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Oregonlawsuit

Oregonlawsuit

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Date Created:December 1, 2015

Date Uploaded to the Library:December 01, 2015

Tags:Oregonlawsuit, Measure, Summons, driver, Clerk, action, mexico, Civil, Plaintiffs, Illegal Immigration, Oregon, defendant, filed, plaintiff, document, transportation, states, district, court, united, IRS


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Case 6:15-cv-02069-AA
Document
Filed 11/04/15
Stephen Walters, OSB 801200
swalters@oregonlawcenter.org
Tel: (503) 473-8311
David Henretty, OSB 031870
dhenretty@oregonlawcenter.org
Tel: (503) 473-8684
Monica Goracke, OSB 060650
mgoracke@oregonlawcenter.org
Tel: (503) 473-8312
OREGON LAW CENTER
522 Fifth Ave., Suite 812
Portland, 97204
Fax: (503) 295-0676
Attorneys for Plaintiffs
UNITED STATES DISTRICT COURT
DISTRICT OREGON
EUGENE DIVISION
M.S., individual,
V.V., individual,
J.H., individual,
E.D., individual,
M.B., individual,
FAMILIAS ACCI domestic
non-profit corporation, and
LOS CUENTAN, domestic
non-profit corporation, behalf
themselves and all those similarly
situated,
Plaintiffs,
vs.
KATE BROWN, her official capacity Governor the State Oregon;
Case No.
CLASS ACTION
ALLEGATION COMPLAINT
(Civil Rights: Equal Protection/
Due Process/42 U.S.C. 1983)
Case 6:15-cv-02069-AA
Document
Filed 11/04/15
TAMMY BANEY, her official
capacity Chair the Oregon
Department Transportation
Commission;
DAVID LOHMAN, his official
capacity member the Oregon
Department Transportation
Commission;
SUSAN MORGAN, her official
capacity member the Oregon
Department Transportation
Commission;
ALANDO SIMPSON, his official
capacity member the Oregon
Department Transportation
Commission;
SEAN HALLORAN, his official
capacity member the Oregon
Department Transportation
Commission;
MATTHEW GARRETT, his
official capacity Director, Oregon
Department Transportation; and
TOM MCCLELLAN, his official
capacity Administrator Driver and
Motor Vehicles Division, Oregon
Department Transportation,
Defendants. NATURE THE ACTION This civil rights action challenge Oregon Ballot Measure Measure
referendum presented the voters the general election November 2014. Measure
rejected duly enacted statutes 833 which authorized the Oregon Department
Transportation issue limited-purpose driver cards Oregon residents who pass driving skill
and knowledge tests, regardless whether they also can prove legal presence the United
States. Plaintiffs contend, behalf themselves and all others similarly situated, that Measure
Case 6:15-cv-02069-AA
Document
Filed 11/04/15 violated the Constitution the United States arbitrarily denying driving privileges
Plaintiffs and others based their membership disfavored minority group, that Measure
was improper attempt the State Oregon regulate immigration, and that Measure
not supported considerations traffic safety any other state interest that legitimate.
Plaintiffs also contend that Measure was motivated substantial part animus towards
persons from Mexico and Central America. Plaintiffs seek certification this case class
action, declaration that Measure unconstitutional and was not effective revoke 833, injunction necessary enforce those declarations, and award their attorney fees and
costs.
II. JURISDICTION AND VENUE This Court has jurisdiction pursuant U.S.C. 1331 and 1343, that Plaintiffs
claims arise under the Fourteenth Amendment the Constitution the United States and
U.S.C. 1983. Venue proper this Court pursuant U.S.C. 1391(b)(1), because Plaintiffs and
Defendants are residents this District and all the events giving rise these claims occurred
here.
III. PARTIES Plaintiffs Plaintiff M.S. was born Mexico, over the age 18, and has lived the Willamette
Valley Oregon since 2000. She passed the vision, knowledge, and driving tests and holds
Oregon driver license that expires December 2015. She needs drive take her disabled
U.S. citizen son weekly medical appointments. M.S. driving privileges never have been
suspended, canceled, revoked, otherwise withdrawn. She will not permitted renew her
Case 6:15-cv-02069-AA
Document
Filed 11/04/15
driver license solely because she unable prove legal presence the United States. M.S.
would qualify for driver card under 833. Plaintiff V.V. was born Mexico, over the age 18, and has lived eastern Oregon
since 1992. She and her husband work support their children, three whom are U.S. citizens.
She works twenty miles from home. Her children are active school and sports. She needs
drive work, shop for her family, and take her children school-related activities and
medical appointments. V.V. passed the vision, knowledge, and driving tests and has held
Oregon driver license since 1994. Her driving privileges never have been suspended, canceled,
revoked otherwise withdrawn. Her license has expired, and she cannot renew the license
solely because she unable prove legal presence the United States. V.V. would qualify for driver card under 833. Plaintiff J.S. was born Mexico, over the age 18, and has lived the Willamette
Valley Oregon since 1997. passed the vision, knowledge, and driving tests and holds
Oregon driver license that expires December 2015. J.S. works many six days week
provide for his wife and children. Two his children are U.S. citizens. His job requires
driving, sometimes far miles from home. His family relies him drive them
church, located twelve miles from home, and medical appointments Salem and Portland.
J.S. driving privileges never have been suspended, canceled, revoked, otherwise withdrawn. will not permitted renew his driver license solely because unable prove legal
presence the United States. J.S. would qualify for driver card under 833. Plaintiff E.D. was born Mexico, over the age 18, and has lived the Oregon
coast since 1999. E.D. and her husband work provide for their children, two whom are U.S.
citizens. E.D. passed the vision, knowledge, and driving tests and was issued Oregon driver
Case 6:15-cv-02069-AA
Document
Filed 11/04/15
license that expired 2012. She quit her job after her driver license expired because she worked
outside town and did not want risk driving that distance without license. E.D. now works
closer home for lower wages and must work before 5:00 a.m. She avoids unnecessary
driving and, result, her children are unable participate after-school activities. She also
has stopped volunteering her children school, the food bank, and domestic violence
resource center. E.D. driving privileges never have been suspended, canceled, revoked,
otherwise withdrawn. She cannot renew her driver license solely because she unable prove
legal presence the United States. E.D. would qualify for driver card under 833. Plaintiff M.B. was born Mexico, over the age 18, and has lived eastern Oregon
since 1997. works 12-hour night shift six days week support his wife and children.
