7/13/2015 2:14:10 PM

I5CV1 81 81

1

2

3

4 IN TILE CIRCUIT COURT FOR THE STATE OF OREGON

5 FOR THE COUNTY OF MULTNOMAII

6 BENNY CLAVERO, an individual, Case No.

Plaintiff, COMPLAINT (Wage Claim)

8

v. Claims Between $10,000 and $49,999

UNDERWRITERS LABORATORIES, Subject to Mandatory Arbitration

10 INC., a foreign nonprofit corporation, UL

VERIFICATION SERVICES, INC., a JURY TRIAL DEMANDED

11 foreign coiporation, UL RESPONSIBLE

SOURCING, a foreign corporation, and UL

12 LLC., a foreign limited liability company,

13 Defendants.

14

Comes now the Plaintiff, Benny Clavero, by and through the attorneys at Schuck Law,

15

LLC, and states and alleges as follows:

16

1.

17

At all times material herein, Defendant Underwriters Laboratories Inc. is a foreign

18

nonprofit corporation.

19

2.

20

At all times material herein, Defendant UL Verification Services, Inc. is a foreign

21

corporation.

22

3.

23

At all times material herein, Defendant UL Responsible Sourcing is a foreign

24

corporation.

25

26

Page 1 -Complaint

SCHUCK LAW, LLC

10013 NE Hazel Dell Avenue #178 Vancouver, WA 98685

Tel (360) 566-9243 Fax (503) 575-2763

Attachment A

Case 3:15-cv-01541-MO Document 1-1 Filed 08/14/15 Page 1 of 15
1 4.

2 At all times material herein, Defendant Ut LLC. is a foreign limited liability

3 company.

4 5.

5 Defendant Underwriters Laboratories Inc., Defendant UL Verification Services, Inc.,

6 Defendant Ut Responsible Sourcing and Defendant Ut LLC. will be referred, herein, as

7 “Defendants.”

8 6.

9 At all times material herein, Plaintiff was employed by Defendants in the State of

10 Oregon.

11 7.

12 At all times material herein, Defendants were doing business in Multnomah County in

13 Oregon.

14 8.

15 The Circuit Court ofOregon has personal jurisdiction over Defendants because they

16 are engaged in substantial and not isolated activities within this state, because the events set

17 forth in this complaint occurred in Oregon and because the claims arise out ofservices

18 actually performed by Plaintifffor the Defendants within Oregon.

19 9.

20 Plaintiffbegan working for Defendants on or about August 2014.

21 10.

22 Defendants employed Plaintiff as an at-will employee.

23 11.

24 Defendants did not contract with Plaintiffto work for any specific period oftime.

25 III

26 I/I

Page 2 -Complaint

SCHUCK LAW, LLC

10013 NE Hazel Dell Avenue #178 Vancouver, WA 98685

Tel (360) 566-9243 • Fax (503) 575-2763

Attachment A

Case 3:15-cv-01541-MO Document 1-1 Filed 08/14/15 Page 2 of 15
1 12.

2 As part ofPlamtiff’s employment, Plaintiff was not subject to a collective bargaining

3 agreement and/or part of a union.

4 13.

5 Defendants hired Plaintiff as a non-exempt, salaried employee.

6 14.

7 Defendants agreed to pay Plaintiff an annual salary of $41,000.00, or $19.75 per hour.

8 15.

9 Defendants also agreed to pay Plaintiff 1 ‘/2 times his regular rate for all hours he

10 works over 40 in a workweek.

11 CLAIM FOR RELIEF

12 (FLSA Overtime, Liquidated Damages)

13 16.

14 Plaintiffre-alleges all paragraphs herein as though fully alleged herein.

15 17.

16 Defendants are subject to the requirements ofthe Fair Labor Standards Act of 1938,

17 29 U.S.C. § 201-219 (“FLSA”).

18 18.

19 Defendants are engaged in trade, commerce, transportation, transmission, and/or

20 communication among and between the States.

21 19.

22 Defendants employ at least two people.

23 20.

24 Defendants have annual dollar volume ofsales or business performed of at least

25 $500,000.

