Service of Process 

Transmittal 

04/01/2015 

CT Log Number 526865834 

TO: Kevin King 

Turner Construction Company 

3 Paragon Dr Ste 1 

Montvale, NJ 07645-1783 

RE: Process Served in Oregon 

FOR: Turner Construction Company (Domestic State: NY) 

ENCLOSED ARE COPIES OF LEGAL PROCESS RECEIVED BY THE STATUTORY AGENT OF THE ABOVE COMPANY AS FOLLOWS: 

TITLE OF ACTION: Alliance Industrial Group, Inc., etc., Pltf. vs. Turner Construction Company, etc. and 

Mutual Insurance Company, etc., Dfts. 

DOCUMENT(S) SERVED: Summons, Complaint, Exhibit(s) 

COURT/AGENCY: Washington County Circuit Court, OR 

Case # C151370CV 

NATURE OF ACTION: Foreclosure Litigation - Lien - 2501 NW 229th Avenue, Hillsboro, Oregon 97124-5503 

ON WHOM PROCESS WAS SERVED: C T Corporation System, Salem, OR 

DATE AND HOUR OF SERVICE: By Process Server on 04/01/2015 at 12:15 

JURISDICTION SERVED : Oregon 

APPEARANCE OR ANSWER DUE: Within 30 days from the date of service of this summons upon you 

ATTORNEY(S) / SENDER(S): Jan D. Sokol 

Stewart Sokol ft Larkin LLC 

2300 SW First Avenue 

Suite 200 

Portland, OR 97201-5047 

503-221-0699 

ACTION ITEMS: CT has retained the current log, Retain Date: 04/02/2015, Expected Purge Date: 

04/07/2015 

Image SOP 

Email Notification, Kevin King kking@tcco.com 

Email Notification, Tom Godsey twgodsey@tcco.com 

Email Notification, Robbie Vargo rvargo@tcco.com 

Email Notification, Jennifer Tancredi jtancredi@tcco.com 

SIGNED: C T Corporation System 

ADDRESS: 388 State St., Suite 420 

Salem, OR 97301 

TELEPHONE: 503-566-6883 

Page 1 of 1 / AV 

Information displayed on this transmittal is for CT Corporation's 

record keeping purposes only and is provided to the recipient for 

quick reference. This information does not constitute a legal 

opinion as to the nature of action, the amount of damages, the 

answer date, or any information contained in the documents 

themselves. Recipient is responsible for interpreting said 

documents and for taking appropriate action. Signatures on 

certified mail receipts confirm receipt of package only, not 

contents. 

Case 3:15-cv-00736-HZ Document 1-1 Filed 04/30/15 Page 1 of 22
Jan D. So SB ff7808 jdsokolg l.com 

STEWART SOKOL & LARKIN LLC 

2300 SW First Avenue, Suite 200 

Portland, Oregon 97201-5047 

Phone: (503) 221-0699 

Trial Attorney: Jan D. Sokol, OSB #780873 

JAN 0. S 73 

OF ATTO INTIFF 

IN THE CIRCUIT COURT OF THE STATE OF OREGON 

FOR THE COUNTY OF WASHINGTON 

ALLIANCE INDUSTRIAL GROUP, INC., an 

Oregon corporation, 

Plaintiff, 

V. . 

TURNER CONSTRUCTION COMPANY, a New 

York corporation; LIBERTY MUTUTAL 

INSURANCE COMPANY, a Massachusetts 

corporation, 

Defendants. 

TO: Turner Construction Company 

do CT Corporation System 

388 State St., Suite 420 

Salem, OR 97301 

SUMMONS 

) 

Case No. C151370CV 

You are hereby required to appear and defend the Complaint filed against you in the above-entitled action within 

thirty (30) days from the date of service of this summons upon you, and in case of your failure to do so, for want 

thereof, Plaintiff will apply to the court for relief demanded in the Complaint. 

NOTICE TO THE DEFENDANT: READ THESE 

PAPERS CAREFULLYI 

You must "appear in this case or the other side will 

win automatically. To "appear you must file with the 

court a legal paper called a 'motion" or 'answer." The 

"motion" or "answer must be given to the court clerk or 

administrator within 30 days along with the required filing 

fee. It must be In proper form and have proof of service 

on the plaintiffs attorney or, if the plaintiff does not have 

an attorney, proof of service upon the plaintiff. 

If you have any questions, you should see an attorney 

immediately. If you need help in finding an attorney, you 

may contact the Oregon State Bar's Lawyer Referral 

Service online at www.osbar.orq or by calling (503) 684-

3763 in the Portland area or toll-free at (800) 452-7636. 

STATE OF OREGON ) 

) as. 

County of Multnomah ) 

I, the undersigned attorney of record for Plaintiff, certify that the foregoing Isan a ct and complete copy 

of the original summons In the above-entitled action. 

tiii 

JAN D 

OF A 

73 

INTIFF 

TO THE OFFICER OR OTHER PERSON SERVING THIS SUMMONS: You are hereby directed to serve a true 

copy of this Summons, together with a true copy of the Complaint mentioned therein, upop the individual(s) or other 

legal entity(ies) to whom or which this Summons is directed, and t mak:,our/ibo1 c service upon a separate 

document which you shall attach hereto. 

8027.012-01168833; 1 

Case 3:15-cv-00736-HZ Document 1-1 Filed 04/30/15 Page 2 of 22
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IN THE CIRCUIT COURT FOR THE STATE OF OREGON 

IN AND FOR THE COUNTY OF WASHINGTON 

Case 

COMPLAINT 

(Lien Foreclosure; Breach of 

Contract; Quantum Meruit) 

NOT SUBJECT TO MANDATORY 

ARBITRATION 

Amount Claimed: $1,217,081.12 

Fee Authority: ORS 21.160(1)(d) 

For its Complaint, Alliance Industrial Group ("AIG") alleges as follows: 

1. 

AIG is an Oregon corporation and is properly licensed by the Oregon 

Construction Contractors Board. 

2. 

