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HomeMy WebLinkAbout05-26-2026 - signed complaint w exhSUPERIOR COURT OF WASHINGTON for COUNTY OF KING ARM1N AMANO NO. Plaintiff, COMPLAINT FOR V. UNLAWFUL DETAINER (Residential) LILLIAN NUNEZ ALL PERSONS IN POSSESSION [ ] CLERK'S ACTION Defendants. REQUIRED COME NOW the Plaintiff, by and through the undersigned attorney, and for the causes of action against Defendants alleges as follows; 1. STATUS OF THE PARTIES 1. Plaintiff ARMIN AMANO is a resident of King County, WA. 2. Plaintiff is the current owner and landlord of the premises commonly known as 1522 N BROOKS ST, RENTON, WA 98057, in KING County, WA. (The property is hereafter referred as the "Premises" or "Property" 3. Defendants LILLIAN NUNEZ and ALL PERSONS IN POSSESSION are residentsof King County, Washington. complaint for unlawful detainer; p 1 of 5 Thuong-Tri Legal Services, PLLC 405 S 4TH ST RENTON, WA 98057 206-772-4621 4. Commencing in 2012, Plaintiff, as landlord, rented to Vincenta Nunez, as tenants, the 1522 N BROOKS ST, RENTON, WA 98057, in KING County, WA, to be held and possessed by the tenants. 5. Vincenta Nunez allowed LILLIAN NUNEZ to move into and occupy the Premises. II. VENUE AND JURISDICTION 6. Each of the above allegations is incorporated herein by reference. 7. The rental premises are situated within King County, WA. 8. The Court has jurisdiction pursuant to the Residential Landlord -Tenant Act and other relevant statutes. III. FACTS FORMING THE BASIS OF RELIEF 9. Each of the above allegations is incorporated herein by reference. 10. Vincenta Nunez and Plaintiff memorialized their agreement. Another written agreement was entered between Vincenta Nunez and Plaintiff >T r five additional years. That second agreement was not renewed. Vincenta Nunez continued to occupy the Property on a month to month basis. 11. Vincenta Nunez is the mother, of Lilian Nunez. 12. In or about December 2025, Vincenta Nunez vacated the Premises. 13. Lilian Nunez continues to occupy the Premises. 14. In the most current rent change notice, the monthly rent is $2800. 15. Pursuant to the rent:, change notices, the rent , payable in advance for the described premises currently is $2800 a month Which computes to .$93.33 daily. 16. The tenancy is currently month to month. complaint for unlawful detainer; p 2 of 5 Thuong-Tri Legal Services, PLLC 405 S 4TH ST RENTON, WA 98057 206-772-4621 17. Each month, rent is due from the Defendants to the Plaintiff on day 1. 18. Starting January 2026, Defendants have not paid the monthly rent. 19. The total of unpaid rent and, utility charges through 31 March 2026 is $8400. True and correct copy of the accounting of rent charges and payments is attached as Exhibit A. 20. As of the filing of this complaint, Defendants have not paid the April and May 2026 rent or any money stated in the accounting of rent charges and payments. 21. The Defendants are in actual possession of the described Premises. 22. RCW 59.18,130 provides "Each tenant shall pay the rental amount at such times and in such amounts as provided for in the rental agreement or as otherwise provided by law and comply with all obligations imposed upon tenants by applicable provisions of all municipal, county, and state codes, statutes, ordinances, and regulations, and in addition shall:..." 23. A fourteen -day notice to pay,or vacate was served on each of the Defendants. A true and correct copy of the notice to pay or vacate is attached as Exhibit B. A true and correct copy of the declaration of service is attached as Exhibit C. IV. PLAINTIFF'S CAUSE OF ACTION AGAINST DEFENDANTS 24. Each of the above allegations is incorporated herein by reference. 