Other LanguagesJosephine Townsend faces up to 90 days in jail for allegedly forging court order
VANCOUVER — Attorney General Bob Ferguson’s office has filed felony criminal charges against a Clark County defense attorney who is accused of forging a court order to deceive law enforcement and prevent her client’s arrest.
The Attorney General’s Office charged Josephine Townsend in Clark County Superior Court with two counts of forgery. The criminal charges stem from an attempted arrest of one of Townsend’s clients for violating an anti-harassment order. Townsend sent her client what she claimed was an amended version of the court order, which was supposed to prove to arresting officers that he had not violated it. Law enforcement later determined the document was forged. It had never been submitted to or signed by the court, despite having the court’s stamp and signature, according to the affidavit of probable cause. The client said he had never seen the amended document, which included a declaration with his signature. The declaration had two misspellings of his name — including the signature — and an incorrect date of birth.
If convicted, Townsend faces up to 90 days in jail and up to $5,000 in fines.
Assistant Attorney General Jaime V. Taft is handling the case for Washington.
The affidavit of probable cause filed with the court yesterday is included in its entirety below. The details contained in the affidavit of probable cause are only allegations. A person is presumed innocent unless and until the individual is proven guilty beyond a reasonable doubt in a court of law.
The Attorney General’s Office does not have authority to initiate criminal prosecutions, unless it receives and accepts a referral from a county prosecutor or the governor. The Attorney General’s office accepted a referral from Clark County.
The Rules of Professional Conduct govern what a prosecutor in a criminal case may say publicly before trial. As the prosecutor in this criminal matter, the Attorney General’s Office and its representatives are prohibited from making public statements beyond the narrow scope allowed by the Rules of Professional Conduct. The office will make every effort to be transparent with the public, while upholding its responsibilities as a criminal prosecutor.
Affidavit of Probable Cause
I, Detective Sergeant Jayson Camp, of the Clark County Sheriff’s Office, declare that I conducted the foregoing investigation and determined that Josephine C. Townsend, born 11 February 1960, did commit the crime of Forgery, in violation of RCW 9A.60.020, on or about 17 July 2024, in Clark County, WA.
Investigation Summary: On 24 July 2024, I was contacted by Sergeant Mark Anderson of the Clark County Sheriff’s Office who forwarded a report to me documented under CCSO Case 24005888. In summary, Sergeant Anderson had been presented with a court order he was unable to authenticate. I was requested to investigate the matter in my official capacity as a Detective Sergeant for the Clark County Sheriff’s Office Special Victims Unit.
On 07 December 2023, Travon Santiago was arrested by the Vancouver Police Department and booked into the Clark County Jail for crimes which included Assault in the first degree. The date of the violation was 25 November 2023. The alleged victim in that case was Joseph Prendergrast. The Superior Court cause number for that case is 23-1-02902-06. A criminal no contact order was issued in that case, restraining Travon Santiago from coming within 1,000 feet of Joseph Prendergrast or his residence, as well as requiring Travon Santiago to submit to GPS monitoring. This criminal no contact order was filed with the Clark County Clerk’s Office on 08 December 2023 under the same cause number. Josephine Townsend was appointed to represent Travon Santiago in this case.
On November 29, 2023, Angela Foss, who is Joseph Prendergrast’s significant other, petitioned the court for a civil order for protection restraining both Travon Santiago and his partner, Nicole Eagle, from Angela Foss and her children. That petition resulted in the issuance of a Superior Court Order for Protection under cause number 23-2-09215-06. The order was issued on 08 January 2024 and was personally served to Travon Santiago by a Clark County Sheriff’s Deputy on the same day. That order restrains Travon Santiago from coming or remaining within 5,000 feet of Angela Foss and/or her children.
On Dember 20, 2023, Nicole Eagle filed a motion objecting to being included in the protection order under 23-2-09215-06. In a January 5, 2024, hearing, Commissioner Sasser granted Ms. Eagle’s request and removed her as a restrained party.
On 25 April 2024, the Court issued an order amending the conditions of Travon Santiago’s release. This order modified the proximity restriction in the criminal no contact order, Cause No. 23-1-02902-06, from 1,000 feet to 500 feet. The reason for this modification is the fact that Mr. Santiago’s residence is approximately 1,065 feet from Mr. Prendergrast’s residence; thus, Mr. Santiago would violate the protection order merely accessing his own residence. The Honorable Superior Court Judge Suzan L. Clark signed this order electronically on 25 April 2024 at 12:09:37 hours. The order was filed electronically with the Clark County Clerk’s Office on the same day at 13:14 hours.
As of the 25th of April, Travon Santiago was no longer at risk of violating the modified criminal no contact order; however, the civil protection order which restrained Travon Santiago from coming within 5,000 feet of Angela Foss or her residence was never modified. Ms. Foss resides with Mr. Prendergrast and, as such, Travon Santiago’s presence at his own residence would place him in violation of the Clark County Superior Court Order for Protection under Cause No. 23-2-09215-06. In my later review of the video of the April 25, 2024, hearing, I confirmed that Judge Suzan Clark made it clear her distance modification only impacted the criminal order, and Santiago would have to return to court on the civil matter. Mr. Santiago and Ms. Townsend were both present at this hearing.
July 17, 2024: at approximately 1839 hours, Clark County Sheriff’s Deputies responded to a 9-1-1 call which was placed by Angela Foss reporting a violation of the civil protection order as she reported to have observed Travon Santiago near the Safeway located at 408 NE 81st St in Vancouver, Clark County, WA, which is just over a thousand feet from Angela Foss’s residence.
Deputies responded and accessed the online GPS monitoring system where they observed Travon Santiago was at his residence in Vancouver, Clark County, WA. This placed Travon Santiago within the 5,000 feet restriction on the civil protection order. Deputies went to that apartment where Travon Santiago answered the door and refused to exit after being advised he was under arrest for violating the protection order.
According to the written reports of Deputy Dennis Zhiryada, Deputy Alex Martinez, and Sergeant Mark Anderson of the Clark County Sheriff’s Office, documented under CCSO Case 24005888, Travon Santiago and his significant other, Nicole Eagle, were uncooperative with law enforcement and Nicole Eagle had presented the Deputies with a document claiming the civil protection order had been modified. The Deputies noted that the document which Nicole presented to them bore a cause number which differed from the order protecting Angela Foss. The Deputies documented in their reports that they observed Nicole Eagle on the phone, speaking with Josephine Townsend, while they were present.
The Deputies ultimately left the scene and Nicole Eagle called and requested to speak with a supervisor. Sergeant Mark Anderson called Nicole Eagle, and she informed him that Travon’s attorney, Josephine Townsend, had sent her an order showing the civil protection order had been modified. Nicole emailed the document to Sergeant Anderson, who observed it bore the correct cause number (23-2-09215-06), along with the electronic signature of Judge Suzan L. Clark and the electronic filing stamp of County Clerk Scott G. Weber.