Turner Construction Company ("Turner") is a New York corporation doing 

business in Washington County, Oregon. Liberty Mutual Insurance Company 

("Liberty") is a Massachusetts corporation and authorized to issue surety bonds in 

the state of Oregon. 

ALLIANCE INDUSTRIAL GROUP, INC., 

an Oregon corporation, 

Plaintiff, • 

V. 

TURNER CONSTRUCTION COMPANY, 

a New York corporation; LIBERTY 

MUTUTAL INSURANCE COMPANY, a 

Massachusetts corporation, 

Defendants. 

9570C1 

PAGE 1 - COMPLAINT STEWART SOKOL 82 LARKIN LLC 

2300 SW First Avenue, Suite 200 

Portland, OR 97201-5047 

(503) 221-0699 

FAX (503) 223-5706 

8027.012-01163657; 1 

Case 3:15-cv-00736-HZ Document 1-1 Filed 04/30/15 Page 3 of 22
1 3. 

2 Turner entered into a contract with Intel Corporation ("Intel") (the "Contract") 

3 to provide certain materials and services for a project in Washington County 

4 commonly known as Intel-Ronler D1X MSB Building (the "Project") located at 2501 

5 NW 229th Avenue, Hillsboro, Oregon 97124-5503 (the "Property"). 

6 4. 

7 On or about December 28, 2011, Turner entered into a Master Agreement 

8 with AIG. Thereafter, Turner issued a subcontract work order dated June 5, 2013 to 

9 provide labor, equipment and materials required to perform metal fabrication and 

10 metal stairs for the Project (collectively, the "Subcontract") (the "Improvement"). The 

11 whole of the Property is necessary for the convenient use and enjoyment of the 

12 Improvement. 

13 5. 

14 At all material times, the owner or reputed owner of the property was Intel. 

15 6. 

16 Throughout the Project, AIG performed its obligations in a good and 

17 workmanlike manner and in accordance with the plans, specifications, drawings and 

18 other contract documents prepared by Turner and furnished to AIG by Turher. AIG 

19 performed its obligations in. compliance with the Subcontract. In connection with the 

20 performance of the work, AIG was required to modify the stair system, adding 

21 structural steel bracing which was specifically excluded from the Subcontract. AIG 

22 was directed to perform the work by Turner. AIG completed its work and asserted a 

23 claim for the additional costs incurred. 

24 7. 

25 AIG and Turner pursued the dispute resolution processes provided in the 

26 Subcontract, but despite demand, Intel refuses to include AIG's claims in its dispute 

PAGE 2- COMPLAINT STEWART SOKOL 81 LARKIN LLC 

2300 SW First Avenue, Suite 200 

Portland, OR 97201-5047 

(503) 221-0699 

FAX (503) 223-5706 

8027.012-01163657; 1 

Case 3:15-cv-00736-HZ Document 1-1 Filed 04/30/15 Page 4 of 22
1 resolution proceedings with Turner. 

2 FIRST CLAIM FOR RELIEF 

3 (Lien Foreclosure Against Turner and Liberty) 

4 8. 

5 AIG realleges the allegations in paragraphs 1-7, above. 

6 9. 

7 Beginning on January 9, 2014, and ceasing on or about January 27, 2015, 

8 AIG provided materials, labor, services and/ or equipment in the furtherance of the 

9 construction, all of which were incorporated for the benefit of the Improvement and 

10 the Property. 

11 10. 

12 The reasonable value of the materials, labor, services and/or equipment AIG 

13 furnished, after deducting all just credits and offset, is $1,217,081.12 plus accrued 

14 and accruing interest. Despite AIG's demand, Turner failed and refused to pay all 

15 amounts due. 

16 11. 

17 AIG satisfied all obligations on its part to be performed and all conditions 

18 precedent to making this claim. 

19 12. 

20 On or about February 4, 2015, within 75 days after the last day AIG provided 

21 materials, labor, services, and/or equipment and incorporated such into the 

22 Improvement, AIG recorded its claim of construction lien in Washington County as 

23 Document No. 2015-007409 (the "Lien"). The Lien, verified by Affidavit, set forth 

24 AIG's true statement of demand after deducting all just offsets and credits, the name 

25 of the owners or reputed owners of the Property and Improvement, the name of the 

26 person to whom AIG furnished materials, labor, services and/or equipment, and a 

PAGE 3- COMPLAINT 

8027.012-01163657; 1 

STEWART SOKOL & LARKIN LLC 

2300 SW First Avenue, Suite 200 

Portland, OR 97201-5047 

(503) 221-0699 

FAX (503) 223-5706 

Case 3:15-cv-00736-HZ Document 1-1 Filed 04/30/15 Page 5 of 22
1 legal description of the property to be charged with the Lien. A true and accurate 

2 copy of the Lien is attached and incorporated hereto as Exhibit 1. 

3 13. 

4 On or about February 5, 2015, within the time prescribed by statute, AIG 

5 mailed by certified mail to the reputed owner of the Property, a notice stating that 

6 AIG had filed the Lien against the Property for materials, labor, services and/or 

7 equipment furnished for the Improvement. By the same certified letter, AIG gave 

8 notice to the reputed owner that unless the Lien was paid within ten (10) days of the 

9 notice, AIG would thereafter commence to foreclose the lien. 

10 14. 

11 In response to AIG's lien, Turner filed and served a bond posted by Liberty 

12 under ORS 87.076 and attached as Exhibit 2 (the "Bond"), with the effect that the 

13 Property is free of AIG's lien and AIG's lien now attaches to the Bond. The Bond 

14 was recorded on March 19, 2015, as document number 2015-019080 of the 

15 Washington County Records. 

16 15. 

17 AIG is entitled to the sum of $76 for filing and recording the lien, $1,845 for 

18 required title reports, and $793 to file the Complaint to foreclose the lien, and the 

19 sum of $1,217,081.12, together with accruing interest. 

20 16. 

21 Under ORS 87.060(5), AIG is also entitled to recover its reasonable attorney 

22 fees incurred in this action. 

