Kayla Nordlurn and Ashley Nordlurn

UNITED STATES DISTRICT COURT

DISTRICT OF OREGON

PORTLAND DMSION

TAISSA AND RAYACHCAR-WINKELS,Individually and as Parentsand Next Friends of S.A.,

a mfflori

No. 3:15-cv-0385-MO

DEFENDANTS KAYLA NORDLUMAND ASHLEY NORDLUM'S TRIALMEMORANDUM

Plaintiffs,

VS.

LAKE OSWEGO SCHOOL DISTRICT;an Oregon municipal corporation;HEATHER BECK, an individual;JENNIFER SCHIELE, an individual;IAN LAMONT, an individual;KAYLA NORDLUM, an individual;

ASHLEY NORDLUM, an individual;

SUZANNE YOUNG, an individual; and

{?JNKNOWN STAFF, unknown

individuals,

Defendants.

Pursuant to the Court's June 9, 2017 Jury Trial Management Order, Defendants Kayla

Nordlurn and Ashley Nordlum (collectively, ?the Nordlurns?) submit this Trial Memorandum.

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2. S.A.'s 42 USC § 1983 Claim asserting violation of her First Amendment rights against

Kayla Nordlurn;

3. S.A.'s Intentional Infliction of Emotional Distress claim against Kayla Nordlum;

4. S.A.'sFalseImprisonmentclaimagainstKaylaNordlum;and

s. A claim for punitive damages.

II. FACTS

Plaintiffs' claims all arise from S.A.'s involvement on the Lakeridge High School Pacer

Dance Team ("PDT?) during the 2014-15 school year, S.A.'s freshman year. Kayla Nordlum was

the Head Coach and Ashley Nordlum was the Assistant Coach. There is no dispute that both Kayla

and Ashley Nordlum were acting as employees of the Lake Oswego School District at all times.

Plaintiffs allege three main "events:? 1) a team bonding weekend that occurred among the

PDT members in Gearhart, Oregon, on June 28-29, 2014 (the "Gearhart Bonding Trip"); 2) a

student only initiation event that took place throughout various locations in Lake Oswego on

August 9, 2014 ("Initiation?); and 3) a team "boot-camp? event that occurred in Sunriver, Oregon,

on August 24-28, 2014 ("Sunriver Trip").

A. Gearhait Bonding TripBoth Kayla and Ashley Nordlum were chaperones at the Gearhart Bonding Trip. As would

be expected during a team bonding event, there were formal activities organized by the coaches andtime for the team members to get to know one another. When S.A.'s parents learned of the plamiedtrip they rented a house in Gearhart with two other families so they could drive S.A. to Gearhart andremain close for the weekend.

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breakfast at a restaurant in Gearhart. At some point the location of breakfast changed to Seaside,

Oregon. Kayla and Ashley Nordlum, whom were not attending breakfast but were headed home

instead, dropped some of the PDT members off at the Seaside breakfast restaurant. Upon dropping

the PDT members off Kayla Nordlum instructed them to coordinate rides home among themselves

and the remaining adult chaperones. Shortly after Kayla and Ashley Nordlum dropped them off, thePDT members changed their mind on eating and left the restaurant. S.A. and a second teammatewere riding home with their families, and they called their parents to pick them up.

B. Initiation

On August 9, 2017 S.A. took part in a student led PDT "Initiation? which was coordinated

by the PDT senior dancers. Prior to Initiation Kayla Nordlum spoke with the senior PDT membersabout their plans. The senior dancers told Kayla that the team was planning to spend the night at a

senior dancer's house, where the dancer's mother, Kathy Fewell, would be present for all the events

the entire night. The senior dancers told Kayla that the night would consist of dinner at a local

Qdoba restaurant. The dancers would then go to the Fewell's house, the freshmen dancers would bedressed in silly costumes, and would complete a scavenger hunt and obstacle course at Lakeridge

Junior High School. The dance team would then return to the Fewell's house for team bonding anda sleepover. Kayla had no reason to distmst the plan as it was explained by the senior dancers.Kayla also confirmed Kathy Fewell would chaperone throughout the evening. Kayla shared the

plan for Initiation via email with PDT parents, including Mrs. Achcar-Winkels. Mrs.

