Construction Law
Published by the Construction Law Section of the Washington State Bar Association
Volume 43
Spring 2014
Number 1
Chair’s Report
by Tom Larkin – Fidelity National Law Group – Seattle, WA
Greetings, Section Members! As I look out my window today
I see nothing but blue skies and sunshine. Hopefully it’s a
sign the cold weather is behind us and warmer days are
closer and more frequent than they seem.
With the new year now fully upon us, the council has
been busy. For the third year in a row, the ConstructiLaw
Section will be sponsoring two CLE’s. The first will take
place in Spokane, WA, on April 18 at the Spokane Club. As
in years past, this CLE will focus on “Construction 101.”
The council’s initiative behind the CLE is to cover multiple
topics that will refresh the experienced construction lawyer
and provide a baseline for new attorneys entering the field.
Jason Piskel of Piskel Yahne Kovarik, PLLC, is chairing the
CLE this year and has organized a great group of speakers
who will certainly offer lots of insight and knowledge. Next
year, we plan to take a similar program to either Bellingham
or Vancouver. If you are interested in working with the section
in either one of those cities next year, please email me, tom.
[email protected], or one of the other council members.
The second, the section’s annual Mid-Year CLE, will
once again take place at the WSBA Conference Center and
be held on June 13. Titled “Construction Disputes: Picking
the Right People and Forum,” this year’s Mid-Year CLE
will focus on how to best approach, prepare, and ultimately
resolve construction disputes. The CLE will consist of multiple panel discussions on topics such as Contract Clauses,
Early Mediation, and Dispute Review Boards. During the
noon break, the section will be providing lunch and hosting
a presentation on Big Bertha and the Highway 99 Tunnel
Project. The presentation will feature the latest on Bertha and
the status of the Project. With all that has gone on over the
past several month regarding the project, the presentation
is not something to be missed by those attending the CLE.
As always, the CLE will include Paul Cressman’s annual
update on new case law and Steve Goldblatt’s legislative
Update. I’ve been attending the Mid-Year CLE for over ten
years now and there is no better yearly update on what’s
new in the construction law world than these two. I hope to
see many of you there.
As always make sure to check out our section webpage
at www.wsba.org/Legal-Community/Sections/Construction-Law.
There you will find section announcements, past newsletters,
our model contracts (check out our new Design Build Contract), sample construction jury instructions, and much more.
- Tom
Section Annual Mid-Year CLE
Mark your calendars for the section’s annual Mid-Year
CLE. It will take place on June 13 at the WSBA Conference Center. The CLE is titled “Construc­tion Disputes:
Picking the Right People and Forum,” and will focus on
how to best approach, prepare, and ultimately resolve
construction disputes. In addition to having multiple
panel discussions on topics such as Contract Clauses,
Early Mediation, and Dispute Review Boards, the CLE
will have its annual update on new case law from Paul
Cressman and a legislative update from Steve Goldblatt.
Stick around for lunch, which will be provided by the
sec­tion, and will include a presentation on the latest Big
Bertha news and the status of the Highway 99 Tunnel
Project.
In This Issue
Chair’s Report...................................................................1
Section Annual Mid-Year CLE........................................1
Construction Law Section First Annual Dinner
Meeting a Success..........................................................2
A New Resource for Washington Lien Law..................3
Geotechnical Reports – Should They Be Part of Your
Contract Documents? A Consultant’s Perspective...3
Design Professional Liens Attach When Nothing is
Built: Answering the Devil’s Advocate......................5
Construction Law 101 Registration Form......................7
1
Construction Law
Spring 2014
Construction Law Section
First Annual Dinner Meeting a Success
Construction Law Section
2013-2014
by Robert Olsen –
Schlemlein Goetz Fick & Scruggs, PLLC – Seattle, WA
Officers
Thomas P. Larkin II, Chair
Fidelity National Law Group
1200 6th Ave., Ste. 620
Seattle, WA 98101-3125
(206) 223-4525 x106
[email protected]
Forty-five members of the Section signed up to attend the
Section’s first ever dinner meeting and mini-CLE on February 6, 2014. Although a few members failed to appear, the
ones that did attend enjoyed an evening of socializing, good
food and education at McCormick & Schmick’s Harborside
Restaurant on Lake Union in Seattle. A hosted cocktail hour
starting at 6 p.m. was followed by dinner at 7 p.m. and an
hour-long CLE (1-hour credit) at 8 p.m. presented by Ted
Prosise of Tsongas Litigation Consulting, Inc. on “Visual
Advocacy: Principles, Tools and Techniques.” Ted’s talk was
both entertaining and informative, full of graphics and tips on
how to enhance presentations to a judge or jury. He showed
how PowerPoint was more robust and useful than merely
presenting a bullet-point outline and how a new piece of
software used by his 13-year-old son could be adapted and
used for compelling professional presentations.
