Speakeasy Charging Docs

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1

Daniel T. Satterberg, Prosecuting Attorney W554 King County Courthouse

516 Third Avenue

Seattle, Washington 98104

(206) 296-9000, FAX (206) 296·0955

2

3

4

5

.6

SUPERIOR COURT OF WASHINGTON FOR KING COUNTY

7 THE STATE OF WASHINGTON, )

Plaintiff, )

8 v. ) No. ll-C-01781-4 SEA )

9 WILLIAM JAMES DONNELL, III, )

.) MOTION, ~INDING OF PROBABLE

10 ) CAUSE AND ORDER DIRECTING ) ISSUANCE OF SUMMONS ·OR

11 Defendant. ) W ARRANTAND FIXING BAIL

12

The plaintiff, having informed the court that it is filing herein an Information charging the defendant with the crime of Professional Gambling in the Pirst Degree, Count III, now. moves the court pursuant to CrR 2.2(a) for a determination of probable cause and an order directing the issuance of a summons or warrant for the arrest of the defendant, and

" "

13

14

15

( ) fixing the bail of the defendant in the amount of~ __ -, cash or approved surety bond.

16

" .

(X) directing the issuance of a summons.

17

In connection with this motion, the plaintiff offers the following incorporated materials:

The Seattle Police Department certification or affidavit for determination of probable cause; the Seattle Police Department suspect identification data; and the prosecutor's summary in support of order directing issuance of sumf!1ons or order fixing bail and/or conditions of release.

18

19

20

If the defendant is not in custody, the plaintiff has attemptedto ascertain the defendant's CIDTent address by searching the District Court Information System database, the driver's license

21

22

23

24

MOTION, FINDING OF PROBABLE CAUSE AND ORDER DIRECTING ISSUANCE OF SUMMONS OR WARRANT AND FIXING BAIL - 1

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8

Daniel T. Satterberg, Prosecuting Attorney \V554 King County Courthouse

516 Third Avenue


(206) 296-9000, FAX (206) 296-0955

Presented by:

. .

Cvt.d~ ?_'~~/-rl.o-J 23 Andrew R. Hamilton, WSBA #8312 Senior Deputy Prosecuting Attorney

1 and identicard database maintained by the Department of Licenses, and the database maintained by the Department of Corrections listing persons incarcerated and under supervision.

2

3

DANIELT. SATTERBERG Prosecuting Attorney

By: ·O-".A civ-0 '7<_. ~~ t.J~ Andrew R. Hamilton, WSBA #8312 Senior Deputy Prosecuting Attorney

4

5

6

, ,

FINDING OF PROBABLE CAUSE AND ORDER FOR ARREST WARRANT

7

The court finds that probable cause exists to believe that the above-named defendant committed an offense or offenses charged in the information herein based upon the police agency certification/affidavit of probable cause incorporated and pursuant to CrR 2.2(a).

9

IT IS ORDERED that the Clerk of this Court issue a summons or warrant of arrest for the above-named defendant; and

10

IT IS FURTHER ORDERED that

11

( ) the bail of the defendant be 'fixed in the amount of _

cash or approved surety bond.

(X) directing the issuance of a summons; if the defendant is incarcerated on the investigation charge herein the defendant shall be released from custody.

( ) Additional Conditions: _

IT IS FURTHER ORDERED that the defendant be advised of the amount of bail fixed by the court and/or conditions of his 01' her release, and of his or her right to request a bail reduction. Service of the warrant by telegraph or teletype is authorized.

SIGNED this _JL day of March, 2011.

JUD

MARy I, YU

MOTION, FIND,ING OF PROBABLE CAUSE AND ORDER DIRECTING ISSUANCE OF SUMMONS OR WARRANT AND FIXING BAIL - 2

UNINCORPORATED KING COUNTY

CITY OF Seattle 0 MISDEMEANOR

KCCF [8l FELONY

RJC

CASE NUMBER

FILE t-jUMBER

Court King County Superior Court-

RACE

08-15-69

W

CITY Seattle

STATE WA

CITIZENSHIP

COURTJCAU#

COURT1CAU#

CITATION #

COURT/CAU#

CITATION #

COURT/CAU # '

CITATION #

WAS CASH TAKEN INTO EYlDENCE?

YESD NO 0

ITEWSERIAL I/-

AMOUNT:

OFFICER/SERIAL I/-

TRANSPORTING OFF1CERISERIAL 1#

SUPERVISOR SIGNATUREISERIAL 1#

CONTACT PERSON FOR AODITIONAl INFORMATION (NM1E1SERlAl#IPHONE)

BOND REQUESTED: $

WARRANT NUMBER

o BENCH 0

o ARREsrD

OFFENSE

A R-

R A

N

T

I

N

F o

I

E X

T

R

-A o I T E

SERIAL

DATE

TIME

SEAKING-LOCAl ONLY WACIC-STATE WIDE

o

NCIC-WlLl EXTRADITE FROM IO&ORONLY

_0

''',Il.-'''''LL EXTRADITE FROM. OR, 10, MT, WY, CA, NV, VT, co, AZ, NM, HI, AI<

NCIC-WlLL EXTRADITE FROM

o All SO STATES 0

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A TOO
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WAC# _

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REV 7195

(perforation/do not duplicate below this line)

1

Daniel T. Satter berg, Prosecuting Attorney W554 King County Courthouse

516 Third Avenue


(206) 296-9000, FAX (206) 296-0955

2

3

4

5

6


Plaintiff, )
8 v. ) No. ll-C-01787-3 SEA
)
9 RASHAAD IMAN THOMPSON, )
) MOTION, FINDING OF PROBABLE
10 ) CAUSE AND ORDER DIRECTING
) ISSUANCE OF WARRANT AND
11 Defendant. ) FIXING BAIL 12

The plaintiff, having informed the COUli that it is filing herein an Information charging the defendant with the crimes of Professional Gambling in the First Degree, Count I, Professional gambling in the First Degree, Count 1I, Professional Gambling in the First Degree, Count III, and Professional Gambling in the First Degree, Count IV, now moves the court pursuant to CrR 2.2(a) for a determination of probable cause and an order directing the issuance of asummons or warrant for the. an-est of the defendant, and

'13

14

15

( . ) fixing the bail of the defendant in the amount of _

16 cash or approved surety bond.

17 (X) directing the issuance of a summons.

18 In connection with this motion, the plaintiff offers the following incorporated materials:

The Seattle Police Depaltment certification or affidavit for determination of probable cause; the 19 Seattle Police Department suspect identification data; and the prosecutor's sumrriary in support of order directing issuance of summons or order fixing bail and/or conditions of release.

20

If the defendant is not in custody, the plaintiff has attempted to ascertain the defendant's 21 current address by searching the District Court Information System database, the driver's license

22

23

24


10

11

12

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8


516 Third Avenue


(206) 296-9000, FAX (206) 29.6·0955

Presented by:

~~ (Z. ,~;tfv

23 Andrew R. Hamilton, WSBA #8312 Senior Deputy Prosecuting Attorney

3

DANIEL T. SATTERBERG Prosecuting Attorney

By: ~dJL-v Ie, ~ '~.1

Andrew R. Hamilton, WSBA #8312 Senior Deputy Prosecuting Attorney.

4

5

6


7


9


ITIS FURTHER ORDERED that

( ) the bail of the defendant be fixed in the amount of _



( ) Additional Conditions: < _

IT IS FURTHER ORDERED that the defendant be advised of the amount of bail fixed by the COUlt and/or conditions of his or her release, and of his or her right to request a bail reduction. Service of the warrant by telegraph or teletype is authorized,

SIGNED this _li_ day of March, 2011.

l\,fAt1.Y I. ~YU

JUDG


,SUPERFORM

peN NUMBER

'fCLEL 13 18 ! 1 Is b I s I

CASE NUMBER FILE NUMBER

Court King County Superior Court

AGENCY:O UNINCORPORATED KING COUNTY

!8l CITY OF Seattle 0, MISDEMEANOR

o KCCF I8J FELONY, .

o RJC

CITY Seattle

STATE WA

ZIP 981

EMPLOYER, SCHOOL (ADDRESS, SHOP/uNION NUMBER)

FBI# 830062AB8

COURT/CAUff.

CITATIONff.

COURT/CAU#

CITATfOH#

COURT/CAU#

CITAT!ONff.

CITATIOH#

CRIMiNAl TRAFFIC CITATION ATTACHED?

YEsD NOD

VALUABLE ITEMS OR PROPERTY EHTERED INTO EVIDENCE YESO NO 0 IF YES, DESCRIBE (8IMPLE DESCRIPTION, IDENTIFYING MARKS, SERIAL #)

ITEM/SERIAL it

CASH OF ARRESTEE WAS CASH TAKEN INTO EVIDENCE?

YESD NO 0

SUPERFORM COMPLETED BY (SIGNATURE/SERIAL If}

ADULTMISDE

both sides

11 -.to 1} 8 7

BOND REQUESTED: $

. CT. DATE

NUMBER

A R R

A POLICE AGENCY ISSUING

N

r

I PERSON APPROVING EXTRADITION N

6

J E X T R A o I T E

OFFENSE

FELONY 0' MISD ... 0

BENCH 0 ARREST 0

COURT

SERIAL UNIT

DATE TIME

. CCN#
E
N WAC#
T
R NIC#
Y 0 0
c.
DOE L DOC
E
TOE, A TOO
R
OPff.· A ·OPff.
N
C REV 7195


1


516 Third Avenue .


(206) 296-9000, FAX (206) 296-0955'

2

3

4

5

6


11

)

Plaintiff, )

) No. n-c-o 1786-5 SEA )

)

) MOTION, FINDING OF PROBABLE ) CAUSE AND ORDER DIRECTING . ). ISSUANCE OF WARRANT AND

Defendant. ) FIXING BAIL

----------~----------------~~~~~

7 THE STATE OF WASHINGTON,

8 v,

9 DKPAN, 10

20

21

22

23

24

12 The plaintiff, having.informed the court that it is filing herein an Information charging

the 'defendant with the crimes of Professional Gambling in the First Degree, Count I,

13 Professional gambling in the First Degree, Count II, and Professional Gambling in the First Degree, Count m.new moves the court pursuant to CrR 2.2(a) for a determination of probable 14 cause and an order directing the issuance of a summons or wan-ant for the arrest of the defendant, and

15

16

( ) fixing the bail of the defendant in the amount of' : __ ---' cash or approved surety bond.

17

(X) directing the issuance of a summons.

18

In connection with this motion, the plaintiff offers the following incorporated materials:

The Seattle Police Department certification or affidavit for determination of probable cause; the Seattle Police Department suspect identification data; and the prosecutor's summary in support of order directing issuance of summons or order fixing bail andlor conditions of release.

19

If the defendant is not in custody, the plaintiffhas attempted to ascertain the defendant's current address by searching the District Court Information System database, the driver's license


2


516 Third Avenue


(206) 296-9000, FAX (206) 296-0955

1 and identicard database maintained by the Department of Licenses, and the database maintained by the Department of Corrections listing persons incarcerated and under supervision.

