Description

URGENT HIRE: An Attorney is Needed ASAP to Handle and Lead, Until the Cases are Disposed of, a Washinton Appellate Matter, a Washinton Federal Matter, and a Washington Superior Court matter. At this Moment, the Immediate Need is for a Washington State Litigator is Urgently Needed to (1) Obtain an Appellate Stay or Extension of Time, (2) Respond to a Federal Motion to Dismiss, and Provide Representation for a CR60 Hearing.

Forums and Matters:

1: COURT OF APPEALS, IN AND FOR THE STATE OF WASHINGTON, DIVISION 1: Michael Salvo v. Washington Criminal Justice Training Commission, Et Ano. 

2: IN THE UNITED STATES DISTRICT COURT, IN AND FOR THE WESTERN DISTRICT OF WASHINGTON STATE: Michael Salvo vs the City of Seattle, Washington.

3: IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON, IN AND FOR KING COUNTY, STATE OF WASHINGTON: Michael Salvo vs. Washington Criminal Justice Training Commission and the State of Washington.

In need of an Immediate start (shortfuse deadlines) role to lead litigation and legal strategies, argue at hearings, provide zealous representation, and all other associated legal services. If chosen, high-quality assistance with legal document drafting can be provided.

These cases have been advanced by a pro se litigant, but with competent legal assistance, to a strong position, the strength of which is substantiated by several factors, such as the following:

1. In the Superior Court case, a timely CR60(b)(3) motion (to introduce newly discovered evidence) was filed on August 2, 2025, within the oneyear window. The newly discovered evidence is top-tier, smoking-gun material that prove the veracity of Plaintiff's allegations, as all the new evidence directly substantiate and affirmatively support all claims made at the trial level. For this motion, the Court has required Plaintiff to set a hearing date--although, with no stated deadline--which has yet to be done, thus making said setting of a hearing date a relatively urgent issue.

2. The federal case is teed up on a Motion to Dismiss, agains which a competent response is being prepared. The immediate need here is to move to extend the deadline to respond, which is on September 18, 2025.

3. The Appellate case is active and with a realistic and compelling route to be granted a stay (pending the resolution of the Superior Court and federal matters) or an extension of time.

a. These sought due date enlargements are sought to allow time to respond to the Respondent's response to the orgiinal opening Appellate brief filed by Appellant, especially considering that Appellant has been proceeding pro se and is pressured by the concurrent deadlines of the other cases.

b. Therefore, there is reasonable confidence that ample leniency is very likely to be granted to Appellant, he has been proceeding alone in a pro se capacity while unrepresented, which amply justifies allowing him time to litigate his matters in a fair manner and not with abusive impositions that would otherwise be more appropriate to impose upon seasoned counsel.

c. Appellant is confident because, among other factors, this such leniency has already been readily and easily granted in the past, with the Court expressing ample sympathy for the Appellant and a willingness to help him where needed.

d. The current deadline to respond to the Respondents response to Appellant's Appellate brief is currently September 11, 2025.

All the records, exhibits, and service information are competently organized and ready. These matters are confidently believed to not need to be rebuilt. The heavy lifting has been succesfully accomplished, so now there is a need for an experienced advocate to drive these cases across the line.

Scope of Work

Track 1 - King County Superior Court (CR60):

1. Goal: Get the CR60 motion heard on a clean, complete evidentiary record.
2. Immediate tasks: Note the motion for the civil motions calendar (LCR7) and seek a long setting (90–120 days if available).
3. Prepare a CR60(e) Order to Show Cause and coordinate with Ex Parte/bailiff.
4. File supporting affidavit(s) with exhibits; finalize exhibit index and working copies.
5. Serve “like a summons” per CR60(e)(3)/CR4; file proof of service.
6. Argue the hearing on diligence, materiality, and probability of a different result.
7. Assess recusal (CJC2.11) if there are objective, extrajudicialbias facts.
8. If relief is indicated, file RAP7.2(e) permission before entry of any order altering the judgment on appeal.

Track 2 — Federal Case (W.D. Wash.):

1. Goal: Preserve claims and forum options; avoid limitations pitfalls.
2. Deadline: Oppose motion to dismiss by Sept 18, 2025.
3. Immediate tasks: File a targeted Opposition (timeliness/accrual, federalquestion, equitable tolling; supplemental jurisdiction).
4. Build in Rule41(a)(2) alternative: dismissal without prejudice for prompt refiling in King County if needed (no “transfer to state court” is available).
5. Protect state claims via 28U.S.C.§1367(d) tolling; have a state complaint ready to file.
6. Move for an extension of, ideally, 90–120days under FRCP6(b)/LCR7(j) with detailed goodcause showing.

Track 3 — Court of Appeals (Div. I):

1. Goal: Align the appeal with the CR60 track.
2. Current due date: Sept 11, 2025 (prior 60day extension granted).
3. Immediate tasks: File a RAP18.8(a) motion to stay the appeal pending the CR60 proceedings (or, alternatively, for the longest extension possible under RAP18.8(b)).
4. If the Superior Court signals a grant, promptly file RAP7.2(e) request for permission before entry of any altering order.

The Following Material Will be Provided:

1. The filed CR60(b)(3) motion (timely), organized exhibits, draft indices, and workingcopy checklists, as well as the pleadings.
2. The federal Motion to Dismiss, supporting materials, and a draft extension motion under FRCP6(b), as well as the pleadings.
3. Prior appellate filings, scheduling orders, and a draft stay or extension motion.
4. All other requested documents and materials.

Ideal Qualifications:

1. Washington admission; confident with King County LCR7 practice.
2. W.D. Wash. admission (or immediate eligibility) and CM/ECF proficiency.
3. Appellate experience (RAP18.8, RAP7.2(e)) and CR60(b) motion practice.
4. Capacity to start immediately and argue the CR60 hearing.

Compensation: Plaintiff/Appellant is flexible regarding paying legal fees. Please propose your hourly rate and, if sought, your initial retainer.

How to inquire or apply: Email [email protected].

Bottom line: The case is wellpositioned and meticulously organized. An experienced litigator is needed to take the helm—calendar the CR60 hearing, argue it, steer the federal response (or strategic exit and state refiling), secure the appellate stay or extension, and subsequently assist with all these matters, providing full representation.