The Council was so encouraged by the turnout and the
positive feedback that it is considering making the dinner an
annual event. Let us know if you like that idea and provide
any suggestions.
Scott Sleight, Chair-elect
Ahlers & Cressman PLLC
999 3rd Ave., Ste. 3800
Seattle, WA 98104-4023
(206) 287-9900
[email protected]
John Evans, Vice-chair
John Evans Law, PLLC
1001 Fourth Ave., Ste. 4400
Seattle, WA 98154
206-389-1527
Ron J. English, Secretary
Seattle Public Schools Office of
General Counsel
MSC 32-151
P.O. Box 34165
Seattle, WA 98124-1165
(206) 252-0651
[email protected]
Annmarie Petrich, Treasurer
Attorney at Law
1900 Nickerson St., Ste. 209
Seattle, WA 98119-1650
(206) 282-1262
[email protected]
Ex Officio Chairs
Athan Tramountanas
Russell King
Short Cressman & Burgess PLLC
999 Third Ave., Ste. 3000
Seattle, WA 98104
(206) 682-3333
[email protected]
[email protected]
Past Chairs
Alan B. Bornstein (2004-05)
Ron English (2005-06)
Bob Olson (2006-07)
Andrew Maron (2007-08)
Bryan Caditz (2008-09)
Robert H. Crick, Jr. (2009-11)
Thomas H. Wolfendale (2011-2012)
Joseph Scuderi (2012-2013)
Council Members
Term Ending 2014
Alicia Berry
Liebler, Connor, Berry & St. Hilaire
1141 N. Edison St., Ste. C
P.O. Box 6125
Kennewick, WA 99336-0125
(509) 735-3581
[email protected]
Your Input Is Needed!
The Construction Law Section Newsletter works best when
Section members actively participate. We welcome your articles,
case notes, comments, and suggestions concerning new developments in public procurement and private construction law.
Please direct inquiries and submit materials for publication to:
Marisa Bavand
Groff, Murphy PLLC
300 E. Pine St.
Seattle, WA 98722-2029
(206) 628-9500
[email protected]
Jennifer McMillan Beyerlein
Lane Powell PC
1420 Fifth Avenue, Suite 4200
Seattle, WA 98111-9402
(206) 223-7000
Athan Tramountanas or Russell King
Short Cressman & Burgess PLLC
999 Third Avenue, Suite 3000
Seattle, WA 98104
[email protected]
[email protected]
Term Ending 2015
Jason Piskel
Piskel Yahne Kovarik PLLC
522 W Riverside Ave., Ste. 410
Spokane, WA 99201-0519
(509) 321-5930
[email protected]
Randy Thiel
Thiel Keaton PLLC
701 5th Ave., Ste. 4775
Seattle, WA 98104-7097
(206) 838-2515
[email protected]