26 /1/

Page 3 -Complaint

SCHUCK LAW, LLC

10013 NE Hazel Dell Avenue #178 . Vancouver, WA 98685

Tel (360) 566-9243 Fax (503) 575-2763

Attachment A

Case 3:15-cv-01541-MO Document 1-1 Filed 08/14/15 Page 3 of 15
1 21.

2 Plaintiffis individually covered by the FLSA.

3 22.

4 Plaintiff’s work while employed with Defendants regularly involves him in interstate

5 commerce.

6 23.

7 Plaintiffregularly travels to locations in other states as part of his job with Defendants.

8 24.

9 Defendants hired Plaintiff as a non-exempt, salaried employee.

10 25.

11 Defendants agreed to pay Plaintiff an annual salary of $41,000.00, or $19.75 per hour.

12 26.

13 Defendants also agreed to pay Plaintiff 1 ‘/2 times his regular rate for all hours he

14 worked over 40 in a workweek.

15 27.

16 Defendants agreed to pay Plaintiff for time he spent traveling as part of his job with

17 Defendants.

18 28.

19 The time Plaintiffspent traveling as part of his job is time worked and federal law

20 requires that this travel time be compensated.

21 29.

22 The FLSA requires non-exempt employees be paid at 1 ‘/2 time their regular rate for all

23 hours over 40 in a work week.

24 30.

25 In deteimining the amount of overtime wages, the regular rate is required to include

26 “all remuneration for employment paid to, or on behalf of, the employee.” 29 Usc § 207(e).

Page 4 -Complaint

SCHUCK LAW, LLC

10013 NE Hazel Dell Avenue #178 Vancouver, WA 98685

Tel (360) 566-9243 • Fax (503) 575-2763

Attachment A

Case 3:15-cv-01541-MO Document 1-1 Filed 08/14/15 Page 4 of 15
1 31.

2 During the three year period of employment before filing ofthis case, Defendants

3 allowed, suffered and permitted Plaintiffto perform work in excess of 40 hours per week for

4 the benefit of Defendants.

5 32.

6 Defendants failed to include all travel time when calculating the total number of hours

7 Plaintiffworked.

8 33.

9 When all travel time is included, during some work weeks, Plaintiff worked more

10 overtime than he was paid.

11 34.

12 When all travel time is included, during some work weeks, Plaintiffworked overtime

13 where he was paid no overtime wages.

14 35.

15 Because Defendants failed to include all travel time when calculating the total number

16 of hours Plaintiffworked, Defendants failed to pay Plaintiff 1 ‘/ times his regular hourly rate

17 for all hours Plaintiff worked in excess of 40 hours for a single workweek and there remains

18 due unpaid overtime in an amount to be determined.

19 36.

20 Defendants also failed to include all wages paid for travel time in Plaintiff’s regular

21 rate when calculating overtime.

22 37.

23 Because Defendants failed to include all wages paid for travel time in Plaintiff’s

24 regular rate when calculating overtime, Defendants failed to pay Plaintiff 1 Yz times his

25 regular hourly rate for all hours Plaintiff worked in excess of40 hours for a single workweek

26 and there remains due unpaid overtime in an amount to be determined.

Page 5 -Complaint

SCHUCK LAw, LLC

10013 NE Hazel Dell Avenue #178 Vancouver, WA 98685

Tel (360) 566-9243 • Fax (503) 575-2763

Attachment A

Case 3:15-cv-01541-MO Document 1-1 Filed 08/14/15 Page 5 of 15
1 38.

2 Further, Plaintiffwas paid a non-discretionary bonus during his employment with

3 Defendants.

4 39.

5 Defendants failed to include the non-discretionary bonus in Plaintiffs regular rate

6 when calculating overtime.

7 40.

8 Defendants failed to pay all overtime and premium wages due to Plaintiff as required

9 bytheFLSA.

10 41.

11 Defendants were required to pay Plaintifffor all hours worked and all overtime wages

12 on Plaintiffs next regularly scheduled pay day under the FLSA.

13 42.

14 Defendants’ conduct in failing to pay overtime wages and premium wages as alleged

15 herein was willful, and there remain due and unpaid overtime wages in amounts to be

16 determined.

17 43.

18 Plaintiff seeks damages in the form of overtime wages and overtime premium wages

19 for Defendants’ failure to pay Plaintiffs overtime wages.

20 44.