Sergeant Anderson contacted Clark County Sheriff’s Office Records who were unable to locate a record of the modified civil protection order which Sergeant Anderson had received from Nicole Eagle. The Records Unit further contacted the Clark County Superior Court Clerk’s Office who were also unable to locate any record of such an order. The Clerk’s Office did, however, locate a motion to modify the civil protection order, which was filed on the morning of 18 July 2024, one day after Mr. Santiago’s attempted arrest. Suspecting he had been presented with a forged document, Sergeant Anderson referred this case to me.
Upon reviewing the case reports and multimedia attachments, I learned the foregoing and I reviewed the motion to modify the protection order under Cause No. 23-2-09215-06, which was filed electronically by Josephine Townsend on 18 July 2024 at 0908 hours. I also reviewed an Order Modifying Protection Order under Cause No. 23-2-09215-06. That order bore Judge Suzan L. Clark’s electronic signature, as well as Clark County Clerk Scott Weber’s electronic filing stamp, both of which bore clear indications of having been forged – which I will explain in detail later – and a date of 25 April 2024. The obvious immediate concern was the fact that the amended order Ms. Townsend provided was signed by the court about three months before the motion for the order was ever even filed on July 18, 2024.
On the afternoon of 04 September 2024, I called Nicole Eagle and spoke with her by phone. I identified myself and informed her I was looking to clear up the confusion with the court order situation involving Travon. Nicole confirmed for me that Josephine Townsend had emailed her the order which she had sent to Sergeant Anderson. Nicole forwarded me the same email.
I observed the original email was sent from josie@jctownsend.com on 17 July 2024 at 20:35 hours to ms.nicoleeagle@gmail.com. The subject line of the email read “modified order.” There was no content in the body of the email, other than the signature line which read “Josephine C. Townsend Esq.” The order was attached to the email as a.pdf document which was titled “modified order.pdf.”
During our phone conversation, Ms. Eagle told me she had been frustrated with law enforcement responding to arrest Travon because she and Travon had been assured the protection orders had been modified so that Travon could be at home. Ms. Eagle told me if I watched the Body Worn Camera video it would show her on the phone with Josephine Townsend. Nicole Eagle stated Josephine sent her the email containing the court order which she presented to Sergeant Anderson. Ms. Eagle stated to me on the phone that she had been frustrated with Ms. Townsend because Ms. Eagle felt like it took “forever” for Ms. Townsend to send the order to her. By Ms. Eagle’s recollection, the police had arrived around 6:30 or 7:00pm and Ms. Townsend didn’t send her the order to show the police until “almost 9.”
Ms. Eagle further indicated she had a text message conversation with Ms. Townsend later that night, related to the order. She later sent me a screenshot of part of that conversation, via email. In reviewing the screenshot, I observed the following:
The conversation is with a contact saved as “JT” with a first name displayed: “Josie.” Ms. Eagle later sent me a screenshot of the contact in her phone. The full name is “Josie Townsends Cell” and the phone number is (360) 903-0812. The top message in the text message conversation is from Nicole Eagle and it reads, “I didn’t get an email yet.”
At 2250 hours on 17 July 2024, Nicole Eagle sent: “Hey josie thanks for helping I spoke with sergeant mark Anderson and forwarded the paperwork you sent however they are saying they don’t see it filed with the court so he’s working with records on it and asked if you could please call or email him all I have is his email he said you might have his number.” Ms. Eagle then sent Sergeant Anderson’s email address.
The response read: “Sure, I did not see it in the court records either, so I am setting a court date to make sure it gets into the system.”
During my conversation with Nicole Eagle, it appeared to me that she and Travon Santiago were unaware that Ms. Townsend had filed the motion to modify the order on 18 July 2024. I sent Nicole a photo of the typed narrative portion of the order. On both the signature line and printed name line were the typed name “Trevon Santiago” after a perjury clause.
When I asked Nicole if Travon wrote that, she replied, “No.” I then advised his signature was on the document and I received a reply of “I did not write that,” twice in a row. The next day, Travon sent me a text message from Nicole’s phone which included, “The documents with my signature I did not write and as you can see, I did not sign them nor did I electronically sign them because my name is spelled incorrectly.”
This statement stood out to me because I had observed something in the court filings related to criminal cause No. 23-2-02902-06: the very top document, Journal of Criminal Minute Entries, contained a handwritten note at the bottom which read: “Defendant states name is spelled “Travon.” It appeared that Mr. Santiago had frequent experience with his name being misspelled with an “E” where should be an “A” and that it was important to him that his name be spelled correctly.
On the morning of 05 September 2024, I contacted Clark County Clerk Scott Weber by phone and requested to meet with him and review the court filings related to this case. He provided me with complete copies of all the filings for both Cause Numbers in this matter: 23-2-09215-06 (the civil protection order protecting Angela Foss from Travon Santiago) and 23-1-02902-06 (the criminal no contact order protecting Joseph Prendergrast from Travon Santiago). In reviewing both complete filing records, I quickly determined that no records had been filed in the civil case 23-2-09215-06 (protecting Angela Foss) on or about 25 April 2024.
Mr. Weber brought me to meet with one of his employees, Chelsea Olver, who explained to me how the electronic filing process works. In short, the system automatically tracks who uploaded a record to the electronic filing system. This is based on specific users being granted access through a unique login which includes a password known only to the user. The system automatically stamps the top of the record with an “e-file” log which shows the name of the folder or user which/whom filed the record. At the same time, the software automatically stamps the top left corner of the top page of the record with the number of pages contained in the record. These will only appear when a document is electronically filed. Otherwise, the top of the record will bear a handwritten note from the employee who received the file, along with the number of pages handwritten at the top left of the record if the record is filed in person.
If a document or record is electronically filed with the Clerk’s Office, it will bear an electronic stamp from the Clerk’s Office with the date and time of the filing, along with the two aforementioned marks. The following is an example of such from this case:
Note the number “1” in the top left, which indicates the number of pages in the document. The “EFILE” log at the top, showing Judge Suzan Clark filed the document, and the Clerk’s electronic filing stamp. This example is from the order modifying the criminal no contact order under Cause No. 23-1-02902-06. A true and correct copy of the modified criminal no contact order is attached hereto as Exhibit 1.
