Lawsuit Filed Against Cedar Grove Composting

COMPLAINT - 2

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413 Eighth Street

Hoquiam, WA 98550 ST RITM ATT ER KE SSL E R WHE L AN COL UCCI O Tel: 360-533-2710

BURLEIGH AND CHRISTINE BURLEIGH, HUSBAND AND WIFE; BRIAN CHERRY AND SUSAN CHERRY, HUSBAND AND WIFE; CONNOR CHERRY AND GRIFFIN CHERRY, MINORS, BY AND THROUGH BRIAN CHERRY; PETE CLOE AND SHIRLEY CLOE, HUSBAND AND WIFE; JIM CORNER AND PAULA CORNER, HUSBAND AND WIFE; JANET CORP, A SINGLE WOMAN; GEORGE COX AND PEGGY COX, HUSBAND AND WIFE; THOMAS CYR AND DIANA CYR, HUSBAND AND WIFE; CHELSEA CYR AND HALEY CYR, MINORS, BY AND THROUGH THOMAS CYR; PATRICK DALY AND LEANNA DALY, HUSBAND AND WIFE; JORDAN DALY, A SINGLE MAN; GARIN DALY, A SINGLE MAN; GENEVIEVE DALY, MINOR, BY AND THROUGH GARIN DALY; DOUG DARLINGTON AND KRISTI DARLINGTON, HUSBAND AND WIFE; DALTON DARLINGTON, A SINGLE MAN; PEYTON DARLINGTON, MINOR, BY AND THROUGH KRISTI DARLINGTON; DAVID DENNISON AND JILL DENNISON, HUSBAND AND WIFE; KYLE DENNISON, A SINGLE MAN; EMILY DENNISON, A SINGLE WOMAN; CHAUNCEY DESCHENES AND JO ESTA DESCHENES, HUSBAND AND WIFE; TERRY DESCHENES AND RITA DESCHENES, HUSBAND AND WIFE; SCOTT DOBROWOLSKI AND JANET DOBROWOLSKI, HUSBAND AND WIFE; JOSEPH DOBROWOLSKI, A SINGLE MAN; NATHAN DOBROWOLSKI, A SINGLE MAN; K. MICHAEL DRESEL, A SINGLE MAN; DONA VON BARGEN, A SINGLE WOMAN; ELLEN DRESEL, A SINGLE WOMAN; KAREN DRESEL, A SINGLE WOMAN; DONALD DUKE AND HELEN DUKE, HUSBAND AND WIFE; CHRIS DUKELOW, A SINGLE MAN; TOBY TURLAY, A SINGLE WOMAN; TRYGVE DUKELOW, KYLE DUKELOW,

COMPLAINT - 3

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AND SYDNEY DUKELOW, MINORS, BY AND THROUGH CHRIS DUKELOW; ALEXANDRA HOFER AND GABRIELLA HOFER, MINORS, BY AND THROUGH TOBY TURLAY; GARY DUKELOW AND LINDA DUKELOW, HUSBAND AND WIFE; MICHELE FISHER, A SINGLE WOMAN; NOLAN FISHER AND BRIANNA FISHER, MINORS, BY AND THROUGH MICHELE FISHER; KELLY GARBER AND DEBBIE GARBER, HUSBAND AND WIFE; JAMES GEORGE AND SUSAN GEORGE, HUSBAND AND WIFE; MATTHEW GEORGE AND KIM GEORGE, HUSBAND AND WIFE; KYLE GEORGE, MINOR, BY AND THROUGH MATTHEW GEORGE; ROBERT CLARK, A SINGLE MAN; LINDA GODFREY, A SINGLE WOMAN; JARON IWAKAMI, A SINGLE MAN; KAYLA IWAKAMI, A SINGLE WOMAN; TERESA GORNEY-HAAG, A SINGLE WOMAN; RANDY HAAG AND TRAVIS HAAG, MINORS, BY AND THROUGH TERESA GORNEY-HAAG; JULIE GOZA, A SINGLE WOMAN; ALLISON GOZA, MINOR, BY AND THROUGH JULIE GOZA; DENNIS GRIFFIN AND ROSALIE GRIFFIN, HUSBAND AND WIFE; TODD HALFON AND SHERRI HALFON, HUSBAND AND WIFE; NATE HALFON, MINOR, BY AND THROUGH SHERRI HALFON; JAMES CANADY, A SINGLE MAN; DEBRA HAWKINS, A SINGLE WOMAN; BAILEE HAWKINS, MINOR, BY AND THROUGH DEBRA HAWKINS; JAMES HERSHEY, A SINGLE MAN; MARK HEINZEN AND PAMELA HEINZEN, HUSBAND AND WIFE; ELIZABETH HOLMBERG, A SINGLE WOMAN; ANDERS HOLMBERG, A SINGLE MAN; AARON HOLMLUND AND MICHELLE HOLMLUND, HUSBAND AND WIFE; LISA HUNTLEY, A SINGLE WOMAN; JAMES HUNTLEY, MINOR, BY AND THROUGH LISA HUNTLEY; JANSON IWAKAMI, A