Achcar-Winkels received the information and responded with a single concern that S.A. not bedriven by other teenagers. Kayla Nordlurn suggested Mrs. Achcar-Winkels to contact Kathy Fewell

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been shared by senior dancers. Although freshmen dancers did dress in silly costumes, including

S.A. dressed as Big Bird, the freshmen dancers were blindfolded and taken to downtown Lake

Oswego where they did tmth-or-dare tasks assigned to them by the senior dancers. S.A. was dared

to dance on top of a car.

After tmth-or-dare, the dancers went to T ,akeridHe High School where other non-dance team

students, both male and female, had congregated. At the high school, the new members were

blindfolded and instmcted to do the PDT "pom dance,? a routine the team had been practicing to

perfornn at events. During the pom dance, students threw water balloons at the freshmen dancers,

and squirted the dancers with squirt guns filled with water and ketchup. After the pom dance, theseniors directed the freshmen PDT members to replace their costumes with plastic garbage bags.While wearing garbage bags, the freshmen wrestled on a tarp covered in maple syrup. The

non-freshmen students threw powder and feathers at the freshmen PDT members.

Although neither defendant coach was aware of these events Mrs. Achcar-Winkels was

observing the Initiation out of sight of the students. Before Initiation began, Mrs. Achcar-Winkelsdropped S.A. off at the Fewell residence. At the time of drop off, Mrs. Achcar-Winkels learnedfrom Kathy Fewell that the senior PDT members planned to take the freshmen to Lakeridge High

School instead of the junior high as previously disclosed. Despite the fact that

Mrs. Achcar-Winkels had contact information for the Nordlums, and for the High School AthleticDirector, Mrs. Achcar-Winkels shared nothing of what she learned early in the evening before thedancers arrived at the high school. Rather, Mrs. Achcar-Winkels followed the students to the High

School, climbed a tree to conceal her presence, and taped the event with her phone camera.

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From T,akerid7e High the PDT members next went to the wading area in George Rogers

Park. The freshmen girls were instmcted to step into the wading area of the water, and then the

senior dancers quizzed the freshmen with questions about their coach and dance. The team then

returned to the Fewell's home where they received their PDT member t-shirts and were

congratulated on becoming official members of the PDT. S.A. called her mother and asked to be

picked up. Mrs. Achcar-Winkels encouraged S.A. to spend the night.

The next morning the dance team members held a car wash, which Kayla Nordlurn

attended. Team members gave positive reports about Initiation and shared nothing with Kayla

Nordlum inconsistent with her understanding of the Initiation plan shared previously. Neither S.A.

nor Mrs. Achcar-Winkels told Kayla Nordlum what occurred the night before.

On August 13, 2017, Kayla Nordlum learned from technique coach Lilly Schauffler that

there was a complaint about Initiation. Kayla Nordlum was told an unidentified PDT member hadcomplained about the events that took place during Initiation. Kayla irmnediately reported theanonymous complaint to Lakeridge Athletic Director Ian Larnont, directing him to Ms. Schauffler.

AD Lamont subsequently met with the Mr. and Mrs. Achcar-Winkels to discuss Initiation. Aftermeeting with the family, AD Lamont sent an email to all coaches instmcting them to cease bondingevents/initiations for new sports team members. Neither Kayla nor Ashley Nordlum were providedadditional information about the complaints concerning Initiation before leaving for Sunriver.

C. Sunriver BootcampOn August 24-28, 2014, the dance team traveled to Sunriver, Oregon. Throughout

Bootcamp, neither of the Nordlums knew who complained about Initiation nor did they know the

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tumor or gossip, the Nordlums met with all PDT member in groups by class year to ask whether any

member had concerns regarding Initiation. None of the dancers raised any concern.

While in Sunriver, as a bonding activity the PDT coaches shared, and asked the PDT

members to share, an example of a challenge and a triumph from their life. Both Kayla and Ashley

Nordlum gave examples from their own lives. No team member was required to participate in this

activity. S.A. did not share anything. S.A. did not complain about this activity to either Kayla or

Ashley Nordlum.