The order which Nicole Eagle sent to me and stated she received from Josephine Townsend bears a Clerk’s E-File stamp; however, it lacks the EFILE log and the page count. This indicates that the E-File stamp was forged onto the document and that it was not actually E-Filed. See below:
Next, I noted the Clerk’s electronic filing stamp was identical between the two orders. The same date and time are displayed. Furthermore, the valid criminal no contact order contains a vertical line on the right side of the pleading paper. This line passes through the Clerk’s e-file stamp, between the “1” and the “4” of the time and between the “L” and the “E” in “Clerk.” There is no vertical line on the forged civil protection order; however, the forged Clerk’s stamp contains the exact same line. The stamp appears to have been cropped from the valid order and pasted onto the forged order. It further bears evidence of having been edited. A closer look shows that it appears the vertical line was erased above the time stamp and below the word “Clerk” and that the erasing removed part of the bottom of the “E” in “Clerk.” See below:
Finally, I compared the Court’s signature between the two documents. They are identical. The valid criminal no contact order bears Judge Suzan L. Clark’s electronic signature, affixed at 12:09:37 on 25 April 2024. The forged civil protection order also bears Judge Suzan L. Clark’s electronic signature, affixed at 12:09:37 on 25 April 2024. I do not believe it possible for Judge Clark to have electronically signed two completely separate orders at the exact same second. In fact, in my later review of the April 25, 2024, criminal order modification hearing, Judge Clark specifically states that Santiago will have to go back to court on the civil protection order. A true and correct copy of the modified civil protection order Ms. Townsend emailed Ms. Eagle on July 17, 2024 is attached hereto as Exhibit 2.
Valid Order:
Forged Order:
I contacted Judge Clark’s Judicial Assistant on 05 September 2024 and requested a meeting with Judge Clark. I met with Her Honor in chambers the same morning and presented her with the order which I suspected to have been forged. Judge Clark confirmed she had never seen the modified civil protection order, nor did she sign it. Her Honor added that she would never have signed the order, regardless, since she had never seen a motion for the order.
This is when I contacted Judge Clark’s judicial assistant once more and requested a copy of the recording of the April 25, 2024, criminal no contact order modification hearing referred to above. I reviewed the recorded hearing on 06 September 2024.
Based on what I learned in my investigation, I believe Josephine Townsend received a modification for one of two protection orders on behalf of her client. Ms. Townsend was contacted by her client on the night of 17 July 2024 who advised Ms. Townsend that law enforcement had arrived to arrest her client for violating the unmodified civil protection order. I believe Ms. Townsend then forged an order modifying the civil protection order (23-2-09215-06) and emailed it to her client to present to law enforcement and thus evade arrest by deception. Evidence in support is the email forwarded to me from Nicole Eagle, originating from Josephine Townsend, along with text messages from Josephine Townsend confirming the civil protection order (23-2-09215-06) alluded to in her email did not exist within court records and that she would schedule a hearing on the matter. Court records show that Josephine Townsend then filed a motion to modify that same civil protection order the very next morning, on 18 July 2024. In filing the motion, I believe Josephine Townsend forged her client’s signature without his knowledge or consent. This is supported by the fact Travon is misspelled as “Trevon” on both the signature and printed name lines.
On the evening of September 4, 2024, Ms. Townsend began contacting me, directly, via email. Her initial email stated, “I am not sure what is going on with the client. But here is what We have on the file.” The email was from josie@jctownsend.com, the same email address which Nicole Eagle had forwarded to me with the modified protection order (23-2-09215-06). The email contained two attachments: one was the order modifying the criminal order (23-1-02902-06) to 500ft and the other was the motion to modify the protection order (23-2-09215-06) Ms. Townsend had filed on 18 July 2024.
I responded to Ms. Townsend by forwarding the email Nicole Eagle had sent me, along with the attachment, and stating: “Ms. Townsend, Thank you for reaching out. Could you please confirm for me whether you sent Ms. Eagle the below email with the included attachment?” Ms. Townsend did not respond to this email.
Ms. Townsend emailed me again on 06 September 2024. Her email read as follows:
“I had to call the WSBA on what I could or could not say on this case. I was advised I could say this. Nichole Eagle and client provided documents to our office that they asked us to scan. Those documents were not created by our office and our office advised both of them that some of the documents provided we did not see in the court system and advised that they needed to go to civil court on the order they were seeking. They came in together. I was asked to submit a statement and attachments for Mr. Santiago regarding his civil matter, which we did and he e-signed. The statement submitted to the court for the civil matter was indeed the statement and declaration of Mr. Santiago. Under RPC 1.6 I have moved to withdraw from his cases.”
I replied to Ms. Townsend, and asked again that she confirm the validity of the July 17, 2024 email forwarded by Ms. Eagle, I also asked her to confirm that the declaration filed with the July 18, 2024 motion to modify the protection order (23-2-09215-06) was signed by Travon and whether or not Ms. Townsend would be willing to share any documents provided by him and Ms. Eagle. I authored and applied for a search warrant for Google records related to the email forwarded me by Nicole Eagle.
On 09 September 2024 at 1534 hours, I received an email from Josephine Townsend in response to my email above. Her email read: “See below. I am somewhat limited by our rules as to what I can say.”
Ms. Townsend confirmed the validity of the July 17, 2024 email with the modified civil protection order attached as follows: “Yes, however, I was asked to scan documents given to me by Both Ms. Eagle and Mr. Santiago and I advised her on the phone I was not familiar with this order, and that the only order I was familiar with, was the criminal order we obtained in court. My paralegal Kait Ramey was working with me that night and heard my end of the conversation if you need to interview her. Given that several months had gone by since I obtained the criminal order, I was confused because I had not seen any orders on the civil side and I had not represented him on that case. In April he said that he planned to hire me for the civil matter but that did not occur. He came in with Ms Eagle and gave me the statements, the 911 call she had made on the alleged victim, pictures they had, and pictures we had in discovery and other documents; we prepared his statement, but he did not hire me so the statement sat on my desk until that call on the 17th. that night he asked me to file it. I did the next day as he requested. I did not cite anything on to be heard because again, I am only appointed on the criminal case and they both were advised that I would file a notice of appearance SOLEY to file his statement for him unless he hired me for the civil matter.”
Ms. Townsend confirmed that Travon Santiago wrote the declaration attached to the July 18, 2024, motion to modify the civil protection order as follows: “Yes, see above. Ms. Eagle and Santiago came to my office, I cannot confirm the date, but his GPS would show him at my office the day he gave the statement or completed the statement. It has been too long for me to say which because we discussed it on the phone, I wrote it for him, they brought documents which I attached but he did not physically sign it that day. When the incident happened on the 17th, I reminded both of them that I was only aware of the criminal order, not any civil order, that as far as I knew there was no civil order signed but they insisted there was one in the documents in the file and they asked me to scan it to them. When we talked to them on the phone I told them, I was confused because I looked in the system and the order was not there. I looked because I wanted to download it from ONBASE for them if it existed. I told them that I did not think the order they wanted scanned was correct because they had to have a civil hearing on it and I did not do one, and I did not see the order in the system Mr. Santiago tried to tell me that I had promised him that I would do it for him and I told him that was impossible as he had not hired me to do it and he had to appear in person for it. Our conversation was not long, I scanned the document and emailed it to them. I remember thinking something was not right, or I was losing my mind (we have a lot of cases and are buried with work) The next day, I filed the NOA, and the statement he authored. I did not cite it on because then I never heard from him again, and he did not again hire me to cite it on for a hearing. I am limited again as to what I can say, but I can say I did confront him about if was he lying to you that he needed to tell the truth. As a result of our conversation and what he said to me, I have filed motions to withdraw on his cases which should be heard next week as our dockets are closed this week. Under Rule 1.6 of our attorney rules, I am not allowed to go further.”
