# OLD FIRE HOUSE TEEN CENTER — COMPREHENSIVE LEGAL ANALYSIS

**Prepared: April 2, 2026**
**Re: City of Redmond, Washington — Closure and Planned Demolition of the Old Fire House Teen Center**
**For: Sasha Glenn and Community Stakeholders**

---

## TABLE OF CONTENTS

1. [Summary Analysis](#1-summary-analysis)
2. [Condensed Timeline](#2-condensed-timeline)
3. [Money Trail & Developer Ties](#3-money-trail--developer-ties)
4. [City Cost Report Evaluation](#4-city-cost-report-evaluation)
5. [Music Equipment Auction](#5-music-equipment-auction)
6. [Washington Surveillance Law Analysis](#6-washington-surveillance-law-analysis)
7. [Public Records Act Violation Analysis](#7-public-records-act-violation-analysis)
8. [Legal Argument: PRA Lawsuit](#8-legal-argument-pra-lawsuit)
9. [Letter to Washington Attorney General](#9-letter-to-washington-attorney-general)
10. [Exhibit List](#10-exhibit-list)

---

## 1. SUMMARY ANALYSIS

### Overview

The Old Fire House (OFH) Teen Center, located at 16510 NE 79th Street, Redmond, WA 98052, has served Redmond youth for over 30 years. The building, constructed in 1952 by community volunteers, was converted to a teen center circa 1991-1992 under Mayor Rosemarie Ives. It became a nationally significant music venue launching bands including Death Cab for Cutie and Modest Mouse.

On March 11, 2025, the City of Redmond publicly announced the closure of OFH, citing a Facility Condition Assessment (FCA) showing deterioration. The building was closed by March 25, 2025. On November 18, 2025, the Redmond City Council voted 6-0 to demolish the building and construct a replacement. No budget or timeline was established. Demolition is targeted for mid-summer 2026.

### Core Findings

A six-month forensic investigation analyzing 7,573 documents obtained through public records requests (Request #32782) reveals a pattern of conduct by the City of Redmond that raises serious questions under Washington State law:

**1. The closure was planned years in advance and concealed from the public.**
- "Alternate Facilities Plan" appeared on OFH Team Meeting agendas as early as **January 2023** — 24+ months before public announcement. (Source: OFH Team Meeting Agendas, Jan 2023 - Aug 2024; `/home/solaya/Desktop/TOE/OFH/FORENSIC_REPORT_COMPLETE.md`)
- By **July 31, 2024**, OFH was internally designated a "satellite site." (Source: Internal email, satellite site memo authored by Erica Chua; `/home/solaya/Desktop/TOE/OFH/FORENSIC_REPORT_COMPLETE.md`)
- A PR firm (Stepherson & Associates) was engaged by **December 2024** ($4,468.75/month) — three months before the public announcement. The earliest S&A email in the PRA production is dated **February 18, 2025**, but references an existing "Engagement Plan" and weekly check-in schedule, indicating the contract predated this email. (Source: Email thread `50dd2d0139ce601e`; S&A Contract #10631, Invoice #5387)
- The Facility Condition Assessment was held in **DRAFT** status for 10 months (presented to Council November 2024, DRAFT watermark removed **February 27, 2025** by Sarah Partap of Meng Analysis — 11 days before public announcement). (Source: FCA Summary Report v4; email thread regarding DRAFT removal)

**2. A senior city official made a documented false statement.**
- On **March 4, 2025** — seven days before the public announcement — Deputy City Administrator **Loreen Hamilton** told RYPAC member **Freya Reiger**: *"There has been no such decision made about the Old Firehouse Teen Center."* (Source: Email thread `652c1dabfad4ad64`, Email IDs 3750/3753; `/home/solaya/Desktop/TOE/OFH/FORENSIC_REPORT_COMPLETE.md`)
- At the time of this statement: the PR firm had been active for 6+ weeks; a 110-email coordination thread was ongoing; the engagement plan was in version 2; the DRAFT watermark had been removed 5 days prior; the press release was 3 business days from distribution; and teen notification was 6 days away.
- The email chain shows Hamilton's response was not spontaneous — the inquiry from Freya was escalated through **four internal staff members** (Hagen → Chua → Houvener → Hamilton) over approximately 4 hours before Hamilton responded.

**3. Massive Public Records Act violations.**
- Of 7,573 documents produced in response to Request #32782, **5,182 (68.4%) are duplicates** used to inflate the production and create the appearance of compliance. Effective unique documents: approximately 1,541. (Source: `/home/solaya/Desktop/TOE/OFH/duplicate_analysis.json`)
- **911+ emails proven withheld** via reply-chain mathematical analysis: if a reply-to email exists in the production, the original email it replies to must have existed — yet the originals were not produced. (Source: `/home/solaya/Desktop/TOE/OFH/PRA_SUPPRESSION_REPORT.md`; Ghost probe analysis)
- **4,109 emails (54.3%)** reference attachments (35,455 total attachment references, 288 unique filenames) — **zero attachments were produced**. (Source: `/home/solaya/Desktop/TOE/OFH/AFFIDAVIT_EXHIBITS.md`, Exhibit 3)
- The **Mayor's outgoing emails were surgically removed**: 8 unique outgoing emails vs. 1,838 mentions of her name. 432 emails received by the Mayor, 82 reply-to proofs, yet only 54 sent emails produced. (Source: Ghost probe analysis, Entity ID: abirney@redmond.gov)
- **Council Member Steve Fields** (the Mayor's 2019 election opponent): 325 emails received, 114 reply-to mathematical proofs, **zero outgoing emails produced**. (Source: Ghost probe analysis, Entity ID: sfields@redmond.gov)
- **Five-month email blackout**: September 2024 through January 2025 — the period during which the PR firm was hired, the facility assessment was held in draft, and the closure timeline was finalized — produced effectively zero emails. (Source: `/home/solaya/Desktop/TOE/OFH/AFFIDAVIT_EXHIBITS.md`, Exhibit 8)
- **96% of raw .msg files corrupted**: 5,967 of 6,213 .msg files have intact OLE2 containers but corrupted MAPI property streams, consistent with programmatic manipulation during export. (Source: `/home/solaya/Desktop/TOE/OFH/FORENSIC_REPORT_COMPLETE.md`)
- **No privilege log** was provided. No exemption explanations accompanied any redaction or withholding.

**4. Surveillance and retaliation against community advocates.**
- On **March 20, 2025**, City Program Coordinator **Tory Watson** filed a surveillance report on community advocate **Sasha Glenn** documenting her advocacy visit to OFH ("Teen Center Observations 3/20"). (Source: Email thread `0fc164f66ff00055`, Email IDs 943+)
- The report was escalated through **five levels of city hierarchy** to **Mayor Angela Birney** within 13.5 hours: Watson → Hagen → Chua → Houvener → Hamilton → Mayor + Malisa Files. (Source: Email chain timestamps 2025-03-20T17:43 through 2025-03-21T07:17)
- The **following day**, Erica Chua sent a "Reminder: City of Redmond Code of Conduct" to the same staff, including Watson, establishing a three-strike escalation: "Verbal Warning → Suspension → **Permanent Expulsion**." (Source: Email thread `31c21ebda2d23656`, Email IDs 907-911)
- Teens at OFH were reportedly confiscated from making "save the teen center" signs. (Source: Community testimony; `/home/solaya/Desktop/TOE/OFH/FORENSIC_REPORT_COMPLETE.md`)

**5. Pattern of concealed decision-making benefiting campaign donors.**
- The OFH lot (0.64 acres) sits adjacent to **Nelson Legacy Group**'s corporate headquarters at 16508 NE 79th Street and their 22-acre downtown development assembly.
- NLG principals and affiliates donated **$12,200+** to Mayor Birney's campaign — the single largest identified donor bloc.
- Three NLG-affiliated individuals (**Tim Overland**, **Amy Webber**, **Mary Morrow**) sit on the **OneRedmond** board alongside **Mayor Birney** herself.
- New zoning adopted **June 28, 2025** designates the OFH site as a Transit-Oriented Development Focus Area: **144 feet height / FAR 8.0** — allowing **300-400 luxury residential units**.
- The **Downtown Redmond Link Light Rail** station opened **May 10, 2025** — maximizing the property's development value.
- **Same pattern, prior case**: In April 2024, the City transferred $5.5 million in public land to Plymouth Housing in a 22-day sprint with zero public hearings. The same law firm pipeline (Kenny/Sato at Ogden Murphy Wallace / Kantor Taylor) executed both property transactions. A citizen identified this pattern in a March 24, 2025 email: *"You got away with selling Cleveland property to Plymouth Housing."* (Source: `/home/solaya/Desktop/TOE/OFH/FOLLOW_THE_MONEY.md`)