Three M.B. children are U.S. citizens. His work located nearly miles from home. One his children has serious health condition that requires travel Portland for medical
treatment. M.B. passed the vision, knowledge, and driving tests and has held Oregon driver
license since 1998. His license expires May 2016. M.B. driving privileges were suspended
for three months more than ten years ago but otherwise have not been suspended, canceled,
revoked, withdrawn. will not permitted renew his driver license solely because
unable prove legal presence the United States. M.B. would qualify for driver card under 833. Plaintiff Familias Acci Familias Oregon non-profit corporation with its
principal place business Multnomah County, Oregon. The mission Familias
promote holistic family well-being for Latinos through community engagement, education,
research and advocacy for social change. Familias serves persons who suffer from serious health
conditions, with emphasis chronic disease prevention and education, cancer survivorship,
Case 6:15-cv-02069-AA
Document
Filed 11/04/15
community leadership development, elimination health disparities, and community-based
participatory research. Many the people served Familias are unable obtain driving
privileges only because they cannot prove legal presence the United States. Familias cannot
fulfill its mission without ensuring that the persons serves attend their medical appointments,
receive medical treatment, and participate other research and leadership-development
activities. Because the implementation Measure 88, Familias has had spend significant
time and divert its limited resources arrange for and provide transportation and additional
support services. driver cards were available the persons serves, Familias would able serve more individuals and families and have more resources devote directly achieving
its mission.
10. Plaintiff Los Cuentan Los Oregon non-profit corporation with its
principal place business Clackamas County, Oregon. The mission Los
support Latino families impacted domestic and sexual violence, addictions, and child abuse; prevent family violence; and help individuals and families achieve self-sufficiency. Los operates emergency shelter for family survivors domestic violence and sexual
assault, support groups, parenting and financial education classes, food pantry, and clothes
closet, and helps families attend appointments related court, school, housing, employment,
therapy, and other medical needs. Los has limited staff and relies heavily volunteers
fulfill its mission. Appointments for the adults and children served Los often require
extensive travel throughout the Portland Metro area. Many those people are unable obtain
driving privileges only because they cannot prove legal presence the United States.
result, Los has been forced spend significant time and divert its limited resources
recruit and train twice many volunteers provide transportation. driver cards were
Case 6:15-cv-02069-AA
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Filed 11/04/15
available the persons serves, Los would able serve more individuals and
families and have more resources devote directly achieving its mission. Defendants
11. Defendant Kate Brown the Governor the State Oregon. Governor Brown
Constitutional duties include ensuring faithful execution State laws, including initiatives and
referenda such Measure 88. Governor Brown also supervises and has authority over the
Oregon Department Transportation ODOT the executive agency responsible for traffic
safety and for issuing driving privileges Oregon residents. Among other things, Governor
Brown appoints the members the Oregon Transportation Commission ODOT Commission
and the Director ODOT, who serves her pleasure. Governor Brown sued her official
capacity.
12. Defendant Tammy Baney the Chair, and Defendants David Lohman, Susan Morgan,
Alando Simpson, and Sean Halloran are members the ODOT Commission. Among other
things, the Chair and members the ODOT Commission are responsible for establishing
policies and adopting rules and orders governing the operation ODOT, including policies,
rules, and orders relating traffic safety and issuing driving privileges Oregon residents.
Commissioners Baney, Lohman, Morgan, Simpson, and Halloran each sued her his
official capacity.
13. Defendant Matthew Garrett the Director ODOT. Director Garrett supervises
and has authority over the activities ODOT, including those designed promote traffic safety
and issuing driving privileges Oregon residents. part his duties, Director Garrett
appoints and supervises the Administrator the Driver and Motor Vehicles Services Division
Case 6:15-cv-02069-AA
Document
Filed 11/04/15
ODOT DMV DMV mission promote driver safety, and responsible for issuing
driving privileges Oregon residents. Director Garrett sued his official capacity.
14. Defendant Tom McClellan the Administrator DMV. Administrator McClellan
supervises and responsible for the activities DMV, including setting standards for and
issuing driving privileges Oregon residents. Administrator McClellan sued his official
capacity.
IV. CLASS ACTION ALLEGATIONS
15. Plaintiffs bring this action pursuant Federal Rules Civil Procedure 23(a) and
23(b)(2), behalf themselves and class similarly situated persons consisting all
Oregon residents who have lived the State for more than one year and are denied driving
privileges solely because they are unable prove legal presence the United States.
16. All members the Plaintiff class are aggrieved persons under the Constitution the
United States and federal civil rights laws result the actions, policies, and practices
Defendants implementing and enforcing Measure 88. Plaintiffs seek declaratory and
injunctive relief, necessary, behalf themselves and all other class members prevent
Defendants from engaging future illegal conduct and rectify the effects present and past
discrimination.
17. This case properly maintainable plaintiffs class action pursuant Fed. Civ. 23(b)(2), that:
The class members are numerous make the joinder all them
impracticable. There are tens thousands Oregon residents who would able obtain renew driving privileges but are unable due the State enactment and
Case 6:15-cv-02069-AA
Document
Filed 11/04/15
enforcement Measure 88. ODOT estimated that, but for Measure 88, would have
issued approximately 84,000 driver cards the first nine months after 833 took effect.
There are questions law and fact common the class members, including:
(1)
Whether Measure impermissibly discriminates against Oregon
residents who are unable prove legal presence violation U.S. Const. Amend. XIV;
(2)
Whether Measure impermissibly singled out unpopular
minority for disparate treatment violation U.S. Const. Amend. XIV;
(3)
Whether Measure was motivated racial animus towards
persons from Mexico and Central America violation U.S. Const. Amend. XIV;
(4)
Whether Measure rationally related state interest that
(5)
Whether the purpose and enforcement Measure violate U.S.
legitimate; and
Const. Amend. XIV.
These common questions law and fact predominate over any questions affecting only
individual class members.
The claims the named individual Plaintiffs are typical those the
proposed class members. The named individual Plaintiffs, like other class members, are
Oregon residents who are unable obtain renew driving privileges due solely their
inability prove legal presence. The discriminatory treatment they have experienced and
will experience because their inability prove legal presence typical the
discriminatory treatment which members the class have suffered, are suffering, will
suffer unless the Court grants the relief requested.