21 Plaintiffseeks damages in the form ofliquidated damages for Defendants’ failure to

22 pay overtime wages on payday in an amount to be determined and attorney fees and costs

23 under the FLSA, plus pre- and post-judgment interest in the amount of 9% per annum

24 incurred herein under ORS 82.0 10.

25 WHEREFORE, Plaintiff demands judgment from Defendants:

26 Upon Plaintiff’s claim for relief for failing to pay FLSA overtime wages:

Page 6 -Complaint

SCHUCK LAW, LLC

10013 NE Hazel Dell Avenue #178 • Vancouver, WA 98685

Tel (360) 566-9243 Fax (503) 575-2763

Attachment A

Case 3:15-cv-01541-MO Document 1-1 Filed 08/14/15 Page 6 of 15
1 1. Unpaid overtime wages in an amount to be determined.

2 2. Liquidated damages under the FLSA in an amount to be determined.

3 3. Pre- and post-judgment interest on all damage amounts in the amount of 9% per

4 annum incurred herein, pursuant to ORS 82.010.

5 4. Costs, disbursements, and attorney fees under the FLSA. 29 USC 216(b).

6 Upon any counterclaim or defense asserted by Defendants without a objectively

7 reasonable basis, or where Defendant disobeys a court order:

8 1. Plaintiff is entitled to recover attorney fees and costs pursuant to ORS 20.105.

9

10 DATED: July 8, 2015.

11

12 s/ Stephanie J. Brown

STEPHANIE 3. BROWN, OSB 030019, WSB 42030 13 sbrownwageclaim.org

Attorney for Plaintiff 14

15

16

17

18

19

20

21

22

23

24

25

26

Page 7- Complaint

SCLIUCK LAW, LLC

10013 NE Hazel Dell Avenue #178 Vancouver, WA 98685

Tel (360) 566-9243 • Fax (503) 575-2763

Attachment A

Case 3:15-cv-01541-MO Document 1-1 Filed 08/14/15 Page 7 of 15
_Verified Correct Copy of Original 7/24/2015.

Case Number: 15CV18181

Plaintiff:

Benny Clavero,

vs.

Defendant:

Underwriters Laboratories, Inc., et aL,

:2UI5JjJj,3 PU VIT OF SERVICE GIRCZJ1T

AFFIDA

FRHULTHH. Cr

Received by RUSH PROCESS SERVICE, INC. to be served on Underwriters Laboratories, Inc. cia CT

Corporation System, Registered Agent, 388 State St., Suite 420, Salem, OR 97301.

I, Veronica T. Broeth, being duly sworn, depose and say that on the 16th day of July, 2015 at 3:25 pm, I:

Served the within named corporation by delivering a true copy of a Summons; Complaint; First Request for

Production of Documents by personal service upon Rylynn Poole, Service of Process TechnIcian who is

authorized to accept service on behalf of the registered agent

I am a competent person 18 years of age or older and a resident of the state of service or this state and am not

a party to nor an officer, director or employee of, nor attorney for any party, corporate or otherwise; and the

person, firm, or corporation served is the identical one named in the action.

Subscribed and worn to before me n the 17th day

f July, 15.

NOTARY P B C

OFFICIAL SEAL

LEAHOGREINER

NOTARY PLI6LIC OREGON

“Y COMMISSION NO 475677

MY CUMMISSION EXPIRES FEBRUARY 13,2017

a.

Veronica T. Broeth

Process Server

RUSH PROCESS SERVICE, INC.

2014 N.E. Sandy Blvd., Suite 204

Portland, OR 97232

(503) 232-3667

Our Job Serial Number: SKS-2015008655

Ref: Clavero

Copyngit C 1992-2011 Dtbaa ServIces, Inc -Ptcncs Sevr’ Toolbox J6 41

F)LE

State of Oregon County of Multnomah Circuit Court

Attachment A

Case 3:15-cv-01541-MO Document 1-1 Filed 08/14/15 Page 8 of 15
_Verified Correct Copy of Original 7/24/201 5._

IN THE CIRCUIT COURT FOR THE STATE OF OREGON

FOR TIlE COUNTY OF MULTNOMA1I

BENNY CLAVERO, an individual, Case No. 15CV18181

Plaintiff,

v—. SUMMONS

UNDERWRITERS LABORATORIES, iNC., a foreign

nonprofit corporation, IlL VERIFICATION SERVICES,

iNC., a foreign corporation, IlL RESPONSIBLE SOURCING,

a foreign corporation, and IlL LLC., a foreign limited liability

company,

Defendants.