25. Defendants have failed to pay the rent orvacatethe described premises within the time required by the fourteen -day notice to pay or vacate, and the Defendants are unlawfully detaining the premises. 26. The Residential Landlord -Tenant Act and other relevant statutes authorize the payment of attorney's fees, court costs, and other reasonable costs to the: prevailing party by the non - prevailing party. complaint for unlawful detainer; p 3of 5 Thuong-Tri Legal Services, PLLC 405 S 4TH ST RENTON, WA 98057 206-772-4621 V. RELIEF REQUESTED WHEREFORE, the Plaintiff prays for judgment against Defendants, jointly and severally, as follows: 1. For restitution of the described premises to the Plaintiff; 2. For termination and forfeiture of the Defendants' tenancy; 3. For judgment against the Defendants for unpaid rent and damages for Unlawful Detainer; 4. For Plaintiff's reasonable attorney's fees in the sum of $1000.00 if no defenses are presented; or such greater sum as the court deems reasonable if defenses are presented; 5. Reasonable court costs; 6. Reasonable other costs; 7. Prejudgment interest; 8. Interest on all monetary awards to Plaintiff, 9. And for such other relief as the Court may deem just and equitable. I, the landlord, a person over 18 years of age and a resident of WA, declare under penalty of perjury under the laws of the state of Washington that the foregoing facts that I have provided in this document are true. Signed at (cityI ind state): a l- Date: 6 i si nature By: ARMN AMANO, LANDLORD 405 S 4TH ST RENTON, WA 98057 complaint for unlawful detainer;' p 4 of 5 Thuong-Tri Legal Services, PLLC 405 S 4TH ST RENTON, WA 98057 206-772-4621 DATED THIS 5 May 2026. /s THUONG-TRI NGUYEN By: Thuong-Tri Nguyen Attorney at Law, WSBA # 31285 THUONG-TRI LEGAL SERVICES, PLLC 405 4TH ST RENTON, WA 98057 206-772-4621 attoiney@thuongtri.com complaint for unlawful detainer; p 5 of 5 Thuong-Tri Legal Services, PLLC 405 S 4TH ST RENTON, WA 98057 206-772-4621 Exhibit A, accounting of rent charges and payments p.. n 0 N W N r- a N N N N a1 a1 Q1 N rn 0000 000 ONo C N N N CD 00 oo 00 �. 69 b9 b9 69 b9 b9 b9 b9 69 69 64 63 69 69 b9 O. O O b9 CJ O O o 0 0 0 0 0 0 O 0 0 0 0 0 0 0 0 0 N O O O O O O O O 0 0 0 0 O O O O O O O O O O O O O O O O O O O O O O O O O O 69 b9 Er4 64 b9 69 69 b9 64 b9 b9 69 69 69 69 69 69 69 U+ 00 00 00 0o 00 00 00 00 00 00 0o 00 00 00 to N � P P P .P -P -P _PP -P 'PO -P � -P -P 'PO -P � -P O\ m O O O O O O O O O O O O O O O O O d 6e n O O O O O O O O O O O O O O O O O O O CD O O O d O d O O O O O O O o d O O O O O O O O O O O O O O O O O O O O O Q Q ' k3 p� 69 64 469 b4 69 63 64 4&9 64 69 69 64 b9 b4 69 4�oq 69 b4 N ly 0 0 0 0 0 0 0 0 0 0 O 0 0 0 0 0 0 0 (p O O O O O O O O O O O O O O O b9 69 69 69 69 69 69 b9 64 69 69 boi 69 b9 b9 b9 4.9 69 b9 O O O O O O O O O O O O O O O O O O O CD O O O O O O O O O O O O O O O O O O O N �N N 00 00 00 69 64 b4 69 459 6S b9 69 69 b9 b4 64 b9 69 64 O O O b3 C O O O O O O O O O O O O O O O O O O O l O O O 0 0 0 0 0 O 0 0 0 0 0 0 0 O 0 0 �-r O b9 69 4b9 69 69 b9 69 b9 be 69 b9 bA b9 69 64 b9 fiS b9 00 00 00 00 00 00 00 00 00 00 00 00 00 00 00 00 C.A N �"' • -P -P 4, -P, -P, -P, -P, -P,. -P � � 4'. -P, P P P rn oo �G O O 0 0 0 O O O O O O O 0 0 0 0 0 0 0 CD + O O O O O O O O O O O O O O O O O O O H N b r yc cn CA N oho 0 c�, b � O CA CA m CA z r Exhibit B. 14-day notice to pay or vacate PHONG LUAT THU(YNG-TRI Our Specialty Is Helping You THUONG-TRI LEGAL SERVICES, PLLC 4 April 2026 LILLIAN NUNEZ ALL PERSONS IN POSSESSION 1522 N BROOKS ST RENTON, WA 98057 425-757-0871 Hello: I am the attorney