Case 6:15-cv-02069-AA
Document
Filed 11/04/15
The claims the named Plaintiff organizations also are typical of, and not
diverge from, those the proposed class members. These organizations have the same
interest the named individual Plaintiffs and the members the proposed class ending
discrimination the State Oregon against persons who are unable obtain renew
driving privileges due solely their inability prove legal presence the United States.
The relief sought the named Plaintiff organizations the same that sought the
named individual Plaintiffs and the proposed class members, and the injuries they allege
will remedied that relief.
The named Plaintiffs will fairly and adequately protect the interests the
class members and have interests aligned with, and not antagonistic to, those the class.
The named Plaintiffs are represented counsel with extensive experience civil rights,
constitutional, and class action litigation. Plaintiffs and their counsel intend vigorously
prosecute this action obtain the relief sought behalf the class. Each named
individual Plaintiff member the proposed class that she eligible for driver
card pursuant 833 and has been, continues be, will denied Oregon driving
privileges due solely inability prove legal presence. Each named Plaintiff organization
serves persons who are members the proposed class and has suffered injury due the
inability those persons obtain renew driving privileges.
Defendants have acted refused act grounds generally applicable the
class denying driving privileges persons who have lived Oregon for more than one
year solely because they are unable prove legal presence the United States. Final
declaratory and injunctive relief with respect the class whole appropriate pursuant Fed. Civ. 23(b)(2).
Case 6:15-cv-02069-AA
Document
Filed 11/04/15 FACTUAL ALLEGATIONS General
18. There are approximately 120,000 persons residing Oregon who are unable prove
legal presence the United States. Many are parents U.S. citizen children, and many more
have lived and worked Oregon for years.
19. Approximately 90,000 the undocumented persons currently residing Oregon were
born Mexico, and thousands others were born Central America.
20. unlawful drive Oregon without state-issued driving privileges.
21. Oregon largely rural state where public transit service extremely limited does
not exist outside urban areas. Even urban areas where public transit available, service
the early morning, late night, weekends, and for inter-city out-of-county trips for work,
medical needs, shopping, recreation, other purposes limited nonexistent.
22. People who are unable drive lawfully Oregon suffer societal, economic, and
health-related disadvantages that they are deterred from driving work, shop, health
care facilities, school, places worship, otherwise are prevented from exercising their
liberty interest operating motor vehicle for lawful purpose. 1080
23. Historically, Oregon issued driving privileges all residents who met age requirements
and demonstrated the ability operate motor vehicle safely; proof legal presence the
United States was not required.
24. 2005, Congress adopted the REAL Act 2005, 119 Stat. 231, 301 REAL
which was intended tighten requirements for state-issued driver licenses and identification
cards that could used federally approved identification. Among other things, REAL
Case 6:15-cv-02069-AA
Document
Filed 11/04/15
required proof legal presence the United States for documents that would accepted
official identification for federal purposes, such passing through security checkpoints
maintained the Transportation Services Administration.
25. REAL expressly allows states issue driving privileges regardless immigration
status long the documents which provide evidence those driving privileges are
distinguishable from driver licenses identification cards that comply with REAL ID. Twelve
states and the District Columbia issue driving privileges their residents regardless
immigration status.
26. The 2008 Oregon Legislature enacted law, 1080, make State-issued driver
licenses compliant with REAL ID. Among other things, 1080 required proof legal
presence the United States obtain Oregon driver license. Pursuant 1080, the DMV
stopped granting driving privileges Oregon residents who were unable prove legal presence the United States. 833
27.
The 2013 Oregon Legislature restored driving privileges Oregon residents regardless immigration status enacting 833, which created limited-use driver card consistent
with REAL ID. 833 was the product extensive public hearings, committee work sessions,
and floor debate. The purpose 833 was promote driving safety Oregon roads.
During debate the House April 30, 2013, for example, one 833 sponsors stated:
First and foremost this bill about public safety. designed improve traffic safety, and
reduce the number unlicensed, uninsured drivers Oregon roads.
28. 833 directs ODOT issue, renew, replace driver card without requiring
person provide proof legal presence the United States, long the applicant satisfies
Case 6:15-cv-02069-AA
Document
Filed 11/04/15
the same age, vision, and driving standards that are required obtain renew driver license;
provides proof identity, date birth, and residency Oregon for more than one year;
provides Social Security number statement that they have not been issued one; and pays
the required fee.
29. Consistent with REAL ID, there are number limitations the driver cards
authorized 833 which distinguish them from Oregon driver licenses, including:
the driver card requires residency Oregon for more than one year, and driver
license does not;
the driver card valid for four years, opposed eight years for driver
license;
the driver card must contain the words driver card and feature distinguishing
the driver card from driver license and driver permit;
the driver card may not contain the words driver license driver permit;
the driver card may used only provide evidence driving privileges;
identify person anatomical donor, emancipated minor, veteran, missing person; provide driver license number for statutory civil money judgment, lien record abstract,
and paternity child support purposes.
30. Under 833, the only documents applicant for driver card may use prove
identity are unexpired valid passport from the person country citizenship, unexpired
valid identification document issued the consulate the person country citizenship
has been determined meet DMV reliability requirements, such other valid
documentation, defined the [DMV] rule.
Case 6:15-cv-02069-AA
Document
Filed 11/04/15
31. 833 passed the Oregon Senate vote April 23, 2013, and passed the
Oregon House vote April 30, 2013. 833 was signed into law the
Governor May 2013, with effective date January 2014. Measure
32. May 2013, two legislators who had opposed 833 and individual involved efforts curb illegal immigration (collectively, Chief Petitioners filed referendum Measure repeal 833, pursuant Article IV, 1(3)(a) the Oregon Constitution.
33. The purpose Measure was take driving privileges from the Plaintiff class
because they were illegal immigrants. Opposition statements the Official 2014 General
Election Voter Pamphlet used variation the phrase illegal immigrant forty times. his
opposition statement the Official 2014 General Election Voter Pamphlet, for example, one
Chief Petitioner wrote: Driving privilege, and citizenship allow people who are
here illegally have the privilege driving insulting all citizens. another opposition
statement the Official 2014 General Election Voter Pamphlet, Chief Petitioner stated that
the purpose the referendum campaign [was] repeal illegal-immigrant driver cards, and
that driver cards would better enable illegal immigrants take jobs from Oregonians. The
president organization known Oregonians for Immigration Reform OFIR wrote
her opposition statement the Official 2014 General Election Voter Pamphlet that driver cards
would cause surge illegal immigration Oregon and likely increase criminal behavior
such [c]artel operations, human trafficking and the flow narcotics through Oregon.
