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Timothy Barnes 

590 South Greenwood Rd. 

Independence, Oregon 97351 

503-585-9517 

FILED05Jl.}t'1515:22USDC1RP 

UNITED STATES DISTRICT COURT 

DISTRICT OF OREGON 

Timothy Barnes, an individual § 

Plaintiff, 

-vsRouth Crabtree Olsen, PC, 

John Thomas, OSB # 024691 

Janaya Carter, OSB # 032830 

Shayda Zaepoor Le, 

OSB # 121547 

Federal National Mortgage Association, 

Seterus, Inc., 

JOHN AND JANE DOES 1 - 10 

DEFENDANTS 

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3'15 CV-1001 

Case No.: 

TO THE HONORABLE UNITED STATES DISTRICT JUDGE 

I. Preliminary Statement 

Plaintiff ~~~~~~~~~~ brings this action against 

BR -:-

~~~~~~~~ 

, and John and Jane Does 

(collectively "Defendants") 

II. Parties 

Plaintiff Timothy Barnes, prose, 590 South Greenwood Rd., 

Independence, Oregon 97351 

Defendant Routh Crabtree Olsen, PC, 511 SW lOth Avenue, 

Suite 400, Portland, Oregon 97205 

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Defendant John M. Thomas, 511 SW lOth Avenue, Suite 400, 

Portland, Oregon 97205 

Defendant Janaya Carter, 511 SW lOth Avenue, Suite 400, 

Portland, Oregon 97205 

Defendant Shayda Zaepoor Le, 511 SW lOth Avenue, Suite 400, 

Portland, Oregon 97205 

Defendant Federal National Mortgage Association, 3900 

Wisconsin Avenue NW, Washington, DC 20016 (14221 Dallas 

Parkway, Suite 1000, Dallas, Texas 75254) and by serving 

the Oregon Secretary of State, 255 Capital Street NE, Suite 

151, Salem, Oregon 97310 

Defendant Seterus, Inc., f/k/a IBM Lender Business Process 

Services, Inc., 14523 Millikan Way, Suite 200, Beaverton, 

Oregon 97005, Afzal Assur, President, 8501 IBM Dr. Bldg. 

201, Suite 2DD 188, Charlotte, North Carolina 28262 and by 

serving its statutory agent CT Corporation System, 388 

State Street, Suite 420, Salem, Oregon 97301. 

Defendants John and Jane Does 

Jurisdiction/Venue 

This Court has Jurisdiction in this proceeding pursuant 

to 28 U.S.C. § 1331, pursuant to 15 U.S.C. § 1692k(d) for 

Fair Debt Collection Practices Act ("FDCPA") and pursuant 

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to 28 U.S.C. § 1367 for supplemental jurisdiction of 

Plaintiff's state law claims because Plaintiff's claims are 

so related to the claims within the court's original 

jurisdiction that they form part of the same case or 

controversy under Article 3 of the United States 

Constitution. The Court has authority to issue a 

declaratory judgment by virtue of 28 U.S.C. § 2201. Counts 

arising under contract, common law, and the law of 

conveyances in real property are properly asserted under 

this Court's pendent jurisdiction. 

Venue is proper in this district pursuant to 28 U.S.C. §§ 

1391 generally whereby the real property and a substantial 

part of the events and claims, the subject of this suit, 

are situated in this district. 

IV. Conditions Precedent 

All conditions precedent have been performed or have 

occurred 

VI. Statement of Facts 

1. Defendants violated federal and state law 

VI. Claims for Relief 

Count 1 - FDCPA 

1 . 

P~e3~4 
Count 2 - OREGON STATE LAW 

1. 

VII. Jury Trial Demand 

Pursuant to the seventh amendment to the Constitution of 

the United States of America, Plaintiff is entitled to, and 

hereby demands a trial by jury. 

VIII. Prayer for Relief 

WHEREFORE, as a result of the violations of the FDCPA 

Plaintiff prays for judgment against Defendants as follows: 

1. Statutory damages under federal law 

2. Statutory damages under state law 

3. Actual damages in an amount to be determined at 

trial 

4. Reasonable attorney fee 

5. For such other relief as the court may deem just 

and proper 

Dated: June 3, 2015 

By s:: -

Timothy Barnes 

590 South Greenwood Rd. 

Independence, Oregon 97351 

503-585-9517 

tim@westsidelandscape.com 

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