Page 1 - Plaintiff's Lay Witness List 

4833-3248-6236.5 MILLER NASH GRAHAM & DUNN LLP ATTORNEYS AT LAW 

TELEPHONE: 503.224.5858 

3400 U.S. BANCORP TOWER 

111 S.W. FIFTH AVENUE 

PORTLAND, OREGON 97204 

Elisa J. Dozono, OSB No. 063150 

elisa.dozono@millernash.com 

Vanessa L. Triplett, OSB No. 154387 

vanessa.triplett@millernash.com 

MILLER NASH GRAHAM & DUNN LLP 

3400 U.S. Bancorp Tower 

111 S.W. Fifth Avenue 

Portland, Oregon 97204 

Telephone: 503.224.5858 

Facsimile: 503.224.0155 

Attorneys for Plaintiff 

UNITED STATES DISTRICT COURT 

DISTRICT OF OREGON 

CONSTANCE GEORGE, 

Plaintiff, 

v. 

HOUSE OF HOPE RECOVERY; 

BRIDGES TO CHANGE, INC.; 

WASHINGTON COUNTY 

DEPARTMENT OF HOUSING 

SERVICES, and PATRICIA BARCROFT, 

Defendants. 

Case No. 3:15-cv-01277-SB 

PLAINTIFF’S LAY WITNESS LIST 

Case 3:15-cv-01277-SB Document 101 Filed 02/28/18 Page 1 of 7
 

Page 2 - Plaintiff's Lay Witness List 

4833-3248-6236.5 

In accordance with this Court's Civil Trial Management Order (ECF 90) dated 

November 30, 2017, plaintiff, Constance George, identifies the following individuals as 

witnesses that she may call at trial: 

WITNESSES 

1. Name: Constance George 

Address: 16865 N.W. Avondale Drive, 

Beaverton, Oregon 97006 

Occupation: Not currently employed 

Estimated Time: 2-3 hours 

Subject Matter of Testimony: 

Ms. George will testify about how she came to live at House of Hope. Ms. 

George will testify that defendants terminated her tenancy after she made complaints about 

defendants' race-related comment and defendants' policies that required her to attend religious 

meetings, among other issues. Ms. George will testify that she was evicted after requesting to be 

excused from one of defendants' meetings because she, an African-American, felt ill, while a 

similarly situated white resident was both excused from the meeting and not evicted. Ms. 

George will testify about her work history, and the economic and noneconomic damages she 

suffered because of defendants' discriminatory actions. 

2. Name: Sharon Davis 

Address: Unknown 

Occupation: Unknown 

Estimated Time: 1 hour 

Subject Matter of Testimony: 

Ms. Davis will testify that she was Ms. George's roommate at House of Hope. 

Ms. Davis will testify that she was excused from attending the 12-step meeting when she called 

in sick on March 19, the same day that Ms. George was evicted. Ms. Davis will testify that her 

illness was not called into question and that she was not evicted. 

/ / / 

Case 3:15-cv-01277-SB Document 101 Filed 02/28/18 Page 2 of 7
 

Page 3 - Plaintiff's Lay Witness List 

4833-3248-6236.5 

3. Name: Kelsey Richardson 

Address: Unknown 

Occupation: Unknown 

Estimated Time: 1 hour 

Subject Matter of Testimony: 

Ms. Richardson will testify that she was the senior resident at House of Hope 

during Ms. George's tenancy. Ms. Richardson will testify that Ms. George was evicted by 

defendants for not attending a meeting because of illness while a similarly situated white resident 

was both excused and not evicted. Ms. Richardson will testify that she witnessed the interaction 

between defendants and Ms. George when she was told to leave. Ms. Richardson will testify that 

she told Ms. George's fiancé, James Matthews, that she didn't think it was right that Ms. George 

was being evicted. 

4. Name: Nancy Ferry 

Address: Unknown 

Occupation: Unknown 

Estimated Time: 1 hour 

Subject Matter of Testimony: 

Ms. Ferry will testify that she told Ms. George that she would not have to attend 

any religious meetings at House of Hope. Ms. Ferry will testify about conversations she had 

with Ms. George on March 13, 2013, in which Ms. George complained about (1) Ms. Barcroft's 

statements about race; (2) the lack of essential supplies in the house (e.g., toilet paper); (3) the 

requirement to attend defendants' religious meetings; and (4) being confined to the property for 

two weeks and the resulting difficulties in being able to actively seek employment. Ms. Ferry 

will testify about the conversation she had on March 19, 2013, with defendants, Autumn Ray and 

Ms. George regarding her complaints and the agreed-upon resolution of that discussion. 

Ms. Ferry will testify regarding conversations she had with Ms. George after her eviction 

regarding finding alternative housing. 

/ / / 

Case 3:15-cv-01277-SB Document 101 Filed 02/28/18 Page 3 of 7
 

Page 4 - Plaintiff's Lay Witness List 

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5. Name: Patricia Barcroft 

Address: 3056	N.W.	160th	Court	

Beaverton,	Oregon		97006

Occupation: House of Hope Director 

Estimated Time: 2 hour 

Subject Matter of Testimony: 

Ms. Barcroft will testify that she is the director of House of Hope Recovery in 

2013. Ms. Barcroft will testify that Ms. Ferry set up an interview for Ms. George with Ms. 

Barcroft on March 5, 2013; Ms. Barcroft will testify about that interview. Ms. Barcroft will 

testify that Ms. George moved into House of Hope on March 10, 2013. Ms. Barcroft will testify 

about Ms. George's compliance with House of Hope policies. Ms. Barcroft will testify about the 

conversation with Ms. Ferry, Ms. George, and Ms. Ray during the March 19, 2013, meeting 

about Ms. George's complaints and the agreed upon resolution of that meeting. Ms. Barcroft will 

testify that Ms. George asked to be excused from the 12-step meeting on March 19, 2013, 

because Ms. George was feeling ill and that she was not excused. Ms. Barcroft will testify that 

she confronted Ms. George on March 19, 2013 and notified Ms. George that she was to be 

evicted from her residence. 

