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IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON

In the Matter of 

PAUL LOCKE.

 No. 81405-2-I

 DIVISION ONE

 UNPUBLISHED OPINION

COBURN, J. — Will Knedlik was a co-attorney-in-fact for Paul Locke under 

a January 2016 power of attorney.

1 Knedlik assigns error to a number of orders 

entered by the trial court in connection with its determination that a later power of 

attorney, which appointed Partners In Care (PIC) as Locke’s sole attorney-in-fact, 

was valid. Because Knedlik fails to support his assignments of error with 

meaningful analysis or citations to authority, we affirm.

FACTS

In August 2019, Knedlik filed a complaint against PIC, Crossland Adult 

Family Home (Crossland), and Catherine Person.

2 He also named a number of 

additional “[i]nterested [p]arties,” including Locke; Kaiser Permanente, which 

Knedlik alleged was treating Locke for macular degeneration; and Melrose 

 1 Locke died during the pendency of this appeal. 

2 Knedlik’s complaint was not sworn. In a later court filing, he attempted to 

“verif[y] his pleadings . . . by his signature below.” But verification requires 

attesting to the truth of the matter under oath, which Knedlik did not do. Gates v. 

Port of Kalama, 152 Wn. App. 82, 88, 215 P.3d 983 (2009). 
No. 81405-2-I/2

2

Terrace, the condominium cooperative where Locke’s home was. According to 

his complaint, Knedlik was Locke’s personal friend and, on January 28, 2016, 

was appointed Locke’s co-attorney-in-fact together with Person.

Knedlik alleged in his complaint that after Locke suffered a fall in late 

September 2018 that led to his hospitalization, Person engaged in efforts to 

thwart Locke’s desired return to his Melrose Terrace home. According to 

Knedlik, Person’s efforts culminated with her “physical abduction” of Locke on 

April 29, 2019. Knedlik alleged that Crossland, where Locke was then residing, 

assisted Person with the abduction. Knedlik also alleged that after being 

abducted, Locke appointed PIC as his agent “based upon a unilateral decision 

imposed on [him], through intentional physical duress, as orchestrated by . . . 

Person.” According to Knedlik, Person, Crossland, and PIC subsequently

engaged in a campaign to, among other things, prevent Locke from receiving eye 

injections to treat his macular degeneration, prevent Locke from returning to 

Melrose Terrace, and “isolate him . . . and . . . infantilize him in furtherance of 

their own personal interests, so that he can never move back into his beloved 

home, and so that he continues to pay monthly fees, as a thus blinded cash-cow, 

both to [Crossland] and also to . . . PIC.” 

Knedlik asked the court to “[d]eclare void ab initio and terminate as a 

matter of law” any agency created by Locke in PIC “on or about April 29, 2019,” 

i.e., the date Knedlik alleged Locke was abducted. Knedlik also asked the court 

to terminate Person’s role as co-attorney-in-fact under the January 2016 power 

of attorney that appointed Knedlik and Person as co-attorneys-in-fact. 
No. 81405-2-I/3

3

A short time after Knedlik filed his August 2019 complaint, PIC filed, under

a separate action (PIC’s confirmation action), a petition to confirm the validity of a 

later power of attorney dated May 8, 2019, under which Locke had appointed PIC 

as his sole attorney-in-fact. PIC supported its petition with a declaration from 

Locke’s attorney, Barbara Isenhour. 

According to Isenhour, she began assisting Locke with his estate planning 

in 2016. Locke brought Knedlik and Person to his initial meeting with Isenhour, 

during which Locke explained that he was 89 years old and had never executed 

a will or power of attorney. During the meeting, Locke, who had no living family 

members, agreed that a will was important to ensure that his substantial estate 

went to support policy issues that were important to him. Locke also agreed that 

it was important to have a power of attorney to designate an agent to help him if 

he became incapacitated. Locke asked Knedlik and Person if they were willing 

to serve as his agents. They indicated they were, and Isenhour prepared a 

power of attorney, which Locke signed. 

Isenhour declared that in late 2018, Person called her to let her know that 

she had found Locke unconscious in his condominium after suffering a fall. 

