Page 1 of 17 – COMPLAINT

JON H. WEINER, Attorney at Law

Of Counsel to Harris Law Firm, P.C.

1595 Commercial Street NE, Salem, OR 97301

Tel. (503)399-7001 Fax (503)399-0745

Jon H. Weiner, OSB #993944

info@nw-attorneys.com

Harris Law Firm, P.C., Of Counsel 

1595 Commercial Street NE

Salem, OR 97301

Tel: (503) 399-7001

Fax: (503) 399-0745

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF OREGON

Portland Division

CHARLOTTE BRAY,

 Plaintiff,

 v.

USAMM, LLC, an Oregon limited liability 

company, BRIAN LARRABEE, an 

individual, SALLY MELCHER, an 

individual, JARED ZABALDO, an 

individual.

 Defendants.

____________________________________

Case No. _____________________

COMPLAINTClaims for Sex Discrimination and related 

Retaliation, 42 U.S.C. § 2000e, et seq.; 42 

U.S.C. § 1981(a); State law claims for Sex 

Discrimination and related Retaliation, 

Sexual Orientation Discrimination and 

related Retaliation, Aiding and Abetting Sex 

Discrimination and related Retaliation, and 

Aiding and Abetting Sexual Orientation 

Discrimination and related Retaliation, 

O.R.S. 659A.004, et seq.; O.R.S. 659A.030, 

et seq.

(Demand for Jury Trial)

Plaintiff alleges:

Case 3:14-cv-02060-PK Document 1 Filed 12/30/14 Page 1 of 17
 

 Page 2 of 17 – COMPLAINT

JON H. WEINER, Attorney at Law

Of Counsel to Harris Law Firm, P.C.

1595 Commercial Street NE, Salem, OR 97301

Tel. (503)399-7001 Fax (503)399-0745

PRELIMINARY STATEMENT

1.

Plaintiff Charlotte Bray (hereinafter referred to as “plaintiff”) asserts claims for sex 

discrimination, and retaliation for opposing sex discrimination, under Title VII of the Civil 

Rights Acts of 1964 and 1991, 42 U.S.C. § 2000e, et seq.; 42 U.S.C. § 1981(a) (hereinafter 

collectively referred to as “Title VII”) and state law (O.R.S. Chapter 659A). Plaintiff also asserts 

claims for sexual orientation discrimination, and retaliation for opposing sexual orientation 

discrimination, under state law (O.R.S. Chapter 659A). Finally, plaintiff asserts claims for 

aiding and abetting sex discrimination and retaliation for opposing sex discrimination, and aiding 

and abetting sexual orientation discrimination and retaliation for opposing sexual orientation 

discrimination, under state law (O.R.S. Chapter 659A). Plaintiff demands a jury trial. The 

allegations set forth below apply to “all times relevant” without regard to whether those 

allegations are set forth in the present or past tense.

JURISDICTION

2.

This Court has jurisdiction over the subject matter of this civil action pursuant to 28 

U.S.C. § 1331, which gives district courts original jurisdiction over civil actions arising under the 

Constitution, laws or treaties of the United States. This Court has supplemental jurisdiction over 

plaintiff’s state law claims pursuant to 28 U.S.C. § 1367. Plaintiff’s state law claims are so 

closely related to her federal law claims that they form part of the same case or controversy 

under Article III of the United States Constitution. 

/ / /

/ / /

Case 3:14-cv-02060-PK Document 1 Filed 12/30/14 Page 2 of 17
 

 Page 3 of 17 – COMPLAINT

JON H. WEINER, Attorney at Law

Of Counsel to Harris Law Firm, P.C.

1595 Commercial Street NE, Salem, OR 97301

Tel. (503)399-7001 Fax (503)399-0745

VENUE

3.

Venue is appropriate in this Court pursuant to 28 U.S.C. § 1391, because a substantial 

part of the events giving rise to this complaint occurred in Clackamas County, Oregon. Plaintiff 

is a resident of Clackamas County, Oregon. Defendant USAMM, LLC is an Oregon limited 

liability company with its headquarters located in Clackamas County, Oregon.

