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This section is prepared for attorneys representing affected owners. It gathers the exhibits, statutes, procedural posture, and remedies in one place. It is a working aid, not legal advice, and does not create an attorney–client relationship.
1. Case posture at a glance
New — this is an organized commercial enterprise, not three lone
filers. Public WA Secretary of State records show Gold Dust Title Company, LLC (UBI
605 800 985; formed 03/20/2025; sole governor Douglas Shroyer; Langley principal
office) whose website markets and sells the land-patent model — “Land Patent
Research,” quitclaim-deed preparation, “County Auditor Legal Filings,” an
“in-house notary,” a “title insurance bypass,” escrow, and online payments.
Its registered agent is Ballard Law Group (partner John Scott Hicks, who shares the name
of the notary #194569 on the deeds). This materially expands the available theories — counsel to
evaluate:
- Criminal profiteering / pattern — RCW 9A.82 (an enterprise + a pattern of the predicate offenses; civil recovery under RCW 9A.82.100, incl. treble-style penalties up to $250,000, costs and fees).
- Consumer Protection Act — RCW 19.86 (an unfair/deceptive commercial practice sold to the public; private and AG enforcement).
- Unlawful operation as a “title company” / escrow & unauthorized practice — offering “title,” “escrow,” and “paralegal-level document preparation” without the required licensure (title insurers/agents: Title 48 RCW; escrow: RCW 18.44; UPL).
- Professional responsibility (attorney/notary) — if the registered-agent attorney also notarized the instruments, potential WSBA/RPC and notary-misconduct (RCW 42.45) exposure — refer to the WSBA and DOL.
- Additional victims — a commercial seller implies other paying clients/filings statewide; consider subpoenaing the company’s payment processor and client records.
2. Exhibit index (hyperlinked)
| Ex. | Instrument / item | Recorded | Document | Machine text |
|---|---|---|---|---|
| A-1 | Schermer Quitclaim Deed INVALID (Sec 4 & Lot 1 Sec 5, T29N R3E) | 04/01/2025 | #4583924.pdf | OCR |
| A-2 | Ingalls Quitclaim Deed INVALID (Secs 32/33, T30N R3E) | 04/01/2025 | #4583923.pdf | OCR |
| A-3 | Shroyer Quitclaim Deed INVALID (Secs 29/32/33, T30N R3E) | 02/27/2025 | #4582708.pdf | OCR |
| B-1 | Shroyer Notice | 02/24/2025 | #4582592.pdf | OCR |
| B-2 | Shroyer Notice | 02/27/2025 | #4582709.pdf | OCR |
| B-3 | Shroyer Declaration | 04/01/2025 | #4583915.pdf | OCR |
| B-4 | Ingalls Notice | 04/02/2025 | #4583965.pdf | OCR |
| B-5 | Ingalls Declaration | 05/02/2025 | #4585251.pdf | OCR |
| B-6 | Schermer Notice | 04/02/2025 | #4583966.pdf | OCR |
| B-7 | Schermer Declaration | 05/02/2025 | #4585252.pdf | OCR |
| C-1 | Verified identifiers (filers) | — | memo | — |
| C-2 | Public-records OSINT & King County property | — | memo | — |
| C-3 | Notary verification (Hicks #194569) | — | memo | — |
| D-1 | Cloud analysis — subject parcels | — | memo | — |
| D-2 | Strategy — securing legal/court documents | — | memo | — |
| D-3 | Court background findings | — | memo | — |
| D-4 | Scheme scope / completeness | — | memo | — |
| E-1 | Chain of custody (all captures, SHA-256) | — | log | — |
| E-2 | Affected parcels & owners (data) | — | CSV | — |
| E-3 | Perpetrators’ full recording footprint (data) | — | CSV | — |
| F-1 | Gold Dust Title Company, LLC — public records & website summary | — | page | golddusttitle.com |
| F-2 | Ballard Law Group / John Scott Hicks (registered agent; notary) | — | page | firm bio |
3. Statutes, penalties & potential causes of action (counsel to confirm; illustrative)
How Washington penalties work. The maximums below are the statutory caps under
RCW 9A.20.021 (Class A felony: life / $50,000; Class B: 10 yrs / $20,000; Class C: 5 yrs /
$10,000; gross misdemeanor: 364 days / $5,000) unless a statute sets its own limit. An actual
sentence is set within the standard range under the Sentencing Reform Act (offender score and offense
seriousness); a fraudulent scheme can support one count per instrument or parcel, and counts may
run consecutively.
Criminal exposure (for the investigation)
- RCW 40.16.030 — knowingly procuring or offering a false or forged instrument to be filed, registered, or recorded. Class C felony — up to 5 years in prison and/or a $5,000 fine (statute-specified fine cap).
- RCW 9A.60.020 — forgery: making, or possessing/uttering, a written instrument known to be forged, with intent to injure or defraud. Class C felony — up to 5 years in prison and/or a $10,000 fine.
- RCW 9A.60.030 — obtaining a signature by deception or duress. Class C felony — up to 5 years in prison and/or a $10,000 fine.
- RCW 9.38.020 — maliciously or fraudulently filing an instrument or putting forward a claim that transfers, encumbers, or clouds another person’s title to real property (directly on point here). Gross misdemeanor — up to 364 days in jail and/or a $5,000 fine.
- RCW 9A.82.080 — using proceeds of, or acquiring an interest in real property through, a pattern of criminal profiteering (if a pattern across the filings is established). Class B felony — up to 10 years in prison and/or a $20,000 fine (conspiracy or attempt is a Class C felony).
Civil remedies & recoveries (for owners)
- Quiet title — RCW 7.28 (establish clear title against the invalid deeds).
- Declaratory judgment — RCW 7.24 (declare the deeds void).
- Slander of title — actual damages for the wrongful recorded cloud (lost sale/financing and clearance costs), plus potential attorney’s fees.
- Civil criminal-profiteering action — RCW 9A.82.100: recovery of damages, costs, and reasonable investigative and attorney’s fees; a court may also impose a civil penalty up to $250,000. Civil recovery runs in addition to the criminal penalties at left.
- Removal of unauthorized/fraudulent instrument; lis pendens management.
- Title-insurance claim — tender the cloud to the owner’s policy for defense/clearance.
The deeds are void on their face: a grantor cannot convey an interest they never
held, and a “land patent” does not divest existing record owners. The
“Bagnell v. Broderick,” “U.S. v. Stone,” and “Collins v. Bartlett”
citations in the deeds are misapplied. (Counsel to confirm all statutory citations and current law.)
4. Quiet-title / LAR roadmap
- Order certified copies of #4583924, #4583923, #4582708 (and supporting filings) from the Auditor.
- Coordinate with the County LAR (Prosecutor via Auditor) to avoid duplicative litigation.
- Confirm each affected parcel’s exposure with the title company’s plat examiner (Government Lot 1 / Section 4 overlay — see Ex. D-1).
- File quiet-title / declaratory action (or join the County action) naming the filers; record the resulting judgment against each affected parcel.
- Tender title-insurance claims; obtain the written underwriting position for the damages record.
5. Damages & title-insurance angle
The concrete, present harm is impaired marketability/insurability: underwriters are declining to insure area transactions until the cloud is removed. Owners should open owner’s title-policy claims and obtain the written denial/exception — this both documents damages for the criminal/civil matters and triggers the insurer’s duty to defend/clear where covered.
6. Key contacts
Open the full strategy memo All documents & data Print this section