WASHINGTON
CIVIL PROCEDURE
DESKBOOK
SECOND EDITION
ABOUT THE EDITORS Hall Baetz, a graduate of the University of Washington Law School, is a partner with the Seattle office of Davis Wright Tremaine. Mr. Baetz concentrates his practice in commercial litigation. Michael E. de Grasse was admitted to the Washington State Bar in 1974. He has been engaged in the private practice of law since that time. He mainly advocates the rights and interests of individuals and small firms in civil and criminal trials and appeals. He has been a sole practitioner in Walla Walla since 1982. His work also includes serving as a neutral arbitrator in labor disputes and mediating a variety of cases. Currently he holds an appointment as Lecturer of English at Whitman College. David R. Goodnight is a partner in the trial, regulatory and technology group of Dorsey & Whitney, LLP. Mr. Goodnight’s practice includes a broad range of civil litigation and appellate work, with an emphasis on corporate defense work involving contract, conspiracy, trade secret, technology, and director and officer liabilities issues. Jill Higgins Hendrix graduated with honors in 1986 from the University of Puget Sound (now Seattle University) School of Law. Ms. Hendrix began private practice at the law firm of Reed McClure. While in private practice, she specialized in municipal defense, products liability, and negligence litigation. She joined the Torts Section of the King County Prosecutor’s Office in 1988 and is a Senior Deputy Prosecuting Attorney. Ms. Hendrix has represented the county in major damage cases involving quadriplegia and death. She also serves as the lead medical malpractice lawyer for the Seattle-King County Health Department. Ms. Hendrix frequently advises colleagues on trial practice issues and gives in-house practice seminars. She is also a frequent lecturer for the Washington Association of Prosecuting Attorneys and has been a National College of District Attorneys faculty member since 1991. Jan C. Kirkwood is a member of Williams, Kastner & Gibbs, PLLC. Ms. Kirkwood is a litigator whose practice focuses on defending manufacturers in product liability actions and representing businesses in commercial and tort litigation in state and federal courts. She has also served as an arbitrator in a number of mandatory arbitration cases. Ms. Kirkwood is a member of the Washington State Bar Association, Oregon State Bar Association, King County Bar Association, and Defense Research Institute. She is a 1980 graduate of Seattle University Law School. Joseph C. Klein is an associate in the trial, regulatory and technology group of Dorsey & Whitney, LLP. Mr. Klein’s practice centers around complex commercial litigation, with special focus on antitrust and technology litigation. Stephen P. Larson is a shareholder in the Seattle law firm of Stafford Frey Cooper. He is a graduate of St. Lawrence University and Willamette University College of Law, where he served as an editor of the Willamette Law Journal. After graduation from law school, he served as a law clerk to Judge Robert Y. Thornton of the Oregon Court of Appeals. Mr. Larson is a member of the Washington Defense trial Lawyers Association and Defense Research Institute. John R. Nelson is a partner in the Spokane office of Preston Gates & Ellis, LLP. He served as a law clerk to the Hon. Alan A. McDonald and the Hon. Justin L. Quackenbush in the United States District Court for the Eastern District of Washington from 1988 to 1990. He litigates a broad range of commercial, employment, and environmental cases, principally in federal court. He has served on the Executive Committee of the WSBA Litigation Section since 1998, and is presently serving as Chair-Elect of the Committee.
Michael H. Runyan is a partner in Lane Powell Spears Lubersky. He is a Director of the Defense Research Institute and former President of the Washington Defense Trial Lawyers. He is a member of the American Board of Trial Advocates, Federation of Insurance and Corporate Counsel, and the Association of Defense Trial Attorneys. His practice includes defense of product liability, toxic tort, and insurance coverage cases. He is a cum laude graduate of the University of Michigan Law School. Gretchen Graham Salazar is an attorney with the Seattle firm of Mills Meyers Swartling. Her practice focuses on employment counseling and litigation. She is a member of the King County, Washington State, and American Bar Associations, and the labor and employment law sections of each. She graduated summa cum laude and first in her class from Seattle University School of Law in 1996, where she was also Editor-in-Chief of the Seattle University Law Review. Ann-Marie Schwartz is a litigation attorney with the Law Offices of Michael E. Schwartz and a graduate of the University of Washington (1991, with honors). She graduated magna cum laude from Seattle University Law School (1996) where she was an Associate Editor of the Seattle University Law Review and published an article, 19 SEATTLE U. L. REV. 385 (1996). From 1996 to 1999, Ms. Schwartz worked as an associate with Bogle & Gates P.L.L.C., where her practice focused on complex commercial litigation and white collar criminal defense. From 1999 to 2001, she worked as an associate with McNaul, Ebel, Nawrot, Helgren & Vance, where her practice emphasized class action litigation. She is a CJA appellate panel member and has lectured on the topic of false confessions in connection with her work as a member of the Innocence Project Northwest. David D. Swartling is a principal in the Seattle firm of Mills Meyers Swartling. He is a graduate of Princeton University and the University of Washington Law School, where he served as Executive Editor of the law review. For more than 25 years, his practice has focused on product liability, aviation, municipality and commercial litigation. Mr. Swartling organized the first litigation skills training course offered by the Washington State Bar Association and served as Program Administrator for the awardwinning skills training course. For these efforts, he received the Harrison Tweed Award from the American Law Institute-American Bar Association in 1990. Mr. Swartling served on the Executive Committee of the Litigation Section of the Washington State Bar Association and was Chairperson in 1992-93. He has served as Editor-in-Chief of the Washington Civil Procedure Deskbook since 1990. Mr. Swartling is a Fellow of the American College of Trial Lawyers.