### Applicable Law

| Statute | Violation | Remedy |
|---------|-----------|--------|
| **RCW 42.56** (Public Records Act) | Willful withholding of 911+ emails, 4,109 attachments; production padding; no privilege log | $5-$100/day per violation + mandatory attorney fees |
| **RCW 42.30** (Open Public Meetings Act) | Closure decision made outside public meeting; no public comment opportunity | Action **null and void** + $500-$1,000 per member + attorney fees |
| **RCW 36.70A.130/.140** (Growth Management Act) | Closing a capital facility without comp plan amendment, public hearing, or participation | Invalidity of closure decision |
| **RCW 43.21C / WAC 197-11** (SEPA) | Demolition of 8,600 sq ft public building without environmental review | Injunction against demolition |
| **42 U.S.C. § 1983** | First Amendment retaliation; surveillance of protected advocacy | Compensatory + nominal damages + attorney fees |
| **WA Const. Art. I, §§ 4, 5, 7** | Suppression of speech, petition, and privacy | Declaratory and injunctive relief |
| **RCW 40.16.020** | Willful concealment of public records (Class B felony) | Criminal referral |

---

## 2. CONDENSED TIMELINE

### Pre-Closure Planning (2019-2024)

| Date | Event | Source |
|------|-------|--------|
| **1952** | OFH building constructed by 75 community volunteers | Building records; KEXP oral history |
| **~1991-92** | Converted to teen center under Mayor Rosemarie Ives | Ives testimony, March 17, 2026 |
| **Nov 5, 2019** | Angela Birney elected Mayor; funded 4:1 ($105K vs opponent's $24K) | PDC filings; `/home/solaya/Desktop/TOE/OFH/FOLLOW_THE_MONEY.md` |
| **Nov 11-30, 2019** | 15+ shell Medium accounts created by Keith Birney network (6 days post-election) | `/home/solaya/Desktop/TOE/OFH/MEDIUM_NETWORK_ANALYSIS.md` |
| **Nov 19, 2019** | Lame-duck Council passes Ord. 2979 (dissolves Redmond Public Corporation) | City of Redmond Ordinance 2979 |
| **Dec 2019** | Ord. 2982 passed — OFH deliberately NOT given landmark protection | City of Redmond Ordinance 2982 |
| **2017-2023** | $94,370 in capital maintenance requests systematically denied (5 of 5 requests) | Capital Equipment Requests 2018-2025; FORENSIC_REPORT_COMPLETE.md |
| **Jan 2023** | "Alternate Facilities Plan" first appears on OFH team agenda (24+ months before public) | OFH Team Meeting Agenda, January 2023 |
| **Apr 2024** | $5.5M public land given free to Plymouth Housing in 22-day sprint, zero hearings | FOLLOW_THE_MONEY.md; legal emails thread |
| **Jul 31, 2024** | Internal decision: OFH becomes "satellite site" | Internal memo, Erica Chua |
| **Sep 2024 – Jan 2025** | **Five-month email blackout** in PRA production | AFFIDAVIT_EXHIBITS.md, Exhibit 8 |
| **Nov 2024** | FCA presented to Council in **DRAFT** status (held 10 months) | FCA Summary Report v4 |
| **Dec 2024** | Stepherson & Associates PR firm engaged ($4,468.75/month) | S&A Contract #10631 |

### Closure Execution (2025)

| Date | Event | Source |
|------|-------|--------|
| **Jan 21, 2025** | S&A formally begins PR campaign (7 weeks pre-disclosure) | S&A engagement records |
| **Feb 18, 2025** | Earliest S&A email in production: "Engagement Plan" already exists with weekly check-ins | Email thread `50dd2d0139ce601e` |
| **Feb 24-25, 2025** | Sprinkler maintenance bid issued (IFB 10861-25) — contradicts "unsafe building" narrative | IFB 10861-25 |
| **Feb 27, 2025** | DRAFT watermark removed from FCA by Sarah Partap (Meng Analysis) | FCA report metadata; email records |
| **Mar 4, 2025** | Hamilton tells Freya Reiger: *"There has been no such decision made"* | Email thread `652c1dabfad4ad64`, IDs 3750/3753 |
| **Mar 4, 2025** | Same day: two "give me a call" channel-switching emails from Kyle Muir in 2 minutes | Email records; AFFIDAVIT_EXHIBITS.md |
| **Mar 7, 2025** | FAQ, web content, staff communications reviewed and approved by Birney | Email thread `c8498925179735f2` (32 emails, 8 revision rounds in one day) |
| **Mar 10, 2025** | Mayor and Hamilton meet with RYPAC teens at RCCMV — told last | Event records |
| **Mar 11, 2025** | Public announcement: "City Transitions Teen Programs from Old Fire House" | Press release; 784 emails on this day |
| **Mar 20, 2025** | Tory Watson files surveillance report on Sasha Glenn | Email thread `0fc164f66ff00055`, ID 943 |
| **Mar 20-21, 2025** | Report escalated through 5 levels to Mayor in 13.5 hours | Email chain timestamps |
| **Mar 21, 2025** | Code of Conduct reminder with permanent expulsion threat sent | Email thread `31c21ebda2d23656`, IDs 907-911 |
| **Mar 21, 2025** | Last show at OFH; doors locked | Community records |
| **Mar 25, 2025** | Closure complete; City Council meeting (886 emails — peak day) | Email volume analysis |
| **Mar 26, 2025** | KIRO 7: "Teens, parents fighting to keep Redmond teen center" | https://www.kiro7.com/news/local/teens-parents-fighting-keep-redmond-teen-center-closing-down/YPS5ZUUDUNHNVP3TOX2SXIQZYI/ |
| **Mar 27, 2025** | KOMO News coverage; Hamilton quoted defending closure | https://komonews.com/news/local/redmond-old-fire-house-teen-center |
| **Mar 30, 2025** | PRA production stops (only 12 emails from April 2025 onward) | Production gap analysis |
| **May 10, 2025** | Downtown Redmond Link Light Rail station opens | Sound Transit |
| **Jun 28, 2025** | New zoning: OFH site designated 144ft / FAR 8.0 (300-400 unit potential) | City of Redmond zoning code |
| **Jul 22, 2025** | Council study session: renovation $9.3M / demolition+rebuild ~$12.1M | 425 Business, Sept 19, 2025 |
| **Nov 18, 2025** | Council votes 6-0 to demolish and rebuild (no budget, no timeline) | 425 Magazine, Nov 2025 |
| **Feb 25, 2026** | GovDeals auction of OFH equipment opens | GovDeals listing; City surplus page |
| **Mar 17, 2026** | Former Mayor Ives testifies against "premature demolition" | Redmond Neighborhood Blog, Mar 25, 2026 |
| **Apr 4, 2026** | Legacy celebration event | 425 Business, Mar 2026 |
| **Mid-summer 2026** | Demolition target | City of Redmond Teen Center Project page |

---

## 3. MONEY TRAIL & DEVELOPER TIES

### Campaign Finance: Mayor Angela Birney

**Total raised: $105,311** (vs. opponent Steve Fields: $23,902 — a 4.4:1 ratio)
Source: Washington State Public Disclosure Commission (PDC) filings; `/home/solaya/Desktop/TOE/OFH/FOLLOW_THE_MONEY.md`

### Nelson Legacy Group — The Adjacent Developer

NLG is headquartered at **16508 NE 79th Street** — directly adjacent to OFH at **16510 NE 79th Street**. NLG controls a **22-acre contiguous assembly** in downtown Redmond with 330+ residential units built or planned ("The Charles": 251 units completed; Phase 2: 88 units + office).

