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FILED

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2020 SEP 17 09:00 AM
KING COUNTY
SUPERIOR COURT CLERK
E-FILED
CASE #: 20-2-13966-1 SEA

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

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AMY CARNELL,
No.

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Plaintiff,
COMPLAINT FOR DAMAGES
v.
MICHAEL KOSLOSKY, an Individual,
SOUND FOOTBALL CLUB f/k/a/
NORTHWEST NATIONALS, a
Washington Non-Profit Corporation, and
THE WASHINGTON STATE YOUTH
SOCCER ASSOCIATION, a Washington
Corporation,

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Defendants.

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I.
1.1.

INTRODUCTION

This case concerns the failure of organized sports to protect young athletes from

predatory coaches. Northwest Nationals’ Coach, Michael Koslosky – trusted by generations of
parents – groomed and sexually abused Amy Carnell, beginning when she was 13. Even when

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Washington Youth Soccer (WYS) learned that Koslosky had Carnell alone in a hotel room for

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an out-of-state soccer tournament, WYS did not take action to protect her.

COMPLAINT FOR DAMAGES 1

SCHROETER GOLDMARK & BENDER
810 Third Avenue ● Suite 500 ● Seattle, WA 98104
Phone (206) 622-8000 ● Fax (206) 682-2305

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1.2.

For nearly two decades, Carnell blocked out memories of the abuse she

endured. It was not until the summer of 2019 that Carnell realized what happened.
1.3.

The following spring, in April of 2020, Carnell contacted WYS, hoping she

could work with WYS leadership to protect the next generation of kids from grooming and

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abuse. WYS did not respond to her inquiries.
1.4.

Shortly after Carnell contacted WYS, Koslosky reached out to Carnell and

admitted what he’d done:

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COMPLAINT FOR DAMAGES 2

SCHROETER GOLDMARK & BENDER
810 Third Avenue ● Suite 500 ● Seattle, WA 98104
Phone (206) 622-8000 ● Fax (206) 682-2305

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II.

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2.1.

PARTIES & JURISDICTION

Plaintiff Amy Carnell, now age 36, resides in Seattle in King County,

Washington.
2.2.

Defendant Michael Koslosky, now age 62, resides in Montlake Terrace in

Snohomish County, Washington. Koslosky coached girls’ soccer for Defendants WYS and
Northwest Nationals for two decades or more.
2.3.

Defendant The Washington State Youth Soccer Association (WYS) is a public

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benefit corporation, registered in the State of Washington. WYS conducts business throughout

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Washington, with its principal office located in Tukwila, King County.

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2.4.

Non-Profit Corporation, registered in the State of Washington.
2.5.

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member” of WYS.
III.
3.1.

JURISDICTION AND VENUE

Jurisdiction and venue are proper in King County Superior Court under RCW

4.12.020 and RCW 2.08.010 because WYS’s principal office is located in King County.

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In the late 90s and early 2000s, the select girls soccer team, “Stellarz” was part

of the Northwest Nationals club. At the time, Northwest Nationals described itself as a “proud

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Defendant Sound Football Club, f/k/a/ Northwest Nationals, is a Washington

IV.

STATEMENT OF FACTS

4.1.

From the time she was 6 years old, Carnell loved playing soccer.

4.2.

In the summer of 1997, just before starting eighth grade, Carnell tried out for

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the “Stellarz” soccer team. She was 13.
4.3.

For Carnell, playing for a team like Stellarz was a step toward college

recruitment and beyond. She was thrilled when she made the team.

COMPLAINT FOR DAMAGES 3

SCHROETER GOLDMARK & BENDER
810 Third Avenue ● Suite 500 ● Seattle, WA 98104
Phone (206) 622-8000 ● Fax (206) 682-2305

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4.4.

Koslosky was the Stellarz’ head coach. He had coached with WYS for a decade

or more. He was an unmarried man, then age 40.
4.5.

Koslosky adopted a goofy, friendly demeanor with the girls and used it to

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develop rapport with them and their parents. He boasted at having coached a girl who went on
to play professionally and told his team that if they wanted to play competitively, they needed
to call him and arrange for extra (one-on-one) training sessions.
4.6.

As soon as Carnell joined the team, Koslosky identified her as a target for

grooming. That fall, Koslosky started driving Carnell home from soccer practice and to some
games as a supposed favor to Carnell’s mom, who worked full-time and was glad for the help.
On these trips, he would lavish Carnell with praise, tease and flirt with her, and use the time to
learn about her vulnerabilities, including a desire for a father figure. A few months in, he told
her God brought them together and that she was an “angel.” He made her mixed tapes of music.

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COMPLAINT FOR DAMAGES 4

SCHROETER GOLDMARK & BENDER
810 Third Avenue ● Suite 500 ● Seattle, WA 98104
Phone (206) 622-8000 ● Fax (206) 682-2305

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4.7.

After Koslosky had established trust with Carnell, he threatened to quit the team

if she and other players did not show him sufficient dedication. Carnell felt responsible to keep
the team together and pled for him to stay. This cycle of manipulation repeated itself over and
over in the years to come.

