Defendants do not explain why these allegations fail to state a claim, nor do Defendants even mention RCW 19.40.051 and 19.40.041. See Gremp v. Ramsey, No. C08-0558RSM, 2009 WL 112674, at *4 (W.D. Wash. Jan. 14, 2009) (construing the defendants' silence on RCW 19.40.041 in their motion to dismiss “as an admission that [the p]laintiffs' arguments have merit”). (See generally Mot. (lacking any mention of RCW 19.40.051 or 19.40.041).)
Plaintiffs must plausibly plead facts to support piercing the corporate veil. See Gremp v. Ramsey, No. C08-558RSM, 2009 WL 112674, at *8 (W.D. Wash. Jan. 14, 2009) (concluding under the facts of that case that the plaintiff adequately pleaded a claim for piercing the corporate veil). Here, Plaintiffs must plead facts sufficient to // pierce two layers of corporate veil—both Rita's and Rita's Holdings—before liability could be plausibly imposed on Falconhead.
Washington courts agree that "money may be the subject of conversion if it was wrongfully received by the party charged with conversion, or [if] such party was under obligation to return the specific money to the party claiming it." Gremp v. Ramsey, No. C08-558RSM, 2009 U.S. Dist. LEXIS 2351, *21-22 (W.D. Wash. 2009). With that said, "[a] fundamental premise of conversion is that the property must have rightfully been in the possession of the owner."