Athan Tramountanas
Short Cressman & Burgess, PLLC
999 Third Ave., Ste. 3000
Seattle, WA 98104
(509) 321-5930
2
Term Ending 2016
Sherman Knight
Knight Mediation
5400 Carillon Pt.
Kirkland, WA 98033-7357
(425) 576-8777
[email protected]
Mark Berg
P.O. Box 13410
Seattle, WA 98198-1006
(206) 310-9482
[email protected]
Roy LundinWilliams, Kastner &
Oseran Hahn Spring Straight & Watts PS
10900 NE 4th St., Ste. 1430
Bellevue, WA 98004-8357
(425) 455-3900
[email protected]
BOG Liaison
Brad Furlong
Furlong - Butler Attorneys
825 Cleveland Ave
Mount Vernon, WA 98273-4210
(360) 336-6508
[email protected]
Young Lawyers Liaison
Amber L. Hardwick
Green & Yalowitz, PLLC
1420 Fifth Ave., Ste. 2010
Seattle, WA 98101-4800
(206) 622-1400
Spring 2014
Construction Law
A New Resource for Washington Lien Law
Geotechnical Reports –
Should They Be Part of Your Contract
Documents? A Consultant’s Perspective
by Athan Tramountanas –
Short Cressman & Burgess PLLC – Seattle, WA
Based on the number of articles written for the newsletter and
the number of emails sent through the listserv on lien law, it
is clear that questions persist on the filing, prosecution, and
defense of mechanics’ liens. The classic secondary sources
for researching Washington lien law are Michael F. Keyes’
Construction Lien Practice and Procedure Annual for the State of
Washington, and Brian A. Blum’s Mechanics’ and Construction
Liens in Alaska, Oregon and Washington. As valuable as these
books are, they were last published in the mid-1990’s. Since
then, cases like Colorado Structures, Inc. v. Blue Mountain Plaza,
LLC,1 Williams v. Athletic Field, Inc.,2 and Estate of Haselwood
v. Bremerton Ice Arena,3 have further developed courts’ interpretation of Chapter 60.04 RCW. A new resource has long
been overdue.
Through the efforts of Karl Oles and Bart Reed of Stoel
Rives LLP, a new treatise on Washington lien law is available:
The Construction Lien in Washington: A Legal Analysis for the
Construction Industry. This book presents a comprehensive
look at construction liens, and includes chapters on pre-claim
notices, recording of liens, foreclosing a lien, and defending
a lien claim. It also has chapters on stop notices and lien-like
remedies on public projects (bond claims, retainage claims,
and prompt payment requirements). In total, the book is
divided into eight chapters, and presents the information in
an easy-to-digest manner, complete with citations to statutes
and important cases. Before publishing the treatise, its authors
submitted it in draft form to section members Kerry Lawrence
(one of the authors of Chapter 60.04 RCW), John Ahlers, and
Robert Crick for peer review and comment.
The best part of The Construction Lien in Washington:
A Legal Analysis for the Construction Industry is clearly the
valuable research and analysis contained in its pages, but a
close second-best is its cost – free. Stoel Rives has made the
treatise available as a free download on its website (www.
stoel.com). It will also be available on the Construction Law
Section’s website (www.wsba.org/Legal-Community/Sections/
Construction-Law) under “Resources.” The authors promise
to issue periodic updates, and will notify those that sign up
on the Stoel Rives website when those updates are available.
by Kristna Weller – The Riley Group1 – Bothell, WA
Your geotechnical engineering report is written to provide
recommendations to the design team based on the subsurface
conditions encountered in the explorations on site. It should
not be part of your contract documents or referenced in such
a way as to imply it is part of the contract documents. This
article discusses use of geotechnical reports on design-build
projects and on traditional design-bid-build projects.
Design-Build Projects
For WSDOT Public Design-Build Contracts, Chapter 22
of the WSDOT Geotechnical Design Manual published in
October 2013 outlines what reports are prepared and how they
are used. A Geotechnical Data Report (GDR), Geotechnical
Baseline Report (GBR), and other related Reference Documents are prepared and have different functions that are
outlined and the various uses are explained in this 14-page
document. Many cities and counties have similar documents
that outline what is included in each document and how
they are used.
The Geotechnical Data Report (GDR) contains all the
factual geotechnical data gathered for the project. The GDR
contains a description of the geotechnical site exploration
program, logs of the explorations, ground water measurements, the geologic and seismic setting for the project corridor, geotechnical field instrumentation and laboratory
tests conducted and the test results, as well as any previous
geotechnical laboratory test results that are relevant for the
project. The GDR is usually included as part of the contract.
However, the other reports are not incorporated into the
contract. The Geotechnical Baseline Report (GBR) contains
interpretations of the GDR and forms the basis of the design
and is usually provided to the proposers but is not part of
the contract documents. The proposers are cautioned to not
rely on the information contained in the GBR. The GBR is a
baseline report about the subsurface conditions encountered
and does not contain design information.
Design-Bid-Build Projects
Use of geotechnical information for design-build is very
different than for design-bid-build public projects and the
private world, where geotechnical reports or geotechnical
engineering reports usually provide not only subsurface
conditions but geotechnical design parameters for foundations, retaining walls, and shoring in addition to recommendations for site grading, erosion control, utilities, drainage
and pavements.
This type of report should not be part of your contract
documents or referenced in such a way as to imply it is part
1 159 Wn. App. 654, 246 P.3d 835 (2011).
