Description

There is an immediate need for an attorney to fully litigate three ongoing Washington cases: one in the Appellate Court, the second in federal court, and the third in the King County Superior Court. Open to negotiating any hourly rate/or retainer fees, or other fee structures. At this Moment, the Immediate Need is to (1) Obtain an Appellate Stay or Extension of Time, (2) Respond to a Federal Motion to Dismiss, and Provide Representation for a CR 60 Hearing.

Plaintiff (in the federal and Superior Court matters)/Appellant (hereinafter, “Client”) is in need of an Immediate start (shortfuse deadlines) role (by one or more attorneys) to lead litigation and legal strategies, argue at hearings, provide zealous representation, and all other associated legal services for the aforementioned Appellate, federal, and Superior Court matters. As above-referenced, compensation is fully negotiable; Client is open to an ample array of options regarding fee amounts, hourly rates, retainers, or any fee structure, etc.  If desired (but not required), a talented, knowledgeable, and experienced legal writer is available to aid with high-quality legal document drafting for all three cases; work samples available upon request.

STATUS OF MATTERS

These cases have been advanced to a strong position, considering the following factors (but not the sole factors):

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 one-year window. The newly discovered evidence is top-tier, smoking-gun material that proves the veracity of Client’s allegations, as it directly substantiates and proves all claims made and heard at the trial level.

a. For this motion, the Court has required Client to set a hearing date--although, with no stated deadline--which has yet to be done. Ideally, the hearing date should be set immediately. Additionally, the new evidence needs to be organized into exhibits and filed with the Court promptly, for which the Court has granted additional time.

b. In order for new counsel to properly comply with setting a hearing and filing the exhibits, the Court will almost certainly extend any deadlines, or outright grant a stay pending the resolution of the federal and Appellate matters (again, there is no formal order as to a deadline), or until new counsel’s familiarization with this matter, so that new counsel can become familiar and adequately prepare for this Superior Court matter.

2. The federal case is teed up on a Motion to Dismiss, against which a competent response is being prepared (but which will be filed only after new counsel reviews, revises, and approves of it). The immediate need is to extend the deadline for responding or to be granted a stay pending resolution of the Superior Court and Appellate matters, or until new counsel becomes familiar with the matter and can adequately prepare.

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 until new counsel becomes familiar with this Appellate matter. Otherwise, the court will reasonably grant an ample extension of time to allow new counsel to become familiar with this matter and adequately prepare.

a. This sought Appellate due date enlargement is to allow time for Client to respond to the Respondent’s response to the original opening Appellate brief filed by Client, especially considering that the concurrent deadlines of the other cases pressure Client.

b. The current deadline to respond to the Respondent’s response to Client’s Appellate brief is September 11, 2025. 

If prospective counsel is concerned about the concurrent deadlines, Client is open to seeking and being granted stays or extensions for these matters before formal engagement begins.

Client is confident that this leniency will be granted, as the Court has already readily granted similar leniency in the past, with the Court expressing ample sympathy for Client due to the load of his cases, showing a willingness to help Client where and when needed.

DOCUMENTATION

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

SCOPES OF WORK AND PROPOSED TASKS

Track 1 - King County Superior Court (CR60):

Goal: Get the CR60 motion heard on a clean, complete evidentiary record.

Immediate tasks:

• • Note the motion for the civil motions calendar (LCR7) and seek a long setting (90–120 days if available).
  • Prepare a CR60(e) Order to Show Cause and coordinate with Ex Parte/bailiff.
  • File supporting affidavit(s) with exhibits; finalize exhibit index and working copies.
  • Serve “like a summons” per CR60(e)(3)/CR4; file proof of service.
  • Argue the hearing on diligence, materiality, and probability of a different result.
  • 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..):

Goal: Preserve claims and forum options; avoid limitations pitfalls.

Deadline: Oppose motion to dismiss by September 18, 2025.

Immediate tasks:

• • File a targeted Opposition (timeliness/accrual, federal question, equitable tolling; supplemental jurisdiction).
  • Build in Rule 41 (a)(2) alternative: dismissal without prejudice for prompt refiling in King County if needed (no “transfer to state court” is available).
  • Protect state claims via 28 U.S.C. § 1367 (d) tolling; have a state complaint ready to file.
  • Move for an extension of, ideally, 90–120 days under FRCP6(b)/LCR7(j) with detailed good cause showing. 

Track 3 — Court of Appeals (Div. I):

Goal: Align the appeal with the CR60 track.

Current due date: September 11, 2025 (prior 60-day extension granted).

Immediate tasks:

• • File a RAP18.8(a) motion to stay the appeal pending the CR60 proceedings (or for the longest extension possible under RAP18.8(b)).
  • If the Superior Court signals a grant, promptly file RAP7.2(e) request for permission before entry of any altering order.

MATERIALS

The Following Material Will be Provided:

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

IDEAL QUALIFICATIONS

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

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