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IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON
7 IN AND FOR THE COUNTY OF SNOHOMISH
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CHRISTOPHER KING and ELISA Case No.: 17-2-12377-31
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BRONSTEIN,
AMENDED COMPLAINT
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Plaintiffs,

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vs.

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KRISTINA MARIE ROBINSON and
AHADU AMLAK-TEREDA; PRECIOUS
13
PAWS;

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Defendants.

15 Plaintiffs CHRISTOPHER KING and ELISA BRONSTEIN, through attorney of

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record ADAM P. KARP of ANIMAL LAW OFFICES, allege:

JURISDICTION, PARTIES, AND VENUE

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1. This court has subject-matter jurisdiction over this action.
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2. Plaintiffs CHRISTOPHER KING and ELISA BRONSTEIN reside in Seattle,
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King County and were the owner-guardians of LIVI, a spayed female, four-year-old German
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Shorthaired Pointer. The Plaintiffs regarded Livi as their sentient personalty and immediate
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family member.
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3. Defendant KRISTINA MARIE ROBINSON, at all times relevant, was married
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to Defendant AHADU AMLAK-TEREDA, who both live in Mountlake Terrace, Snohomish
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County, Washington.
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AMENDED COMPLAINT - 1 ANIMAL LAW OFFICES OF

A D A M P. K A R P , E S Q .
114 W. Magnolia St., Ste. 400-104  Bellingham, WA 98225
(888) 430-0001  Facsimile: (866) 652-3832
adam@animal-lawyer.com
1 4. The marital community has been sued as Robinson’s acts and omissions enriched

2 the marital community and the incident occurred at 5808 218th Pl. SW, Mountlake Terrace

3 (“Marital Residence”).

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5. On December 29, 2016, Robinson did business as PRECIOUS PAWS, UBI No.

603-126-695, a doggie daycare and boarding service operating out of 9657 Firdale Ave.,
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Edmonds, Wash. (“Business Facility”). The business registration for this sole proprietorship
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opened September 1, 2014 and closed on December 31, 2016.
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6. This court has personal jurisdiction over all named defendants.
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7. Venue is proper.
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GENERAL ALLEGATIONS
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8. Robinson and Amlak-Tereda owned and operated Precious Paws on the date of
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Livi’s death.
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9. On August 8, 2014, Robinson was cited by Mountlake Terrace Animal Control
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when she and her father Michael E. Robinson lost a German Shorthaired Pointer without even
14 knowing that the dog had gone missing from the Marital Residence. Mountlake Terrace Animal
15 Control Officer Elena McKee reports in her incident narrative, “The training and experience of
16 [her employees] is not known[.]”
17 10. In correspondence to the City of Mountlake Terrace attempting to explain why

18 Precious Paws allegedly did not fall under its zoning code restrictions and should not be

19 prohibited from operating a doggie day care from Defendants’ home, Robinson made the

20 statement, “The dogs have 24/7 supervision they (sic) are NEVER left unattended” (emphasis in

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original).

11. On September 18, 2014, the City of Mountlake Terrace alerted Robinson and
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Amlak-Tereda that they were illegally operating a kennel from the Marital Residence in violation
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of MTMC 5.05.030 (Operating without a business license), MTMC 19.120.230(B) (Operating a
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Home Occupation without a valid home occupation permit or conditional use permit); and
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AMENDED COMPLAINT - 2 ANIMAL LAW OFFICES OF

A D A M P. K A R P , E S Q .
114 W. Magnolia St., Ste. 400-104  Bellingham, WA 98225
(888) 430-0001  Facsimile: (866) 652-3832
adam@animal-lawyer.com
1 MTMC 19.120.230(F)(1) (Conducting a prohibited use as a home occupation, viz., “Kennels”).

2 From that date until December 29, 2016, they never obtained a permit, appealed the notice, or

3 sought a variance. The City of Mountlake Terrace assessed a fine relative to the subject premises

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in 2017 for violations relative to the illegal kennel.

