DECLARATION OF DAN KALISH IN 

SUPPORT OF PLAINTIFF’S MOTION FOR 

PARTIAL SUMMARY JUDGMENT– 1

(No. 6:15-cv-01886-AA)

HKM Employment Attorneys LLP

308 SW First Avenue, Suite 325

Portland, OR 97204

(503) 389-1130

Daniel Kalish, OSB No. 111529

Shemia Fagan, OSB No. 093476

HKM EMPLOYMENT ATTORNEYS LLP

308 SW First Avenue, Suite 325

Portland, OR 97204

Telephone: (503) 389-1130

dkalish@hkm.com

sfagan@hkm.com

Jason A. Rittereiser, WSBA No. 43628 

(admitted pro hac vice)

HKM EMPLOYMENT ATTORNEYS LLP

600 Stewart Street, Suite 901

Seattle, WA 98101

Telephone: (206) 826-5358

jrittereiser@hkm.com

Of Attorneys for Plaintiff Coty Richardson

UNITED STATES DISTRICT COURT

DISTRICT OF OREGON

EUGENE DIVISION

COTY RICHARDSON,

Plaintiff,

vs.

NORTHWEST CHRISTIAN UNIVERSITY, 

an Oregon Corporation,

Defendant.

No. 6:15-cv-01886-AA

DECLARATION OF DANIEL KALISH 

IN SUPPORT OF PLAINTIFF’S 

MOTION FOR PARTIAL SUMMARY 

JUDGMENT
DECLARATION OF DAN KALISH IN 

SUPPORT OF PLAINTIFF’S MOTION FOR 

PARTIAL SUMMARY JUDGMENT– 2

(No. 6:15-cv-01886-AA)

HKM Employment Attorneys LLP

308 SW First Avenue, Suite 325

Portland, OR 97204

(503) 389-1130

1. I, Dan Kalish, represent the plaintiff Coty Richardson in the above-entitled 

action. I am over age of 18 and I am competent to testify about the matter stated herein.

2. Attached as Exhibit A are true and correct copies of various documents 

provided by defendant Northwest Christian University (“NCU”) in discovery.

3. Attached as Exhibit B is a true and correct copy of “Defendant’s Response to 

Plaintiff’s First Set of Interrogatories.”

4. Attached as Exhibit C is a true and correct copy of In the Matter of WAL-MART 

STORES EAST, INC. dba Wal-Mart, 22 BOLI 27 (July 13, 2001).

5. Attached as Exhibit D is a true and correct copy of portions of the Deposition of 

Dr. Heike McNeil taken on April 29, 2016.

6. Attached as Exhibit E is a true and correct copy of portions of the Deposition of 

Coty Richardson taken on April 25, 2016.

7. Attached as Exhibit F is a true and correct copy of portions of the Deposition of 

Dr. Joseph Womack taken on April 26, 2016.

8. Attached as Exhibit G is a true and correct copy of portions of the Deposition of 

Dr. Dennis Lindsay taken on April 28, 2016.

9. Attached as Exhibit H is a true and correct copy of portions of the Deposition of 

Gene De Young taken on April 27, 2016.
DECLARATION OF DAN KALISH IN 

SUPPORT OF PLAINTIFF’S MOTION FOR 

PARTIAL SUMMARY JUDGMENT– 3

(No. 6:15-cv-01886-AA)

HKM Employment Attorneys LLP

308 SW First Avenue, Suite 325

Portland, OR 97204

(503) 389-1130

I declare under penalty of perjury of the laws of the United States of America that the 

foregoing is true and correct.

Dated this 25th day of October, 2016 at Seattle, Washington.

s/Daniel Kalish

Daniel Kalish
DECLARATION OF DAN KALISH IN 

SUPPORT OF PLAINTIFF’S MOTION FOR 

PARTIAL SUMMARY JUDGMENT– 4

(No. 6:15-cv-01886-AA)

HKM Employment Attorneys LLP

308 SW First Avenue, Suite 325

Portland, OR 97204

(503) 389-1130

CERTIFICATE OF SERVICE

I hereby certify under penalty of perjury of the laws of the United States of America and 

the State of Oregon that on October 25, 2016, I electronically filed the foregoing document 

with the Clerk of the Court using the CM/ECF system which will send notification of such 

filing to the following: 

Dated this 25th day of October, 2016. 

s/Lara Flores

Lara Flores

Karen M. Vickers, OSB No. 913810

Blake H. Fry, OBS No. 100128

Mersereau Shannon LLP

One SW Columbia Street, Suite 1600

Portland, OR 97258

Telephone: 503-226-6400

Facsimile: 503-226-0383

Email: kvickers@mershanlaw.com

Email: bfry@mershanlaw.com

Attorneys for Defendant