FILED
18 AUG 03 PM 3:54

THE HONORABLE SANDRA
KING WIDLAN
COUNTY

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SUPERIOR COURT CLERK
E-FILED
CASE NUMBER: 18-2-18613-7 SEA

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SUPERIOR COURT OF WASHINGTON FOR KING COUNTY
BETTS PATTERSON & MINES, P.S.,
No. 18-2-18613-7 SEA

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Plaintiff,
v.
EDWARD B. MURRAY, individually and his
marital community; and MICHAEL
SHIOSAKI, individually and his marital
community,

DEFENDANTS EDWARD B. MURRAY
AND MICHAEL SHIOSAKI’S ANSWER
TO COMPLAINT FOR BREACH OF
CONTRACT, QUANTUM
MERUIT/UNJUST ENRICHMENT,
ATTORNEYS’ FEES, COSTS, AND
OTHER RELIEF

Defendants.

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Defendants Edward B. Murray and Michael Shiosaki (“Defendants”), by and through

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undersigned counsel, provide the following Answer and Affirmative Defenses to Plaintiff

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Betts Patterson & Mines, P.S.’s (“Plaintiff”) Complaint for Breach of Contract, Quantum

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Meruit/Unjust Enrichment, Attorneys’ Fees, Costs, and Other Relief (hereinafter

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“Complaint”). All allegations not specifically admitted are denied.

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I. PARTIES
1.1

Defendants are without sufficient information to admit or deny the allegations

set forth in this paragraph and on that basis alone deny the same.
1.2

Defendants admit that Defendant Edward Murray is a resident of King County,

Washington. Defendants deny the remaining allegations in this paragraph.

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DEFENDANTS’ ANSWER TO COMPLAINT FOR BREACH OF
CONTRACT, QUANTUM MERUIT/UNJUST ENRICHMENT,
ATTORNEYS’ FEES, COSTS, AND OTHER RELIEF – 1

CORR CRONIN LLP
1001 Fourth Avenue, Suite 3900
Seattle, Washington 98154-1051
Tel (206) 625-8600
Fax (206) 625-0900

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1.3

Defendants admit that Defendant Michael Shiosaki is a resident of King

County, Washington. Defendants deny the remaining allegations in this paragraph.
II. VENUE AND JURISDICTION

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2.1.

Defendants admit that venue and jurisdiction are proper in this Court.
III. FACTS

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3.1.

Defendants admit that Defendant Edward Murray entered into an attorney-

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client relationship with Plaintiff in late 2017. To the extent this paragraph contains additional

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allegations, Defendants deny the same.

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3.2.

Defendants respond that the terms of the parties’ engagement letter speak for

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themselves and that no responsive pleading to this paragraph is required. To the extent this

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paragraph contains additional allegations, Defendants deny the same.

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3.3.

Deny.

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IV. FIRST CAUSE OF ACTION

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(Breach of Contract)

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4.1

Defendants reallege and incorporate their responses to paragraphs 1.1 through

3.3 as if restated fully herein.
4.2

This paragraph states a legal conclusion to which no responsive pleading is

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required. To the extent a response is required, Defendants deny the allegations in this

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paragraph.

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V.

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(Quantum Meruit/Unjust Enrichment)

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5.1

SECOND CAUSE OF ACTION

Defendants reallege and incorporate their responses to paragraphs 1.1 through

4.2 as if restated fully herein.

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DEFENDANTS’ ANSWER TO COMPLAINT FOR BREACH OF
CONTRACT, QUANTUM MERUIT/UNJUST ENRICHMENT,
ATTORNEYS’ FEES, COSTS, AND OTHER RELIEF – 2

CORR CRONIN LLP
1001 Fourth Avenue, Suite 3900
Seattle, Washington 98154-1051
Tel (206) 625-8600
Fax (206) 625-0900

 5.2

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This paragraph states a legal conclusion to which no responsive pleading is

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required. To the extent a response is required, Defendants deny the allegations in this

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paragraph.
PRAYER FOR RELIEF

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Defendants deny that Plaintiff is entitled to any relief whatsoever and, therefore,

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denies all allegations in the Prayer for Relief.
AFFIRMATIVE DEFENSES

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In further answer to the Complaint, and as its Affirmative Defenses, Defendants allege

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as follows:

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1.