There was substantial loss of blood from the fall, and when he arrived at 

Harborview, Locke was dehydrated and malnourished. Eventually, Locke was 

discharged to a nursing home, and Person then located an adult family home, 

Crossland, where Locke continued to reside at all times relevant herein.

According to Isenhour, in early April 2019, Knedlik emailed her copies of 

several exchanges with Crossland’s owner in which Knedlik raised complaints 
No. 81405-2-I/4

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with the quality of the care Crossland was providing. Isenhour declared that

“[e]ach exchange with [Crossland] escalated in terms of the aggressive tone from 

Mr. Knedlik.” Isenhour declared that on April 9, 2019, she met with Knedlik and 

Person to discuss Knedlik’s concerns about Locke’s care at Crossland. 

According to Isenhour, “[t]he meeting was very acrimonious between Mr. Knedlik 

and Ms. Person, as Mr. Knedlik expressed his anger at Ms. Person for not being 

more supportive of a plan for Mr. Locke to return to his condominium.” Isenhour 

declared that after the meeting, there was a more conciliatory exchange between 

Knedlik and Person in which they agreed that Locke should retain a case 

management agency to investigate whether it was feasible for Locke to return 

home. However, “a few days later, Mr. Knedlik’s emails and written 

memorandums started again, but now Mr. Knedlik directed his anger at both the 

owner of [Crossland] and Ms. Person.” 

Isenhour declared that “[b]ecause of the increasing breakdown in the coagent relationship” between Knedlik and Person, Isenhour set up an appointment 

to meet with Locke on April 29, 2019 (i.e., the day that Knedlik alleged Locke was 

abducted). She declared that at the meeting, “Locke told me that he did not want 

Mr. Knedlik to continue to serve as his agent” and that Locke “was concerned 

that Mr. Knedlik had his checkbook and he wanted to be sure his care at 

[Crossland] was paid promptly.” According to Isenhour, 

[Locke] was also unhappy about the negative interactions between 

Mr. Knedlik and the [Crossland] staff and owner and Mr. Knedlik’s 

negativity with Ms. Person. Mr. Locke knew that Ms. Person did not 

have the time because of her job to serve as his sole agent so I 

encouraged Mr. Locke to consider naming a professional fiduciary 

as his agent in place of Mr. Knedlik and Ms. Person. I gave Mr. 
No. 81405-2-I/5

5

Locke the names of professional fiduciaries to consider and 

explained that any professional agent would charge fees for the 

services they provided. I also assured Mr. Locke that any agent he 

hired could help him implement a care plan to return to his 

condominium if that was Mr. Locke’s choice.

On May 8, 2019, Isenhour met with Locke, Person, and a representative 

from Aging Wisdom, the company that had been retained to assess the feasibility 

of Locke’s returning to his condominium. According to Isenhour, the Aging 

Wisdom representative reviewed with Locke what it would cost for him to return 

home and have caregivers assist him there. Isenhour declared that the 

representative also offered to assist Locke to find a different adult family home if 

that was his concern, but Locke said he was happy with Crossland if he was not 

able to return home. Isenhour declared that “[e]veryone at the meeting assured 

Mr. Locke that he had sufficient resources to return to live in his condominium, 

but the costs would be considerably more than what Mr. Locke was currently 

paying for care.” 

After the meeting, Isenhour met with Locke “to discuss the change he 

wanted to make to his estate plan to have a professional fiduciary replace Mr. 

Knedlik and Ms. Person in his power of attorney and his Will.” According to

Isenhour, Locke had met with a representative from PIC the week before, and 

wanted to name PIC as his fiduciary. Isenhour declared that in her opinion, 

Locke had the mental capacity to execute a new power of attorney and will 

naming PIC as his agent:

I spent a substantial amount of time reviewing these changes with 

Mr. Locke. In my opinion he had the mental capacity to execute a 

new power of attorney and Will, naming [PIC] as his agent. No 

other changes were made to either document. Mr. Locke was clear
No. 81405-2-I/6

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about what he wanted and the reasons for making these changes. 

