1 - Collective	and	Class	Action	Complaint

Alan J. Leiman (OSB No. 98074)

LEIMAN & JOHNSON, LLC

44 W. Broadway, Suite 326

Eugene, OR 97401

alan@leimanlaw.com

Drew G. Johnson (OSB No. 114289)

LEIMAN & JOHNSON, LLC

44 W. Broadway, Suite 326

Eugene, OR 97401

drew@leimanlaw.com

Andrew S. Lewinter (OSB No. 080031)

ANDREW LEWINTER, ATTORNEY, P.C.

101 E. Broadway, Suite 220

Eugene, OR 97401

andrewlewinter@yahoo.com

IN THE UNITED STATES DISTRICT COURT

DISTRICT OF OREGON

EUGENE DIVISION

CORBYN VANCE and LOGAN VANCE,

individually and on behalf of others similarly 

situated,

Plaintiffs, 

 v.

CUARTO LLC, and Oregon limited liability 

company, SEPTIMO LLC, an Oregon limited 

liability company, LBB LLC, an Oregon 

limited liability company, SEXTO LLC, an 

Oregon limited liability company, PRIMERO 

LLC, an Oregon limited liability company, 

SEGUNDO LLC, an Oregon limited liability 

company, QUINTO LLC, an Oregon limited 

liability company, collectively all doing 

business as LITTLE BIG BURGER

and MICAH CAMDEN and KATHERINE 

POPPE, individually,

Defendants.

CASE NO.: 6:14-cv-00777

COLLECTIVE and CLASS 

ACTION ALLEGATION 

COMPLAINT; FLSA 

RETALIATION; OREGON WAGE 

AND HOUR LAWS

Fair Labor Standards Act 29 U.S.C. § 

201 et. seq.; Oregon Wage and Hour 

Laws (ORS 652 and 653)

DEMAND FOR JURY TRIAL

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Plaintiffs, CORBYN VANCE and LOGAN VANCE, on behalf of themselves and all 

other similarly situated employees of Defendants bring this Fair Labor Standards Act (“FLSA”)

collective action and Fed R. Civ. P. Rule 23 class action Complaint for violations of Oregon’s 

Wage and Hour laws against Defendants, SEPTIMO LLC, LBB LLC, SEXTO LLC, CUARTO 

LLC, PRIMERO LLC, SEGUNDO LLC, and QUINTO LLC, all collectively doing business as 

an enterprise engaged in commerce or the production or goods for commerce (hereinafter, 

collectively “Little Big Burger”), and individual defendants MICAH CAMDEN and 

KATHERINE POPPE. Plaintiff LOGAN VANCE also brings a separate claim for retaliation 

under the FLSA. Plaintiffs make their individual allegations based upon personal knowledge. 

Plaintiffs allege all other allegations upon information and belief.

INTRODUCTION

1. This is a collective and class action suit to recover unpaid overtime wages brought under 

the Fair Labor Standards Act (“FLSA”), 29 U.S.C. § 201 et seq. and Oregon Wage and Hour 

Laws, ORS Chapters 652 and 653 (“Oregon Wage and Hour Laws”).

2. Plaintiff Logan Vance also brings this action on his own behalf seeking reinstatement, 

backpay, front pay, compensatory damages, and punitive damages for his retaliatory termination, 

in violation of 29 U.S.C. § 215(a)(3), for complaining to Defendants about their unlawful 

overtime pay practices.

3. This action seeks equitable relief, compensatory and liquidated damages, attorney's fees, 

taxable costs of court, pre- and post-judgment interest and penalty wages for Defendants’ willful 

failure to pay wages, including overtime wages, and other relief, pursuant to 29 U.S.C. § 216(b) 

and Oregon Wage and Hour Laws for Plaintiffs and for all others similarly situated in the course 

of their employment with the Defendants.

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4. Plaintiffs and all others similarly situated demand a jury trial on all issues that may be 

tried to a jury.

5. This action is authorized and instituted pursuant to the FLSA, 29 U.S.C. § 201 et seq.

JURISDICTION AND VENUE

6. Jurisdiction is conferred on this Court by 29 U.S.C. § 216(b), as this action arises under 

the Fair Labor Standards Act, 29 U.S.C. § 201, et seq.; 28 U.S.C. § 1331; and 28 U.S.C. §1337, 

as it arises under acts of Congress regulating commerce. Jurisdiction of the state law claims is 

conferred on this Court by 28 U.S.C. § 1367 because the state law claims form a part of the same 

case or controversy as the federal claims under Article III of the United States Constitution.