COMPLAINT - 4

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SINGLE MAN; DEBRA JAGERMAN, A SINGLE WOMAN; SCOTT DUNGAN, A SINGLE MAN; RICHARD JAMES AND GLORIA JAMES, HUSBAND AND WIFE; ROGER JONES AND PAT JONES, HUSBAND AND WIFE; JOHN KALMBACH AND WENDY KALMBACH, HUSBAND AND WIFE; BRANDI KALMBACH, MINOR, BY AND THROUGH JOHN KALMBACH; JOLENE D. KALMBACH, A SINGLE WOMAN; FRECIA KELLY, A SINGLE WOMAN; RICHARD NIEMAN, A SINGLE MAN; ROLAND KLIX AND DOROTHY KLIX, HUSBAND AND WIFE; EDWARD KNEBEL, A SINGLE MAN; PATRICIA LOPACINSKI, A SINGLE WOMAN; SEAN KRONBERG AND TRACEY KRONBERG, HUSBAND AND WIFE; ANNIKA KRONBERG, MINOR, BY AND THROUGH SEAN KRONBERG; JEROLD KUTZKE AND LISA KUTZKE, HUSBAND AND WIFE; OLIVIA KUTZKE AND JOSHUA KUTZKE, MINORS, BY AND THROUGH JEROLD KUTZKE; DONN LANSING, A SINGLE MAN; MARC LECOQ AND LISA LECOQ, HUSBAND AND WIFE; ROBERT LIEBLING AND SUSAN LIEBLING, HUSBAND AND WIFE; MICHAEL LUEDKE AND HEATHER LUEDKE, HUSBAND AND WIFE; JONAH LUEDKE AND ELISE LUEDKE, MINORS, BY AND THROUGH MICHAEL LUEDKE; ELIZABETH MARSHALL, A SINGLE WOMAN; STEPHANIE MAYO, A SINGLE WOMAN; BEN COYNE, A SINGLE MAN; OLIVIA COYNE, MINOR, BY AND THROUGH BEN COYNE; WILLIAM MCGAHEY AND MARY MCGAHEY, HUSBAND AND WIFE; DEMARCUS MONTE AND RACHEL MONTE, HUSBAND AND WIFE; KRISTEL MONTE, A SINGLE WOMAN; BRET MONTE, A SINGLE MAN; AVA MONTE, MINOR, BY AND THROUGH KRISTEL MONTE; PATRICK MORFORD

COMPLAINT - 5

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AND STACY MORFORD, HUSBAND AND WIFE; GRACE MORFORD AND RYAN MORFORD, MINORS, BY AND THROUGH STACY MORFORD; LESLIE MORGAN, A SINGLE WOMAN; CURTIS GREEN, A SINGLE MAN; STUART GRAYSON AND JACQUELINE GREEN, HUSBAND AND WIFE; TODD MORTON AND DEBORAH MORTON, HUSBAND AND WIFE; ASHLYN MORTON, A SINGLE WOMAN; AMANDA MORTON, A SINGLE WOMAN; SHAWN MULQUEENEY AND KARA MULQUEENEY, HUSBAND AND WIFE; KIANA MULQUEENEY, TAYLOR MULQUEENEY, AND SHEA MULQUEENEY, MINORS, BY AND THROUGH KARA MULQUEENEY; STEPHAN NEPSA AND SATINA NEPSA, HUSBAND AND WIFE; ZOE NEPSA, ASPEN NEPSA, AND ENZO NEPSA, MINORS, BY AND THROUGH STEPHAN NEPSA; CHARLES NEVI AND KAREN NEVI, HUSBAND AND WIFE; DENNIS NUGENT AND JANET NUGENT, HUSBAND AND WIFE; JAMIE NUGENT, A SINGLE WOMAN; JORDAN NUGENT, A SINGLE WOMAN; JOHN O'DAY AND CATHERINE O'DAY, HUSBAND AND WIFE; BRENDAN PECHT AND JOJI PECHT, HUSBAND AND WIFE; JAN PELROY AND HELGA PELROY, HUSBAND AND WIFE; RANDY PESCHEK AND DAWN PESCHEK, HUSBAND AND WIFE; ALLISON PESCHEK AND SARAH PESCHEK, MINORS, BY AND THROUGH RANDY PESCHEK; TOM PFEIFFER AND JENNIFER PFEIFFER, HUSBAND AND WIFE; MATTHEW PFEIFFER, MINOR, BY AND THROUGH TOM PFEIFFER; STEPHANIE PFEIFFER, A SINGLE WOMAN; ROCHELLE PFEIFFER, A SINGLE WOMAN; ALEXANDER PISHUE AND JESSE PISHUE, HUSBAND AND WIFE; LYLA PISHUE AND GRACIE

COMPLAINT - 6

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PISHUE, MINORS, BY AND THROUGH JESSE PISHUE; DAVID PROCHAZKA AND DIAN PROCHAZKA, HUSBAND AND WIFE; RION RAU AND AMY RAU, HUSBAND AND WIFE; MADISEN RAU AND EMILY RAU, MINORS, BY AND THROUGH RION RAU; RICHARD REININGER AND LINDA REININGER, HUSBAND AND WIFE; BRENT REININGER, A SINGLE MAN; HILLARY REININGER, A SINGLE WOMAN; STEVE WILSON, A SINGLE MAN; KELSEY WILSON, A SINGLE WOMAN; DUANE RICE AND EDITH RICE, HUSBAND AND WIFE; ANNALEE ROTHENBERG, A SINGLE WOMAN; ERIC DURBAN, A SINGLE MAN; ASHLEY SAUNDERS, A SINGLE MAN; GARY SCHIMKE AND SHARON SCHIMKE, HUSBAND AND WIFE; KEVIN SCOTT AND BECKY SCOTT, HUSBAND AND WIFE; EVELYN SCOTT AND HENRY SCOTT, MINORS, BY AND THROUGH BECKY SCOTT; RICHARD SCOTT AND HELEN SCOTT, HUSBAND AND WIFE; LINDA SHEPHERD, A SINGLE WOMAN; DELAINY STRITTMATTER AND JODI STRITTMATTER, HUSBAND AND WIFE; JORDAN STRITTMATTER AND SIDNEY STRITTMATTER, MINORS, BY AND THROUGH DELAINY STRITTMATTER; ERROL SWEENEY-EASTER AND KATHY SWEENEY-EASTER, HUSBAND AND WIFE; PATRICK SWEENEY-EASTER, A SINGLE MAN; SEAN SWEENEY-EASTER, A SINGLE MAN; DAN TAYLOR, A SINGLE MAN; ROBERT THOMPSON AND DANA THOMPSON, HUSBAND AND WIFE; DAVID TONER AND DEENA TONER, HUSBAND AND WIFE; DARREN TREMBLAY AND KELSEY TREMBLAY, HUSBAND AND WIFE, EMMA TREMBLAY AND RYDER TREMBLAY, MINORS, BY AND THROUGH KELSEY TREMBLAY RICHARD TUCKER AND PAMELA