6. Name: Autumn Ray 

Address: 3056	N.W.	160th	Court	

Beaverton,	Oregon		97006

Occupation: Employee at House of Hope 

Estimated Time: 1 hour 

Subject Matter of Testimony: 

Ms. Ray will testify that she was an employee of defendants during Ms. George's 

tenancy with defendants. Ms. Ray will testify that she was sick during much of the time of Ms. 

George's tenancy. Ms. Ray will testify about providing Ms. George with a copy of House of 

Hope's policies and her instructions to Ms. George. Ms. Ray will testify about Ms. George's 

compliance with House of Hope policies. Ms. Ray will testify that she was present at the March 

19, 2013, morning meeting with defendants, Ms. Ferry, and Ms. George, and about the 

complaints Ms. George had raised to Ms. Ferry before that meeting and the agreed upon 

Case 3:15-cv-01277-SB Document 101 Filed 02/28/18 Page 4 of 7
 

Page 5 - Plaintiff's Lay Witness List 

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resolution of that discussion. She will testify that Ms. George called her in the afternoon of 

March 19, 2013, asking to be excused from the 12-step meeting because she was feeling ill and 

that Ms. George was not excused. Ms. Ray will testify that she received a similar call from Ms. 

Davis and that Ms. Davis was excused. 

7. Name: James Matthews 

Address: 2131 Quince Street, Apt. 1 

Forest Grove, Oregon, 97116 

Occupation: Unknown 

Estimated Time: 1 hour 

Subject Matter of Testimony: 

Mr. Matthews will testify that he is Ms. George's former fiancé, that he was 

engaged to her during her tenancy with defendants, and that he lived with her after her tenancy 

with defendants. Mr. Matthews will testify about Ms. George's mental state before her tenancy 

with defendants. Mr. Matthews will testify that he picked up Ms. George on the day she was 

evicted by defendants. Mr. Matthews will testify about Ms. George's mental state after being 

evicted by defendants, and state that it was one of the reasons for their breakup. Mr. Matthews 

will testify to Ms. George's attempts to find employment before and after her eviction. 

8. Name: DeShawn George 

Address: 16865 N.W. Avondale Drive, 

Beaverton, Oregon 97006 

Occupation: Unknown 

Estimated Time: 1 hour 

Subject Matter of Testimony: 

Mr. George will testify that he is Ms. George's son and that she lived with him 

before and after her tenancy with defendants. Mr. George will testify about Ms. George's mental 

state before her tenancy with defendants compared to her mental state after being evicted by 

defendants. Mr. George will testify to Ms. George's attempts to find employment before and 

after her eviction, and about her economic and noneconomic damages. 

/ / / 

Case 3:15-cv-01277-SB Document 101 Filed 02/28/18 Page 5 of 7
 

Page 6 - Plaintiff's Lay Witness List 

4833-3248-6236.5 

9. Name: Sally Wentz 

Address: Unknown 

Occupation: Unknown 

Estimated Time: 1 hour 

Subject Matter of Testimony: 

Ms. Wentz will testify about Ms. George's therapy sessions after she was evicted 

by defendants. Ms. Wentz will testify about the Sequoia Medical Health Records. 

Ms. George reserves the right to call other witnesses if relevant to testimony or 

evidence offered by defendants during their case. 

DATED: February 28, 2018. MILLER NASH GRAHAM & DUNN LLP 

s/ Elisa J. Dozono 

Elisa J. Dozono, OSB No. 063150 

elisa.dozono@millernash.com 

Vanessa L. Triplett, OSB No. 154387 

vanessa.triplett@millernash.com 

Telephone: 503.224.5858 

Facsimile: 503.224.0155 

Attorneys for Plaintiff 

Case 3:15-cv-01277-SB Document 101 Filed 02/28/18 Page 6 of 7
 

Page 1 - Certificate of Service 

4833-3248-6236.5 

CERTIFICATE OF SERVICE 

I hereby certify that I served the foregoing plaintiff's lay witness list on: 

Ms. Rebecca Cambreleng 

Cambreleng Law, LLC 

806 S.W. Broadway, Suite 1200 

Portland, Oregon 97205 

Attorney for Defendants House of Hope Recovery 

and Patricia Barcroft 

by the following indicated method or methods on the date set forth below: 

 CM/ECF system transmission. 

 E-mail. (Courtesy copy.) 

 E-mail. As required by Local Rule 5-11, any interrogatories, requests for 

production, or requests for admission were e-mailed in Word or WordPerfect 

format, not in PDF, unless otherwise agreed to by the parties. 

 First-class mail, postage prepaid.

 Hand-delivery.

 Overnight courier, delivery prepaid.

DATED: February 28, 2018. 

 

s/ Elisa J. Dozono 

Elisa J. Dozono, OSB No. 063150 

Of Attorneys for Plaintiff 

Case 3:15-cv-01277-SB Document 101 Filed 02/28/18 Page 7 of 7