Mr. Locke did not want to get involved in disputes Mr. Knedlik was 

generating with other people who were helping Mr. Locke; Mr. 

Locke did not want Mr. Knedlik threatening to withhold payment for 

the care Mr. Locke was receiving at [Crossland]; and Mr. Locke did 

not want to side with Mr. Knedlik in Mr. Knedlik’s disputes with Ms. 

Person. When I reviewed the revised documents with Mr. Locke, I 

had no concern that Mr. Locke’s decision was involuntary or that he 

was being pressured by Ms. Person or the owner of [Crossland] to 

make this change against Mr. Locke’s wishes.

PIC also supported its petition with a declaration from Stephe NewellNiggemeyer, PIC’s financial manager. Newell-Niggemeyer declared that Knedlik 

had called the police on Crossland several times and also “induced Mr. Locke’s 

health care providers to report [PIC] and . . . Crossland . . . to Adult Protective 

Services (‘APS’).” Newell-Niggemeyer declared that APS interviewed Locke and 

investigated Crossland. An APS “Investigation Summary Report” attached as an 

exhibit to Newell-Niggemeyer’s declaration indicated, with regard to allegations 

that Crossland had not taken Locke to his eye injection appointments, “In 

interview with [Locke] and others [Locke] clearly stated he did not want to attend 

any more appointments for eye injections. Record review documented [Locke] 

had told several individuals he did not want to go to the appointments.” The 

report indicated further that the investigator did not identify any failed provider 

practice or write a citation as a result of the investigation. 

In its petition requesting that the court confirm the validity of the May 2019 

power of attorney appointing PIC, PIC also requested that the court (1) conclude 

that Knedlik lacked standing and was engaging in the unauthorized practice of 

law by maintaining his lawsuit, (2) consolidate Knedlik’s lawsuit with PIC’s 

confirmation action, (3) award PIC its fees and costs, (4) order Knedlik to 
No. 81405-2-I/7

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produce an accounting given an assertion in Knedlik’s complaint that he had 

removed cash from Locke’s condominium and deposited it into Knedlik’s 

personal bank account for safekeeping, and (5) enter an order restraining Knedlik 

from filing additional lawsuits against anyone assisting Locke without prior court 

approval. PIC asserted that Knedlik “is a disbarred former attorney and 

vexatious litigant,” citing excerpts from Knedlik’s Washington State Bar 

Association discipline notice and other legal proceedings in which Knedlik had 

been admonished for filing frivolous litigation intended to harass third-parties.3 

In October 2019, the trial court, through a commissioner, held a hearing 

on PIC’s petition. After entertaining argument from both parties, the court made 

an oral ruling “that the case argued . . . by Mr. Knedlik looking out for the welfare 

of Mr. Locke is frivolous, vexatious, and an attempt to harass the named 

Defendants.” The court indicated that it would enter an order “reminding Mr. 

Knedlik that the presentation of such a case . . . constitutes the unlawful practice 

 3 Knedlik does not dispute that he was disbarred in 2000. In In re Knedlik, 

the Bankruptcy Appellate Panel of the Ninth Circuit (BAP) affirmed the 

Bankruptcy Court’s sua sponte decision to (1) dismiss an involuntary bankruptcy 

petition, filed against Knedlik by his mother, as a collusive, “sham” filing intended 

to circumvent an earlier order barring Knedlik from filing any further bankruptcy 

petitions without prior court approval and (2) refer the matter to the U.S. Attorney 

for criminal investigation of bankruptcy abuse. Nos. WW-08-1011-KuKJu, 07-

15547, 2008 WL 8444815, at 1 (9th Cir. B.A.P. June 30, 2008). In so doing, the 

BAP took note that Knedlik’s litigation history included filing an involuntary 

bankruptcy petition against a company “on the eve of a public stock offering, as 

part of a negotiating strategy and in violation of a court injunction. Id. at 1. The 