representing your landlord for the rental premises located at the above address. -A As of today, you owe the landlord $8400 for unpaid rent and utilities. Please see the attached accounting of your rent payments. (You may owe more money for late fees and damages to the premises.) Please review the attached documents. You are behind on rent for several months. If you are represented by an attorney, please forward this correspondence to your attorney so that your attorney will contact me. Very truly yours, Signed at (city and state): Seattle, WA s/ THUONG-TRI NGUYEN WSBA #31285 THUONG-TRI LEGAL SERVICES, PLLC 405 S 4TH ST RENTON, WA 98057 Telephone: (206) 772-4621 E-mail: attorneyCg)thuon trg i.com 405 S 4TH ST / RENTON, WA 98057 (by appointment only) attorney(c�tliuongtri.com / 206-772-4621 / www.thuongtri.com FOURTEEN -DAY NOTICE TO PAY RENT OR VACATE PREMISES 4 April 2026 TO: LILLIAN NUNEZ ALL PERSONS IN POSSESSION 1522 N BROOKS ST H RENTON, WA 98057 425-757-0871 Re: FOURTEEN -DAY NOTICE TO PAY RENT OR VACATE PREMISES Dear LILLIAN NUNEZ, and All Person in Possession, You are receiving this notice because the landlord alleges you are not in compliance with the terms of the lease agreement by failing to pay rent and/or utilities and/or recurring or periodic charges that past due. (1) Monthly rent due for (list month(s)): $8400 (dollar amount). See attached accounting. AND/OR (2) Utilities due for (list month(s)): $0 (dollar amount) AND/OR (3) Other recurring or periodic charges identified in the lease for (list month(s)): $ (dollar amount) TOTAL AMOUNT DUE: $8400 (dollar amount) Note — payment must be made pursuant to the terms of the rental agreement or by nonelectronic means including, but not limited to, cashier's check, money order, or other certified funds. You must pay the total amount due to your landlord within fourteen (14) days after service of this notice or you must vacate the premises. Any payment you make to the landlord must first be applied to the total amount due as shown on this notice. Any failure to comply with this notice within fourteen (14) days after service of this notice may result in a judicial proceeding that leads to your eviction from the premises. The Washington state Office of the Attorney General has this notice in multiple languages as well as information on available resources to help you pay your rent, including state and local rental assistance programs, on its website at www.atg.wa.gov/landlord-tenant. State law provides you the right to legal representation and the court may be able to appoint a lawyer to represent you without cost to you if you are a qualifying low-income renter. If you believe you are a qualifying low-income renter and would like an attorney appointed to represent you, please contact the Eviction Defense Screening Line at 855-657- 8387 or apply online at https://nwjustice.org/apply-online. For additional resources, call 2- 1-1 or the Northwest Justice Project CLEAR Hotline outside King County (888) 201-1014 weekdays between 9:15 a.m. —12:15 p.m., or (888) 387-7111 for seniors (age 60 and over). You may find additional information to help you at http://www.washingtonlawhelp.org. Free or low-cost mediation services to assist in nonpayment of rent disputes before any judicial proceedings occur are also available at dispute resolution centers throughout the state. You can find your nearest dispute resolution center at littps://www.resolutionwa.org. State law also provides you'the right to receive interpreter services at court. YOU MUST COMPLY WITH THIS NOTICE BY 30 APRIL 2026 WHICH IS AT LEAST 14 DAYS FROM THE DATE OF THIS NOTICE. Please remit