34. Other public statements opposition 833 similarly singled out illegal
immigrants the specific target their efforts. For example,
Case 6:15-cv-02069-AA
Document
Filed 11/04/15 May 2013, driver card opponents formed the Protect Oregon Driver Licenses
Political Action Committee and promptly set the Protect Oregon Driver Licenses website
(www.protectoregondl.org) PODL order repeal 833, law they characterized
legitimiz[ing] the presence illegal aliens Oregon granting them highly coveted state
issued the form driver card. The PODL home page specifically referred visitors
the OFIR website [l]earn more about stopping illegal immigration Oregon. During the Measure campaign, the PODL website urged Oregon voters
repeal 833 because:
Illegal immigration serious problem the U.S. Neglect enforcement
the immigration laws, over the past several decades well currently, has
resulted millions illegal immigrants entering the U.S. without inspection,
dangerous situation from the standpoint national security and public health.
For example, the September terrorists carried among them over state
drivers licenses and identification cards using over 300 aliases. These documents
allowed them obtain housing, transportation and other accommodations without
raising suspicion while they planned and executed their deadly conspiracy that
fateful day. Accommodating illegal aliens invites more come. Recent history
clearly shows this. Illegal immigration inflates the population, further burdening
our already-stressed natural environment. adversely affects the labor market
and swamps our overburdened entitlement programs. Citizens are forced
compete with illegal aliens for jobs, causing significant unemployment and wage
depression. Loss respect for the rule law grows consequence such
legislation. Observance the rule law essential for successful economy
and civil society. During the Measure campaign, the PODL website quoted Chief
Petitioner saying: You have wonder someone willing disregard
immigration laws, what other laws are they willing disregard?. .We should very
careful about who allow the privilege driving Oregon roads. During the Measure campaign, the PODL website quoted another Chief
Petitioner saying: The state Oregon should have business rewarding illegal
behavior and, [w]ith the passage 833, the Legislature actions invited other
Case 6:15-cv-02069-AA
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Filed 11/04/15
people enter this country and state illegally. individuals know that they not have here legally get license drive and have job why would they not come here droves?
35. Measure also was motivated racial animus. Measure primarily affects persons
from Mexico and Central America, and bears more heavily those persons than individuals any other race nationality. Opposition statements the Official 2014 General Election
Voter Pamphlet denounced the Mexican consular possible form identification, the
possibility increased activity Mexican drug cartels, and the flood and surge
Central American minors our southern border. Opposition statements did not single out,
even mention, immigrants any other race nationality.
36. The Oregon Secretary State qualified Measure for the November 2014 Election. November 2014, 66% Oregon voters voted Measure 88.
37. result Measure 88, Defendants refuse issue driver cards the Plaintiff class authorized and required 833.
VI. FIRST CLAIM FOR RELIEF
(U.S. Const. Amend. XIV (Equal Protection): U.S.C. 1983)
38. Plaintiffs incorporate this reference the allegations paragraphs through 37,
above.
39. Measure took driving privileges from Plaintiffs for reasons which have rational
relationship traffic safety any other state interest that legitimate.
40. desire punish, avoid rewarding, politically unpopular minority, such
the Plaintiff class, taking away driving privileges from members that minority not
legitimate state interest.
Case 6:15-cv-02069-AA
Document
Filed 11/04/15
41. The regulation immigration not legitimate state interest. The federal government
has broad, undoubted power over the subject immigration and the status aliens. Congress
has rejected criminal penalties for unauthorized presence and work inhumane and contrary
our nation tradition and history. particular, not crime for person seek engage
unauthorized work the United States, nor crime for undocumented person simply present this country. Denying driving privileges persons who cannot prove legal
presence the United States neither required nor harmonious with federal policy
expressed REAL ID.
42. The enactment Measure and ODOT consequent refusal issue driver cards
Plaintiffs and members the Plaintiff class provided 833 not rationally related
any legitimate state interest, violation the Equal Protection Clause the Fourteenth
Amendment the Constitution the United States.
VII. SECOND CLAIM FOR RELIEF
(U.S. Const. Amend. XIV (Due Process): U.S.C. 1983)
43. Plaintiffs incorporate this reference the allegations paragraphs through 37, and through 42, above.
44. The enactment Measure and ODOT consequent refusal issue driver cards
Plaintiffs and members the Plaintiff class provided 833 arbitrary, capricious, and
not rationally related any legitimate state interest, violation the Due Process Clause the
Fourteenth Amendment the Constitution the United States.
Case 6:15-cv-02069-AA
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Filed 11/04/15
VIII. THIRD CLAIM FOR RELIEF
(U.S. Const. Amend. XIV (Equal Protection): U.S.C. 1983)
45. Plaintiffs incorporate this reference the allegations paragraphs through 37,
through 42, and above.
46. The enactment Measure was motivated, least part, animus towards
Mexicans and Central Americans, and not narrowly tailored advance any state interest that legitimate, let alone compelling. result, Defendants refusal issue driver cards pursuant 833 Plaintiffs and members the Plaintiff class violates the Equal Protection Clause
the Fourteenth Amendment the Constitution the United States.
IX. PRAYER FOR RELIEF
WHEREFORE, Plaintiffs request that the Court grant the following relief: Certification Plaintiff class alleged above; declaration that Measure violates Plaintiffs rights under the Equal Protection and
Due Process Clauses the Fourteenth Amendment the Constitution the United
States, and void and unenforceable; declaration that Defendants are authorized and required issue driver cards pursuant 833; injunction, necessary, prohibit Defendants from enforcing Measure and
requiring them issue driver cards pursuant 833; Plaintiffs costs and reasonable attorney fees pursuant U.S.C. 1988; and
Case 6:15-cv-02069-AA
Document
Filed 11/04/15 Such other and further relief this Court deems just and proper.
DATED this 4th day November, 2015.
