FILED
18 MAR 14 AM 9:22

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KING COUNTY
SUPERIOR COURT CLERK
E-FILED
CASE NUMBER: 18-2-06812-6 SEA

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SUPERIOR COURT OF THE STATE OF WASHINGTON
IN AND FOR KING COUNTY

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BETTY PINA, individually,
NO.

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Plaintiffs,
v.

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COMPLAINT FOR DAMAGES:
WORKPLACE RAPE

ALASKA AIRLINES, INC., a corporation
headquartered in Washington State, and

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Defendant.

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COMES NOW the Plaintiff, by and through her attorneys of record, and by way of
information and belief allege as follows:
I.

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1.

PARTIES

Plaintiff Betty Pina is a Washington State resident and current employee of

Alaska Airlines, Inc.

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2.

Defendant Alaska Airlines, Inc. is a for profit corporation with a registered

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agent identified as Kyle Levine located at corporate headquarters: 1300 International
Boulevard, Seatac, Washington 98188.
II.

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3.

STATEMENT OF FACTS

Betty Pina is a distinguished military veteran and trained airline pilot. Ms.

Pina is currently employed as a first officer in good standing by Alaska Airlines.
COMPLAINT - 1 of 5

CONNELLY LAW OFFICES, PLLC
2301 North 30th Street
Tacoma, WA 98403

(253) 593-5100 Phone - (253) 593-0380 Fax

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raping of Ms. Pina by another Alaska Airlines employee, Paul Engelien.

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This lawsuit against Alaska Airlines arises form the workplace drugging and

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Mr. Englien is a senior pilot. Mr. Engelien drugged and raped Ms. Pina during

an overnight stay in Minneapolis on a flight from Anchorage to Seattle to Minneapolis.

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6.

The entire event was investigated by Alaska Airlines, and reflected in the

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referenced investigation summary compiled by Marcella Fleming Reed, J.D.

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7.

On the flight, Mr. Engelien was the senior pilot and Ms. Pina was the first

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In sum, Mr. Engelien invited Ms. Pina for drinks at the hotel in between

officer:

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flights:

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COMPLAINT - 2 of 5

CONNELLY LAW OFFICES, PLLC
2301 North 30th Street
Tacoma, WA 98403

(253) 593-5100 Phone - (253) 593-0380 Fax

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9.

At the hotel lounge, odd circumstances occurred in relation to Ms. Pina’s

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glass(es) of wine:

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***

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10.

Mr. Engelien proceeded to drug Ms. Pina and rape her during a state of

involuntary intoxication:

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COMPLAINT - 3 of 5

CONNELLY LAW OFFICES, PLLC
2301 North 30th Street
Tacoma, WA 98403

(253) 593-5100 Phone - (253) 593-0380 Fax

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***
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When Ms. Pina challenged Mr. Engelien as to what had occurred, Mr.

Engelien denied any sexual contact and claimed: “You were coming onto me pretty hard.”

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12.

After reporting the rape, Ms. Pina was taken off active flight crew for an

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extended period. Ms. Pina was recently returned to full duty.
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13.

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To the best of Ms. Pina’s knowledge, Mr. Engelien is still employed by Alaska

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Airlines, and remains a threat to other employees.

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III.

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CAUSES OF ACTION: WASHINGTON LAWS AGAINST DISCRIMINATION
(RCW 49.60), SEXUAL ASSAULT & NEGLIGENCE
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Mr. Engelien’s actions, as the supervising officer on the flight, constitute

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violations of Washington Laws Against Discrimination, sexual assault, and negligence.

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Given Mr. Engelien’s position of authority on the flight and within the company, Alaska

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Airlines is liable for the violations stated herein. Mr. Engelien’s grossly abusive actions

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epitomize the necessity and purpose of the #metoo movement. Further, the actions on the part
of Alaska Airlines after the incident could be construed as unlawfully retaliatory.

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COMPLAINT - 4 of 5

CONNELLY LAW OFFICES, PLLC
2301 North 30th Street
Tacoma, WA 98403

(253) 593-5100 Phone - (253) 593-0380 Fax

 IV.

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PRAYER FOR RELIEF

WHEREFORE, Plaintiffs request a judgment against Defendants:
(a)

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Awarding Plaintiff general damages and special damages in an amount to be
proven at trial;

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(b)

Awarding her reasonable attorney’s fees and costs as available under law,

(c)

Awarding her any and all applicable interest on the judgment;

(d)

Awarding her such other and further relief as the Court deems just and proper

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under the circumstances of this case.

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DATED this 13th day of February, 2018.

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CONNELLY LAW OFFICES, PLLC
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Lincoln Beauregard
By__________________________________
Lincoln C. Beauregard, WSBA No. 32878
Attorney for Plaintiff

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MAKUS LAW, PS
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Lincoln Beauregard for
By__________________________________
Eric John Makus, WSBA No. 41683
Attorney for Plaintiff

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COMPLAINT - 5 of 5

CONNELLY LAW OFFICES, PLLC
2301 North 30th Street
Tacoma, WA 98403

(253) 593-5100 Phone - (253) 593-0380 Fax