Finally, Ms. Townsend responded to my request for verification of documents received from Travon and Ms. Eagle by stating she contacted the Bar association for guidance on what she could and could not say. She would only state that her office did not obtain any orders in the civil matter and that they were provided with several documents by Ms. Eagle and Mr. Santiago over time. “I called the bar association to get their opinion on what I can and cannot do. Because attorneys are required to keep their client’s secrets even if they confess things to us about their activities, we are bound to keep them. We cannot take their information that we know is untruthful and use it in a case however, as we cannot suborn perjury. Even though I will no longer be on his case, the most I can say is that our office did not obtain any orders in the civil matter, only the criminal matter and that we were provided several documents by Ms. Eagle and Mr. Santiago over time in support of the cases. I never met with either of them alone, and I cannot say which or both of them gave us the documents.”
On September 9, 2024, my search warrant application for Google records was approved by the Honorable Judge Robert A. Lewis of the Clark County Superior Court. I served the search warrant to Google by uploading it to my secure Google Law Enforcement Request System. Google confirmed receipt of the search warrant at 1119 hours.
I reviewed the email which Ms. Townsend had previously sent me, in which she provided a copy of the statement she claims is from Mr. Santiago. See below:
I opened the Word document and reviewed the document’s properties:
And I observed the document had been created by Josephine Townsend, who was the author. The document had last been printed on 17 July 2024 at 2151 hours, and that the document had last been modified at 2220 hours on the same date:
A review of a Microsoft forum revealed that a document can be printed and then later saved again using the “save as” function which will modify the created date and time to reflect the most recent save in a new location despite not erasing the metadata related to the printing of the original file. This indicates that the original document could have been created at any time prior to 17 July 2024 at 2151 hours. This data does not reflect anything which would contradict Ms. Townsend’s statements that she and Mr. Santiago worked on the statement together, in person, or that he provided her the statement over the phone, and she wrote it for him.
Based on Ms. Townsend’s suggestion to review Mr. Santiago’s GPS records, I accessed Intellitrack to review Mr. Santiago’s ankle monitor location history to discern when he visited Ms. Townsend’s office. Townsend Law is listed as being located at 1920 Broadway St in Vancouver, Clark County, WA.
The system is not particularly user-friendly, I had to search, day-by-day, in two-hour time blocks (the system only allows for up to 180 data points to be viewed at once - one trace point is generated per minute) from 01 July 2024 through 18 July 2024 for the hours of 0800-1800. Travon Santiago was never located at 1920 Broadway St during that time.
I reviewed Ms. Townsend’s email again and located a point where she indicated Mr. Santiago and Ms. Eagle had come to her office in April. I finally located Mr. Santiago’s historical presence at 1920 Broadway St. This occurred on 25 April 2024 from approximately 1018 – 1037 hours:
Ms. Townsend’s email indicates she and Travon Santiago worked on the statement for the motion one single time and that the matter was not brought up again until 17 July 2024.
It is possible that Ms. Townsend and Mr. Santiago worked on drafting the motion on 25 April 2024. Mr. Santiago claimed he did not write the statement, nor did he sign the motion (citing the misspelling of his name). In her September 9, 2024, email, Ms. Townsend indicated Mr. Santiago did not physically sign the motion on the day that he came to her office: “I cannot confirm the date, but his GPS would show him at my office the day he gave the statement or completed the statement. It has been too long for me to say which because we discussed it on the phone, I wrote it for him, they brought documents which I attached but he did not physically sign it that day. When the incident happened on the 17th, I reminded both of them that I was only aware of the criminal order, not any civil order, that as far as I knew there was no civil order signed but they insisted there was one in the documents in the file, and they asked me to scan it to them.”
Based on this, I believe Ms. Townsend affixed Travon Santiago’s signature to the motion without his knowledge or consent and that an arbitrary date was placed next to the signature. It is certain that Mr. Santiago was not at Ms. Townsend’s office on 07 July 2024, nor any day in the month of July 2024, which is the date the signature is indicated to have been placed. His signature and printed name are both spelled incorrectly; however, his name is spelled correctly at the top of the document, where he is listed as the respondent in the case. Mr. Santiago’s birth date is also incorrectly listed as “9/26/27.”
On 10 September 2024 at approximately 1300 hours, I met with Nicole Eagle and Travon Santiago at the Vancouver Public Library. This contact was recorded on my Body Worn Camera; the following is a summary:
I advised Nicole Eagle that Ms. Townsend told me in an email that Nicole and Travon had brought the document to Ms. Townsend’s office and that, on 17 July 2024, Nicole had asked Ms. Townsend to scan the document and send it back to Nicole. Ms. Eagle adamantly denied this. Nicole went on to describe Ms. Townsend as mostly absent and noncommunicative in her representation of Travon. Both Nicole and Travon told me Travon tried to have Ms. Townsend removed from his case and replaced with a new attorney.
They further informed me that, after Travon was released from jail, he did not come home for fear of violating his restraining orders. Travon repeatedly contacted Ms. Townsend and asked for guidance on how to go about getting the orders modified so that he could be home. Ms. Eagle allowed me to review her text messages with Ms. Townsend in order to show me this. In reviewing the text messages, I observed the following, which are merely a few examples of Travon Santiago’s efforts to abide by the conditions of his release:
10 April 2024 at 2327 hours: “Ok thank you my job is wanting me to start back as soon as I can work this distance thing out because there turn over rate is real bad and I’m trying to get back to work as soon as I can they need all the help the can get and I got to get my money together and my life together I’m trying to change my life and be a better man thank you again.”