The Complaint fails to state a claim upon which relief can be granted.

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2.

Plaintiff’s claims are barred by the doctrines of laches, waiver, and/or estoppel.

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3.

Plaintiff’s claims are barred, in whole or in part, by the doctrine of unclean

4.

Plaintiff’s claims relate to legal work that was allegedly performed on

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hands.

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Defendants’ behalf prior to the formation of a formal attorney-client relationship, and

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Plaintiff’s claims are thus barred in whole or in part.

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5.

Plaintiff’s claims relate to legal work that was performed without Defendants’

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authorization and/or not performed at Defendants’ direction, and Plaintiff’s claims are thus

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barred in whole or in part.

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6.

Plaintiff failed to perform its respective duties and obligations under the

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applicable contract between the parties, and Plaintiff is therefore barred from recovery on the

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basis of such contract.

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7.

Defendants reserve the right to assert other affirmative defense as they become

known, based on facts developed during discovery in this action.

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DEFENDANTS’ ANSWER TO COMPLAINT FOR BREACH OF
CONTRACT, QUANTUM MERUIT/UNJUST ENRICHMENT,
ATTORNEYS’ FEES, COSTS, AND OTHER RELIEF – 3

CORR CRONIN LLP
1001 Fourth Avenue, Suite 3900
Seattle, Washington 98154-1051
Tel (206) 625-8600
Fax (206) 625-0900

 PRAYER FOR RELIEF

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Based on the above, Defendants pray that judgment be entered as follows:

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1.

For judgment against Plaintiff dismissing Plaintiff’s claims in their entirety;

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2.

For an award of reasonable attorneys’ fees and costs; and

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3.

For other such relief as the Court deems just and equitable.

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DATED this 3rd day of August, 2018.

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CORR CRONIN LLP

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s/ Kelly H. Sheridan
Steven W. Fogg, WSBA No. 23528
Kelly H. Sheridan, WSBA No. 44746
1001 Fourth Avenue, Suite 3900
Seattle, WA 98154-1051
(206) 625-8600 Phone
(206) 625-0900 Fax
sfogg@corrcronin.com
ksheridan@corrcronin.com
Attorneys for Defendants Edward B. Murray
and Michael Shiosaki

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DEFENDANTS’ ANSWER TO COMPLAINT FOR BREACH OF
CONTRACT, QUANTUM MERUIT/UNJUST ENRICHMENT,
ATTORNEYS’ FEES, COSTS, AND OTHER RELIEF – 4

CORR CRONIN LLP
1001 Fourth Avenue, Suite 3900
Seattle, Washington 98154-1051
Tel (206) 625-8600
Fax (206) 625-0900

 CERTIFICATE OF SERVICE

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The undersigned certifies as follows:
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I am employed at Corr Cronin LLP, attorneys for Defendants Edward B.

Murray and Michael Shiosaki.
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On August 3, 2018, I caused a true and correct copy of the foregoing

document to be served on the following parties in the manner indicated below:
Attorneys for Plaintiff:

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Matthew D. Green, WSBA No. 18046
Elizabeth Hebener Norwood, WSBA No. 40930
GREEN & NORWOOD PLLC
2722 Eastlake Ave E., #350
Seattle, WA 98102
matt@gnlawseattle.com
elizabeth@gnlawseattle.com

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Via Email and E-Service

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I declare under penalty of perjury under the laws of the State of Washington that the
foregoing is true and correct.
DATED: August 3, 2018, at Seattle, Washington.

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s/ Lauren Beers
Lauren Beers

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DEFENDANTS’ ANSWER TO COMPLAINT FOR BREACH OF
CONTRACT, QUANTUM MERUIT/UNJUST ENRICHMENT,
ATTORNEYS’ FEES, COSTS, AND OTHER RELIEF – 5

CORR CRONIN LLP
1001 Fourth Avenue, Suite 3900
Seattle, Washington 98154-1051
Tel (206) 625-8600
Fax (206) 625-0900