7. Venue is proper in this District Court pursuant to 28 U.S.C. § 1391 because a substantial 

part of the events giving rise to this complaint occurred in the District of Oregon.

PARTIES

8. Plaintiff Logan Vance is a resident of Deschutes County, Oregon. Plaintiff Logan Vance 

was employed at Defendant Cuarto LLC’s Little Big Burger restaurant in Eugene, Oregon during 

the three-year period preceding the filing of this Complaint. Defendants jointly and severally 

owe plaintiff Logan Vance unpaid overtime, liquidated damages, and penalty wages under the 

FLSA and Oregon Wage and Hour laws.

9. Plaintiff Corbyn Vance is a resident of Deschutes County Oregon. Plaintiff Corbyn 

Vance was employed as a cook and cashier at Defendant Cuarto LLC’s Little Big Burger 

restaurant in Eugene, Oregon during the three-year period preceding the filing of this Complaint.

Defendants jointly and severally owe plaintiff Corbyn Vance unpaid overtime, liquidated 

damages, and penalty wages under the FLSA and Oregon Wage and Hour Laws.

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10. Plaintiffs bring their claims individually, and on behalf of all other similarly situated 

individuals who worked over 40 hours in a workweek for Defendants at any time within three 

years of the filing of this action, and were not paid time and one-half their regular rate of pay for 

all hours worked over 40 in a workweek. 

11. Defendants Primero LLC, Segundo LLC, LBB LLC, Cuarto LLC, Quinto LLC, Sexto 

LLC, Septimo LLC, are Oregon limited liability companies doing business in Portland and 

Eugene, Oregon. Defendants referenced in this paragraph (collectively “Little Big Burger”), are

an enterprise engaged in commerce or the production of goods for commerce. Furthermore, these

Defendants have acted, directly or indirectly, in the interest of an employer with respect to the 

Plaintiffs.

12. Defendants Primero LLC, Segundo LLC, LBB LLC, Cuarto LLC, Quinto LLC, Sexto 

LLC, Septimo LLC, each do business as separate “Little Big Burger” restaurants. They are all 

part of the common enterprise described herein as “Little Big Burger.”

13. Defendant Katherine Poppe, an individual, is a member of each limited liability company 

in Little Big Burger. Defendant Poppe is an individual engaged in commerce or the production 

of goods for commerce. Defendant Poppe has acted, directly or indirectly, in the interest of an 

employer with respect to the Plaintiffs.

14. Defendant Micah Camden, an individual, is a member of each limited liability company 

in Little Big Burger. Defendant Camden is an individual engaged in commerce or the production 

of goods for commerce. Defendant Camden has acted, directly or indirectly, in the interest of an 

employer with respect to the Plaintiffs.

15. Defendants are subject to the Fair Labor Standards Act (“FLSA”), 29 U.S.C. § 201 et seq. 

and Oregon Wage and Hour Laws, ORS Chapters 652 and 653. 

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16. Defendants employed Plaintiffs and the similarly situated current and former employees 

referenced herein to work in the Little Big Burger restaurants during the three-year period 

preceding the filing of this complaint. 

17. At all material times, Defendants have been employers within the meaning of 3(d) of the 

FLSA, 29 U.S.C. § 203(d). Defendants directly or indirectly acted in the interest of an employer 

toward the Plaintiffs at all material times, including, without limitation, directly or indirectly 

controlling all employment terms and conditions of the Plaintiffs.

18. At all material times, Little Big Burger has been an enterprise within the meaning of 29 

U.S.C. § 203(r). Each individual limited liability company in Little Big Burger, Katherine Poppe 

and Micah Camden acted as joint employers of all Plaintiffs. 

19. At all material times, Little Big Burger has been an enterprise in commerce or in the 

production of goods for commerce within the meaning of 29 U.S.C. § 203(s)(1) because it had 

employees engaged in commerce. Based upon information and belief, the annual gross sales 

volume of Little Big Burger was in excess of $500,000.00 per annum at all times material hereto. 

Alternatively, the Plaintiffs and the similarly situated employees worked in interstate commerce 

so as to fall within the protections of the FLSA.

