed in the R-10 zoning district are
listed in the table in RMC 4-2-060. The uses you have proposed might meet the requirements for an
"adult family home" or a "Group Home II (Protective Residency)" both of which can be allowed in the
1055 South Grady Way,Renton,WA 98057• rentonwa.gov
Mr.William Foreman
Page 2 of 2
October 10,2017
R-10 zoning district if the applicable criteria are met and if the required permits are obtained. If you
wish to pursue establishing a new or different use on the property,we recommend that you
schedule a pre-application meeting with our planning staff to discuss applicable requirements and
the permit process. Please contact me for more information.
You requested a hearing in response to the Warning of Violation issued by the City on September 8,
2017. The City's code does not provide for a hearing or other form of appeal of a Warning of Violation.
Please respond to me by October 17,2017, so that we may move forward. If I do not receive a
response by that date,the City may issue a Finding of Violation pursuant to RMC 1-3-2.C.2. Please note
that unlike a Warning of Violation, a Finding of Violation does provide for an opportunity for a hearing,
if the request for a hearing is timely and properly filed and served pursuant to RMC 1-3-2.E. Failure to
request such a hearing waives any further appeal rights.
Sincerely,
Donna Locher
Lead Code Compliance Inspector
cc: Mayor Denis Law
Jay Covington,Chief Administrative Officer
Shane Moloney,City Attorney
Leslie Clark,Senior Assistant City Attorney
Kevin Milosevich,Police Chief
C.E."Chip"Vincent,CED Administrator
1055 South Grady Way,Renton,WA 98057 • rentonwa.gov
EXHIBIT C
12 October 2017
Bill Foreman
27316 NE 143rd CT RECEIVED
Duvall, WA 98019
Donna Locher- Code Compliance OCT 16 2011
1055 S Grady Way
Renton WA 98057 CITY OF RENTON
CODE COMPLIANCE
Dear Donna Locher,
I'd like to formulate a more detailed response to the WARNING OF VIOLATION dated October 10th, 2017,
but I'm typing this letter only a few hours before an airline departure. In fact, I'll be out of the country with
absolutely no cell or internet service through evening of October 19th at 8:31 PM. I'll be happy to provide more
detail upon my arrival back to the US,if needed.
In brief response to your questions:
• Yes,the two houses you mentioned are located at 401 Pelly North and 910 North 4th Street.
• Previous folks at those addresses had leases,but that has ended and no current individual at either of
those houses have tenant agreements at this time. They might be considered month-to-month tenants as
per the Seattle Tenant Landlord Laws. I believe Renton might have adopted those same tenant-landlord
month-to-month default regulations,but let me know if that is not the case.
• You have asked about my disabled tenants. I have at least two disabled veterans as well as disabled
recovering drug/alcohol addicts residing at the homes. They consider the home a safe supportive
environment that provides shelter, safe non-discriminate housing, and a perfectly clean& sober
environment. The accommodations they are requesting are simple. They want a safe environment where
they can live long term without fear of discrimination.
• Moving two individuals to balance tenancy is certainly a consideration,but I actually prefer everyone
has their own bedroom and not double up rooms.
• The houses have always been clean& sober houses,but I did not realize until your letter that clean&
sober housing was not ordinarily allowed in R-10 zoning. I originally assumed that people with
substance abuse and disabilities were protected under the fair housing act and were eligible for housing
accommodations in residential areas. I'll admit I might be confusing the RCWs with some of the local
regulations.
• I have done extensive work with the Veterans Association and the Veterans Affairs Supportive Housing
for nearly 20 years. In fact, I have been given an award for going above and beyond in providing
housing to disabled and homeless Veterans in several of my homes. If needed, I can have the HUD-
VASH office write you a letter attesting to that fact.
• As you might already know, I've had conversations with the local school district to relocate tenants
currently residing at those homes to other housing due to the construction of a nearby school. In fact,I
am currently converting a West Seattle home and also purchasing another clean& sober home in Mount
Lake Terrace to help facilitate that effort. One tenant has already moved and his room has not been
backfilled. On the heels of transitioning the remaining tenants,I plan to backfill the empty bedrooms and
continue to provide low cost housing assistance for anyone in need with an emphasis on disabled
persons,veterans, and housing for the homeless. I have talked to a non-profit group in consideration of
a possible battered women's shelter,but upon further consideration I'm leaning more towards continuing
to support disabled persons with a safe non-discriminatory long term low cost living solution.