OREGON LAW CENTER
s/David Henretty
David Henretty, OSB 031870
(503) 473-8684
Attorney for Plaintiffs
Case 6:15-cv-02069-AA (Rev. 12/12)
Document 1-1
Filed 11/04/15
CIVIL COVER SHEET
The civil cover sheet and the information contained herein neither replace nor supplement the filing and service pleadings other papers required law, except
provided local rules court. This form, approved the Judicial Conference the United States September 1974, required for the use the Clerk Court for the
purpose initiating the civil docket sheet. (SEE INSTRUCTIONS NEXT PAGE THIS FORM.) (a) PLAINTIFFS
DEFENDANTS
M.S., V.V., J.H., E.D., M.B., Familias Accion, and Los Ninos Cuentan
(b) County Residence First Listed Plaintiff
State Oregon:Kate Brown (Governor); ODOT:Tammy Baney, David
Lohman, Susan Morgan, Alando Simpson, Sean OHalloran
(Commissioners), Matthew Garrett (Director); DMV:Tom Mcclellan (Ad
County Residence First Listed Defendant
Multnomah
(EXCEPT U.S. PLAINTIFF CASES)
NOTE:
(IN U.S. PLAINTIFF CASES ONLY) LAND CONDEMNATION CASES, USE THE LOCATION
THE TRACT LAND INVOLVED.
Attorneys (If Known)
(c) Attorneys (Firm Name, Address, and Telephone Number)
Oregon Law Center, 522 Fifth Ave., Suite 812, Portland, 97204,
503-473-8684
II. BASIS JURISDICTION (Place One Box Only)
Oregon Attorney General, 1162 Court NE, Salem, 97301, 503378-6002
III. CITIZENSHIP PRINCIPAL PARTIES (Place One Box for Plaintiff
U.S. Government
Plaintiff
U.S. Government
Defendant
(For Diversity Cases Only)
PTF
Citizen This State
Citizen Another State
Federal Question
(U.S. Government Not Party)
Diversity
(Indicate Citizenship Parties Item III)
DEF
Incorporated and Principal Place Business Another State
Citizen Subject
Foreign Country
and One Box for Defendant)
PTF
DEF
Incorporated Principal Place Business This State
Foreign Nation
IV. NATURE SUIT (Place One Box Only)
CONTRACT
TORTS
110 Insurance
120 Marine
130 Miller Act
140 Negotiable Instrument
150 Recovery Overpayment Enforcement Judgment
151 Medicare Act
152 Recovery Defaulted
Student Loans
(Excludes Veterans)
153 Recovery Overpayment Veteran Benefits
160 Stockholders Suits
190 Other Contract
195 Contract Product Liability
196 Franchise
REAL PROPERTY
210 Land Condemnation
220 Foreclosure
230 Rent Lease Ejectment
240 Torts Land
245 Tort Product Liability
290 All Other Real Property
PERSONAL INJURY
310 Airplane
315 Airplane Product
Liability
320 Assault, Libel
Slander
330 Federal Employers
Liability
340 Marine
345 Marine Product
Liability
350 Motor Vehicle
355 Motor Vehicle
Product Liability
360 Other Personal
Injury
362 Personal Injury Medical Malpractice
CIVIL RIGHTS
440 Other Civil Rights
441 Voting
442 Employment
443 Housing/
Accommodations
445 Amer. w/Disabilities Employment
446 Amer. w/Disabilities Other
448 Education ORIGIN (Place One Box Only) Removed from Original
Proceeding
State Court
FORFEITURE/PENALTY
PERSONAL INJURY
365 Personal Injury Product Liability
367 Health Care/
Pharmaceutical
Personal Injury
Product Liability
368 Asbestos Personal
Injury Product
Liability
PERSONAL PROPERTY
370 Other Fraud
371 Truth Lending
380 Other Personal
Property Damage
385 Property Damage
Product Liability
PRISONER PETITIONS
Habeas Corpus:
463 Alien Detainee
510 Motions Vacate
Sentence
530 General
535 Death Penalty
Other:
540 Mandamus Other
550 Civil Rights
555 Prison Condition
560 Civil Detainee Conditions
Confinement
Remanded from
Appellate Court
625 Drug Related Seizure Property USC 881
690 Other
BANKRUPTCY
422 Appeal USC 158
423 Withdrawal USC 157
PROPERTY RIGHTS
820 Copyrights
830 Patent
840 Trademark
LABOR
710 Fair Labor Standards
Act
720 Labor/Management
Relations
740 Railway Labor Act
751 Family and Medical
Leave Act
790 Other Labor Litigation
791 Employee Retirement
Income Security Act
SOCIAL SECURITY
861 HIA (1395ff)
862 Black Lung (923)
863 DIWC/DIWW (405(g))
864 SSID Title XVI
865 RSI (405(g))
FEDERAL TAX SUITS
870 Taxes (U.S. Plaintiff Defendant)
871 IRS Third Party USC 7609
OTHER STATUTES
375 False Claims Act
400 State Reapportionment
410 Antitrust
430 Banks and Banking
450 Commerce
460 Deportation
470 Racketeer Influenced and
Corrupt Organizations
480 Consumer Credit
490 Cable/Sat
850 Securities/Commodities/
Exchange
890 Other Statutory Actions
891 Agricultural Acts
893 Environmental Matters
895 Freedom Information
Act
896 Arbitration
899 Administrative Procedure
Act/Review Appeal
Agency Decision
950 Constitutionality
State Statutes
IMMIGRATION
462 Naturalization Application
465 Other Immigration
Actions Reinstated
Reopened Transferred from
Another District
(specify) Multidistrict
Litigation
Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity): U.S.C. Sec. 1983
VI. CAUSE ACTION Brief description cause:
Violation the Equal Protection and Due Process Clauses the Fourteenth Amendment the U.S. Const.
CHECK THIS CLASS ACTION
VII. REQUESTED
UNDER RULE 23, F.R.Cv.P.
COMPLAINT:
VIII. RELATED CASE(S)
(See instructions): ANY
JUDGE N/A
DATE
CHECK YES only demanded complaint:
Yes
JURY DEMAND:
DEMAND
DOCKET NUMBER N/A
SIGNATURE ATTORNEY RECORD
s/David Henretty
11/02/2015
FOR OFFICE USE ONLY
RECEIPT
AMOUNT
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JUDGE
MAG. JUDGE
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Case 6:15-cv-02069-AA
Document 1-1
Filed 11/04/15 Reverse (Rev. 12/12)
INSTRUCTIONS FOR ATTORNEYS COMPLETING CIVIL COVER SHEET FORM
Authority For Civil Cover Sheet
The civil cover sheet and the information contained herein neither replaces nor supplements the filings and service pleading other papers
required law, except provided local rules court. This form, approved the Judicial Conference the United States September 1974,
required for the use the Clerk Court for the purpose initiating the civil docket sheet. Consequently, civil cover sheet submitted the Clerk
Court for each civil complaint filed. The attorney filing case should complete the form follows:
I.(a)
(b)
(c)
Plaintiffs-Defendants. Enter names (last, first, middle initial) plaintiff and defendant. the plaintiff defendant government agency, use
only the full name standard abbreviations. the plaintiff defendant official within government agency, identify first the agency and
then the official, giving both name and title.