COMPLAINT - 7

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TUCKER, HUSBAND AND WIFE; APRIL TUCKER, A SINGLE WOMAN; AMY LYN TUCKER, A SINGLE WOMAN; DENISE VANCE, A SINGLE WOMAN; KEVIN VIGEN AND SANDY VIGEN, HUSBAND AND WIFE; ASHLEY VIGEN, A SINGLE WOMAN; JOHN VILLA AND LINDA VILLA, HUSBAND AND WIFE; CARL WAGNER AND SANDRA WAGNER, HUSBAND AND WIFE; SCOTT WAGNER AND HANNAH WAGNER, MINORS, BY AND THROUGH SANDRA WAGNER; KELLY WALSHE AND BARBARA WALSHE, HUSBAND AND WIFE; BELLA WALSHE AND MILLER WALSHE, MINORS, BY AND THROUGH KELLY WALSHE; NICOLE BENSON, A SINGLE WOMAN; LANGSTON FORD AND LATTIMORE FORD, MINORS, BY AND THROUGH NICOLE BENSON; WILLIAM WARD AND MURIEL WARD, HUSBAND AND WIFE; BENJAMIN WARD, A SINGLE MAN; ALISHA WARD, A SINGLE WOMAN; WHITNEY BASCOM, A SINGLE WOMAN; MARC BASCOM, A SINGLE MAN; ROBERT WITTENBERG AND THERESA WITTENBERG, HUSBAND AND WIFE; RACHEL WITTENBERG, JACOB WITTENBERG, AND REEVE WITTENBERG, MINORS, BY AND THROUGH ROBERT WITTENBERG; KURT WOODARD AND SANDIE WOODARD, HUSBAND AND WIFE; MADISON WOODARD AND COLE WOODARD, MINORS, BY AND THROUGH KURT WOODARD; BERNARD WRIGHT AND SUSAN WRIGHT, HUSBAND AND WIFE; AND LEONARD ZITZER, A SINGLE MAN, Plaintiffs, v. CEDAR GROVE COMPOSTING, INC., A CORPORATION,

COMPLAINT - 8

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Defendant.

I. INTRODUCTION

1. Plaintiffs are individuals with property and possessory interests and are residents of King

County, Washington.

2. Plaintiffs bring this action for monetary damages against Cedar Grove Composting, Inc.

(hereafter referred to as “Cedar Grove”) arising out of Cedar Grove’s tortious conduct

and operation of its commercial composting facility (hereafter referred to as “Cedar

Grove Facility”) located in Maple Valley, King County, Washington.

3. Cedar Grove’s operations have created a nuisance through the recurrent off-site

emissions of noxious odors. As a proximate consequence of Cedar Grove’s tortious

conduct, Plaintiffs have suffered, and will continue to suffer, damages including, but not

limited to: (1) the loss of use and enjoyment of their properties; (2) substantial and

unreasonable interference with the quiet use and enjoyment of their property; and, (3)

annoyance, inconvenience and substantial personal discomfort.

II. PARTIES

4. Plaintiffs Catherine and Dionicio Avila, own and resides at property located at 15601

258th Place SE in Issaquah, King County, Washington.

5. Plaintiffs Nick Anton and Shelly Anton, husband and wife, Plaintiff Tyler Anton, a single

man, and Minor Plaintiff Brock Anton, by and through Nick Anton, own and reside at

property located at 16829 234th Way SE in Maple Valley, King County, Washington.

6. Plaintiffs Chuck Arnold and Jana Arnold, husband and wife, and Minor Plaintiffs Charlie

COMPLAINT - 9

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Arnold and Jordan Arnold, by and through Jana Arnold, own and reside at property

located at 16009 204th Pl. SE in Renton, King County, Washington.

7. Plaintiffs Michael Balderson and Sherrie Balderson, husband and wife, own and reside at

property located at 14857 204th Ave. SE in Renton, King County, Washington.

8. Plaintiffs Robert Balderson and Lynne Balderson, husband and wife, own and reside at

property located at 14913 - 175th Avenue SE in Renton, King County, Washington.

9. Plaintiffs Richard Beaudry and Dianne Beaudry, husband and wife, own and reside at

property located at 23323 SE 169th St. in Maple Valley, King County, Washington.

10. Plaintiffs Jason Bernritter and Kathleen Bernritter, husband and wife, own and reside at


11. Plaintiffs Paul Beuter and Sheila Beuter, husband and wife, and Minor Plaintiffs Carl

Beuter and Audrey Beuter, by and through Paul Beuter, own and reside at property

located at 14701 206th Ave. SE in Renton, King County, Washington.

12. Plaintiff Wayne Bingham, a single man, owns and resides at property located at 16727

239th Ave. SE in Issaquah, King County, Washington.

13. Plaintiffs Michael Blue and Cindy Blue, husband and wife, Plaintiff Hannah Blue, a

single woman, and Minor Plaintiffs Marie Blue, and Grace Blue, by and through Michael

Blue, own and reside at property located at 15032 205th Ave. SE in Renton, King

County, Washington.

14. Plaintiffs Jerome Boldrin and Pamela Boldrin, husband and wife, own and reside at

property located at 20616 SE 147th St. in Renton, King County, Washington.

15. Plaintiffs Chris Burleigh and Christine Burleigh, husband and wife, own and reside at

property located at 14519 – 205th Ave SE in Renton, King County, Washington.

COMPLAINT - 10

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16. Plaintiffs Brian Cherry and Susan Cherry, husband and wife, and Minor Plaintiffs Connor

Cherry and Griffin Cherry, by and through Brian Cherry, own and reside at property

located at 20553 SE 158th St. in Renton, King County, Washington.

17. Plaintiffs Pete Cloe and Shirley Cloe, husband and wife, own and reside at property

located at 15718 - 207th Pl. SE in Renton, King County, Washington.