TO: Underwriters Laboratories, Inc.

IN THE NAME OF THE STATE OF OREGON: You are hereby required to appear and defend the complaint

filed against you in the above-entitled cause within 30 days from the date ofservice ofthis summons on you; and if

you fail to appear and defend, the plaintiffwill apply to the court for the relief demanded in the complaint.

NOTICE TO DEFENDANT:

READ THESE PAPERS CAREFULLY

You must “appear” in this case or the other side will win automatically. To “appear” you must file with the

court a legal paper called a “motion” or “answer.” The “motion” or “answer” must be given to the court clerk or

administrator within 30 days along with the required filing fee. It must be in proper form and have proof ofservice on

the plaintiffs attorney or, ifthe plaintiff does not have an attorney, proof ofservice on the plaintiff.

Ifyou have any questions, you should see an attorney immediately, If you need help in finding an

attorney, you may call the Oregon State Bar’s Lawyer Referral Service af(5O3) 684-3763 or toll-free in Oregon

at (800) 452-7636.

993WSB 37285

dschuckwageclaim.org -

Attorney for Plaintiff

10013 NE Hazel Dell Ave. #178

Vancouver, WA 98685 (360) 566-9243

STATE OF WASHINGTON, County of Clark) ss

I, the undersigned attorney ofrecord for the Plaintiff, certify that the foregoing is an exact and complete copy

ofthe original summons in the above entitled action.

DAVID A. SCHUCK, OSB 993564, WSB 37285

dschuckwageclaim.org

Attorney for Plaintiff

TO TUE OFFICER OR OTHER PERSON SERVING TIlLS SUMMONS: You are hereby directed to serve a

true copy ofthis summons, together with a true copy ofthe complaint mentioned therein, upon the individual(s) or

other legal entity(ies) to whom or which this summons is di e , and to mak ou roof ofservice on the reverse

hereof or upon a separate similar document which y attach ereto.

DAVID A. CK, 5 , SB 37285

dschuck@wageclaim.org

Attorney for Plaintiff

SCHUCK LAW, LLC —

Attorneys at Law

10013 NE Hazel Dell Avenue #178 Vancouver, WA 98685

Tel (360) 566-9243 • Fax (503) 575-2763

Attachment A

Case 3:15-cv-01541-MO Document 1-1 Filed 08/14/15 Page 9 of 15
_Veritied Correct Copy of Original 7/241201 5_

FILED

2015JLJL23 PI 28

AFFIDAVIT OF SERVICE ccuir c’

State of Oregon County of Multnomah CIrcuit Court

Case Number: 15CV18181

Plaintiff:

Benny Clavero,

vs

Defendant:

Underwriters Laboratories, Inc., et al.,

Received by RUSH PROCESS SERVICE, INC. to be served on UL, LLC do CT Corporation System,

Registered Agent, 388 State St., Suite 420, Salem, OR 97301.

I, Veronica T. Broeth, being duly sworn, depose and say that on the 16th day of July, 2015 at 3:25 pm, I:

Served the within named corporation by delivering a true copy of a Summons; Complaint; First Request for

Production of Documents by personal service upon Rylynn Poole, Service of Process Technician who is

authorized to accept service on behalf of the registered agent

I am a competent person 18 years of age or older and a resident of the state of service or this state and am not

a party to nor an officer, director or employee of, nor attorney for any party, corporate or otherwise; and the

person, firm, or corporation served is the identical one named in the action.

the 17th day

TARY PUBLIC

OFFICIAL SEAL

W LEAN 0 GREINER ij) NOTARY PUBLIC -OREGON

(f) COMMISSION NO. 475677

MYC0MMISION EXPIRE3 FEBRuARY 13.2017 — —.—.— I

Vs

JL

nica T. Broeth

Process Server

iQs,L

RUSH PROCESS SERVICE, INC.