I hope this answers your questions. I hope I'm not misinterpreting the RCW codes on fair housing. If you have
more information to provide,please let me know. I'm eager to partner with the City of Renton in providing
housing for those in need.
As previously mentioned, I'll be returning to the US on evening of October 19th, 2017 and will be available
thereafter. Thank you.
Regards,
Bill Foreman
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EXHIBIT D
Finding of Violation j.
Community&Econamk Development CE."Chip"Vincent,Administrator
issued To: Date:November 30,2017
Code Case No:CODE17-000526
Wiliam Foreman
27316 NE 143rd St Owner(Tax-Payer):William Foreman.
[twain,Vito 98019 Violation Address:
401 Pally Ave N
Renton,WA 98057-5455
The undersigned City of Renton Code Compliance Inspector hereby certifies and states that a Warning of Violation has been
provided to the named violator and the violation was not eliminated The Violator has created.permitted to eroat,maintained
or failed to eleninate the following vidation(s).
r l4 * f' 'av}t is7 «a•A t +
Violation Note: You are hereby issued this Finding of Violation and Order to Correct(Notice and Order)related to your
property at 401 Pally Avenue North,Renton,King County Assessor Parcel Number 722500-0005(the
Property).
The Property is a'single fainly dwelling'as defined by the Renton Municipal Code(RMC),which
allows'not more than four(4)unrelated individuals'to reside within.See RMC 411-040,060,and
060.The City has received complaints that more than four unrelated Individuals are residing at the
Property.The City has obtained records which indicate that as many as eight unrelated individuals are
registered as residing at the Property,in violation of the RMC. You have also indicated in your
communications with the City that sac individuals are living in one of the houses on The Property.
You were issued a Vlfarniig of Violation as a result of these conditions on the Property on September
8,2017,and you were ordered at that time to bring the property into compliance prior to September
15,2017,pursuant to RMC l32.C.1.As of November 20,2017,no meaningful action has been taken
to abate the violations,more than four individuals continue to live within a single family doweling,and
the Property remains in violation of the RMC.
Accomfingly,the City is now issuing you this Notice and Order and assessing a fine of$250. You are
hereby ordered to both:(1)bring the Property Into compliance such that no more than fax unrelated
individuals reside at the Property and(2)provide adequate documentation of the compliance before
December 1,2017.
Under RMC 1-3-2.E,you have a right to challenge this finding in writing within fifteen(15)days of
receiving this notice and the right to a hearing.After fifteen(15)days,this finding will become a final
determination,and the City may take additional remedial or punitive action,which could indude
criminal charges.
Cods Text: Number of Residents
Corrective Action:
Fats: Desaiotion
CODE-Violation Fme $250.00
Violation 1 Subtotal: $250.00
Page 1 of
Payment of$250.00 must be made within fifteen(15)days of the date of this Finding of Violation.All city codes listed on this
Finding of Violation must be brought Into compliance within fifteen(15)days of the date of this Finding of Violation.Invoice to
follow.
I codify under penalty of perjury under the laws of the State of Washington that I have issued this Finding of Violation on this
date and at the location stated above. I certify that I believe by a preponderance of the evidence that the violator committed
the above violation(s).
Stirred: V Date: l k--3o -n
Issued By:Donna Locher
Lead Code Compliance Inspedor
425-430-7438
dlodiereentonwa.gov
Page 2 of 3
EXHIBIT E
4252595994 Mazzone and Cantor,LLP 14:59:54 05-21-2018 1 /16
Mazzone Law Firm, PLLC
3002 Colby Avenue, Suite 302
Phone (425) 259-4989 Fax(425) 259-5994
www.mazzonelawfirm.corn
Peter Mazzone James Herr Braden Pence
RE City of Renton v. Foreman.CODE 17-000526
Leslie Clark
City of Renton
1055 S. Grady Way
Renton, WA 98057
Dear Ms. Clark,
Enclosed is a list of tenants and accompanying documentation for their
disabilities. One tenant, Mr. S.A., is blind in one eye and also has mental disabilities, but
we have been unable to get documentation from his Tribal medical provider at this point.
