By Elizabeth Campbell, MPA
On May 1, 2025, I filed a Declaration and Notice in King County Superior Court to formally document the systematic efforts by defense counsel to block fair and orderly discovery in Campbell v. Matthiesen et al., No. 23-2-25128-8 SEA.
This declaration isn’t simply procedural — it is a public record of the obstruction I’ve encountered and the structured response I’ve advanced.
Despite serving individualized interrogatories and requests for production — each linked directly to causes of action in my 383-page Second Amended Complaint — counsel for the sixteen named defendants rejected the offer of written objections and tailored conferrals. Instead, they demanded a single, collective “meet-and-confer” call involving all counsel. I declined.
Defense Counsel, by Defendant Group
Defendant Group 1 – Karen Kalzer (Helsell Fetterman LLP)
- Kristine Leander – Former employee
- Toene Hayes – Former employee
Defendant Group 2 – Brad Bigos and Alex Lopez (Lane Powell PC)
- The Swedish Club (entity)
- Langdon Miller – Board member
- Kris Johansson – Board member
- Gary Sund – Board member
- Sharon Lucas – Club member
Defendant Group 3 – Megan Starks and Sarah Tatistcheff (Patterson Buchanan)
- Sarah Alaimo – Former employee (terminated)
- Shama Albright, Mary Emerson, Anna Faino, Martin Johansson, Ib Odderson, Molly Olson Smith, Neil Snyder – Former board members who resigned
Defendant Group 4 – Nicholas Larson and Miguel Mendez-Pintado (Murphy Pearson)
- Lars Matthiesen – Club member
Each group filed its own Answer with distinct legal positions — yet their attorneys demanded a unified process, despite their clients’ differing interests.
“Given the complexity of this litigation — involving 16 defendants now represented across multiple distinct groups, with 56 causes of action, and a 383-page Second Amended Complaint — a meaningful meet-and-confer process must reflect the reality that the defendants’ interests, defenses, and exposures are no longer aligned.”
– Declaration ¶ 7
“My goal has been to create a transparent and collaborative pathway to resolve disagreements and avoid unnecessary burden on the Court.”
– Declaration ¶ 11
Washington law supports written conferral when proportionate and meaningful:
“The discovery rules…contemplate that parties will make a good-faith effort to resolve discovery disputes without court involvement.”
– Mayer v. Sto Industries, 156 Wn.2d 677, 684–85 (2006)
“Where the parties have made meaningful efforts in writing to resolve disputes, courts have accepted that as sufficient.”
– WSBA Civil Discovery Deskbook, § 7.4
🔗 Read the Filings and Materials
📄 Filed Declaration and Notice (May 1, 2025)
👉 Download the PDF
📂 Discovery Summaries and Correspondence Exhibits
👉 View Supporting Documents
This declaration was necessary to preserve the record — and to document my full compliance with discovery law, even in the face of coordinated pushback from four law firms.
The Swedish Club’s Legal Stonewall: Plaintiff Files Formal Declaration to Document Discovery Obstruction
By Elizabeth Campbell, MPA
On May 1, 2025, I filed a Declaration and Notice in King County Superior Court to formally document the systematic efforts by defense counsel to block fair and orderly discovery in Campbell v. Matthiesen et al., No. 23-2-25128-8 SEA.
This declaration isn’t simply procedural — it is a public record of the obstruction I’ve encountered and the structured response I’ve advanced.
Despite serving individualized interrogatories and requests for production — each linked directly to causes of action in my 383-page Second Amended Complaint — counsel for the sixteen named defendants rejected the offer of written objections and tailored conferrals. Instead, they demanded a single, collective “meet-and-confer” call involving all counsel. I declined.
Defense Counsel, by Defendant Group
Defendant Group 1 – Karen Kalzer (Helsell Fetterman LLP)
- Kristine Leander – Former employee
- Toene Hayes – Former employee
Defendant Group 2 – Brad Bigos and Alex Lopez (Lane Powell PC)
- The Swedish Club (entity)
- Langdon Miller – Board member
- Kris Johansson – Board member
- Gary Sund – Board member
- Sharon Lucas – Club member
Defendant Group 3 – Megan Starks and Sarah Tatistcheff (Patterson Buchanan)
- Sarah Alaimo – Former employee (terminated)
- Shama Albright, Mary Emerson, Anna Faino, Martin Johansson, Ib Odderson, Molly Olson Smith, Neil Snyder – Former board members who resigned
Defendant Group 4 – Nicholas Larson and Miguel Mendez-Pintado (Murphy Pearson)
- Lars Matthiesen – Club member
Each group filed its own Answer with distinct legal positions — yet their attorneys demanded a unified process, despite their clients’ differing interests.
“Given the complexity of this litigation — involving 16 defendants now represented across multiple distinct groups, with 56 causes of action, and a 383-page Second Amended Complaint — a meaningful meet-and-confer process must reflect the reality that the defendants’ interests, defenses, and exposures are no longer aligned.”
– Declaration ¶ 7
“My goal has been to create a transparent and collaborative pathway to resolve disagreements and avoid unnecessary burden on the Court.”
– Declaration ¶ 11
Washington law supports written conferral when proportionate and meaningful:
“The discovery rules…contemplate that parties will make a good-faith effort to resolve discovery disputes without court involvement.”
– Mayer v. Sto Industries, 156 Wn.2d 677, 684–85 (2006)
“Where the parties have made meaningful efforts in writing to resolve disputes, courts have accepted that as sufficient.”
– WSBA Civil Discovery Deskbook, § 7.4
🔗 Read the Filings and Materials
📄 Filed Declaration and Notice (May 1, 2025)
👉 Download the PDF
📂 Discovery Summaries and Correspondence Exhibits
👉 View Supporting Documents
This declaration was necessary to preserve the record — and to document my full compliance with discovery law, even in the face of coordinated pushback from four law firms.