12. On February 27, 2015, Mountlake Terrace Animal Control Officer Elena McKee
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wrote to a Lynnwood Animal Control Officer that Robinson “is on my radar” and that she “has
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drama wherever she goes and doesn’t hesitate to lie when it serves her purposes. If you are
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interviewing her or relying on any statement from her, take it with a grain of salt.”
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13. Throughout 2015, neighbors to the Marital Residence complained to the City of
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Mountlake Terrace about Robinson and Amlak-Tereda’s ongoing, illegal home business
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operation.
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14. On July 30, 2015, Mountlake Terrace Police reported that Karen Simms was the
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registered owner of a vehicle in which a blonde dog was removed from the Marital Residence
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after having been under alleged direct supervision of Robinson.
14 15. Throughout 2016, Robinson told Plaintiffs that Precious Paws was licensed,
15 bonded, and insured, inducing them to entrust Livi and Fang, their neutered male, three-legged
16 Chihuahua, to Precious Paws’s intermittently for a total of approximately seven (7) days over the
17 course of a year.

18 16. Plaintiffs planned a holiday retreat to the East Coast from December 21, 2016

19 through January 4, 2017 with the intent of boarding Livi and Fang with Precious Paws over that

20 period.

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17. Robinson and Amlak-Tereda were not licensed or permitted to operate a

commercial kennel from the Marital Residence on December 29, 2016, or at any time.
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18. Robinson and Amlak-Tereda were not bonded on December 29, 2016.
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19. While Robinson and Amlak-Tereda did have commercial liability insurance to
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cover claims at the Business Facility, that policy did not cover acts and omissions at their illegal
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AMENDED COMPLAINT - 3 ANIMAL LAW OFFICES OF

A D A M P. K A R P , E S Q .
114 W. Magnolia St., Ste. 400-104  Bellingham, WA 98225
(888) 430-0001  Facsimile: (866) 652-3832
adam@animal-lawyer.com
1 kenneling operation operated from the Marital Residence on December 29, 2016.

2 20. Robinson represented and warranted that Livi and Fang would be kept and

3 continually supervised at the Business Facility from opening until closure at about 7 p.m.,

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whereupon they would then be transported to the Marital Residence for continuous supervision

overnight. Robinson represented to Plaintiffs that their Business Facility and Marital Residence
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were both licensed, bonded, and insured.
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21. On December 21, 2016, Livi was delivered to the Business Facility in Edmonds,
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Wash. Fang was delivered to the same location on December 22, 2016.
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22. On December 25, 2016, Plaintiffs Facetimed with Robinson, Livi, and Fang from
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the East Coast.
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23. On December 29, 2016, Robinson and Amlak-Tereda owned, kept, and harbored
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at the Marital Residence the following dogs: Bullet, a neutered male English Bulldog/Bassett
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Hound mix; Miya, a spayed female Australian Shepherd; Chevy, a neutered male pitbull terrier-
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type dog; and Nova, a spayed female pitbull terrier-type dog (collectively, “Defendants’ Dogs”).
14 They also owned and resided with a feline.
15 24. Due to being overbooked for the holidays, instead of Livi and Fang being
16 transported to the Business Facility from opening to close at 7 p.m., on December 29, 2017,
17 Defendants left them at the Marital Residence with Defendants’ Dogs and three other dogs

18 owned by Defendants’ business clients. One of those three dogs was Duba, a male Golden

19 Retriever mix owned by the aforementioned Simms.

20 25. Robinson and Amlak-Tereda were not supervising any of these nine (9) dogs from

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opening hours at the Business Facility until 6:45 p.m. Instead, Robinson’s father, Michael E.

Robinson, was left home alone to watch these animals. Plaintiffs did not know or consent to
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Robinson’s father watching Livi and Fang.
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26. At approximately 6:45 p.m. on December 29, 2017, Robinson returned to the
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Marital Residence to pick up her father and two dogs owned by Defendants’ business clients,
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AMENDED COMPLAINT - 4 ANIMAL LAW OFFICES OF

A D A M P. K A R P , E S Q .
114 W. Magnolia St., Ste. 400-104  Bellingham, WA 98225
(888) 430-0001  Facsimile: (866) 652-3832
adam@animal-lawyer.com
1 leaving behind, unsupervised, Defendants’ Dogs, Livi, Fang, and Duba.

2 27. Sometime between approximately 6:45 p.m. and 7:30 p.m. on December 29,

3 2017, dogs owned, kept, and/or harbored by Robinson and Amlak-Tereda killed Livi without

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provocation while left unattended by Robinson, Amlak-Tereda, and Michael Robinson at the

unlicensed Marital Residence.

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28. Around 7:30 p.m. on December 29, 2016, Amlak-Tereda returned to the Marital
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Residence from the Business Facility to find Livi dead in the Marital Residence.
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29. On December 29, 2016, Robinson informed the Plaintiffs that Livi was found
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dead at the Marital Residence after King sent a text message to Amlak-Tereda asking to see Fang
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and Livi.
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30. From Pennsylvania, King called Mountlake Terrace Police Department, which
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responded that evening to the Marital Residence.
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31. On information and belief, Robinson was told by at least one other person that
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Nova had aggressive tendencies towards a human and to other dogs. Robinson was told not to
14 bring Nova to the other person’s home because of these observations.
15 32. Claiming that Bullet exhibited negative behavioral tendencies in the aftermath of
16 Livi’s death, Robinson and Amlak-Tereda had him euthanized without any direction, citation,
17 charge, or declaration of dangerous or potentially dangerous dog by Mountlake Terrace Animal

18 Control.

19 33. Nova was the suspected perpetrator of Livi’s death but was not euthanized due to

20 same.

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34. At no time, for any of the dates of boarding Livi and Fang, did Plaintiffs know

their dogs would be kept at the Marital Residence during business hours, exposed to a pack of
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Defendants’ Dogs, while unattended by Robinson and Amlak-Tereda or any other competent
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adult. Rather, they were expected to be at the Business Facility and watched by trained
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personnel.
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AMENDED COMPLAINT - 5 ANIMAL LAW OFFICES OF

A D A M P. K A R P , E S Q .
114 W. Magnolia St., Ste. 400-104  Bellingham, WA 98225
(888) 430-0001  Facsimile: (866) 652-3832
adam@animal-lawyer.com
1 35. On the date Livi was mauled and killed by Defendants’ dog(s), Defendants

2 illegally kept more than four dogs in a single household, not including Livi and Fang, in

3 violation of MTMC 6.30.040(A).

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36. Plaintiffs returned to Seattle on December 30, 2016, departing on a 6:30 a.m.

emergency flight from Harrisburg, Pennsylvania, curtailing their holiday travels and forcing
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them to incur additional travel costs. Plaintiffs lost the opportunity to complete their trip to see
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King’s family in New York City, followed by a visit to see dear friends in Boston.
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37. Livi was privately cremated at significant expense.
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38. At no time did Defendants offer to pay for cremation. Nor did they send a card or
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flowers.
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39. On January 4, 2017, Robinson testified before the Mountlake Terrace City
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Council, proclaiming that she has “run this business for four (4) years with not so much as one
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bite.” This statement was belied by evidence of at least one prior incident, resulting in veterinary
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expense.
14 40. Robinson has admitted that, prior to Livi’s death, she left Precious Paws’s clients’
15 dogs alone, resulting in at least one injury.
16 41. Robinson and Amlak-Tereda engaged in several unfair and deceptive practices in
17 trade and commerce, proximately causing injury to the Plaintiffs, including but not limited to, (a)

18 misusing their Edmonds business license to bring dogs, including Plaintiffs’, to their illegal

19 kennel in Mountlake Terrace; (b) representing that the business was licensed, bonded, and

20 insured at both the Business Facility and Marital Residence; (c) promising that Plaintiffs’ dogs