3

DANIELT. SATTERBERG Prosecuting Attorney

By: C~t"J<i(·'~;t/vJ

AndrewR. Hamilton, WSBA #8312 Senior Deputy Prosecuting Attorney

4

5

6


7

The court finds that probable cause exists to believe that the above-named defendant committed, an offense 01' offenses charged in the information herein based upon the police agency certification/affidavit of probable cause incorporated and pursuant to CrR 2.2(a)~


8

9

10


11

12



13

(X) directing the issuance of a summons; if the defendant is incarcerated on the investigation charge herein the defendant shall be released froni custody.

14

15

( ) Additional Conditions: __ -,-- _

16

17

18

IT IS FURTHER ORDERED that the defendant be advised of the amount of bail fixed by the court and/or conditions of his or her release, and of his or her right to request a bail reduction. Service 'of the warrant by telegraph or teletype is authorized.

SIGNED this I (

19

day of March, 2011.

20

IVIARYI. YU

21

Presented by:

~~ ((, <p./~-:tI~ 23 Andrew R. Hamilton, WSBA #8312 Senior Deputy Prosecuting Attorney

22

24


- b Is 11 Is b 151

CASE NUMBER

FILE NUMBER

SUPERFORM

PCNNUMBER

AGENCY:D UNINCORPORATED KING COUNTI'

I8l CITY OF Seattle 0 MISDEMEANOR

DAJD 0 KCCF !8l FELONY

RJC


BOOKING DATEfTlME

!

RACE

09-04-72

A

CITY Seattle

STATE WA

ZIP

98104

crnZENSHIP

SCHOOL (ADDRESS, SHOPIUNjON NUMBER)

COURT/CAUl

COURT/CAUR

CITATION#.

COURT/CAUl

CITATION #

COURT/CAUl

CITATION #

CRIMINAL TRAFFIC CITATION ATIACHED?·

YES 0 NoD

OR PROPERTY ENTERED INTO EVIDENCE

NO 0 IF YES, DESCRIBE

DESCRIPTION, IDENTIFYING MARKS, SERIAL fJ)

CASH TAKEN INTO EVIDENCE?

YESD NO 0

SIGNATURE OF JAIL STAFF RECEMNG ITEM/SERIAL #

S IGNATUREISERIAL II

lete both sides

COURT CAUSE (STAMP OR WRITE)

1 1

BOND REQUESTED; $

BENci-l D ARREST D

OFFENSE

DATE

TIME

COURT

APPROVING EXTRADI!ION

D

,0 D
C
l DOC
E
A TOO
R
A Opt
N
C E N T R Y

CCN#~ __

WACII __

NICII ~ __

06E ,.- _

TOE _

OP# _

REV 7195


1


516 Third Avenue


(206) 296-9000, FAX (206) 296-0955

, -

2

3

4

5

6 SUPERIOR COURT OF WASHINGTON FOR KING COUNTY

7 THE' STATE OF WASHINGTON, )
Plaintiff, )
8 v. ) No. l1-C-01785-7 SEA
)
9 JAMES P. MILLER, )
11 Defendant. ) FIXING BAIL 12 The plaintiff, having informed the court that it is filing herein an Information charging

the defendant with the crimes of Professional Gambling in the First Degree, Count I,

13 Professional gambling in the First Degree, Count II, and Violation of the Uniform Controlled Substances Act, Count V, now moves the court pursuant to CrR 2.2(a) for a

14 determination of probable cause and an order directing the issuance of a summons or warrant for the arrest of the defendant, and'

15

( ) fixing the bail of the defendant in the amount.of~~~_




The Seattle Police Department certification or affidavit for determination of probable cause; the 19 Seattle Police Depmtment suspect identification data; and the prosecutor's summary in support of order directing issuance of summons or order fixing bail andlor conditions. of release.

20


22

23

24


Presented by:

&<.~ '12, <rL._--.~ v-H~

23 Andrew R. Hamilton, WSBA #8312 Senior Deputy Prosecuting Attorney

10

11

12

13

14

15

16

17

18

19

20

21

22

24

1. and identicard database maintained by the Department of Licenses, and the database maintained by the Department of Corrections listing persons incarcerated and under supervision.

2

3


By: ~~ 72, ~,J/N

Andrew R. Hamilton, WSBA #8312 Senior Deputy Prosecuting Attorney

4

5

6

FINDING OF PROBABLE CAUSE AND ORDER FOR ARREST WARRANT·

7


8

9



( ) the bail of the defendant be fixed in the amount of .:»




IT IS FURTHER ORDERED that the defendant be advised of the amount of bail fixed by the court and/or conditions of his or her release, and of his or her right to request a bail reduction, . Service of thewarrant by telegraph or teletype is authorized.

SIGNED this L day of Ma~'ch, 2011.

moo

MARY I. YU



516 Third Avenue

. Seattle, Washington 98104

(206) 296-9000, FAX (206) 296-0955

SUPERFORM


Seattle D MISDEMEANOR

KCCF [2J FELONY

RJC

RACE

w

ZIP 98103

crrv Seattle

STATE WA

CASE NUMBER

FILE NUMBER


EMPLOYER, SCHOOL (ADDRESS, SHOPIUNION NUMBER)

CRIMINAL TRAFFIC CITATION ATTACHED?

YES 0 NOD,

COURT/CAUIl

FBI#

CITATION #

CITATION #

COURT/CAUIl

CITATION;!!

COURT/CAUIl

COURT/CAU#

CITATION;!!

OF JAIL STAFF RECEMNG ITEM/SERIAl #

V1\'.V,,'C>L" ITEMS OR PROPERTY INTO EVIDENCE

NO 0 IFYES. DESCRIBE

DESCRIPTION, IDENTlfYlNG MARKS, SERIAL Ii)

CASH TAKEN INTO EVIDENCE? D NOD

BY (SIGNATUREISERIAl #}

11,-(;01

REQUESTED:

• CT. DATE

NCIC-WlLl EXTMDITE FROM 10 &ORONLY

o

NCIC-WI Ll EXTRADITE FROM OR, ID, MT. Wf, CA, NV, UT, 0 AZ, NM, HI, AK

"""'I.r'","" EXTRAOITE fROM ALL 50 STATES 0

SUPERVISOR S IGNATUREISERIAl 11-

plete both sides

BENCH 0 ARREST 0

SERIAL

DATE

TIME

CCN# __

WACfI. -:- __

DOE __

TOE __

E N T R Y

NICfI. _

OP# __

C
L DOC
E.
A TOO
R
A OP#
N
c REV 7195


16

1

Daniel T. Satter berg, Prosecuting Attorney W554 King County Courthouse

516 Third Avenue


(206) 296-9000, FAX (206) 296-0955

2

3

4

5

6

SUPElUOR COURT OF WASHINGTON FOR KING COUNTY

Plaintiff; )
8 v. ) No. II-C-01784-9 SEA
)
9 IAN MICHAEL MCNAMARA, )
) MOTION, FINDING OF 'PROBABLE
11 Defendant. ) FIXING BAIL 12

The plaintiff, having informed the court that it is filing herein an Information charging the defendant with the crime of Professional Gambling in the First Degree, Count IV, now moves the court pursuant to CrR 2.2(a) for a determination of probable cause and an order directing the issuance of a summons or warrant for the arrest of the defendant, and

13

14

( ) fixing the bail of the defendant in the amount of _


(X:) directing the issuance ofa summons.

17

In connection with this motion, the plaintiffoffers the following incorporated materials:

The Seattle Police Department certification or affidavit for determination of probable cause; the Seattle Police Depatiment suspect identification data; and the prosecutor's summary in support of order directing issuance of summons or order fixing bail and/or conditions of release.

18

19


21

22

21

24

MOTION, FINDING OF PROBABLE CAUSE AND ORDER DIRECTING ISSUANCE OF SUMMONS OR WARRANT AND FIXING BAIL-l

2


516 Third Avenue


(206) 296-9000, FAX (206) 296·0955

1 and identicard database maintained by the Department of Licenses, and the database inaintained by the Department of Corrections listing persons incarcerated and under supervision.

3


·By: (h_~~j I( ,. ~ ,-t/;_.j

Andrew R, Hamilton, WSBA #8312 Senior Deputy Prosecuting Attorney

4

5

6


7

The court finds that probable cause exists to believe that the above-named defendant committed an offense or offenses charged in the information herein based upon the police agency certification/affidavit of probable cause incorporated and pursuant to CrR 2.2( a),

8

9

IT IS ORDERED that the Clerk of this Court issue a summons or warrant of an est for the above-named defendant; and

10


11

12



13

(X) directing the issuance of a summons; if the defendant is incarcerated on the investigation charge herein the defendant shall be released from custody,

14

15

( ) Additional Conditions: _____:. _

16

17

IT IS FURTHER ORDERED that the defendant be advised of the amount of bail fixed by 18 the court and/or conditions of his or her release, and of his or her right to request a bail reduction, Service of the warrant by telegraph or teletype is authorized.

19

SIGNED this (1 day of March, 2011.

20

JUDGE

21

MARYI,YU

22

Presented by:

CL.J~.J 7(. (P{~-:dLr0


~ 23

24


AGENCY:D UNINCORPORATED KING COUNTY

I'2J CITY OF Seattle 0 MISDEMEANOR

o KCCF .1'2J FELONY

o RJC

CASE NUMBER

FILE NUMBER


BOOKING DATEffIME

I

RACE

09-04-72

W

CITY Seattle

STATE

WA

CITIZENSHIP

1} OFFENSE RCW/ORD #

o DV INV of PROFESSIONAL GAMBLING 1; RCW 9.46.220

COURTICAU#

2}OFFENSE RCW/ORDti

o DV INV of CONDUCT GAMBLING wlo LICENSE; 9.46.160

COURT/CAUi

CITATION #

COURT/CAU#

CITATION #

CITATION #

SIGNATURE OF JAlL STAFF RECEMNG ITEMIS ERIAL #

TRANSPORTING OFFICER/SERIAL tI

SIGNATURE/SERIAL #

both sides

o IN CUSTODY

o AT lARGE

o OLIT ON BOND

'. ~ I

JC.h

DIST.CT. BOND$

WARRANT NUMBER

SUP. CT. DATE

BOND s

OFFENSE

BENCH 0 ARREST 0

DATE

TIME

D

NCIC-W1LL EXTRADITE FROM ID&ORONLY

D

r """lrYVILL EXTRADITE FROM ALL so STATES 0

I
E
X CCN#
T E
R N WACtI
A T.
D R NIC#
J Y
REV7J95 DOE __

TOE ~ __

DOC __

l E A R A N C

TOD ~--

OPtl __

OP# __

(perforation/do not duplicate below. this line)

1

DanlelT. Satterberg, Prosecuting Attomey W554 King County Courthouse

516 Third Avenue


(206) 296·9000, FAX (206) 296·0955

2

3

4

5

6 SUPERIOR COURT OF WASHINGTON FOR KING COUNTY

7 THE STATE OF WASHINGTON) )
Plaintiff, )
8 v. ) No. ll-C-01783-1 SEA
J
9 BRADY DONOGHUE MCGARRY, )
11 Defendant. ) FIXING BAIL 12 The plaintiff) having informed the court that it is filing herein an Information charging

the. defendant with the crimes of Professional Gambling in the First Degree, Count I,

13 Professional gambling in the First Degree, Count II, Professional Gambling in tile First Degree, Count III, and Professional Gambling in the First Degree, Count IV, now moves the i4 court pursuant to CrR 2.2(a) for a determination of probable cause and an.order directing the issuance of a summons or warrant for the arrest of the defendant, and

15·

( ) fixing the bail of the defendant in the amount of _




The Seattle Police Department certification or affidavit for determination of probable cause; the 19 Seattle Police Department suspect identification data; and the prosecutor's summary in support of order directing issuance of summons or order fixing bail and/or conditions of release.