the payment in full to the following address: THUONG-TRI LEGAL SERVICES, PLLC 405 S 4TH ST RENTON, WA 98057 Failure to comply with this notice. -within the specified fourteen -day period may result in further legal action to recover possession of the property in accordance with the laws of the State of Washington. This notice is issued in compliance with RCW 59.18.057. You are granted this fourteen -day period to rectify the situation by paying the outstanding rent and utilities in full or vacate the premises as per legal obligations. If you have any question or need clarification, please contact me immediately at 206-772-4621 or attorp.ey@t.iauongtri.com . Sincerely, s/ THUONG-TRI NGUYEN`;., WSBA #31285 THUONG-TRI LEGAL SERVICES, PLLC 405 S 4TH ST RENTON, WA 98057 Telephone: (206) 772-4621 E-mail: attomey@thuongtri.com w t�CD N N N CD N r r �c 00 >� z p CD oo N ONO 0000 0000 p oOo rn 000 �. rn p 0 0 0 z �C Ge J N p coo ty 00 00 00 6e 6e 64 6e b9 b9 be 6e be be be be be 6e 69 O O O be n Q O O O O O O O O O O O O O O O O O O (D O O O O O O O O O O O O O O O O O O O O O O O O O O O O O 0 0 0 0 0 0 0 0 0 b9 be be be 69 69 69 b9 be be 69 69 64 64 6e be 69 6e R. -" Oo 00 00 Oo 00 00 00 00 00 00 Oo 00 00 00 00 GO (.h 1 -P -P -P -P -P� -P�l � -P � -P -P � P. P -P .P 01 00 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 69 O O O O O O O O O O O O O O O O O O O N O O O O O O O O O O O O O O O O O O O -, O O O O O O O O O O O O O O O O O O O CL a0's✓ 69 6e 6e be 69 6e 64 69 69 6e 69 69 69 be 69 be be 4&9 CD G 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 C O O O o o O O O O O o 0 0 0 0 0 0 0 69 69 69 69 be be be be be 69 69 be be 69 be be 6e 69 b9 ty 000000000000000000o rs`C 00000000000000000cao CD 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 69 69 69 N N N 00 00~+ , 6R be 6bb6 9 6e e e 9 be be be b9 be b6 e 9 69 O O O 6e C + S� O O O O O O O O O O O O O O O O O O O ¢, O O O O O O O O O O O O O O O O O O O O O O O O O O O O O O O O O O O O O O N � O 69 69 6B 69 69 69 69 6e be be 69 be 69 69 be 69 69 Erg ti li 00 00 00 'PO o0 00 00 00 00 00 00 00 00 00 00 m to N sv 4, P -1,. �P �P -P 4, -P -P P 000C)C 0CD 0000CDC) C> p CD 0 0 0 0 0 0 0 0 0 p p p p p p 0 p 0 0 a o 0 0 0 0 0 0 0 0 0 0 0 00 0 0 0 0 + 0 0 0 0 0 0 0 0 0 0 0 0 0 23, 0 0 0 0 0 Exhibit C, declaration of service that Defendants were each served with copies of the 14-day notice to pay or vacate Superior Court of Washington County of KING ARMIN AMANO Plaintiff, V. LILLIAN NUNEZ ALL PERSONS IN POSSESSION, Defendant. No. CERTIFICATE OF SERVICE CERTIFICATE OF SERVICE I certify the following: 1. l am the attorney of record for Plaintiff ARMIN AMANO. 2. T served the following document to Defendant LILLIAN NUNEZ and ALL PERSONS IN POSSESSION. • Letter to tenants; • 14-day pay or vacate notice including unpaid rent and utility accounting. 3. The date, time and place of service were: Date: 7 April 2026 Time: _12:45 p.m. Address: 1522 N BROOKS ST certificate of service; p I of 2 Thuong-Tri Legal Services, PLLC 405 S 4TH ST RENTON, WA 98057 206-772-4621 RENTON WA 98057 4. Service was made: [X] On the date of service, about 12:20 PM, I came to the property. I met a woman coming to her car . I asked her whether she was Lilian. She said yes. I told her I have documents to serve her. I asked again whether she was Lilian. She again said yes. I gave her 2 copies of the documents. Each set of the documents contains: letter to tenants; 14-day pay or vacate notice which includes the unpaid rent and utility accounting. [X] About 12:45 PM, I arrived to the 98057 post office and mailed 2 envelopes by regular first-class mail. Each envelope contains: letter to tenants; 14-day pay or vacate notice which includes the unpaid rent and utility accounting. One envelope was addressed to: LILLIAN NUNEZ. The other envelope was addressed to: ALL PERSONS IN POSSESSION. The envelopes were mailed to the service address. [X] On the same trip to the 98057 post office, I mailed mailed 2 more envelopes by certified mail. Each envelope contains: letter to tenants; 14-day pay or vacate notice which includes the unpaid rent and utility accounting. One envelope was addressed to: LILLIAN NUNEZ. The other envelope was addressed to: ALL PERSONS IN POSSESSION. The envelopes were mailed to the service address. 5. Fees charged for service - Fees: $ + Mileage $ " = Total: $ 6. Attached are: 1) pictures of what was mailed; 2) certified mail receipts at time of mailing; and 3) receipts of certified mail after the postal service has delivered the letters. 4 May 2026 s/ THUONG-TRI NGUYEN WSBA #31285 THUONG-TRI LEGAL SERVICES, PLLC 405 S 4TH ST RENTON, WA 98057 Telephone: (206) 772-4621 E-mail: attorney a,thuon tri.com certificate of service; p 2 of 2 Thuong-Tri Legal Services, PLLC 405 S 4TH ST RENTON, WA 98057 206-772-4621 PHONE I.,UAT THU(ING-TRI Our Specialty Is Helping You THUONG-TRI LEGAL SERVICES, PLLC 4 April 2026 LILLIAN NUNEZ ALL PERSONS IN POSSESSION 1522 N BROOKS ST RENTON, WA 98057 425-757-0871 Hello: I am the attorney representing your landlord for the rental premises located at the above address. As of today, you owe the landlord $8400 for unpaid rent and utilities. Please see the attached accounting of your rent payments. (You may owe more money for late fees and damages to the premises.) Please review the attached documents. You are behind on rent for several months. If you are represented by an attorney, please forward this correspondence to your attorney so that your attorney will contact me. Very truly yours, Signed at (city and state): Seattle; WA s/ THUONG-TRI NGUYEN WSBA #31285 THUONG-TRI LEGAL SERVICES, PLLC 405 S 4TH ST RENTON, WA 98057 Telephone: (206) 772-4621 E-mail: attorney(- thuon trg i. com 405 S 4TH ST / RENTON, WA 98057 (by appointment only) attorney0jInion trg i.com / 206-772-4621 / www.thuon.y�tri.com FOURTEEN -DAY NOTICE TO PAY RENT OR VACATE PREMISES 4 April 2026 TO: LILLIAN NUNEZ ALL PERSONS IN POSSESSION 1522 N BROOKS ST RENTON, WA 98057 425-757-0871 Re: FOURTEEN -DAY NOTICE TO PAY RENT OR VACATE PREMISES Dear LILLIAN NUNEZ, and All Person in Possession, You are receiving this notice because the landlord alleges you are not in compliance with the terms of the lease agreement by failing to pay rent and/or utilities and/or recurring or periodic charges that past due. (1) Monthly rent due for (list month(s)): $8400 (dollar amount). See attached accounting. AND/OR (2) Utilities due for (list month(s)): $0 (dollar amount) AND/OR (3) Other recurring or periodic charges identified in the lease for (list month(s)): $ (dollar amount) TOTAL AMOUNT DUE: $8400 (dollar amount) , Note — payment must be made pursuant to the terms of the rental agreement or by nonelectronic means including, but not limited to, cashier's check, money order, or other certified funds. You must pay the total amount due to your landlord within fourteen (14) days after service of this notice or you must vacate the premises. Any payment you make to the landlord must first be applied to the total amount due as shown on, this notice. Any failure to comply with this notice within fourteen (14) days after service of this notice may result in a judicial proceeding that leads to your eviction from the premises. The Washington state Office of the Attorney General has this