10 a 42 13 14 15 16 a7 18 19 20 an 22 23 24 25 26 27 28 SUPERIOR COURT, STATE OF WASHINGTON, COUNTY OF SPOKANE CITY OF SPOKANE, a municipal 23 corporation, we2e0l 033- 32 Plaintiff, (AFFIDAVIT OF TIMOTHY MORGAN v. STATE OF WASHINGTON and WASHINGTON STATE DEPARTMENT OF TRANSPORTATION, et al. Defendants. STATE OF WASHINGTON County of Spokane = TIMOTHY MORGAN, being first duly swom upon oath, deposes and says: 1. [state the following based upon my personal knowledge. 2. lamover the age of eighteen, not a party to this lawsuit, and | am competent to testify to the matters set forth below, 3. For 8 months | was a security guard working for CMS down at Camp Hope. Now I work for Revive Counseling and am an FCS Specialist down at Camp Hope. 7 TyndenP: Smithson, iy Attorney ‘AFFIDAVIT OF TIMOTHY MORGAN - 1 Uyaden Seinen. CR Ate '208 W. Spokane Falls Biv ‘Spokane, WA. 99201-3326, (608) 625.6225 FAX (609) 625.627710 a 12 13 aa 15 16 47 18 19 20 21. 22 23 2a 25, 26 27 28 4. have physically seen the following people dealing drugs (blues or methamphetamines) at Camp Hope: Daniel Guy Taylor, Arkansas, Tank, Robert Moody, Wood, Mimi, Jesse, Sarah, Joker, Frisca, Joseph Carson. 5, _ Ihave personally observed the following individuals sell girls off as if they were property: Ted, Shawn, Scooter, Daniel Guy Taylor, New York, Hector, Jayson Crawford. | would call this Human trafficking, and this is occurring at Camp Hope. 6. _ Anumber of people have come up to me and reported that they were either molested or raped in the Camp. Here is a list of the perpetrators of rape and molestation at the camp: Ted, Scooter, Danny, Patrone, Ted, Hector, Joker, Robert Pashon, Joseph Carson. 7. [have observed numerous stolen guns in the WADOT Camp. | do not like this and it terrifies me. | still have empathy for these people and am trying to help {the individuals get out of this environment. 8. Joseph Carson damaged police drone over camp hope. 9. Numerous things have been brought to my attention such as Katrina |Shaw being raped; Robert Moody dealing drugs which Jewels was told about and she stated "Nothing | can do about it.” 10. The South and West gates remain locked 24 hours a day. Julie Garcia ‘stated on the rules about the addendum to do with drugs and then stated publicly to ithe camp she will not enforce it. She also changed the curfew due to “the working girls schedule.” ‘AFFIDAVIT OF TIMOTHY MORGAN - 2 Ten Sion. iy Arey 1208 W. Spokane Falls Blva ‘Spokane, WA” 95207-3328 (608) 625-6225 FAK (509) 625.627710 u a2 43 14 as 16 uw 18 19 20 21 22 23 2a 25 26 27 28 44. Julie Garcia has repetitively told campers to deal with issues however they so see fit, When she is confronted about the violence, and if ts someone she doesn't lke, she lets it slide. 42. The Jewels Helping Hands security has assaulted members of the camp more than two dozen times. They pay the water bill on an adjacent house. ‘There was an assault in which they paid someone to stay quiet about. 43, Matthew Hutchinson has stolen and brought a large amount of stolen vehicles to the camp. 14, Baby Doja was seen on the east wash dot lot with stolen 2018 Toyota Rav 4 and allowed to stay at camp. 45. _ Jason Crawford was responsible for over a dozen assaults knowingly allowed to stay in camp. 46. People have been forcibly removed from camp weather through assault or by jewels illegally towing their campers / fith wheels / rv's off the property. 17. Julie Garcia stated she is trying to get to under 400 people on the lot so she can lock all gates permanently. She also stated that in order to get a tiny home they had to do an assessment and are not allowed to find or acquire shelter elsewhere. 18. People are not allowed to leave if they want. Jewels hasn't rehoused anyone, Revive is responsible for the rehousing. Salvation army, truth ministries and other entities also offer housing, rehab and stabilization 19, | have also collaborated with Fred Meyers, Mobile and Conoco when they come over to camp in regards to thefts because Jewels refuses to believe the MO" - Tynden P. Smithson, Cy Atorney ‘AFFIDAVIT OF TIMOTHY MORGAN - 3 Lyrae P Seiison, Cy Atoey ‘808 W. Spokane Falls Bivd. ‘Spokane, WA 99201-3325, (G03) 625.6225 FAX (509) 625-627710 a 12 13 aa as 16 vv ae 19 20 a1 22 23 24 25 26 27 people in the camp are capable of doing wrong. I hope that this information gives some insight into what's going on at the camp. 20. _ | would like to the victims of these heinous crimes removed to a safer place. I would also like to see the perpetrators held accountable. The only reason they are getting away with these crimes (selling drugs, human trafficking, and rape) is because they live in this lawless Camp. 21. Despite the fence, badges and curfew, the camp is still lawless. There is no fear from anyone here that the camp is going to get shut down. 22. Housing is down to 1% availability in the County and the shelters are all full. | have personally sat down at the TRAC facility with clients for hours and they have not been able to get in because they are full to the brim every night. TIMOTHY MORGAN; sth SUBSCRIBED AND SWORN to before me this 3" "day of December, 2022. Notary Public in and for the State of Washington. My Commission expires 3/3! /2.02o : ‘iynden P. Seithson, Cy Atiomey ‘AFFIDAVIT OF TIMOTHY MORGAN - 4 Lesion Sinan cay Raroey ‘808 W. Spokane Falls Bivd. pokane, WA. 99201-3326, (600) 625-6225 AX (608) 625.6277