Carolyn Weikel

Snohomish County Auditor

3000 Rockefeller Avenue
Everett, WA 98201

January 29, 2015

NOW COMES, Snohomish County residents and registered voters Anne Block and Noel
Frederick pursuant to Wash. Const. Art. 1, Sections 33-34 and RCW 29A.56.110, seeking the
recall and discharge of Snohomish County Prosecutor Mark Roe who has committed an act or
acts of misfeasance, or an act or acts of malfeasance while in office, or has violated the oath of
office and should be recalled from office for the foregoing reasons:

RECALL CHARGES
At all times relevant to this Recall Petition, Mark Roe was and still is a public official
duly sworn in to uphold the laws of Washington. Mark Roe is currently serving as Snohomish
County Prosecutor.
Charge 1: Snohomish County Executive employee Kevin Hulten was exposed by two
Snohomish County reporters from the Snohomish County Daily Herald on February 14, 2014,
for harassing Snohomish County resident and taxpayer Anne Block. Snohomish County
Executive Aaron Reardon resigned as a result, and Snohomish County executive employee
Kevin Hulten was terminated from Snohomish County employment for misconduct. His claim
for unemployment was denied as a result of his misconduct.
In March 2014, the Snohomish County council ordered the criminal investigation as outlined by
the Snohomish County Daily Heralds article Reardons Office linked to harassment to the
King County Major Crimes Unit. Kevin Hultens county computers and cell phone were
transferred to King County Major Crimes Unit for forensic inspection.
According to King Countys Major Crimes Unit, Kevin Hulten used a wiping program and
destroyed evidence. Upon completion of its investigation, King County Major Crimes Unit
transferred its criminal investigation to Skagit County for possible prosecution. Skagit County
brought criminal evidence tampering charges against Kevin Hulten, and Kevin Hulten plead
GUILTY in an open public court located in Arlington, Washington, to criminal evidence
tampering on July 7, 2014.

pg. 1

In August 2014, Snohomish County Prosecutor Mark Roe violated RCW 4.96.010 when he
allocated and entered into an agreement using Snohomish County taxpayer monies to fund a
convicted criminal and former Snohomish County Executive employee Kevin Hulten.
RCW 4.96.010 in pertinent part prohibits use of taxpayer funds for conduct outside of the
employees official duties and states the following:
Tortious conduct of local governmental entities Liability for damages.
(1) All local governmental entities, whether acting in a governmental or proprietary capacity,
shall be liable for damages arising out of their tortious conduct, or the tortious conduct of their
past or present officers, employees, or volunteers while performing or in good faith
purporting to perform their official duties, to the same extent as if they were a private person
or corporation. Filing a claim for damages within the time allowed by law shall be a condition
precedent to the commencement of any action claiming damages. The laws specifying the
content for such claims shall be liberally construed so that substantial compliance therewith will
be deemed satisfactory.

To the effect that the criminal activities (of named persons) were neither part of their official
duties nor were actions in good faith, the Snohomish County Prosecutor is well aware that
providing legal counsel at the taxpayers expense is outside of the scope of RCW 4.96.010.

I certify and swear, under oath, that the facts set forth in this statement are true and correct
and I believe the charges to be true and have knowledge of the facts upon which the stated recall
grounds are based.
Submitted this 29th day of January 2015.

_________________________________
Anne Block
313 Shelby St
Gold Bar, WA 98251

__________________________________
Noel Frederick
313 Shelby St
Gold Bar, WA 98251

pg. 2

pg. 3