18. Plaintiffs Jim Corner and Paula Corner, husband and wife, own and reside at property

located at 20334 SE 145th in Renton, King County, Washington.

19. Plaintiff Janet Corp, a single woman, owns and resides at property located at 14604 205th

Ave. SE in Renton, King County, Washington.

20. Plaintiffs George Cox and Peggy Cox, husband and wife, own and reside at property

located at 16530 237th Ave. SE in Issaquah, King County, Washington.

21. Plaintiffs Thomas Cyr and Diana Cyr, husband and wife, and Minor Plaintiffs Chelsea

Cyr and Haley Cyr, by and through Thomas Cyr, own and reside at property located at

14642 203rd Ave. SE in Renton, King County, Washington.

22. Plaintiffs Patrick Daly and Leanna Daly, husband and wife, Plaintiff Jordan Daly, a

single man, Plaintiff Garin Daly, a single man, and Minor Plaintiff Geneveive Daly, by

and through Garin Daly, own and reside at property located at 20605 SE 159th St. in

Renton, King County, Washington.

23. Plaintiffs Doug Darlington and Kristi Darlington, husband and wife, Plaintiff Dalton

Darlington, a single man, and Minor Plaintiff Payton Darlington, by and through Kristi

Darlington, own and reside at property located at 16940 - 234th Way SE in Maple

Valley, King County, Washington.

24. Plaintiffs David Dennison and Jill Dennison, husband and wife, Plaintiff Emily

COMPLAINT - 11

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Dennison, a single woman, and Plaintiff Kyle Dennison, a single man, own and reside at

property located at 20141 SE 145th St in Renton, King County, Washington.

25. Plaintiffs Chauncey Deschenes and Jo Esta Deschenes, husband and wife, own and reside

at property located at 16435 239th Ave SE in Issaquah, King County, Washington.

26. Plaintiffs Terry Deschenes and Rita Deschenes, husband and wife, own and reside at

property located at 16419 239th Ave SE in Issaquah, King County, Washington.

27. Plaintiffs Scott Dobrowolski and Janet Dobrowolski, husband and wife, Plaintiff Joseph

Dobrowolski, a single man, and Plaintiff Nathan Dobrowolski, a single man, own and

reside at property located at 21003 SE 155th Pl. in Renton, King County, Washington.

28. Plaintiff K. Michael Dresel, a single man, Plaintiff Donna Von Bargen, a single woman,

Plaintiff Ellen Dresel, a single woman, and Plaintiff Karen Dresel, a single woman, own

and reside at property located at 20512 SE 158th St. in Renton, King County,

Washington.

29. Plaintiffs Donald Duke and Helen Duke, husband and wife, own and reside at property

located at 22916 SE 159th St. in Issaquah, King County, Washington.

30. Plaintiff Chris Dukelow, a single man, Plaintiff Toby Turlay, a single woman, Minor

Plaintiffs Trygve Dukelow, Kyle Dukelow, and Sydney Dukelow, by and through Chris

Dukelow, and Minor Plaintiffs Alexandra Hofer and Gabriella Hofer, by and through

Toby Turlay, own and reside at property located at 16254 205th Pl. SE in Renton, King

County, Washington.

31. Plaintiffs Gary Dukelow and Linda Dukelow, husband and wife, own and reside at


32. Plaintiff Michele Fisher, a single woman, and Minor Plaintiffs Nolan Fisher and Brianna

COMPLAINT - 12

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Fisher, by and through Michele Fisher, own and reside at property located at 14708 209th

Ave. SE in Renton, King County, Washington.

33. Plaintiffs Kelly Garber and Debbie Garber, husband and wife, own and reside at property

located at 20403 SE 145th St. in Renton, King County, Washington.

34. Plaintiffs James George and Susan George, husband and wife, own and reside at property

located at 15816 209th Ave SE in Renton, King County, Washington.

35. Plaintiffs Matthew George and Kim George, husband and wife, Plaintiff Robert Clark, a

single man, and Minor Plaintiff Kyle George, by and through Matthew George, own and

reside at property located at 15810 209th Ave SE in Renton, King County, Washington.

36. Plaintiff Linda Godfrey, a single woman, Plaintiff Jaron Iwakami, a single man, and

Plaintiff Kayla Iwakami, a single woman, own and reside at property located at 14207

177th Ave SE in Renton, King County, Washington.

37. Plaintiff Teresa Gorney-Haag, a single woman, and Minor Plaintiffs Randy Haag and

Travis Haag, by and through Teresa Gorney-Haag, own and reside at property located at

15002 206th Ave SE in Renton, King County, Washington.

38. Plaintiff Julie Goza, a single woman, and Minor Plaintiff Allison Goza, by and through

Julie Goza, own and reside at property located at 16449 239th Ave. SE in Issaquah, King

County, Washington.

39. Plaintiffs Dennis Griffin and Rosalie Griffin, husband and wife, own and reside at

property located at 22917 SE 159th St. in Issaquah, King County, Washington.

40. Plaintiffs Todd Halfon and Sherri Halfon, husband and wife, Plaintiff James Canady, a

single man, and Minor Plaintiff Nate Halfon, by and through Sherri Halfon, own and

reside at property located at 15056 205th Ave. SE in Renton, King County, Washington.

COMPLAINT - 13

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41. Plaintiff Debra Hawkins, a single woman, Plaintiff James Hershey, a single man, and

Minor Plaintiff Bailee Hawkins, by and through Debra Hawkins, own and reside at


42. Plaintiffs Mark Heinzen and Pamela Heinzen, husband and wife, own and reside at

property located at P.O. Box 834 in Issaquah, King County, Washington.

43. Plaintiff Elizabeth Holmberg, a single woman, and Plaintiff Anders Holmberg, a single

man, own and reside at property located at 20217 SE 157th St. in Renton, King County,

Washington.