23 SECOND CLAIM FOR RELIEF 

24 (Breach of Contract against Turner only) 

25 17. 

26 AIG realleges the allegations in paragraphs 1-16, above. 

PAGE 4- COMPLAINT STEWART SOKOL & LARKIN LLC 

2300 SW First Avenue, Suite 200 

Portland, OR 97201-5047 

(503) 221-0699 

FAX (503) 223-5706 

8027.012-01163657; 1 

Case 3:15-cv-00736-HZ Document 1-1 Filed 04/30/15 Page 6 of 22
1 18. 

2 AIG has performed all conditions or obligations on its part to be performed 

3 under the Subcontract and the Contract, or such obligations have been waived by 

4 Turner. 

5 19. 

6 Turner materially breached its obligations under the Subcontract by failing 

7 and refusing to compensate AIG for work performed. As a result of Turner's material 

8 breaches of contract, AIG has been damaged in an amount to be proven at trial, but 

9 which is not less than $1,217,081.12, together with interest at 9% per annum until 

10 paid. 

11 THIRD CLAIM FOR RELIEF 

12 (Quantum Meruit/Reasonable Value Against Turner only) 

13 20. 

14 AIG realleges the allegations in paragraphs 1-19, above. 

15 21. 

16 AIG provided labor, materials, services and equipment for the Project for the 

17 benefit of and at the request of Turner, for which AIG has not been compensated. 

18 As a matter of fairness and equity, and in order to avoid unjust enrichment, AIG 

19 should be paid the fair and reasonable value of labor, services, material and 

20 equipment it furnished to Turner in connection with the Project, in amount not less 

21 than $1,217,081.12. 

22 WHEREFORE, AIG prays for judgment as follows: 

23 1. On its First Claim for Relief against all defendants (Construction Lien 

24 Foreclosure), for a judgment against Turner and Liberty, in the amount of 

25 $1,217,081.12, together with pre and post judgment interest accruing at the rate of 

26 9% per annum until paid, $793 for the filing fee for its Complaint, $76 for the filing 

PAGE 5- COMPLAINT STEWART SOKOL & LARKIN LLC 

2300 SW First Avenue, Suite 200 

Portland, OR 97201-5047 

(503) 221-0699 

FAX (503) 223-5706 

8027.012-01163657; 1 

Case 3:15-cv-00736-HZ Document 1-1 Filed 04/30/15 Page 7 of 22
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and recording of the lien, $1,845 for the required title reports, and for AIG's 

reasonable attorney fees; 

2. On its Second and Third Claims for Relief, for judgment against Turner 

in an amount to be proven at trial, but which is not less than $1,217,081.12, together 

with interest at the rate of 9% per annum; and 

3. On all claims for relief, for its costs and disbursements incurred, and 

for such other and further relief as the Court deems just and equitable. 

DATED this 27th day of March, 2015. 

STEWART SOKOL & LARKIN LLC 

By: 

Jan #780873 

jdsok awssl.com 

Attorneys for Plaintiff Alliance Industrial 

Group, Inc. 

Trial Attorney: Jan D. Sokol 

PAGE 6- COMPLAINT STEWART SOKOIL LARKIN LLC 

2300 SW First Avenue, Suite 200 

Portland, OR 97201-5047 

(503) 221-0699 

FAX (503) 223-5706 

8027.012-01163657; 1 

Case 3:15-cv-00736-HZ Document 1-1 Filed 04/30/15 Page 8 of 22
2015-007409 

CLAIM OF CONSTRUCTION LIEN 

FOR AN IMPROVEMENT 

Alliance Industrial Group, Inc. 

5823 S. 6th Way 

Ridgefield, WA 98642 

Lien Claimant 

Turner Construction Company 

1200 NW Naito Parkway, Suite 300 

Portland, OR 97209 

Lien Debtor 

Washington county, Oregon 

02/04/2015 10:23:21 AM 

DLC Crit.1 Stri.21 RECORDS 

$40.00 $5.00 $11.00 $2000 - Total 475.00 

1 111111111111111111111110 11111111 

02010460201500074090080087 

I, Mohan, Hobe rileht, Director of Assessment and 

Taxation and fou-Offittio County Clerk for Washington 

County, Oregon, do hereby certify that the within 

Instrument of writing was received • die rdad In the 

book or records of said cow 

Richard Hob.rnlcflt, Director of Mainaamant and 

Taxation, Exdfflolo County Clark 

I'll' 

After recording return to: 

Jan D Sokol 

STEWART SOKOL & LARKIN LLC 

2300 SW First Avenue, Suite 200 

Portland, OR 97201 

(503) 221-0699 

lien Claimant: 

lien Debtor: 

Reputed Owner: 

Lien Amount: 

Alliance Industrial Group, Inc. 

Turner Construction Company 

Intel Corporation 

$1,217,081.12, plus accrued and accruing interest, attorney fees, and 

title insurance. 

The undersigned, Alliance Industrial Group, Inc. ("Claimant') claims a lien created under ORS 

87.010 on the real property and improvements described in this document and further claims perfection 

of such lien under ORS 87.035 by the filing of this Claim of Lien for work in connection with the 

construction contract dated June 5, 2013 (the "Subcontracafor the construction of an improvement 

commonly known as the Intel-Ronler D1X MSB Building (the "Project"), including the real property that 

may be required for the convenient use and occupation thereof (collectively the "Property"). 

1. The address or description of the Property is: 2501 NW 2291h Avenue, Hillsboro, 

Washington County, Oregon 97124-5503, and more particularly described as: 

See Exhibit A. 

2. At all times material herein mentioned, Intel Corporation, the Owner and Reputed Owner 

of the Property, had knowledge of the work Lien Claimant performed in connection with the Project on 

the Property. 

3. The name of the party by whom Lien Claimant was employed or to whom Lien Claimant 

furnished labor, materials or services or from whom contributions are owed is Turner Construction 

Company, 1200 NW Naito Parkway, Suite 300, Portland, OR 97209. 