2 172 Wn.2d 683, 261 P.3d 109 (2011).
3 166 Wn.2d 489, 210 P.3d 308 (2009).
continued on next page
3
Construction Law
Spring 2014
plate that does not take into account the information for the
geotechnical report or site specific information. Having the
geotechnical engineer review the specifications – especially
on projects where significant earthwork is expected – can save
the owner a lot of issues and change orders later.
Geotechnical Reports – Should They Be Part of Your
Contract Documents? A Consultant’s Perspective
from previous page
of the contract documents. If you really feel the need to include the subsurface information in the contract documents,
the location of the explorations, logs and laboratory testing
can be separated from the text and included. This should be
only done, however, with significant caveats similar to the
ones contained in the geotechnical report.
Here is an example of typical limitations contained in a
Geotechnical Engineering Report (GER):
Editor’s Note: I want to thank The Riley Group for contributing an
article for our newsletter. As we are trying to publish the newsletter
more frequently, we are always on the lookout for more articles.
There is no reason to limit this space to lawyer-written articles. If
section members know of any other participants in the construction
industry that would be willing to write a relevant article, please
contact me. -Athan
Within the limits of the scope and budget, this GER
was prepared in accordance with generally accepted
geotechnical engineering practices in the area at the
time this GER was issued. This GER is intended for
specific application to the proposed project in project
city, Washington, and for the exclusive use of the client
and its authorized representatives. No other warranty,
expressed or implied, is made. Site safety, excavation
support, and dewatering requirements are the responsibility of others.
1 The Riley Group Inc. (RGI) was founded in 1996 with the intention of supporting local municipal and private clients with a small firm atmosphere.
Over the past 15 years, we have managed our firm’s growth and direction
with the intention of providing our clientele with innovative, cost-effective
solutions. Our professional staff of 22 includes environmental scientists,
licensed geologists, hydrogeologists, and professional engineers. Our staff
is motivated, experienced and strives to provide the best possible service
to our clients. We have provided services for over 2,000 projects throughout the Pacific Northwest. RGI has provided geotechnical engineering
services since 1998. Our goal is to provide our clients with innovative,
state-of-the-art techniques that exceed each project’s goal.
The analyses and recommendations presented in
this GER are based upon data obtained from the test
exploration performed on site. Variations in soil conditions can occur, the nature and extent of which may
not become evident until construction. If variations
appear evident, the geotechnical engineer should be
requested to reevaluate the recommendations in this
GER prior to proceeding with construction.
Information for Your Clients
Did you know that easy-to-understand pamphlets
on a wide variety of legal topics are available from
the WSBA? For a very low cost, you can provide
your clients with helpful information. Pamphlets
cover a wide range of topics:
It is the project owner’s responsibility to see that all parties to the project, including the designers, contractors, and
subcontractors, are made aware of this GER in its entirety.
The use of information contained in this GER for bidding
purposes should be done at the contractor’s option and risk.
Alternatives to Court
Consulting a Lawyer
Criminal Law
Dissolution of Marriage (Divorce)
Landlord/Tenant Rights
Law School
Lawyers’ Fund for Client Protection
Legal Fees
Revocable Living Trusts
Signing Documents
The Best Solution
The geotechnical report should be provided to the design team, bidders and contractors for their information.
The owner and contract specialists should also read and be
familiar with the recommendations in the geotechnical report
so that assumptions the contractor makes in the bid can be
evaluated. If the geotechnical report says “the native soil
is not suitable for use as structural fill” and the contractor
proposes in their contract to use the native soil as structural
fill, this should be an immediate red flag that the contractor
will be sending you a change order when they have to import
structural fill material.
It is also helpful to involve your geotechnical engineering
professional in the development of the specifications for your
project that are part of the contract documents. The architect
usually produces the earthwork specifications from a tem-
Each topic is sold separately. Pamphlets are $9 for
25, $15 for 50, $20 for 75, and $25 for 100. Pricing for
larger quantities is available on request.
To place your order or for more information, please
contact the WSBA Service Center at 800-945-WSBA
or 206-443-WSBA. Sales tax is applicable to all instate orders.
4
Spring 2014
Construction Law
Design Professional Liens Attach When Nothing is Built:
Answering the Devil’s Advocate
by Lane Powell Construction Group – Seattle, WA
An article in the Construction Bar’s Winter Newsletter tried
to suggest that Washington law does not grant lien rights
for the work of a design professional where nothing is built.1
We disagree and take the author, Michael Bond, up on his
invitation to set the record straight.