44. Plaintiffs Aaron Holmlund and Michelle Holmlund, husband and wife, own and reside at

property located at 20439 SE 157th St. in Renton, King County, Washington.

45. Plaintiff Lisa Huntley, a single woman, and Minor Plaintiff James Huntley, by and

through Lisa Huntley, own and reside at property located at 15541 207th PL SE in


46. Plaintiff Janson Iwakami, a single man, owns and resides at property located at 14717

206th Ave SE in Renton, King County, Washington.

47. Plaintiff Debra Jagerman, a single woman, and Plaintiff Scott Dungan, a single man, own

and reside at property located at 15017 204th Ave. SE in Renton, King County,

Washington.

48. Plaintiffs Richard James and Gloria James, husband and wife, own and reside at property


49. Plaintiffs Roger Jones and Pat Jones, husband and wife, own and reside at property

located at 15611 263rd Ave. SE in Issaquah, King County, Washington.

50. Plaintiffs John Kalmbach and Wendy Kalmbach, husband and wife, and Minor Plaintiff

COMPLAINT - 14

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Brandi Kalmbach, by and through John Kalmbach, own and reside at property located at

15508 206th Ave. SE in Renton, King County, Washington.

51. Plaintiff Jolene D. Kalmbach, a single woman, owns and resides at property located at

15615 203rd Ave. SE in Renton, King County, Washington.

52. Plaintiff Frecia Kelly, a single woman, and Plaintiff Richard Nieman, a single man, own

and reside at property located at 20852 SE 155th Pl. in Renton, King County,

Washington.

53. Plaintiffs Roland Klix and Dorothy Klix, husband and wife, own and reside at property


54. Plaintiff Edward Knebel, a single man, and Plaintiff Patricia Lopacinski, a single woman,

own and reside at property located at 14615 205th Ave. SE in Renton, King County,

Washington.

55. Plaintiffs Sean Kronberg and Tracey Kronberg, husband and wife, and Minor Plaintiff

Annika Kronberg, by and through Sean Kronberg, own and reside at property located at

15607 230th Ave. SE in Issaquah, King County, Washington.

56. Plaintiffs Jerold Kutzke and Lisa Kutzke, husband and wife, and Minor Plaintiffs Olivia

Kutzke and Joshua Kutzke, by and through Jerold Kutzke, own and reside at property


57. Plaintiff Donn Lansing, a single man, owns and resides at property located at 14620

205th Ave. SE in Renton, King County, Washington.

58. Plaintiffs Marc Lecoq and Lisa Lecoq, husband and wife, own and reside at property

located at 15734 203rd Ave. SE in Renton, King County, Washington.

59. Plaintiffs Robert Liebling and Susan Liebling, husband and wife, own and reside at

COMPLAINT - 15

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60. Plaintiffs Michael Luedke and Heather Luedke, husband and wife, and Minor Plaintiffs

Jonah Luedke and Elise Luedke, by and through Michael Luedke, own and reside at

property located at 20731 SE 155 Pl. in Renton, King County, Washington.

61. Plaintiff Elizabeth Marshall, a single woman, owns and resides at property located at

20428 SE 145th St. in Renton, King County, Washington.

62. Plaintiff Stephanie Mayo, a single woman, Plaintiff Ben Coyne, a single man, and Minor

Plaintiff Olivia Coyne, by and through Ben Coyne, own and reside at property located at

14508 205th Ave. SE in Renton, King County, Washington.

63. Plaintiff William McGahey and Mary McGahey, husband and wife, own and reside at


64. Plaintiffs Demarcus Monte and Rachel Monte, husband and wife, Plaintiff Kristel Monte,

a single woman, Plaintiff Bret Monte, a single man, and Minor Plaintiff Ava Monte, by

and through Kristel Monte, own and reside at property located at 20718 SE 155th Pl. in


65. Plaintiffs Patrick Morford and Stacy Morford, husband and wife, and Minor Plaintiffs

Grace Morford and Ryan Morford, by and through Stacy Morford, own and reside at

property located at 14857 205th Ave SE in Renton, King County, Washington.

66. Plaintiff Leslie Morgan, a single woman, Plaintiff Curtis Green, a single man and

Plaintiffs Stuart Grayson and Jacquelyn Green, husband and wife, own and reside at

property located at 20924 SE 155th Place in Renton, King County, Washington.

67. Plaintiffs Todd Morton and Deborah Morton, husband and wife, Plaintiff Ashlyn Morton,

a single woman, and Plaintiff Amanda Morton, a single woman, own and reside at

COMPLAINT - 16

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68. Plaintiffs Shawn Mulqueeney and Kara Mulqueeney, husband and wife, and Minor

Plaintiffs Kiana Mulqueeney, Taylor Mulqueeney, and Shea Mulqueeney, by and through

Kara Mulqueeney, own and reside at property located at 16437 241st Ave. SE in

Issaquah, King County, Washington.

69. Plaintiffs Stephan Nepsa and Satina Nepsa, husband and wife, and Minor Plaintiffs Zoe

Nepsa, Aspen Nepsa and Enzo Nepsa, by and through Stephan Nepsa, own and reside at

property located at 15553 207 Pl. SE in Renton, King County, Washington.

70. Plaintiffs Charles Nevi and Karen Nevi, husband and wife, own and reside at property


71. Plaintiffs Dennis Nugent and Janet Nugent, husband and wife, Plaintiff Jamie Nugent, a

minor woman, and Plaintiff Jordan Nugent, a single woman, own and reside at property

located at 15629 203rd SE in Renton, King County, Washington.

72. Plaintiffs John O'Day and Catherine O’Day, husband and wife, own and reside at

property located at 20504 SE 152nd St. in Renton, King County, Washington.

73. Plaintiffs Brendan Pecht and Joji Pecht, husband and wife, own and reside at property

located at 16741 239th Ave. SE in Issaquah, King County, Washington.

74. Plaintiffs Jan Pelroy and Helga Pelroy, husband and wife, own and reside at property

located at 16755 239th Ave SE in Issaquah, King County, Washington.