Followed by: “Also this monitor is stuck on green I’m tryna stay on top of this and do things the right way so I’m just letting you know I got pictures of it I’m gonna call and email 2watch and Lisa in the AM”
11 April 2024 at 1403 hours: “Hey josie sorry to bother I know your super busy but I am trying to fix these things my job is waiting on me hand and foot I’m tryna make money DoorDashing on the side and can’t even go certain places I’m spending money on rooms because I can’t go home my fiancé is needing help with the girls at home and I’m tryna to be patient and stay out of trouble and do things the right way but I got to handle this so I can help my home and get to work so I can be a better man and person to the community I just want to know if there’s any updates please”
Followed by: “I don’t mean to keep on bothering but my chef is ready for me to get to work and back to being a Saute cook and on my way to prepare for being an actual chef can I please get some help resolving this please I’m really needing help please”
Ms. Townsend responded, “I know and I have contacted judges assistant every day” and “she is waiting on the god damned prosecutor to get back to her”
Travon replied: “Ok [emoticon] oh man I hope I’m not upsetting you” and “I’m just trying to stay on top of these things to stay out of trouble get back to work and go home and take care of these kids”
The hearing for the criminal protection order took place on the afternoon of 24 April 2024. The order modifying the distance to 500ft was signed by Judge Clark on 25 April 2024.
After the hearing on the 24th, Travon sent the following text message to Ms. Townsend: “Hey thank you for all your help so far honestly I’m sorry if I ever came off any type of way I apologize sincerely I really do.” Later that evening, Ms. Townsend responded with: “No worries at all now I’ll set a motion on your civil case for you”
Travon replied: “Is the civil case the protection order they didn’t allow me to attend the court date too? Also when will I be allowed to go to my home sorry for all the questions I’m just trying to do things the right way and stay on top of everything” and “And also thank you for that as well.” Ms. Townsend did not reply.
On the morning of 25 April, Travon Santiago sent Josephine Townsend the following text message:
“Do you think I’m going to be able to go home today?”
She replied: “As far as the gps yes I should have that order today for you to take to them” and “I have to schedule the civil hearing and will file that today as well”
Travon responded: “Ok thank you I’ll swing by your office here in a bit to grab them and should I contact with two watch just in case because if I go home and say something happens I just want them to know and to already have adjusted the range for me”
At 1138 hours, Travon sent: “Hey so I took the papers to Lisa my pre-trial officer and she said those won’t work that they have to be a signed paper from a judge and the order so I was wondering how long is that going to take because I thought it was already done my fault again I don’t mean to bother”
At 1545 hours, Travon sent: “Do you think that order is going to get signed today or tomorrow.” At 1654 hours, Ms. Townsend replied, “I have it!” and “I emailed to Nichole.” Travon responded, “Can you send it to Lisa and thank you” and “Never mind I see you already cc to everyone.” Ms. Townsend: “I did.” Travon: “Ok appreciate it thanks for all your help.”
On 02 May 2023 at 1205 hours, Travon Santiago sent Ms. Townsend the following text message: “Hey josie sorry to bother just touching base checking in everything’s been going still working still trying to fix and do things better and the right way and was curious about that civil matter and to what’s going on haven’t heard anything and I’m just not trying to seem content or complacent because I still want to do things better and figure all this out and stay out of trouble.”
Ms. Townsend responded: “I’m getting it cited on docket.” Travon replied, “Ok cool just wanted to see where things were at.”
On 23 May 2024 at 1208 hours, Travon sent: “Hey josie Travon Santiago just checking in on things seeing where we’re at also I know you said you were working on that protection order for me it’s been awhile just wanting to see if any things happening.” Ms. Townsend did not reply.
On 29 May 2024 at 1207 hours, Travon sent: “Hey.” Ms. Townsend did not respond.
As I spoke with Nicole Eagle and Travon Santiago, they both told me they were constantly trying to get updates from Ms. Townsend regarding the protection orders. They both told me that they interpreted Ms. Townsend’s text message saying, “as far at the gps yes,” in response to Travon asking if he could go home, to mean that Travon was allowed to be at his house and that the matter was being resolved.
According to the text message conversation, Ms. Townsend was the one who offered to file the motion and cite the hearing to modify the civil protection order, numerous times, in fact. There was no discussion in the texts of Mr. Santiago hiring Ms. Townsend to represent him in the civil case.
Ms. Eagle addressed this during our conversation. She said to me, “I don’t remember if they said the civil thing needed to be handled at that time, because the way Josie put it was, ‘Yes, you can go home now. It’s fine for you to go home.’ And she said that she was going to try to get him some sort of court date to talk about because he wasn’t present at the civil order. She never said that because of that order, he couldn’t go home. She just said, ‘Yes, you can go home, based on the GPS, and I’ll be putting in a motion to—umm—not amend, but, she said, like a motion to talk about the civil case…”
I pointed to the motion which Ms. Townsend had filed on 18 July 2024 and said, “That’s what this is.” Ms. Eagle replied, “But he [Travon] never said any of these things.” I said, “So, she said that she was going to do this—” and Ms. Eagle stated, “In May.” I asked, “But you guys never met with her to go through the steps?” Ms. Eagle said, “No, she continued from May all the way up until the police showed up. ‘I’m putting in an order to have this looked at for the civil order’ was basically along the lines of what she was saying. She had been saying that since May. Not one time did she ever tell him directly, ‘Hey, you need to go and put in a motion to amend this.’ Do you know how long it took us to do that? 10 minutes. We went up to the courthouse, they told us exactly what to do, and we got a court date. So, why from May until the day they showed up at my door Josie couldn’t communicate that properly, I’m not sure. Because there was continual times where we would text her and say, ‘Hey, is there a court date set for this? Hey, is there a court date set for this?’”
Ms. Eagle continued, “But we were under the impression, due to what she said, that yes, he could be at our address because it had been amended. So that’s kind of what was going on. I don’t know if it was just miscommunication or what was going on. But, that’s kind of where we’re at. And she never had a chance to ask him anything because she never met with him on the phone nor in person until within the last few weeks, and it was on a Sunday or a Saturday and both my children were with us and we went in there and met with her in person.”
Nicole checked her phone and told me that Sunday, August 18th, 2024 at two o’clock was the first time Travon had ever met with Josephine Townsend and spoke with her in person.
I showed Travon the motion which Ms. Townsend had filed, containing the statement which Ms. Townsend claimed she and Travon wrote together and bearing Travon’s signature. I told Travon that Ms. Townsend said he had come to her office in person to write the statement, and that she had spoken with him on the phone to help him write it. I told him I confirmed his ankle monitor had been located at Ms. Townsend’s office for about 20 minutes the day the criminal order modification was signed.
Travon said, “I didn’t talk to her one time.” I asked, “You didn’t speak with Josie in person?” Travon responded, “We spoke with her—the day, or around the time when I first got out—I spoke with her paralegal or the lady who was the front office. That’s why we were there for around 20 minutes, because, for a good long period of time, I haven’t had any contact with her. So, like I said, I didn’t write this.”