BAP also took note that in the litigation that resulted from that filing, “the trial 

court characterized Knedlik’s conduct as malicious and found ‘Knedlik’s conduct 

is beyond the Court’s comprehension, and the Court has never seen a more 

outrageous course of conduct in all the time that the Court has sat on the 

bench.’ ” Id. 
No. 81405-2-I/8

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of law.” The court also ruled that it was “clear” that the power of attorney 

appointing PIC was valid and that the allegations in Knedlik’s complaint did not 

raise “any question . . . at all about the validity of the power of attorney.” After 

the hearing, the court entered an order (1) consolidating Knedlik’s lawsuit with 

PIC’s confirmation action, (2) declaring the May 2019 power of attorney valid and 

effective, (3) dismissing the claims in Knedlik’s complaint, (4) awarding PIC its 

fees and costs, (5) ordering Knedlik to produce an accounting of transactions 

made on Locke’s behalf, and (6) restraining Knedlik from initiating, without prior 

written court approval, litigation against Locke, PIC, Person, Crossland, their 

attorneys, “and any other person assisting . . . Locke” without court approval. 

The court also entered an “Order Re: Unauthorized Practice of Law” stating, “Mr. 

Knedlik’s complaint is one on behalf of Mr. Locke. Mr. Knedlik is not a licensed 

attorney and therefore has no standing to file this action. The case is a frivolous 

and vexatious attempt to harass all named defendants.” 

Knedlik subsequently moved for reconsideration of both orders. The trial 

court denied reconsideration. Later, the court fixed the amount of PIC’s feesand-costs award at $40,118.71. Knedlik appealed directly to the Washington 

State Supreme Court, which transferred the appeal to this court. 

DISCUSSION

As a pro se litigant, Knedlik is held to the same standard as an attorney 

and must comply with all procedural rules on appeal. In re Marriage of Olson, 69 

Wn. App. 621, 626, 850 P.2d 527 (1993). Among these rules is RAP 10.3(a)(6), 

under which an appellant must provide “argument in support of the issues 
No. 81405-2-I/9

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presented for review, together with citations to legal authority and references to 

relevant parts of the record.” Failure to support assignments of error with legal 

arguments precludes review; so may failure to comply with procedural rules. 

Howell v. Spokane & Inland Empire Blood Bank, 117 Wn.2d 619, 624, 818 P.2d 

1056 (1991); State v. Marintorres, 93 Wn. App. 442, 452, 969 P.2d 501 (1999). 

Similarly, arguments that are not supported by references to the record, 

meaningful analysis, or citation to pertinent authority need not be considered. 

Cowiche Canyon Conservancy v. Bosley, 118 Wn.2d 801, 809, 828 P.2d 549 

(1992).

Here, Knedlik requests “reversals of every order entered by the trial court.”

But he fails to support his assignments of error with meaningful analysis or 

citations to pertinent legal authority. Under the authorities cited above, this 

failure dooms Knedlik’s appeal. 

Furthermore, the thrust of Knedlik’s argument on appeal is that the trial 

court erred by confirming the validity of the May 2019 power of attorney and 

granting the other relief requested by PIC without (1) conducting an in-court 

examination of Locke under RCW 74.34.135 or (2) taking into account that 

Knedlik was immune from liability under RCW 74.34.050 and entitled to 

indemnity under the January 2016 power of attorney. But RCW 74.34.135

applies only when a petition for a vulnerable adult protection order (VAPO 

petition) is filed, see RCW 74.34.135(1), and nothing in the record reflects that 

Knedlik filed a VAPO petition. Knedlik suggests the trial court should have 

treated his lawsuit as a VAPO petition, but he cites no authority for the 
No. 81405-2-I/10

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proposition that the court was required to do so—particularly where Knedlik’s 

complaint did not satisfy several of the applicable procedural requirements. See, 

e.g., RCW 74.34.110(2) (“A petition shall allege that the petitioner, or person on 

whose behalf the petition is brought, is a vulnerable adult.”); RCW 74.34.110(3)