75. Plaintiffs Randy Peschek and Dawn Peschek, husband and wife, and Minor Plaintiffs

Allison Peschek and Sarah Peschek, by and through Randy Peschek, own and reside at

property located at 15724 207th Pl. SE in Renton, King County, Washington.

76. Plaintiffs Tom Pfeiffer and Jennifer Pfeiffer, husband and wife, Plaintiff Stephanie

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Pfeiffer, a single woman, Plaintiff Rochelle Pfeiffer, a single woman, and Minor Plaintiff

Matthew Pfeiffer, by and through Tom Pfeiffer, own and reside at property located at


77. Plaintiffs Alexander Pishue and Jesse Pishue, husband and wife, and Minor Plaintiffs

Lyla Pishue and Gracie Pishue, by and through Jesse Pishue, own and reside at property


78. Plaintiffs David Prochazka and Dian Prochazka, husband and wife, own and reside at


79. Plaintiffs Rion Rau and Amy Rau, husband and wife, and Minor Plaintiffs Madisen Rau

and Emily Rau, by and through Rion Rau, own and reside at property located at 14723

205th Ave. SE in Renton, King County, Washington.

80. Plaintiffs Richard Reininger and Linda Reininger, husband and wife, Plaintiff Brent

Reininger, a single man, Plaintiff Hillary Reininger a single woman, Plaintiff Steve

Wilson, a single man and Plaintiff Kelsey Wilson, a single woman, own and reside at

property located at 16311 252nd Ave. SE in Issaquah, King County, Washington.

81. Plaintiffs Duane Rice and Edith Rice, husband and wife, own and reside at property

located at 14651 203rd Ave. SE in Renton, King County, Washington.

82. Plaintiff Annalee Rothenberg, a single woman, and Plaintiff Eric Durban, a single man,

own and reside at property located at 23175 SE 184th St. in Maple Valley, King County,

Washington.

83. Plaintiff Ashley Saunders, a single man, owns and resides at property located at 23921

SE 160th St. in Issaquah, King County, Washington.

84. Plaintiffs Gary Schimke and Sharon Schimke, husband and wife, own and reside at

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property located at 15562 207th Place SE, in Renton, King County, Washington.

85. Plaintiffs Kevin Scott and Becky Scott, husband and wife, and Minor Plaintiffs Evelyn

Scott and Henry Scott, by and through Becky Scott, own and reside at property located at


86. Plaintiffs Richard Scott and Helen Scott, husband and wife, own and reside at property


87. Plaintiff Linda Shepherd, a single woman, owns and resides at property located at 14985

256th Ave. SE in Issaquah, King County, Washington.

88. Plaintiffs Delainy Strittmatter and Jodi Strittmatter, husband and wife, and Minor

Plaintiffs Jordan Strittmatter and Sidney Strittmatter, by and through Delainy Strittmatter,

own and reside at property located at 23888 SE 162nd St in Issaquah, King County,

Washington.

89. Plaintiffs Errol Sweeney-Easter and Kathy Sweeney-Easter, husband and wife, Plaintiff

Patrick Sweeney-Easter, a single man, and Plaintiff Sean Sweeney-Easter, a single man,

own and reside at property located at 15269 206th Ave. SE in Renton, King County,

Washington.

90. Plaintiff Dan Taylor, a single man, owns and resides at property located at 15701 207th

Pl. SE in Renton, King County, Washington.

91. Plaintiffs Robert Thompson and Dana Thompson, husband and wife, own and reside at

property located at 13464 191st Ave. SE in Renton, King County, Washington.

92. Plaintiffs David Toner and Deena Toner, husband and wife, own and reside at property

located at 15719 207th Pl. SE in Renton, King County, Washington.

93. Plaintiffs Darren Tremblay and Kelsey Tremblay, husband and wife, and Minor Plaintiffs

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Emma Tremblay and Ryder Tremblay, by and through Kelsey Tremblay, own and reside

at property located at 15241 204th Ave SE in Renton, King County, Washington.

94. Plaintiffs Richard Tucker and Pamela Tucker, husband and wife, Plaintiff April Tucker, a

single woman, and Plaintiff Amy Lyn Tucker, a single woman, own and reside at

property located at 15717 203rd Ave. SE in Renton, King County, Washington.

95. Plaintiff Denise Vance, a single woman, owns and resides at property located at 21117

SE 155th Pl. in Renton, King County, Washington.

96. Plaintiffs Kevin Vigen and Sandy Vigen, husband and wife, and Ashley Vigen, a single

woman, own and reside at property located at 15007 205th Ave. SE in Renton, King

County, Washington.

97. Plaintiffs John Villa and Linda Villa, husband and wife, own and reside at property

located at 14838 203rd Ave SE in Renton, King County, Washington.

98. Plaintiffs Carl Wagner and Sandra Wagner, husband and wife, and Minor Plaintiffs Scott

Wagner and Hannah Wagner, by and through Sandra Wagner, own and reside at property


99. Plaintiffs Kelly Walshe and Barbara Walshe, husband and wife, Plaintiff Nicole Benson,

a single woman, Minor Plaintiffs Bella Walshe and Miller Walshe, by and through Kelly

Walshe, and Minor Plaintiffs Langston Ford and Lattimore Ford, by and through Nicole

Benson, own and reside at property located at 15221 204th Ave. SE in Renton, King

County, Washington.

100. Plaintiffs William Ward and Muriel Ward, husband and wife, Plaintiff Benjamin

Ward, a single man, Plaintiff Alisha Ward, a single woman, Plaintiff Whitney Bascom, a

single woman, and Plaintiff Marc Bascom a single man, own and reside at property

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located at 16436 241st Ave. SE in Issaquah, King County, Washington.