County Residence. For each civil case filed, except U.S. plaintiff cases, enter the name the county where the first listed plaintiff resides the
time filing. U.S. plaintiff cases, enter the name the county which the first listed defendant resides the time filing. (NOTE: land
condemnation cases, the county residence the defendant the location the tract land involved.)
Attorneys. Enter the firm name, address, telephone number, and attorney record. there are several attorneys, list them attachment, noting this section (see attachment).
II.
Jurisdiction. The basis jurisdiction set forth under Rule 8(a), F.R.Cv.P., which requires that jurisdictions shown pleadings. Place one the boxes. there more than one basis jurisdiction, precedence given the order shown below.
United States plaintiff. (1) Jurisdiction based U.S.C. 1345 and 1348. Suits agencies and officers the United States are included here.
United States defendant. (2) When the plaintiff suing the United States, its officers agencies, place this box.
Federal question. (3) This refers suits under U.S.C. 1331, where jurisdiction arises under the Constitution the United States, amendment the Constitution, act Congress treaty the United States. cases where the U.S. party, the U.S. plaintiff defendant code takes
precedence, and box should marked.
Diversity citizenship. (4) This refers suits under U.S.C. 1332, where parties are citizens different states. When Box checked, the
citizenship the different parties must checked. (See Section III below; NOTE: federal question actions take precedence over diversity
cases.)
III.
Residence (citizenship) Principal Parties. This section the completed diversity citizenship was indicated above. Mark this
section for each principal party.
IV.
Nature Suit. Place the appropriate box. the nature suit cannot determined, sure the cause action, Section below,
sufficient enable the deputy clerk the statistical clerk(s) the Administrative Office determine the nature suit. the cause fits more than
one nature suit, select the most definitive.
Origin. Place one the six boxes.
Original Proceedings. (1) Cases which originate the United States district courts.
Removed from State Court. (2) Proceedings initiated state courts may removed the district courts under Title U.S.C., Section 1441.
When the petition for removal granted, check this box.
Remanded from Appellate Court. (3) Check this box for cases remanded the district court for further action. Use the date remand the filing
date.
Reinstated Reopened. (4) Check this box for cases reinstated reopened the district court. Use the reopening date the filing date.
Transferred from Another District. (5) For cases transferred under Title U.S.C. Section 1404(a). not use this for within district transfers
multidistrict litigation transfers.
Multidistrict Litigation. (6) Check this box when multidistrict case transferred into the district under authority Title U.S.C. Section 1407.
When this box checked, not check (5) above.
VI.
Cause Action. Report the civil statute directly related the cause action and give brief description the cause. not cite jurisdictional
statutes unless diversity. Example: U.S. Civil Statute: USC 553 Brief Description: Unauthorized reception cable service
VII.
Requested Complaint. Class Action. Place this box you are filing class action under Rule 23, F.R.Cv.P.
Demand. this space enter the actual dollar amount being demanded indicate other demand, such preliminary injunction.
Jury Demand. Check the appropriate box indicate whether not jury being demanded.
VIII. Related Cases. This section the used reference related pending cases, any. there are related pending cases, insert the docket
numbers and the corresponding judge names for such cases.
Date and Attorney Signature. Date and sign the civil cover sheet.
Case 6:15-cv-02069-AA
Document 1-2
Filed 11/04/15 440 (Rev. 06/12) Summons Civil Action
UNITED STATES DISTRICT COURT
for the
District Oregon
__________ District __________
M.S., al.
Plaintiff(s)
KATE BROWN, al.
Defendant(s)
Civil Action No.
SUMMONS CIVIL ACTION
To: (Defendant name and address) Kate Brown, Governor Oregon, c/o Oregon Attorney General, 1162 Court NE,
Salem, 97301 lawsuit has been filed against you.
Within days after service this summons you (not counting the day you received it) days you
are the United States United States agency, officer employee the United States described Fed. Civ. (a)(2) (3) you must serve the plaintiff answer the attached complaint motion under Rule
the Federal Rules Civil Procedure. The answer motion must served the plaintiff plaintiff attorney,
whose name and address are: David Henretty
Oregon Law Center
522 Fifth Ave., Suite 812
Portland, 97204 you fail respond, judgment default will entered against you for the relief demanded the complaint.
You also must file your answer motion with the court.
CLERK COURT
Date:
Signature Clerk Deputy Clerk
Case 6:15-cv-02069-AA
Document 1-2
Filed 11/04/15 440 (Rev. 06/12) Summons Civil Action (Page
Civil Action No.
PROOF SERVICE
(This section should not filed with the court unless required Fed. Civ. (l))
This summons for (name individual and title, any)
was received (date) personally served the summons the individual (place) (date) left the summons the individual residence usual place abode with (name) person suitable age and discretion who resides there, (date) and mailed copy the individual last known address; served the summons (name individual) who
designated law accept service process behalf (name organization) (date) returned the summons unexecuted because
Other (specify): fees are
for travel and
for services, for total
0.00 declare under penalty perjury that this information true.
Date:
Server signature
Printed name and title
Server address
Additional information regarding attempted service, etc:
Print
Save As...
Reset
Case 6:15-cv-02069-AA
Document 1-3
Filed 11/04/15 440 (Rev. 06/12) Summons Civil Action
UNITED STATES DISTRICT COURT
for the
District Oregon
__________ District __________
M.S., al.
Plaintiff(s)
KATE BROWN, al.
Defendant(s)
Civil Action No.
SUMMONS CIVIL ACTION
To: (Defendant name and address) Tammy Baney, Chair the Oregon Department Transportation Commission, c/o
Oregon Attorney General, 1162 Court NE, Salem, 97301 lawsuit has been filed against you.
