NO. 23-2-04149-1-SUMMONS

NO. 23-2-04149-1-SUMMONS

NO. 23-2-04149-1

SUMMONS

IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON

IN AND FOR THE COUNTY OF PIERCE

BREAKWATER MARINA, INC,

Plaintiff,

v.

ANDREW LEE D/B/A FIRST PROJECT AND/OR MAKKI INC.,

Defendants.

TO THE DEFENDANTS: A lawsuit has been started against you in the above-entitled court by Breakwater Marina, Inc, plaintiff. Plaintiff’s claim is stated in the written Complaint, a copy of which is served upon you with this Summons.

The State of Washington to the said, Andrew Lee D/B/A First Project and/or Makki Inc., you are hereby summoned to appear within sixty days after the date of the first publication of this summons, to wit, within sixty days after January 17, 2023, and defend the above entitled action in the above entitled court, and answer the complaint of the plaintiff, Breakwater Marina, Inc. and serve a copy of your answer upon the undersigned attorneys for the plaintiff, Christopher Keay, and Brennen Johnson at their office stated below; and in case of your failure so to do, judgment will be rendered against you according to the demand of the complaint, which has been filed with the clerk of said court. The object of the complaint is breach of contract related to delivery of ownership of the website domain “breakwatermarina.com.” The action requests relief of the court in the form of ordering specific performance and/or injunctive relief for delivery of ownership of the domain breakwatermarina.com, as well as declaratory relief establishing Breakwater Marina, Inc. as the rightful owner and/or domain holder of breakwatermarina.com.

If you wish to seek the advice of an attorney in this matter, you should do so promptly so that your written response, if any, may be served on time.

This Summons is issued pursuant to RCW 4.28.110.

DATED this 10th day of January, 2023, at Tacoma, Washington.

JOHNSON, GRAFFE, KEAY, MONIZ

& WICK, LLP

/s/Brennen Johnson Christopher Keay, WSBA# 13143

Brennen Johnson, WSBA# 51665

Attorney for Plaintiff Breakwater

Marina, Inc. 2115 N. 30th St., Ste. 101

Tacoma, WA 98403

(253) 572-5323

ckeay@jgkmw.com

brennenj@jgkmw.com

IDX-969806

January 17, 24, 31, February 7, 14, 21, 2023