4.

At all times relevant, defendant USAMM, LLC (hereinafter referred to as “USAMM”) 

employed plaintiff at its principal location in Clackamas County, Oregon. At all times relevant, 

USAMM conducted regular, substantial, and sustained business activity in the State of Oregon, 

including, but not limited to, Clackamas County.

FACTUAL ALLEGATIONS

5. 

USAMM employed 15 or more individuals during twenty or more weeks in 2013 and 

2014. Plaintiff has exhausted her administrative remedies under federal and state law. Plaintiff 

timely filed discrimination charges with the Equal Employment Opportunity Commission 

(EEOC) and the Oregon Bureau of Labor and Industries (BOLI). Plaintiff received a right-to-sue 

letter from each entity, and timely filed suit within the respective 90-day limitations periods. 

6.

Defendant Jarred Zabaldo (hereinafter referred to as “Zabaldo”) is founder and owner of 

USAMM. Defendant Brian Larrabee (hereinafter referred to as “Larrabee”) is Operations 

Manager for USAMM. In this capacity, Larrabee manages the Shipping Department, amongst

other departments. Defendant Sally Melcher (hereinafter referred to as “Melcher”) is a manager

Case 3:14-cv-02060-PK Document 1 Filed 12/30/14 Page 3 of 17
 

 Page 4 of 17 – COMPLAINT

JON H. WEINER, Attorney at Law

Of Counsel to Harris Law Firm, P.C.

1595 Commercial Street NE, Salem, OR 97301

Tel. (503)399-7001 Fax (503)399-0745

for USAMM, and also manages the Shipping Department. Plaintiff was employed to work in the

Shipping Department.

7.

Plaintiff was hired to work for USAMM on or around April, 2013. She was hired to 

work as a “packer” within the Shipping Department. There were approximately 10 - 15 other 

packers with whom plaintiff worked. 

8.

Plaintiff is a female. She openly identifies as bisexual. Plaintiff’s sexual orientation was 

common knowledge within the workplace. Plaintiff brought her girlfriend to the 2013 USAMM 

Christmas party, and introduced her as such to others at the party. Also, plaintiff’s sexual 

orientation and relationship status were known through casual workplace conversation. In 

addition to plaintiff, there were two other openly gay or bisexual females working as packers in

the Shipping Department. At the time of plaintiff’s employment, all the packers were female.

9.

On numerous occasions, Larrabee made sexually suggestive comments regarding females 

in the presence of plaintiff and others. In addition, Larrabee and Melcher treated the gay and 

bisexual employees differently from the straight employees. For example, on numerous 

occasions Melcher and/or Larrabee would delay plaintiff and Raelynn Turner from going on 

break or lunch, permitting straight employees to go before them, even though plaintiff and Ms. 

Turner had made their requests first. Ms. Turner was openly gay. On another occasion, during 

which many employees were speaking amongst themselves in hushed tones in the work area, 

Larrabee singled out plaintiff and Ms. Turner. He told them to “shut up” in the presence of the

entire Shipping Department.

Case 3:14-cv-02060-PK Document 1 Filed 12/30/14 Page 4 of 17
 

 Page 5 of 17 – COMPLAINT

JON H. WEINER, Attorney at Law

Of Counsel to Harris Law Firm, P.C.

1595 Commercial Street NE, Salem, OR 97301

Tel. (503)399-7001 Fax (503)399-0745

10.

Pursuant to her job duties, plaintiff was required to properly pack military medals on

foam boards to ensure they were shipped without becoming damaged. On or around February,

2014, Larrabee held a meeting with the packers in order to discuss shipments which had been 

improperly packed. Larrabee instructed the packers to check with him before shipping any 

medals so he could confirm that the medals were placed straight, and not crookedly, upon the 

foam boards prior to shipping.

11.

On or around March, 2014, Larrabee again met with the packers regarding proper

placement of the medals. Larrabee became agitated during the meeting. He stated, “Straight is 

relative. Even to you Charlotte”, and looked directly at plaintiff. A number of the other packers 

were noticeably shocked by Larrabee’s statement. After a tense moment, several employees 

attempted to laugh off the comments. Plaintiff was embarrassed and humiliated by Larrabee’s 

comments, which were made in the presence of all the other packers. Melcher was also present.