20

If the defendant is not in custody, the. plaintiff has attempted to ascertain the defendant's 21 current address by searching the District Court Information System database, the driver's license

22.

23

24

MOTION, FINDING OF PROBABLE CAUSE AND ORDER DIRECTING ISSUANCE OF SUMMONS OR WARRANT AND FIXING BAIL-l

JI

2


516 Third Avenue


(206) 296-9000, FAX (206) 296-0955

1 and identicard database maintained by theDepartment of Licenses) and the database maintained by the Department of Corrections listing persons incarcerated and under supervision.

3


By: . CAA---J-J---l 'I{ , ~~ J'f/dh) Andrew R. Hamilton) WSBA #8312 Senior Deputy Prosecuting Attorney

4

5

6


7


8

9

IT IS ORDERED that the Clerk of this Court issue a summons or warrant of arrest for· the above-named defendant; and

10


.11

12


cash or approved surety bond,

13


14

15

( ) Additional Conditions: . ~ _

16

17

18

IT IS FURT,HER ORDERED that the defendant be advised of the amount of bail fixed by the court and/or conditions of his or her release, and of his or her right to request a bail reduction. Service of the warrant by telegraph or teletype is authorized.

SIGNED this --t-k- day of March, 2011,

19

20

21

Presented by:

G~d1_L-J. '7< ,~~ $/-J

23 Andrew R. Hamilton) WSBA #8312 Senior Deputy Prosecuting Attorney

MARYI.YU

22

24

. MOTION) FINDING OF PROBABLE CAUSE AND

ORDER DIRECTING ISSUANCE OF SUMMONS OR WARRANT AND FIXING BAIL - 2


SUPERFORM


[8l CITY OF Seattle 0 :MISDEMEANOR

o KC:CF [8l FELONY

RJC

CASE NUMBER

FILE NUMBER

RACE

04-20-82

W

crrv Seattle

ZIP

98122

CITIZENSHIP

STATE WA

EMPLOYER, .

(ADDRESS, SHOPIUNION NUMBER)

COURTfCAU#

COURT/CAU#

CITATION #

COURT/CAU#

CITATION #

COURT/CAU#

C!TAT!ON#

CRIMINAL TRAfFIC CITATION ATTACHED?

YEsD NoD

ACCOMPLICES

SIGNATURE OF JAIL· STAFF RECEMNG ITEMISERIAL #I

SUPERVISOR SIGNATUREJSERIAL #I

COMPLETED BY (SIGNATURE/SERIAl til

lete both,sldes

OUTONBOND.

OIST,CT· BOND s

BOND $

OFFENSE

D D

BENCH 0 ARREST 0 .

OF BAil

TIME

SERIAL

COURT

DATE

SEAKING·LOCAL ONLY WACIC..sTATE WIDE

o

D

NCIC-WlLL EXTRADITE FROM lD&ORONlY

'0

NCIC-WllL EXTRADITE OR, 10, MT, \NY, CA, NV, UT, CO, AZ, NM, HI, AI{

"'v'v-V'VILL EXTRADITE FROM ALL so STATES D

E N T R Y

DOE ----------~--

DOC ~

L E A R A N C

·T.OE __

OP# __

WAC# ~---------

TOO __

OP# __

NIC# ___

REV7}95

(perforation/do not duplicate below this Ilne)

!' ,

1


516 Third Avenue


(206) 296·9000, FAX (206) 296·0955

.! . . ~

2

3

4

5



Plaintiff, )

8 v. ) No. ll-C-01782-2 SEA )

9 HOWARD THOREN HONEYCUTI, )


10 ) CAUSE AND ORDER DIRECTING ) ISSUANCE OF WARRANT AND

11 Defendant. ) FIXING BAIL

6

12 ,The plaintiff, having informed the court that it is filing herein an Information charging

the defendant with the crimes of Professional gambling in the First Degree, Count II, and

13 Violation of the Uniform Controlled Substances Act, Count VI, now moves the court pursuant to CrR 2.2(a) for a determination of probable cause and an order directing the issuance

14 of a summons or warrant for the arrest of the defendant, and .

15 ( ) fixing the bail of the defendant in the amount of _ cash or approved surety bond.

16

ex) directing the issuance of a summons.

17

In connection with this motion, the plaintiff offers the following incorporated materials: 18 The Seattle Police Department certification or affidavit for determination of probable cause; the Seattle Police Depmiment suspect identification data; and the prosecutor's summary in support 19 of order directing issuance of summons or order fixing bail and/or conditions of release.

20 If the defendant is not in custody, the plaintiff has attempted to ascertain the defendant's

CU11'ent address by searching the District C0U11 Information System database, the driver'S license

21

22

23

24


. .

. 1 and identicard database maintained by the Department of Licenses, and the database maintained by the Department of Corrections listing persons incarcerated and under supervision.

10

il

12

13

14

15

16

17

18

19

20

21

22

23

24

2

3


By: ~~ 72 .. ~-;t/(J-._J


4

5

6


7

The court finds that probable cause exists to believe that the above-named defendant committed an offense or offenses charged in the information herein based upon the police agency

certification/affidavit of probable cause incorporated and pursuant to CrR 2.2(a). . .

8

9



( ) the bail of the defendant be fixed in the amount of~ _




IT IS FURTHER ORDERED that the defendant be advised of the amount of bail fixed by the court and/or conditions of his or her release, and of his or her right to request a bail reduction. Service of the warrant by telegraph or teletype is authorized.

SIGNED this A day of March, 2011.

JUD

MARY 1. 18

Presented by:

~~ I( ~ cM~/-tlo--J



Daniel T. Satterberg, Prosecuting Attomey

. W554 King County Courthouse 516 Third Avenue


(206) 296-9000, FAX (206) 296-0955


SUPERFORM

PCNNUMBER

IOJJJ_ b Is" -h Is b 15 I

CASE NUMBER

AGENCY:O UNINCORPORATED KING COUNTY "

[8J CITY OF Seattle 0 MISDEMEANOR

o KCCF [8J FELONY "

o RJC

FILE NUMBER

RACE

w

CITY Seattle

STATE WA

ZIP

EMPLOYER, SCHOOL (ADDRESS, SHOPiUNION NUMBER)

COURT/CAUfi

COURTICAUfi

CITATIONfi

- delivery; RCW 6~.50

RCW/OROI

COURT/CAUfi

CITATIONfi

RCW/ORDI

CITATIONfi

COURT/CAUfi

CRIMINAL TRAFFIC CITATION ATTACHED?

YES 0 NOO

SIGNATURE OF JAIL STAFF RECEIVING ITEM/SERIAL fI

SUPERVISOR SIGNATURE/SERIAL #

CONTACT PERSON FOR ADOITJONAL INFORMATION (NAMEISERlALfIIPHONE)

sides

0I8T. CT. BOND REQUESTED;

BOND $ $

7 o r; t) SEA
I II "
NUMBER
BENCH 0
AAREST D
SERIAL UN]:r " DATE TIME OFF CODE OFFENSE

NCIC-Wlll EXTRADITE FROM lD & OR ONLY

D

NCIC-Wlll EXTRADITE FROM

OR, [D, Mr, WY, CA, NIl, UT, D CO, AZ, NM, HI, AI<

NCIC-Wlll EXTRADITE FROM All 50 STATES 0

C L E A R A N C

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20

21

22

23

24

JI

,.

1

2

3

4

5

6


516 Third Avenue


(206) 296-9000, FAX (206) 296-0955


) )

) No. ll-C-01781-4 SEA

) 11-C-01782-2 SEA

) l1-C-01783-1 SEA

) ll-C-01784-9 SEA

) l1-C-01785-7 SEA

) . ll-C-01786-5 SEA

)" 11-C-01787-3 SEA

)

) INFORMATION )

)

Defendants. )'

That the defendants BRADY DONOGHUE MCGARRY, JAMES P. MILLER, DK PAN and RASHAAD IMAN THOMPSON, and each Of them, in King County, Washington, during a period of time intervening between October 1,2007 through June 30, 2009, did engage in and knowingly cause, aid, abet and conspire with each other and others to engage in professional gambling; and did act in concert with and conspire with five or more people; and was involved with and worked in an operation that accepted wagers exceeding five thousand dollars during any thirty-day period on future contingent events; and did operate, manage and profit from the

14

I, Daniel T. Satterberg, Prosecuting Attorney for King County in the name and by the authority of the State of Washington, do accuse BRADY DONOGHUE MCGARRY, JAMES P. MILLER, DK PAN and RASHAAD IMAN THOMPSON, and each of them, of the crime of

17 Professional Gambling in the First Degree, committed as follows:

COUNT I

15

16

18

19

INFORMATION - 1

14

15

16

17

18

19

20

21

22

23

24

11


516 Third Avenue


(206) 296·9000, FAX (206) 296·0955

1. people; and was involved with and worked in an operation that accepted wagers exceeding five thousand dollars during any thirty-day period on future contingent events; and did operate, manage and profit from the operation of premises or locations where persons were charged a fee to participate in card games that were not lawfully authorized or licensed, ata premises known as "Bill's," originally located at 2646 NW 64th Street, Seattle, and subsequently moving to 9721 6th Avenue NW, Seattle;

2

3

4

5

Contrary to RCW 9.46.220(1)(a) and (d), and against the peace and dignity of the State of

Washington. . .

6

COUNT IV

7

And I, Daniel T. Satterberg, Prosecuting Attorney aforesaid further do accuse BRADY DONOGHUE MCGARRY, IAN MICHAEL MCNAMARA and RASHAAD IMAN THOMPSON, and each of them, of the crime of Professional Gambling in the First Degree, a crime of the same or similar character as another crime charged herein, which crimes were part of a common scheme or plan and which crimes were so closely connected in respect to time, place and occasion that it would be difficult to separate proof of one charge from proof of the other, committed as follows:

8

9

10

12

That the defendants BRADY DONOGHUE.MCGARRY, IAN MICHAEL MCNAMARA and RASHAAD IMAN THOMPSON, and each of them, hi King County, Washington, during a period oftime intervening between February 1,2008 through June 3D, 2009, did engage in and knowingly cause, aid, abet and conspire with each other and others to engage in professional gambling; and did act in concert with and conspire with five or more people; and was involved with and worked in an operation that accepted wagersexceeding five thousand dollars during any thirty-day period on future contingent events; and did operate, manage and profit from the operation of premises or locations where persons were charged a fee to participate in card games that were not lawfully authorized or licensed, at a premises known as

"The Bit Tavern," located at 4818 17th Avenue NW, Seattle; .