After the Gearhart trip, Mrs. Achcar-Winkels told Kayla Nordlum that some of the dancers

had snuck out after curfew and she believed they plam'ied to do the same in Sunriver. In an

abundance of caution and to prevent this from occurring again, Kayla provided all of the dancers her

cell phone number and instmcted them to contact her in in the event they needed to leave their room

that evening. Kayla Nordlurn also decided to tape the bedroom doors, a detail she shared with

parents via email. Mrs. Achcar-Winkels responded to this initial email that she believed everything

Kayla was doing was correct. However, because other parents had concerns Kayla decided todiscontinue the tape after one night. Kayla sent a follow up email to parents agreeing she woulddiscontinue taping the doors. In response to Kayla Nordlum's follow up email to parents,

Mrs. Achcar-Winkels again encouraged Kayla, stating ?Don't let the small stuff get to you . .. You

ARE doing the right things? and further "Keep your head up. God gives his hardest battles to his

strongest soldiers.?

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Reasonably believing the Seniors had not been using drugs nor alcohol, and concerned about thedismption this narrative was causing the PDT, Kayla Nordlum sent Mrs. Achcar-Winkels thefollowing email later that evening:

Hi Taissa,Thank you for all of your help with the vans and getting everything

going for us we had a blast!Ok, I need to address something that has caused a lot of havoc that I

think you may know something about. The details that we hear you

are saying happened at initiation are not tme and I'm pretty upset thatfor one you would believe I would allow something like that to

happen and for two that you would go to everyone and talk about itbut me. It has made me feel very upset and I don't understand whyyou would spread something like this about my team without coming

directly to me with your concern. That is one thing I ask of all of my

parents.

In sunriver [sic] I had one on ones with each class asking for very

specific details about initiation night and the details that yousupposedly think happened could be further from the tmth. I even

gave [S.A.] an opportunity to tell me if anything the seniors had everdone made her feel uncomfortable and she said no.

My freshmen class are afraid to go into high school because they areafraid to get asked if they were the one poisoned by the PDT seniors.This is not okay! ! ! ! !

So if you would like to discuss this issue I would be more than happy

to have a phone call with you or meet you, if not, please stop talk

about an event you weren't present at. You are mining what is

supposed to be a good healthy team.

I hope I don't hear anything more about this night from anyone elsebut you, but if I do it could result in some sort of suspension for

[S.A.]. It isn't fair to my team and I won't have it.

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regarding Initiation nor that Mrs. Achcar-Winkels had been witness to the events of Initiation.

Shortly after receiving Kayla's email, Mrs. Achcar-Winkels discussed it with AD Larnont and

Lakeridge High Principal Jennifer Schiele. Both AD Lamont and Principal Schiele told Kayla that

the email to Mrs. Achcar-Winkels was not appropriate and that she should not discipline S.A. forher parents' concerns regarding Initiation. Kayla Nordlum called Mrs. Achcar-Winkels to

apologize for the email and her misunderstanding.

Other than at practices, the only subsequent contact that Kayla Nordlurn had with the

Achcar-Winkels family was by text message and email. This included cornrnunicating Kayla's

coaching decisions on which PDT members would be dancing in the three PDT routines. All

dancers were chosen for two of the three routines and S.A. and another dancer were made alternatesfor the Jazz routine.

On September 22, 2014, less than a month into the school year, S.A. resigned from the

dance team. Mrs. Achcar-Winkels told Kayla Nordlum S.A. quit to improve her technique through

private dance lessons. Neither Kayla nor Ashley Nordlurn were aware S.A. or her parents had any

complaints or concerns about their coaching of the PDT until December 2014, when the Districtinitiated its own investigation into complaints it later received. Rather, during all pertinent times

that S.A. was a member of the PDT, Mrs. Achcar-Winkels always praised Kayla for her efforts as a

coach.

III. ISSUES FOR TRIAL

A. The Oregon Tort Claims Act Applies To Plaintiff's Tort Claims.

The Oregon Tort Claims Act (?OTCA") applies to all tort claims against the Nordlurns.

Each surviving tort claim alleges the Nordlums acted as employees and agents of the Lake Oswego

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Claims.

ORS 30.265(2) establishes that the sole cause of action for torts caused by the conduct of a

public employee acting within the course and scope of her employment is an action under the

OTCA. The only exception to this role is where the amount of damages sought by the plaintiff

exceeds the statutory cap in effect at the time. Id. The applicable cap in effect in this case is

$667,700.00. ORS 30.272(2)(f).

While plaintiffs have not pled a specific amount of damages in their operative complaint,

regardless of the amount of damages they seek, the Nordlums will be entitled to have the District

substituted in their place on all tort claims. First, if plaintiffs allege an amount of damages under the

applicable cap, ORS 30.265(4) applies and the District must be substituted as the defendant.