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4.8.

Koslosky continued grooming Carnell through

1998. In the fall of that year, Koslosky told Carnell (now age

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14) her talent would be wasted playing high school soccer. He

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insisted if she wanted to be a star, she’d need to train with him.

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Trusting the coach, Carnell’s mom and step-dad agreed. After

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training sessions, which often included “fitness hikes” on
remote mountain trails, Koslosky treated Carnell to meals out,
where he invoked God to explain their “special” connection. Alone with her, he gradually

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moved from massaging her shoulders to rubbing her legs and thighs; he fixed his gaze on

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Carnell until she blushed; he called her at home and spoke with her for hours; he gave Carnell

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notes and cards; typed-up song lyrics; and bought her gifts, including angel-themed trinkets –

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a reference to his “angel” nickname for her.

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4.9.

In 1999, Koslosky escalated the abuse and manipulation. He suggested to

Carnell that life was short and that, in heaven, they could be together. He told her he loved her.
When Carnell did not give Koslosky the attention he wanted, he would act hurt or threaten to
quit coaching. Carnell began to suffer through bouts of depression.
4.10.

That summer, the Stellarz team traveled to California to play in a tournament

and watch the Women’s World Cup. Once there, Koslosky manipulated the team’s plans so he

COMPLAINT FOR DAMAGES 5

SCHROETER GOLDMARK & BENDER
810 Third Avenue ● Suite 500 ● Seattle, WA 98104
Phone (206) 622-8000 ● Fax (206) 682-2305

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could take Carnell alone on a hike with him to Joshua Tree National Park. He pushed physical

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boundaries to include hand-holding, hugging, and caressing. He took pictures of her:

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4.11.

Koslosky found more ways to be alone with Carnell. A month after their return

from California, in August 1999, Koslosky organized a camping trip with several of the

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Stellarz players. Once the adult chaperone and other players were in their tents sleeping,
Koslosky led Carnell far away from the campsite where he kissed and groped her breasts,
pressed his erect penis against her, and digitally penetrated her vagina.
4.12.

From this point forward, Koslosky abused Carnell every time he got her alone,

sometimes weekly. Most of the time, he forced Carnell to masturbate him or he rubbed against
her until he ejaculated. He invoked God and the need to keep the team together as ways to keep
Carnell quiet about the abuse.
4.13.

When Carnell decided to play with her high school team her sophomore year,

Koslosky remained present in her life, sitting with Carnell’s parents during games, calling her

COMPLAINT FOR DAMAGES 6

SCHROETER GOLDMARK & BENDER
810 Third Avenue ● Suite 500 ● Seattle, WA 98104
Phone (206) 622-8000 ● Fax (206) 682-2305

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often, and taking her on “fitness hikes” on weekends. He reminded her that God could take

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him away at any time.

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4.14.

Sometime in November 1999, Koslosky hired Carnell to do work around his

properties on weekends. He convinced Carnell’s parents he would pay better than any fast-

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food gig and that he could train Carnell before or after work. During this time, Koslosky gave
Carnell a ring and suggested they get married when she turned “legal” (age 16). Alone with
her at his property, he abused her repeatedly. Carnell was confused, ashamed, and depressed.
4.15.

In 2000, after she turned 16, Carnell took and passed a driver’s test. She began

driving herself to soccer practice and games, avoiding Koslosky as much as she could. Still,
he used his position as the Stellarz coach to get her alone.
4.16.

That summer, the team had another soccer tournament in California. Koslosky

convinced Carnell’s parents they should save their money on plane fare and allow him to drive

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Carnell in a caravan with other players and parents. But rather than meet up with the other

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families in Oregon as planned, Koslosky took Carnell to a hotel room far away from the rest

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of the players and abused her.

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COMPLAINT FOR DAMAGES 7

SCHROETER GOLDMARK & BENDER
810 Third Avenue ● Suite 500 ● Seattle, WA 98104
Phone (206) 622-8000 ● Fax (206) 682-2305

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4.17.

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When the team met up in California, some of the parents realized Koslosky and

Carnell had been alone together on the drive down. One father brought his concerns to the
assistant coach and other parents, but each dismissed him, with variations of “Mike is a great
coach” or “Mike is a good guy.” With that, Koslosky had Carnell back into his car for the trip

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home, giving him the opportunity to abuse her again.
4.18.

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police, did not make a call to Child Protective Services, and took no other action to separate
Koslosky from Carnell or the other girls. The team’s assistant coach likewise did nothing.

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Meanwhile, another parent called WYS about Koslosky. WYS did not alert the

4.19.

At the time, neither WYS nor Northwest Nationals had implemented policies

or practices for protecting players from abuse nor did they have protocols for how to respond
to reports of such incidents.
4.20.

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WYS’s sole action was to call Carnell’s mom, to confirm whether she knew

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about the “carpool” to California. She of course knew about the trip, but worried the caller was

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implying something else. Carnell was still on the drive home from California, but when Carnell

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called to check in, her mom told Koslosky about WYS’s call and asked him to drive straight

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home.