101. Plaintiffs Robert Wittenberg and Theresa Wittenberg, husband and wife, and

Minor Plaintiffs Rachel Wittenberg, Jacob Wittenberg, and Reeve Wittenberg, by and

through Robert Wittenberg, own and reside at property located at 14629 204th Ave. SE in


102. Plaintiffs Kurt Woodard and Sandie Woodard, husband and wife, and Minor Plaintiffs

Madison Woodard and Cole Woodard, by and through Kurt Woodard, own and reside at

property located at 16613 230th Ave. SE in Maple Valley, King County, Washington.

103. Plaintiffs Bernard Wright and Susan Wright, husband and wife, own and reside at

property located at 16711 239th Ave. SE in Issaquah, King County, Washington.

104. Plaintiff Leonard Zitzer, a single man, owns and resides at property located at 25006

SE 165th St. #8 in Issaquah, King County, Washington.

105. Defendant Cedar Grove Composting, Inc., is a Washington corporation with its

principal place of business in King County located at 7343 E. Marginal Way South,

Seattle, Washington, 98108. Cedar Grove owns and operates the Cedar Grove Facility

located at 17825 Cedar Grove Road, Maple Valley, King County, Washington, which is

the source of the harm.

106. Motions to appoint Guardian Ad Litems for all minor Plaintiffs will be filed within

thirty (30) days of the filing of this Complaint.

III. JURISDICTION AND VENUE

107. This Court has jurisdiction pursuant to RCW 3.66.020. The damages sought by each

individual Plaintiff, are less than $75,000.00, the jurisdictional maximum limit of this

court.

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108. Venue is proper pursuant to RCW 3.66.040. Plaintiffs reside in King County.

Defendant’s Cedar Grove Facility, which is the source of the harm, and Defendant’s

primary office are both located in King County.

IV. THE FACTS

109. Plaintiffs, as a direct result of Cedar Grove’s tortious conduct, have been, and continue

to be, exposed to noxious odors emanating from the Cedar Grove Facility.

110. The nuisance suffered by Plaintiffs is a temporary nuisance in that it is abatable.

111. The nuisance suffered by Plaintiffs is continuous in that Cedar Grove’s tortious conduct

is recurrent. The noxious odors are being released on a recurrent basis and without a

permanent cessation of such releases and, by its conduct, Cedar Grove continues to have

new violations of the statutes and common law of the State of Washington.

112. The Cedar Grove Facility is a commercial composting facility which processes, through

biological degradation, up to 351,250 tons per year of organic waste including, but not

limited to, food waste.

113. The degradation process produces off-gases, including malodorous gases.

114. Malodorous gases, when released by composting operations, mix with the ambient air

and can be carried to surrounding areas.

115. The manner by which Cedar Grove operates it commercial composting facility

accelerates the degradation process which, as a result, accelerates the production of off-

gases, including malodorous gases.

116. Cedar Grove has had knowledge that malodorous gases, have been and continue to be,

released into the ambient air from the Cedar Grove Facility and has continued to allow

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the malodorous gases to escape from the Cedar Grove Facility and reach Plaintiffs’

homes and properties.

117. Cedar Grove has failed to control and contain the volumes of malodorous gas generated

during its commercial composting operations.

118. Cedar Grove has failed to implement feasible and readily available off-gas collection

and treatment systems, and/or improved operating procedures, and/or reduce its feedstock

intake all of which would, if implemented properly, prevent the emission of malodorous

gases onto and around Plaintiffs’ properties.

CEDAR GROVE’S REGULATORY VIOLATIONS

119. Residents from the neighborhoods near the Cedar Grove Facility have continually and

frequently complained of the odors emanating from the Cedar Grove Facility and have

described the odors as, for example, disgusting, sickening, putrid, highly pungent,

horrendous, compost odor and absolutely the worst smell ever.

120. In 2011 the Puget Sound Clean Air Agency (“PSCAA”) performed 978 odor complaint

evaluations relating to complaints about odors emanating from the Cedar Grove Facility.

PSCAA inspectors’ evaluations confirmed that obnoxious odors emanating from the

Cedar Grove Facility were detectable in the ambient air around Cedar Grove. For

example, on August 26, 2011, during a period when PSCAA inspectors were only

conducting weekly scheduled inspections, a PSCAA inspector noted off site compost

odor which was confirmed by Cedar Grove’s consultant.

121. In 2012 the PSCAA performed over 372 odor complaint evaluations relating to

complaints about odors emanating from the Cedar Grove Facility. PSCAA inspectors’

evaluations included, on August 3, 2012, for example, that a PSCAA inspector, in

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response to an odor complaint, detected a compost odor described as putrid, distinct and

unpleasant and was confirmed to be coming from the Cedar Grove Facility.

122. PSCAA Regulation I, §9.11(a), provides that:

It shall be unlawful for any person to cause or allow the emission of any air contaminant in sufficient quantities and of such characteristics and duration as is, or is likely to be, injurious to human health, plant or animal life, or property, or which unreasonably interferes with enjoyment of life and property.

123. In just 2011 and 2012 the PSCAA has issued multiple Written Warnings to Cedar

Grove for violation of PSCAA Regulation I, §9.11(a).

124. The PSCAA has issued multiple Notices of Violation to Cedar Grove for, among other

violations, failure to control odors from the Cedar Grove Facility citing violation of

PSCAA Regulation I, §9.11(a).

125. On July 14, 2012, The State of Washington Pollution Control Hearings Board

addressed Cedar Grove’s commercial composting operations in Everett and Maple

Valley. The Pollution Control Hearings Board noted, in part, that: “[T]here have been a

large number of odor complaints associated with Cedar Grove’s composting facilities.

The odors emanating from the facilities have interfered with the reasonable enjoyment of

life and property of a large number of surrounding residents.” Cedar Grove Composting,

Inc. v. Puget Sound Clean Air Agency, Findings of Fact, Conclusions of Law, and Order,

PHB NOS. 10-044, 10,045, 10-120, 10-130, 10-131, 10-132, 10-147, 10-148, 10-149, 10-

150 & 10-154, p65, (July 14, 2012).