2014 N.E. Sandy Blvd., Suite 204

Portland, OR 97232

(503) 232-3667

Our Job Serial Number: SKS-201 5008656

Ref: Clavem

CapyngM 5 1992-2011 Database Services, Lr -Process Serie?, Toolbox V5 44

Attachment A

Case 3:15-cv-01541-MO Document 1-1 Filed 08/14/15 Page 10 of 15
_Verifled Correct Copy of Original 7124/2015._

IN THE CIRCUFT COURT FOR ThE STATE OF OREGON

FOR THE COUNTY OF MULTNOMAH

BENNY CLAVERO, an individual, Case No. 15CV18181

Plaintiff,

v. SUMMONS

UNDERWRTIERS LABORATORIES, INC., a foreign

nonprofit corporation, UL VERIFICATION SERVICES,

INC., a foreign corporation, IJL RESPONSIBLE SOURCING,

a foreign corporation, and UL LLC., a foreign limited liability

company,

Defendants.

TO: ULLLC.

iN THE NAME OF THE STATE OF OREGON: You are hereby required to appear and defend the complaint

filed against you in the above-entitled cause within 30 days from the date ofservice ofthis summons on you; and if

you fail to appear and defend, the plaintiff will apply to the court for the relief demanded in the complaint.

NOTICE TO DEFENDANT:

REAl) THESE PAPERS CAREFULLY

You must “appear” in this case or the other side will win automatically. To “appear” you must file with the court a legal paper called a “motion” or caner. The “motion” or “answer” must be given to the court clerk or

administrator within 30 days along with the required filing fee. It must be in proper form and have proof ofservice on

the plaintiffs attorney or, ifthe plaintiff does not have an attorney, proof of service on the plaintiff.

Ifyou have any questions, you should see an attor immedi tely. If you need help in finding an

attorney, you may call the Oregon State Bar’s Lawyer R I Se e at (503) 684-3763 or toll-free in Oregon

at (800) 452-7636.

DAVID A. SCHUCK, OSB 993564, WSB 37285

dschuckwageclaim.org

Attorney for Plaintiff

10013 NE Hazel Dell Ave. #178

Vancouver, WA 98685 (360) 566-9243

STATE OF WASHINGTON, County of Clark) ss

I, the undersigned attorney ofrecord for the Plaintiff, certify that the foregoing is an exact and complete copy ofthe original summons in the above entitled action.

DAVID A. SCHUCK, OSB 993564, WSB 37285

dschuckwagec1aim.org

Attorney for Plaintiff

TO THE OFFICER OR OTHER PERSON SERVING THIS SUMMONS: You are hereby directed to serve a

true copy ofthis summons, together with a true copy ofthe complaint mentioned therein, upon the individual(s) or

other legal entity(ies) to whom or which this summons is direct , and to make your proof ofservice on the reverse hereof or upon a separate similar document

37285

dsehuckwageclaim.org

Attorney for Plaintiff

SCHUCK LAW, LLC

Attorneys at Law

10013 NE Hazel Dell Avenue #178 Vancouver, WA 98685

Tel (360) 566-9243 • Fax (503) 575-2763

Attachment A

Case 3:15-cv-01541-MO Document 1-1 Filed 08/14/15 Page 11 of 15
Verified Correct Copy of Original 7/24/2015.

F1LED

ZOI5JUL.23 Pt tt28

AFFIDAVIT OF SERVICE CJQC’iii;T C-•; rR

State of Oregon County of Multnomah Circuit Court

Case Number. 15CV18181

Plaintiff:

Benny Clavero,

vs.

Defendant:

Underwriters Laboratories, Inc., at at.,

Received by RUSH PROCESS SERVICE, INC. to be served on UL Responsible Sourcing, do Secretary of

State -Corp. Division, 255 Capitol St. NE, Salem, OR 97310.

I, Veronica T. Broeth, being duly sworn, depose and say that on the 16th day of July, 2015 at 3:45 pm, I:

SERVED the within named entity by delivering a true copy of the Summons; Complaint; First Request for

Production of Documents to Bob Broacek, PSR IV at the address stated above

Additional Information pertaining to this Service:

Follow up mailing was sent to: UL Responsible Sourcing 47173 Benicia St Fremont, CA 94538

I am a competent person 18 years of age or older and a resident of the state ofservice or this state and am not

a party to nor an officer, director or employee of, nor attorney for any party, corporate or otherwise, and the

person, firm, or corporation served is the identical one named in the action

Veroulica T. Broeth

6L

Process Server

RUSH PROCESS SERVICE, INC.

