1 IN THE STATE OF WASHINGTON
2 DEPARTMENT OF LICENSING - REAL ESTATE APPRAISER SECTION
3 DEPARTMENT OF LICENSING - REAL ESTATE BROKER AND AGENTS SECTION
4 In re the Real Estate Appraiser and Real Estate ) Case No.:
5 Broker Licenses of Thomas O. Cushman: ) COMPLAINT FOR VIOLATIONS OF RCW 18.140
) REAL ESTATE APPRAISER ACT and RCW 18.85
6 George Nervik, a single man, ) REAL ESTATE BROKERS AND SALESPERSONS
) ACT – FRAUD, CONVERSION AND MORAL
7 Complainant, ) TURPITUDE
8 and )
9 Thomas O. Cushman, a Washington State )
10 Appraiser Licensee, )
13 COMPLAINT FOR FRAUD, CONVERSION AND MORAL TURPITUDE
14 1. Complainant hereby formally requests that the Washington State Department of Licensing,
15 Professional and Business Division, Real Estate Section (hereinafter known as “DOL”), launch
16 an immediate and full investigation into the personal and business conduct of Thomas O.
17 Cushman, who is a currently licensed Real Estate Appraiser and Real Estate Broker.
18 2. The Complainant has reason to believe that the Respondent has been conducting an ongoing
19 fraud scheme, as evidenced by the attached Thurston County Superior Court papers relating to
20 Case Number 03-2-30253-5 at Family Justice Center in which Kent Cushman (the
21 Respondent’s 84 year old father) filed against Thomas O. Cushman for acting as his power of
22 attorney after said power had been rescinded and assigned to Ed Holm (now the Thurston
23 County Prosecutor).
24 3. Said fraud, conversion and misappropriations involved real estate, bank accounts and other
25 personal property which did not belong to the Respondent.
Nervik's Complaint Against Cushman’s Real Estate Appraiser License to DOL - 1
1 4. Complainant has confirmed that the Respondent is being actively investigated by Detective
2 Chris Edin of the Thurston County Sheriff's Office under Case Number 03-1579-02.
3 5. Ed Holm, the Thurston County Prosecutor, has properly recused himself and his office from the
4 prosecution and has referred it over to the Pierce County Prosecutor’s Office.
5 PRAYER FOR RELIEF
6 1. Complainant prays that the Washington State Department of Licensing Appraiser Section will
7 acknowledge receipt of this Complaint and inform the Complainant as to the specific
8 investigator and case number assigned so that further information may be forwarded to said
10 2. Complainant prays that the Washington State Department of Licensing Appraiser Section will
11 contact the parties, attorneys and law enforcement investigators already involved so that
12 information can be gained quickly so that the public is not put at further risk by the Respondent
13 due to DOL lack of action.
14 2. Complainant prays that the Washington State Department of Licensing Appraiser Section will
15 make a full and immediate investigation into this complaint against the Respondent, and then
16 upon a finding of fact, impose whatever penalties it deems appropriate.
18 COMPLAINANT INFORMATION:
19 I certify or declare under penalty, under the laws of the State of Washington, that the forgoing is true
20 and accurate. (RCW 9A.72.085)
21 DATED this 26th day of October 2003 at Olympia, Washington
George E. Nervik
24 800 Sleater-Kinney Rd SE - #148
Lacey, Washington 98503-1127
Nervik's Complaint Against Cushman’s Real Estate Appraiser License to DOL - 2