12.

Mac Marshall, USAMM’s Human Resources employee, was on vacation at this time.

13.

Zabaldo purportedly had an “open door policy”, and encouraged employees to come to 

him with workplace problems. However, other USAMM managers, including Larrabee, 

discouraged employees from doing so. Larrabee instructed plaintiff and others not to bring their 

problems to Zabaldo, and said they should “solve them within the warehouse.”

/ /

/ /

Case 3:14-cv-02060-PK Document 1 Filed 12/30/14 Page 5 of 17
 

 Page 6 of 17 – COMPLAINT

JON H. WEINER, Attorney at Law

Of Counsel to Harris Law Firm, P.C.

1595 Commercial Street NE, Salem, OR 97301

Tel. (503)399-7001 Fax (503)399-0745

14.

Around this time, plaintiff wrote an anonymous letter to Zabaldo regarding problems she 

had noticed and/or encountered while working for USAMM. These problems included sexual 

harassment. It was clear from the content of the letter that it came from one of the packers.

15.

On or around Monday, March 24, 2014, plaintiff deposited the letter in a box which was 

kept in USAMM’s call center office. Among other things this letter expressed opposition to a 

hostile work environment, and concerns regarding related retaliation, based on gender and sexual 

orientation. The box was ordinarily used to deposit recommendations for employee of the 

month. Approximately ten people work in this office and at least two had desks directly facing 

the box. “Zach” is one of the employees whose desk faced the box.

16.

It is plaintiff’s understanding that co-worker, and fellow packer, Stephanie Halstead also

deposited a slip of paper into the box around this time. Ms. Halstead is a bisexual female.

17.

That same day, USAMM managers gathered for a meeting. Following this meeting, 

USAMM managers began monitoring the packers more closely than usual. Plaintiff saw 

Melcher and her assistant whispering to one another. Plaintiff overheard Melcher tell her 

assistant to “keep her ears open.” In addition, Larrabee and other managers monitored the 

packers and watched them as they worked. They whispered amongst themselves as they did so. 

This was unusual behavior. There was noticeable tension in the environment.

18.

The following day, Larrabee, Melcher and others continued to engage in similar conduct. 

Case 3:14-cv-02060-PK Document 1 Filed 12/30/14 Page 6 of 17
 

 Page 7 of 17 – COMPLAINT

JON H. WEINER, Attorney at Law

Of Counsel to Harris Law Firm, P.C.

1595 Commercial Street NE, Salem, OR 97301

Tel. (503)399-7001 Fax (503)399-0745

They closely monitored the packers and whispered amongst themselves.

19.

On or around March 26, 2014, management held three additional meetings amongst 

themselves. Following the third manager’s meeting, Larrabee called plaintiff and Ms. Halstead 

into a private meeting. “Zach” was also present. Larrabee claimed that Ms. Halstead and 

plaintiff were aggressive and had issues with management. Plaintiff asked if they were going to 

get a warning. Larrabee responded that they had been given plenty of warnings and that their 

termination was their warning. Ms. Halstead and plaintiff asked about their most recent 

evaluations, which had been favorable. Larrabee responded that “things had obviously changed 

since then.” He refused to discuss the matter further. Ultimately, plaintiff and Ms. Halstead 

were terminated at the conclusion of this meeting.

20.

Plaintiff had not received prior warning or discipline regarding the behaviors for which 

she was allegedly terminated.

21.

Plaintiff was later informed by former co-workers that, on the day she was terminated, 

Larrabee held a meeting with the packers in which he claimed that plaintiff and Ms. Halstead

were “being aggressive” and “causing problems.” Following the meeting, Zabaldo held a 

separate meeting with the packers, during which he asked if there was anything which needed to 

be brought to his attention “off the record.” Plaintiff believes that Zabaldo was referring to the 

issues she raised in her letter.