I clarified, “So, you didn’t talk to Josie on the phone and you guys didn’t plan out this statement to be written?” Travon answered, “No, because to my knowledge, all this was already handled. That’s why if I knew I wasn’t supposed to be there, I wouldn’t have been over there. That’s the reason why I kept saying, ‘Hey, is this good? Is this good?’ I kept trying to check in with her, ‘Am I good? I’m just trying to do the right thing.’ I told her this on numerous occasions.”
Travon went on to say, “I have no reason to lie to you people is what I was trying to tell her from the beginning. This whole thing from the beginning has not been properly handled. I’ve been getting misinformation. Why would I write this if I have a document, from you, saying that this was already handled by a judge? Think about it. I’m not gonna do that. I’m not a stupid person. This is basically saying that I knew I wasn’t supposed to be there.”
I asked Travon to review the statement. He read it and, as he did so, he said, “Yeah, see, no, no, no, no. She never told me it was the criminal matter. She made it seem like it was all one thing being handled at once. Travon Santiago then stated to me, “No. I did not sign this and I did not give her my consent to use my signature.” Later, I told Nicole Eagle and Travon Santiago that I assumed neither of them knew how to file court documents. They both confirmed my assumption to be true. I asked them if either of them knew what kind of stamps go where and what gets applied by the Clerk’s Office and what gets affixed by the court. They both stated the did not know these things. I said to them, “So, you probably wouldn’t know which things to crop from one document and put on the other to make it look legitimate.” They both answered, “No.” I asked them if they know what a Clerk’s Stamp is and they both responded in the negative. I asked them if they know where the Clerk’s Stamp goes on a document and they both responded in the negative. Nicole Eagle stated, “All I know how to do is go in there to the little window and tell them, ‘Hey, this is the shit I need today. Where do I go?”
I provided Ms. Eagle and Mr. Santiago each with written statement forms, to include perjury clauses. They both provided written statements, which they gave to me after signing under penalty of perjury. I explained the perjury clauses to each of them and neither expressed any issue or confusion.
On 17 September 2024, I responded to Ms. Townsend’s September 9, 2024, email. I relayed my understanding as follows, and asked her to confirm:
- Mr. Santiago was the respondent in two protection orders: a criminal order under cause no. 23-1- 02902-06, and a civil order under cause no. 23-2-09215-06.
- The court granted a modification to the criminal order, reducing the distance to 500ft, on April 25th of this year.
- After the modification to the criminal order, Mr. Santiago and Ms. Eagle brought some documents to your office and asked you to scan them.
- On July 17th of this year, Ms. Eagle called you to let you know law enforcement had come to her residence to arrest Mr. Santiago for violating the protection order. She asked you to scan one of the documents she gave you and send it to her.
- You collected a document, which was an order modifying the civil order to a 500ft distance and bearing the Clerk’s E-file Stamp and Judge Clark’s e-signature, and you told Ms. Eagle you were not familiar with the order – you were only familiar with the modification to the criminal order.
- You checked ONBASE and saw there was no order in the court records modifying the civil protection order. You thought the document was incorrect and you scanned the document and emailed it to Ms. Eagle.
- Mr. Santiago then asked you to file the motion to modify the civil order, in an effort to legally obtain the very document you had just scanned and emailed to Ms. Eagle, and you did so the next day.
On 23 September 2024 at 2245 hours, I received a response from Josephine Townsend as follows:
“For the most part yes. I do have text messages on the conversation as well. When I was asked to send them the document, I told them that I had not seen it before and I did not think it was valid- they should not be using it for anything- I told them very specifically I was not aware of any civil order modifying the distance and I had not been hired to file anything in the civil case. I was asked if I would file his statement which was his statement, his words and his request - the next day and I said I would – because I told them that I did not believe them that the civil order had been modified and I had not been hired to do that.
I am having my paralegal who was with me that night of the 17th prepare a declaration as well. I am offended that you would think I would forge a document for anyone, let alone a criminal client that I do not know.”
On 19 September 2024, I received notification from Google, Inc. that the production files in response to the search warrant in this case were available for download. A letter from Google along with an accompanying certificate of authenticity, signed by Brant Hudgins on 19 September 2024, and a list of the folder names and hash files for the records provided by Google.
I downloaded the file and opened the folder titled “Mail” and located a file titled “All mail Including Spam and Trash.” I found the file to contain the metadata for the contents of the email account during the specified time range. There was a single email, which was identical to the email which Nicole Eagle had forwarded to me from Josephine Townsend. It contained an attachment, titled “modified order.pdf” which I also viewed and observed to be the allegedly forged court order. Ultimately, I determined the metadata revealed the forged court order had, in fact, originated from the email account josie@jctownsed.com and was sent to ms.nicoleeagle@gmail.com on 17 July 2024 at 2035 hours.
I printed and attached the letter from Google, along with the aforementioned email and attachment, to a Return to the search warrant. I filed the completed Return with the Clark County Clerk’s Office.
Each of the files in the list had an associated “zip” file which contained the metadata for each item in the list. Most of the files contained a single message which read “There are no responsive records.” There were several files which listed Nicole Eagle as the subscriber for the account, along with some activity; however, the primary data I received was for the single email referenced. I uploaded the data to an external storage device which I logged into evidence.
On 24 September 2024, I responded to Ms. Townsend’s most recent email. I repeated my request for documents and asked if she could provide the texts she referenced.
I contacted Nicole Eagle once more and requested she send me screenshots from her phone showing the phone call logs between her and Ms. Townsend on 17 July 2024. Ms. Eagle did so, and I observed the following:
Three screenshots displaying call logs with the phone number (360) 903-0812 and the contact name “Josie Townsends Cell” for the date of 17 July 2024. There were 28 consecutive phone calls listed as “outgoing call” or “canceled call” between the hours of 1925 and 2001 on that date. At 2004 hours, Nicole Eagle received an incoming call from Josephine Townsend which lasted 17 minutes. A second incoming call was received at 2035 hours which lasted 3 minutes.
On 24 September 2024 at 1850 hours, I received another email from Josephine Townsend that stated:. “Here are the text messages where he admitted to me he was lying to you and my direction to him that he needed to tell the truth. We also spoke on the phone. Ms. Ramey will have her declaration done by tomorrow.”
The email contained 23 photos attached to it. The photos were all screenshots from Ms. Townsend’s phone, displaying a text message conversation with Nicole Eagle’s phone.
I reviewed all 23 photos and observed they displayed the conversation which took place after Nicole Eagle and Travon Santiago contacted Josephine Townsend to advise her I had contacted them, on or about 04 September 2024. I reviewed the photos in a side-by-side comparison to the photos I had taken of the same conversation displayed on Nicole Eagle’s phone. I discovered the two to be completely identical.
