Page 1 – JOINT STATUS REPORT

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 

Pursuant to the Court’s Order dated March 19, 2015, the parties, plaintiff City of Portland 

and defendants Uber Technologies, Inc. and Rasier, LLC (“Uber”), submit this Joint Status 

Report. 

JOINT STATUS REPORT 

1. By Order dated March 19, 2015, the parties were directed to file a Joint Status 

Report by May 8, 2015. 

Case 3:14-cv-01958-SI Document 34 Filed 05/07/15 Page 1 of 3
Page 2 – JOINT STATUS REPORT

PORTLAND CITY ATTORNEY’S OFFICE 

1221 SW 4TH AVENUE, RM 430 

PORTLAND, OREGON 97204 

(503) 823-4047

BACKGROUND 

2. To briefly recap, 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 assembled the Private For-Hire 

Transportation Innovation Task Force that met 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. 

7. The Task Force had numerous meetings, including 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. Thereafter, on April 21, 2015, the City Council adopted a Resolution authorizing 

the Director of the Bureau of Transportation to adopt interim rules for a 120-day period 

regarding transportation network companies. 

Case 3:14-cv-01958-SI Document 34 Filed 05/07/15 Page 2 of 3
Page 3 – JOINT STATUS REPORT

PORTLAND CITY ATTORNEY’S OFFICE 

1221 SW 4TH AVENUE, RM 430 

PORTLAND, OREGON 97204 

(503) 823-4047

10. The interim rules were adopted on April 23, 2015. 

11. The 120-day pilot program expires on August 21, 2015. 

12. Following the 120-day pilot program, the City Council will examine the results 

and consider, among other things, Code changes directly impacting this case that may resolve all 

the legal issues between the parties. 

13. Accordingly, for the next 120 days or through and including August 21, 2015, the 

interim rules shall be in effect. Thereafter, City Council will consider whether to make 

permanent changes to City Code. 

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

presented, it is anticipated that such action would be accomplished within 30 days of the 

completion of the 120-day period or September 18, 2015. 

15. A motion is filed contemporaneously to extend deadlines and to submit a Joint 

Status Report. 

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: May 7, 2015 1300 SW 5th Avenue 

Portland, OR 97201-5630 

Telephone: 503-241-2300 

Of Attorneys for Defendants 

Dated: May 7, 2015 

Case 3:14-cv-01958-SI Document 34 Filed 05/07/15 Page 3 of 3