Betz Cellars, Llc V. Red Scare Media, Llc D/b/a Varial Agency

CourtCourt of Appeals of Washington
DecidedDecember 8, 2025
Docket87058-1
StatusUnpublished

This text of Betz Cellars, Llc V. Red Scare Media, Llc D/b/a Varial Agency (Betz Cellars, Llc V. Red Scare Media, Llc D/b/a Varial Agency) is published on Counsel Stack Legal Research, covering Court of Appeals of Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Betz Cellars, Llc V. Red Scare Media, Llc D/b/a Varial Agency, (Wash. Ct. App. 2025).

Opinion

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON

BETZ CELLARS, LLC, No. 87058-1-I Respondent,

v. DIVISION ONE

RED SCARE MEDIA, LLC, d/b/a VARIAL AGENCY, UNPUBLISHED OPINION

Appellant.

CHUNG, J. — Thomas Beck appeals the superior court’s July 16, 2024, order

denying his CR 60(b)(4) motion to vacate a contempt order entered on April 27, 2023,

and a judgment entered against him on September 12, 2023. Because most of his

claims are untimely and he fails to show the trial court abused its discretion when it

denied his CR 60(b)(4) motion, we affirm.

FACTS

On October 1, 2020, Red Scare Media LLC (Red Scare Media) d/b/a Varial

Agency (Varial) entered into a contract with Betz Cellars LLC (Betz) to provide services

including market research, strategy development, paid advertising, email marketing, and

website design. Thomas Beck signed on behalf of Red Scare Media. Following a

dispute, Red Scare Media initiated arbitration. Attorney Cornelius McKnight with the

Illinois law firm McKnight & Kitzinger, LLC (McKnight & Kitzinger) represented Red No. 87058-1-I/2

Scare Media. 1 The demand for arbitration alleged that Varial “acts through its officers

Joseph Beason and Thomas Beck.”

The final hearing in the arbitration was held in March 2022. Beck and Beason

testified as Varial’s witnesses. During the hearing, Beck was asked about his role within

Varial, and he responded he was the “Chief Executive Officer [(CEO)] . . . [T]he lead

strategic officer for the company.” Beck also confirmed that Varial is the “DBA of

Redscare Media.” Ultimately, the arbitrator found that Red Scare Media had failed to

prove its claims and was not entitled to recovery. The arbitrator also awarded Betz, as

the prevailing party, attorney fees and costs.

In August 2022, Betz moved to confirm the arbitration award in superior court

and subsequently filed a certificate of service confirming that the “Petition to Confirm

Arbitration Award, Declaration in Support of Petition, [Proposed] Order Granting Petition

to Confirm Arbitration Award, [Proposed] Judgment and Notice of Court Date

documents” were “served on opposing counsel and Respondent via Email, Certified

Mail, Return Receipt Requested . . . and by Mess[en]ger.” On August 24, 2022, the

superior court entered an order confirming the award and issued judgment in Betz’s

favor against “Red Scare Media, LLC dba Varial Agency” (judgment debtor).

On January 31, 2023, Betz filed a motion to compel Red Scare Media to “appear

before this Court . . . to be examined . . . in supplemental proceedings to answer

questions about Red Scare’s assets, and to produce documents concerning its assets

and property that may be used to satisfy the judgment in favor of Betz.” Betz stated in a

1 Throughout the arbitration proceeding, Varial identified itself as “the Petitioner, RED SCARE

MEDIA, LLC d/b/a VARIAL AGENCY (hereinafter ‘VARIAL’) by and through its counsel, MCKNIGHT & KITZINGER, LLC.”

2 No. 87058-1-I/3

declaration that as of January 25, 2023, the judgment remained “wholly unsatisfied.” On

February 1, the superior court entered an order (First Order) requiring Red Scare Media

to be examined and produce documents on March 2. The order was served on Red

Scare Media via its registered agent, Beason, on February 4. On February 23, McKnight

sent Betz a letter contending the First Order was void as to “Red Scare Media, LLC”

since it was “organized in . . . Illinois . . . and involuntarily dissolved [in] 2008.” Betz

responded, disputing the contention and arguing that “the Order is valid and enforceable

against Red Scare Media, LLC d/b/a Varial Agency.” (Emphasis omitted).

On March 1, Betz emailed McKnight instructions for “Red Scare Media, LLC

d/b/a Varial Agency” to appear for the March 2 examination. In response, McKnight

stated that his prior letter was “solely on behalf of Red Scare Media, LLC of Illinois” and

that he had “not appeared for any party in this action and [would] not be appearing

tomorrow.” 2 No one for the judgment debtor appeared for the March 3 examination. The

following day, the superior court entered an order (Second Order) stating that “Red

Scare Media, LLC d/b/a Varial Agency is in contempt of this Court’s Order in

Supplemental Proceedings entered by this Court on February 1, 2023,” and that the

hearing on supplemental proceedings was continued to March 23. The order also stated

that “Red Scare Media, LLC’s d/b/a Varial Agency’s failure to comply with the terms of

this Order shall result in the imposition of sanctions pursuant to RCW 6.32.010,

including without limitation . . . entry of an order for a bench warrant for the arrest of

2 Betz also asked McKnight if he was representing “Red Scare Media, LLC d/b/a Varial Agency,

or Thomas Beck or Joseph Beason.” The record did not include an immediate response to this question. However, the next correspondence from McKnight specified that he was “writing on behalf of Thomas Beck.”

3 No. 87058-1-I/4

Varial Agency’s Chief Executive Officer, Thomas Beck.” The Second Order was served

on Red Scare Media via Beason as its registered agent on March 8.

On March 22, McKnight sent Betz a letter “on behalf of Thomas Beck.” The letter

once again disputed who the judgment debtor was and argued that Beck “is not and

never has been a member, manager, officer or owner of the judgment debtor, Red

Scare Media, LLC,” and that he has “not and never maintained the company records or

financial records of the judgment debtor.” McKnight also asserted that Betz was obliged

to tell the court that none of the pleadings or petitions were served directly on Beck

regarding the bench warrant. Betz responded the following day, disputing the contention

that Beck was not a “member, manager, officer or owner.”

No one appeared on behalf of the judgment debtor at the March 23 supplemental

proceeding. The superior court held “Red Scare Media, LLC [d/b/a] Varial Agency” in

contempt and imposed a daily sanction of $250. It also continued the supplemental

proceeding to April 13, which would “constitute the purge hearing for contempt.” The

purge conditions concerned complying with the original February 1, 2023, order, and the

court stated that if Betz wanted to request a bench warrant, it could submit briefing. On

March 28, “Red Scare Media, LLC [d/b/a] Varial Agency” was served with the contempt

order (Third Order) and an order continuing the supplemental proceeding via its

registered agent, Beason. Betz emailed the order to McKnight “as counsel for Thomas

Beck” on March 27.

On April 6, Betz submitted supplemental briefing in support of a bench warrant

for Beck’s arrest. The certificate of service indicated that “Red Scare Media, LLC d/b/a

Varial Agency” was served at two separate addresses via overnight delivery and that

4 No. 87058-1-I/5

“Cornelius McKnight” received the brief via overnight delivery and email. Neither

McKnight nor anyone else on behalf of Beck or “Red Scare Media, LLC d/b/a Varial

Agency” filed opposing briefing.

Beck appeared at the April 13 hearing. Stan Kitzinger from McKnight & Kitzinger

was also present and attempted to appear as Beck’s counsel, but the court noted that it

did not see a notice of appearance for him.

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