Seattle, WA | May 6, 2025 — In a key procedural move aimed at fortifying the legal foundation of her claims, Plaintiff Elizabeth A. Campbell filed a motion on April 21st seeking leave to file a Third Amended Complaint in her civil rights lawsuit against the Swedish Cultural Center and a long list of its former officers, directors, and affiliated actors. The motion, which details newly developed causes of action for conspiracy, fiduciary breach, and reinstated tortious interference, is supported by direct allegations of financial misconduct, retaliatory governance actions, and exclusion from cultural participation on discriminatory and retaliatory grounds.
📄 Read the Motion to Amend (filed April 21, 2025) Here
The proposed Third Amended Complaint “TAC” builds on Plaintiff’s existing factual record, adding new counts based on emerging evidence and discovery requests—including a set of interrogatories served on April 16 that target alleged misconduct by defendants Sarah Alaimo (former HR Director), Gary Sund (former Board President), and Molly Olson Smith (former Board Vice President). These interrogatories, which seek details related to employment exclusion, governance irregularities, and the misuse of privilege defenses, are expected to yield responses by May 16th.
Defendants File Thin Opposition, Reveal Strategic Weakness
On May 6, 2025, defense counsel for Alaimo, Sund, and Smith filed an objection to Plaintiff’s motion. Their opposition, however, was light on substance and heavy on recycled procedural arguments. They claimed “futility,” invoked CR 11 without cause, and suggested the amendment would prejudice their clients—despite the fact that trial remains ten months away and discovery is open through early 2026.
📄 Read the Defense Opposition (filed May 6, 2025) Here
The opposition notably failed to address Washington’s liberal CR 15(a) amendment standard, nor did it meaningfully contest the new legal theories introduced in the TAC. Defendants also leaned on federal pleading standards (such as Twombly and Iqbal), which Washington courts have repeatedly declined to adopt in favor of a notice pleading framework.
Plaintiff’s Reply Highlights the Gaps—and the Stakes
In a powerful reply filed on May 8, Campbell dismantled the opposition with precision. Her filing cites controlling Washington case law—including Wilson v. Horsley, Herron v. Tribune Publishing, and Karlberg v. Otten—establishing that proposed amendments supported by specific facts or anticipated discovery must be permitted unless clearly prejudicial or brought in bad faith.
📄 Read the Plaintiff’s Reply (filed May 8, 2025) Here
The reply also makes clear that Plaintiff is acting diligently and in good faith—filing the motion within six weeks of discovery reopening and directly addressing prior dismissal grounds through new interrogatories and factual allegations. Where Defendants cite delay and confusion, Plaintiff offers clear legal standards, precise timelines, and good-faith compliance with CR 11.
Strategic Framing: Momentum for Accountability
This exchange is a revealing window into the current litigation posture: the Plaintiff is pressing forward with specificity and procedural integrity, while certain defense groups appear to be recycling procedural defenses to shield themselves from meaningful scrutiny.
The fact that Alaimo, Sund, and Smith—each linked to decisions excluding Plaintiff from employment, membership, and cultural participation—now seek to block narrowly tailored claims aimed at their own roles suggests a growing concern on the defense side about what discovery may uncover.
Team Elizabeth remains confident that the Court will apply Washington’s well-settled legal standards and permit the TAC to proceed—expanding the scope of accountability and continuing the march toward vindication.
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Stay tuned for updates after the May 12th hearing. All documents referenced here will be available in the Case Filings Archive and the Discovery Tracker section of the site.