20. All Defendants were joint employers of Plaintiffs because they (1) had the power to hire 

and fire the employees, (2) supervised and controlled employee work schedules or conditions of 

employment, (3) determined the rate and method of payment, and (4) maintained employment 

records. All Defendants are therefore jointly and severally liable to each Plaintiff for all claims 

alleged herein.

21. At all material times, each Plaintiff was an individual employee who was engaged in 

commerce or in the production of goods for commerce as required by 29 U.S.C. §§ 206-207.

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22. Defendants Katherine Poppe and Micah Camden directed the day-to-day operations of all 

the individual limited liability companies in Little Big Burger. Defendants Katherine Poppe and 

Micah Camden set company policies, had the authority to hire and fire employees, and had the 

authority to sign checks at each Little Big Burger restaurant.

23. Plaintiffs have retained the law firms of Leiman & Johnson, LLC and Andrew Lewinter, 

Attorney, P.C. to represent them individually, and have incurred attorneys’ fees and costs in 

bringing this action. Pursuant to 29 U.S.C. § 216(b) and ORS 652.200, Plaintiffs are entitled to 

recovery of reasonable attorneys’ fees and costs. 

FIRST CLAIM FOR RELIEF

(FLSA Overtime Violations - 29 U.S.C § 207; Collective Action)

24. Plaintiffs re-allege and incorporate herein by reference, all allegations contained in 

paragraphs 1 through 23 above.

25. At all material times, Plaintiffs performed duties for the benefit of, and on behalf of 

Defendants. Defendants were required to pay the Plaintiffs and the hereinafter defined FLSA 

Class members in accordance with the overtime provisions of the FLSA.

26. Plaintiffs brings this collective class action under § 216(b) of the FLSA and against 

Defendants for unpaid overtime compensation, and related penalties and damages on behalf 

themselves and the following persons:

All current and former employees of Defendants who were 

employed by Defendants at any of the Oregon Little Big Burger 

restaurants at any time within the three (3) years immediately 

preceding the filing of this Complaint; and who worked over forty

(40) hours in any workweek within that period; and who did not 

receive time and one-half the employees’ regular rate of pay for all 

hours worked over 40 in a workweek (the “FLSA Class”).

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27. Plaintiffs bring the FLSA claim for unpaid overtime and liquidated damages as an “optin” collective action pursuant to 29 USC § 216(b). The FLSA claims may be pursued by those 

FLSA Class members who opt-in to this case pursuant to 29 USC § 216(b).

28. Plaintiffs individually, and on behalf of FLSA Class members, seek relief on a collective 

basis alleging the FLSA was violated when they and others were not paid the correct amount of 

overtime due to them under the FLSA. Plaintiffs and FLSA Class members are similarly situated 

because the underpayment of overtime was caused by an unlawful pay practice that was common 

to Defendants’ employees. Defendants’ failure to pay time and one-half an employee’s regular 

rate of pay for all hours worked over 40 in a workweek to Plaintiffs and FLSA Class members 

resulted in the underpayment of overtime to the Plaintiffs and FLSA Class members. The 

number and identity of the other members of the putative FLSA Class may be readily determined 

from the records of Defendants, and potential opt-in FLSA Class members may be easily and 

quickly notified of the pendency of this action. 

29. Defendants have not paid Plaintiff and FLSA Class members time and one-half their 

regular rate of pay for all the hours they worked over 40 in a workweek in violation of 29 U.S.C. 

§ 207.

30. Plaintiffs and similarly situated FLSA Class members have not been paid all of the 

overtime wages owed to them by Defendants.

31. Plaintiffs and similarly situated FLSA Class members are owed overtime wages for hours 

worked over 40 in a workweek at a rate equal to one-half of their regular rate of pay.

32. Records of hours worked and wages paid are in possession and control of Defendants.

33. Defendants’ records show that Defendants failed to pay FLSA Class members overtime.

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34. At all material times hereto, Defendants failed to comply with Title 29 U.S.C. §§ 201-209 

in that the Plaintiffs performed services and labor for Defendants for which Defendants failed to 

pay the correct amount of overtime when due. Plaintiffs are entitled to liquidated damages, or, 

alternatively, an Oregon wage penalty for Defendants’ willful failure to pay overtime when due.

35. Plaintiffs bring this action on their own behalf, and on behalf all similarly situated 

individuals seeking unpaid overtime compensation, liquidated damages, pre-judgment interest, 

costs, penalty wages, and attorneys’ fees arising from the law violations set forth herein.

