Page 1 – JOINT STATUS REPORT AND STIPULATED MOTION TO POSTPONE 

DEADLINES

PORTLAND CITY ATTORNEY’S OFFICE 

1221 SW 4TH AVENUE, RM 430 

PORTLAND, OREGON 97204 

(503) 823-4047

TRACY REEVE, Oregon State Bar ID Number 891123 

City Attorney 

Email: Tracy.Reeve@portlandoregon.gov

J. SCOTT MOEDE, Oregon State Bar ID Number 934816 

Chief Deputy City Attorney 

Email: Scott.Moede@portlandoregon.gov

Kenneth A. McGair, Oregon State Bar ID Number 990148 

Senior Deputy City Attorney 

Email: Ken.McGair@portlandoregon.gov

Office of City Attorney 

1221 SW Fourth Avenue, Room 430 

Portland, OR 97204 

Tele: 503-823-4047 

Fax: 503-823-3089 

Of Attorneys for Plaintiff City of Portland 

UNITED STATES DISTRICT COURT 

DISTRICT OF OREGON 

PORTLAND DIVISION 

CITY OF PORTLAND, a municipal 

corporation of the State of Oregon, 

 PLAINTIFF, 

 v. 

UBER TECHNOLOGIES, INC., a Delaware 

corporation, and RASIER, LLC, its wholly 

owned subsidiary, 

 DEFENDANTS.

3:14-cv-01958-SI

JOINT STATUS REPORT AND 

STIPULATED MOTION TO POSTPONE 

DEADLINES 

Plaintiff City of Portland and defendants Uber Technologies, Inc. and Rasier, LLC 

(“Uber”) submit this joint Status Report and Stipulated Motion to Postpone Deadlines. 

JOINT STATUS REPORT 

1. By Order dated entered on December 18, 2014, the parties were directed to file a 

Joint Status Report by March 18, 2015. 

Case 3:14-cv-01958-SI Document 31 Filed 03/17/15 Page 1 of 3
Page 2 – JOINT STATUS REPORT AND STIPULATED MOTION TO POSTPONE 

DEADLINES

PORTLAND CITY ATTORNEY’S OFFICE 

1221 SW 4TH AVENUE, RM 430 

PORTLAND, OREGON 97204 

(503) 823-4047

2. On December 29, 2014, the parties filed a stipulated request to postpone deadlines 

and represented to the Court that the parties anticipated that it may be possible to reach a 

resolution of this case through the City’s legislative and regulatory processes. 

3. The parties represented that Uber had ceased operating the Uber application in the 

City of Portland. 

4. The parties also requested that deadlines for actions, including responses to the 

Complaint and responses to requests for discovery, be postponed until fourteen (14) days after 

the submission of the Joint Status Report due March 18, 2015. 

5. Based upon that stipulation, on December 29, 2014, this Court granted the 

stipulated request to postpone deadlines and ordered that the deadlines for actions, including 

responses to the Complaint and to requests for discovery, were postponed until fourteen (14) 

days after the submission of the Joint Status Report due March 18, 2015. 

6. Since that time, the City of Portland has assembled the Private For-Hire 

Transportation Innovation Task Force that has been meeting regularly for the purpose of 

analyzing and evaluating changes to the private for-hire portions of the City Code with an 

emphasis on addressing issues related to transportation network companies like defendants Uber 

Technologies, Inc. and Raiser, LLC. 

7. The Task Force has met six times, including two community listening forums. 

8. In addition, on March 12, 2015, the City Council passed an emergency ordinance 

adopting definitions for transportation network companies, vehicles and drivers and provisions 

requiring transportation network companies be validly permitted prior to operating in the City of 

Portland. 

9. It is anticipated that interim rules will be adopted on or about April 9, 2015, and 

will remain in effect for 120 days. This additional time will allow the Private For-Hire 

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Case 3:14-cv-01958-SI Document 31 Filed 03/17/15 Page 2 of 3
Page 3 – JOINT STATUS REPORT AND STIPULATED MOTION TO POSTPONE 

DEADLINES

PORTLAND CITY ATTORNEY’S OFFICE 

1221 SW 4TH AVENUE, RM 430 

PORTLAND, OREGON 97204 

(503) 823-4047

Transportation Innovation Task Force to complete its work and recommend permanent Code 

changes to the Portland City Council. 

10. It is anticipated that during this 120-day period following adoption of the interim 

rules, the permanent Code will be adopted by City Council. 

STIPULATED MOTION TO POSTPONE DEADLINES 

AND SET A FURTHER JOINT STATUS REPORT 

1. As outlined above, the parties anticipate that it may be possible to reach a 

permanent resolution of the issues in this case through the City’s legislative and regulatory 

processes. 

2. In order to allow the parties to work toward ultimate resolution of the issues 

presented, the parties request that the Court set a deadline for an additional Joint Status Report 

30 days following April 9, 2015, specifically on May 8, 2015. 

3. The parties request that the deadlines for actions, responses, including responses 

to the Complaint and to requests for discovery, be postponed until 14 days after submission of 

the Joint Status Report due May 8, 2015. 

s/ Tracy Reeve s/ Harry Korrell 

Tracy Reeve, OSB #891123 Harry Korrell, WSBA #23173 

City Attorney Davis Wright Tremaine LLP 

City Attorney’s Office 1201 Third Avenue, Suite 2200 

1221 SW Fourth Avenue, Room 430 Seattle, WA 98101-3045 

Portland, OR 97204 Tele: 206-757-8080 

Tele: 503-823-4047 

Of Attorneys for Plaintiff Gregory A. Chaimov, OSB #822180 Davis Wright Tremaine LLP 

Dated: March 17, 2015 1300 SW 5th Avenue 

Portland, OR 97201-5630 

Telephone: 503-241-2300 

Of Attorneys for Defendants 

Dated: March 17, 2015 

Case 3:14-cv-01958-SI Document 31 Filed 03/17/15 Page 3 of 3