**NLG Donor Bloc to Mayor Birney ($12,200+ identified):**

| Donor | Role | Total | Dates |
|-------|------|-------|-------|
| William Nelson III | Managing Member, NLG | $2,000 | Jun 7, 2019 ($1K); Sep 11, 2019 ($1K) |
| Michael Nelson | Managing Member, NLG | $2,000 | Jun 7, 2019 ($1K); Sep 11, 2019 ($1K) |
| Brian Nelson | Managing Member, NLG | $1,000 | Sep 11, 2019 |
| Mary Morrow | Managing Member/Owner, NLG; OneRedmond Past President | $2,250 | Jun 7, 2019 ($1K); Sep 11, 2019 ($1K); Feb 7, 2023 ($250) |
| Janet McCann | Managing Member, NLG (Santa Barbara, CA) | $3,200 | Jun 7, 2019 ($1K); Sep 11, 2019 ($1K); Apr 1, 2023 ($1.2K) |
| Thomas Markl | CEO, NLG | $1,500 | Jun 7, 2019 ($1K); Aug 4, 2022 ($500) |
| NLG (organization) | — | $250 | May 28, 2015 |

Source: PDC filings; `/home/solaya/Desktop/TOE/OFH/FOLLOW_THE_MONEY.md`

### OneRedmond Board — The Conflict of Interest

OneRedmond is the City of Redmond's economic development partner, receiving a **$300,000 annual city contract**. The board includes:

| Member | Role on Board | Affiliation | Connection to OFH |
|--------|--------------|-------------|-------------------|
| **Angela Birney** | At-Large Member | Mayor of Redmond | Decision-maker on OFH closure |
| **Tim Overland** | Secretary | CEO, Nelson Legacy Group | Adjacent developer |
| **Amy Webber** | Member | Agent, Nelson Legacy Group | Adjacent developer |
| **Mary Morrow** | Past President | Managing Member, NLG | Adjacent developer; $2,250 donor |
| Steve Yoon | Chairman | Mill Creek Residential (700+ units in Redmond) | Developer interest |
| Angela Rozmyn | Vice President | Natural & Built Environments (entitlements firm) | Facilitates development approvals |
| Vanessa Kritzer | Public Sector Partner | City Council Member | Voted 6-0 to demolish |

Source: OneRedmond board listings; PDC filings; `/home/solaya/Desktop/TOE/OFH/FOLLOW_THE_MONEY.md`

### Other Major Donors with Development Interest

| Donor | Amount to Birney | Interest |
|-------|-----------------|----------|
| WA Realtors PAC | $2,000 | Real estate industry lobby |
| NAIOP Commercial RE PAC | $1,000 | Commercial real estate developers |
| Waste Management | $1,450 | No-bid contract since 1994; also $3,650 to Rep. Amy Walen |
| AT&T | $1,000 | OneRedmond Board (via Paolini) |
| Amazon | $1,000 | OneRedmond Board (via Pravitz) |
| Comcast | $1,000 | Utility with city franchise |

### The Property Play

| Factor | Detail |
|--------|--------|
| **OFH lot size** | 0.64 acres |
| **Assessed value (2013)** | $1,624,400 |
| **Estimated current value** | ~$5,000,000 |
| **Adjacent owner** | Nelson Legacy Group (16508 NE 79th St) |
| **NLG assembly** | 22 contiguous acres in downtown core |
| **Light rail** | Station opened May 10, 2025, walking distance |
| **New zoning (Jun 28, 2025)** | 144ft height / FAR 8.0 |
| **Development potential** | 300-400 luxury residential units |
| **Landmark protection** | Deliberately denied (Ord. 2982, Dec 2019) |

### Plymouth Housing Precedent (The Playbook)

In **April 2024**, the City transferred **$5.5 million** in public land (the Cleveland property) to Plymouth Housing — a nonprofit — in a **22-day sprint** with **zero public hearings**. The same legal pipeline executed both transactions:
- **Daniel P. Kenny** (Ogden Murphy Wallace) — property transfer negotiations
- **Andrea Sato** (Kantor Taylor) — Plymouth Housing Transfer Option Agreement

A citizen identified the pattern in a March 24, 2025 email: *"You got away with selling Cleveland property to Plymouth Housing."*

Source: Email records; Ogden Murphy Wallace / Kantor Taylor correspondence thread; `/home/solaya/Desktop/TOE/OFH/FOLLOW_THE_MONEY.md`

### The Three-Case Pattern

| Case | Year | Method | Outcome |
|------|------|--------|---------|
| **COVID whistleblower** | 2020 | Investigation capped at $49,999.99 (one cent under council approval threshold); Chief fired + $95K NDA | Silenced |
| **Plymouth Housing** | 2024 | 22-day sprint, zero hearings, $5.5M free land | Property transferred |
| **OFH Closure** | 2025 | 24+ months internal planning, PR firm before public, false denial, PRA suppression | Building closed, demolition pending |

Common elements: decide in secret → control the message → silence dissent → destroy/conceal evidence → game procedural thresholds.

---

## 4. CITY COST REPORT EVALUATION

### The Three Estimates

The City presented cost estimates at the **July 22, 2025 Council Study Session**, based on the Meng Analysis Facility Condition Assessment:

| Option | City Estimate | Timeline |
|--------|--------------|----------|
| **Renovation** | $9.3 million | 11 months |
| **Demolition + New Construction** | ~$12.1 million | 13 months |
| **Demolition only** | Not publicly documented as standalone figure | — |

Source: 425 Business, September 19, 2025 (https://www.425business.com/news/public-invited-to-share-vision-for-old-fire-house-teen-center/article_dd256326-730f-4282-a139-dc37409022f5.html); July 22, 2025 Council Study Session video (https://www.facebook.com/CityOfRedmond/videos/1261289585484151/)

### Critical Analysis

**1. The renovation estimate may be inflated.**
- The City's own FAQ admits the building is *"currently safe for occupancy."* (Source: FAQ, Smoking Gun #9, FORENSIC_REPORT_COMPLETE.md)
- A safety audit found only *"minor issues."* (Source: Safety audit, Smoking Gun #11)
- The sprinkler system bid (IFB 10861-25) was issued **February 24-25, 2025** — two weeks before the closure announcement — contradicting the narrative of immediate danger.
- The FCA was held in DRAFT for 10 months, with the DRAFT watermark removed only 11 days before public announcement, suggesting the report was being used as a justification rather than a genuine assessment.

**2. The building was systematically starved of maintenance.**

| Year | Request | Amount | Status |
|------|---------|--------|--------|
| 2017 | Stage Lighting Replacement | $22,000 | **DENIED** |
| 2019 | Stage Lighting (re-requested) | $12,000 | **DENIED** |
| 1995-2021 | ADA-Compliant Stage | — then $40,000 | **26-year federal ADA violation; DENIED** |
| 2021 | Awning Frame Repair | $15,345 | **DENIED** |
| 2023 | Amplifier Replacement | $5,025 | **DENIED** |
| **Total denied** | | **$94,370** | **5 of 5 requests** |

Source: Capital Equipment Requests 2018-2025; `/home/solaya/Desktop/TOE/OFH/FORENSIC_REPORT_COMPLETE.md`

The City denied every capital request for six years, then cited the resulting deterioration as grounds for closure. This is a self-fulfilling prophecy — starve the building, then condemn it.

**3. The $9.3M renovation vs $12.1M rebuild comparison is misleading.**
- The $2.8M difference between renovation and rebuild is relatively small.
- The City presented these as the only two options — no "targeted repair" option addressing only the most critical items was offered.
- Former Mayor Ives noted the public *"has not seen renderings for the new 13 Million dollar building, nor heard about funding which appropriately should be part of council's budgetary decisions."* (Source: Ives testimony, March 17, 2026; Redmond Neighborhood Blog)
- The Council voted to demolish and rebuild with **no budget set and no timeline established**. This leaves the lot vacant indefinitely.

**4. Geotechnical risk was flagged but unresolved.**
- The consultant noted costs could rise if a geotechnical report finds liquefaction hazard requiring additional foundation work. No such report has been conducted.
- This means the actual rebuild cost is unknown and could exceed $12.1M significantly.

