Postal Regulatory Commission Submitted 12/7/2018 11:49:38 AM Filing ID: 107344 Accepted 12/7/2018 1 2 3 4 5 BEFORE THE POSTAL REGULATORY COMMISSION 6 WASHINGTON, D.C. 7 RANDALL EHRLICH, Docket No.: C2019-1 8 Complainant. DECLARATION OF ADAM P. KARP 9 10 I, ADAM P. KARP, being over 18, of sound mind, and having personal knowledge, 11 declare under penalty of perjury under the laws of the United States that the following is true and 12 correct: 13 1. I am counsel for complainant Randall Ehrlich. 14 15 2. In the course of my investigation into Tonya Voisine and the Ballard Postal 16 Annex’s abuse of various postal customers on Voisine’s route, I have uncovered the following true 17 copies of statements and documentary evidence acquired through public disclosure, which clearly 18 show that the mistreatment of Mr. Ehrlich states not a singular grievance, but is of broad duration 19 or several residences on her route. 20 3. The first victim of Voisine of the BPA is Peggy Hougardy, a retired private 21 investigator. See Declaration of Peggy Hougardy (KARP 1-6) and Complaint, Paras. 10-23. 22 4. Other victims include Erika and Mark Middlebrooks of 707 NW 58th St., whose 23 statements are attached as KARP 7-10, and supported by neighbors Jeanne McGrady (KARP 27), 24 Urban Waite and Karen Leung-Waite (KARP 11-12). 25 KARP DECLARATION - 1 A NIMAL L AW O FFICES OF ADAM P. KARP, ESQ. 114 W. Magnolia St., Ste. 400-104 Bellingham, WA 98225 (888) 430-0001 Facsimile: (866) 652-3832 [email protected] 5. More victims include Wendy Hamal Redding and Tracy N. Redding of 5505 6th 1 Ave. NW (KARP 13-18), India Ornelas of 5832 7th Ave. NW (KARP 19), Jeremiah Winghart of 2 707 NW 58th St. #2 (KARP 20), Jim Ratti of 5818 7th Ave. NW (KARP 21-22), Valerie Capon 3 th th 4 and Ryota Akamine of 5827 7 Ave. NW (KARP 23-24), Kimberly Arrow of 5509 6 Ave. NW th 5 (KARP 25-26), Matthew Leonard of 5811 6 Ave. NW (KARP 27-28), Melissa Flynn of 5706 6 and 5708 8th Ave. NW (KARP 29), and David and Jacqui Barnes of 5621 6th Ave. NW (KARP 7 30-31). 8 6. Stacia Valley was told by Voisine that if all people with dogs did not follow the 9 rules, she would stop delivering to the entire block. KARP 32. 10 7. Another victim who was assaulted by Voisine requested anonymity due to fear of 11 retaliation. I attach this person’s statement but redacted personal identifying information. Yet, I 12 am prepared to submit an unredacted version under seal for the Commission’s eyes only (not 13 USPS). I do this out of respect for the witness coupled with striving to meet the Commission’s 14 extended deadline (which was one third of that originally requested) and not having adequate time 15 16 to contact this person for further authorization. See KARP 33-34. 17 8. On August 8, 2017, I submitted a public records request to Seattle Animal Control 18 requesting all records pertaining to any complaint concerning Randall Ehrlich of 5833 7th Ave. 19 NW, Seattle. No records were found per KARP 35-36, thus contradicting USPS’s claim that there 20 was any history of complaints to animal control concerning Mr. Ehrlich’s dog. 21 9. On November 11, 2017, I spoke with Heather Coles of 5700 8th Ave. NW. She 22 rented from 2013-2014 and explained that the elderly man who shared her duplex did not get mail 23 due to Voisine’s refusal to deliver, not because Ms. Coles or her immediate neighbor had a dog, 24 but because their immediate neighbor, Daniel Berglund of 5620 8th Ave. NW, did. Ms. Coles spoke 25 KARP DECLARATION - 2 A NIMAL L AW O FFICES OF ADAM P. KARP, ESQ. 114 W. Magnolia St., Ste. 400-104 Bellingham, WA 98225 (888) 430-0001 Facsimile: (866) 652-3832 [email protected] to Voisine, who explained she was almost attacked by a vicious dog from Mr. Berglund’s residence 1 and, as a result, refused to deliver mail to him or me for a ridiculously long period of time. She 2 often went to the postal annex and argued what seemed like for an eternity (the better part of a 3 4 year) to restore mail delivery. She suffered anxiety to pick up mail at the BPA, knowing it would 5 always be a huge confrontation and nothing would happen and sometimes she would be placed on 6 hold indefinitely, only to have someone pickup and then hang up the phone on her moments later. 