1 

Title Data, Inc. CH P0R10512 WN 2015007409.001 

Exhibit 1 

Page 1 of 8 

Case 3:15-cv-00736-HZ Document 1-1 Filed 04/30/15 Page 9 of 22
4. Lien Claimant was authorized to commence construction work on the Project and furnished 

labor, materials, services and/or equipment for the construction services contemplated in the 

Subcontract commencing on January 9, 2014. Within the meaning of ORS 87.035 and ORS 87.045, lien 

claimant substantially completed performance of the work on the Property giving rise to the amounts 

claimed in this lien on January 27, 2015. 

5. The total contract amount and reasonable value of the labor, materials, services and/or 

equipment are, as follows: 

Original contract $1,610,461.00 

Change Orders 120,912.31 

Extra Work Orders 1.161.510.02See attached Exhibit B 

Total contract $2,892,883.30 

Payments <$1,675,802.21> (This includes SO% of retention) 

and the unpaid amount after deducting all just credits and offsets, is: $1,217,081.12. 

6. Lien Claimant claims a Lien on the Property described above, extending to the 

improvements and to the site, and together with the land that may be required for the convenient use 

and occupancy of the improvement as determined by the court at the time of foreclosure of this Claim 

of Lien in the amount of: $1,217,081.12, plus accrued and accruing interest, attorney fees, and title 

insurance. 

NOTE: Lien Claimant files this lien for amounts known and calculated to date. The actual 

amounts due under the Subcontract at issue likely exceed the amounts set forth in this Claim of Lien. 

Lien Claimant reserves its right to claim additional sums against the Lien Debtor and/or Owner or 

Reputed Owner of the Property, as such sums become identified, under appropriate legal theories other 

than under foreclosure of this lien against the land and improvement. 

DATED: February 4, 2015. 

ALLiA E INDUSTRIAL GROUP, INC. 

Isamu. 

Jim Buchan, President 

STATE OF OREGON ) 

) ss 

County of Multnomah ) 

I, Jim Buchan, being first duly sworn, depose and say: I am the President for lien claimant, 

Alliance Industrial Group, Inc., named in the foregoing instrument. I have knowledge of the facts stated 

herein, and all statements made in this instrument are true and correct as I verily believe and made 

subject to the criminal penalties for false swearing 'tied unde S 162.075. 

Jim Buchan 

2 

Tltle Data, Inc. CH P0R10512 MN 2015007409.002 

Exhibit 1 

Page 2 of 8 

Case 3:15-cv-00736-HZ Document 1-1 Filed 04/30/15 Page 10 of 22
• 13 .fAi L 

DAYNA L SIMMONS 

NOTARY PUBUC-OREGON 

COMMISSION NO. 470130 

MY COMMISSION EXPIRES SEPTEMBER 05, 2016 

STATE OF OREGON ) 

) ss 

County of Multnomah ) 

I, Jim Buchan, being first duly sworn, depose and say: I am the President of lien claimant, 

Alliance Industrial Group, Inc., named in the foregoing instrument, that said instrument was signed and 

sealed on behalf of Alliance Industrial Group, Inc., and acknowledge said instrument to be a voluntary 

act and deed of said corporation. 

Subscribed and sworn to before me, a Notary Public for Oregon 

1\4/ km(Merly) 

Notary Public for Oregon 

My commission expires: 6€0-. 61 a-01 to 

NOTICE TO THE OWNER of the land described in the foregoing copy of claim of lien: 

Please be advised that the original Claim of Construction Lien, of which the foregoing is 

a true copy, was filed and recorded in the office of the recording officer of Washington County. 

Oregon, on February 2015. 

Alliance Industrial Group, Inc. 

(Claimant) 

By; 

m:\wdocAssgmain\8027\8027.012\lien\01150020.clocx 

3 

Title Data, Inc. CH P0R10512 WN 2015007409.003 

Exhibit 1 

Page 3 of 8 

Case 3:15-cv-00736-HZ Document 1-1 Filed 04/30/15 Page 11 of 22
Guarantee No. 14F0027175 Effective Date: October 13, 2014 at 5:00 P.M. 

Order No. 14F0027175 

Exhibit "A" 

PARCEL I: 

Parcel 1, PARTITION PLAT NO. 1996-042, in the City of Hillsboro, Washington County, Oregon. 

EXCEPTING THEREFROM that portion lying North of N.W. Evergreen Parkway. 

ALSO EXCEPTING THEREFROM that portion conveyed to the Hillsboro Evergreen, LLC by 

Quitclaim Deed recorded April 6, 2001 as Fee No. 2001-030303. 

FURTHER EXCEPTING THEREFROM those portions thereof described in Deeds to the City of 

Hillsboro recorded June 6, 2013 as Recording Fee No. 2013-051412; and recorded October 28, 

2013 as Recording Nos. 2013-093989 and 2013-093990, Washington County Deed Records. 

PARCEL IV 

That certain property situated in George H. Ebberts Donation Land Claim No. 46, in the City of 

Hillsboro, County of Washington and State of Oregon, described as follows: 

Commencing at the Northeast corner of said George H. Ebberts Donation Land Claim No. 46, 

marked by a 3-1/4 inch aluminum disk per USBT Book 7, Page 324; thence along the East line 

of said Donation Land Claim No. 46 South 01° 25' 15" West, a distance of 544.55 feet to the 

true point of beginning, being a point on the centerline of creek as It runs on the date of 

November 22, 1994; thence, from said point of beginning, continuing South 010 25' 15" West 

along said East line a distance of 1084.50 feet; thence, departing said East line, and following 

the Northerly line of that certain parcel of land conveyed to E. H. Johnson by Deed recorded 

March 20, 1951 in Book 318 at Page 410 of Deed Records, Washington County, Oregon, North 

880 04' 33" West a distance of 1349.96 feet an iron pipe: thence along the West line of 

aforesaid Donation Land Claim No. 46, North 01° 35' 42" East a distance of 63.43 feet to the 

centerline of a creek, said point of centerline also being South 01° 35' 42" West a distance of 

1565.41 feet from the Northwest corner of Donation Land Claim No. 46, being marked by a 3-

