In The Receivership Of Nw Trustee Services, Inc. And Rco Legal, P.s.

CourtCourt of Appeals of Washington
DecidedJune 1, 2026
Docket86766-1
StatusUnpublished

This text of In The Receivership Of Nw Trustee Services, Inc. And Rco Legal, P.s. (In The Receivership Of Nw Trustee Services, Inc. And Rco Legal, P.s.) 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.

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In The Receivership Of Nw Trustee Services, Inc. And Rco Legal, P.s., (Wash. Ct. App. 2026).

Opinion

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON DIVISION ONE

In the Matter of the Receivership of No. 86766-1-I

NORTHWEST TRUSTEE SERVICES, INC. and RCO LEGAL, P.S.

ELLIOT BAY ASSET SOLUTIONS, LLC, UNPUBLISHED OPINION Appellant/Cross Respondent,

v.

PNC BANK, N.A.,

Respondent/Cross Appellant.

BOWMAN, A.C.J. — Elliott Bay Asset Solutions LLC (EBAS) served as the

general receiver for RCO Legal PS and its affiliate, Northwest Trustee Services

Inc. (NWTS). EBAS hired attorneys to help with its receivership duties, including

defending against a claim for payment by PNC Bank NA. EBAS appeals from

the trial court’s orders disqualifying its attorneys from defending against PNC’s

claim and refusing to authorize EBAS to compensate them for work performed in

January and February 2024. PNC cross appeals, arguing the court abused its

discretion by approving payment to EBAS’ attorneys for work done in May, June,

and July 2024. Because the attorneys had no conflict of interest preventing them

from defending against PNC’s claim, we reverse and remand for the trial court to No. 86766-1-I/2

authorize payment for work that EBAS and its professionals performed in

January and February 2024 and to vacate its order disqualifying them. We also

affirm the trial court’s subsequent order granting EBAS’ requests to compensate

its attorneys.

FACTS

RCO and NWTS were a collective law firm and trust company that

represented financial institutions and foreclosed on over 49,000 properties per

year. In October 2015, JPMorgan Chase & Co. and JPMorgan Chase Bank NA

(collectively Chase) initiated an arbitration proceeding against RCO for damages

incurred during nonjudicial property foreclosures in Hawaii. Chase alleged that

RCO breached its contractual obligations and committed professional

malpractice. RCO’s malpractice insurer, Catlin Specialty Insurance Company,

defended RCO in the arbitration subject to a reservation of rights.1 On

November 29, 2017, RCO, Chase, and Catlin reached a tentative settlement

agreement.

On March 27, 2018, RCO and NWTS could not pay their debts and

assigned their property to EBAS to benefit the creditors under RCW 7.08.030.

EBAS accepted the assignment. The same day, EBAS petitioned for

appointment as general receiver “over all the assets owned by NWTS and/or

RCO.” The next day on March 28, the trial court issued an “Order Appointing

1 RCO’s Catlin policy covered the period of July 1, 2013 to July 1, 2024. It was an eroding policy with a $5,000,000 per claim limit of liability, a $5,000,000 aggregate limit of liability, and a $50,000 retention applicable to each covered claim.

2 No. 86766-1-I/3

General Receiver” (Appointment Order), appointing EBAS as the general

receiver for RCO and NWTS.

The Appointment Order authorized EBAS to “take charge over all the

assets and property owned by NWTS and RCO . . . and to take such actions as

are required to protect and preserve such property.” It also authorized EBAS to

contract with, hire or retain (including on a contingency fee basis), direct and discharge any professional persons, including attorneys and accountants, that the Receiver, in its sole discretion, deems necessary for the efficient collection, operation, maintenance, and/or liquidation of the Receivership Property in accordance with RCW . . . 7.60.180.

Section 16 of the Appointment Order explained that EBAS may “disburse funds

from the Receivership Estate as payment for its fees and costs and for the fees

and costs of its professionals on a periodic basis” after filing a compensation

notice. It said the “approved fees and costs of the Receiver and its professionals

shall be paid from the gross receipts derived from the Receivership Property.”

On May 29, 2018, PNC filed a secured proof of claim with EBAS, seeking

over $30 million. Like the Chase claim, PNC alleged that RCO and NWTS

breached a legal services agreement and committed professional negligence

related to nonjudicial foreclosure proceedings in Hawaii. EBAS submitted the

claim to Catlin, which accepted it subject to a reservation of rights.

On May 30, 2018, Chase filed a proof of claim with EBAS. Two years

later in April 2020, EBAS moved the trial court to approve the settlement

agreement with Chase. The settlement agreement required Catlin to pay Chase

$2,500,000 on behalf of RCO and NWTS. In exchange, Chase would withdraw

its proof of claim and dismiss the arbitration with prejudice. PNC opposed EBAS’

3 No. 86766-1-I/4

motion to approve the settlement agreement. It argued that if the court considers

the proceeds of the Catlin insurance policy to be property of the receivership

estate, the settlement agreement improperly grants Chase’s unsecured claim

priority over other creditors’ claims like PNC’s. On September 1, the trial court

approved the settlement agreement. It found that “the proceeds of the Catlin

Policy payable directly to Chase are not assets of the Receivership Estate . . .

and are not subject to pro rata distribution to other receivership creditors.”

On January 28, 2021, EBAS moved to employ the law firm Beck Chase

Gilman PLLC (BCG) and its attorneys James Beck and Eric Gilman to assist it

with its receivership duties. EBAS told the court it “does not believe that [BCG]

and/or its attorneys . . . have a conflict of interest with the Receiver or the

Receivership Estate.” On February 24, the trial court granted the motion.

Almost two years later on November 2, 2022, EBAS informed PNC that its

May 2018 proof of claim was statutorily noncompliant because it did not include

“a copy of the contract” supporting its claim for over $30 million. On December 6,

PNC amended its proof of claim, reducing it to $7,812,287 and identifying it as an

unsecured claim.

On February 13, 2023, EBAS moved to employ the law firm Wenokur

Riordan PLLC (WR) and its attorney Alan Wenokur “to advise and assist [EBAS]

with respect to administration of the Receivership Estate, including . . . the PNC

. . . Proof of Claim.” EBAS said it was hiring WR as “additional” counsel “to

investigate the PNC Bank Proof of Claim to determine liability and defend the

Proof of Claim if needed.” It stated, “Neither [WR] nor its attorney . . . have a

4 No. 86766-1-I/5

conflict of interest with the Receiver or the receivership estate.” The court

granted the motion.

On October 18, 2023, WR sent PNC a letter, stating that it was aware

PNC was trying to identify insurance policies other than Catlin to which EBAS

could submit PNC’s claim. But it disputed that PNC’s claims have merit because

“all the legal actions where [PNC] alleged that RCO Legal committed

professional negligence fall far outside [the] statutes of limitations.” WR told PNC

that “unless we can settle these matters very soon, [EBAS] will be filing an

objection to the PNC claim.”

On November 15, 2023, PNC stated in a letter to EBAS that it discovered

additional RCO malpractice insurance policies. It said, “We are advised that

Chubb was RCO’s insurer from July 1, 2009 to June 30, 2011 and [that] Zurich

was RCO’s insurer from July 1[,] 2011 to June 30, 2013.” PNC asked EBAS to

tender its claim to Chubb and Zurich. EBAS refused.

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