13

Contrary to RCW 9.46.220(1)(a) and (d), and against the peace and dignity of the State of Washington.

COUNT V

And I, Daniel T. Satterberg, Prosecuting Attorney aforesaid further do accuse JAMES P.

MILLER of the crime of Violation of the Uniform Controlled Substances Act) a crime of the same 01' similar character as another crime charged herein, which crimes were part of a common scheme or plan and which crimes were so closely connected in respect to time, place and occasion that it would be difficult to separate proof of one charge from proof of-the other, committed as follows:

INFORMATION - 3

20

24

2

INFORMATION - 4


516 Third Avenue

Seattle, Washington 9& 104

(206) 296-9000, FAX (206) 296-0955

That the defendant JAMES P, MILLER in King County, Washington, during a period of time intervening between June 8, 2008 through September 24, 2008, unlawfully and feloniously did deliver cocaine, a controlled substance and a narcotic drug, to another, and did know it was a controlled substance;

3

4

Contrary to RCW 69.50.401(1), (2)(a), and against the peace and dignity of the State of Washington.

5

COUNT VI

6

And I, Daniel T. Satterberg, Prosecuting Attorney aforesaid further do accuse HOWARD THOREN HONEYCUTT of the crime of Violation of the Uniform Controlled Substances Act, a crime of the same or similar character as another crime charged herein, which crimes were part of a common scheme or plan and which crimes were so closely connected in respect to time, place and occasion that it would be difficult to separate proof of one charge from proof ofthe other, committed as follows:

7

8

9

10

That the defendant HOWARD THOREN HONEYCUTT inKing County, Washington, on or about January io, 2009, unlawfully and feloniously did deliver cocaine, a controlled substance and a narcotic drug, to another, and did know it was a controlled substance; .

11

12

. Contrary to RCW 69.50.401(1), (2)(a), and against the peace and dignity of the State of Washington.

13


14

15

By: aA-~ )"C, ~ Ttic~


16

17

18

19

21

22

23

,l'I--[:_iJlf

CAUSE NO. D_l _'_-_Lt_S_EA 'Cf!;~~'Jtftf

SEATTLE POLICE DEPARTMENT

eERT/FICA TlON FOR DETERMINA TlON OF PROBABLE CAUSE

That Ryan M. Long is a Detective Sergeant with the Seattle Police Department and has reviewed the investigation conducted in Seattle Police Department Case Number 07-381875;

There is probable cause to believe that William J. Donnell 8/15/1969 committed the crime(s) of Professional Gambling 1st degree, RCW 9.46.220 (Class B Felony); Ownership/Interest in a Gambling Device, RCW 9.46.215; Conducting (Gambling) Activity Without a License, RCW 9.46.160 (Class B felony); Causing a Person to Violate Chapter, RCW 9.46.180 (Class B Felony); Acting Without a (Liquor) License, RCW 66.44.090 (Gross Misdemeanor) within the City of Seattle, County of King, State of Washington.

5. ~t~:~~6.~~/ . ..

Thisbelie(js predicated on the following facts and circumstances: !~~t":_;J?~$"l~ .... ~. ~~~i1:-·

Seattle Police personnel became aware of an illegal gambling/alcohol enterprise at 2646 NW 64th Street, Seattle, King County, Washington, on or about February 18, 2008. Subsequent investigation utilizing Undercover Detectives (UeD), audio intercepts, and video and photographic surveillance confirmed the existence of underground illegal gambling enterprises (concurrent with illegal liquor sales), and supported the issuance of search warrants which yielded additional evidence.

Between February of 2008 and June of 2009, WilliamJ, Donnell planned, conspired, prepared, participated in and paid support for gambling enterprise(s) within the City of Seattle, County of King, State of Washington. These included the houses located at 2646 NW 64th Street and 9.121

6th Avenue NW, in the City of Seattle. '

Donnell rented each of these houses, resided in them, and oversaw the gambling activities that took place in each residence. Donnell performed all of the duties of a "game manager/pit boss." A "game manager/pit boss') oversees the gambling activity and acts as the ultimate arbiter of any disputes that may arise during the gambling activity. He provides direction to each dealer regarding table operations including gifting (giving a player free chips), when to change decks of cards) and the rotation of dealers. In addition to performing the function of the "game manager/pit boss," Donnell participated in the illegal gambling activities as both a dealer and a player.

Persons or organizations who wish to engage in lawful, charitable gambling activities such as raffles, must satisfy certain requirements of the Washington State Gambling Commission, which includes the notification of local law enforcement. For the City of Seattle, the police department's .Vice Unit is the entity to be notified. The review of such notifications is my responsibility, At no .time did any person associated with the afore-mentioned locations make notification of such charitable efforts, even for subterfuge.

Illegal gambling/liquor activities occurred frequently at these locations, and rose to a level sufficient to reach 'Professional Gambling in the 15t degree. Agent Clint Lucci, of the Washington State Gambling Commission, accompanied Detective Bryan Van Brunt to these illegal gambling locations. While there, Agent Lucci made a technical estimate of the gambling

Form 34,0 1/06

PAGE 1 OF 2


INCIDENT NUMBER

07-381875

CERTIFICA TION FOR DETERMINATION OFPROBABLE CAUSE

UN IT FILE NUM BER

activities. His conclusion was that there was in excess of $5,000 in wagers made on each of the occasions he was there in which the operators made financial gain. Each purchased alcoholic beverages from staff within these locations. According to the undercover officer, he observed more than five individuals involved in the gambling operations of each location.

Donnell's specific violations were noted on approximately 10 undercover visits during the investigation, not including the incident when Donnell was detained during the service of search

warrants at 9721 6th Avenue NW On June 10,2009. .

Detective Van Brunt engaged in illegal gambling activities at 2646 NW 64th Street on two occasions: February 18 and April 16, 2006. Donnell demonstrated his leadership role in the

former and participated as a dealer in the latter. .

By the end of April, 2008, Donnell ceased activities at the former address and moved to a new residence at 9721 6th Av NW. The illegal activities continued at .this location. During undercover visits on April 29, May 5, and June 9, Donnell participated as a dealer. He hosted these activities again. during an undercover visit on August 12 and then participated as a player on October 12, 2008, when he invited Detective Van Brunt to a party at the residence on November 1,2008. A flyer advertising this event was maintained as evidence, though Detective Van Brunt did not participate. Additional undercover visits included December 7, 2008, as well

as January 11 and March 26, 2009. .

Form 34.0E 5/98

PAGE 2 OF 2

Pursuant to the issuance of search warrants, the residence at 9721 6th A v NW was searched for evidence, which revealed countless items of investigatory value. These included gambling items . (tables, chips, cards, etc), liquor items (alcohol, coolers, etc), and drug items (quantities of assorted drugs, scales, etc), as well as money. An examination of Donnell's cellular phone revealed additional incriminating evidence regarding the illegal gambling and drug activity.

Under penalty of perjury under the laws of the State of Washington, I certify that the foregoing is

true and correct to best of my knowledge and belief. Signed and dated by me this ]' ri]

day of EEBR-uAfl--y ,2011, at Seattle, Washington.

f2fi~-G' (C l2~3

SEATTLE POLICEDEPARTMENT

CA USE NO. ______,ll---ill----C;9-f<--/--- H--. -+-1 +-7 -J'T-B ~Z __"",_- -7-2 _---"-'Sw-fEA\---CERTIFICA TION FOR DETERMINA TlON

OF PROBABLE CAUSE

i.

UNIT FILE NUMBER


There is probable cause to believe that Howard Thoren Honeycutt 9/28/78 committed the crime(s) of Professional Gambling 1st degree, RCW 9.46.220 (Class B Felony); within the City of Seattle; County of King, State of Washington.

This belief is predicated on the following facts and circumstances:

Seattle Police personnel became aware of an illegal gambling/alcohol enterprise at 1410-1412 14th Avenue, Seattle, King County, Washington, on or about August 25, 2007. Subsequent

{;., investigation utilizing Undercover Detectives (UCD), audio intercepts; and video and photographic surveillance confirmed the existence of underground illegal gambling enterprises (concurrent with illegal liquor sales), and sUPP0l1ed the issuance of search warrants which yielded additional evidence.

Between August of 2007 and June of 2009, Howard "Thoren" Honeycutt planned, conspired, prepared and/or participated in gambling enterprise(s) within the City of Seattle, County of King, State of Washington. These included the locations of 1019 E Pike St (Apt "Y"), known as "the YARD'; or simply "Rick's place," and also 2400-2410 3rd Avenue, known as the "Cafe Corsair," or simply "the space." Honeycutt performed duties consistent with "security" and laborer, while more than five other conspirators/participants performed administrative, management, and employee functions in gambling activities where players were charged a fee to participate in card games. These activities were not licensed by the' state; but resulted in financial gain for the venue operators.

Persons or organizations; who wish to engage in lawful, charitable gambling activities such as raffles, must satisfy certain requirements of the Washington State Gambling Commission, which includes the notification of local law enforcement. For the City of Seattle, the police department's Vice Unit is the entity to be notified. The review of such notifications is my responsibility. At no time did any person associated with the afore-mentioned locations make notification of such charitable efforts, even as subterfuge.

Illegal gamblinglIiquor activities occurred frequently at these locations, and rose to a level sufficient to reach Professional Gambling in the 15t· degree. Agent Clint Lucci, of the Washington State Gambling Commission, accompanied Detective Bryan Van Brunt to these illegal gambling locations and assisted with a technical estimate of the gambling activities, to include wagers in excess of $5000 in any 30-day period, in which the operators made financial gain. While there; Agent Lucci made a technical estimate of the gambling activities at the Yard and at Cafe Corsair. His conclusion was that there was in excess of $5,000 in wagers made on each of the occasions he was there in which the operators made financial gain. Each purchased alcoholic beverages from staff within these locations. According to the undercover officer, he observed more than five individuals involved in the gambling operations of each location.

Form 34.0 1(06

PAGE 1 OF 2

SEATTLE POLICE DE,PARTMENT

INCIDENT NUMBER

07~381875

CERTIFICA TION FOR DETERMINA TlON OF PROBABLE CAUSE

UNIT FI LE NUM BER

Honeycutt's specific violations were noted on approximately 12 undercover visits during the investigation.