1/2 inch aluminum disk per USBT Book 7 at Page 326; thence departing the Westerly line of 

Donation Land Claim NO. 46, and following the centerline of said creek as it flows on November 

22, 1994 the following eight (8) bearing and distances: 

1. thence North 60° 36' 07" East a distance of 75.09 feet; 

2. thence North 430 55' 24" East a distance of 42.47 feet; 

3. thence North 37° 26' 55" East a distance 01 402.81 feet; 

4. thence North 330 19' 36" East a distance of 106.18 feet; 

5. thence North 390 58' 57" East a distance of 107.61 feet; 

6. thence North 58° 14' 49" East a distance of 111.24 feet; 

7. thence North 68° 26' 47' East a distance of 151.87 feet; 

Guarantee-OTIRO OR-01060.474573-RAM-27364-1- -14F0027175 

RamQueSt 3/2006 

Page lOof 13 

EMOMAYAGE 1 OF (3 

Title Data, Inc. CH P0R10512 WN 2015007409.004 

Exhibit 1 

Page 4 of 8 

Case 3:15-cv-00736-HZ Document 1-1 Filed 04/30/15 Page 12 of 22
Guarantee No. 14r410271715 Effective Date: October 13, 2014 at 5:00 P.M. 

8. thence North 65° 43' 56" East a distance of 736.10 feet to the true point of beginning. 

PARCEL III: 

TRACT A: 

A parcel of land located in the West one-half of Section 27, Township 1 North, Range 2 West of 

the Willamette Meridian, in the City of Hillsboro, County of Washington and State of Oregon, 

being further described as follows: 

Beginning at the Southeast corner of the Walter Pomeroy Donation Land Claim No. 39; thence 

South 89° 39' 24" West, along the South line of said Donation Land Claim, a distance of 

1500.32 feet to a point on the Southerly extension of the East right-of-way line of NE Shute 

Road; thence North 00° 33' 27" West, along said extension and right-of-way Ilne, a distance of 

1950.29 feet to an iron rebar; thence North 89° 26' 33" East, a distance of 243.21 feet to an 

iron rebar; thence North 59° 58' 57" East, a distance of 495.43 feet to an iron rebar; thence 

North 30° 19' 16" East, a distance of 646.09 feet to an iron rebar; thence North 03° 34 39" 

East, a distance of 210.00 feet to an iron rebar; thence North 370 51' 40" East, a distance of 

409.00 feet to an iron rebar; thence South 54° 09' 08" East, a distance of 207.79 feet to an 

iron mbar; thence North 89° 25' 29" East, a distance of 64.36 feet to an iron rebar; thence 

South 00° 34' 31' East, a distance of 38.00 feet; thence South 58° 25' 39" West a distance of 

9.82 feet to an iron rebar; thence South 00° 34' 46" East, a distance of 63.44 feet to a 1 inch 

Iron pipe; thence South 00° 35' 16" East, a distance of 3054.16 feet to the true point of 

beginning. 

EXCEPTING THEREFROM that portion described in Dedication Deed to the public recorded 

August 13, 1996 as Fee No. 96-072316. 

TRACT B: 

A parcel of land located in the North one-quarter of Section 27 and the South half of Section 

22, Township 1 North, Range 2 West of the Willamette Meridian, In the City of Hillsboro, 

County of Washington and the State of Oregon, being further described as follows: 

Commencing at the Northwest corner of the G.H. Ebberts Donation Land Claim No. 46; thence 

North 890 44' 50' East, along the North line of said Donation Land Claim, a distance of 8.41 

feet; thence South 00° 34' 31" East, a distance of 63.00 feet to a point on the Southerly rightof-way line of NW Evergreen Road and the true point of beginning, said point being North 00° 

34' 31" East 1.00 feet from an Iron rebar; thence North 890 44' 54' East, along said right-ofway line, a distance of 758.27 feet; thence 167.27 feet along the arc of a curve lathe right, 

said curve having a radius of 1,949.85 feet, central angle of 04° 54' 55", a chord bearing of 

South 870 47' 39" East, and a Chord length of 167.22 feet to a point of reverse curve; thence 

172.94 feet along the arc of a curve to the left, said curve having a radius of 2,045.05 feet, 

central angle of 04° SO' 43°, a chord bearing of South 870 45' 32" East, and a chord length of 

172.89 feet; thence North 89° 49' 05" East, continuing along said right-of-way line, a distance 

of 238.96 feet to a brass screw, said point bears South 00° 4513" East 78.00 feet from the 

Northeast earner of said Ebberts Donation Land Claim; thence along the East line of said 

Ebberts Donation Land Claim; thence South 00° 45' 13" East, a distance of 466.64 feet to an 

Iron rebar; at the Northeast corner of that tract described in Document No. 94109221, Deed 

Records; thence along said line South 63° 33' 26" West, a distance of 736.22 feet iron rebar; 

thence South 660 16' 19" West, a distance of 151.90 feet to an iron rebar; thence South 56° 

04' 21" West, a distance of 111.26 feet to an iron rebar; thence South 37° 48' 29" West, a 

Guarantee-OTIRO OR-01060.474573-RAM-27364-1- -14P0027175 

RamQuest 3/2006 

Page 11 ef 13 

FAINT A- PAGE OF.63- 

Title Data, Inc. CH POR10512 WN 2015007409.005 

Exhibit 1 

Page 5 of 8 

Case 3:15-cv-00736-HZ Document 1-1 Filed 04/30/15 Page 13 of 22
•• 

Guarantee No. 14F0027175 Effective Date: October 12, 2014 at 5:00 P.M. 

distance of 107.63 feet to an iron rebar; thence South 31° 09' 08" West, a distance of 106.20 

feet to an iron rebar; thence South 35° 16' 27" West, a distance of 402.88 feet to an iron 

rebar; thence South 41° 44' 56" West, a distance of 42.68 feet loan iron rebar; thence South 

58° 25' 39" West, a distance of 65.29 feet to a point which bears South 00° 34' 31" East 38.00 

feet from an iron rebar; thence North 00° 34' 31" West, a distance of 1,497.69 feet to the true 

point of beginning. 