**5. The "demolition only" cost.**
- We could not independently confirm a $6 million demolition-only estimate in any publicly available city document. If this figure exists, it may be in the PDF facility assessment documents or was stated verbally at a council session. **We recommend requesting this specific document via PRA.**

**6. Revenue vs. Cost Context.**
- OFH revenue target: $106,271
- Actual revenue collected: $6,129 (5.8% of target)
- Average monthly maintenance: $3,083
- PR firm cost: $4,468.75/month — **the PR firm hired to announce the closure cost more per month than the building's average maintenance.**

Source: Budget vs. Actuals; `/home/solaya/Desktop/TOE/OFH/FOLLOW_THE_MONEY.md`

---

## 5. MUSIC EQUIPMENT AUCTION

### What We Know

| Detail | Finding |
|--------|---------|
| **Platform** | GovDeals (govdeals.com) — City of Redmond seller page: https://www.govdeals.com/index.cfm?fa=Main.AdvSearchResults&myseller=16505 |
| **City surplus page** | https://www.redmond.gov/1384/Surplus |
| **Auction open date** | February 25, 2026 |
| **Duration** | ~2 weeks (closing approximately March 11, 2026) |
| **Pickup window** | 10 days after auction close |
| **Items described as** | "Furnishings and equipment from the Old Fire House Teen Center" |

### What the OFH Contained

- Full digital recording studio
- Performance stage with PA system
- Stage lighting equipment
- Amplifiers and musical instruments
- Game room/lounge equipment
- **Historical artifacts** including *"the city's first vault and local newspapers"* (per Ives testimony, March 17, 2026)

### What Could NOT Be Determined

- **Specific items sold**: No detailed public itemized list was found
- **Individual sale prices**: GovDeals completed auction records are not publicly accessible
- **Buyer identities**: Not publicly available
- **Whether teens/community received first right of refusal**: **No evidence found** of preferential access; standard open public auction
- **Whether historical artifacts were included in the sale**: Ives testified that *"priceless artifacts such as the city's first vault and local newspapers"* remained inside the building

### City's Claim

Staff stated they *"worked with stakeholders and community members to ensure that items connected to the legacy of the building were preserved"* and *"programmatic items that could continue to be used were retained and transferred to other City facilities."*

### Legal Concerns

1. **No documented right of first refusal** for the teens and families who used and often donated the equipment.
2. **Historical artifacts**: If city-owned historical items (vault, newspapers) were sold at surplus auction, this could constitute improper disposal of cultural resources.
3. **Adequacy of notice**: Was the auction separately noticed to the OFH community beyond posting on GovDeals?
4. **Revenue disposition**: Where did auction proceeds go? Were they earmarked for teen programming or absorbed into the general fund?

### Recommended Actions

1. **File PRA request** for: complete inventory of all items removed from OFH; GovDeals listing details; winning bids and buyer information; any internal communications regarding disposition of OFH contents; records of items transferred to other facilities vs. auctioned.
2. **Check GovDeals** for any remaining auction records under seller #16505.
3. **Interview community members** who may have attended the auction or received notification.

---

## 6. WASHINGTON SURVEILLANCE LAW ANALYSIS

### Applicable Statutes

#### RCW 9.73 — Privacy, Violating Right of

Washington is a **two-party (all-party) consent** state for recording private communications. (RCW 9.73.030)

While the surveillance of Sasha Glenn documented in the emails does not appear to involve electronic interception, the physical surveillance and reporting on advocacy activity implicates broader constitutional protections.

#### Washington Constitution Article I, Section 7

> *"No person shall be disturbed in his private affairs, or his home invaded, without authority of law."*

The Washington Supreme Court has interpreted this provision as providing **stronger privacy protections** than the federal Fourth Amendment. *State v. Gunwall*, 106 Wn.2d 54, 720 P.2d 808 (1986) (establishing six-factor test for when state constitution provides greater protection).

#### Washington Constitution Article I, Section 4

> *"The right of petition and of the people peaceably to assemble for the common good shall never be abridged."*

#### Washington Constitution Article I, Section 5

> *"Every person may freely speak, write and publish on all subjects, being responsible for the abuse of that right."*

### Evidence of Surveillance and Suppression

**Incident 1: The Tory Watson Surveillance Report (March 20-21, 2025)**

On March 20, 2025, City Program Coordinator Tory Watson authored "Teen Center Observations 3/20" — a report documenting Sasha Glenn's visit to the OFH during her advocacy activities. The report was 4,404 characters long. (Source: Email thread `0fc164f66ff00055`, Email ID 943)

The report was escalated through the following chain in 13.5 hours:

| Time | From | To | Action |
|------|------|----|--------|
| Mar 20, 5:43 PM | Tory Watson | Erica Chua, Jeff Hagen | Initial report (4,404 chars) |
| Mar 21, 6:00 AM | Jeff Hagen | Watson, Chua | Reply (7,095 chars) |
| Mar 21, 6:04 AM | Erica Chua | Hagen, Watson | Reply (10,208 chars) |
| Mar 21, 6:31 AM | Erica Chua | Zach Houvener | Forward to supervisor (11,873 chars) |
| Mar 21, 6:55 AM | Zach Houvener | Chua | Reply (16,410 chars) |
| Mar 21, 6:57 AM | Zach Houvener | **Loreen Hamilton** | Forward to Deputy City Admin (19,146 chars) |
| Mar 21, 7:17 AM | **Loreen Hamilton** | **Mayor Birney** + Malisa Files | Forward to Mayor (19,915 chars) |
| Mar 21, 8:51 AM | Erica Chua | Houvener | Additional (19,384 chars) |
| Mar 21, 11:29 AM | Houvener | DeLarme, Falkenburg, Hagen | Broader distribution (19,091 chars) |

Source: Email thread `0fc164f66ff00055`; timestamps from email metadata in corkboard database

**Incident 2: Code of Conduct Weaponization (March 21, 2025)**

The next day — March 21, 2025 — Erica Chua distributed a "Reminder: City of Redmond Code of Conduct" to staff including Tory Watson, establishing a three-strike escalation path culminating in **permanent expulsion** from city facilities. (Source: Email thread `31c21ebda2d23656`, Email IDs 907-911; body length ~5,500-6,000 chars)

The temporal proximity (surveillance report → Code of Conduct reminder within 14 hours) suggests this was directed at creating a framework to permanently ban the advocate from city facilities if she continued her activities.

**Incident 3: Confiscation of Advocacy Materials**

Teens at OFH were reportedly prevented from making "save the teen center" signs — a direct suppression of protected political speech on public property. (Source: Community testimony; FORENSIC_REPORT_COMPLETE.md)

**Incident 4: Internal Tracking List (February 19, 2025)**

Christina Wilner sent Brant DeLarme an email titled "Parks things to continue tracking" — an internal-only tracking document whose content needs to be verified from the source file but whose subject suggests ongoing monitoring of community activities or individuals. (Source: Email thread `b1a86162516b0525`, Email ID 5478)

### Legal Analysis: Surveillance Violations

**42 U.S.C. § 1983 — First Amendment Retaliation**

Elements (all satisfied):
1. **Protected activity**: Sasha Glenn's advocacy for the OFH is constitutionally protected speech, petition, and assembly under the First Amendment and WA Const. Art. I, §§ 4, 5.
2. **Adverse action**: Government surveillance report filed and escalated to Mayor; Code of Conduct weaponized with permanent expulsion threat; teens confiscated from making advocacy signs.
3. **Causal connection**: The surveillance report was filed *because of* Glenn's advocacy visit. The Code of Conduct reminder followed the surveillance report by less than 14 hours.

**Chilling Effects Doctrine**

Government surveillance of constitutionally protected activity violates the First Amendment even without direct punishment if it would *"deter a person of ordinary firmness from exercising constitutional rights."*

Applicable precedent:
- *Mendocino Environmental Center v. Mendocino County*, 192 F.3d 1283 (9th Cir. 1999) — Government surveillance of advocacy groups constituted First Amendment violation.
- *Gibson v. United States*, 781 F.2d 1334 (9th Cir. 1986) — Surveillance of protest activity can violate First Amendment even without direct punishment.
- *Presbyterian Church v. United States*, 870 F.2d 518 (9th Cir. 1989) — Government infiltration and surveillance of protected activities violated First Amendment.

**Municipal Liability Under Monell**

The surveillance was not a rogue act — it was escalated through the entire chain of command to the Mayor within hours and met with no corrective action. This establishes:
- **Policy/custom**: The rapid, systematic escalation suggests an established practice of monitoring advocates.
- **Final policymaker**: The Mayor received the report and took no action to stop the surveillance or protect the advocate's rights. *Pembaur v. City of Cincinnati*, 475 U.S. 469 (1986).
- No qualified immunity for the municipality. *Owen v. City of Independence*, 445 U.S. 622 (1980).

---

## 7. PUBLIC RECORDS ACT VIOLATION ANALYSIS

### Statutory Framework

The Washington Public Records Act (RCW 42.56) declares:

> *"The people of this state do not yield their sovereignty to the agencies that serve them. The people, in delegating authority, do not give their public servants the right to decide what is good for the people to know and what is not good for them to know."* — RCW 42.56.030

Key provisions:
- **RCW 42.56.070**: Each agency shall make available for public inspection and copying all public records unless specifically exempt.
- **RCW 42.56.080**: Agencies must respond within **five business days**.
- **RCW 42.56.100**: Agencies have an affirmative **duty to prevent destruction** of public records.
- **RCW 42.56.550(4)**: Any prevailing requester is entitled to **mandatory attorney fees** and penalties of **$5-$100 per day** per violation.
- **RCW 42.56.565**: Enhanced penalties for bad faith; potential personal liability for officials who directed withholding.