(“A petition shall be accompanied by affidavit made under oath, or a declaration 

signed under penalty of perjury, stating specific facts and circumstances which 

demonstrate the need for the relief sought.”); RCW 74.34.115(1) (requiring that 

“standard petition . . . forms must be used . . . for all petitions filed . . . under this 

chapter”).4 

Similarly, Knedlik is not immune from liability under RCW 74.34.050. That 

statute provides, “A person participating in good faith in making a report under 

this chapter or testifying about alleged abuse, neglect, abandonment, financial 

exploitation, or self-neglect of a vulnerable adult in a judicial or administrative 

proceeding under this chapter is immune from liability resulting from the report or 

testimony.” RCW 74.34.050(1) (emphasis added). Knedlik’s lawsuit was not a 

good faith report as contemplated by that statute. See RCW 74.34.035 (setting 

forth circumstances under which reports must and may be made to the 

department of social and health services and/or to law enforcement agencies). 

And, Knedlik did not provide any testimony in a proceeding under RCW chapter 

74.34. RCW 74.34.050 does not immunize Knedlik from liability. 

Finally, Knedlik does not cite any authority to persuade us the trial court 

 4 Knedlik asserts in his opening brief that he twice requested the standard 

forms but was not provided them. App. Br. at 12. But Knedlik does not support 

this assertion with citation to the record.
No. 81405-2-I/11

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erred in confirming the validity of the May 2019 power of attorney, and that power 

of attorney revoked all earlier powers of attorney. Therefore, Knedlik, who filed 

his complaint in August 2019, was not entitled to indemnity under the January 

2016 power of attorney. Additionally, the January 2016 power of attorney 

indemnifies the attorney-in-fact from liability only “for acts done for [Locke] in 

good faith,” and the trial court’s unchallenged finding that Knedlik’s lawsuit was “a 

frivolous and vexatious attempt to harass all named defendants” implies that 

Knedlik did not act in good faith. Cf. Fuller v. Emp. Sec. Dep’t, 52 Wn. App. 603, 

605, 762 P.2d 367 (1988) (unchallenged findings of fact are verities on appeal); 

RAP 10.3(g) (requiring parties to make “[a] separate assignment of error for each 

finding of fact a party contends was improperly made”). 

In short, Knedlik fails to cite to authority or provide meaningful analysis in 

support of his assignments of error. This failure alone is fatal to his appeal. 

Nevertheless, Knedlik also fails to persuade us that the trial court was required to 

conduct an in-court examination under RCW 74.34.135 before granting the relief 

requested by PIC or that he is entitled to liability immunity or indemnity. Any 

additional arguments raised by Knedlik—who not only fails to cite authority and 

provide meaningful analysis but whose briefs consist largely of nearly 

incomprehensible run-on sentences—are not sufficiently briefed to warrant 

consideration. Cf. Norcon Builders, LLC v. GMP Homes VG, LLC, 161 Wn. App. 

474, 486, 254 P.3d 835 (2011) (appellate court “will not consider an inadequately 

briefed argument”); U.S. v. Dunkel, 927 F.2d 955, 956 (7th Cir. 1991) (“Judges 

are not like pigs, hunting for truffles buried in briefs.”). 
No. 81405-2-I/12

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FEES ON APPEAL

PIC requests fees on appeal. It cites a number of statutes and rules as 

the basis for its request, but it provides argument only with regard to RCW 

11.125.200(3). That statute sets forth the circumstances under which a person 

must accept an acknowledged power of attorney and provides, “A person that 

refuses in violation of this section to accept an acknowledged power of attorney 

is subject to . . . [l]iability for reasonable attorneys’ fees and costs incurred in any 

action or proceeding that confirms the validity of the power of attorney.” RCW 

11.125.200(3)(b). 

It is undisputed that the May 2019 power of attorney appointing PIC was 

acknowledged. Furthermore, despite the fact that both PIC and the trial court

also relied on RCW 11.125.200(3) with regard to the award of fees and costs 

below, Knedlik does not dispute the applicability of RCW 11.125.200(3)(b) in 

either his opening or his reply brief. Therefore, we grant PIC’s requests for fees 

and costs on appeal under RCW 11.125.200(3)(b). 

We affirm.

WE CONCUR: