Upload
others
View
0
Download
0
Embed Size (px)
Citation preview
PAGE 1 –COMPLAINT Law Offices of Daniel Snyder
Attorneys At Law
1000 S.W. Broadway, Suite 2400
Portland, Oregon 97205 (503) 241-3617 Fax (503) 241-2249
Daniel Snyder, OSB No. 783856
Carl Post, OSB No. 061058
John Burgess, OSB No. 106498
LAW OFFICES OF DANIEL SNYDER
1000 S.W. Broadway, Suite 2400
Portland, Oregon 97205
Telephone: (503) 241-3617
Facsimile: (503) 241-2249
Of Attorneys for the plaintiff
UNITED STATES DISTRICT COURT
DISTRICT OF OREGON
PORTLAND DIVISION
RICH SNEATH,
Plaintiff,
v.
CLACKAMAS COUNTY,
Defendants.
Case No. 3:16-cv-1907
COMPLAINT
UNLAWFUL EMPLOYMENT ACTION
Title VII Discrimination, Retaliation and
supplemental state law claims
JURY TRIAL DEMANDED
I. PRELIMINARY STATEMENT
1. This action is an action for equitable relief and damages, including compensatory
damages, back pay, front pay, and attorneys’ fees and costs, brought under ORS 659A.030 and
42 U.S.C. § 2000e et. seq. to redress discrimination, harassment, and retaliation by Defendant
Case 3:16-cv-01907-MO Document 1 Filed 09/29/16 Page 1 of 13
PAGE 2 –COMPLAINT Law Offices of Daniel Snyder
Attorneys At Law
1000 S.W. Broadway, Suite 2400
Portland, Oregon 97205 (503) 241-3617 Fax (503) 241-2249
against Plaintiff in terms and conditions of employment on the basis of religion and under 42
U.S.C. § 2000e-3(a), ORS 659A.199, ORS 659A.203, and ORS 659A.230, to redress
discrimination, harassment, and retaliation by Defendant against Plaintiff because Plaintiff
opposed discrimination and retaliation based upon his religion and filed complaints against
Defendant with BOLI, the EEOC, and a prior lawsuit against Defendant.
II. JURISDICTION
2. Jurisdiction is conferred upon this Court by 28 U.S.C. §1331, federal question
jurisdiction, and 28 U.S.C. §1343, civil rights jurisdiction.
3. Plaintiff requests this Court invoke its supplemental jurisdiction pursuant to
28 U.S.C. § 1367 with respect to all causes of action based on Oregon statutory provisions or
common law as the state claims arise from the same nucleus of operative facts as the federal
claims.
4. On August 21, 2015, Plaintiff filed a charge of employment discrimination and
retaliation with the Oregon Bureau of Labor and Industries (BOLI), case number 38D-2015-
00774C, for discrimination, harassment, and retaliation because of Plaintiff’s religion; making
good faith reports of information Plaintiff believed was evidence of a violation of a state or
federal law, rule, or regulation; and for initiating and participating in the filing of BOLI and
EEOC complaints and a lawsuit against Clackamas County.
5. BOLI co-filed Plaintiff’s charge with the Equal Employment Opportunity
Commission (EEOC), charge number EEEMRG150821-12890.
6. On July 6, 2016, BOLI issued Plaintiff a right to sue letter for case number 38D-
2015-00774C.
7. Plaintiff has requested that the attorney general issue Plaintiff a right to sue letter
Case 3:16-cv-01907-MO Document 1 Filed 09/29/16 Page 2 of 13
PAGE 3 –COMPLAINT Law Offices of Daniel Snyder
Attorneys At Law
1000 S.W. Broadway, Suite 2400
Portland, Oregon 97205 (503) 241-3617 Fax (503) 241-2249
for charge number EEEMRG150821-12890.
8. Venue is in the District of Oregon pursuant to 28 U.S.C. §1391(b) because the
claim arose in this Judicial District.
III. PARTIES
9. Plaintiff Rich Sneath is a citizen of the United States. At all times material,
Plaintiff worked for defendant in Clackamas County, Oregon.
10. Defendant Clackamas County is a political subdivision of the State of Oregon.
The County, through the Clackamas County Sheriff’s Office, owns and operates correctional
facilities or jails in Clackamas County, Oregon.
11. At all times material, defendant has employed more than 100 people.
12. At all times relevant, defendant’s employees and supervisors as their conduct is
alleged herein were acting within the course and scope of their employment with the defendant.
IV. GENERAL FACTUAL ALLEGATIONS
13. Since approximately September 2007, Mr. Sneath has been employed by
Clackamas County Sheriff’s Office as a deputy sheriff.
14. Mr. Sneath is Jewish.
15. Starting in or about December, 2011, Plaintiff’s co-workers and supervisors began
harassing and retaliating against Plaintiff, including but not limited to:
a. Posting threatening and derogatory comments on a group
Facebook page, members of which were other co-workers and supervisors. These
posts were made both on and off the clock. These posts included anti-Semitic
comments directed at Plaintiff such as “looks like Hitler missed one.”
b. Making similar comments as the Facebook comments verbally in
Case 3:16-cv-01907-MO Document 1 Filed 09/29/16 Page 3 of 13
PAGE 4 –COMPLAINT Law Offices of Daniel Snyder
Attorneys At Law
1000 S.W. Broadway, Suite 2400
Portland, Oregon 97205 (503) 241-3617 Fax (503) 241-2249
the workplace.
16. On or about January 9, 2013, Mr. Sneath informed some co-workers of his
knowledge of the Facebook posts and workplace comments.
17. On or about January 22, 2013, Undersheriff Kirby, Mr. Sneath’s supervisor,
informed him that he was aware of the Facebook posts, but Defendant failed to take effective
remedial measures to address the Facebook posts and workplace comments.
18. On or about April 7, 2013, Mr. Sneath learned that a co-worker had made anti-
Semitic comments in the workplace directed at Mr. Sneath, including but not limited to:
a. “Hitler missed one”;
b. Saying “Happy Holocaust Appreciation Day” in reference to
Holocaust Remembrance Day;
c. Substituting the word “Jew” for “you” when referring to Mr.
Sneath.
19. Despite reports of the discrimination and harassment towards Mr. Sneath,
Defendant failed to take remedial actions to allow Mr. Sneath to work in an environment free
from discrimination and harassment. Instead Mr. Sneath was threatened with discipline, up to
and including termination of employment, in retaliation.
20. On or about October 13, 2013, Mr. Sneath provided Clackamas County with a tort
claim notice for discrimination, harassment and retaliation because of his religion.
21. In October 2013, Mr. Sneath filed a BOLI complaint against Clackamas County
for discrimination, harassment, and retaliation because of his religion and because he was
subjected to discrimination, harassment and retaliation for making a good faith report of
information he believed was evidence of a violation of a state or federal law, rule, or regulation.
Case 3:16-cv-01907-MO Document 1 Filed 09/29/16 Page 4 of 13
PAGE 5 –COMPLAINT Law Offices of Daniel Snyder
Attorneys At Law
1000 S.W. Broadway, Suite 2400
Portland, Oregon 97205 (503) 241-3617 Fax (503) 241-2249
The complaint was co-filed with the EEOC.
22. In June 2014, Mr. Sneath filed a lawsuit, USDC Case No. 3:14-cv-01 013-BR,
regarding discrimination and retaliation against him by Clackamas County.
23. Mr. Sneath was further discriminated against, retaliated against, and harassed by
defendant for filing the BOLI and EEOC complaints and his lawsuit.
24. In July 2014, Mr. Sneath filed complaints against Clackamas County with the
Equal Employment Opportunity Commission and the Bureau of Labor and Industries for
discrimination and retaliation because Mr. Sneath made good faith reports of violations of the
law and because he filed complaints against defendant with the EEOC, BOLI, and in federal
court.
25. On October 31, 2014, Mr. Sneath amended his lawsuit to also include claims for
retaliation for filing his administrative complaints.
26. In December 2014, the parties agreed to settle all of Mr. Sneath’s claims against
Clackamas County through November 3, 2014. The County failed to comply with the terms of
the settlement agreement.
27. Regrettably, Mr. Sneath continues to experience discrimination, retaliation and
harassment because of his religion and retaliation for good faith reports of violations of the law
and for filing his administrative complaints and lawsuit against Clackamas County.
28. On or about October 25, 2014, Mr. Sneath applied for an open Sergeant position.
At first, there was one open position. Later a second position was announced and eventually a
third. Mr. Sneath’s application was for all three and for any additional positions that open over
the next two years.
29. On November 24, 2014, Mr. Sneath received an email saying that he passed the
Case 3:16-cv-01907-MO Document 1 Filed 09/29/16 Page 5 of 13
PAGE 6 –COMPLAINT Law Offices of Daniel Snyder
Attorneys At Law
1000 S.W. Broadway, Suite 2400
Portland, Oregon 97205 (503) 241-3617 Fax (503) 241-2249
written test in the Sergeant selection process.
30. On December 29, 2014, Mr. Sneath was notified that he would not be moving into
the final group of applicants to be interviewed despite scoring higher in the oral board testing
process than at least four of the other candidates that moved forward and being a more qualified
candidate.
31. In December of 2014 Mr. Sneath was told that management did not want to work
with Mr. Sneath because of the lawsuit he filed and on January 4, 2015, Mr. Sneath emailed
Chief Deputy Layng and reported retaliation.
32. In January of 2015 was Sneath was again told that management did not want to
work with him because of the lawsuit.
33. On January 7, 2015, Mr. Sneath met with Chief Deputy Layng regarding the
retaliation in the selection process. Chief Deputy Layng asked who told Mr. Sneath about
Lieutenant Thies’s comments. Mr. Sneath did not have permission to share the identity of the
person who told him. Chief Deputy Layng asked Mr. Sneath to ask the person that had provided
Mr. Sneath this information if it was ok if Mr. Sneath passed his name along. The two continued
to discuss the prior lawsuit and Mr. Sneath’s concerns. After a while, Chief Deputy Layng told
Mr. Sneath that he was getting a red flag and a feeling that Mr. Sneath was going to sue the
county and he ordered Mr. Sneath to tell him who told Mr. Sneath about Thies’s comments. Mr.
Sneath requested union representation. Chief Deputy Layng told Mr. Sneath he was being
insubordinate by not answering his question despite the fact that Mr. Sneath’s job duties did not
require disclosure and there was no business necessity for Mr. Sneath to disclose the name
without the informant’s permission. Mr. Sneath responded that he would like time to check in
with his legal counsel/union representatives and confirm that this was a lawful order if the
Case 3:16-cv-01907-MO Document 1 Filed 09/29/16 Page 6 of 13
PAGE 7 –COMPLAINT Law Offices of Daniel Snyder
Attorneys At Law
1000 S.W. Broadway, Suite 2400
Portland, Oregon 97205 (503) 241-3617 Fax (503) 241-2249
meeting was going to become disciplinary in nature. Mr. Sneath informed Chief Deputy Layng
that Mr. Sneath had a right to union representation and Chief Deputy Layng said that he did not,
which is in violation of Mr. Sneath’s Weingarten rights. Chief Deputy Layng told Mr. Sneath
that he had to “mend fences” prior to being selected for promotion and gave examples of other
employees that mended fences prior to promotion. Mr. Sneath pointed out the clear violation of
county policy related to this statement and that it was retaliation.
34. On January 7, 2015, at 7:22 PM, Chief Deputy Layng emailed Mr. Sneath and
told him that he must disclose the informant’s name. Mr. Sneath obtained permission from the
witness to disclose the name and Mr. Sneath provided the name to Chief Deputy Layng.
35. On January 8, 2015, Mr. Sneath received notice of intent to discipline Mr. Sneath.
36. On January 13, 2015, Mr. Sneath asked for a review of the selection results from
DES due defendant not following appropriate procedures and policies.
37. On January 21, 2015, the Sergeant selection was made for two positions and Mr.
Sneath was not selected.
38. On January 27, 2015, Mr. Sneath received a letter from the Department of
Employee Services Nancy Drury saying that she had completed the review and there were no
problems with the Sergeant selection process.
39. In February of 2015 Mr. Sneath was informed of new comments made by his co-
workers related to his Jewish affiliation. These comments were made while at work and by some
of the same bad actors involved in the original lawsuit. The comments brought up Mr. Sneath
being Jewish, and repeated some statements from the original investigation. Mr. Sneath reported
this conduct to his supervisor.
40. On February 4, 2015, Mr. Sneath was disciplined with a 40 hour unpaid
Case 3:16-cv-01907-MO Document 1 Filed 09/29/16 Page 7 of 13
PAGE 8 –COMPLAINT Law Offices of Daniel Snyder
Attorneys At Law
1000 S.W. Broadway, Suite 2400
Portland, Oregon 97205 (503) 241-3617 Fax (503) 241-2249
suspension in retaliation for his opposition to unlawful activity and for his prior lawsuit and
administrative complaints. Mr. Sneath served the suspension on February 18, 19, 25, and 26,
2015. Additionally, Mr. Sneath was disciplined in violation of the settlement agreement reached
with the county.
41. In March of 2015 Mr. Sneath was informed that the Sergeant selection process
was not correctly conducted and selections were put on hold or withdrawn for the time being. .
42. On April 7, 2015 Chief Deputy Layng sent out an email saying that the Sergeant
selection was completed. Mr. Sneath was not selected.
43. On May 7, 2015 Mr. Sneath received his evaluation from the period of September
2013 to September 2014. Mr. Sneath’s performance review stated that he “meets standard”
instead of “exceeds standard” as his score would indicate. The low performance review was
retaliation.
44. On May 12, 2015, Mr. Layng sent an email saying there were actually three open
Sergeant positions. Mr. Sneath was not interviewed.
45. On June 11, 2015, Chief Deputy Layng emailed that the third Sergeant position
was filed. Mr. Sneath was not selected.
46. In December of 2015, management directed a nurse to file a complaint against
Mr. Sneath in retaliation for Mr. Sneath’s protected activity.
47. On February 10, 2016, Mr. Sneath received a performance review that stated Mr.
Sneath “Does Not Meet Expectations” The poor review was retaliation and made Mr. Sneath
ineligible to apply for new positions.
48. The county modified its selection process for the three Sergeant positions in a
way to exclude Mr. Sneath from being selected for the positions. Additionally, throughout the
Case 3:16-cv-01907-MO Document 1 Filed 09/29/16 Page 8 of 13
PAGE 9 –COMPLAINT Law Offices of Daniel Snyder
Attorneys At Law
1000 S.W. Broadway, Suite 2400
Portland, Oregon 97205 (503) 241-3617 Fax (503) 241-2249
process Mr. Sneath was treated unfavorably and defendant failed to promote Mr. Sneath in
retaliation for his protected activity.
FIRST CLAIM FOR RELIEF
(ORS Chapter 659A.030)
49. Plaintiff re-alleges all relevant paragraphs as though fully restated herein.
50. In violation of ORS 659A.030, Defendant discriminated against Plaintiff because
of religion, Plaintiff was subjected to a hostile work environment because of his religion, and
Plaintiff was retaliated against for reporting violations of ORS 659A.030.
51. As a result, Plaintiff suffered damage and is entitled to the damages and other
relief set forth below.
52. Plaintiff is entitled to a declaration that the conduct of the Defendant violated
ORS 659A.030.
SECOND CLAIM FOR RELIEF
(42 U.S.C. §2000e et. seq)
53. Plaintiff re-alleges all relevant paragraphs as though fully restated herein.
54. In violation of 42 U.S.C. § 2000e et seq., Defendant discriminated against
Plaintiff because of religion, Plaintiff was subjected to a hostile work environment because of his
religion, and Plaintiff was retaliated against for reporting violations of 42 U.S.C. § 2000e et seq.
55. As a result, Plaintiff suffered damage and is entitled to the damages and other
relief set forth below.
56. As a result of Defendant’s unlawful employment actions, Plaintiff suffered and
continues to suffer humiliation, anxiety, distress, and impairment of his personal dignity and
right to be free from discrimination or interference with his statutory rights. Plaintiff has also
Case 3:16-cv-01907-MO Document 1 Filed 09/29/16 Page 9 of 13
PAGE 10 –COMPLAINT Law Offices of Daniel Snyder
Attorneys At Law
1000 S.W. Broadway, Suite 2400
Portland, Oregon 97205 (503) 241-3617 Fax (503) 241-2249
suffered, and continues to suffer, economic damages, including, but not limited to, past and
future wages, past and future benefits, and other expenses.
57. Plaintiff is entitled to a declaration that the conduct of the Defendant violated 42
U.S.C. § 2000e et seq.
THIRD CLAIM FOR RELIEF
(ORS 659A.203 – Whistleblower)
58. Plaintiff re-alleges all relevant paragraphs as though fully restated herein.
59. Plaintiff disclosed information that Plaintiff believed was a violation of federal or
state laws, rules, or regulations.
60. Defendant discriminated and retaliated against Plaintiffs because of the
disclosures made by Plaintiffs. Defendant’s actions violated ORS 659A.203.
61. As a result, Plaintiff suffered damage and is entitled to the damages and other
relief set forth below.
62. Plaintiffs are entitled to a declaration that defendant’s conduct violated ORS
659A.203.
FOURTH CLAIM FOR RELIEF
(ORS Chapter 659A.199 – Whistleblower)
63. Plaintiff re-alleges all relevant paragraphs as though fully restated herein.
64. Plaintiff reported to Defendant conduct that Plaintiff believed was evidence of a
violation of state or federal law, rule, or regulation.
65. Defendant discriminated and retaliated against Plaintiff because of the report
made by Plaintiff. Defendant’s actions violated ORS 659A.199.
Case 3:16-cv-01907-MO Document 1 Filed 09/29/16 Page 10 of 13
PAGE 11 –COMPLAINT Law Offices of Daniel Snyder
Attorneys At Law
1000 S.W. Broadway, Suite 2400
Portland, Oregon 97205 (503) 241-3617 Fax (503) 241-2249
66. As a result, Plaintiff suffered damage and is entitled to the damages and other
relief set forth below.
67. Plaintiff is entitled to a declaration that the conduct of the Defendant violated
ORS 659A.199.
FIFTH CLAIM FOR RELIEF
(42 U.S.C. § 2000e-3(a) – Whistleblower)
68. Plaintiff re-alleges all relevant paragraphs as though fully restated herein.
69. Plaintiff opposed conduct that Plaintiff believed was evidence of a violation of 42
U.S.C. § 2000e, or because he made a charge, testified, assisted, or participated in any manner in
an investigation, proceeding, or hearing under this subchapter.
70. Defendant’s actions violated 42 U.S.C. § 2000e-3, are an unlawful employment
practice, and caused Plaintiff economic and noneconomic damages.
71. As a result, Plaintiff suffered damage and is entitled to the damages and other
relief set forth below.
72. Plaintiff is entitled to a declaration that the conduct of the Defendant violated 42
U.S.C. § 2000e-3.
SIXTH CLAIM FOR RELIEF
(ORS Chapter 659A.230 – Whistleblower)
73. Plaintiff re-alleges all relevant paragraphs as though fully restated herein.
74. Plaintiff initiated several BOLI and EEOC complaints and a lawsuit against
defendant.
75. Defendant discriminated and retaliated against Plaintiff because of the complaints
made by Plaintiff. Defendant’s actions violated ORS 659A.230.
Case 3:16-cv-01907-MO Document 1 Filed 09/29/16 Page 11 of 13
PAGE 12 –COMPLAINT Law Offices of Daniel Snyder
Attorneys At Law
1000 S.W. Broadway, Suite 2400
Portland, Oregon 97205 (503) 241-3617 Fax (503) 241-2249
76. As a result, Plaintiff suffered damage and is entitled to the damages and other
relief set forth below.
77. Plaintiff is entitled to a declaration that the conduct of the Defendant violated
ORS 659A.230.
DAMAGES
78. Plaintiff is entitled to equitable relief, including, an injunction prohibiting further
discrimination and retaliation.
79. Plaintiff is entitled to an award for past lost wages and benefits and future lost
earnings, benefits, and lost earning capacity, and other compensatory damages for past and future
pecuniary losses. Plaintiff should be awarded economic damages in an amount determined fair
by a jury.
80. Plaintiff is entitled to non-economic damages sufficient to compensate Plaintiff
for emotional pain, suffering, inconvenience, mental anguish, loss of enjoyment of life, and other
nonpecuniary losses in an amount to be proved at trial. Plaintiff should be awarded non-
economic damages in an amount determined fair by a jury.
81. To the extent any amount awarded to Plaintiff is for damages occurring prior to
the entry of judgment, Plaintiff is entitled to an award of prejudgment interest at the legal rate
from the date the damage occurred until the date of judgment.
82. Pursuant to ORS Chapter 659A and ORS 20.107, the Plaintiff is entitled to
recover his reasonable attorney fees and costs, including expert witness fees.
83. Plaintiff is entitled to post judgment interest on all damages, costs, expenses, and
fees from the date of judgment until the date paid.
PRAYER FOR RELIEF
Case 3:16-cv-01907-MO Document 1 Filed 09/29/16 Page 12 of 13
PAGE 13 –COMPLAINT Law Offices of Daniel Snyder
Attorneys At Law
1000 S.W. Broadway, Suite 2400
Portland, Oregon 97205 (503) 241-3617 Fax (503) 241-2249
Plaintiff prays for the following judgment against defendant:
1. A sum which will fully compensate Plaintiff for Plaintiff’s non-economic
damages in a sum that is just as determined by a jury;
2. A sum which will fully compensate Plaintiff for Plaintiff’s economic damages in
a sum that is just as determined by a jury;
3. Equitable relief, including but not limited to, injunctive relief;
4. Plaintiff’s costs and disbursements incurred herein;
5. Plaintiff’s attorney fees; and
6. For such other and further relief as the Court may deem just and equitable.
Plaintiff demands a trial by Jury.
Dated: September 29, 2016
Law Offices of Daniel Snyder
/s/ Carl Post
Daniel Snyder, OSB No. 783856
Carl Post, OSB No. 061058
John Burgess, OSB No. 106498
Telephone: (503) 241-3617
Facsimile: (503) 241-2249
Of Attorneys for Plaintiff
Case 3:16-cv-01907-MO Document 1 Filed 09/29/16 Page 13 of 13
CIVIL COVER SHEET
(SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)
I. (a) PLAINTIFFS DEFENDANTS
(b)(EXCEPT IN U.S. PLAINTIFF CASES) (IN U.S. PLAINTIFF CASES ONLY)
(c) (Firm Name, Address, and Telephone Number) (If Known)
II. BASIS OF JURISDICTION (Place an “X” in One Box Only) III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an “X” in One Box for Plaintiff(For Diversity Cases Only) and One Box for Defendant)
PTF DEF PTF DEF(U.S. Government Not a Party) or
and(Indicate Citizenship of Parties in Item III)
IV. NATURE OF SUIT (Place an “X” in One Box Only)CONTRACT TORTS FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES
PERSONAL INJURY PERSONAL INJURY
PROPERTY RIGHTS
LABOR SOCIAL SECURITY PERSONAL PROPERTY
REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS FEDERAL TAX SUITSHabeas Corpus:
IMMIGRATIONOther:
V. ORIGIN (Place an “X” in One Box Only)
(specify)
VI. CAUSE OF ACTION(Do not cite jurisdictional statutes unless diversity)
VII. REQUESTED IN COMPLAINT:
CLASS ACTION DEMAND $JURY DEMAND:
VIII. RELATED CASE(S) IF ANY (See instructions):
FOR OFFICE USE ONLY
Sneath, Rich
Clackamas
See attached.
Clackamas County
42 U.S.C. § 2000e et. seq.
discrimination/retaliation based on religion and filing administrative complaints and prior lawsuit
500,000.00
09/29/2016 /s/ Carl Post
Case 3:16-cv-01907-MO Document 1-1 Filed 09/29/16 Page 1 of 2
Attachment to Civil Cover Sheet
The following attorneys will be representing the Plaintiffs.
Daniel Snyder, Oregon State Bar #78385
Carl Post, OSB No. 06105
John Burgess, OSB No. 106498
LAW OFFICES OF DANIEL SNYDER
1000 S.W. Broadway, Suite 2400
Portland, Oregon 97205
Telephone: (503) 241-3617
Facsimile: (503) 241-2249
Case 3:16-cv-01907-MO Document 1-1 Filed 09/29/16 Page 2 of 2
AO 440 (Rev. 04/08) Civil Summons
UNITED STATES DISTRICT COURTfor the
__________ District of __________
)))))
Plaintiffv. Civil Action No.
Defendant
Summons in a Civil Action
To: (Defendant’s name and address)
A lawsuit has been filed against you.
Within days after service of this summons on you (not counting the day you received it), you must serveon the plaintiff an answer to the attached complaint or a motion under Rule 12 of the Federal Rules of Civil Procedure. Theanswer or motion must be served on the plaintiff’s attorney, whose name and address are:
If you fail to do so, judgment by default will be entered against you for the relief demanded in the complaint. You alsomust file your answer or motion with the court.
Name of clerk of court
Date:Deputy clerk’s signature
(Use 60 days if the defendant is the United States or a United States agency, or is an officer or employee of the United States allowed 60 days byRule 12(a)(3).)
District of Oregon
RICH SNEATH
Clackamas County3:16-cv-1907
Clackamas CountyClackamas County Counsel2051 Kaen RdOregon City OR 97045
21
Carl PostLaw Office of Daniel Snyder1000 SW Broadway, Suite 2400Portland, Oregon 97205
Case 3:16-cv-01907-MO Document 1-2 Filed 09/29/16 Page 1 of 1