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4.21.

Koslosky spent the next twelve hours in the car coaching Carnell on what to say

(and what not to say); he told her his life and hers would be over if anyone found out; he told
her she would lose everything, including sports scholarships and the chance to play in college.

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Once home, Carnell’s mom and step-dad spoke with Koslosky while Carnell waited upstairs

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in her bedroom. Koslosky convinced Carnell’s parents there had been a huge misunderstanding

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and that it was probably a rumor started by one of the other players who was jealous of
Carnell’s talent. Carnell corroborated Koslosky’s story, just as he’d instructed.

COMPLAINT FOR DAMAGES 8

SCHROETER GOLDMARK & BENDER
810 Third Avenue ● Suite 500 ● Seattle, WA 98104
Phone (206) 622-8000 ● Fax (206) 682-2305

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4.22.

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quitting soccer, even though college recruiters had started to take an interest in her.

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Carnell felt tremendous pressure to keep the team together. She thought about

4.23.

Sometime in late summer of 2000, Koslosky isolated Carnell again and tried to

touch her, but this time, she pushed him away and said “no.” When she did, Koslosky

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threatened to kill himself and sobbed uncontrollably. Carnell was terrified. For the rest of 2000,
Carnell drove herself to practices and games and tried to avoid Koslosky.
4.24.

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In early 2001, after several months without any abuse, Koslosky reached out to

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Carnell to ask if they could be “friends.” She agreed to see him at his house. He lured her inside

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and abused her again.

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4.25.

Koslosky continued to coach the Stellarz team until sometime in 2002.

4.26.

Carnell blocked out memories of the abuse for nearly two decades. Despite

having a loving family, a career, and loyal friends, she struggled on and off with depression.

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She felt incapable of having a healthy romantic relationship. In 2018, she considered ending

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her life.

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4.27.

June, Carnell watched a movie that featured childhood sexual abuse. Memories of Koslosky
returned and flooded her mind. For the first time, she connected the abuse from her childhood
to the suffering in her adulthood.
4.28.

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Later in 2019, Carnell learned she was not the first soccer player Koslosky had

groomed.
4.29.

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In the summer of 2019, Carnell decided to take a break from her career. That

In April of 2020, Carnell reached out to WYS. She invited WYS to work with

her on adopting better policies and practices to protect kids from abuse. WYS ignored her
letters.

COMPLAINT FOR DAMAGES 9

SCHROETER GOLDMARK & BENDER
810 Third Avenue ● Suite 500 ● Seattle, WA 98104
Phone (206) 622-8000 ● Fax (206) 682-2305

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4.30.

Shortly after Carnell contacted WYS, Koslosky texted Carnell and admitted to

the abuse.

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V.
5.1.

LIABILITY

Based on the above, Carnell alleges that Koslosky is liable for assault, battery,

negligent infliction of emotional distress; outrage; and sexual assault and exploitation in
violation of RCW 9.68A.
5.2.

Based on the above, Carnell alleges that WYS and Northwest Nationals are

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liable at common law, including for negligent hiring, retention, and supervision of coaches,

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including Koslosky; negligent infliction of emotional distress; and negligent failure to adopt

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policies and practices to guard against sexual abuse of minor soccer players, for example, by

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prohibiting one-on-one contact between coaches and players and educating parents and athletes
about grooming.
5.3.

Based on the above, Carnell further alleges that WYS and Northwest Nationals

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committed an unfair practice under RCW 49.60.215, depriving Carnell of her full enjoyment

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of services, including sport and recreation.

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5.4.

As a result of Defendants’ actions described above, Carnell has suffered and

continues to suffer severe emotional distress, mental anguish, and other general and special
damages.

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VI.

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6.1.

Plaintiff demands this action be tried to a jury.
VII. PRAYER FOR RELIEF

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JURY DEMAND

7.1.

Plaintiff Amy Carnell asks for judgment against Defendants in an amount of

damages to be proven at trial, attorneys’ fees and costs pursuant to RCW 49.60.030 and RCW

COMPLAINT FOR DAMAGES 10

SCHROETER GOLDMARK & BENDER
810 Third Avenue ● Suite 500 ● Seattle, WA 98104
Phone (206) 622-8000 ● Fax (206) 682-2305

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9.68A.130, injunctive relief against Defendants in the form of enhanced protections for youth

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soccer players, and other relief as the Court deems just.

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DATED this 17th day of September, 2020.

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SCHROETER, GOLDMARK & BENDER

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___________________________________
LINDSAY L. HALM, WSBA #37141
RICHARD L. ANDERSON, WSBA #25115
THOMAS J. BREEN, WSBA #34574

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COMPLAINT FOR DAMAGES 11

SCHROETER GOLDMARK & BENDER
810 Third Avenue ● Suite 500 ● Seattle, WA 98104
Phone (206) 622-8000 ● Fax (206) 682-2305