That being said, we have included documentation for five disabled individuals.
With regard to Mr. A.D.: I have included documentation from an assessment
showing a diagnosis of severe alcohol use disorder. The assessment also references his
mental health diagnosis of schizoaffective disorder,and his engagement with services
through Sound Mental Health, as well as his previous homelessness being a major barrier
to his sobriety.
I believe that,with the documentations of disability for the above-named
gentlemen, we have provided evidence to satisfy the requirements of the Fair Housing
Amendments Act of 1988, and pursuant to RCW 35A.63.240, Mr. Foreman's property
should be considered"in compliance."
If you have any further questions, please do not hesitate to reach out to me.
Thank you again for your help,
/7'
rr
Attorney, Mazzone Law Firm
4252595994 Mazzone and Cantor,LLP 15:00:26 05-21-2018 2116
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• ah ..Q‘.o. J/i/4uiu 4:43:13 PM PAGE 2/003 Fax Server
,�tiLit
,,'"`�, Department Of Veterans Affairs
' A.J.Celebreae Federal Building
1240 East 9th Street
1, ' Cleveland,OH 44199
March 0I,2018
In Reply Refer To: 325/NCC/L:VCW
t To Whom It May Concern:
The official records of the Department of Veterans Affairs verify that.A W_is rated at
40%for a service-connected disability.
Do You Have Questions or Need Assistance?
If you have any questions,you may contact us by telephone, e-mail.or letter.
If you Here Is what to do.
Telephone For Compensation,call us at 1-800-827-1000.
If you use a Telecommunications Device for the Deaf(TDD), the
number is 711.
For Pension,call us at 1-877-294-6380.
Use the Internet Send electronic inquiries through the Internet at https://iris.va.gov.
Write Put your full name and VA file number on the letter. Please send all
correspondence to the address below:
Department of Veterans Affairs
Intake.Center
PO Box 4444
Janesville,WI 53547-4444
Toll Free Fax: 1-844531-7818
• DID: 248-524-4260
With sincere regard for the Veteran's service,
RO Director
' VA Regional Office
To email us visit https://iris.va.gov
4252595994 Mazzone and Cantor,LLP 15:02:32 05-21-2018 4/16
HAM
BOuN R
UW Medicine
April 26,2018
Re:IMO,NMI
D08:1111111.
To Whom It May Concern,
I am a licensed social worker with Harborview Medical Center's Downtown Mental Health Team.I am
currently working with Mr.111111 as his mental health counselor.
tam writing this letter to verify that Mr.P has a disability.
If you have any questions or require more information please feel free to contact me atm
or by email a
Sincerely,
Keit es,LISW
Harborview Downtown Mental Health Team
Pioneer square Mole
206 Thud Ax.5 Stank.WA 98104-2697 206.744.1500 Fax 206.7441555
Owned by King County and Managed by the University of Washington
4252595994 Mazzone and Cantor,LLP 15:03:11 05-21-2018 5/16
Fax: 206.205.1634 Jay 5(10 Residential Treatment
Backup Fax: 206.205.8262 Authorization Request Cover Sheet
T.; T,' f ( 1 Yr.•1(•.`.
D�Crisis
Solutions Center 1600 S. Lane Street. Seattle
Jeff AlllsonBrian Danforth. Dawn Porter
Vox ilk
1111 t. Willi
A"• 1-01;L: ' t.,;,t,m;. LAM
.mile*DOM er
g
›klaIe 0 Female O Tiansgender 0 Intersex(born with characteristics of both male and female)
__..,
eemanseseli
•le os reNever Married 0 Divorced i O Heterosexual pq� luestioning
0 riled or Committed ❑Widowed 0 Gay/Lesbian/Queer/ �'SNot Asked
Relationship Homosexual
O Separated 0 Unknown O Bisexual 0 Unknown
0 Choosing Not to Disclose
a Bleat Motif
0 White/Caucasian . 0 Cambodian O Vietnamese
O American Indian or laskan 0 Chinese O Guamanian or Chamorro
Native
0 Asian Indian ❑Filipino O Samoan
O Native Hawaiian O Japanese 0 Middle Eastern
O Other Pacific Islander 0 Korean 0 African-Ethnic
O Other Asian 0 Laotian 0 Some Other Race
tack or African American 01'hal O Not Reported/Unknown
1$M UC balk eleiracresse -
0 Cuban Ntlailot Spanish/Hispanic
O Other Spanish/Hispanic 0 Unknown
Cl Puerto Rican
MOON IN
O'Its ❑ Not asked/refused to 0 Yes Nario 0 Not asked/refused to
answer answer
O Unknown O Unknown
ee 391d sian
5aiTSZEW MK BtOULT/EB
4252595994 Mazzone and Cantor,LLP 15:06:18 05-21-2018 6/16
•
'n INVOWIO IN CIONINILL jUsnce(AC1R60 WHAM 1f'017 &111S--3)404---------
0
S 0
0 Drug/Mental Health 0 Family Treatment 0 O CPS 0 Other(please describe)
«• rt Court .411/11,1114.