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would be at the Business Facility until closing at about 7 p.m.; (d) and promising that Plaintiffs’

dogs would be supervised by competent staff at all times when at the Marital Residence. Such
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practices had, and on information and belief may continue to have, the capacity to injure others.
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42. At the time of Livi’s untimely death, the Plaintiffs, and each of them, never would
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have been willing to sell or part with her. She had no fair market value, and could not be
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AMENDED COMPLAINT - 6 ANIMAL LAW OFFICES OF

A D A M P. K A R P , E S Q .
114 W. Magnolia St., Ste. 400-104  Bellingham, WA 98225
(888) 430-0001  Facsimile: (866) 652-3832
adam@animal-lawyer.com
1 replaced or reproduced. Rather, Livi had an immense intrinsic value to each of the Plaintiffs.

2 43. The Plaintiffs, and each of them, lost Livi’s intrinsic value and utility.

3 44. The Plaintiffs, and each of them, suffered and continue to suffer severe emotional

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distress and loss of enjoyment of life, among other general damages, as a direct result of

Defendants’ acts and omissions.

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6 Per CR 8(e)(2), the Plaintiffs alternatively and

cumulatively plead the following as to Defendants:
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45. Claim I: RCW 16.08.010 (Liability for Dogs Harming Animals)
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46. Claim II: Fraud (relative to being licensed, bonded, insured, and as to location
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where boarding would take place; promising that Livi and Fang would be supervised at the
10 Business Facility until closing time and then transported to the Marital Residence under constant
11 supervision by trained personnel)
12 47. Claim III: RCW 19.86.090 (Consumer Protection Act)

13 48. Claim IV: Outrage

14 49. Claim V: Negligence (including negligent misrepresentation)

15 50. Claim VI: Breach of Contract

16 51. Claim VII: Breach of Bailment

52. Claim VIII: Strict Common Law Liability

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PRAYER
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WHEREFORE, the Plaintiffs seek judgment against the Defendants as follows:
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A. For economic damages related to the intrinsic value of Livi, loss of use of Livi,
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increased travel costs, and burial expenses;
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B. For noneconomic damages;
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C. For prejudgment interest on liquidated sums;
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D. For treble damages under RCW 19.86.090 for each Plaintiff;
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E. For reasonable attorney’s fees as allowed by law (including RCW 16.08.010 and
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AMENDED COMPLAINT - 7 ANIMAL LAW OFFICES OF

A D A M P. K A R P , E S Q .
114 W. Magnolia St., Ste. 400-104  Bellingham, WA 98225
(888) 430-0001  Facsimile: (866) 652-3832
adam@animal-lawyer.com
1 19.86.090), contract, and/or equity;

2 F. For costs of suit;

3 G. For postjudgment interest at 12% per annum or the highest rate permitted by law,

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whichever is higher, pursuant to RCW 4.56.110;

H. For such other and further relief as the Court may deem just and proper.
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I. NOTICE: Each of the Plaintiffs seeks damages in excess of the statutory fee-shifting
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limit set by RCW 4.84.250-.280, as amended.
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Dated this December 22, 2017

9 ANIMAL LAW OFFICES

10 _________________________________
Adam P. Karp, WSBA No. 28622
11 Attorney for Plaintiffs
12 CERTIFICATE OF SERVICE
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On December 23, 2017, I caused to be served the foregoing on Defendants by first-class mail to
14 Kristina Robinson and Ahadu Amlak-Tereda, 5808 218th Pl. SW, Mountlake Terrace, Wash. A
copy was also sent by email to Kristina Robinson.
15
ANIMAL LAW OFFICES
16
_________________________________
17 Adam P. Karp, WSBA No. 28622
Attorney for Plaintiffs
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AMENDED COMPLAINT - 8 ANIMAL LAW OFFICES OF

A D A M P. K A R P , E S Q .
114 W. Magnolia St., Ste. 400-104  Bellingham, WA 98225
(888) 430-0001  Facsimile: (866) 652-3832
adam@animal-lawyer.com