/ /

/ /

Case 3:14-cv-02060-PK Document 1 Filed 12/30/14 Page 7 of 17
 

 Page 8 of 17 – COMPLAINT

JON H. WEINER, Attorney at Law

Of Counsel to Harris Law Firm, P.C.

1595 Commercial Street NE, Salem, OR 97301

Tel. (503)399-7001 Fax (503)399-0745

FIRST CLAIM –TITLE VII DISCRIMINATION, 42 U.S.C. § 2000e-2.

(Count 1 - Sex Discrimination against Defendant USAMM)

22.

Plaintiff incorporates and re-alleges paragraphs 1 through 21 by this reference. Pursuant 

to 42 U.S.C. § 2000e-2(a), “it shall be an unlawful employment practice for an employer” to 

discharge an individual, “or otherwise to discriminate against any individual with respect to his 

compensation, terms, conditions, or privileges of employment because of such individuals race, 

color, religion, sex, or national origin . . .”

23.

Defendant USAMM violated this statute when it subjected plaintiff to disparate treatment 

based on her sex and thereby adversely affected the compensation, terms, conditions and/or 

privileges of plaintiff’s employment.

24.

Plaintiff has suffered non-economic and economic damages in an amount to be 

determined at the time of trial. Plaintiff seeks equitable relief and recovery of all compensatory 

and punitive damages provided by law, in addition to reasonable attorney fees and costs pursuant 

to 42 U.S.C. §§ 1988 and 2000e-5(k).

(Count 2 – Retaliation for Opposing Sex Discrimination against Defendant USAMM)

25.

Plaintiff incorporates and re-alleges paragraphs 1 through 24 by this reference. Pursuant 

to 42 U.S.C. § 2000e-3(a), “it shall be an unlawful employment practice for an employer to 

discriminate against any [of the employer’s] employees... because [the employee] has opposed 

any practice made an unlawful employment practice by [Title VII], or . . . has made a charge, 

Case 3:14-cv-02060-PK Document 1 Filed 12/30/14 Page 8 of 17
 

 Page 9 of 17 – COMPLAINT

JON H. WEINER, Attorney at Law

Of Counsel to Harris Law Firm, P.C.

1595 Commercial Street NE, Salem, OR 97301

Tel. (503)399-7001 Fax (503)399-0745

testified, assisted, or participated in any manner in an investigation, proceeding, or hearing under 

[Title VII].”

26.

Defendant USAMM violated this statute when it subjected plaintiff to disparate treatment 

in retaliation for her opposition to defendant USAMM’s sex discrimination, and thereby 

adversely affected the compensation, terms, conditions and/or privileges of plaintiff’s 

employment.

27.

Plaintiff has suffered non-economic and economic damages in an amount to be 

determined at the time of trial. Plaintiff seeks equitable relief and recovery of all compensatory 

and punitive damages provided by law, in addition to reasonable attorney fees and costs pursuant 

to 42 U.S.C. §§ 1988 and 2000e-5(k).

SECOND CLAIM – STATE SEX DISCRIMINATION 

(Count 1 – Sex Discrimination against Defendant USAMM)

28.

Plaintiff incorporates and re-alleges paragraphs 1 through 27 by this reference. 

According to O.R.S. 659A.030(1)(a) and (b), it is an unlawful employment practice, “for an 

employer, because of an individual’s race, religion, color, sex, national origin, marital status or 

age if the individual is 18 years of age or older, . . . to refuse to hire or employ or to bar or 

discharge from employment such individual [or] . . . to discriminate against such an individual in 

compensation or in terms, conditions, or privileges of employment.” 

29.

Defendant USAMM willfully violated this statute it subjected plaintiff to disparate 

Case 3:14-cv-02060-PK Document 1 Filed 12/30/14 Page 9 of 17
 

 Page 10 of 17 – COMPLAINT

JON H. WEINER, Attorney at Law

Of Counsel to Harris Law Firm, P.C.

1595 Commercial Street NE, Salem, OR 97301

Tel. (503)399-7001 Fax (503)399-0745

treatment based on her sex and thereby adversely affected the compensation, terms, conditions, 

and/or privileges of plaintiff’s employment. 