For decades, Alaska, California, and Oregon have mirrored Washington by allowing design professional liens to
attach to real property in the absence of actual construction.2
Adopting the same public policy, the Uniform Construction
Lien Act, § 102(17)(v), allows design professionals to lien
whether or not the planned improvement is actually made.3
This article summarizes the history of the Washington lien
statute and addresses a recent case that acknowledges that
a design professional can obtain lien rights when improvements are not built.
Some say the road to hell is paved with good intentions.
One may have the intention to undertake an action but nevertheless fail to take action. The construction industry is no
exception – the best intentions may result in an abandoned
project. The design professional services lien provides
security – even when nothing is built – for the intangible
intellectual property that improves the property and makes
construction possible.
design professionals as set forth in RCW 60.04.031. Like a
1990 California statute,6 the 1991 redrafting also included
a new defined term – “professional services” – including
“preparing maps, plans, or specification for … or otherwise
performing any other architectural or engineering services
for the improvement of real property.”7
A careful reading of RCW 60.04.011(5)’s novel definition
of improvement demonstrates that it borrows from the old
engineering lien statute’s language: “prepares … plans and
specifications for the improvement of such real property.”8
The new definition also includes the broader prospective
category of “intended activities.” Subsection (5) states:
(5) “Improvement” means: (a) Constructing, altering,
repairing, remodeling, demolishing, clearing, grading,
or filling in, of, to, or upon any real property or street
or road in front of or adjoining the same; (b) planting
of trees, vines, shrubs, plants, hedges, or lawns, or
providing other landscaping materials on any real
property; and (c) providing professional services upon
real property or in preparation for or in conjunction with
the intended activities in (a) or (b) of this subsection.9
Mr. Bond’s article in the last newsletter focused on the
“intended activities in (a) or (b) of this subsection” language,
asking “doesn’t the addition of the words ‘in preparation for
or in conjunction with the intended activities in (a) or (b),
which refer only to ‘constructing on real property’ … serve
only to reiterate that there can be no lien absent an actual
improvement?”10
The answer is no.11 The adjective “intended” means
“proposed”12 construction – not “actual” construction. The
use of the term “preparation” reinforces that plain meaning
that “intended” construction activities may never come to
fruition as “actual” construction. Those intended activities include preconstruction services in “preparation” for
construction. Also, the interpretation offered in the article
renders the separate notice provision in RCW 60.04.031(5)
for professional services superfluous, which courts are loath
to do. The separate notice for professional services applies
where “no improvements as defined in RCW 60.04.011(5)
(a) or (b) has commenced,” i.e., where there is no tangible
improvement such as construction or landscaping.13 In other
words, the optional notice is triggered where there is an
intangible improvement. Those intangible improvements are
defined in RCW 60.04.011(5)(c) – improvements in the form
of “providing professional services upon real property or in
preparation for … the intended activities ….”
The Minutiae of the Analysis
Before the redrafting of the construction lien laws in 1991,
engineers, architects, and others had a separate lien statute.
In 1931, the Legislature adopted what later became known
as chapter 60.48 RCW, Lien for Engineering Services. This
statute remedied the “very old Washington case” that held
an architect had no lien rights under the building lien statute
unless the building was actually constructed.4 The original
engineering lien statute, former RCW 60.48.010, provided:
Any person who at the request of the owner of any
real property, or his duly authorized agent, surveys,
establishes or marks the boundaries of, or prepares
maps, plans or specifications for the improvement of
such real property, or does any other engineering work
upon such real property, shall have a lien upon such
real property for the agreed price or reasonable value
of work so performed.
A lien under former RCW 60.48.010 was not conditioned
upon actual improvement of the property. The lien was “upon
the real property.” The former RCW 60.48.010 thus superseded
the holding in Lipscomb v. Exchange.5
Decades later, the 1991 redrafting of the construction lien
statute combined all construction-related lien rights into a
single chapter, but retained a separate notice provision for
continued on next page
5
Construction Law
Spring 2014
Design Professional Liens Attach When Nothing is Built: Answering the Devil’s Advocate from previous page
The Colorado Structures, Inc. v. Blue Mt. Plaza, LLC14 decision, cited by the Bond article, does not suggest that actual
physical construction is required to trigger a lien.15 That is
neither the holding of Colorado Structures nor can such an
interpretation be extrapolated from the reasoning behind the
decision. The lien dispute in Colorado Structures ran afoul of a
fundamental and specific requirement in the lien statute that
the party providing construction services for the improvement of property have a contract with the property owner.