On 25 September 2024 at 1117 hours, I received an email from Roxana Manesh of The Vern McCray Law Firm. The email contained a Letter of Representation, addressed to me and the Washington State Attorney General’s Office Criminal Justice Division. I responded to the email and attached a pdf document containing the email correspondence between myself and Ms. Townsend from the previous weeks. I also asked Ms. Manesh for assistance in obtaining the original allegedly forged documents from her client.
When I attached the email string to this email, I began to skim through it. As I did so, I noticed something which I previously missed. It was an email which Ms. Townsend sent to Senior Deputy Prosecuting Attorney Dan Gasperino on 04 September 2024 at 1706 hours, which included me as a carbon copy, Ms. Townsend wrote:
“This was his statement on 7/7 which was electronically filed for him at his request and a copy of the modification order on the criminal matter.”
In this email, Ms. Townsend reaffirmed her assertion that Travon Santiago had either come to her office in person or spoke with her by phone and provided her that statement to write on 07 July 2024. I had already confirmed that Travon Santiago’s GPS monitor showed he was never at Ms. Townsend’s office on that date. I contacted Ms. Eagle once more and requested she look through her phone for any text messages or phone calls with Ms. Townsend on 07 July 2024.
Ms. Eagle sent me two photos: one was a screenshot of her phone call log from 06–08 July 2024. The other was her text messages with Josephine Townsend from 06-08 July 2024. I observed there were no text messages with Josephine Townsend on Nicole Eagle’s phone on 07 July 2024. There were also no phone calls with Josephine Townsend on that date. Nicole Eagle and Travon Santiago share one phone. They both use the same phone to make calls and send and receive text messages. Josephine Townsend confirmed later that she only ever communicated with either of the two through the same phone number. Thus, I determined that Travon Santiago did not provide Ms. Townsend with any statement on 07 July 2024, in person or by telephone.
Detective Sergeant Fred Neiman and I interviewed Josephine Townsend at her office at 1920 Broadway on 10 October 2024 at 1500 hours. Present in person were Ms. Townsend’s attorneys, Vernon McCray and Roxana Manesh. Present by Zoom were Assistant Attorney General Jaime Taft and Thomas Foley, representing Kate Ramey, Josephine Townsend’s legal assistant.
The interview was recorded by my Body Worn Camera, as well as Ms. Townsend’s audio recorder. All parties present consented to the recordings prior to the recordings starting; however, I believe I neglected to inform Ms. Taft or Mr. Foley that the conversation was being recorded once they joined the Zoom meeting. I did, however, request everyone verbally identify themselves for the purpose of voice identification. Thus, I believe everyone knew the conversation was being recorded.
The following is a summary of Ms. Townsend’s statements during the interview:
Ms. Townsend claimed that Travon Santiago requested her assistance in modifying the civil protection order after the modification to the criminal order was granted. Ms. Townsend indicated she told him she would help him, but only if he paid to retain her services on the matter. I confronted Ms. Townsend with the April-May, 2024, text messages showing the contrary – that she had actually offered and promised numerous times that she was taking care of the civil order and getting it cited on for a hearing. Ms. Townsend told me these text messages lacked context because they were related to an in-person conversation wherein she added the part about “only if you pay me.”
Ms. Townsend claimed Nicole Eagle and Travon Santiago had brought documents to her office, which were kept in some capacity. Ms. Townsend said she did not get to the documents until the night of 17 July, when Nicole Eagle called her and asked her to send the civil order modification. Ms. Townsend claimed she told Nicole Eagle that no such document existed, but that Ms. Eagle told her to go through the files on her desk. Ms. Townsend said she located the forged order and recognized it to not be a valid document. She claimed she confronted Nicole Eagle, raising her voice, and saying, “Where did you get this? You cannot use this. You’re going to get yourself in trouble.”
Now, this stood out to me because I had previously requested the original document which Ms. Townsend claimed had been brought to her office by Ms. Eagle and Mr. Santiago. I was told it no longer existed because the firm’s standard practice for receiving documents was to immediately scan them into electronic format and then shred the original. This clearly directly conflicted with this new version of events.
Ms. Townsend stated to me that Ms. Eagle pleaded with her to send the document; however, Ms. Townsend refused, until Ms. Eagle told her that law enforcement had left. At that time, Ms. Townsend sent her the document. Her original reason for sending it was “well, because it belongs to her and she asked for it,” which changed to, “I sent it to her so I could confront her about it.” Nevertheless, Ms. Townsend admitted she knew it was a forged document when she emailed it to Nicole Eagle.
I asked Ms. Townsend why she had gone ahead and filed the CR60 motion for Mr. Santiago the next day if she had spent months telling him she wouldn’t do it unless he paid her. She replied that she did it just to “get him out of my hair.” This doesn’t make sense, either, because she still represented him on the criminal case. Ms. Townsend claimed she would never have filed a CR60 motion on such a matter because it “wouldn’t go anywhere,” indicating she only filed the motion to put on a show for Mr. Santiago, while knowing that nothing would actually come of it.
Throughout the interview, Josephine Townsend repeatedly claimed that she was yelling at Nicole Eagle on the phone, saying, “Where did you get this? You can’t have this! Judge Clark doesn’t sign civil orders. You’re going to get yourself in trouble!,” etc.
After the interview, I reviewed the Body Worn Camera videos of the deputies who had responded to arrest Travon Santiago on 17 July 2024. What I observed was in direct conflict with what Ms. Townsend had just stated to me.
The video showed Nicole Eagle had finally made phone contact with Josephine Townsend and she had her phone on “speaker.” Josephine Townsend could be heard on the phone in the BWC videos. Never once did I hear Josephine Townsend raise her voice or confront Ms. Eagle about anything. In fact, what I observed was that Nicole Eagle had presented a printed version of the signed criminal order modification to the deputies. They reviewed it and confirmed that it was the wrong order, as they were there to arrest Travon Santiago for violating the civil order, which had a different case number.
Nicole Eagle appeared confused; however, she appeared confident that the order had been modified and that she would contact Josephine Townsend to clear everything up. In reviewing the BWC video of Deputy Bryson Layton, recorded on 17 July 2024, I observed the following:
At 2011 hours, Nicole Eagle was on the phone with Josephine Townsend, explaining that she had presented a document which bore the case number for the criminal court case, not for any protection orders.
Josephine Townsend: “His court case is the 2-9-0-2.” (The criminal cause number is 23-1-02902-06)
At 2012 hours, Josephine Townsend said, “The system is down for maintenance, so I can’t even get into the system right now.”
At 2016 hours:
Josephine Townsend: “I should be able to download it [inaudible]
Nicole Eagle: “Okay. I wonder if it’s just the same paper I have.” (referring to the criminal order modification she had just presented to the deputies)
Josephine Townsend: “No, it’s got a different case number on it.”
It was immediately apparent to me that Josephine Townsend indicated to Nicole Eagle that there was a separate order modifying the civil protection order. Nicole Eagle never provided Ms. Townsend with this idea.