notice in multiple languages as well as information on available resources to help you pay your rent, including state and local rental assistance programs, on its website at www.atg.wa.gov/landlord-tenant. State law provides you the right to legal representation and the court may be able to appoint a lawyer to represent you without cost to you if you are a qualifying low-income renter. If you believe you are a qualifying low-income renter and would like an attorney appointed to represent you, please contact the Eviction Defense Screening, Line at 855-657- 8387 or apply online at https://nwjustice.org/apply-online. For additional resources, call 2- 1-1 or the Northwest Justice Project CLEAR Hotline outside King County (888) 201-1014 weekdays between 9:15 a.m. -12:15 p.m., or (888) 387-7111 for seniors (age 60 and over). You may find additional information to help you at http://www.washingtonlawhelp.org. Free or low-cost mediation services to assist in nonpayment of rent disputes before any judicial proceedings occur are also available at dispute resolution centers throughout the state. You can find your nearest dispute resolution center at https://www.resolutionwa.org. State law also provides you the right to receive interpreter services at court. YOU MUST COMPLY WITH THIS NOTICE BY 30 APRIL 2026 WHICH IS AT LEAST 14 DAYS FROM THE DATE OF THIS NOTICE. Please remit the payment in full to the following address: THUONG-TRI LEGAL SERVICES, PLLC 405 S 4TH ST RENTON, WA 98057 Failure to comply with this notice within the specified fourteen -day, period may result in further legal action to recover possession of the property in accordance with the laws of the State of Washington. This notice is issued in compliance with RCW 59.18.057. You are granted this fourteen -day period to rectify the situation by paying the outstanding rent and utilities in full or vacate the premises as per legal obligations. If you have any question or need clarification, please contact me immediately at 206-772-4621 or attorneyntbuongtri.com . Sincerely, s/ THUONG-TRI NGUYEN WSBA #31285 THUONG-TRI LEGAL SERVICES, PLLC 405 S 4Tx ST RENTON, WA 98057 Telephone: (206) 772-4621: E-mail: attorney@thuongtri.com p+ 0 C �J N N N N O O l0 C� rn rn n C C o ONO ONO ONO . 000., N N N CD ty 00 00 00 6S 6S fig 69 6S 6S 69 Ef3 69 6S 6S I&S 69 HS f6s O O O 64 c7 O O O O O O O O O O O O O O O O O O O CD 0 0 0 0 0 0 0 O :O O O O O O O O O O O O O O O O O O O O O O O O O O O O O O 69 64 ff3 ErS 69 6S 6S 6S fig 6S 6S 6S 6S fro 6S rfS 169 fig C1 C) p 00 00 00 00 00 OD 00 00 00 00 00 00 00 00 00 00 A .N p_ -P -P P P -P -P -P P V-P -P -P -P - -P cl� 00 a' ?� O O. 0 0 0 O O O O O O O O O O O O O n �t O O O O O O O O O O O O O O O O O O O CD CD O O O O O 0 0 0 0 0 0 0 0 0 0 0 0 0 O c� O O O O O O O O O O O O O O O O O O O 4be 6s 6S 4EW9 6S 6S 6S 6S 6S b9 6S b9 65 69b9 69 69 69 CD 0 0 0 0 0 0 0 O O 0 0 0 0 0 0 0 O O CD 0 0 0 0 o O o o O O O O o 0 0 0 0 0 a fig 6S 6S rfe 6S r /S 69 b9 6S H9 fiS 6S 6S HS 6S 69 6S: HS 66 CD w �. 0 0 0 0 0 0 0 0 o O O O Cl 0 0 0 0 o O C 000000C)C) C)0o=a) CD ' CD 0 o 0 0 0 o O o O O O O O O o 0 0 o c� N N N 00 00 00 Go 69 69 b9 69 69 fig 6S 69 6S 6S 4&S fig 69 69 O O O 69 C i 0 0 0 0 0 0 0 0 0 0 0 0 O O O O O O O 0 0 0 0 O 0 0 0 0 0 0 0 .O O O O O C) O O O O O O O O O O O O O O O O O O O O 6S 6S 6S 6S 6S 69 69 6S 6S 6S 6S 6S 6S 6S 6S 6S 6S 6S �� O 00 00 00 0o 00 0o 00 00 00 00 00 0o 00 00 00 00 V1 O O O O O O O O O O 0 0 0 0 0 0 0 0be O O O O O O O O O O O O O O O O O O =0 O O O O O O O O O O O O O O O O O O Q O C y N 17' r o°zo >con N 00 0 � b cn Cl) m cn O z Postal �C! 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