Alternatively, even assuming plaintiffs allege an amount in excess of the cap, plaintiffs cannotrecover any amount in excess of cap, thus making the District the only appropriate defendant.

Clarke v. OHSU, 343 oR 581, 175 P3d 418 (2007). Clarke and its progeny identify the limited

circumstances under which the Remedies Clause to the Oregon Constitution permits a plaintiff to

recover damages in excess of the cap. Id. Only when the damages limitations of the OTCA result

in an "emasculated remedy that is incapable of restoring the right that has been injured? will the cap

be disregarded. Id. at 605-606. In Ackerman v. OHSU, the Court of Appeals identified factors acourt should consider in determining whether application of the cap violates the Remedies Clause.233 0r App 511, 227 P3d 744 (2010). The factors, in descending order of importance, are: 1) the

disparity between the capped damages and the damages that the plaintiff would have recovered atcommon law; 2) the amount of uncompensated out-of-pocket expenses a plaintiff endures by virtue

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Unlike Clarke and Ackerman where the plaintiffs had many millions of dollars in verifiable

economic damages in addition to substantial noneconomic damages, in this case plaintiffs' evidenceat trial will be insufficient to prove that application of the cap would result in an emasculated

remedy for plaintiffs' claimed injuries. As such, ORS 30.265(3) applies and requires that theDistrict be the only defendant for all tort claims.

2. The OTCA Precludes Plaintiffs' Claim For Punitive Damages Based Upon Any Of

The Torts Alleged Against Kayla And Ashley Nordlum.

Because all of plaintiffs' allegations against Kayla and Ashley Nordlum arise from actions

taken in the course and scope of their employment with the Lake Oswego School District, the

OTCA applies to each tort claim. ORS 30.265(1). For claims governed by the OTCA, punitivedamages are not available. ORS 30.269(1). Thus, plaintiffs are not entitled to, and the jury must

not consider, any request for punitive damages arising from plaintiffs' tort claims.

B. Plaintiff S.A. Cannot Prove Her Tort Claims.

1. Plaintiff S.A.'s Negligence Claims Against Kayla And Ashley Nordlum Will Fail

Because Plaintiffs Will Be Unable To Prove Either Kayla Or Ashley Had TheRequisite Prior Knowledge To Be Held Liable For The Initiation Activities.

Plaintiff S.A.'s operative complaint asserts a negligence claim against Kayla and Ashley

Nordlum. Although plaintiff S.A. has yet to plead her negligence claim with specificity, defendants

assume S.A.'s negligence claim stems from Kayla and Ashley Nordlum's alleged failure tointervene and prevent the Initiation activities. Assurning defendants' assumption is correct, S.A.'sburden is found in Mosely v. Portland Sch. Dist. No IJ, 315 0r 85, 843 P2d 415 (1992). In

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False Imprisonment Claim.

Plaintiff S.A. asserts a false imprisonment claim against Kayla Nordlurn as a result of Kayla

placing tape on the door to S.A.'s room during the Sunriver Trip. To prevail on this claim S.A.must prove: 1) Kayla confined her; 2) the confinement was intentional; 3) S.A. was aware of the

confinement; and 4) the confinement was unlawful. Hiber v. Creditors Collection Serv. Inc., 154

Or App 408, 413 P2d 989 (1998). It has long been established that school employees serve in an in

loco parentis capacity while supervising students during school activities, such as the PDT SumiverTrip. See e.g. Fazzolari v. Portland Sch Dist No IJ, 3030 0r 1, 20, 734 P2d 1326 (1987)(explaining the duty of supervision owed by educators to students arises from the relationship

between educators and children entrusted to their care). Consent to the confinement is a complete

defense to a claim for false imprisonment. RESTATEMENT (SECOND) OF TORTS, § 892A; Roberts v.Coleman, 228 0r 286, 365 P2d 79 (1961).

The evidence will show: l) the duct-tape placed on the students' doors was not placed for

confinement, but rather, for the purpose of identifying any dancer leaving her room after curfew;2) Mrs. Achcar-Winkels and S.A. were aware that Kayla placed duct-tape on the PDT member

doors after curfew for one night while in Sunriver, and 3) Mrs. Achcar-Winkels and S.A. consentedto S.A.'s confinement to her room, after curfew, as evidenced by Mrs. Achcar-Winkels' multipleemail communications, the absence of any objection or request to leave, and S.A.'s agreement that

she would not leave her assigned room after curfew.