### Corkboard Evidence: Specific PRA Violations

#### Violation 1: Willful Withholding of Responsive Records (911+ Emails)

**Method of proof**: Reply-chain mathematical analysis. If Email B is a reply to Email A, Email A must have existed. If Email A is not in the production but Email B is, Email A was withheld.

**Key ghost entities (zero outgoing emails produced despite mathematical proof of existence):**

| Entity | Emails Received | Reply-To Proofs | Outgoing Produced | Assessment |
|--------|----------------|----------------|-------------------|------------|
| Mayor Angela Birney (abirney@redmond.gov) | 432 | 82 | 54 (8 unique) | **WITHHELD** — surgically reduced |
| Mayor's Office (mayor@redmond.gov) | 570 | 108 | 0 | **WITHHELD** — complete suppression |
| Stepherson Associates - hrudin | 209 | 178 | 0 | **WITHHELD** — PR firm responses suppressed |
| Stepherson Associates - dedmunds | 209 | 178 | 0 | **WITHHELD** — PR firm responses suppressed |
| Council (council@redmond.gov) | 229 | 120 | 0 | **WITHHELD** — all council responses suppressed |
| Steve Fields (sfields@redmond.gov) | 325 | 114 | 0 | **WITHHELD** — sole opposition voice erased |
| Osman Salahuddin (osalahuddin@redmond.gov) | 298 | 105 | 0 | **WITHHELD** — City Administrator suppressed |
| Malisa Files (mfiles@redmond.gov) | 405 | 84 | 6 | **WITHHELD** — near-complete suppression |
| Carol Payne (cpayne@redmond.gov) | 123 | 20 | 0 | **WITHHELD** |
| City Clerk (cityclerk@redmond.gov) | 27 | 15 | 0 | **WITHHELD** |

**Total additional ghost entities**: 73 (all with zero outgoing messages despite receiving emails)

Source: `/home/solaya/Desktop/TOE/OFH/PRA_SUPPRESSION_REPORT.md`; Ghost probe analysis; `/home/solaya/Desktop/TOE/OFH/AFFIDAVIT_EXHIBITS.md`, Exhibit 1

#### Violation 2: Production Padding with Duplicates

| Metric | Count |
|--------|-------|
| Total documents produced | 7,573 |
| Unique message bodies | 2,399 |
| Exact duplicates | 5,047 |
| Cross-installment duplicates | 1,137 |
| Automated/system noise | 985 |
| **Effective unique documents** | **~1,541** |
| **Inflation rate** | **79.7%** |

Worst case: A single email from Angie Nuevacamina was duplicated **134 times**.

This constitutes obfuscation under the *Yousoufian* penalty framework and is evidence of bad faith.

Source: `/home/solaya/Desktop/TOE/OFH/duplicate_analysis.json`; `/home/solaya/Desktop/TOE/OFH/AFFIDAVIT_EXHIBITS.md`, Exhibit 2

#### Violation 3: Systematic Attachment Stripping

- **4,109 emails (54.3%)** contain attachment references
- **35,455 total attachment references** across the production
- **288 unique attachment filenames** identified
- **Zero attachments produced**

Known withheld attachments include: talking points documents, legal memoranda, engagement plans, embargoed materials, facility assessment drafts, meeting presentations, staff communications templates, and the FCA report itself.

Source: `/home/solaya/Desktop/TOE/OFH/AFFIDAVIT_EXHIBITS.md`, Exhibit 3

#### Violation 4: Severed Conversation Threads

**41 orphan threads** identified where the original initiating email was withheld but subsequent replies were produced. The original email in each case is mathematically proven to have existed.

Notable example: *"For review: Redmond OFH 2/18 team check-in meeting notes"* — 110 messages in thread, zero original email. Thread ID: `2d8965445a4bfdd1`.

Source: `/home/solaya/Desktop/TOE/OFH/AFFIDAVIT_EXHIBITS.md`, Exhibit 4

#### Violation 5: Five-Month Production Gap

September 2024 through January 2025: effectively zero emails produced for this period. This gap covers:
- The period when the PR firm was contracted
- When the FCA was held in draft
- When the closure timeline was finalized
- When the "satellite site" decision was operationalized

Source: `/home/solaya/Desktop/TOE/OFH/AFFIDAVIT_EXHIBITS.md`, Exhibit 8

#### Violation 6: Channel Switching (45 Documented Instances)

**45 instances** of city officials directing conversations off-email ("give me a call," "let's discuss offline") at critical decision points, creating gaps in the public record.

Notable: March 4, 2025 — Kyle Muir sent two "give me a call" messages within 2 minutes, the same day Hamilton issued the false denial.

Source: `/home/solaya/Desktop/TOE/OFH/AFFIDAVIT_EXHIBITS.md`, Exhibit 5

#### Violation 7: File Corruption

**96% of raw .msg files** (5,967 of 6,213) exhibit corrupted MAPI property streams within intact OLE2 containers. This pattern is consistent with **programmatic manipulation during export** rather than natural file degradation, which would affect the container structure uniformly.

Source: `/home/solaya/Desktop/TOE/OFH/FORENSIC_REPORT_COMPLETE.md`

#### Violation 8: No Privilege Log

The PRA requires that withheld records be identified with specific exemption citations. The City provided **no privilege log** and **no exemption explanations** for any withheld or redacted material. Under *PAWS v. University of Washington*, 125 Wn.2d 243, 884 P.2d 592 (1994), the burden is on the agency to prove an exemption applies.

### Penalty Calculation Framework

Under *Yousoufian v. Office of Ron Sims*, 152 Wn.2d 421, 98 P.3d 463 (2004), penalties are calculated using the following factors:

1. **Bad faith**: Demonstrated by surgical removal of Mayor's emails, systematic ghost suppression, production padding, attachment stripping, and file corruption. **Factor strongly favors maximum penalty.**
2. **Willfulness**: The pattern (suppress opposition voice, suppress PR firm responses, suppress Mayor's office) is too systematic to be accidental. **Factor strongly favors maximum penalty.**
3. **Harm to requester**: Requester could not evaluate the City's decision-making process, participate meaningfully in public comment, or identify conflicts of interest. **Factor favors enhanced penalty.**
4. **Mitigation**: None. The City has not supplemented the production, acknowledged errors, or produced withheld records. **No mitigation.**
5. **Magnitude**: 911+ withheld emails, 4,109 stripped attachments, 5-month gap, 73 ghost entities. **Factor favors maximum penalty.**
6. **Reasonable interpretation**: No exemption was claimed. The City cannot argue it reasonably believed emails from the Mayor's office or a PR firm were exempt. **Factor favors maximum penalty.**
7. **Pattern or practice**: Three documented cases of suppression (COVID, Plymouth Housing, OFH). **Factor strongly favors maximum penalty.**
8. **Public importance**: Disposal of a $5M+ public asset, closure of a 30-year community institution, with developer conflict of interest. **Factor favors maximum penalty.**
9. **Obfuscation**: 79.7% duplicate inflation, attachment stripping. **Factor strongly favors maximum penalty.**

**All nine Yousoufian factors favor penalties at the maximum $100/day rate.**

### Estimated Penalty Exposure

Assuming violations running from the date of inadequate response (approximately March 2025) through resolution:

- **Per-day penalty**: $100/day (maximum)
- **Duration**: ~365+ days and counting
- **Minimum penalty**: $36,500+ (one violation stream)
- **Multiple violation streams**: If calculated per-category (ghost emails, attachments, gaps), exposure multiplies significantly
- **Mandatory attorney fees**: RCW 42.56.550(4)
- **Additional bad-faith penalties**: RCW 42.56.565

### Criminal Referral

**RCW 40.16.020** — Willful destruction or concealment of public records is a **Class B felony**. The systematic patterns documented here (surgical email removal, programmatic file corruption, five-month gaps) may warrant referral to the King County Prosecuting Attorney or Washington Attorney General.

---

## 8. LEGAL ARGUMENT: PRA LAWSUIT

### SUPERIOR COURT OF THE STATE OF WASHINGTON FOR KING COUNTY

**[PLAINTIFF(S)] v. CITY OF REDMOND**

### COMPLAINT FOR VIOLATION OF THE WASHINGTON PUBLIC RECORDS ACT (RCW 42.56)

#### I. INTRODUCTION

1. This action arises from the City of Redmond's systematic and willful violation of the Washington Public Records Act ("PRA"), RCW 42.56, in response to Public Records Request No. 32782.