PARCEL IV: 

Parcel 1, PAR-Ill-TON PLAT NO. 2002-025, in the City of Hillsboro, Washington County, Oregon. 

PARCEL V: 

A parcel of land located in the North one-half of Section 27 and the Southeast one-quarter of 

Section 22, Township 1 North, Range 2 West of the Willamette Meridian, in the City of 

Hillsboro, County of Washington and the State of Oregon, being further described as follows: 

Beginning at the Southeast corner of the Walter Pomeroy Donation Land Claim No. 39; thence 

South 89°39'24" West, along the South line of said Donation Land Claim, a distance of 

1,500.32 feet to a point on the Southerly extension of the East right-of-way line of N.E. Shute 

Road; thence North 00°33'2P West, along said extension and right-of-way line, a distance of 

1,950.29 feet to an iron rebar and the true point of beginning; thence North 00°33'27" West, 

along said right-of-way line, a distance of 1,368.05 feet to a brass screw; thence 384.51 feet 

along the arc of a curve to the left, said curve having a radius of 385.06 feet, central angle of 

57°12'51", a chord bearing of North 29°09'52" West, and a chord length of 368.73 feet; 

thence North 57°47'07" West, along said right-of-way line, a distance of 67.32 feet to a brass 

screw; thence 83.20 feet along the arc of a curve to the right to an iron rebar, said curve 

haying a radius of 55.01 feet, central angle of 86°39'38", a chord bearing of North 14°27'18" 

West, and a chord length of 75.49 feet; thence 406.75 feet along the arc of a curve to the left 

to an iron rebar, said curve having a radius of 1,484.45 feet, central angle of 15°41'58", a 

chord bearing of North 21°01'32" East, and a chord length of 405.48 feet thence North 

89°22'13" East, a distance of 931.29 feet to an iron rebar; thence South 00°37'21" East, a 

distance of 605.56 feet to an Iron rebar; thence 52.19 feet along the arc of a curve to the left 

to an iron rebar, said curve having a radius of 35.00 feet, central angle of 85°26'24", a chord 

bearing of South 43° 20'33" East, and a chord length of 47.49 feet; thence South 86°03'45" 

East, a distance of 18.40 feet to an Iron rebar; thence 241.71 feet along the arc of a curve to 

the right to an iron rebar, said curve having a radius of 434.00 feet, central angle of 

31°54'37", a chord bearing of South 70°06'26" East, and a chord length of 238.60 feet; thence 

South 54°09'08" East, a distance of 213.03 feet to an iron rebar; thence South 37°51'40" 

West, a distance of 409.00 feet to an Iron rebar; thence South 03°34'39" West, a distance of 

210.00 feet to an Iron rebar,; thence South 30°19'16" West, a distance of 646.09 feet to an 

Iron rebar thence South 59°58'57" West, a distance of 495.43 feet to an iron rebar; thence 

perpendicular to said East right-of-way line, South 89°26'33" West, a distance of 243.21 feet 

to the true point of beginning. 

TOGETHER WITH the benefits of that certain Sewer and Storm Water Drainage Easement 

Reservation as set forth in Deed recorded March 30, 2000 as Recording Fee No. 2000-025096, 

Washington County Deed Records. 

EXCEPTING THEREFROM that portion thereof described in Deed to the City of Hillsboro 

recorded January 17, 2003 as Recording Fee No. 2003-007700 WashIngton County Deed 

Records. 

Guarantee-071RO OR-01060.474573-RAM-27364-1- -14F0027175 

RamQuest 3/2006 

Page 12of 13 

121118ITA_- PAGE ".3 

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Tvtle Data, Inc. CH P0R10512 WN 2015007409.006 

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Exhibit 1 

Page 7of 8 

Case 3:15-cv-00736-HZ Document 1-1 Filed 04/30/15 Page 15 of 22
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Exhibit 1 

Page 8 of 8 

Case 3:15-cv-00736-HZ Document 1-1 Filed 04/30/15 Page 16 of 22
2015.019080 03/19/2015 01:03:22 PM 

NAB Crit.1 Stn=29 RECORDS1 

$30.00 $5.00 $11.00 $20.00 - Total -$66.00 

1111111111111 III 1111111111111 IIIIIIII 

02023288201500190800060061 

I, Richard Robernloht. Dim or of Assessment end 

Texatton and Ex•Officto County Clerk for Washington 

County, Oregon, do hereby certity that the within 

Instrument of writing was received I t d re orded in the 

book of record' of said cou e 

. 

ymo4.04.D 

Richard HobernIght. Director of Imeetement end 

Taxation, Ex•Officlo County Clerk 

Washington County, Oregon 

III 

Document Type: 

Person Filing Bond: 

BOND FOR DISCHARGE OF LIEN, ORS 87.076 

(Lien recorded on 02/04/15 — 2015-007409) 

Turner Construction Company 

1200 NW Naito Parkway, Suite 300 

Portland, Oregon 97210 

Person and address to whom the instrument is to be returned, labeled: 

RETURN TO: Turner Construction Company 

Attention: Tony Leon Guerrero 

1200 NW Nalto Parkway, Suite 300 

Portland, Oregon 97210 

True and actual consideration: Not applicable 

MAIL TAX STATEMENT TO: No change 

Exhibit 2 

Page 1 of 6 

Case 3:15-cv-00736-HZ Document 1-1 Filed 04/30/15 Page 17 of 22
Mark . Edwards, II 

• 

Tu Construction C 

Princl 

BY: 

Da Kavana 

Vice Preside 

J.,ibertv Mutual Insurance Comnanv 

175 Berkele Street. Boston. 02116 

Surety 

BY: 

ger 

Attomey-in-Fact 

, ; • g 

- . - 

LIBERTY BOND NO. 015047350 

MECHANICS LIEN - BOND FOR DISCHARGE 

KNOW ALL MEN BY THESE PRESENTS, That we Turner Construction Company,as principal 

(hereinafter called "Principal") and SEE ATTACHMENT AofSEE ATTACHMENT A,a corporation of 

the slate of SEE ATTACHMENT A and duly organized to transact surety business within the State of 

Oregon, as surety, are held and firmly bound unto Alliance Industrial Group, Inc.of 5823 S. 6thWay, 

Ridgefield, WA 98642as Obligee in the penal sum of One Million Eight Hundred Twenty-Five Thousand 

Six Hundred Twenty-One and 60/100 ($1.825.621.60) Dollars, lawful money of the United States of 

America, for which payment well and truly to be made, we bind ourselves, our heirs, executors and assigns, 

jointly and severally, firmly by these presents. 