Honeycutt advised the undercover officer that he was in charge of security at the Cafe Corsair, and he was observed by the undercover officer to be acting in that capacity. He was the person who allowed - or refused to allow - patrons to enter the gambling establishment. He enforced card-room conduct rules, and ejected patrons who misbehaved or acted unruly. He also performed duties as directed by the pit boss. He also was responsible for guarding the cash acquired inside the establishment, and Honeycutt told the undercover officer he always had access to guns to ensure the money was secured,

Specific to the "YARD," Honeycutt was present during several undercover visits to the illegal enterprises. During these visits, his level of participation was not significantly noted due to other target aspects of the investigation.

Regarding the "Corsair," Honeycutt served in the capacity of a "security" and laborer in the operation of the illegal enterprises. -Specifically:

Honeycutt facilitated the development of the Corsair by performing assorted construction inside the building, transporting gambling and furniture materials, to include the movement of doors, tables, and chairs from storage (4750 University Way NE, formerly known as "Tubs") to the Corsair, such as on 9/15/08 and 9119108. Detective Van Brunt visited the Corsair on numerous other occasions, when Honeycutt was present for the purposes of security duties.

Under penalty of pel jury under the laws of the State of Washington, I certify that the foregoing is true and correct to best of my knowledge and belief. Signed and dated by me this 9 TH

day of S=;BRuA-£.LJ ,"2011, at Seattle, Washington.

r eJ/~ ((; /Z7; .

Form 34.0E 5/98

PAGE 2 OF 2

. SEATTLE POLICE DEPARTMENT

CAUSENO. _

CERTIFICATION FOR DETERMINA TION OF PROBABLE CAUSE - NARCOTICS

INCIDENT NUMBER

07-381875

UNIT FILE NUMBER

That Detective Sergeant Ryan M. Long of the Seattle Police Department believes that there is probable cause that Howard Thoren Honeycutt 9/28178 committed the crime(s) of Violation of the Uniformed Controlled Substances Act on January 10,2009 at 9721 6th Avenue NW within the City of Seattle, County of King, State of Washington by delivering cocaine, a controlled substance.

This beliefis predicated on the following facts and circumstances:

Detective Bryan Van Brunt encountered Howard "Thoren" Honeycutt starting in September 2008, during an undercover investigation into illegal gambling activities in the Seattle area.

On December 19, 2008, Detective Van Brunt met with Honeycutt, when Honeycutt expressed his desire for Detective Van Brunt to buy cocaine from him instead of co-conspirator Rick Wilson. Honeycutt explained he could arrange to sell large quantities of cocaine and he would charge Detective Van Brunt $750 per ounce. He said to contact him and ask for a "girl," which would be their code for ounce.

In the afternoon of January 10, 2009, Detective Van' Brunt met Honeycutt at 2400-2410 3rd Avenue, where they discussed the purchase of cocaine. Honeycutt agreed to sell Detective Van Brunt an ounce of cocaine per earlier discussion. He said he would meet Detective Van Brunt in the evening. Detective VanBrunt later returned to 2400-2410 3rd Avenue, but Honeycutt did not arrive, so Detective Van Brunt went to 9721 6th Avenue NW to engage in illegal gambling activities related to the ongoing investigation, While there, Honeycutt called Detective Van Brunt and asked whether he could deliver the cocaine to Detective Van Brunt there. Detective Van Brunt agreed. A short time later, Honeycutt arrived in Eric Sun's white van, which was

'driven by Scott McKnight. Honeycutt moved to Detective Van Brunt's vehicle, where he handed him a brown paper towel, which Detective Van Brunt opened to find a glassine baggie containing a white powder. Detective Van Brunt paid Honeycutt $750 for the ounce of suspected cocaine and they 'separated. The substance was later field-tested positive for the presence of cocaine.

On March 18, 2009, Detective Van Brunt met again with Honeycutt at 1019 E Pike St Apt Y. Honeycutt informed Detective Van Brunt that he could sell Detective Van Brunt a half-kilogram of cocaine for $12,000, and that he would only need two hours notice to get it. He also offered to sell Detective Van Brunt oxycontin.

No enforcement action was immediately taken due to the other ongoing investigation.

Form 34.1e 5/98

PAGE 1 OF 1

Under penalty of perjury under the laws of the State of Washington, I certify that the foregoing is true and correct to best of my knowledge and belief. Signed and dated by me this 2. '3

day of LVl~Ct.-\ , ' ) 2010, at Seattle, Washi~~IJ?;J I, '

, t;ll~C-= Ca_fl)


CERTIFICA TlON FOR DETERMINA TlON OF PROBABLE CAUSE

INAL

CA USE NO. _'-=----=----1 ---4- ~--'--------=- ~O ___!_1 -!.._7 -'>L8 __._t3--~l--1,.S1-l..dEAq_·

. That Ryan M. Long is a Detective Sergeant with the Seattle Police' Department and has reviewed the investigation conducted in Seattle Police Department Case Number 07-381875;

There is probable cause to believe that Brady D. McGarry 4/20/1982 committed the crime(s) of Professional Gambling 1st degree, RCW 9.46.220 (Class B Felony); Conducting (Gambling) Activity Without a License, .RCW 9.46.160 (Class B felony); Causing a Person to Violate. Chapter, RCW 9.46.180 (Class B Felony); within the City of Seattle, County of King, State of Washington.


Seattle Police personnel became aware of an illegal gambling/alcohol enterprise at 1410-1412 14th Avenue, Seattle, King County, Washington, on or about August 25, 2007. Subsequent investigation utilizing Undercover Detectives (DCD), audio intercepts, and video and photographic surveillance confirmed the existence of underground illegal gambling enterprises (concurrent with illegal liquor sales), and supported the issuance of search warrants which yielded additional evidence.

Between April of 2008 and June of 2009, Brady McGarry participated in gambling enterprise(s) within the City of Seattle, County of King, State of Washington. These included the locations of 1019 E Pike St (Apt "Y"), known as "the YARD" or simply "Rick's place," and also 2400-2410 3rd Avenue, known as the "Cafe Corsair," or simply "the space," as well as 9721 6th Avenue NW, known as "Bill's," and a start-up game above The Bit Tavern at 4818 1 ill Avenue NW ..

Persons or organizations who wish to engage in lawful, charitable gambling activities such as raffles, must satisfy certain requirements of the Washington State Gambling Commission, which includes the notification of local law enforcement. For the City of Seattle, the police department's Vice Unit is the entity to be. notified. The review of such notifications is my responsibility. At no time did any person associated with the afore-mentioned locations make notification of such charitable efforts, but resulted in the financial gain of the operators.

Illegal gambling/liquor activities occurred frequently at these locations, and rose to a level sufficient to reach Professional Gambling in the 1st degree. Agent Clint Lucci, of the Washington State Gambling Commission, accompanied Detective Bryan Van Brunt to these illegal gambling locations and assisted with a teclmical estimate of the gambling activities, to include wagers in excess of $5000 in any 30~day period, in which the operators made financial gain. While there, Agent Lucci made a technical estimate of the gambling activities. His conclusion was that there was in excess of $5,000 in wagers made on each of the occasions he was there in which the operators made financial gain. Each purchased alcoholic beverages from staff within these locations. According to the undercover officer, he observed more than five individuals involved in the gambling operations of each locations>

Form 34.0 ·1106

PAGE 1 OF 3

McGarry's specific violations were noted during approximately 20 undercover visits during the investigation, including the incident when .McGarry was detained during the service of search

~ SEATTLE (§>j. POLICE

DEPARTMENT

INCIDENT NUMBER

07-381875


UNIT FILE NUMBER

warrants during gambling activities at 1019 E Pike St on June 10,2009. McGarry acted in the capacity of an employee, performing the duties of a poker dealer, while also providing his input with other conspirators during the planning phases of the illegal gambling enterprises. While dealing cards, McGarry performed a "rake" from the "pot" of each hand, collecting the profits on behalf of the illegal gambling enterprise. He also participated as a card player during some of the games.

A "rake" is a predetermined percentage 01' amount collected by the dealer on behalf of the owners/operators of the gambling establishment from the final pot of each particular card game. The "rake is taken from the pile of chips on the table, and these chips are cashed out by the house. A "rake" is taken from every final pot and this is the price each player pays to participate in the card game.

Specific to the "YARD," Brady McGarry served in the capacity of a "poker dealer" in the operation of the illegal enterprises. For example:

On 5/21108,8/20108, and 9/10108, Detective Van Brunt observed McGarry dealing poker and taking a rake from each hand.

Regarding the "Corsair," McGarry served in the capacity of a "poker dealer" in the operation of the illegal enterprises. Specifically:

On several occasions, McGarry and Detective Van Brunt conspired regarding aspects of the Corsair, to include living conditions and theatrical performances. On 1012108 and 1115/08, Detective Van Brunt entered the Corsair and observed the' poker game from the previous evening was still ongoing, where McGarry was dealing.

Regarding "Bill's," Mcfiarry served in the capacity of a "poker dealer" in the operation of the illegal enterprises. Specifically:

McGarry accompanied Detective Van Brunt to 9721 6th Av NW on 4/21108, where both participated as players in illegal gambling activities. On 5/4/08, 6/9/08, 8/4/08, 8/11108, and 8/18/08, Detective Van Brunt gambled and observed McGarry dealing cards and taking a rake. MCGatTY explained on 8111108 that William Donnell asked him to be a card dealer at his address.

Form 34.0E 5/98

PAGE 2 OF 3

Regarding the "Bit,» McGarry served in the capacity of a "poker dealer" in the operation of the illegal enterprises. Specifically:

On 11119/08, McGany discussed the illegal poker activities at the Bit, of which the tavern owners indicated a desire to share in the illegal profits. He explained that McKay and Davis will run the game at the tavern, while McGarry, Thompson, and Godwin will be the dealers. On 1217108, Detective Van Brunt went to the Bit and participated in illegal gambling, in which McGarry was a dealer and took a rake.

INCIDENT NUMBER

07-381875


CERTIFICA TlON FOR DETERMINA TION OF PROBABLE CAUSE

UNIT FILE NUMBER

Under penalty of pel jury under the laws of the State of Washington, I certify that the foregoing is true and correct to best of my knowledge and belief. Signed and dated by me this 9 rr+

day of C~l) eu A-I1 ,2011, at Seattle, Washington. .

{2j!)&A'SC; 0? (2;>

Form 34.0E 5/98

PAGE 3 OF 3

SEATTLE POLICE bEPARTMENT


UNIT F JLE NUMBER

That Ryan M. Long is a Detective Sergeant with the Seattle Police Department and has reviewed the investigation conducted in Seattle Police Department Case Number 07~381875;

There is probable cause to believe that Ian M. McNamara, 9~4~ 72, committed the crime(s) of 'Professional Gambling lSI degree, RCW 9.46.220 (Class B Felony); Ownership/Interest in a Gambling Device, RCW 9.46.215; Conducting (Gambling) Activity Without a License, RCW 9.46.160 (Class B felony); Causing a Person to Violate Chapter, RCW 9.46.180 (Class B Felony); Acting Without a (Liquor) License, RCW 66.44.090 (Gross Misdemeanor) within the City of Seattle, County of King, State of Washington.