POPULATION?
O Woman pregnant&injecting ' 0 Parenting woman 0 Offender
drugs
O Woman pregnant w/STOs O Postpartum woman 0 Referred by SHIRT
o Individual Injecting drugs 0 Parenting Individual w/CPS
'CV
r'1:.0 '3 x,:'..451 CI 74.-7-- ' TOppi' ; ' k;sit'.__1 J.`4: V lr,'.:{{ ,"7 Sp, .1 1.7
.N- +��-
f
pti �tsti,3'i1�tsdaa+ c r�asf:iva.ankl .�k k t5� x
OEmployed Competitively Full Time 0 Not Employed-Actively ONLF:Disabled
Looking
OEmployed Competitively Part-Time 0 Not in labor Force(NLF): AltillWreTther
> 20 hrs. Homemaker
liEmployed Competitively Part-Time ONLF:Student OUnknown
<20 hrs.
OEmployed Non-Competitive lob ONLF:Retired
„1::,r"".-•1.'r.'.1 . ', .f t •,...% P
O Full-time education:(1.12 grade:20+hours per week; kindergarten end>12 grade: 12+ hours per
week).A person Is considered enrolled In school during scheduled vacations or term breaks that follow a perlad of enrolatient as
defined above.
❑Part-time education: (1-12 grade:less than 20 hours per week:kindergarten and.>12 grade:less than
12 hours per week).A person Is considered erualltd in school dur'n5 scheduled vacadona or term breaks that follow a period
of • as donned above.
:•; -, n educational a •vides
0 Grade 1 0 Grade 9 03 years of college
0 Grade 2 0 Grade 10 O 4 years of college
0 Grade 3 0 Grade 11 0 Vocational •
O Grade 4 . HQh School Diploma or GED O Nursery school,pre-school,
head start
0 Grade 5 0 2 years of college or Associate a Kindergarten
Degree
O Grade 6 0 Bachelor's Degree 0 Grade 12(no d'plorna or GED)
0 Grade lar of college 0 Never attended or below
•reschool
a ••- - - •ua : du tin + Unknown
, . - ,,, ..ms's. 'R.
gwo�ie tip ill�'ile"i —�'
< urrent 0 Former O Never Ates 0 No
�1,•: •ke `' . -r —
No attendance 0 About once a week ttAt least 4 times a week
U Less than once a week 0 2 to 3 times per week QUnknown
•
•r apt'' rhr + r {J-1 _,_t. . _- ;
4252595994 Mazzone and Cantor,LLP 15:10:04 05-21-2018 7/16
Downtown Emergency Service Center Crisis Undone Center
ADULT PSYCSOSOCIALASSESSMENT
Wive. Mass;C_PtL i(. ," grant��!,L,ti LAs.-t
Rctadve_.� Whirs Status . -__., f
seladvt
..tt6aear„ -_ sem_. __ -•-_r.- l
a 3saveyell evort*ndltysoaedwWrumantattwdlh.dttian7 110 es ityt.swlwtuthwedirtyttos's7 swan f
Who neon*U? PibdreCteAw�+C.�atj."el �
+
Ate you wonally Wog baled Poe**dagaoted wand lieshbeend}d0a7 L114o Otis 1� G�
Whit Is Vann yell? Hwa nition do yua ice your protddax! V\ \ 41X'
Wlwt is the progttas471 * t ( a ) "�
'taus:tt0d', 'Jot IV* a' -a '►[acfig
4, A-aa you annoy t eiicet as a trial Inn c>Wrr or toeing ap�dt to autitionot kwany other monad lmWtt COMMIS of caAMfttta,.W No
..„1;trAt if peg whatmMLo7• ..t.tlal (IAA/LA �`+ .tel X- `�` jatt .JL LA-'V`5r-
16t I signed:r 1141 I s
S. Flava lou evarst rived aoutatvatt or paychintne Wand I J+ht A,it s,volas whir.and far what?20/9
6. Hoa woatd ou duct*ter cont s soya!holds iruur Ac f Good I ]L outuem
7. 8vatyttioa of client's sown health: I ittoae �C]'Avem 10.04r� f
't. Enhance of ckkat'o Why 1p perform daily living WOOL tn.( T I Aoeraga� .J Bxdleet
Oman
!7.1Arad3st•.titan l.:dtautitartgAinp...Nandi
CDP Shlueddra of BALAIAC(Death:Ow doled oiiriScanen of the mud's,d.s•high totmatt skstslwrtgxioa:cortpefi b mi(-'.nest sin).