30.

As a result of defendant USAMM’s sex discrimination, plaintiff requests equitable relief 

and economic damages, including back pay, benefits, and front pay, in an amount to be 

determined at trial, along with compensatory and punitive damages in an amount to be 

determined at trial. 

31.

Pursuant to O.R.S. 659A.885, plaintiff is entitled to her reasonable attorney fees and costs

in this action.

(Count 2 – Retaliation for Opposing Sex Discrimination against Defendant USAMM)

32.

Plaintiff incorporates and re-alleges paragraphs 1 through 31 by this reference. 

According to O.R.S. 659A.030(1)(f) it is an unlawful employment practice for an employer to 

“discharge, expel or otherwise discriminate” against any person who has opposed any unlawful 

employment practice, or has “filed a complaint, testified or assisted in any proceeding” under 

ORS chapter 659A or “has attempted to do so.”

33.

Defendant USAMM violated this statute when it subjected plaintiff to disparate treatment 

in retaliation for her opposition to defendant USAMM’s sex discrimination, and thereby 

adversely affected the compensation, terms, conditions and/or privileges of plaintiff’s 

employment.

/ /

Case 3:14-cv-02060-PK Document 1 Filed 12/30/14 Page 10 of 17
 

 Page 11 of 17 – COMPLAINT

JON H. WEINER, Attorney at Law

Of Counsel to Harris Law Firm, P.C.

1595 Commercial Street NE, Salem, OR 97301

Tel. (503)399-7001 Fax (503)399-0745

34.

As a result of defendant USAMM’s retaliation, plaintiff requests equitable relief and 

economic damages, including back pay, benefits, and front pay, in an amount to be determined at

trial, along with compensatory and punitive damages in an amount to be determined at trial. 

35.

Pursuant to O.R.S. 659A.885, plaintiff is entitled to her reasonable attorney fees and costs

in this action.

(Count 3 – Aiding and Abetting Sex Discrimination against Defendants Larrabee, Melcher 

and Zabaldo)

36.

Plaintiff incorporates and re-alleges paragraphs 1 through 35 by this reference. 

According to O.R.S. 659A.030(1)(g) it is an unlawful employment practice for “any person, 

whether an employer or an employee, to aid, abet, incite, compel or coerce the doing of any of 

the acts forbidden under [O.R.S. 659A] or to attempt to do so.”

37.

Defendants Larrabee, Melcher and Zabaldo violated this statute when they aided and/or 

abetted USAMM in its sex discrimination, and retaliation for opposing sex discrimination, and 

thereby adversely affected the compensation, terms, conditions and/or privileges of plaintiff’s 

employment.

38.

As a result of defendants’ aiding and abetting activities, plaintiff requests equitable relief 

and economic damages, including back pay, benefits, and front pay, in an amount to be 

determined at trial, along with compensatory and punitive damages in an amount to be 

determined at trial. 

Case 3:14-cv-02060-PK Document 1 Filed 12/30/14 Page 11 of 17
 

 Page 12 of 17 – COMPLAINT

JON H. WEINER, Attorney at Law

Of Counsel to Harris Law Firm, P.C.

1595 Commercial Street NE, Salem, OR 97301

Tel. (503)399-7001 Fax (503)399-0745

39.

Pursuant to O.R.S. 659A.885, plaintiff is entitled to her reasonable attorney fees and costs

in this action.

THIRD CLAIM – STATE SEXUAL ORIENTATION DISCRIMINATION 

(Count 1 – Sexual Orientation Discrimination against Defendant USAMM)

40.

Plaintiff incorporates and re-alleges paragraphs 1 through 39 by this reference. 

According to O.R.S. 659A.030(1)(a) and (b), it is an unlawful employment practice, “for an 

employer, because of an individual’s race, religion, color, sex, national origin, marital status or 

age if the individual is 18 years of age or older, . . . to refuse to hire or employ or to bar or 

discharge from employment such individual [or] . . . to discriminate against such an individual in 

compensation or in terms, conditions, or privileges of employment.” 

41.