This belief is predicated on the following facts and circumstances: .

Seattle Police personnel became aware of an illegal gambling/alcohol enterprises at 1019 E Pike Street (known as the YARD), 2646 NW 64th Street, 9721 6th Avenue NW, and 4818 17th Avenue NW, Seattle, King County, Washington, on or about August, 2007. Subsequent investigation utilizing Undercover Detectives (DCD), audio intercepts, and video and photographic surveillance" confirmed the existence of underground illegal gambling enterprises (concurrent with illegal liquor sales), and supported the issuance of search warrants which yielded additional evidence.

Between February of 2008 and June of 2009, Ian McNamara planned, conspired, prepared, participated in and paid support for gambling enterprise(s) within the City of Seattle, County of King, State of Washington. Detective Van Brunt identified McNamara as a regular participant at the locations of 1019 E Pike Street, 2646 NW 64th Street, 9721 6th Avenue NW, and 4818 17th Avenue NW, as well as 2400-2410 3rd Avenue, in the City of Seattle. McNamara performed assorted duties at the illegal gambling enterprises, from a poker card player (at Wilson's) to pitboss (at Dormell's) to venue operator (at the Bit Tavern).

Persons 01' organizations, who wish to engage in lawful, charitable gambling activities such as raffles, must satisfy certain requirements of the Washington State Gambling Commission, which includes the notification of local law enforcement. For the City of Seattle, the police' department's Vice Unit is the entity to be notified, The review of such notifications is my . responsibility. At no time did any person associated with the afore-mentioned locations make notification of such charitable efforts, even for subterfuge.

Illegal gambling/liquor activities occurred frequently at these locations; and rose to a level sufficient to reach Professional Gambling in the 1 st "degree. Agent Clint Lucci, of the Washington State Gambling Commission, accompanied Detective' Bryan Van Brunt to these illegal gambling locations and assisted with a technical estimate of the gambling activities, to include wagers in excess of $5000 in any 30~day period; in which the operators made financial gain .. While there, Agent Lucci made a technical estimate of the gambling activities. His conclusion was that there was in excess of $5;000 in wagers made on each of the occasions he was there in which the operators made financial gain, Each purchased alcoholic beverages from staff within these locations. According to the undercover officer; he observed more than five

Form 34.0 1/06

PAGE 1 OF 2


INCIDENT NUMBER

07~381875


UNIT F!LE NUMBER

individuals involved in the gambling operations of both locations, McNamara's specific violations were noted on approximately 10 undercover visits during the investigation, not including the incident when McNamara was detained during the service of search warrants at 1019 E Pike Street on June 10,2009.

. .

The undercover police officer was advised by a coconspirator to the gambling operation that

McNamara was paying money to the owners of the Bit Tavern in order to use the room above for this gambling enterprise. According to the undercover police officer, he saw McNamara on two separate occasions at the Bit Tavern. On each occasion, McNamara oversaw the gambling activities that took place in this location. McNamara performed all of the duties of a "game manager/pit boss." A "game manager/pit boss" oversees the gambling activity and acts as the ultimate arbiter of any disputes that may arise during the gambling activity. He provides direction to each dealer regarding table operations including gifting (giving a player free chips), when to change decks of cards, and the rotation of dealers .

. By the end of April, 2008, William Donnell ceased illegal gambling activities at the former address (2646 NW 64th Street) and moved to a new residence at 9721 6thAv NW. The illegal activities continued at this location. McNamara was observed participating in the illegal gambling activities on 6-9-08, and specifically gave directions to the poker dealers on 3-26-09. .

On 11-19-08, McNamara was identified by co-conspirator Brady McGarry as the operator of the illegal game at the Bit Tavern; on 12-11-08, Detective Van Brunt visited this illegal gambling establishment, where McNamara gave a tour of the bar service area and two poker rooms. While participating in these illegal gambling activities, hosted by McNamara, Detective Van Brunt heard McNamara say, "This is my place" to another player. Later that same evening, 12-19-08, McNamara "cashed out» other players, meaning he accepted their poker chips and provided money in return.

Pursuant to the issuance of search warrants, the residence at 9721 6th Av NW was searched for evidence, which revealed countless items of investigatory value. These included gambling items (tables, chips, cards, etc), liquor items (alcohol, coolers, etc), and drug items (quantities of assorted drugs, scales, etc), as well as money. An examination of co-conspirator Donnell's cellular phone revealed additional incriminating evidence against Mcl-Iamara regarding the illegal gambling activity.

Under penalty of perjury under the laws of the State of Washington, I certify that the foreg0Yir is true and co~ct to best of my knowledge and belief. Signed and dated by me this 9 .

day of r"'0.€uA~ ,2011, at Seattle, Wa~~1ton,

~/e-..LfJ~~~&Z~' -=-0~!0~. ~~-

Form 34.0E 5/98

PAGE 2 OF 2·

CAUSE NO. 1 _1 _- ---"",Q:--=1 __ O_, 1_7_8 __;_5 ----L...--=-":


CERTIFICA TION FOR DETERMINA TION OF PROBABLE CAUSE

That Ryan M. Long is a Detective Sergeant with the Seattle Police Department and has reviewed the investigation conducted in Seattle Police Department Case Number 07~381875;

There is probable cause to believe that James P. Miller 1/9/1981 committed the crime(s) of Professional Gambling 1st degree, RCW 9.46.220 (Class B Felony); Conducting (Gambling) Activity Without a License, RCW. 9.46.160 (Class B felony); Causing a Person to Violate Chapter, RCW 9.46.180 (Class B Felony); Acting Without a (Liquor) License, RCW 66.44.090 (Gross Misdemeanor) within the City of Seattle, County of King, State of Washington. .,


Seattle Police personnel became aware of an illegal gambling/alcohol enterprise at 1410-1412 14th Avenue, Seattle, King County, Washington, on 01' about August 25, 2007. Subsequent investigation utilizing Undercover Detectives (UCD), audio intercepts, and video and photographic surveillance confirmed the existence of underground illegal gambling enterprises (concurrent with illegal liquor sales), and supported the issuance of search warrants which

YIelded additional evidence. .

Between August of2007 and June of 2009, James P. Miller planned, conspired, prepared, and/or participated in gambling enterprise(s) within the City of Seattle, County of Xing, State of Washington. These included the locations of 1410-1412 14th Avenue, which was known colloquially as the "Cafe (un)American" or simply "the speakeasy," 1019 E Pike St (Apt "Y"), known as "the YARD" or simply "Rick's place," and also 2400-2410 3rd Avenue, known as the "Cafe Corsair," or simply "the space." Miller performed duties consistent with a "Pit Boss" and "Assistant Manager," while more than five other conspirators/participants performed administrative, management, and employee functions in gambling activities where players were charged a fee to participate in card games. These activities were not licensed by the state for financial gain of the operators. Miller also supervised the illegal sales of liquor concurrent with the gambling enterprise.

Persons or organizations who wish to engage in lawful, charitable gambling activities such as raffles, must satisfy certain requirements of the Washington State Gambling Commission, which includes the notification of local law enforcement. For the City of Seattle, the police department's Vice Unit is the entity to be notified. The review of'such notifications is my responsibility. At no time did any person associated with the afore-mentioned locations make

notification of such charitable efforts, even for subterfuge. .

Illegal gambling/liquor activities occurred frequently at these locations, and rose to a 'level sufficient to reach Professional Gambling in the 1 st degree. Agent Clint Lucci, of the Washington State Gambling Commission, accompanied Detective Bryan Van Brunt to the illegal gambling locations at 1019 East Pike Street ("the Yard") and 2400-2410 3rd Avenue ("Cafe Corsair") on two separate occasions. While there,' Agent Lucci made a technical estimate of the gambling activities. His conclusion was that there was in excess of $5,000 in wagers made on each of the occasions he was there in which the operators made financial gain. Each purchased alcoholic

Form 34.0 1106

PAGE 1 OF 2

INCIDENT NUMBER

07-381875



UNIT FILE NUM8ER

beverages from staff within the locations, which were supervised by Miller. Miller's specific violations were noted on approximately 25 undercover visits during the investigation, including the incident when Miller was detained during the service of search warrants during gambling activities at i019 E Pike St on June 10,2009. According to the undercover officer, he observed more than five individuals involved in the gambling operations of both locations.-

James Miller served in the capacity of a "game manager" or "pit boss" in the operation of the illegal enterprises. A "game manager/pit boss" oversees the gambling activity and acts as the ultimate arbiter of any disputes that may arise during the gambling activity. He provided direction to each dealer regarding table operations including gifting (giving a player free chips), when to change decks of cards, and the rotation of dealers. Miller's actions included:

Specific to the "YARD":

On 10-17-07, Detective Van Brunt met Miller at his first visit to the Yard. Detective Van Brunt exchanged money for gambling chips with Miller in order to play cards, then Miller participated in the poker game as well. On numerous occasions in 2007, 2008, and 2009, Miller acted in the capacity of "pit boss" arid poker player at the illegal gambling enterprise located at 1019 E Pike St, Seattle (King County), WA. Detective Van Brunt . observed Miller exercise decision-making control over card dealers and the bartenders selling liquor. On 6-8-08, Miller entered Wilson's office and retrieved a powder that he identified to Detective Van Brunt as "cocaine." Detective Van Brunt then purchased approximately 2 grams of cocaine from Miller. "Miller had on-demand access to Wilson's office/private room, which contained the proceeds, narcotics, and weapons.

Specific to the "Corsair": "

Miller visited the prospective gambling location at 2400-2410 3rd Avenue, Seattle (King County), WA on 03-05-08 to conspire with other subjects, On 3-23-08 he stated he would be the game manager/pit boss. Miller met with Pan and Detective Vim Brunt on 03w26-08 to discuss the float' plan. On 4-1-08, Wilson confirmed Miller's position as pit boss for the Corsair, and income would be 5% of the illegal profit. Miller acted as pit boss at the Corsair during Detective Van Brunt visits such as 9-24-08 and II-Sw08.

Under penalty of perjury under the laws of the State of Washington; I certify that the foregoing is true and correct to best of my knowledge 'and belief .. Signed and dated by me this Ct n~ .

day of i=EBf2<..("''\.r~ , 2011, at Seattle, was~jllgton.". .

" &/IJ! L9AG" (o/2;'z.

Form 34.0E 5/98

PAGE 2 OF 2


CAUSE NO. _

CERTIFICA TION FOR DETERMINA TlON OF PROBABLE CAUSE - NARCOTICS

INCIDENT NUMBER

07-381875

UNIT FILE NUMBER

That Detective Sergeant Ryan M. Long of the Seattle Police Department believes that there is probable cause that James P Miller 119/1981 committed the crime(s) of Violation of the Uniformed Controlled Substances Act on June 8, 2008; July 3, 2008; September 24, 2008; September 26, 2008; October 15, 2008 at 1019 E Pike St Apt llyn and 2400-2410 3rd Avenue within the City of Seattle, County of King, State of Washington by delivering cocaine, a controlled substance.


