Page 1 – AFFIDAVIT OF TRACY REEVE

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

AFFIDAVIT OF TRACY REEVE 

(In Support of Plaintiff’s Motion for a 

Temporary Restraining Order and Preliminary 

Injunction) 

STATE OF OREGON) 

 ) ss. 

County of Multnomah ) 

I, TRACY REEVE, being first duly sworn, state: 

1. I am the City Attorney for the City of Portland, Oregon, and am one of the attorneys 

representing plaintiff City of Portland in the above-entitled case. 

Case 3:14-cv-01958-SI Document 10 Filed 12/10/14 Page 1 of 3
Page 2 – AFFIDAVIT OF TRACY REEVE

PORTLAND CITY ATTORNEY’S OFFICE 

1221 SW 4TH AVENUE, RM 430 

PORTLAND, OREGON 97204 

(503) 823-4047

2. I make this affidavit in support of Plaintiff’s Motion for a Temporary Restraining 

Order and Preliminary Injunction. 

3. Attached hereto as Exhibit A is a true and accurate copy of the current version of 

City of Portland Code Chapter 16.40 Private For-Hire Transportation Regulations. 

4. Attached hereto as Exhibit B is a true and correct copy of the current version of 

Chapter 16.40 of the Private For-Hire Transportation Regulations – Administrative Rules 

promulgated by the Private For-Hire Transportation Board of Review. 

5. Attached hereto as Exhibit C is a true and accurate copy of a cease and desist order 

by letter dated December 8, 2014, from the City of Portland Bureau of Transportation to Ms. 

Brooke Steger, General Manager, Uber, Inc. 

6. Attached hereto as Exhibit D is a true and accurate copy of a letter dated December 

8, 2014, from the City of Portland Office of Management and Finance to Uber Technologies, Inc. 

regarding registering the business with the City of Portland’s Revenue Bureau. 

7. Attached hereto as Exhibit E is a true and accurate printout of the results of an online 

search at the website of the Oregon Secretary of State Corporation Division, Business Name 

Search. Results show no active or inactive business related to Uber Technologies, Inc. 

8. Attached hereto as Exhibit F is a true and accurate printout of the results of an online 

search at the website of the Oregon Secretary of State Corporation Division, Business Name 

Search. Results show no active or inactive business related to Rasier, LLC 

9. Attached hereto as Exhibit G are true and accurate samples of Uber ads placed on 

Craigslist from November 4, 2014, through December 8, 2014. During that time period, the 

Craigslist website shows 677 Uber ads for drivers. 

////// 

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Case 3:14-cv-01958-SI Document 10 Filed 12/10/14 Page 2 of 3
Page 3 – AFFIDAVIT OF TRACY REEVE

PORTLAND CITY ATTORNEY’S OFFICE 

1221 SW 4TH AVENUE, RM 430 

PORTLAND, OREGON 97204 

(503) 823-4047

10. Attached hereto as Exhibit H is a true and accurate copy of the December 8, 2014, 

email from Tracy Reeve to Uber attorney Gregory Chaimov giving notice of the intent to appear at 

ex parte in Multnomah County Circuit Court on December 9, 2014, at 1:30 p.m. 

11. Attached hereto as Exhibit I is a true and accurate copy of the Complaint for 

Permanent Injunction, Civil Penalties, Restitution and Other Equitable Relief filed in the case of 

The People of the State of California v. Uber Technologies, et al., Case No. CGC-14-543120, in the 

Superior Court of the State of California, City and County of San Francisco. 

 s/ Tracy Reeve 

 Tracy Reeve 

SUBSCRIBED AND SWORN TO before me this 10th day of December, 2014, by Tracy 

Reeve. 

 s/ Jody L. Thoman Notary Public for Oregon 

 My commission expires: 10/29/2014 

Case 3:14-cv-01958-SI Document 10 Filed 12/10/14 Page 3 of 3