Own tut web'for lids dint _
2. CIDP ttvduadoa of tin re'!-repotmd driving non wad'Ogren at i?ic is t driving mart
3, Wing latha..I5a:iisooddampest tolbum? we. Low t rasuOniyh ..r�
4. Wiwi is due Ukoliuood otstgttitk ant sink it self a when if spear offeust racers? ae 1-ew Pinata ONigli
S. Whet h the liuUhood otAnd fano!a tits 6utgdiw i rasa? oat O Low I_I iio s cote lit itgit
As ariQa :
dnano 311'1*RaticW
e 'No t'motlaswi,behavioral or colpniUvc ooaditioas that anal'.tmdmaat
lhogssonstaanhalityr Qcod invoke control ural coping stills
aurin s aco with AddiRtas Ramat tRarta:Ability to focus on ninny,Moo epptoprina soppons and moh Out too bslp
Social Patentor en fbwetbalag Ia stio ocdlps with iigaifiant atm,oowudoste,!dead;of.
Ability forint-awn Pei hsooltocysg,with luted soaouvaa ad ells to cops with vat U000l robing
_,cam- Cat's.of Ulnae l b emotional or behavioral probl.r,ottproblcai lanolin aro sbetb.No now snow or higtt.nsk vuUterrbthy
1 1041-lte pedant bos a darned wand ethers*lin win inov.tion,but docs not drift's*bwedere with addiction notansta
/” Dasigan►vfL,athdity:Adcgds ttuputac Cameo'and antra stdlis to de with any thotsglltrattttetrto-nu'ar ulnas
btorfesmee with Addiction fic civery''forts:lirsotiottd utters tette to ourafve Cootalaat►wa and Mots of ttddiettou the
VaOoat is sine m view dna as put of sdmatott and recovery.
San N+ac600iag:Rdattoosisps or spawns asocial antedating an WAS awaited but tut andmtgered by patient's cub sumo use.
The paaex,is able to net persons!totpotWbsUtias dasphc dna,mild aymptutac tgterimwl
A011by far sdf-care:Adequate taming and skllb,:Ocoee t tlh.notional at battwiaraf plobkirta
Cobra of Wass:Mind to ewdorate signs ane tq mpwsts wigs good taepoitses ao mimeo in the Icon An yarn realm's pivableuw iwse*
lowland of tailing Of nut problems ao thank but not scam enough to pore any blah-tilt vtdeotsb bay. _
2 T_IPturas has of two Stats,
no am.xtubtla Oita levet of bapatmwnt only dude moots do4oapensdtoa
• Tat:'tion dettaustefes US'Ind ofdr.atntkntyCyti t at hsed_btL
Rax 4/1400171M) Pogo t of 2/
e)W I I'4
9T 3SVet SIC13 990I6LE9BL LT:DL am/twee
4252595994 Mazzone and Cantor,LLP 15:13:17 05-21-2018 8/16
•
Downtown Emergency Service Center Crisis Solutions Center
ADULT PSYCEOSOCIALASSESSMZNT
oeuatod ASMI Laval of y.for Ito-- .-46-MO.04.at RnetoMraetint
i No i.uttadine motors am traded.Dna sot affe
ea the plaemeat dacirton. r
I JLeval 03 Lady mmtraadat
L.1017-Levet 1 Opioid'lleatmontProwl
1 jLad I °uvulatSetiiaet
f: Len!2.1 winces Ontia*at Servicer
Ell Leon 23 Partial Hospnalirniao Sar.lcca
�,�Levet3.1 Miceli,tdenesse Low-isterui r Refidcadal Srrriccs