Detective Bryan Van Brunt encountered Miller, starting in October 2007, during an undercover investigation into. illegal gambling activities.

On June 8, 2008, Detective Van Brunt observed Miller retrieve a white powder from a dresser in Richard Wilson's bedroom at 1019 E Pike St, Apt Y. Miller then inhaled some of the powder through his nose. When Detective Van Brunt inquired what it was) Miller responded "cocaine." A short time later, Detective Van Brunt asked if he could purchase some cocaine. Miller advised that "Rick has some" and inquired how much Detective Van Brunt wanted. Miller advised that the price would be $50 per gram. Detective Van Brunt and Miller went into Wilson's bedroom again and Detective Van Brunt gave $100 to Miller, 'who retrieved 4 glassine baggies, from the same location as before, containing white powder and gave them to Detective Van Brunt. The 'approximately 2 grams in these baggies later field-tested positive for the presence of cocaine.

On July 3, 2008, Detective Van Blunt met Miller again at 1019 E Pike St, Apt Y, and asked to buy $50 more cocaine. Miller accepted the $50 and led Detective Van Brunt into Richard Wilson's bedroom and weighed a glassine baggie containing white powder on an electronic scale. Miller continued to add powder until the scale read approximately 1 gram, then gave it to Detective Van Brunt. The contents later field-tested positive for the presence of cocaine.

On September 24, 2008~ Detective Van Brunt met Miller at 2400-2410 3rd Avenue, known as the "Corsair." Detective Van Brunt purchased approximately 1.5 grams of cocaine (in three glassine baggies) from Miller for $75. This was memorialized via audio recording. The contents later field-tested positive for the presence of cocaine.

On September 26, 2008, Detective Van Brunt met Miller at 2400-2410 3rd Avenue, known as the "Corsair." Detective Van Brunt purchased approximately 1.5 grams of cocaine (in three glassine baggies) from Miller for $75. This was memorialized via audio recording. The contents later

field-tested positive for the presence of cocaine. .

On October 15, 2008, Detective Van Brunt met Miller at 2400-2410 3rd Avenue, known as the "Corsair." Detective Van Brunt asked to purchased cocaine from Miller, who replied that he did not have any cocaine available. Instead, Miller introduced Detective Van Brunt to a white female (known only as "Liz"), who he said would be able to sell Detective Van Brunt cocaine. Liz ultimately sold approximately 3 grams of suspected cocaine to Detective Van Brunt for

Form 34.1e 5/98

PAGE 1 OF 2


CERTIFICA TION FOR DETERMINA TlON OF PROBABLE CAUSE NARCOTICS

INCIDENT NUMBER

07-381875

UNIT FILE NUMBER

$130. This was memorialized via audio/video recording. The contents later field-tested positive for the presence of cocaine.

On June 10, 2009, the service of search warrants served at 1019 E Pike St resulted in the discovery of 'additional drugs in the same location where Miller obtained the drugs to serve Detective Van Brunt.

Under penalty of perjury under the laws of the State of Washington, I certify that the foregoing

is hue and correct to best of my knowledge and belief. Signed and dated by me this '2. '1

day of t11~0-\. ; 2010, at Seattle, Washington. .

1(});j/Ll1~ G_iZl

Form 34.0E 5/98

PAGE 2 OF. 2


CAUSE NO. --f-l--l-l--'-"'-\t~----+O-l-1t--;f--7 8~6 ----F-5 -+>S-F-£J1 V1 r p r "

i!>ENERAL OFFENSE #

."'" I '. 'o7~381875

CERTIFICA TION FOR DETERMINA TJON OF PROBABLE CAUSE

UNIT FilE NUMBER

That Ryan M. Long is a' Detective Sergeant with the Seattle Police Department and has reviewed the investigation conducted in Seattle Police Department Case Number 07-381875;

There is probable cause to believe that DK Pan 6-30-1972 committed the crime(s) of Money Laundering, RCW 9A.83.020; Criminal Impersonation 15( degree, RCW 9A.60.040; Professional Gambling l" degree, RCW 9.46.220; Conducting Activity without a License, RCW 9.46.160; Causing a Person to Violate Gambling Chapter, RCW 9.46.180; Acting without a (Liquor) License, RCW 66.44.090; within the City of Seattle, County of King, State of Washington.


Seattle Police personnel became aware of an illegal gambling/alcohol enterprise at 1410-1412 14th Avenue, Seattle, King County, Washington,on or about August 25, 2007. Subsequent investigation utilizing Undercover Detectives (UCD), audio intercepts, and video and photographic surveillance confirmed the existence of underground illegal gambling enterprises, and supported the issuance of search warrants which yielded additional evidence.

Between August of 2007 and June of 2009, DK Pan planned, conspired, prepared, participated in, and operated gambling enterprise(s) within the City of Seattle, County of King, State of Washington. These included the locations of 1410-1412 14th Avenue, which was known colloquially as the "Cafe (un)American" or simply "the speakeasy," 1019 E Pike St (Apt "Y"), known as "the YARD" or simply "Rick's place," and also 2400-2410 3rd Avenue, known as the "Cafe Corsair," or simply "the space," as well as 2646 NW 64th Street and 9721 6th Avenue NW, known as "Ballard" or "Bill's." Pan performed duties consistent with a "Chief Operating Officer" and bartender and dealer/player for the enterprises affiliated with Rick Wilson, and performed duties as a dealer and player for the enterprise operated by William Donnell, while more than five other. conspirators/participants performed administrative, management, and employee functions in gambling activities where players were charged a fee to participate in card games. These activities were not licensed by the state.

Illegal gambling/liquor activities occurred frequently at these locations, and rose to a level sufficient to reach Professional Gambling in the 1st degree. Agent Clint Lucci, of the Washington State Gambling Commission, accompanied Detective Bryan Van Brunt to these illegal gambling locations and assisted with a technical estimate of the gambling activities, to include wagers in excess of $5000 in any 30-day period) in which the operators made financial gain. While there, Agent Lucci made a technical estimate of the gambling activities. His conclusion was that .thcre was in excess of $5,000 in wagers made on each of the occasions he was there in which the operators made financial gain. Each purchased alcoholic beverages from staff within these locations, According to the undercover officer, he observed more than five individuals involved in the gambling operations of each locations.-

Specific to the Cafe (un)American, 1410-1412 14th Avenue, DK Pan served as the operational second in command to Wilson, supervising and coordinating the day-to-day illegal activities at the location(s).

Form 34.0 1/06

PAGE 1 OF 4


INCIDENT NUMBER

07-381875

CERTIFICATION FOR DETERMINA TlON OF PROBABLE CAUSE

UNITFILE NUMBER

On 1O~12~07, Eric Sun introduced Detective Van Brunt to DK Pan at the Cafe (un)American in order to facilitate Detective Van Brunt's entry into "Rick's" illegal gambling enterprise at 1019 E Pike St. Detective Van Brunt purchased an alcoholic beverage from Pan to verify the alcohol violation criminal allegation. Pan provided Wilson's cellular phone number (206-271-7227) for Detective Van Brunt to arrange entry into "Rick's," and then provides his own cellular phone number (206-940-6079).

A "rake" is. a predetermined percentage or amount collected by the dealer on behalf of the owners/operators of the gambling establishment from the final pot of each particular card game. The "rake is taken from the pile of chips on the table, and these chips are cashed out by the house. A "rake" is taken from every final pot and this is the price each player pays to participate in the card game.

Specific to 1019 E Pike St, Seattle, King County, Washington; known as "Rick's" or "The Yard,"

Beginning October 2007, Detective Van Brunt became a regular customer and card player at the illegal gambling location known as the "Yard," because of the stenciled letters "YARD" above the door, which was also Rick Wilson's residence. Detective Van Brunt gambled at the location, where he observed a "rake." The poker chips have the denomination on one side (red=$0.2S, black=$l, and orange/red=$5) and "cafe (unjamerican" on the other. Detective Van Brunt participates in gambling and observes the various dealers take a "rake." This is when the dealer takes a portion of the pot for the house's profit.

On October 16,2007, Pan left a voicemail message for Detective Van Brunt stating there would be a poker game at URick's" on 10-17-07 at 1900, and provided directions. On 5~ 29-08, 6-26-08, 7-7-08, 8-7-08, 8-20-08, 9-10-08, Pan dealt poker and acquired the

- "rake." On other occasions, Pan played poker from which the house took a rake.

Specific to 2400-2410 3rd Avenue, Seattle, King County, Washington; known as "the Corsair" or. "tile space," and the associated front enterprise known as the "Free Sheep Foundation,"

Beginning in February 2008, Detective Van Brunt became a silent partner with Wilson, Sun, and Pan, among others, to identify, open and operate an illegal gambling venue in the Belltown neighborhood of Seattle. In exchange for being the "clean" name on the lease; Detective van Brunt would get part of the illegal gambling profit.

Form 34.0E 5/98

Pan visited prospective location on 03-05-08 to conspire with other members of the group. Pan met with Miller and Detective Van Brunt on 03-26-08 to discuss the floor plan, and also discussed ways to cover the illegal activity at the location. Wilson, who was acting in the capacity as a Chief Executive Officer, identified Pan on 4-1 ~08 as the one responsible for managing the "legal front" involving the sublease of space to local artists, then went on to reiterate his position as "CEO" and Sun to be an "advisory partner" responsible for accounting. Additional discussions with Detective Van Brunt on 4-8-08 address the issue of concealing the illegal activities from the police, The method

PAGE 2 OF 4


~IN=C=IOE=N~T~NU~M~BE~R--------"-

07-381875


UNIT FILE NUMBER

. of re-infusing illegal profit into the gambling enterprise was also discussed, as well as the disbursement of percentage proceeds to the managers. On 4-21-08 Pan discusses operating methods for the "legal front" for the illegal activities at the Corsair. On 5-8-08, Detective Van Brunt returned to the Corsair, where he was to meet Pan to conduct a walkthrough of the warehouse. Pan did not arrive, but they conversed by phone regarding the activities. Pan did meet with Detective Van Brunt and the building owner's representative on 5-12-08 to discuss assorted construction topics related to the building. Pan completed construction and modification tasks at the Corsair on numerous occasions. Pan dealt poker at the Corsair on 9-24-08, 9-26-08 and acquired the "rake" for the house. On 12-5-08, Pan sent an email to Detective Van Brunt regarding the Corsair, where he admitted that they were starting to profit from the operations, and offered Detective Van Brunt his monetary share. On 12-9-08, Pan provided $2600 in payments to Detective Van Brunt for Corsair expenses and illegal profit from the illegal gambling enterprise.