Within days after service this summons you (not counting the day you received it) days you
are the United States United States agency, officer employee the United States described Fed. Civ. (a)(2) (3) you must serve the plaintiff answer the attached complaint motion under Rule
the Federal Rules Civil Procedure. The answer motion must served the plaintiff plaintiff attorney,
whose name and address are: David Henretty
Oregon Law Center
522 Fifth Ave., Suite 812
Portland, 97204 you fail respond, judgment default will entered against you for the relief demanded the complaint.
You also must file your answer motion with the court.
CLERK COURT
Date:
Signature Clerk Deputy Clerk
Case 6:15-cv-02069-AA
Document 1-3
Filed 11/04/15 440 (Rev. 06/12) Summons Civil Action (Page
Civil Action No.
PROOF SERVICE
(This section should not filed with the court unless required Fed. Civ. (l))
This summons for (name individual and title, any)
was received (date) personally served the summons the individual (place) (date) left the summons the individual residence usual place abode with (name) person suitable age and discretion who resides there, (date) and mailed copy the individual last known address; served the summons (name individual) who
designated law accept service process behalf (name organization) (date) returned the summons unexecuted because
Other (specify): fees are
for travel and
for services, for total
0.00 declare under penalty perjury that this information true.
Date:
Server signature
Printed name and title
Server address
Additional information regarding attempted service, etc:
Print
Save As...
Reset
Case 6:15-cv-02069-AA
Document 1-4
Filed 11/04/15 440 (Rev. 06/12) Summons Civil Action
UNITED STATES DISTRICT COURT
for the
District Oregon
__________ District __________
M.S., al.
Plaintiff(s)
KATE BROWN, al.
Defendant(s)
Civil Action No.
SUMMONS CIVIL ACTION
To: (Defendant name and address) David Lohman, member the Oregon Department Transportation Commission, c/o
Oregon Attorney General, 1162 Court NE, Salem, 97301 lawsuit has been filed against you.
Within days after service this summons you (not counting the day you received it) days you
are the United States United States agency, officer employee the United States described Fed. Civ. (a)(2) (3) you must serve the plaintiff answer the attached complaint motion under Rule
the Federal Rules Civil Procedure. The answer motion must served the plaintiff plaintiff attorney,
whose name and address are: David Henretty
Oregon Law Center
522 Fifth Ave., Suite 812
Portland, 97204 you fail respond, judgment default will entered against you for the relief demanded the complaint.
You also must file your answer motion with the court.
CLERK COURT
Date:
Signature Clerk Deputy Clerk
Case 6:15-cv-02069-AA
Document 1-4
Filed 11/04/15 440 (Rev. 06/12) Summons Civil Action (Page
Civil Action No.
PROOF SERVICE
(This section should not filed with the court unless required Fed. Civ. (l))
This summons for (name individual and title, any)
was received (date) personally served the summons the individual (place) (date) left the summons the individual residence usual place abode with (name) person suitable age and discretion who resides there, (date) and mailed copy the individual last known address; served the summons (name individual) who
designated law accept service process behalf (name organization) (date) returned the summons unexecuted because
Other (specify): fees are
for travel and
for services, for total
0.00 declare under penalty perjury that this information true.
Date:
Server signature
Printed name and title
Server address
Additional information regarding attempted service, etc:
Print
Save As...
Reset
Case 6:15-cv-02069-AA
Document 1-5
Filed 11/04/15 440 (Rev. 06/12) Summons Civil Action
UNITED STATES DISTRICT COURT
for the
District Oregon
__________ District __________
M.S., al.
Plaintiff(s)
KATE BROWN, al.
Defendant(s)
Civil Action No.
SUMMONS CIVIL ACTION
To: (Defendant name and address) Susan Morgan, member the Oregon Department Transportation Commission, c/o
Oregon Attorney General, 1162 Court NE, Salem, 97301 lawsuit has been filed against you.
Within days after service this summons you (not counting the day you received it) days you
are the United States United States agency, officer employee the United States described Fed. Civ. (a)(2) (3) you must serve the plaintiff answer the attached complaint motion under Rule
the Federal Rules Civil Procedure. The answer motion must served the plaintiff plaintiff attorney,
whose name and address are: David Henretty
Oregon Law Center
522 Fifth Ave., Suite 812
Portland, 97204 you fail respond, judgment default will entered against you for the relief demanded the complaint.
You also must file your answer motion with the court.
CLERK COURT
Date:
Signature Clerk Deputy Clerk
Case 6:15-cv-02069-AA
Document 1-5
Filed 11/04/15 440 (Rev. 06/12) Summons Civil Action (Page
Civil Action No.
PROOF SERVICE
(This section should not filed with the court unless required Fed. Civ. (l))
This summons for (name individual and title, any)
was received (date) personally served the summons the individual (place) (date) left the summons the individual residence usual place abode with (name) person suitable age and discretion who resides there, (date) and mailed copy the individual last known address; served the summons (name individual) who
designated law accept service process behalf (name organization) (date) returned the summons unexecuted because
Other (specify): fees are
for travel and
for services, for total
0.00 declare under penalty perjury that this information true.
Date:
Server signature
Printed name and title
Server address
Additional information regarding attempted service, etc:
Print
Save As...
Reset
Case 6:15-cv-02069-AA
Document 1-6
Filed 11/04/15 440 (Rev. 06/12) Summons Civil Action
UNITED STATES DISTRICT COURT
for the
District Oregon
__________ District __________
M.S., al.
Plaintiff(s)
KATE BROWN, al.
Defendant(s)
Civil Action No.
SUMMONS CIVIL ACTION
To: (Defendant name and address) Alando Simpson, member the Oregon Department Transportation Commission,
c/o Oregon Attorney General, 1162 Court NE, Salem, 97301 lawsuit has been filed against you.
Within days after service this summons you (not counting the day you received it) days you
are the United States United States agency, officer employee the United States described Fed. Civ. (a)(2) (3) you must serve the plaintiff answer the attached complaint motion under Rule
the Federal Rules Civil Procedure. The answer motion must served the plaintiff plaintiff attorney,
whose name and address are: David Henretty
Oregon Law Center
522 Fifth Ave., Suite 812
Portland, 97204 you fail respond, judgment default will entered against you for the relief demanded the complaint.
You also must file your answer motion with the court.
CLERK COURT
Date:
Signature Clerk Deputy Clerk
Case 6:15-cv-02069-AA
Document 1-6
Filed 11/04/15 440 (Rev. 06/12) Summons Civil Action (Page
Civil Action No.