36. Defendants violated §207 of the FLSA when they willfully failed to pay overtime to the 

Plaintiffs and FLSA Class members at one and one-half times their regular rate of pay for all 

hours worked over 40 in a workweek during the applicable statutory period. 

37. Defendants’ failure to pay the Plaintiffs and FLSA Class members all overtime earned at 

one and one-half times their regular rate of pay resulted from the Defendants’ willful act of 

knowingly adopting a pay practice and policy to pay employees their regular rate of pay for all 

hours worked over 40 in a workweek and not pay such hours at one and one-half the employees’

regular rate of pay. Defendants’ policy thus violated the FLSA and resulted in the underpayment 

of overtime pay to Plaintiffs and each FLSA Class Member.

38. As a result of Defendants’ willful failure to pay the Plaintiffs and FLSA Class members 

all of their overtime earned, Plaintiffs and FLSA Class members have incurred actual damages 

and are entitled to liquidated damages or a penalty under ORS 653.055, whichever is greater, but 

not both.

39. By reason of said intentional, willful, and unlawful acts of Defendants, Plaintiffs and 

FLSA Class members have suffered damages and have also incurred costs and reasonable 

attorneys’ fees. 

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SECOND CLAIM FOR RELIEF

(Logan Vance FLSA Retaliation Claim)

40. Plaintiff Logan Vance re-alleges and incorporates herein by reference, all allegations 

contained in paragraphs 1 through 39 above.

41. On or about January 19, 2014, Plaintiff Logan Vance complained to Matthew Lynch, 

General Manager of Little Big Burger, that Defendants were violating Oregon and Federal law 

by not paying him overtime for the hours he had worked in excess of 40 per week. Manager

Lynch responded by stating that Little Big Burger “does not pay overtime.”

42. During late January and February 2014, Plaintiff Logan Vance approached several 

managers of Little Big Burger restaurants to inform them that it was illegal for Defendants to fail 

to pay them overtime. He asked if they wanted to take legal action together so that they would 

be paid the wages to which they were entitled.

43. On or about March 11, 2014, Manager Lynch discharged Plaintiff Logan Vance.

44. Plaintiff Logan Vance “filed a complaint,” within the meaning of 29 U.S.C. § 215(a)(3), 

when he told General Manager Lynch that Defendants were violating Oregon and Federal law by 

not paying him overtime for the hours he had worked in excess of 40 per week. Plaintiff Logan 

Vance again “filed a complaint,” within the meaning of 29 U.S.C. § 215(a)(3), when he told 

other Defendant managers that Defendants owed them overtime for the hours they had worked in 

excess of 40 per week, and suggested they take legal action against Defendants so that they 

would be paid in accordance with Oregon and Federal law.

45. Defendants violated 29 U.S.C. § 215(a)(3) by discharging Plaintiff Logan Vance on or 

about March 11, 2014 because he filed complaints alleging that Defendants had failed to pay him 

overtime as required by the FLSA.

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46. Plaintiff Logan Vance is entitled to reinstatement or front pay, and backpay for 

Defendants’ wrongful termination of him in violation of 29 U.S.C. § 215, as alleged above, 

pursuant to 29 U.S.C. § 216(b). 

47. Moreover, as a result of Defendants’ actions described herein, Plaintiff Logan Vance has 

suffered emotional distress, humiliation, and loss of future earning capacity. These damages are 

continuing. Plaintiff Logan Vance is entitled to recover payment for these compensatory 

damages under 29 U.S.C. § 216(b) in an amount to be determined by the jury.

48. Defendants acted with malice or reckless indifference to Plaintiff’s federally protected 

rights when they fired him on or about March 11, 2014 because he had filed complaints alleging

that the Defendants had not paid him in accordance with the FLSA. Plaintiff Logan Vance is 

therefore entitled to recover punitive damages under 29 U.S.C. § 216(b) for that violation in an 

amount to be determined by the jury. 

49. Plaintiff Logan Vance is entitled to the recovery of reasonable attorney fees and costs 

incurred in prosecuting this action pursuant to 29 U.S.C. § 216(b). Plaintiff Logan Vance is also 

entitled to his prejudgment and post-judgment interest on all awards.