2. The City's violations include: willful withholding of at least 911 mathematically proven responsive emails; failure to produce 35,455 referenced attachments across 4,109 emails; inflation of the production with 5,047 exact duplicate documents (79.7% padding rate); a five-month production blackout covering the critical decision-making period; systematic corruption of 96% of raw source files; and complete failure to provide a privilege log or cite any exemption for withheld records.

3. These violations were not the product of negligence. The surgical nature of the withholding — specifically targeting the Mayor's outgoing communications, the sole opposition council member's entire record, and all responses from the PR firm hired to manage the OFH closure — demonstrates deliberate suppression of records that would reveal the true decision-making process behind the closure and planned demolition of the Old Fire House Teen Center.

#### II. PARTIES

4. Plaintiff(s) [TO BE DETERMINED] are residents and taxpayers of the City of Redmond, Washington, and/or requesters of public records under RCW 42.56.

5. Defendant City of Redmond is a municipal corporation organized under the laws of the State of Washington, located in King County.

#### III. JURISDICTION AND VENUE

6. This Court has jurisdiction under RCW 42.56.550(1), which provides that any person may seek judicial review of an agency's denial of or failure to respond to a public records request.

7. Venue is proper in King County Superior Court, as the City of Redmond is located in King County.

#### IV. STANDING

8. Standing under the PRA is broad. "Any person" may request records, and "any person" who prevails is entitled to relief. RCW 42.56.080; RCW 42.56.550. No showing of special injury or specific interest is required. *Hearst Corp. v. Hoppe*, 90 Wn.2d 123, 580 P.2d 246 (1978).

#### V. FACTUAL ALLEGATIONS

**A. The Public Records Request**

9. On or about [DATE], Plaintiff(s) submitted Public Records Request No. 32782 to the City of Redmond, requesting records related to the Old Fire House Teen Center.

10. The City responded by producing records in four installments, totaling 7,573 documents.

**B. The Production Was Willfully Inadequate**

11. Forensic analysis of the production reveals it was systematically manipulated to conceal the City's decision-making process:

*Duplicate Inflation*

12. Of 7,573 documents produced, 5,047 are exact duplicates of other documents in the production — a 79.7% inflation rate. Only approximately 1,541 unique, substantive documents were actually produced. A single email was duplicated 134 times. This padding created the appearance of compliance while burying the substantive record.

*Withheld Emails — Mathematical Proof*

13. Reply-chain analysis proves at least 911 responsive emails were withheld. The methodology is irrefutable: if Email B is a "reply to" Email A, then Email A must have existed at the time of the response. When Email B appears in the production but Email A does not, Email A has been withheld.

14. The withholding follows a clear pattern targeting specific actors:

   a. **Mayor Angela Birney**: 432 emails addressed to her were produced; only 8 unique outgoing emails from her were produced; 82 reply-chain proofs demonstrate additional withheld outgoing emails. Her name appears in 1,838 emails, yet she is functionally absent as a sender.

   b. **Council Member Steve Fields** (the Mayor's 2019 election opponent): 325 emails addressed to him were produced; 114 reply-chain proofs demonstrate outgoing emails existed; zero outgoing emails were produced. His voice was completely erased from the record.

   c. **Stepherson & Associates PR Firm** (hrudin, dedmunds): 209 emails addressed to each were produced; 178 reply-chain proofs each; zero outgoing emails produced from either individual. The City's hired communications consultants — whose entire function was to write responses — have zero responses in the record.

   d. **City Administrator Osman Salahuddin**: 298 emails received; 105 reply-chain proofs; zero outgoing produced.

   e. **City Council (council@redmond.gov)**: 229 emails received; 120 reply-chain proofs; zero outgoing produced.

   f. An additional 63 "ghost entities" received 100+ emails each with zero outgoing produced.

*Attachment Stripping*

15. Of 7,573 produced emails, 4,109 (54.3%) reference attachments — a total of 35,455 attachment references citing 288 unique filenames. Zero attachments were produced. The withheld attachments include talking points, legal memoranda, engagement plans, facility assessment drafts, embargoed materials, and presentation documents central to understanding the closure decision.

*Five-Month Production Gap*

16. The production contains effectively zero emails from September 2024 through January 2025. This five-month gap covers the period during which: the PR firm was contracted; the Facility Condition Assessment was held in draft; the closure timeline was finalized; and key decisions were made. The gap is not explained by any exemption claim or privilege log entry.

*File Corruption*

17. 96% of raw .msg files (5,967 of 6,213) exhibit a specific corruption pattern: intact OLE2 containers with corrupted MAPI property streams. Natural file degradation would affect the container structure; selective corruption of only the property streams (which contain email metadata, headers, and body content) is consistent with programmatic manipulation during the export process.

*No Privilege Log*

18. The City provided no privilege log, no exemption citations, and no explanation for any withheld or redacted material, in violation of the PRA's requirement that agencies identify the specific exemption relied upon. *PAWS v. University of Washington*, 125 Wn.2d 243, 884 P.2d 592 (1994).

**C. The Withholding Was in Bad Faith**

19. The selective nature of the suppression — targeting the Mayor, her political opponent, the PR firm, the City Administrator, and the full Council — demonstrates the withholding was designed to prevent public understanding of who made the closure decision, when, and why.

20. This is consistent with the City's documented pattern of records suppression in at least two prior cases: the 2020 COVID whistleblower matter (investigation capped at $49,999.99, records sealed) and the 2024 Plymouth Housing property transfer ($5.5M in public land transferred with zero public hearings).

#### VI. CAUSES OF ACTION

**First Cause of Action: Failure to Produce Responsive Records (RCW 42.56.070)**

21. The City failed to produce at least 911 mathematically proven responsive emails, 35,455 referenced attachments, and an unknown number of records from the five-month production gap.

22. The City bears the burden of proving any exemption applies. RCW 42.56.550(3). The City has cited no exemption.

**Second Cause of Action: Failure to Provide Fullest Assistance (RCW 42.56.100)**

23. The PRA requires agencies to provide "the fullest assistance" to requesters. The City's production — inflated with 79.7% duplicates, stripped of all attachments, missing five months of records, and corrupted at the file level — does not constitute "fullest assistance."

**Third Cause of Action: Bad Faith Withholding (RCW 42.56.565)**

24. The systematic and selective nature of the withholding constitutes bad faith, warranting enhanced penalties under RCW 42.56.565.

#### VII. RELIEF REQUESTED

WHEREFORE, Plaintiff(s) respectfully request that the Court:

A. Order the City to produce all responsive records, including the 911+ withheld emails, all 35,455 referenced attachments, and all records from the September 2024-January 2025 gap period;

B. Order the City to produce a complete privilege log for any records it claims are exempt;

C. Award per-day penalties at the maximum rate of $100/day under RCW 42.56.550(4), running from the date of initial violation through the date of full compliance;

D. Award enhanced penalties for bad faith under RCW 42.56.565;

E. Award all costs and mandatory attorney fees under RCW 42.56.550(4);

F. Issue a preservation order requiring the City to preserve all records related to the OFH, including electronic communications on all platforms (email, text, messaging apps, personal devices used for government business);

G. Order in camera review of the City's email systems to verify completeness of any supplemental production;

H. Grant such other and further relief as the Court deems just and equitable.

#### VIII. VERIFICATION

[To be signed by Plaintiff(s)]

---

## 9. LETTER TO WASHINGTON ATTORNEY GENERAL

---

**[Date]**

The Honorable Nick Brown
Attorney General of Washington
1125 Washington Street SE
PO Box 40100
Olympia, WA 98504-0100

**RE: Request for Investigation — City of Redmond Public Records Act Violations, Open Public Meetings Act Violations, and Potential Criminal Records Concealment (RCW 40.16.020)**

Dear Attorney General Brown:

We write to request that your office investigate systematic and willful violations of the Washington Public Records Act (RCW 42.56), the Open Public Meetings Act (RCW 42.30), and potential criminal concealment of public records (RCW 40.16.020) by the City of Redmond, Washington, in connection with the closure and planned demolition of the Old Fire House (OFH) Teen Center.