kI - L ci 3.3 CbrucallybinnaesdPopolstion Spunk hush-Tntcaib'Residential Setvical
el 3.3 CUnlctftl'Miami Hitklntaaity RendoadsI Santer
i' !Laval 3 7 AdatlinUy Moaimred lslasies tupedeut Pesoledat Services
Level a Medically IsnoMpfd Newsy I altoam U
CDP Summary lgterprctiag DlwensiOn i Data Oulu&cNmt smossutai1 data lbat itkotifies epaclik Voile**Mleria to
;unify abgve levet at cam ravtoeset od utloel: DO MOT WWI BLANK t�,•-
to,<Ltivt t't 1V1V ONe uA )4100\• -saggar\,l.. .. C\\{ (4 is 4-k ,,.1.42,SC
pttnL( love,.t5 V+ dIP}iiUik "tu V'De Ot,,.,t v `' ,fes
&vide=Sopped,DOMsflladneatlaCrimea i rr ;e riaMetn+. teepsteery russtarnir tt •u- s16;1
for to rug eatr ".ix.. �,!6,
G1►v.ajvy+ g1611 i I
DSM-5 DIAGNOSTIC ASSESSMENT STATEMENT
MT Coda: �- —
rt Prise**,Drewetuma t GrrvloL sw+ata.cauroswrderkia�t.4a.lmeo
It S cadart uaaadUJ r rR.. Serbstmeoldsu hbnfar litaiwrdse4;Maio
ii 70rt Ore Of Up'. t: A. .. , A sotto _ r, Sower 4 r matte tut Iu
fndifreae SW nth st IVs abetted at Octal two of the MIMawsee varea alai'Mikis a 12-amatb pcdadt
t 2 3 lSTcoece Nonnt idiom
I.N Jibe sabrtance is atlas taken a larger amovats or ever a Wager period thea was Manta
1. ere tr a pardetaol desire orr,wmnatul efforts to tot down or ooatrol on.
3., ,,A pat
deal of dale is spot Is aim*.aarcnar7'to obtain.nab or mw We the effects of the tottstaaCe.
t.by `' Cnrbrot,uraMewl auk*orerne eawathe abdtmo.
5. Yawrrent use temper le a failure to artful major rote obulatiosr of waw Khan.or seine.
04cabcrreatinitell not atone baring panisfwt or towM31 social or Iatorpcnoaal probbms mowed by oratatabated by who Woo at
TR-{t�ttc subsume.
T.r�L jropurtad
scald,septpaWuaf.or rtnaatioaul adbooms hftke are gime op or reduc*d boof aid.
a ""t;. 0,J itecorreat roe In situations is wbicb R!,physioaUr bo ardoua
9 , , Use is cuetiea:a despite Imowtedpe of bolas a panktaad or recenao t physeal Or peyebotoglcui problem that Is Maly to bass
(I tausedurcaaccrbetnrt by srturanca use
L .--.__.. __._. ___. .._-_
Rep 4nsrtbi7(34 Page to or 21
9Z Weda SIQz SSG T6LE98Z MDT 8t8Z/LTIC i,
4252595994 Mazzone and Cantor,LIP 15:15:39 05-21-2018 9/16
s
Downtown Emergency Service Cotter Crisis Solutions Center
ADULT?SYCMOSOCIALASSESSMINT
in.--T,_ ]glarnme.u dthto4 ey t eraf the fvIowtaa
t. n a!for martrcdly tbc*eased ameuats of the subdaee to achieve ht;oskadva or Ms daind effect.
Andlor
0. A markedly dlraiaisbed dlect with continued limo(the same Doom of the sttbsia sec:
11.1,,,,e,911'; therm.31.w mcolfcacd by either of the fotfewioF
i. raPwnz:d withdrawal syndrome for the feddaax(we Dhaemirn 1).