Defendant USAMM willfully violated this statute when it subjected plaintiff to disparate 

treatment based on her sexual orientation and thereby adversely affected the compensation, 

terms, conditions, and/or privileges of plaintiff’s employment. 

42.

As a result of defendant USAMM’s sexual orientation discrimination, plaintiff requests 

equitable relief and economic damages, including back pay, benefits, and front pay, in an amount 

to be determined at trial, along with compensatory and punitive damages in an amount to be 

determined at trial. 

/ / /

/ / /

Case 3:14-cv-02060-PK Document 1 Filed 12/30/14 Page 12 of 17
 

 Page 13 of 17 – COMPLAINT

JON H. WEINER, Attorney at Law

Of Counsel to Harris Law Firm, P.C.

1595 Commercial Street NE, Salem, OR 97301

Tel. (503)399-7001 Fax (503)399-0745

43.

Pursuant to O.R.S. 659A.885, plaintiff is entitled to her reasonable attorney fees and costs

in this action.

(Count 2 – Retaliation for Opposing Sexual Orientation Discrimination against Defendant 

USAMM)

44.

Plaintiff incorporates and re-alleges paragraphs 1 through 43 by this reference. 

According to O.R.S. 659A.030(1)(f) it is an unlawful employment practice for an employer to 

“discharge, expel or otherwise discriminate” against any person who has opposed any unlawful 

employment practice, or has “filed a complaint, testified or assisted in any proceeding” under 

ORS chapter 659A or “has attempted to do so.”

45.

Defendant USAMM violated this statute when it subjected plaintiff to disparate treatment 

in retaliation for her opposition to defendant USAMM’s sexual orientation discrimination, and 

thereby adversely affected the compensation, terms, conditions and/or privileges of plaintiff’s 

employment.

46.

As a result of defendant USAMM’s retaliation, plaintiff requests equitable relief and 

economic damages, including back pay, benefits, and front pay, in an amount to be determined at

trial, along with compensatory and punitive damages in an amount to be determined at trial. 

47.

Pursuant to O.R.S. 659A.885, plaintiff is entitled to her reasonable attorney fees and costs

in this action.

/ / /

Case 3:14-cv-02060-PK Document 1 Filed 12/30/14 Page 13 of 17
 

 Page 14 of 17 – COMPLAINT

JON H. WEINER, Attorney at Law

Of Counsel to Harris Law Firm, P.C.

1595 Commercial Street NE, Salem, OR 97301

Tel. (503)399-7001 Fax (503)399-0745

(Count 3 – Aiding and Abetting Sexual Orientation Discrimination against Defendants 

Larrabee, Melcher and Zabaldo)

48.

Plaintiff incorporates and re-alleges paragraphs 1 through 47 by this reference. 

According to O.R.S. 659A.030(1)(g) it is an unlawful employment practice for “any person, 

whether an employer or an employee, to aid, abet, incite, compel or coerce the doing of any of 

the acts forbidden under [O.R.S. 659A] or to attempt to do so.”

49.

Defendants Larrabee, Melcher and Zabaldo violated this statute when they aided and/or 

abetted USAMM in its sexual orientation discrimination, and retaliation for opposing sexual 

orientation discrimination, and thereby adversely affected the compensation, terms, conditions

and/or privileges of plaintiff’s employment.

50.

As a result of defendants’ aiding and abetting activities, plaintiff requests equitable relief 

and economic damages, including back pay, benefits, and front pay, in an amount to be 

determined at trial, along with compensatory and punitive damages in an amount to be 

determined at trial. 

51.

Pursuant to O.R.S. 659A.885, plaintiff is entitled to her reasonable attorney fees and costs

in this action.

WHEREFORE, Plaintiff requests the following for her claims for relief:

1. For Plaintiff’s First Claim For Relief:

A. Count One – against Defendant USAMM – Non-economic and economic 

damages in an amount to be determined at the time of trial. Plaintiff seeks 

Case 3:14-cv-02060-PK Document 1 Filed 12/30/14 Page 14 of 17
 

 Page 15 of 17 – COMPLAINT

JON H. WEINER, Attorney at Law

Of Counsel to Harris Law Firm, P.C.

