Elizabeth A. Campbell, plaintiff in the civil rights and governance lawsuit Campbell v. Matthiesen, et al., filed a Supplemental Declaration and CR 26(i) Certification this morning at 8:30 a.m. in King County Superior Court. The filing, entered into the docket for Case No. 23-2-25128-8 SEA, documents that none of the Swedish Club’s four defense groups* responded to her May 1 email offering a final opportunity to resolve discovery disputes without court intervention.
The declaration — which builds upon Campbell’s detailed May 1st Notice and Declaration] — includes Exhibit K, her email sent to all defense counsel on May 1, 2025, offering a fallback deadline of May 7 for written objections or concerns. This fallback was proposed after Campbell had already set staggered deadlines for each group in late April, and was designed to jumpstart the discovery process without unnecessary motion practice.
“They were given every opportunity,” Campbell said. “But not one of the Club’s lawyers — not one — would put their objections or positions in writing. I gave them weeks. I gave them a structured summary for each set of discovery requests. And I gave them a final compromise deadline. They chose silence.”
Despite claiming a collective desire to confer, the Swedish Club’s defense counsel have refused to individually engage or acknowledge the tailored discovery requests that Campbell served on all sixteen defendants in April. Their position, repeatedly reiterated in emails included in Campbell’s declaration, was that a single collective Zoom call was the only acceptable option — a stance Campbell rejected as procedurally chaotic and prejudicial to a self-represented litigant managing divergent claims across four defendant groups.
Background: Defense Delays Spanning Over a Year
The current impasse follows more than a year of obstruction by the Swedish Club’s attorneys. In May 2024, they obtained a discovery stay, and even after the Court issued rulings on September 27, 2024, they insisted the stay remained in effect — without any basis in law. It ultimately required a Court order on March 4, 2025, to formally reopen discovery.
Since then, Campbell has issued sixteen sets of interrogatories and requests for production, [available for public review here]([INSERT LINK]). Each set corresponds to one or more defendants and is supported by structured summaries mapping the discovery to specific causes of action and complaint allegations.
“What I’ve filed today shows not just diligence — it shows disproportionate resistance from the defense,” Campbell added. “This is not good-faith litigation. It’s manufactured gridlock designed to prevent facts from seeing daylight.”
Next Steps
Campbell’s filing preserves the record under CR 26(i) and sets the stage for a potential motion to compel if discovery responses are not served by the required May 19, 2025 deadline. If defense counsel fail to comply, they risk a court order compelling responses and possible sanctions under CR 37.
A copy of today’s filing — including the new [Notice and Supplemental Declaration filed May 8, 2025] — is now available for public access.
* 🟦 Defendant Group 1
Represented by: Karen Kalzer (Helsell Fetterman LLP)
Defendants:
• Kristine Leander
• Toene Hayes (discovery request later withdrawn due to typo)
🟩 Defendant Group 2
Represented by: Brad Bigos and Alex Lopez (O’Hagan Meyer)
Defendants:
• Swedish Cultural Center d/b/a the Swedish Club
• Langdon L. Miller
• Kris E. Johansson
• Sharon Lucas
• Gary Sund
🟧 Defendant Group 3
Represented by: Megan Starks and Sarah Tatistcheff (Patterson Buchanan)
Defendants:
• Sarah Alaimo
• Shama Albright
• Mary Emerson
• Anna Faino
• Martin K. Johansson
• Ib R. Odderson
• Molly Olson Smith
• Neil Snyder
🟥 Defendant Group 4
Represented by: Nicholas Larson and Miguel Mendez-Pintado (Murphy Pearson)
Defendant:
• Lars Christian Matthiesen