In addition to the gambling activities, Pan was the person identified by the group of conspirators to act as the "curator" for the front organization designed to hide the illegal gambling activities. In recorded conversations, monikers such as "Don't Arrest Us, Incorporated" and"Legal Front" were jokingly considered as potential names to be used for the front organization, which was an ali gallery that ultimatelybore the name of "Free

. Sheep Foundation." Pan organized "fundraiser" art and music events under the name of this organization, which was admittedly created only to generate plausible deniability to law enforcement, should suspicion arise. Pan 'stated that inquiries would be made to the Liquor Control Board, Secretary' of State, Gambling Commission, and non-profit sponsors in order to generate favor from investigating agencies, should a question arise. Electronic mail messages advertising events were received and/or recovered by investigators. On occasion, Detective Van Brunt attended the gatherings to document the activities. Further, Pan provided interviews to local independent reporters regarding the ali foundation in order to give it legitimacy. On 7-10~08. Pan asked Detective Van Brunt to purchase some supplies for the illegal enterprise. Upon Detective Van Brunt's arrival, Pan gave Detective Van Brunt an invitation for the opening of the Corsair's art studio cover, which was scheduled for 7,-11-08. This cover was identified as the Free Sheep Foundation. Pan then hosted the opening event on the 11 tho It was discovered that, while Pan initially applied for licensing recognition for the Free Sheep Foundation, he never' followed through, either at the city or state level. On 8-8~08, Pan applied for fiscal sponsorship from the Allied Arts Foundation, as he said he would, but never followed up with .any supportive records or documentation beyond the jnitialapplication, though he hosted numerous events which resulted in monetary gain. One of these was an event in which money was raised via an online ticket sales corporation, known· as "brownpapertickets.org." (October 10-19,2008).

On October 11,2008, uniformed police officers contacted Pan at 2400-2410 3rd Avenue. Pan provided the rehearsed cover story regarding art activities at the location in order to divert any further investigation.

Form 34.0E 5/98

pAGE 3 OF 4

Several times during meetings with Detective Van Brunt, Pun was recorded, pursuant to court authorization, articulating the details of the criminal gambling enterprises. including


INCIDENT NUMBER

07-381875


UNIT FILE NUMBER

his leadership role. Throughout 2007,2008, and 2009, Pan continued to participate in the illegal enterprises and exercise control over the front operation

Specific to 2646 NW 64th St, Seattle, King County, Washington; known as "Bill's" 01:

"Ballard" ..

,

In February, 2008, DK Pan facilitated Detective Van Brunt's participation in another gambling enterprise, known as "Bill's," at 2646 NW 64th St, Seattle. Detective Van Brunt participated in illegal gambling and meets the proprietors, William Donnell and Todd Lucas. The dealers consistently took a "rake" for the house profits. Detective Van Brunt becomes a semi-frequent player at this location. Pan regularly played poker and dealt poker (accepting the rake) at this illegal gambling enterprise.

Specific to 9721 6th Av NW, Seattle, King County, Washington; known as "Bill's" During this time, the gambling activities at 2646 NW 64th St moved to a new location at 9721 6th Avenue . NW, Seattle (King County), WA. Detective Van Brunt went to that location on numerous occasions and participated in the illegal gambling activities that were ongoing there, still operated by Donnell, though Lucas was no longer a partner. Pan continued to participate in a similar role at this location.

Pan operated the ali gallery front covering the gambling venue at 2400-2410 3rd Avenue until its closure in January, 2009, at which time he moved the Free Sheep Foundation to the former hot tub rental business known as "Tubs," which ·was owned by, Sun and vacant pending redevelopment.

On June 10, 2009, police executed a search warrant at 1019 E Pike St, among other locations, and seized evidence pertaining to the criminal activities, which included gambling equipment, documents, and electronics. An examination of the evidence revealed more incriminating information peliaininW to Pan's responsibility for activities at 1410-1412 14lhAvenue, 1019 E Pike St, 2646 NW 64t1 Street, 9721 6th Avenue NW, and 2400-2410 3rd Avenue.

Under penalty of perjury under the laws of the State of Washington, I certify that the foregoing is true and correct to best of my knowledge and belief. Signed and dated by me this. 1 n-l

day of f§;BRAJ.A-f1 ,2011, at Seattle, Washin,ton.

, 2v) ~ 0(2,;3·

Form 34.0E 5/98

PAGE 4 OF 4

CAUSE NO. __ ,-'-.'_----"'>.(=_-_0_1_7_8_7_. _~ _i _SE_A

GEN~RAL OFFENSE #

07-381875



UNIT FILE NUMBER


'There is probable cause to believe that Rashaad 1. Thompson 114176 committed the crime(s) of Professional Gambling 151 degree, RCW 9.46.220 (Class B Felony); Conducting (Gambling) Activity Without a License, RCW 9.46.160 (Class B felony); Causing a Person to Violate Chapter, RCW 9.46.180 (Class B Felony); within the City of Seattle, County of King, State of Washington.


Seattle Police personnel became aware of an illegal gambling/alcohol enterprise at 1410-1412 14th Avenue, Seattle, King County, Washington, on or about August 25, 2007. Subsequent investigation utilizing Undercover Detectives (UCD), audio intercepts, and video and photographic surveillance confirmed the existence of underground illegal gambling enterprises (concurrent with illegal liquor sales), and supported the issuance of search warrants which

yielded additional evidence.' .

Between October of 2007 and June of 2009, Rashaad 1. Thompson planned, conspired, prepared, and/or participated in gambling enterprise(s) within the City of Seattle, County of King, State of Washington. These included the locations of 1019 E Pike St (Apt "Y"), known as' "the YARD" 01' simply "Rick's place," and also 2400-2410 3rd Avenue, known as the "Cafe Corsair", or simply "the space," and above The Bit Tavern, located at 4818 17th Avenue NW. Thompson performed employee duties as a poker card dealer, while more than five other conspirators/participants performed administrative, management, and employee functions in gambling activities where players were charged a fee to participate in card games. These' activities were not licensed by the state, but were conducted for profit by the operators.

Persons or' organizations who wish to engage in lawful, charitable gambling activities such as raffles, must satisfy certain requirements of the Washington State Gambling Commission, which includes the notification of local law enforcement. For the City of Seattle, the police department's Vice Unit is the entity to be notified. The review of such notifications is my responsibility. At notime did any person associated with the afore-mentioned locations make notification of such charitable efforts .

. Illegal gambling/liquor activities' occurred frequently at these locations, and rose to a revel sufficient to reach Professional Gambling in the 1 st degree. Agent Clint Lucci, of the Washington State Gambling Commission, accompanied Detective Bryan Van Brunt to these illegal gambling locations and assisted with a tec1mical estimate of the gambling activities, to include wagers in excess of $5000 in any 3D-day period, in which the operators made financial gain. While there, Agent Lucci made a technical estimate of the gambling. activities. His conclusion was that there was in excess of $5,000 in wagers made on each of the occasions he was there in which the operators made financial gain. Each purchased alcoholic beverages from staff within these locations. According to the undercover officer, he observed more than five

Form 34.0 1/0$

PAGE 1 OF 2


INCIDENT NUMBER

07-381875


UNIT FilE NUMBER

individuals involved in the gambling operations of each location. Thompson's specific violations were noted on approximately 20 undercover visits during the investigation.

A "rake" is a predetermined percentage or amount collected by the dealer on behalf of the owners/operators of the gambling establishment from the final pot of each particular card game, The "rake is taken from the pile of chips on the table, and these chips are cashed out by the house. A "rake" is taken from every final pot and this is the price each player pays to participate in the card game.

Specific to the "YARD," Rashaad Thompson served in the capacity of a poker card dealer in the operation of the illegal enterprises. For example:

Detective Van Brunt observed Thompson performing employee duties at the Yard as a card dealer for illegal gambling on 10/31/07, 1117107,2/20108,4/9108,6/4/08, 7/3/08, and 10/8/08. During each incident, Detective Van Brunt observed Thompson take a rake from.the final pot of each hand, for the profit of the illegal gambling enterprise.

Regarding the illegal gambling activity at "Bill's," which was located at 2646 NW 64th Street, Thompson vouched for Detective Van Brunt's entry into the illegal gambling enterprise on 2/18/08 in order for Detective Van Brunt to participate in the gambling.

Regarding the "Corsair," Thompson served in the capacity of a poker card dealer in the

operation of the illegal enterprises. Specifically: .

Detective Van Brunt visited the Corsair, located at 2400-2410 3rd Avenue, and observed Thompson performing duties as a card dealer (taking a rake from the final pot of each hand as house profit) on 10/8/08, 10/19/08, and 11/5/08.

Regarding the Bit Tavern, Thompson served in the capacity of a poker card dealer in the operation of the illegal enterprises. Specifically:

On 1217108,. Detective Van Brunt visited the Bit, located at 4818 1 ih Avenue NW, where Thompson met him at the exterior door, let him in, and then closed and locked the door behind them. Detective Van Brunt then observed Thompson performing duties as a card dealer (taking a rake from the final pot of each hand as house profit) on that date and on 12113/08. On both dates, Thompson "cashed-in" Detective Van Brunt, accepting Detective Van Brunt's money in exchange for poker chips at the start of the game.

Under penalty of perjury under the laws of the State of Washington, I certify that the foregoing is true and correct to best of my knowledge and belief. Signed and dated by me this q p-f-

day of ""FEfV4l!V?( ; 2011, at Seattle, Washington. j

efJ;Z~~ (Q I ?3

Form 34.0E 5/98

PAGE 2 OF 2

16

20

21

22

23

24

1

Daniel T. Satterberg, Prosecuting Attorney WS54 King County Courthouse

516 Third Avenue


(206) 296-9000, FAX (206) 296-0955

2

CAUSE NO. ll-C-01781-4 SEA CAUSE NO. ll-C-OI782-2 SEA CAUSE NO. ll-C-01783-1 SEA CAUSE NO. II-C-O 1784-9 SEA CAUSE NO. ll-C-01785-7 SEA CAUSE NO. l1-C-OI786-5 SEA CAUSE NO. ll-C-01787-3 SEA

3

4

5

PROSECUTING ATTORNEY CASE SUMMARY AND REQUEST FOR BAIL AND/OR

6 " CONDITIONS OF RELEASE

7 The State incorporates by reference the Certification for Determination of Probable

Cause written by Sgt. Ryan Long of the Seattle Police Department regarding incident number

8 07-381875. "

9 REQUEST FOR BAIL

10 Pursuant to CrR 2 .2(b )(2)(i), the State requests that the" Court issue a summons directing

each defendant to appear in court, "

11

Defendant Honeycutt's criminal history includes convictions for Theft in the Second

12 Degree (2 counts) and Theft of a Firearm. "

l3 Defendant McGarry's criminal history includes convictions for Criminal Trespass in the

Second Degree.

14

15

Defendant Thompson's criminal history includes convictions for Attempted Theft in the Second Degree.

Defendants Donnell, McNamara, Miller, and Pan have no prior criminal convictions.

17

Signed this ,-I L day of March, 2011.

18

19

t'A--.-~ )(. ):1~-;;;-0

" Andrew R Hamilton, WSBA #8312

Prosecuting Attorney Case Summary "and Request for Bail and/or Conditions of Release - 1

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