Their phone call originated at 2004 hours and ended at approximately 2021 hours. In the BWC video, at 2021 hours, Nicole Eagle can be heard saying, “Thank you so much. She’s sending it to my email address.” Travon Santiago relayed to the deputies, “She’s got the thing, my attorney’s sending her for everybody that’s under this anti-harassment.” Nicole Eagle then asks to have Travon carbon-copied to the email “just to be safe.” The deputies walked away and stopped recording at approximately 2025 hours.
I contacted superior court employee Chelsea Olver again and requested an access log for Josephine Townsend’s OnBase account. OnBase is the computer system which the Clark County Clerk uses to record all court documents. Users can electronically file records through this system, which is where a court employee will review the filings and either accept or reject them. Users can further access filed documents through this system, and it is the system which Clark County Judges use to access filings. I was sent a spreadsheet, prepared by Jared Knofczynski, Programmer Analyst for Clark County Information Technology. The spreadsheet indicated the following:
July 17, 2024: 2004 hours, Josephine Townsend viewed and printed document 36041327 which was titled, “#23-1-02902-06 – 1Pg-OR-APRIL2024-Santiago, Travon” from OnBase. This is the modification to the criminal no contact order.
At 2022 hours, Josephine Townsend viewed document 35650506 which was titled, “'#23-2-09215-06 - 2320921506.000023.00 - 11Pg - ORAH - JANUARY2024 - ANGELA KAY FOSS vs TRAVON SANTIAGOet al'” from OnBase. This is the civil protection order which restrained Travon Santiago from Angela Foss.
At 2022 hours, Josephine Townsend viewed and printed document 35646104 which was titled, “'#23- 2-09215-06 - 2320921506.000021.00 - ANGELA KAY FOSS vs TRAVON SANTIAGO et al - Order Modifying Protection Order Removing Nicole Eagle from Order'” from OnBase.
So when, at 2011 hours, Josephine Townsend told Nicole Eagle by phone that the system was down for maintenance, she lied. She was accessing and printing documents related to the two court cases in this matter. The documents which Josephine Townsend accessed were the documents which contained the court case numbers, the electronic signature of Judge Clark, and the electronic filing stamp of the County Clerk. These documents contained the information which Josephine Townsend would have needed to crop from in order to paste to the allegedly forged court order. They also contained information which Josephine Townsend would have needed to draft a Civil Rule 60 motion in Travon Santiago’s name.
Josephine Townsend printed the last document at 2022 hours. She emailed Nicole Eagle the allegedly forged civil protection order at 2035 hours. This is a 13-minute period of time in which I believe Josephine Townsend was forging the document, herself, using the documents she had just printed.
On 31 October 2024, I received a detailed court report from Amy Billups, Branch Supervisor for 2 Watch Monitoring Group. The document was an Excel spreadsheet containing data points related to the GPS ankle monitor for Travon Santiago for the month of July 2024. I requested assistance from Detective Sergeant Neiman who entered the data into CellHawk, a location analysis software, which plotted the data points onto an interactive map based on the latitude and longitude points documented on the spreadsheet. Our review of the data showed that Travon Santiago was never located at Josephine Townsend’s office between 01 and 17 July 2024, which confirmed what I had previously reviewed on my own.
To recap, here is a timeline of events:
November 25, 2023 – incident that later leads to the arrest of Travon Santiago for Assault in the First Degree. Alleged victim is Joseph Prendergast.
November 29, 2023 – Joseph Prendergast’s partner, Angela Foss, files for a civil protection order restraining both Travon Santiago and his partner, Nicole Eagle. It is assigned cause number 23-2-09215- 06.
December 8, 2023 – A criminal no contact order is entered restraining Travon Santiago from coming within 1,000 ft of Joseph Prendergast. The cause number is 23-1-02902-06.
December 20, 2023 – Nicole Eagle petitions to be removed as a restrained party from the civil protection order 23-2-09215-06.
January 5, 2024 –The court grants Nicole Eagle’s request to be removed from the 23-2-09215-06 civil protection order. The order is signed by Commissioner Sasser.
January 8, 2024 – The court issues 23-2-09215-06 civil protection order restraining Travon Santiago from coming within 5,000 feet of Angela Foss. The order is signed by Commissioner Hayes.
April 2, 2024 – Santiago posts bail and is released to GPS monitoring.
April 25, 2024 – Motion to modify criminal no contact order 23-1-02902-06 to 500 ft is granted. Ms. Townsend and Travon Santiago are both present in court. Judge Suzan Clark makes it clear that this modification is only for the criminal no contact order and that the civil protection order will still have to be modified. Judge Suzan Clark signs the order, the order is stamped by Superior Court Clerk Scott Weber.
April 2024-May 2024- Repeated texts from Santiago to Townsend asking if he can go home; Townsend either does not respond or represents that she will take care of it/cite it on. On April 25, 2024, Townsend responds that Santiago can go home in regard to the GPS monitoring.
July 17, 2024 – Deputies arrive at Santiago’s home on a report that he is violating the civil no contact order.
- Deputies arrive at 6:30 p.m.
- 8:04 p.m. – 8:21 p.m. Nicole Eagle on phone with Josie Townsend
- Also at 8:04 p.m. – Josie Townsend accesses and prints the civil protection order (23- 2-09215-06)
- 8:22 p.m. – Josie Townsend accesses two more documents from the civil protection cause on OnBase.
- Deputies leave
- 8:35 p.m. – Josie Townsend emails the modified civil protection order (23-2-09215-06) to Nicole Eagle. This is the modified order that is the subject of the investigation and contains a 4/25/24 e-signature from Judge Suzan Clark and a 4/25/24 e-stamp from Court Clerk Scott Weber. This modified order is the subject of the investigation, and both Judge Clark and Scott Weber have confirmed that these are not legitimate signatures or stamps.
July 18, 2024 – Josie Townsend files a Motion to Modify civil protection order (23-2-09215-06) with a July 7, 2024 declaration purportedly e-signed by Travon Santiago.
Mr. Santiago has confirmed he did not sign that document as his name is misspelled. Review of GPS records confirm that Mr. Santiago did not go to Josie Townsend’s law office July 1- July 18, 2024.
In summary, I determined that Josephine Townsend had forged numerous records, including the forged electronic signature of a Superior Court Judge and the forged electronic filing stamp of the Clark County Clerk.
Probable Cause exists to arrest Josephine Townsend for Forgery.
I certify or declare under penalty of perjury under the laws of the State of Washington that the foregoing is true and correct. I intend my printed name and PSN on this document to be my signature. This document was signed in Clark County, Washington. Signed this 9th day of December, 2024, in Vancouver, Clark County, Washington.
Detective Sergeant Jayson Camp #4852
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