Azialar
li. 11w wbsrraer(or a curdy related whitener)4 taken to relieve*:mild withdrawal tyraohnot,
D$M4 DLAGNOSI$
} i toe Dims*?&IN 2,3 criteria
-1 Oe Disorder Mideswa 44**Ma
tier Disorder Serena 4 or more Miens
s4 Welt• ,,• 0-t1, . -Aid 1 Contioruus 24 sod' L.�, .. i+la 11 inn
ul:yrertte Al •nerd•per fors Ill ; redHitM.JesenOind T. r.
._ Metai.c—
*OM (( 303.0 „, icer_ 3W.9 C Indio_
liellocitaiten j305.3 ljr--
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Aarphelenent 3031 1113.10 r 304 4 fell 20
irthaiaae 103 9 A t0._ 304.4 ru m
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irrbu _j 303.1 a 304 3 72
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" 4 ! �acwrk i t 9os.d _ _� _ su.3p- 304.2 Plc
aus.s l ,. 2.0
P11.20
fklrcduptorwlt —
111.-M.—cisrl)mJ$of 111412“si o Mite,revcalcd tawIAdtot Aimee areploan to odbbEaterate a 8ubstetwe 3113 prsmder dlaq83 .
LEVEL OF C4RE RECOCARE RECOMMENDATION
Treatment Recommendations using ASAM Criteria Levers of Care:
Ther trolling 1'Aeett tits ioltuwitip tavut n towuirttiteiou eritoera
I Dim sloe 1.L ver! Dimeesiun 3:Le `
Level 4 5 'Dimansiun SLevc1
Dimension 2.Level _...Dimension 4:Level �j, ril'en iof 6 X e d e.
—11
, OVE4A1,1.RitCOMMV1J,ATION.(Level of Gee recomrnandedperASAM Criteria):
O No uulnodutte suvkx s act;decdotl
O A arty 1alatvet1Coa(A3311i1 .
Q U1ra.n Opted Titntnwap Scat ict t
0 /.b Ouipstidit Strikes
O 11.1 Itruraibe Ooyuairl,t Suriut
C /IS Irattiit uoralt:rltrailnn wince
O I11.5 •Clraa:utly 041orolot 1.uw4lakntey iteititktutul 3,41490
p 103 Clinicaliy4 toast od Population Speedo 180,4 meow,Ittardcabni Serviced
WI Cllaieatlyhtauogad11gkHlorcgrhyRowan krvito
0 Ott Katie:11y Mgtdtored laumairo.ltyMltout Reiidentkit Servlaas
O iV MedicxilyM wsl;W ltdotufva inpatient ScM i
(:erdeolly rtttcusaty levtlttrr verve tC..Arlaalplpeoweat level of care„7.s .Kant Wa tar override.if iNRlronl
tr. tarots of cervico h dopersdwt us lura of lerOnty.level i se:rwrev,and patrettt prvattw la.ncatritar. —
Rev.v74=17441 wdWe 20 or et �. '....
>/ .27.rl/6
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gS8162E902 21:D1 9Ii3t/2T/£6
4252595994 Mazzone and Cantor,LLP 15:18:49 05-21-2018 10/16
Downtown Emergency Service Center Crisis Solutions Center
ADULT PSYCROSOCIAL ASSESSMENT
Catkies eCOOride:nuiees:
Does the clietn eta pad tame of quad the cloak childcare!u ender to smut unattne 't t car f tt ya
Digits What Deed kip rxessing or steam chit l Np 'Ya❑it9es
itelbeall Wormsou f t Wed an wic4s:
Aho tecaamtrdca: _ _
UDon ea lc Mime Permian/0 Pam= � �Anlia Mmehinuatu
Ll Macadamia Ralahlthatiod RaULIPt Heald,Cewgeedas
LiteasYAhtwinePegg* ei"-itarim11,Kerngtonpf
_110ED I` 1 ewer testnalnt:
Hf VMA1DS D ries Rids tntatvontion conduced by s CDP during the tssonseeet pnocest? Yrs •"'
tf mt,aw141e
�• _ �1
My at/YIiue below vivito' nett I neve been itdbnued ofa Manua tante and dot 1 edrtsed of the right to he esterva to Amy itgeopdav Wel
oderiug &Rei aan whit ui wI s or theasseamour. T o(oUowins mensal epdeas were psovt4ed 10 mo
3.