### I. BACKGROUND

The Old Fire House Teen Center, located at 16510 NE 79th Street, Redmond, WA, served Redmond's youth for over 30 years. The building, constructed in 1952, was converted to a teen center circa 1991. It became a culturally significant venue that launched nationally recognized musicians including Death Cab for Cutie and Modest Mouse. (See KEXP Oral History, September 2017.)

On March 11, 2025, the City publicly announced the closure of OFH, citing building deterioration identified in a Facility Condition Assessment. The building was closed within two weeks, with less than three weeks' notice to the community. On November 18, 2025, the City Council voted 6-0 to demolish and rebuild, but established no budget and no timeline.

### II. SUMMARY OF VIOLATIONS

Forensic analysis of 7,573 documents obtained through Public Records Request No. 32782 reveals a pattern of willful records suppression designed to conceal the City's decision-making process. The key findings include:

**A. Willful Withholding of Records (RCW 42.56.070)**

Reply-chain mathematical analysis proves **at least 911 responsive emails were withheld**. The suppression specifically targeted:
- **Mayor Angela Birney**: 82 reply-chain proofs of withheld outgoing emails; only 8 unique outgoing emails produced despite 1,838 mentions of her name across the production.
- **Council Member Steve Fields** (the Mayor's 2019 election opponent): 114 reply-chain proofs; zero outgoing emails produced.
- **Stepherson & Associates** (PR firm hired to manage the closure): 178 reply-chain proofs per consultant; zero outgoing emails produced from either.
- **City Administrator**: 105 reply-chain proofs; zero outgoing.
- **City Council**: 120 reply-chain proofs; zero outgoing.

The selectivity of the suppression — erasing the Mayor, her political opponent, the PR firm, the City Administrator, and the full Council from the outgoing record — cannot be attributed to error.

**B. Attachment Stripping**

4,109 emails (54.3%) reference attachments (35,455 total references, 288 unique filenames). **Zero attachments were produced.** Withheld attachments include talking points, legal memoranda, engagement plans, facility assessment drafts, and embargoed presentation materials.

**C. Production Inflation**

5,047 of 7,573 documents are exact duplicates — a **79.7% inflation rate**. One email was duplicated 134 times. This created the false appearance of a comprehensive response while burying the substantive record.

**D. Five-Month Gap**

The production contains effectively zero records from **September 2024 through January 2025** — the period during which the PR firm was contracted, the facility assessment was held in draft, and the closure decision was finalized. No exemption was cited for this gap.

**E. Potential Criminal Records Manipulation (RCW 40.16.020)**

96% of raw .msg files exhibit a specific corruption pattern: intact OLE2 containers with selectively corrupted MAPI property streams. This is inconsistent with natural degradation and consistent with programmatic manipulation during export. If confirmed, this constitutes willful concealment of public records — a Class B felony under RCW 40.16.020.

**F. Open Public Meetings Act Violations (RCW 42.30)**

The decision to close OFH was made outside of any open public meeting. Internal records show planning began at least 24 months before the public announcement (January 2023 "Alternate Facilities Plan" on team agendas). No public comment opportunity was provided before the closure was executed. Under RCW 42.30.060, any action taken in violation of the OPMA is **null and void**.

### III. CONFLICT OF INTEREST AND PUBLIC TRUST CONCERNS

The closure involves potential conflicts of interest warranting investigation:

- The OFH lot (0.64 acres, est. $5M value) is directly adjacent to the corporate headquarters of **Nelson Legacy Group** (16508 NE 79th St), which controls a 22-acre development assembly in downtown Redmond.
- NLG principals and affiliates donated **$12,200+** to Mayor Birney's campaign — the single largest identified donor bloc.
- Three NLG-affiliated individuals sit on the **OneRedmond** economic development board alongside **Mayor Birney herself**.
- New zoning adopted June 28, 2025 designates the OFH site for up to **144 feet / FAR 8.0** — enabling 300-400 luxury residential units.
- The same legal team (Ogden Murphy Wallace / Kantor Taylor) executed both the OFH process and a prior $5.5 million public land transfer to Plymouth Housing in 2024 — accomplished in 22 days with zero public hearings.

### IV. SURVEILLANCE AND RETALIATION

On March 20, 2025, City staff filed a surveillance report on community advocate **Sasha Glenn** documenting her advocacy visit to OFH. The report was escalated through five levels of city hierarchy to the Mayor within 13.5 hours. The following day, a Code of Conduct reminder was distributed establishing a framework for **permanent expulsion** from city facilities. This constitutes government surveillance of protected First Amendment activity and creates an impermissible chilling effect.

### V. DOCUMENTED FALSE STATEMENT

On March 4, 2025 — seven days before the public announcement — Deputy City Administrator **Loreen Hamilton** told a community member: *"There has been no such decision made about the Old Firehouse Teen Center."* At that time, the PR firm had been active for six weeks, a 110-email coordination thread was ongoing, the engagement plan was in version 2, and the press release was three business days from distribution.

### VI. REQUEST

We respectfully request that the Attorney General's Office:

1. **Investigate** the City of Redmond's compliance with the Public Records Act and Open Public Meetings Act in connection with the OFH closure;
2. **Determine** whether the systematic file corruption and email suppression warrant criminal prosecution under RCW 40.16.020;
3. **Issue an opinion** on whether the closure decision was made in compliance with OPMA public meeting requirements;
4. **Examine** potential conflicts of interest between the Mayor's campaign donors and the disposition of public property; and
5. **Consider intervention** under RCW 42.56.565 or the Attorney General's general authority to enforce state law and protect the public interest.

### VII. SUPPORTING DOCUMENTATION

The following evidence is available for your review:

1. Complete forensic analysis report (7,573 documents analyzed)
2. Duplicate analysis database (JSON)
3. Ghost entity probe results (reply-chain mathematical proofs)
4. Gap analysis (timeline, thread, and entity gaps)
5. Campaign finance records (PDC filings)
6. Affidavit exhibits (9 categories of suppression evidence)
7. All original PRA productions (4 installments)
8. Interactive forensic corkboard (https://akataleptos.com/ofh) — 7,573 emails with relationship mapping

We are prepared to provide all materials to your office upon request.

Respectfully submitted,

[Signature Block]
[Contact Information]

cc: King County Prosecuting Attorney
    City of Redmond City Council
    Washington State Auditor

---

## 10. EXHIBIT LIST

### Primary Exhibits (Native Files on Disk)

| Exhibit | Description | Location |
|---------|-------------|----------|
| **A** | Forensic Report — Complete analysis (15 smoking guns, timeline, key players) | `/home/solaya/Desktop/TOE/OFH/FORENSIC_REPORT_COMPLETE.md` |
| **B** | Affidavit Exhibits — 9 categories of suppression evidence | `/home/solaya/Desktop/TOE/OFH/AFFIDAVIT_EXHIBITS.md` |
| **C** | PRA Suppression Report — Executive summary of deliberate withholding | `/home/solaya/Desktop/TOE/OFH/PRA_SUPPRESSION_REPORT.md` |
| **D** | Follow the Money — Campaign finance analysis | `/home/solaya/Desktop/TOE/OFH/FOLLOW_THE_MONEY.md` |
| **E** | The Full Picture — Deductive theory, 7 layers of evidence | `/home/solaya/Desktop/TOE/OFH/THE_FULL_PICTURE.md` |
| **F** | Duplicate Analysis — Production padding metrics | `/home/solaya/Desktop/TOE/OFH/duplicate_analysis.json` |
| **G** | Gap Analysis — Entity, thread, and timeline gaps | `/home/solaya/Desktop/TOE/OFH/gap_analysis.json` |
| **H** | Medium Network Analysis — 15+ shell accounts, Keith Birney hub | `/home/solaya/Desktop/TOE/OFH/MEDIUM_NETWORK_ANALYSIS.md` |
| **I** | IP Investigation — Vacares LLC, 46+ fake persona domains | `/home/solaya/Desktop/TOE/OFH/IP_INVESTIGATION_84.247.3.129.md` |
| **J** | Keith Birney Patent Analysis — Web indexing patents, SEO expertise | `/home/solaya/Desktop/TOE/OFH/birney_patents_analysis.md` |
| **K** | Corkboard Database — 7,573 emails, 337 people, 717 connections | `/home/solaya/Desktop/TOE/OFH/corkboard.db` (SQLite) |
| **L** | Public Records Follow-Up Request Template | `/home/solaya/Desktop/TOE/OFH/PUBLIC_RECORDS_REQUEST.md` |