2014 N.E. Sandy Blvd., SuIte 204

Portland, OR 97232

(503) 232-3667

Our Job Serial Number: SKS-201 5008657

Ret: Clavero

Subscnbed an worn to befor the 20th day

NOTARY PUBLIC

MY COMMISSION

Ccpynglit 1992-2011 Dolthase Serwoa, Inc - Pmcess Servoi’s Toolbox V6 41

Attachment A

Case 3:15-cv-01541-MO Document 1-1 Filed 08/14/15 Page 12 of 15
Verified Correct Copy of Original 7/2412015._

IN THE CIRCUIT COURT FOR THE STATE OF OREGON

FOR THE COUNIW OF MIJLTNOMAH

BENNY CLAVERO, an individual, Case No. 15CV18181

Plaintiff,

v. SUMMONS

UNDERWRITERS LABORATORIES, INC., a foreign

nonprofit corporation, liE VERIFICATION SERVICES,

INC., a foreign corporation, IlL RESPONSIBLE SOURCING,

a foreign corporation, and IlL LLC., a foreign limited liability

company,

Defendants.

TO: IlL Responsible Sourcing

IN THE NAME OF TIlE STATE OF OREGON: You are hereby required to appear and defend the complaint

filed against you in the above-entitled cause within 30 days from the date ofservice ofthis summons on you; and if

you fail to appear and defend, the plaintiff will apply to the court for the relief demanded in the complaint.

NOTICE TO DEFENDANT:

READ THESE PAPERS CAREFULLY

You must “appear” in this case or the other side will win automatically. To “appear” you must file with the

court a legal paper called a “motion” or “answer.” The “motion” or “answer” must be given to the court clerk or

administrator within 30 days along with the required filing fee. It must be in proper form and have proof ofservice on

the plaintiffs attorney or, lithe plaintiff does not have an attorney, proof ofservice on the plaintiff.

If you have any questions, you should see an attorney immediately. Ifyou need help in finding an

attorney, you may call the Oregon State Bar’s Lawyer Ref ra Servi at (503) 684-3763 or toll-free in Oregon

at (800) 452-7636.

DAVID A. SCHUC 0 993564, WSB 37285

dschuckwageclaim.org

Attorney for Plaintiff

10013 NE Hazel Dell Ave. #178

Vancouver, WA 98685 (360) 566-9243

STATE OF WASR1NGTON, County of Clark) as

I, the undersigned attorney of record for the Plaintiff, certif’ that the foregoing is an exact and complete copy

ofthe original summons in the above entitled action.

DAVID A. SCHIJCK, OSB 993564, WSB 37285

dschuckwageclaini.org

Attorney for Plaintiff

TO THE OFFICER OR OTHER PERSON SERVING TIlTS SUMMONS: You are hereby directed to serve a

true copy ofthis summons together with a true copy ofthe complaint mentioned therein, upon the individual(s) or

other legal entity(ies) to whom or which this summons is direc , a d to make your proof ofservice on the reverse

hereof or upon a separate similar document which y all a oh reto.

D . CHUC 993564, WSB 37285

dschuckwageclaim.o

Attorney for Plaintiff

SCHUCK LAw, LLC

Attorneys at Law

10013 NE Hazel Dell Avenue #178 Vancouver, WA 98685

Tel (360) 566-9243 • Fax (503) 575-2763

Attachment A

Case 3:15-cv-01541-MO Document 1-1 Filed 08/14/15 Page 13 of 15
_Verified Correct Copy of Original 7/24/201 5._S

AFFIDAVIT OF SERVICE

20JjJL23 P442 8

‘(jR

State of Oregon County of Multnomah Circuit Court

Case Number: 15CV18181

Plaintiff:

Benny Clavero,

vs.

Defendant:

Underwriters Laboratories, Inc., ot al.,

Received by RUSH PROCESS SERVICE, INC. to be served on UL Verification Services, Inc. cia Secretary

of State - Corp. Division, 255 CapItol St NE, Salem, OR 97310.