lls�a
tr Ow pedant vent sot inbreed Mitts ammosunm mouth me/or id•ett mango agleam(gbh'why. _
RUM Eta lIC'ATi0N OniO t erri0N
norm Canned Allctrdy wanokne p,N okra
Rua of GYP )P 1Yaiis(CDP.)eaapteYdh uawma a:
O
.tpi►en +erttinnr '',1rf . i Date
a Alai
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t '°r
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SSOI62E90Z ZT:bT Sinai/60
4252595994 Mazzone and Cantor,LLP 15:20:59 05-21-2018 11/16
}
American Behavioral Health Systems
Mental Health Intake
Initial Contact Date:3/7/2018 Intake Date:4/4/20111 Begin to End Time:.75 hours Location: Cozza
Completed Intake Date(if different):
Last Name: AM First Name: t�
DOB:_ Age:60 Gender:Male SS#:
Description: Mr.A'is a 60-year-old African-American male.He was born and raised in Seattle,WA.Before coming to
ABHS-Colza he was homeless.He has been in u long-term relationship for fourteen years which he describes as healthy.Ho
reports that he has no support from his family of origin,his parents are deceased,and he has a poor relationship with his
siblings. He has no children.
Presenting problem(a)and history or illness as described by the individual:Mr.A.is in treatment under the
circumstances of"being out cf control,not trusting nrvsel/and dishnutesty."He is in treatment through funding from the
Department of Corrections(DOC).He reports that he has been diagnosed with"Bipolar I.P77'II)and Ansiety."He reports
symptoms of"racing thoughts, anxiousness, nightmares. recurring thoughts."He also reports periods of mania,aversion to
people who remind him of a traumatic event,nightmares,loss of emotional control,and a history of suicidal attempts and
ideation.He says that these interfere with his functioning: "I can't leave the house,alters my route,appetite."He also reports
that he continues to relapse which makes it difficult for him to maintain his medication regimen. He reports a low self-
esteem.He says that his father died when he was a child.He didn't know him.His grandparents took over parenting from his
mother when he was five years old and raised him.Because of this he says, "for some reason l have trouble bonding."
Current Suicidal Thoughts/Behaviors:Denied
Historical Suicidal Thoughts/Behaviors: "I've had three episodes. 1994(manic early in the year and depressive later).
1997, 1998 and 2013. (rest were depressive),"
Homicidal Thoughts/Behaviors: Denied
Based upon the symptoms endorsed and reported by the individual during the intake,the Intake provider has
determined the individual meets diagnostic criteria for F'31.9 Bipolar I Disorder,Current Episode Unspecified,as
evidenced by:Mr.A.presents with reported symptoms of mania,which he says occurs over a period of a week several
times a year,and he has been hospitalized for these manic episodes.He endorses inflated self-esteem,decreased need for
sleep, pressured,rapid speech,flight of ideas,distractibility,increase in goal-oriented activity,and increase in
involvement in activities with a high potential for painful consequences,specifically he mentioned theft and sexual
encounters.He reports that the mania causes impairment. "Look where/am and have been." These symptoms are not
likely to be a result of medical issues or substances use disorder, "Because I'm manic when/turn to drugs,but before that
I'm not using drugs.1 didn't start using drugs until 1 was 28 in a serious way."He also presents with reported symptoms
of depression,which he says occurs often over the course of months.He endorses depressed mood most of the day,nearly
every day;diminished interest in activities all day nearly every day;Hypersomnia;Fatigue;feelings of shame and guilt;
difficulty concentrating;history of suicidal ideation and attempts.Mr A.also reports symptoms of Posttraumatic Stress
Disorder(PTSD).
Clinician's observations of individual's presentation:Mr.A'is alert and his attention span is normal.His intelligence is
estimated to be average to above average.Ills appearance is clean and well groomed.He appears to be younger than his
stated age.Posture is normal and eye contact is moderate.Motor activity is unremarkable.Speech amplitude,quality and rate
are normal. Thought processing is logical and coherent.No thought disorder is noted currently,though he reports periods of
psychosis during manic states in the past.No unusual perceptions are noted,though he reports hearing voices during manic
states in the past.Mood is euthymic and mildly depressed.Affect is appropriate.Attitude is cooperative.Memory is normal.
Judgment is normal.and insight is adequate. He is oriented x4.