SUPERIOR COURT OF WASHINGTON FOR KING COUNTY
STONEBRIDGE SECURITIES, )
LLC, a Washington limited )
liability company; EASTSIDE )
PINNACLE, LLC, a Washington ) NO. 05-2-29419-1
limited liability company; ) SEA
MARTIN S. ROOD; JOSEPH )
S. CARR; LANCE E. FARR; ) SUMMONS
GEORGE D. HOLLAND; and )
KEVIN L. KALDESTAD, )
Plaintiffs, )
vs. )
MICHAEL W. DEVINE; JANE )
DOE DEVINE; the marital )
community comprised of )
MICHAEL W. DEVINE and )
JANE DOE DEVINE; WALTER )
"KELLY" RYAN; JANE DOE )
RYAN; the marital community )
comprised of WALTER )
"KELLY" RYAN and JANE )
DOE RYAN, )
) Defendants. )
TO: WALTER "KELLY" RYAN AND BONNIE RYAN
You are hereby summoned to appear within sixty (60) days after the date of the first publication of this summons, to wit, sixty (60) days after the 31st day of May, 2006, and defend the above entitled action in the above entitled court, and anwer the Amended Complaint of the plaintiffs Stonebridge Securities, LLC, Eastside Pinnacle, LLC, Martin S. Rood, Joseph S. Carr, Lance E. Farr, George D. Holland, and Kevin L. Kaldestad (hereinafter, collectively "Plaintiffs"), and serve a copy of your answers upon James D. Nelson or Victoria M. Pond, who are attorneys for Plaintiffs, at Betts, Patterson & Mines, P.S., 701 Pike St., Suite 1400, Seattle, WA 98101; and in case of your failure to do so, judgment will be entered against Walter "Kelly" Ryan and the marital community comprised of Walter "Kelly" Ryan and Bonnie Ryan according to the demand of the Amended Complaint, which has been filed with the clerk of said court.
This lawsuit against you and your marital community arises out of Walter "Kelly" Ryan's breach of the Guaranty Agreement that he signed on behalf of himself and his marital community on or about August 20, 2004 to personally guaranty the debt of Video Internet Broadcasting Corporation to Plaintiffs. Plaintiffs are collectively owed $273,000.00 pursuant to the Guaranty Agreement. Plaintiffs brought this lawsuit to enforce the Guaranty Agreement to recover $273,000.00, plus interest, attorney fees, and costs from Walter "Kelly" Ryan and from the marital community comprised of Walter "Kelly" Ryan and Bonnie Ryan.
A copy of the Amended Complaint is being mailed to you at General Delivery at the U.S. Post Office in Ephrata, Washington, where plaintiffs believe Walter "Kelly" Ryan to be collecting mail. You may also obtain a copy of the Amended Complaint in this action by contacting the undersigned attorney. If you wish to seek the advice of an attorney in this matter, you should do so promptly so that your written response, if any, may be served on time.
DATED this 25th day of May, 2005.
BETTS, PATTERSON & MINES, P.S.
By /s/Victoria M. Pond
James D. Nelson, WSBA #11134
Victoria M. Pond, WSBA #33159
Attorneys for Plaintiffs
#07005
Pub.: May 31, June 7, 14, 21, 28, July 5, 2006