I, Veronica T. Broeth, being duly sworn, depose and say that on the 16th day of July, 2015 at 3:45 pm, I:

SERVED the within named entity by delivenng a true copy of the Summons; Complaint; First Request for

Production of Documents to Bob Broucek, PSR IV at the address stated above.

Additional information pertaining to this Service:

Follow up mailing was sent to: UL Verification Services Inc. 47173 Benicia St. Fremont, CA 94538.

I am a competent person 18 years of age or older and a resident of the state of service or this state and am not

a party to nor an officer, director or employee of, nor attorney for any party, corporate or otherwise; and the

person, firm, or corporation served is the identical one named in the action.

ubscribed an worn to before me on e 20th day Veronica T. Broeth

f July. 15. Process Server

RUSH PROCESS SERVICE, INC.

NOTARY PUBLIC 2014 N.E. Sandy Blvd., Suite 204

Portland, OR 97232

LFAHDGREINER (503) 232-3667

NOTARY PUBLIC -OREGON YA

2017 Our Job Serial Number: SKS-2015008658

Cop,Tlght @ 1B92-201 I Dalabese Servis, Inc -Pmcess Sc,ve’s Tooib V 41

Attachment A

Case 3:15-cv-01541-MO Document 1-1 Filed 08/14/15 Page 14 of 15
_Verified Correct Copy of Original 7124/2015._

IN THE CIRCUIT DOURT FOR THE STATE OF OREGON

FOR THE COUNTY OF MULTNOMA}I

BENNY CLAVERO, an individual, Case No. 15CV18181

Plaintiff,

v. SUMMONS

UNDERWRiTERS LABORATORIES, INC., a foreign

nonprofit corporation, UL VERIF[CATION SERVICES,

INC., a foreign corporation, Ut RESPONSIBLE SOURCING,

a foreign corporation, and UL LLC., a foreign limited liability

company,

Defendants.

TO: UL Verification Services, Inc.

iN THE NAME OF THE STATE OF OREGON: You are hereby required to appear and defend the complaint

filed against you in the above-entitled cause within 30 days from the date ofservice ofthis summons on you; and if

you fail to appear and defend, the plaintiff will apply to the court for the relief demanded in the complaint.

NOTICE TO DEFENDANT:

READ THESE PAPERS CAREFULLY

You must “appear” in this case or the other side will win automatically. To “appear” you must file with the

court a legal paper called a “motion” or “answer.” The “motion” or “answer” must be given to the court clerk or

administrator within 30 days along with the required filing fee. It must be in proper form and have proof ofservice on

the plaintiff’s attorney or, ifthe plaintiff does not have an attorney, proof ofservice on the plaintiff.

If you have any questions, you should see an attorney immediately. If you need help in finding an

attorney, you may call the Oregon State Bar’s La r Refe a ervice at (503) 684-3763 or toll-free in Oregon

at (800) 452-7636.

DAVID A. SCHTiCK, B 993564, WSB 37285

dschuckwageclairn. rg

Attorney for Plaintiff

10013 NE Hazel Dell Ave. #178

Vancouver, WA 98685 (360) 566-9243

STATE OF WASHINGTON, County of Clark) ss

I, the undersigned attorney ofrecord for the Plaintiff, certify that the foregoing is an exact and complete copy

ofthe original summons in the above entitled action.

DAVID A. SCHTJCK, OSB 993564, WSB 37285

dschuck@wageclaim.org

Attorney for Plaintiff

TO THE OFFICER OR OTHER PERSON SERVING THIS SUMMONS: You are hereby directed to serve a

true copy ofthis summons, together with a true copy ofthe complaint mentioned therein, upon the individual(s) or

other legal entity(ies) to whom or whicb this summons is directed, and to make your proof ofservice on the reverse

hereof or upon a separate similar document which yoteto.

DA . HUCK,OSB99356’, B 37285

dschuckwagec1aim.org

Attorney for Plaintiff

SCIIUCK LAw, LLC

Attorneys at Law

10013 NE Hazel Dell Avenue #178 Vancouver, WA 98685

Tel (360) 566-9243 Fax (503) 575-2763

Attachment A

Case 3:15-cv-01541-MO Document 1-1 Filed 08/14/15 Page 15 of 15