PROOF SERVICE
(This section should not filed with the court unless required Fed. Civ. (l))
This summons for (name individual and title, any)
was received (date) personally served the summons the individual (place) (date) left the summons the individual residence usual place abode with (name) person suitable age and discretion who resides there, (date) and mailed copy the individual last known address; served the summons (name individual) who
designated law accept service process behalf (name organization) (date) returned the summons unexecuted because
Other (specify): fees are
for travel and
for services, for total
0.00 declare under penalty perjury that this information true.
Date:
Server signature
Printed name and title
Server address
Additional information regarding attempted service, etc:
Print
Save As...
Reset
Case 6:15-cv-02069-AA
Document 1-7
Filed 11/04/15 440 (Rev. 06/12) Summons Civil Action
UNITED STATES DISTRICT COURT
for the
District Oregon
__________ District __________
M.S., al.
Plaintiff(s)
KATE BROWN, al.
Defendant(s)
Civil Action No.
SUMMONS CIVIL ACTION
To: (Defendant name and address) Sean OHalloran, member the Oregon Department Transportation Commission,
c/o Oregon Attorney General, 1162 Court NE, Salem, 97301 lawsuit has been filed against you.
Within days after service this summons you (not counting the day you received it) days you
are the United States United States agency, officer employee the United States described Fed. Civ. (a)(2) (3) you must serve the plaintiff answer the attached complaint motion under Rule
the Federal Rules Civil Procedure. The answer motion must served the plaintiff plaintiff attorney,
whose name and address are: David Henretty
Oregon Law Center
522 Fifth Ave., Suite 812
Portland, 97204 you fail respond, judgment default will entered against you for the relief demanded the complaint.
You also must file your answer motion with the court.
CLERK COURT
Date:
Signature Clerk Deputy Clerk
Case 6:15-cv-02069-AA
Document 1-7
Filed 11/04/15 440 (Rev. 06/12) Summons Civil Action (Page
Civil Action No.
PROOF SERVICE
(This section should not filed with the court unless required Fed. Civ. (l))
This summons for (name individual and title, any)
was received (date) personally served the summons the individual (place) (date) left the summons the individual residence usual place abode with (name) person suitable age and discretion who resides there, (date) and mailed copy the individual last known address; served the summons (name individual) who
designated law accept service process behalf (name organization) (date) returned the summons unexecuted because
Other (specify): fees are
for travel and
for services, for total
0.00 declare under penalty perjury that this information true.
Date:
Server signature
Printed name and title
Server address
Additional information regarding attempted service, etc:
Print
Save As...
Reset
Case 6:15-cv-02069-AA
Document 1-8
Filed 11/04/15 440 (Rev. 06/12) Summons Civil Action
UNITED STATES DISTRICT COURT
for the
District Oregon
__________ District __________
M.S., al.
Plaintiff(s)
KATE BROWN, al.
Defendant(s)
Civil Action No.
SUMMONS CIVIL ACTION
To: (Defendant name and address) Matthew Garrett, Director the Oregon Department Transportation, c/o Oregon
Attorney General, 1162 Court NE, Salem, 97301 lawsuit has been filed against you.
Within days after service this summons you (not counting the day you received it) days you
are the United States United States agency, officer employee the United States described Fed. Civ. (a)(2) (3) you must serve the plaintiff answer the attached complaint motion under Rule
the Federal Rules Civil Procedure. The answer motion must served the plaintiff plaintiff attorney,
whose name and address are: David Henretty
Oregon Law Center
522 Fifth Ave., Suite 812
Portland, 97204 you fail respond, judgment default will entered against you for the relief demanded the complaint.
You also must file your answer motion with the court.
CLERK COURT
Date:
Signature Clerk Deputy Clerk
Case 6:15-cv-02069-AA
Document 1-8
Filed 11/04/15 440 (Rev. 06/12) Summons Civil Action (Page
Civil Action No.
PROOF SERVICE
(This section should not filed with the court unless required Fed. Civ. (l))
This summons for (name individual and title, any)
was received (date) personally served the summons the individual (place) (date) left the summons the individual residence usual place abode with (name) person suitable age and discretion who resides there, (date) and mailed copy the individual last known address; served the summons (name individual) who
designated law accept service process behalf (name organization) (date) returned the summons unexecuted because
Other (specify): fees are
for travel and
for services, for total
0.00 declare under penalty perjury that this information true.
Date:
Server signature
Printed name and title
Server address
Additional information regarding attempted service, etc:
Print
Save As...
Reset
Case 6:15-cv-02069-AA
Document 1-9
Filed 11/04/15 440 (Rev. 06/12) Summons Civil Action
UNITED STATES DISTRICT COURT
for the
District Oregon
__________ District __________
M.S., al.
Plaintiff(s)
KATE BROWN, al.
Defendant(s)
Civil Action No.
SUMMONS CIVIL ACTION
To: (Defendant name and address) Tom McClellan, Administrator the Driver and Motor Vehicles Division, Oregon
Department Transportation, c/o Oregon Attorney General, 1162 Court NE,
Salem, 97301 lawsuit has been filed against you.
Within days after service this summons you (not counting the day you received it) days you
are the United States United States agency, officer employee the United States described Fed. Civ. (a)(2) (3) you must serve the plaintiff answer the attached complaint motion under Rule
the Federal Rules Civil Procedure. The answer motion must served the plaintiff plaintiff attorney,
whose name and address are: David Henretty
Oregon Law Center
522 Fifth Ave., Suite 812
Portland, 97204 you fail respond, judgment default will entered against you for the relief demanded the complaint.
You also must file your answer motion with the court.
CLERK COURT
Date:
Signature Clerk Deputy Clerk
Case 6:15-cv-02069-AA
Document 1-9
Filed 11/04/15 440 (Rev. 06/12) Summons Civil Action (Page
Civil Action No.
PROOF SERVICE
(This section should not filed with the court unless required Fed. Civ. (l))
This summons for (name individual and title, any)
was received (date) personally served the summons the individual (place) (date) left the summons the individual residence usual place abode with (name) person suitable age and discretion who resides there, (date) and mailed copy the individual last known address; served the summons (name individual) who
designated law accept service process behalf (name organization) (date) returned the summons unexecuted because
Other (specify): fees are
for travel and
for services, for total
0.00 declare under penalty perjury that this information true.
Date:
Server signature
Printed name and title
Server address
Additional information regarding attempted service, etc:
Print
Save As...
Reset