Seattle, WA — May 7, 2025 In a case already defined by procedural complexity and entrenched resistance from opposing counsel, plaintiff Elizabeth Campbell has taken another critical step to preserve the integrity of the record—and her rights on appeal. On May 7, 2025, Campbell filed a motion under Civil Rule 60(a), asking the King County Superior Court to correct a clerical error in an April court order that she argues doesn’t reflect what the judge actually intended.
At first glance, it might sound arcane—caption errors, binders, court portals. But this motion gets at something far deeper: the right of a self-represented litigant to ensure that the official court record reflects what really happened.
📚 The Problem: A Mixed-Up Caption and a Missing Record
In April, the Court issued an order denying Campbell’s request to preserve hearing binders prepared for a critical June 2024 dismissal hearing in a related case. The issue? The order was captioned “GRANTING IN PART AND DENYING IN PART”, but the body of the ruling denied everything—including preservation of the very hearing binders that defense counsel had themselves acknowledged should be kept.
📄 Read the April 21, 2025 Order Here
These were not trivial materials. The hearing notebooks contained the written briefs that Judge Holloway likely relied on in ruling to dismiss large portions of Campbell’s case. And as Campbell explains in her motion, due to rejected filings, portal paywalls, and technical blocks on submitting working copies by email, the court’s paper copies may have been the only version of her opposition briefs the judge ever saw.
So why is the Court denying their preservation, especially when its own caption seemed to say the opposite?
That’s what Campbell is asking the judge to clarify—and correct.
📄 Read the Motion Filed May 7, 2025 Here
📄 Read Campbell’s Declaration Filed May 7, 2025 Here
⚖️ The Legal Tool: CR 60(a)
Campbell’s motion invokes Civil Rule 60(a), which gives courts the power to fix clerical errors or drafting mistakes—as opposed to changing a decision’s substance. Her argument is tightly focused: the caption reflects the Court’s intent to preserve some part of the requested materials (namely the hearing binders), but the body of the order misstates that intent. A mistake, not a change of heart.
She doesn’t ask the Court to revisit the merits of its decision—only to bring the language of the order into alignment with the record and the apparent intent behind the caption.
🧩 Why It Matters
This is about more than formatting. Campbell’s appeal (already underway in Court of Appeals Case No. 874985) covers orders issued by Judge Holloway—decisions potentially made on an incomplete or flawed record. If the hearing notebooks that influenced those decisions disappear without a trace, the appellate court will never be able to fully understand how the rulings were reached. That’s a risk not just to her case, but to judicial accountability.
In a high-stakes lawsuit involving over a dozen defendants, including the Swedish Club and former board members, Campbell has often had to fight not just the legal arguments, but the logistics of being heard. Filing barriers, formatting technicalities, and defense tactics have all contributed to a situation where the court record may not reflect the full story.
This motion is an effort to fix that—quietly, carefully, and within the rules.
📝 What’s Next?
A hearing is set for May 22, 2025, although the motion requests that the matter be decided without oral argument, given its narrow and procedural nature. Defense counsel has not yet filed opposition, but even if they do, the burden will be on them to explain why a court should let stand an order that appears to contradict itself—and discard materials both parties previously agreed were worth preserving.
The public may not often see the gears turning in the background of civil litigation, but motions like this one are where procedural fairness is either preserved—or quietly lost.
And Elizabeth Campbell is making sure it’s preserved.