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extraordinarily beyond the bounds of socially tolerable behavior; and 3) the conduct in fact caused

plaintiff S.A.'s severe emotional distress. McManus v. Auchinclos, 271 0r App 765, 781, 353 P3d

17, (2015) (internal quotation marks and citations omitted). Harsh or intimidating words or conduct

that is merely rode, boorish, tyrannical, churlish and mean is insufficient to support a claim for

IIED. Schoen v. Freightliner, LLC, 224 0r App 613, 626-27, 199 P3d 332, 341 (2008) (citationsomitted). Instead, "[1]iability has been found only where the conduct has been so outrageous incharacter, and so extreme in degree, as to go beyond all possible bounds of decency, and to be

regarded as atrocious, and utterly intolerable in a civilized community." House v. Hicks, 218 0rApp 348, 358, 179 P3d 730, rev den 345 0r 381 (2008).

Plaintiff S.A. will be unable to prove that Kayla Nordlum undertook any conduct with the

purpose of causing S.A. severe emotional distress. A disagreement as to the methods or decisions

of Kayla Nordlum or the means by which she coached and supervised the team is insufficient toallow this claim to proceed to the jury.

C. Plaintiff S.A.'s First Amendment Claim Is Insufficient As A Matter Of Law.

1. Plaintiff S.A.'s First Amendment Claim Is Limited To The Email That Kayla

Nordlurn Sent To Mrs. Achcar-Winkels On August 28, 2014.

S.A.'s First Arnendment claim against Kayla Nordlurn is limited to the August 28, 2014

email that Kayla sent to Mrs. Achcar-Winkels, quoted in its entirety above. (See Opinion andOrder, Dkt. No. 165, pp 2, explaining: "There are several portions of Judge You's [Findings and

Recommendations] to which no party objects. In regard to those portions, I ADOPT Judge You'sF&R as my own opinion.")

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Sunriver - is any evidence of specific actual or threatened consequences to S.A. that might result if

the instmction to cease talking about what took place at initiation were not followed." The Courtmled, "[a] group inquiry about whether the freshmen PDT dancers had any concerns about whattook place at initiation, followed by a directive that the coaches 'didn't want to talk about it ever

again,' accompanied by nothing more than an admonition that the dancers would be 'in trouble' forany further talk about the incident is insufficient to support a First Amendment claim for alleged

retaliation against S.A." (See Findings & Recormnendations, Dkt. No. 142, pp. 33-34). As a result

of the Court's mling, S.A.'s 42 USC § 1983 claim requires the jury only to consider whether

Kayla's August 28, 2014 email to Mrs. Achcar-Winkels violated S.A.'s First Amendment rights.

2. KaylaNordlumDidNotViolateS.A.'sFirstArnendmentRights.

In order to prevail on her First Amendment retaliation claim, S.A. must prove: 1) S.A.

engaged in protected activity; 2) Kayla Nordlurn took action towards S.A. that would chill a person

of ordinary firmness from continuing to engage in protected activity; and 3) S.A.'s engagement in

the protected activity was a substantial or motivating factor in Kayla's conduct, i.e., there was a

nexus between Kayla's email to Mrs. Achcar-Winkels and Kayla's intent to chill protected speech.

Ariz. Students ' Ass 'n v. Ariz. Bd. of Regents, 824 F3d 858, 867 (9th Cir 2016) (citation omitted);

Pinard v. Clatskanie Sch. Dist. 6J, 467 F3d 755, 770 (9th Cir 2006) (citations omitted).

S.A. will need to identify the protected speech to which she believes Kayla's email was

directed. Kayla's testimony will be clear that her email was intended to deter Mrs. Achcar-Winkelsfrom spreading rumors about PDT members using illegal substances during Initiation. No

reasonable juror could conclude that Kayla Nordlum was trying to chill an athlete or parent from

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concerns. Plaintiff will be unable to prove the necessary nexus.

3. S.A.'s First Amendrnent Claim Fails Because Under Tinker And Its Progeny

Kayla's Email To Mrs. Achcar-Winkels Was In Response To Kayla's ReasonableConclusion That Rumors Of PDT Member Substance Use Infringed On The RightsOf Other Students.