THIRD CLAIM FOR RELIEF/CLASS ACTION ALLEGATIONS

(Violation of Oregon Wage and Hour Laws)

50. Plaintiffs, on behalf of themselves and others similarly situated, re-allege and incorporate

herein by reference, all allegations contained in paragraphs 1 through 39 above.

51. As alleged herein, Defendants willfully failed to pay Plaintiffs and similarly situated 

current and former employees overtime, thereby violating ORS 653.261.

52. Plaintiffs and similarly situated current and former employees are owed overtime wages 

at a rate equal to one-half of their regular rate of pay for hours worked over 40 in a workweek.

53. Records of hours worked and wages paid are in possession and control of Defendants.

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54. Defendants’ records show that Defendants failed to pay overtime to Plaintiffs and 

similarly situated current and former employees.

55. Plaintiffs bring a class action pursuant to Fed. R. Civ. P. 23(b)(3) on behalf of themselves 

and the following class of persons:

All current and former employees of Defendants who were 

employed at any of the Oregon Little Big Burger restaurants at any 

time within the two (2) years immediately preceding the filing of 

this Complaint; and who worked over forty (40) hours in any 

workweek within that period; and who did not receive time and 

one-half the employees’ regular rate of pay for all hours worked 

over 40 in a workweek (the “Oregon Wage Class”).

56. As a result of Defendants’ willful failure to pay Plaintiffs and the Oregon Wage Class all 

of their overtime earned, as alleged above, Defendants failed to pay all wages when due, and are 

liable to Plaintiffs and the Oregon Wage Class for actual overtime wages owed, plus a penalty to 

be computed in accordance with ORS 652.150, or liquidated damages under the FLSA, 

whichever is greater, but not both.

57. By reason of said intentional, willful, and unlawful acts of Defendants, Plaintiffs and the 

similarly situated current and former employees have suffered damages and have also incurred 

costs and reasonable attorneys’ fees.

58. All members of the Oregon Wage Class who do not opt out may pursue the Oregon state 

law claims if those claims are certified for class-wide treatment.

59. Plaintiffs’ state law claims satisfy the Fed. R. Civ. P. 23(a) class action prerequisites of 

numerosity of members, commonality of questions of law and fact, typicality of class claims, and 

fair and adequate representation of class member interests.

60. Numerosity (Fed. R. Civ. P 23(a)(1)): The Oregon Wage Class satisfies the numerosity 

standards. The Oregon Wage Class is believed to be approximately 80 people. As a result, 

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joinder of all Class members in a single action is impracticable. The precise number of Oregon 

Wage Class members and their identities and contact information are unknown to Plaintiffs but 

can be easily ascertained from Defendants’ payroll records. Oregon Wage Class members may 

be notified of the pendency of the action by first-class mail. 

61. Commonality (Fed. R. Civ. P 23(a)(2)): Questions of law and fact common to the Oregon 

Wage Class predominate over any questions affecting only individual members. All Oregon 

Wage Class members were subject to the same payroll practices that resulted in the 

underpayment of overtime. All Oregon Wage Class members received paychecks for more than 

40 hours per week, but did not receive overtime compensation for those hours over 40 in a 

workweek. Thus, all Oregon Wage Class Members been paid incorrectly in the same manner, 

and all Oregon Wage Class members are owed additional wages, overtime, and other 

compensation. 

62. Common questions of fact include but are not limited to: (a) whether Defendants policy 

and practice of failing to pay overtime for all hours worked in excess of 40 in a workweek 

resulted in underpayment of wages and compensation; and (b) whether Defendants acted 

willfully in failing to pay the correct amount of wage. 

63. Common questions of law exist regarding: (a) whether Defendants paid overtime wages 

in accordance with Oregon Wage and Hour Law, ORS Chapters 652 and 653; (b) whether such 

actions were willful and (c) whether former employees are owed penalties under ORS 652 and 

ORS 653.

64. The common issues predominate over any questions affecting only individual persons, 

and a class action is superior with respect to considerations of consistency, economy, efficiency, 

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fairness, and equity to other available methods for the fair and efficient adjudication of the 

Oregon state law claims. 