WHEREAS, said Obligee has commenced an action and filed a lien in connection with the above bounden 

Principal, and has agreed to discharge said lien in consideration of the covenants contained herein. In the 

event any court of competent jurisdiction should enter an award in connection with the action, this bond will 

be honored to the extent of such award, plus costs, fees and interest awarded. 

WHEREAS, the amount and undertaking to be executed for the purpose of discharging said lien has been 

fixed at the sum stated above. 

This bond shall become effective on the 17thday of March. 2015. 

NOW, THEREFORE, the condition of this obligation is such that if the above bounden principal, its 

successors and assigns shall well and truly pay any judgment which may be rendered, not exceeding the 

above stated sum, then this obligation shall be void; otherwise to remain in full force and effect. 

SIGNED, SEALED AND DATED this 17thday of March, 2015. 

Exhibit 2 

Page 2 of 6 

Case 3:15-cv-00736-HZ Document 1-1 Filed 04/30/15 Page 18 of 22
CORPORATE ACKNOWLEDGMENT 

Form 152 

STATE OF OREGON 

COUNTY OF MULTNOMAH 

On this 17 day of March ,2O1, before me personally 

came Dan Kavanaugh to me known, who, being by me 

duly sworn, did depose and say that she/he resides in Portland/ Oregon 

that she/he is the vice President/General Manager of the 

Turner Construction Company 

the corporation described in and which executed the above instrument that she/he knows 

the seal of said corporation; that the seal affixed to said instrument is such corporate seal; 

that it was so affixed by order of the Board of Directors of said corporation, and that 

she/he signed her/his name thereto by like order. 

(SEAL) 1

FFICIAL SEAL 4 

MARILYN M R MORRISON 8 

NOTARY PUBLIC. OREGON 

COMMISSION NO. 478821 

W COMMISSION EXPIPISAPRL 07 2817 4 

Mar

1

i yn R. Morris() 

Exhibit 2 

Page 3 of 6 

Case 3:15-cv-00736-HZ Document 1-1 Filed 04/30/15 Page 19 of 22
cc o. 

Donna Jane Austi tary Public, State at Large 

My commission expi s March 31, 2018. 

CERTIFICATE OF ACKNOWLEDGEMENT OF ALL PURPOSE SURETY 

State of Alabama ) 

) ss 

County of Jefferson) 

On this 171hday of March, 2015 , before me appeared Mark W. Edwards, 

II, to me personally known, who, being by me duly sworn, did say that he is the 

Attorney-In-Fact of Liberty Mutual Insurance Company, the corporation named 

in the foregoing instrument, and that the seal affixed to said instrument is the 

corporate seal of said corporation, and that said instrument was signed and sealed 

on behalf of said corporation by authority of its Board of Directors and said Mark 

W. Edwards, II acknowledged said instrument to be the free act and deed of said 

.... corporation. •. 

Exhibit 2 

Page 4 of 6 

Case 3:15-cv-00736-HZ Document 1-1 Filed 04/30/15 Page 20 of 22
'THIS POWER OF ATTORNEY IS NOT VALID UNLESS IT IS PRINTED ON RED BACKGROUND. 

This Power of Attorney limns the acts of those named herein, and they have no authority to bind the Company except In the manner and to the extent herein slated. 

Certificate No. 6825762 

American Fire and Casually Company Liberty Mutual Insurance Company 

The Ohio Casualty Insurance Company West American Insurance Company 

POWER OF ATTORNEY 

KNOWN ALL PERSONS BY THESE PRESENTS: That American Fire & Casually Company and The Ohio Casualty Insurance Company are corporations duly organized under the laws of 

the Slate of New Hampshire, that Liberty Mutual Insurance Company is a corporation duly organized under the laws of the Slate of Massachusetts, and West American Insurance Company 

Is a corporation duly organized under the laws of the Slate of Indiana (herein collectively called the 'Companion pursuant to and by authority herein set forth, does hereby name, constitute 

and appoint, Ailsa B. Ferris: Evondia H. Woessner: Jeffrey M. Wilson: Mark W. Edwards II: Robert R. Free!: Ronald B. Gladrosich: Willem M. Smith 

at of the city of Birmingham state of Al each Individually if there be more than one named, its true and lawful attorney-In-fact to make, execute, seal, acknowledge 

and deliver, for and on its behalf as surety and as its act and deed, any and all undertakings, bonds, recognizances and other surety obligations, In pursuance of these presents and shall 

be as binding upon the Companies as if they have been duly signed by the president and attested by the secretary of the Companies In their own proper persons. - 

IN WITNESS WHEREOF, this Power of Attorney has been subscribed by an authorized officer or official of the Companies and the corporate seals of the Companies have been affixed 

thereto this 6 h day of January 2015 

STATE OF PENNSYLVANIA 

COUNTY OF MONTGOMERY 

On this 5th day of January 2015 before me personally appeared David M. Carey, who acknowledged himself to be the Assistant Secretary of American Fire and 

Casually Company, Liberty Mutual Insurance Company, The Ohio Casualty Insurance Company, and West American Insurance Company, and that he, as such, being authorized so to do, 

execute the foregoing instrument for the purposes therein contained by signing on behalf of the corporations by himself as a duly authorized officer. 

