1/31/2019 | Page 1

Dear ______:

I am writing in response to a contact that your company recently made with my law firm about the lien you have filed on behalf of MultiCare/Mt. Rainier/______against the claims of my client ______.

The lien that you have filed against my client’s case was notarized by a woman named Rebecca Rohlke and signed by Mr. Wadsworth as the managing partner of Hunter Donaldson. I am attaching a copy of that lien to this letter as Exhibit A.

As you already know from having been served with the class action complaint captioned Walker, et al. v. Hunter Donaldson, et al., attached hereto as Exhibit B,it has been alleged that Hunter Donaldson and Multicare conspired to implement a practice of encumbering the recoveries of injured plaintiffs with fraudulently-notarized and invalid liens. The class action complaint itself contains exhibits showing compelling evidence that Hunter Donaldson and Multicare have, indeed, filed invalid liens where they have used Rebecca Rohlke as a Washington-commissioned notary and included Mr. Wadsworth signature on behalf of Hunter Donaldson, despite Rohlke never being a Washington resident nor Hunter Donaldson being a recognized claimant under Washington’s medical lien statute. I also direct your attention to the news coverage in both the The Morning News Tribune, found at

/05/05/2585070/suit-against-multicare-says-its.html,and the story done by reporter Tracey Vedder for KOMO News, found at

As I understand it, the Walker plaintiffs filed a motion in state court seeking a temporary restraining order and preliminary injunction to prevent Hunter Donaldson from continuing to engage in its collection efforts regarding the invalid and unperfected liens notarized by Rebecca Rohlke and signed by Mr. Wadsworth. I have attached this motion as Exhibit C. I also understand that Hunter Donaldson then immediately removed the case to federal court, delaying that motion. In light of the legal proceedings underwayas to the validity of these Rohlke-notarized liens, such as the one filed against the case of my client, I find it hard to believe that Hunter Donaldson continues to make contact with my office about the lien.

Because there is a very genuine concern about the validity of the lien Hunter Donaldson has filed against the claims brought by my client, I believe thatHunter Donaldson now has a legal and ethical obligation to prove it has followed all the rules and laws of Washington in filing this lien before you contact my office again about collecting any money based on its existence.Pearl v. Greenlee,76 Wn. App. 338, 340, 887 P.2d 405 (1994). Unless and until you make a showing as to the validity of the liens, or until a court resolves the issue as to the validity of the lien, we will not make any payment based upon it. Further, if the lien is, in fact, invalid as it has been described in the Walker lawsuit alleged against you, we ask that you immediately acknowledge this in writing so that my client can avoid further expenses and delay in receiving compensation for their personal injury lawsuit.

Sincerely,

[name]