Homesite Insurance Company v. Schlackman

CourtDistrict Court, W.D. Washington
DecidedMay 1, 2023
Docket2:22-cv-01106
StatusUnknown

This text of Homesite Insurance Company v. Schlackman (Homesite Insurance Company v. Schlackman) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Homesite Insurance Company v. Schlackman, (W.D. Wash. 2023).

Opinion

5 UNITED STATES DISTRICT COURT 6 WESTERN DISTRICT OF WASHINGTON 7 AT SEATTLE 8 HOMESITE INSURANCE COMPANY, Case No. C22-1106RSL 9

10 Plaintiff, ORDER GRANTING 11 v. PLAINTIFF’S MOTION FOR SUMMARY JUDGMENT 12 EMILY SCHLACKMAN, et al., 13 Defendants. 14 15 This matter comes before the Court on plaintiff’s unopposed “Motion for Summary 16 Judgment” (Dkt. # 11). Having reviewed plaintiff’s submissions and the remainder of the record, 17 the Court grants plaintiff’s motion for summary judgment for the reasons stated herein. 18 I. Background 19 Plaintiff Homesite Insurance Company seeks declaratory judgment from this Court that it 20 owes no duty to provide defense or indemnity coverage under a homeowners policy held by 21 defendant Emily Schlackman with regard to a state court lawsuit arising out of sex trafficking 22 allegations (the “Underlying Action”). Dkt. # 11 at 1. 23 A. The Underlying Action 24 The Underlying Action is a lawsuit brought by Ms. Shlackman’s co-defendants in the 25 instant case – Angelica Campbell, Amanda Branch, Megdalena Perez Hilts, Tessa Mortenson, 26 and Nabila Haji-Ali – against non-party Solomon Simone, Ms. Schlackman, and others in King 27 County Superior Court. See Dkt. # 1-1 (copy of complaint in Angelica Campbell et al. v. 28 Solomon Simone et al., King County Superior Court, Case No. 21-2-11125-1). The complaint 1 alleges that Ms. Schlackman and others assisted Mr. Simone in operating a sophisticated human 2 trafficking ring and drug distribution operation. The thrust of the lawsuit focuses on the 3 misdeeds of Mr. Simone – specifically his scheme of “targeting young, vulnerable women,” 4 gaining their trust, “forc[ing] them into stripping, prostitution, and selling drugs,” and 5 “maintain[ing] control over the women with a variety of tactics that amount to force, fraud, and 6 coercion.” Dkt. # 1-1 at 9-11. However, Ms. Schlackman is identified as a “participant[] in the 7 scheme.” Id. at 11.1 The Underlying Complaint alleges that: 8 Defendant Schlackman assists with Defendant Simone’s drug distribution operation. She distributes it to the women within Defendant Simone’s 9 organization and sells it at the street level, either while the women are 10 working in strip clubs or prostituting. She has also assisted Defendant Simone in sheltering assets by holding real property in her name on his 11 behalf. 12 Id. at 13. 13 B. Claims Asserted Against Schlackman in Underlying Complaint 14 Per the Underlying Complaint, Ms. Campbell has asserted claims of (1) 15 Outrage/Intentional Infliction of Emotional Distress; (2) violations of Washington’s Criminal 16 Profiteering Act, RCW § 9A.82; and (3) conspiracy against Ms. Schlackman. The factual basis 17 for the charges is described in the Underlying Complaint: 18 In mid-August, Defendant Simone visited the Shoreline property 19 accompanied by Defendant Schlackman and told Ms. Campbell that she was obligated to begin making money again. He told Ms. Campbell matter- 20 of-factly that she was going to help him sell cocaine. 21 Defendant Simone explained that “Katie [Fulford] makes the shit,” and that 22 Defendant Schlackman would then deliver it to the various street-level 23 dealers, including Defendant Adams. Cocaine was to be sold at a rate of $180 per gram. Defendant Simone told Ms. Campbell that her role would 24 be to use her connections in the strip clubs to bring in new customers for 25 Defendant Adams to sell to. 26 1 Notably, the Underlying Complaint also states “[u]pon information and belief, Defendant 27 Schlackman is another victim of Defendant Simone’s criminal enterprise, though she presently lacks the 28 ability to free herself.” Dkt. # 1-1 at 59. 1 Over the course of a month and a half, Defendant Schlackman would 2 deliver new cocaine whenever Defendant Adams reported back to her that 3 the prior batch had been sold. She would provide the new batch to Defendant Adams, who would turn over the money to Defendant 4 Schlackman to deliver back to Defendant Simone. Once Defendant Adams 5 had the cocaine in hand, he would press Ms. Campbell for contacts and customers to purchase it. This pattern repeated at least five times during 6 that month and a half, and in that time, Ms. Campbell was able to secure 7 approximately 12 new, regular purchasers for Defendant Adams and Defendant Simone. 8 Id. at 65. Ms. Schlackman is also included in Ms. Campbell’s allegation that she “faces the 9 ongoing presence of Defendant Simone and his entourage.” Id. at 68. Specifically, members of 10 Simone’s “organization frequently show up in public places at which Ms. Campbell is 11 socializing or working and watch her.” Id. 12 Ms. Campbell alleges that this conduct supports a cause of action under the tort of 13 outrage/intentional infliction of emotional distress because: 14 Defendant Schlackman was complicit in the scheme to traffic Ms. 15 Campbell by virtue of her having provided material support to Defendant 16 Simone and running his drug manufacturing and distribution operation, as well as shielding certain assets by titling real property in her name. 17 Defendant Schlackman further perpetuated his abusive conduct by 18 harassing and stalking Ms. Campbell after she left Defendant Simone, threatening her via social media, and regularly appearing in public places 19 to stalk her and monitor her activities in the months after she escaped. 20 Defendant [Schlackman]’s2 conduct was extreme and outrageous because she knew she was an accomplice to Defendant Simone in his trafficking of 21 Ms. Campbell, and because her ongoing conduct after her escape only 22 served to further traumatize Ms. Campbell. 23 Id. at 79. 24 25