The constitutional rights of students in public school are not automatically coextensive with

the rights of adults in other settings, and the rights of students must be applied in light of the special

characteristics of the school enviromnent. Morse v. Frederick, 551 US 393, 396, 127 S Ct 2618,

168 L Ed 290 (2007). Schools have the ability to limit student speech where the school officials

reasonably conclude the speech or expression would ?materially and substantially dismpt the workand discipline of the school.? Tinker v. Des Moines Indep. Cmty Sch. Dist., 393 US 503, 513, 89

S Ct 733, 21 L Ed 2d 731 (1969). A school also has the ability to limit student speech where the

school officials reasonably conclude the speech infringes on the rights of other students. Pinard,

467 F3d at 768 (9th Cir 2006).

The evidence in this case will reveal that Kayla's email did not infringe S.A.'s First

Amendment rights because the speech Kayla was addressing with her email -Mrs. Achcar-Winkels' rumors of PDT member substance use - was speech Kayla reasonablybelieved would materially and substantially dismpt the work and discipline of the PDT, and would

infringe the rights of the PDT members about whom the rumors pertained.

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Lakeridge High School, Beck, Schiele, Lamont, Nordlurn, and

Ashely, from failing to adequately protect S.A., and other similarly

situated students, from hazing, retaliation, child abuse, bullying, and

cyber bullying; [and?

***

Prevent Nordlurn and Ashley from serving as a volunteer, coach,

teacher, or agent at any school in the District.

The equitable remedies sought in plaintiffs' operative complaint constitute relief to which plaintiffs'are not entitled. "An injunction is an extraordinary remedy, to be granted only on clear andconvincing proof of irreparable harm when there is no adequate remedy at law.? Knight v. Nyara,240 0r App 586, 597, 248 P3d 36 (2011 ) (internal citations omitted). The issuance of an injunction

requires an appreciable threat of continuing harm. Id. (Internal quotations and citations omitted).

Plaintiffs have not plead that they have suffered irreparable harm, nor that there is any threat

of continuing harm posed by Kayla or Ashley Nordlum acting as agents of the District. In fact, theevidence will show that neither Kayla nor Ashley Nordlum have worked for any school Districtsince the 2014-15 school year. For that reason, plaintiffs are not entitled to the equitable remedies

requested in their prayer.

DATED this 6th day of October 2017.

GARRETT HEMANN ROBERTSON P.C.

s/ Luke W Reese

Luke W. Reese

OSB No. 076129

Phone: 503-581-1501

Fax: 503-581-5891

lreese@,ghrlawyers.com

Of Attorneys for Defendants

Kayla Nordlum and Ashley Nordlum

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LETA E. GOR?MAN

OSB No. 984015

Betts, Patterson & Mines, p.s.

111 SW 5th Avenue, Suite 3650

Portland OR 97204

Phone: 503-761-6330

Fax: 503-961-6339

?gorman(a);bmplaw. com

Of Attomeys for Plaintiffs

JEFFREY M. DORE

WSB No. 44951

Betts, Patterson & Mines, p.s.

701 Pike Street, Suite 1400

SeattleWA 98101

Phone: 206-292-9988Fgx: 206-343-7053idore(ai,bpmlaw. com

Of Attorneys for Plaintiffs

KAREN M. VICKERS

OSB No. 913810

Mersereau Shannon LLP

111 SW Columbia Street, Suite 1100

Portland OR 97201-5865

Phone: 503-226-6400Fax: 503-226-0383

kvickers@,mershanlaw. com

Of Attomeys for Defendant

Lake Oswego School District, et al.

CHRISTOPHER B. MARKS

OSB No. 833911

ROBERT D. SCHOLZ

OSBNo. 773379

MacMillan, Scholz & Marks, p.c.Attorneys at Law900 SW Fifth Avenue, Suite 1800Portland OR 97204

Phone.' 503-224-2165

Fax: 503-224-0348

cmarks(a,msmlegal. com

rscholz@,msmlegal. com

Of Attorneys for Suzanne Young

DATED October 6, 2017.

GARRETT HEMANN ROBERTSON p.c.

s/ Luke W Reese

Luke W. Reese

(OSB No. 076129)

Phone: 503-581-1501

Fax: 503-581-5891

lreese(a.ghrlawyers.com

Of Attomeys for Defendants

Kayla Nordlum and Ashley Nordlum

4825-6997-9985, v. 1

CERTIFICATE OF SERVICE:

Achcar-Winkels V. Lake Oswego School District, et al.