126. Cedar Grove has violated WAC 173-350-220(4)(a), which provides, in part, that “The

owner or operator of a composting facility shall operate the facility to control dust,

nuisance odors, and other contaminants to prevent migration of air contamination beyond

property boundaries.”

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V. CAUSES OF ACTION CAUSE ONE

(PUBLIC NUISANCE)

127. Plaintiffs adopt the allegations of paragraphs 1 through 126 as though fully set forth

herein.

128. RCWA 7.48.010 defines an actionable nuisance, in pertinent part, as:

…whatever is injurious to health or indecent or offensive to the senses, or an obstruction to the free use of property, so as to essentially interfere with the comfortable enjoyment of the life and property, is a nuisance and the subject of an action for damages and other further relief.

129. “Such action may be brought by any person whose property is, or whose patrons or

employees are, injuriously affected or whose personal enjoyment is lessened by the

nuisance.” RCWA 7.48.020.

130. A public nuisance is one which affects equally the rights of an entire community or

neighborhood, although the extent of the damage may be unequal. RCWA 7.48.130

131. It is a public nuisance to “erect, continue, or use any building, or other place, for the

exercise of any trade, employment, or manufacture, which by occasioning obnoxious

exhalations, offensive smells, or otherwise is offensive or dangerous to the health of

individuals or of the public.” RCWA 7.48.140(7).

132. As a proximate consequence of Cedar Grove’s tortious conduct, Cedar Grove has

maintained a public nuisance.

133. As a proximate consequence of Cedar Grove’s tortious conduct, Plaintiffs have

incurred and will continue to incur an infringement of their private rights not common to

the general public.

134. “A private person may maintain a civil action for public nuisance, if it is specially

injurious to himself or herself but not otherwise.” RCWA 7.48.210.

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135. Cedar Grove has acted unlawfully and/or omitted to perform a duty.

136. Cedar Grove’s unlawful act and/or its omission to perform a duty, annoyed, injured, or

endangered the comfort, repose, health or safety of each Plaintiff and was specially

injurious to each Plaintiff.

137. Cedar Grove’s act and/or omission was a proximate cause of the injury to Plaintiffs or

damage to Plaintiffs’ properties, has caused a substantial and unreasonable interference

with Plaintiffs’ interest in the private use and enjoyment of land and was specially

injurious to each Plaintiff.

138. As a proximate consequence of Cedar Grove’s tortious conduct, Plaintiffs have

incurred and will continue to incur damages, including, but not limited to, the following:

a) Annoyance, inconvenience and substantial personal discomfort;

b) Loss of use and enjoyment of their property; and,

c) Plaintiffs have been otherwise injured and damaged.

CAUSE TWO (PRIVATE NUISANCE)

139. In the alternative, Plaintiffs claim private nuisance.

140. Plaintiffs adopt the allegations of paragraphs 1 through 126 as though fully set forth

herein.

141. RCWA 7.48.010 defines an actionable nuisance, in pertinent part, as:

…whatever is injurious to health or indecent or offensive to the senses, or an obstruction to the free use of property, so as to essentially interfere with the comfortable enjoyment of the life and property, is a nuisance and the subject of an action for damages and other further relief.

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142. “Such action may be brought by any person whose property is, or whose patrons or

employees are, injuriously affected or whose personal enjoyment is lessened by the

nuisance.” RCWA 7.48.020.

143. A private nuisance is every nuisance not included in the definition of RCW 7.48.130.

RCWA 7.48.150.

144. Cedar Grove has acted unlawfully and/or omitted to perform a duty.

145. Cedar Grove’s unlawful act and/or its omission to perform a duty, annoyed, injured, or

endangered the comfort, repose, health or safety of each Plaintiff.

146. Cedar Grove’s act and/or omission was a proximate cause of the injury to Plaintiffs or

damage to Plaintiffs’ properties and has caused a substantial and unreasonable

interference with each Plaintiffs’ interest in the private use and enjoyment of land.

147. As a proximate consequence of the private nuisance created by the Cedar Grove

Facility, Plaintiffs have incurred and will continue to incur damages, including, but not

limited to, the following:

a) Annoyance, inconvenience and substantial personal discomfort;

b) Loss of use and enjoyment of their property; and,

c) Plaintiffs have been otherwise injured and damaged.

PRAYER FOR RELIEF

WHEREFORE, Plaintiffs pray for judgment as follows:

1) An award of annoyance, inconvenience and discomfort damages to each individual

Plaintiff, in an amount to be proved at trial;

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2) An award of loss of use and enjoyment of their property damages, in an amount to be

proved at trial;

3) An award of the costs and disbursements of this action and such other and further

relief as to the Court may deem just and proper; and,

4) Each individual Plaintiff seeks damages less than $75,000.

VI. JURY DEMAND

Plaintiffs demand a trial by jury on all issues triable to a jury by law.

DATED: January 23, 2013.

Paul L. Stritmatter, WSBA #4532

Brad J. Moore, WSBA #21802 413 8th Street Hoquiam, WA 98550 Phone: (360) 533-2710 Fax: (360) 532-8032 [email protected] [email protected]

Todd S. Hageman (Pro Hac Vice to be filed shortly) The Simon Law Firm, P.C. 800 Market Street, Ste. 1700 St. Louis, Missouri 63101 Phone: (314) 241-2929 Fax: (314) 241-2029 [email protected]

Zakariah Johnson (Pro Hac Vice to be filed shortly) Zakariah Johnson, PLLC PO Box 600017 Jacksonville, Florida 32260

Phone: (904) 553-7193 Fax: (904) 371-3645 [email protected] Anthony Z. Roisman, (Pro Hac Vice to be filed shortly) National Legal Scholars Law Firm, P.C.

mailto:[email protected]




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241 Poverty Lane - Unit 1 Lebanon, New Hampshire 03766 Phone: (603) 443-4162 Fax: (603) 443-4175 [email protected] Attorneys for Plaintiffs


Lawsuit Filed Against Cedar Grove Composting

Documents