### Email Evidence (Source Files — Key Threads)

| Exhibit | Description | Thread ID | Key Email IDs |
|---------|-------------|-----------|---------------|
| **M** | Hamilton false denial to Freya Reiger ("no such decision") | `652c1dabfad4ad64` | 3750, 3753 |
| **N** | Watson surveillance report on Sasha Glenn ("Teen Center Observations 3/20") | `0fc164f66ff00055` | 943+ |
| **O** | Code of Conduct weaponization (permanent expulsion framework) | `31c21ebda2d23656` | 907-911 |
| **P** | S&A engagement plan and weekly check-ins (earliest PR firm evidence) | `50dd2d0139ce601e` | — |
| **Q** | 110-message S&A coordination thread (meeting notes) | `2d8965445a4bfdd1` | — |
| **R** | 201-message S&A outreach check-in thread | `ae34bc21365d487b` | — |
| **S** | FAQ/Web Content/Staff Communications (32 emails, 8 revisions in one day) | `c8498925179735f2` | 3710-3725 |
| **T** | "Parks things to continue tracking" (internal monitoring list) | `b1a86162516b0525` | 5478 |
| **U** | S&A Invoice #5387 / Contract #10631 | `1234b704a73964bd` | — |
| **V** | Media inquiry coordination — Seattle Times | `d5499d8af4165ed9` | — |
| **W** | Media inquiry coordination — KOMO | `2fee5add1d895a6f` | — |

### External Sources

| Exhibit | Description | URL/Source |
|---------|-------------|------------|
| **X-1** | KIRO 7 News — "Teens, parents fighting to keep Redmond teen center" (Mar 26, 2025) | https://www.kiro7.com/news/local/teens-parents-fighting-keep-redmond-teen-center-closing-down/YPS5ZUUDUNHNVP3TOX2SXIQZYI/ |
| **X-2** | KOMO News — "Redmond seeks to move resources from popular Old Fire House Teen Center" (Mar 27, 2025) | https://komonews.com/news/local/redmond-old-fire-house-teen-center |
| **X-3** | KUOW — "Battle for the teen center" (Jul 22, 2025) | https://www.kuow.org/stories/battle-for-the-teen-center-youth-on-seattle-s-eastside-fight-to-reopen-beloved-space |
| **X-4** | 425 Business — Cost estimates article (Sep 19, 2025) | https://www.425business.com/news/public-invited-to-share-vision-for-old-fire-house-teen-center/article_dd256326-730f-4282-a139-dc37409022f5.html |
| **X-5** | 425 Magazine — "Redmond City Council Votes to Rebuild" (Nov 2025) | https://www.425magazine.com/culture-life/redmond-old-fire-house-teen-center-rebuild/article_aa33cc27-1471-4bb1-a296-476f61b3b56e.html |
| **X-6** | Redmond Neighborhood Blog — Ives testimony (Mar 25, 2026) | https://redmondcity.blogspot.com/ |
| **X-7** | KEXP Oral History of OFH (2017) | https://www.kexp.org/read/2017/9/28/we-just-want-to-play-shows-an-oral-history-of-redmonds-old-fire-house-teen-center-part-1/ |
| **X-8** | Change.org Petition (3,998 signatures) | https://www.change.org/p/save-old-fire-house-teen-center |
| **X-9** | Interactive Forensic Corkboard | https://akataleptos.com/ofh |
| **X-10** | OFH Stakeholder Group Final Report | https://www.redmond.gov/DocumentCenter/View/39787/OFH-Stakeholder-Group-Final-Report |
| **X-11** | City of Redmond Teen Center Project page | https://www.redmond.gov/2494/Teen-Center-Project |
| **X-12** | City of Redmond FAQs | https://www.redmond.gov/Faq.aspx?TID=125,118,122,123,124 |
| **X-13** | City of Redmond GovDeals Surplus page | https://www.govdeals.com/index.cfm?fa=Main.AdvSearchResults&myseller=16505 |
| **X-14** | Seattle Times — "How Redmond's Old Fire House became the bedrock" | https://www.seattletimes.com/entertainment/music/how-redmonds-old-fire-house-became-the-bedrock-of-a-local-music-movement/ |
| **X-15** | Redmond Historical Society — OFH History | https://www.redmondhistoricalsociety.org/post/where-redmond-found-its-sound-club-red-the-old-fire-house-and-the-teens-who-made-music-history |

### Statutory Authorities

| Statute | Subject |
|---------|---------|
| RCW 42.56.010 | Definition of public records |
| RCW 42.56.030 | People's sovereignty — construction clause |
| RCW 42.56.070 | Duty to disclose; fullest assistance |
| RCW 42.56.080 | Five business day response requirement |
| RCW 42.56.100 | Duty to prevent record destruction |
| RCW 42.56.210(1) | Exemptions narrowly construed |
| RCW 42.56.230 | Personal information exemptions |
| RCW 42.56.240 | Investigative records exemption |
| RCW 42.56.550 | Judicial review; $5-$100/day penalties; mandatory attorney fees |
| RCW 42.56.565 | Enhanced penalties for bad faith |
| RCW 42.30.010-.130 | Open Public Meetings Act |
| RCW 42.30.060 | Actions in violation are null and void |
| RCW 42.30.120 | Personal liability ($500-$1,000 per member) |
| RCW 36.70A.130/.140 | Growth Management Act — public hearing requirements |
| RCW 43.21C / WAC 197-11 | State Environmental Policy Act |
| RCW 40.16.020 | Criminal concealment of public records (Class B felony) |
| RCW 9.73.030 | Two-party consent — private communications |
| WA Const. Art. I, § 4 | Right of petition and assembly |
| WA Const. Art. I, § 5 | Freedom of speech |
| WA Const. Art. I, § 7 | Privacy (stronger than federal 4th Amendment) |
| 42 U.S.C. § 1983 | Federal civil rights — First Amendment retaliation |
| 42 U.S.C. § 1988 | Attorney fees for § 1983 prevailing plaintiffs |

### Case Law Cited

| Case | Citation | Principle |
|------|----------|-----------|
| *Yousoufian v. Office of Ron Sims* | 152 Wn.2d 421, 98 P.3d 463 (2004) | PRA penalty calculation framework (9 factors) |
| *Yousoufian v. Sims (II)* | 168 Wn.2d 444, 229 P.3d 735 (2010) | Penalty range applies per request; bad faith = maximum |
| *Neighborhood Alliance v. County of Spokane* | 172 Wn.2d 702, 261 P.3d 119 (2011) | Silent withholding = bad faith; duty to search all custodians |
| *Nissen v. Pierce County* | 183 Wn.2d 863, 357 P.3d 45 (2015) | Adequacy of search; duty to produce all responsive records |
| *PAWS v. University of Washington* | 125 Wn.2d 243, 884 P.2d 592 (1994) | Exemptions narrowly construed; burden on agency |
| *Hearst Corp. v. Hoppe* | 90 Wn.2d 123, 580 P.2d 246 (1978) | PRA liberally construed; broad standing |
| *Monell v. Dep't of Social Services* | 436 U.S. 658 (1978) | Municipal liability under § 1983 |
| *Owen v. City of Independence* | 445 U.S. 622 (1980) | No qualified immunity for municipalities |
| *Pembaur v. City of Cincinnati* | 475 U.S. 469 (1986) | Single act by final policymaker = municipal liability |
| *Mendocino Envtl. Ctr. v. Mendocino Cty.* | 192 F.3d 1283 (9th Cir. 1999) | Government surveillance of advocacy = First Amendment violation |
| *Gibson v. United States* | 781 F.2d 1334 (9th Cir. 1986) | Surveillance chilling effect on protest |
| *Presbyterian Church v. United States* | 870 F.2d 518 (9th Cir. 1989) | Government infiltration of protected activities |
| *State v. Gunwall* | 106 Wn.2d 54, 720 P.2d 808 (1986) | WA constitution stronger than federal on privacy |
| *White v. City of Norwalk* | 900 F.2d 1421 (9th Cir. 1990) | Public comment is protected First Amendment activity |
| *Norway Hill Preservation v. King County* | 87 Wn.2d 267 (1976) | SEPA violations routinely enjoined |

---

**DISCLAIMER**: This document constitutes legal research and analysis, not legal advice. All statutory citations and case law should be verified through official sources (Westlaw, LexisNexis, or official reporters) before use in any legal filing. Consult a licensed Washington State attorney before initiating legal proceedings.

---

*Prepared using forensic data from the OFH Investigation Archive*
*Full evidence available at: https://akataleptos.com/ofh*
*Local archive: `/home/solaya/Desktop/TOE/OFH/`*