1595 Commercial Street NE, Salem, OR 97301

Tel. (503)399-7001 Fax (503)399-0745

recovery of all compensatory and punitive damages provided by law, in addition 

to reasonable attorney fees and costs pursuant to 42 U.S.C. §§ 1988 and 2000e5(k).

B. Count Two – against Defendant USAMM – Non-economic and economic damages 

in an amount to be determined at the time of trial. Plaintiff seeks recovery of all 

compensatory and punitive damages provided by law, in addition to reasonable 

attorney fees and costs pursuant to 42 U.S.C. §§ 1988 and 2000e-5(k).

2. For Plaintiff’s Second Claim For Relief:

A. Count One – against Defendant USAMM – Equitable relief and economic 

damages, including back pay, lost benefits and front pay, in an amount to be 

determined at trial with interest, along with compensatory and punitive damages,

in an amount to be determined at trial, along with her reasonable costs and 

attorney fees incurred in this matter pursuant to O.R.S. 659A.885.

B. Count Two – against Defendant USAMM – Equitable relief and economic 

damages, including back pay, lost benefits and front pay, in an amount to be 

determined at trial with interest, along with compensatory and punitive damages, 

in an amount to be determined at trial, along with her reasonable costs and 

attorney fees incurred in this matter pursuant to O.R.S. 659A.885.

C. Count Three – against Defendants Larrabee, Melcher and Zabaldo – Equitable 

relief and economic damages, including back pay, lost benefits and front pay, in 

an amount to be determined at trial with interest, along with compensatory and 

punitive damages, in an amount to be determined at trial, along with her 

Case 3:14-cv-02060-PK Document 1 Filed 12/30/14 Page 15 of 17
 

 Page 16 of 17 – COMPLAINT

JON H. WEINER, Attorney at Law

Of Counsel to Harris Law Firm, P.C.

1595 Commercial Street NE, Salem, OR 97301

Tel. (503)399-7001 Fax (503)399-0745

reasonable costs and attorney fees incurred in this matter pursuant to O.R.S.

659A.885.

3. For Plaintiff’s Third Claim For Relief:

A. Count One – against Defendant USAMM – Equitable relief and economic 

damages, including back pay, lost benefits and front pay, in an amount to be 

determined at trial with interest, along with compensatory and punitive damages, 

in an amount to be determined at trial, along with her reasonable costs and 

attorney fees incurred in this matter pursuant to O.R.S. 659A.885.

B. Count Two – against Defendant USAMM – Equitable relief and economic 

damages, including back pay, lost benefits and front pay, in an amount to be 

determined at trial with interest, along with compensatory and punitive damages, 

in an amount to be determined at trial, along with her reasonable costs and 

attorney fees incurred in this matter pursuant to O.R.S. 659A.885.

/ / /

/ / /

/ / /

/ / /

/ / /

/ / /

/ / /

/ / /

/ / /

/ / /

Case 3:14-cv-02060-PK Document 1 Filed 12/30/14 Page 16 of 17
 

 Page 17 of 17 – COMPLAINT

JON H. WEINER, Attorney at Law

Of Counsel to Harris Law Firm, P.C.

1595 Commercial Street NE, Salem, OR 97301

Tel. (503)399-7001 Fax (503)399-0745

C. Count Three – against Defendants Larrabee, Melcher and Zabaldo – Equitable 

relief and economic damages, including back pay, lost benefits and front pay, in 

an amount to be determined at trial with interest, along with compensatory and 

punitive damages, in an amount to be determined at trial, along with her 

reasonable costs and attorney fees incurred in this matter pursuant to O.R.S.

659A.885.

DATED this 30th day of December, 2014.

/s/ Jon Weiner

Jon Weiner, OSB #993944

info@nw-attorneys.com

Harris Law Firm, P.C., Of Counsel

1595 Commercial Street NE

Salem, OR 97301

Tel: (503) 399-7001

Fax: (503) 399-0745

Of Attorneys for Plaintiff

Case 3:14-cv-02060-PK Document 1 Filed 12/30/14 Page 17 of 17