65. Typicality (Fed. R. Civ. P. 23(a)(3)): Plaintiffs’ claims are typical of Oregon Wage Class 

members’ claims because:

a. Defendants employed Plaintiffs in the same or similar positions as the Oregon 

Wage Class members;

b. Plaintiffs and the Oregon Wage Class members were subject to the same payroll 

policies and were affected in the same manner by those policies;

c. All of the named Plaintiffs together with all of the Oregon Wage Class members 

received payment at their regular rate of pay for hours worked in excess of 40 per 

week;

d. All of the named Plaintiffs together with all of the Oregon Wage Class members 

are owed one-half their regular rate of pay for all hours they worked in excess of 

40 per week;

e. Plaintiffs’ claims are based on the same legal and remedial theories as those of the 

Oregon Wage Class and have similar factual circumstances; and

f. Plaintiffs have suffered the same or similar injury as did members of the Oregon 

Wage Class.

66. Adequacy of Plaintiffs’ Representation (Fed. R. Civ. P. 23(a)(4)): The named Plaintiffs 

will fairly and adequately represent and protect the interests of the Oregon Wage Class because:

a. There is no conflict between their claims and the Oregon Wage Class’ claims.

b. Plaintiffs have retained counsel who are skilled and experienced, who specialize 

in wage and hour cases, and who will vigorously prosecute the litigation;

c. Plaintiffs’ claims are typical of the claims of the Oregon Wage Class members; 

and

d. Plaintiffs and their counsel will fairly and adequately protect the interests of the 

Oregon Wage Class members.

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67. A class action is the superior procedural vehicle for the fair and efficient adjudication of 

the claims asserted herein given that: 

a. There is minimal interest of members of the Oregon Wage Class in individually 

controlling their prosecution of claims under Oregon Wage and Hour Laws;

b. It is desirable to concentrate the litigation of these claims in this forum; and 

c. There are no unusual difficulties likely to be encountered in the management of 

this case as a class action.

68. The presentation of separate actions by individual Oregon Wage Class members creates 

the risk of inconsistent and varying adjudications, and may establish incompatible standards of 

conduct for Defendants and/or substantially impair or impede the ability of Oregon Wage Class 

members to protect their interests.

69. In the absence of a class action, Defendants would be unjustly enriched because they 

would be able to retain the benefits and fruits of wrongful violations of Oregon Wage and Hour 

Laws.

PRAYER FOR RELIEF

WHEREFORE, Plaintiffs, on behalf of themselves and the Class members respectfully 

ask the Court to grant the following relief:

1. On the First Claim for Relief, award Plaintiffs and Class members their actual 

damages for unpaid overtime in an amount to be determined at trial, plus an equal 

amount as liquidated damages for failure to pay overtime pursuant to 29 U.S.C. 

§207; or in the alternative an Oregon Wage penalty computed pursuant to ORS 

652.150, whichever is greater.

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2. On the Second Claim for Relief, award Plaintiff Logan Vance reinstatement or 

front pay, backpay, compensatory and punitive damages in an amount to be 

determined by the jury.

3. On the Third Claim for Relief, actual damages and penalty wages calculated 

according to ORS 652.150, in an amount to be determined at trial, plus prejudgment interest in an amount to be determined at trial.

4. Award Plaintiffs and other similarly situated individuals their reasonable attorney 

fees and costs;

5. Award Plaintiffs and other similarly situated individuals their pre-judgment and 

post-judgment interest; and 

6. Award Plaintiffs and other similarly situated individuals any and all such other 

legal and equitable relief as this Court deems just and proper.

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DATED May 12, 2014.

Respectfully submitted,

__/s Alan J. Leiman_________

Alan J. Leiman

E-mail: alan@leimanlaw.com

Oregon State Bar No.: 98074

44 W. Broadway, Suite 326

Eugene, OR 97401

Telephone: (541) 345-2376

Facsimile: (541) 345-2377

Of Attorneys for Plaintiffs

__/s Drew G. Johnson_______

Drew G. Johnson

E-mail: drew@leimanlaw.com

Oregon State Bar No.: 114289

44 W. Broadway, Suite 326

Eugene, OR 97401

Telephone: (541) 345-2376

Facsimile: (541) 345-2377

Of Attorneys for Plaintiffs

__/s Andrew S. Lewinter_____

Andrew S. Lewinter

E-mail: andrewlewinter@yahoo.com

Oregon State Bar No: 080031

ANDREW LEWINTER ATTORNEY, P.C.

101 E. Broadway, Suite 220

Eugene, OR 97401

Telephone: (541) 686-4900

Fax: (541) 686-1300

Of Attorneys for Plaintiffs

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