26 2 The Underlying Complaint refers to “Defendant Fulford” – another woman named as a defendant in the Underlying Action. Id. at 79. As defendant Fulford’s actions constituting the tort of 27 outrage are discussed elsewhere in the Underlying Complaint, id. at 78, the Court assumes this is a typo 28 and that this full paragraph is meant to refer to Defendant Schlackman. 1 Ms. Campbell further alleges that this conduct constitutes a violation of the 2 Washington Criminal Profiteering Act, RCW § 9A.82, arguing that: 3 Defendant Schlackman violated the WCPA by assisting Defendant Simone in the trafficking of Ms. Campbell with respect to the manufacture and sale 4 of controlled substances. Defendant Schlackman was directly responsible 5 for the distribution of the cocaine for which Ms. Campbell was forced to perform labor in the form of recruiting purchasers. 6 Id. at 83-84. 7 Finally, Ms. Campbell also alleges that this conduct constitutes participation in a 8 civil conspiracy, as: 9 Each of the named Defendants conspired with Defendant Simone in the 10 unlawful purpose to traffic Ms. Campbell, force her into prostitution, force 11 her into involuntary servitude, and unlawfully imprison her. The sum total of Ms. Campbell’s ordeal would not have been possible without the 12 coordinated unlawful agreement of the conspiring Defendants. 13 Id. at 84. Ms. Campbell alleges that as a result of this conduct, she has “suffered severe 14 emotional and physical injury.” Id. at 80, 84. Accordingly, Ms. Campbell seeks (1) “not 15 less than one million dollars” in actual damages jointly and severally from the named 16 defendants; (2) treble damages as authorized by the Washington Criminal Profiteering 17 Act, RCW § 9A.82 et seq.; (3) reasonable attorney’s fees and investigative fees as 18 authorized by the Washington Criminal Profiteering Act, RCW § 9A.82

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Homesite Insurance Company v. Schlackman, Counsel Stack Legal Research, https://law.counselstack.com/opinion/homesite-insurance-company-v-schlackman-wawd-2023.