Moreover, a 2004 Court of Appeals decision confirmed
that a design professional could acquire lien rights despite the
lack of execution on the planned improvements. In McAndrews
Group, Ltd. v. Ehmke,16 the court construed RCW 60.04.031 and
acknowledged that such a lien right is available even where
“no improvement as defined in RCW 60.04.011(a) or (b) has
been commenced.”17
In short, the Washington statute grants lien rights for
a design professional’s work where nothing is built. This
conclusive response should eliminate the unintended risk of
meritless litigation over the well-developed law regarding
the scope of a design professional’s lien right.18
that the current lien statute “contemplates that lien rights for professional
services may arise even though no improvement has been commenced.”)
12Webster’s 3d New Int’l Dictionary at 1175 (1981).
13RCW 60.04.031(5).
14159 Wn. App. 654, 246 P.3d 835 (2011).
15Bond at 4.
16121 Wn. App. 759, 90 P.3d 1123 (2004).
17Id.
18Co-authors David Spellman, Carson Cooper, Jennifer McMillan Beyerlein,
and on behalf of Lane Powell PC’s Construction Group.
Manage your membership anytime, anywhere at
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update your credits.
1 See Michael J. Bond, Professional Services Lien Rights Absent Improvement,
62 Constr. Law No. 3 at 3-4, WSBA, Winter 2013-14.
2 AS 34.35.050(5) (providing for architectural or engineering lien for
construction of a building or improvement, “whether or not actually
implemented on that property”); D’Orsay Int’l Partners, v. Superior Ct.,
20 Cal. Rptr. 3d 399, 402, 123 Cal.App.4th 836 (2005) (describing how in
1990, the legislature created a new design professional lien constituting
“the exclusive lien remedy for design professionals in cases where no
actual construction of the planned work of improvement is commenced
prior to the recordation of the notice of lien.”); Or. Rev. Stat. § 87.010(5)
(“An architect, landscape architect, land surveyor or registered engineer
who, at the request of the owner or an agent of the owner, prepares plans,
drawings or specifications that are intended for use in or to facilitate the
construction of an improvement or who supervises the construction shall
have a lien upon the land and structures necessary for the use of the plans,
drawings or specifications so provided or supervision performed.”).
3 7 Pt. III U.L.A at 11 (2002); id. at 3 (prefatory note).
4 See Bond at 3 (citing Lipscomb v. Exch. Nat’l Bank of Spokane, 80 Wash.
296, 301, 141 P. 686 (1914) (“[T]he building contemplated has not been
erected, no lien for the architect’s services in drawing plans can attach
to the specific property.”)).
5 80 Wash. 296, 141 P. 686 (1914).
6 Cal. Civil Code §§ 3081.1.
7 RCW 60.04.011(13).
8 Former RCW 60.48.010)
9 RCW 60.04.011 (5) (underline and bold added).
10Bond, at 3-4 (bold in original).
11Karl F. Oles, Bart W. Reed, The Construction Lien in Washington, A legal
analysis for the construction industry, ch. 2, p.4 (Stoel Rives 2014) (stating
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6
Spring 2014
Construction Law
Construction Law 101 Registration Form
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Construction Law
Spring 2014
ADMINISTRATIVE LAW
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Spring 2014
Construction Law
This is a publication of a section of the Washington State Bar Association. All opinions and comments in this publication represent the views of the
authors and do not necessarily have the endorsement of the WSBA or its officers or agents.
Washington State Bar Association
Construction Law Section
1325 Fourth Avenue, Suite 600
Seattle, WA 98101-2539
2013-2014
Construction Law Section Membership Form
October 1, 2013 – September 30, 2014
r Please enroll me as an active member of the Construction Law Section.
My $25 annual dues are enclosed.
Name_____________________________________
Please send this form to:
Construction Law Section
Washington State Bar Association
1325 Fourth Avenue, Suite 600
Seattle, WA 98101-2539
Firm Name_ _______________________________
Address___________________________________
City/State/Zip_____________________________
Telephone_ ________________________________
E-mail Address_____________________________ office use only
Date_ ____________________________
9
Check #_ ________________
Total $_____________________