7 She described it as torture. She never had a dog and described Voisine as unhinged. The only 8 reason mail resumed was after news coverage in 2016 addressing various complaints by 9 individuals such as Mark Middlebrooks. The news pieces may be watched at King 5 from May 11, 10 2016 (https://www.king5.com/article/news/local/seattle/no-mail-delivery-in-seattle- 11 neighborhood-for-3-years/281-185128503) and Jun. 3, 2016 12 (https://www.king5.com/article/news/local/more-complaints-about-no-mail-delivery-in- 13 ballard/229523633). Text from those pages are attached as KARP 37-41. 14 10. As part of my further investigation, and speaking on the explicit condition of 15 16 anonymity, a confidential informant at BPA quite familiar with Voisine explained that Voisine is 17 not only regarded as mentally ill by her peers but, in addition to her intimidation of postal 18 customers like Mr. Ehrlich, she has also done violence to fellow postal workers, including the 19 commission of such acts as property destruction, harassment, and physical assault and battery. I 20 also learned that John Bell was the subject of an EEOC complaint by Voisine and her partner 21 Wylice Temple (co-worker at BPA) and that, since then, he was not permitted to even talk to them. 22 Being on eggshells, as it were, he is clearly biased in their favor with respect to Mr. Ehrlich’s 23 complaint. On information and belief, Ms. Temple has falsified information on Voisine’s route to 24 favor Voisine. As part of discovery Mr. Ehrlich wanted to seek in federal court, and hopes to seek 25 KARP DECLARATION - 3 A NIMAL L AW O FFICES OF ADAM P. KARP, ESQ. 114 W. Magnolia St., Ste. 400-104 Bellingham, WA 98225 (888) 430-0001 Facsimile: (866) 652-3832 [email protected] here, I intend to send requests for production to USPS for BPA’s Route Safety Files, Employee 1 Files, Floor Files, and Union Grievances related to Voisine and hereby put USPS on notice that a 2 litigation hold remains in place and no such documents should be tampered with or destroyed. 3 4 11. Mr. Ehrlich’s experience is certainly not isolated. The corruption of BPA runs deep 5 and executive oversight by the PRC is the only recourse Ballard residents may invoke to rectify 6 this longstanding defect in agency governance. 7 Executed this December 7, 2018 in the city of Seattle, Wash. 8 _________________________________ 9 Adam P. Karp 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 KARP DECLARATION - 4 A NIMAL L AW O FFICES OF ADAM P. KARP, ESQ. 114 W. Magnolia St., Ste. 400-104 Bellingham, WA 98225 (888) 430-0001 Facsimile: (866) 652-3832 [email protected] Superior Court of Washington County of Case No: TBD TBD No. Petitioner(s), and Declaration of TBD Peoov Houoardv Respondent(s). [Name] (Optional Use) DC This declaration is made by: Name Peegv Houeardv Age: 65 Relationship to the parties in this action: TBD I Declare: On Monday ,7"'1y24,2017 at approximately 3: l5pm I was walking in my neighborhood. As I walked west on NW 56th St from 3rd Ave NW I encountered the local mail carrier for that area, Tonja Voisine. I know Tonja from previous delivery issues with her in2004 and 2005, after which she rvas disciplined and reh'ained. She no longer delivers to my address. As I passed Tonja on NW 56th St, no words were exchanged. After she went back to het USPS van, which was parked illegally facing west on the sattlrside of the street, I took a photo of her to memorialize the event time. Tonja then drove west and while she was driving she stopped at the intersection of 4th Ave NW and NW 56th St. While she was driving the USPS van, she took a photo of me. I've attached 3 photos as proof of this declaration. Declaration (DCLR) - Page 1of !- KARP 000001 (Attach Additional Pages if Necessary and Number Them.) 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