IN WITNESS WHEREOF, I have hereunto subscribed my 'MINI and affixed my notarial seal at Plymouth Meeting, Pennsylvania, on the day and year first above written. 

or 1'1:tit! 3y.I VANIA 

•0 I '8e.1,03. *Amy 17,7. By: 

. ikan0joineiy Teresa Pastella , Notary Public 

Or r.ty r:crroirr-i'on tivrorns t.blub 20. 2817 

A . 

H.0 Pr 

This Power of Attorney Is made and execut pu ,t to and ITaulhon ty of the following By•laws and Authorizations of America n Fire and Casualty Company, The Ohio Casualty insurance 

Company, Liberty Mutual Insurance Company,hd Vitt A4hcali Insurance Company which resolutions are now in full force and ettect reading as follows: 

ARTICLE IV– OFFICERS – Section 12. Power of Attomey.Any officer or other official of the Corporation authorized for that purpose In writing by the Chairman or the President, and subject 

to such limitation as the Chairman or the President may prescribe, shall appoint such attomeystn•fact, as may be necessary to act in behalf of the Corporation to make, execute, seal, 

acknowledge and deliver as surety any and all undertakings, bonds, recognizances and other surety obligations. Such allomeys•In•fact, subject to the limitations set forth in their respective 

powers of attorney, shall have full power to bind the Corporation by their signature and execution of any such instruments and to attach thereto the seal of the Corporation. When so 

executed, such instruments shall be as binding as if signed by the President and attested to by the Secretary. Any power or authority granted to any representative or attomepin•fact under 

the provisions of this articte may be revoked at any lime by the Board, the Chairman, the President or by the officer or officers granting such power or authority. 

ARTICLE XIII – Execution of Contracts – SECTIONS. Surety Bonds and Undertakings. Any officer of the Company authorized for that purpose in writing by the chairman or the president, 

and subject to such limitations as the chairman or the president may prescribe, shall appoint such altorneys•Ifact, as may be necessary to act In behalf of the Company to make, execute, 

seal, acknowledge and deliver as surely any and all undertakings, bonds, recognizances and other surety obligations. Such altorneys-lrefact subject to the limitations set forth In their 

respective powers of attorney, shall have full power to bind the Company by their signature and execution of any such Instruments and to attach thereto the seal of the Company. When so 

executed such Instruments shall be as binding as If signed by the president and attested by the secretary. 

Certificate of Designation – The President of the Company, acting pursuant to the Bylaws of the Company, authorizes David M. Carey, Assistant Secretary to appoint such afforneys•infact as may be necessary to act on behalf of the Company to make, execute, seal, acknowledge and deliver as surety any and all undertakings, bonds, recognizances and other surety 

obligations. 

Authorization – By unanimous consent of the Company's Board of Directors, the Company consents that facsimile or mechanically reproduced signature of any assistant secretary of the 

Company, wherever appearing upon a certified copy of any power of attorney Issued by the Company In connection with surely bonds, shall be valid and binding upon the Company with 

Use same force and effect as though manually affixed. 

I, Gregory W. Davenport, the undersigned, Assistant Secretary, of American Fire and Casualty Company, The Ohio Casualty Insurance Company, Liberty Mutual Insurance Company, and 

West American Insurance Company do hereby certity that the original power of attorney of which the foregoing Is a full, true and correct copy of the Power of Attorney executed by said 

Companies, is in full force and effect and has not been revoked. 

IN TESTIMONY WHEREOF, I have hereunto set my hand and affixed the seals of said Companies this 44'` day of N-A.N re V \ , 2015 . 

SS 

American Fire and Casualty Company 

The Ohio Casualty Insurance Company 

Liberty Mutual Insurance Company 

West piertcan Insurance Company 

By: Apif117/6 

David M. CareassIstant Secretary 

By: 

Gregory W. Davenport, Assistant Secretary 

Exhibit 2 

_I.MS=12873,122013 43 of 250 

— 

Case 3:15-cv-00736-HZ Document 1-1 Filed 04/30/15 Page 21 of 22
Liberty 

Mutual. 

LIBERTY MUTUAL INSURANCE COMPANY 

FINANCIAL STATEMENT — DECEMBER 31,2013 

SURETY 

Assets Liabilities 

Cash and Bank Deposits $1,118,180,550 Unearned Premiums $5,940,431,054 

*Bonds —U.S Government 1,888,225,943 Reserve for Claims and Claims Expense 17,305,063,560 

Funds Held Under Reinsurance Treaties 212659,311 "Other Bonds 12,039,490,815 

Reserve for Dividends to Policyholders 1,226,236 

*Stocks 9,030,962,112 Additional Statutory Reserve 63,348,980 

Real Estate 251,301,907 Reserve for Commissions, Taxes and 

Agents' Balances or Uncollected Premiums 4,783,042,931 Other Liabilities 5.826.683.629 

Accrued Interest and Rents 149,855,386 Total $29,349,412,770 

Special Surplus Fuods $55,686,852 

Other Admitted Assets 15.216.749 451 Capital Stock 11,250,000 

Paid in Surplus 7,898,288,167 

Unassigned Surplus 7,161,171,306 

Total Admitted Assets $44,475,809,095 Surplus to Policyholders 15.126,396,325 

Total Liabilities and Surplus 444475,809,095 

" Bonds are stated at amortized or investment value; Stocks at Association Market Values. 

The foregoing financial information is taken from Liberty Mutual Insurance Company's financial 

statement filed with the state of Massachusetts Department of Insurance. 

I, TIM MIKOLAJEWSKI, Assistant Secretary of Liberty Mutual Insurance Company, do hereby certify that the foregoing is a true, and 

correct statement of the Assets and Liabilities of said Corporation, as of December 31, 2013, to the best of my knowledge and belief. 

IN WITNESS WHEREOF, I have hereunto set my hand and affixed the seal of said Corporation at Seattle, Washington, this 20th day of 

March, 2014. 

Assistant Secretary 

S-12621.141C/a 4/13 

Exhibit 2 

Page 6 of 6 

Case 3:15-cv-00736-HZ Document 1-1 Filed 04/30/15 Page 22 of 22